Health and Safety Information: EPA and OSHA Could Improve Their Processes for Preparing Communication Products
GAO-08-265
Published: Mar 31, 2008. Publicly Released: Apr 30, 2008.
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Highlights
Agencies address their missions not only through regulations but also by issuing communication products--such as guidance, fact sheets, and brochures--that can provide crucial information to regulated parties and the public. Since 2000, the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency's (EPA) Office of Prevention, Pesticides, and Toxic Substances (OPPTS) developed new versions of such products to address the potential hazards of exposure to asbestos in automotive brakes. GAO was asked to describe (1) how OSHA and OPPTS prepared their products on asbestos in automotive brakes, (2) the general processes that OSHA and OPPTS use to prepare their communication products, and (3) how these processes compare to those for rulemaking and how recent administration initiatives might affect them. GAO reviewed and analyzed available documents and interviewed officials at OSHA, OPPTS, and the Office of Management and Budget (OMB).
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Occupational Safety and Health Administration | The Assistant Secretary for OSHA and the Administrator of EPA should ensure that their key general policies and procedures for preparing communication products include, as appropriate, time frames or benchmarks to help ensure that products that the agencies have determined are needed are developed, reviewed, and disseminated in a timely manner. | As of May 2011, OSHA officials had identified policies, guidance and other actions taken by the agency that, in combination, addressed this recommendation. OSHA officials stated that, because of the diversity of its compliance assistance materials, the timelines for developing the materials vary. While some products may be developed quickly, circumstances and complexity may affect timelines for product development. OSHA stated that two guidance documents address the timeliness associated with the development and dissemination of compliance assistance products. ADM-03-00-004 (December 11, 2000) addresses the timing for clearances that specify a time period for all regions, National Office... Directorates, and Office to review and clear a compliance assistance product. Once the product has been cleared, OSHA Instruction IPC-01-00-006 (September 25, 2007) provides guidance on the dissemination of the compliance assistance products. OSHA Update (10/09): According to OSHA officials, the agency uses several methods to help ensure that a product is completed on a specific timeline. OSHA guidance projects are tracked on the Compliance Assistance Products Under Development database and each project is managed by the OSHA Directorate responsible for its completion. The directorates report to the OSHA Compliance Assistance Coordinating Group (CACG) on product development issues at CACG meetings. OSHA also prepares an annual Compliance Assistance Plan that include plans for product development during the upcoming fiscal year. Products included in the Compliance Assistance Plan are expected to be developed during the specific fiscal year. OSHA's Office of the Assistant Secretary will set deadlines for completion of certain time-sensitive products, such as pandemic influenza outreach materials. In addition, OSHA Instruction IPC-01-00-006 (Section X.F.) requires the originating Directorate/Office to put a product back through clearance if it has not cleared within 120 days. This helps ensure that cleared products include timely information and helps prevent "stale" products from being approved. However, regulatory projects and other agency priorities can affect timetables for completing guidance products. According to OSHA, the administration is now prioritizing standard setting, while pursuing meaningful guidance products. As a result, OSHA's Directorate of Standards and Guidance is redirecting resources to match this priority. Guidance product timelines will be affected by administration priorities. In 2011, OSHA implemented a process for reviewing its existing publications to ensure that they are accurate and reflect current agency policy. As an example of the implementation of this process, OSHA's Directorate of Cooperative and State Programs worked with the Directorate of Construction and the Office of Communications to establish a process for reviewing, and updating as necessary, OSHA's construction-related publications.
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| Environmental Protection Agency | The Assistant Secretary for OSHA and the Administrator of EPA should ensure that their key general policies and procedures for preparing communication products include, as appropriate, time frames or benchmarks to help ensure that products that the agencies have determined are needed are developed, reviewed, and disseminated in a timely manner. | As of March 27, 2012, EPA officials informed us that they believe they have appropriately responded to this recommendation. In their prior response, they essentially disagreed with our recommendation. EPA officials have previously stated that, while they agree that developing timely communication materials is important, the agency believes that it should be allowed the flexibility to divert its resources and to adjust its schedules from lower-priority projects to higher-priority projects when necessary. EPA also believes that the timeframes associated with the asbestos in brakes brochure was an "anomaly" and therefore, may not be a useful standard to compare with other cases. Finally,...
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| Environmental Protection Agency | The Assistant Secretary for OSHA and the Administrator of EPA should take steps to ensure that their key general policies and procedures for preparing communication products are fully documented. To the extent feasible, this should include identifying the applicable policies and procedures governing OMB/interagency coordination and reviews of such products, as well as any other key processes that the agencies believe are important to understanding how they prepare their products. |
EPA agreed with this recommendation and provided the documentation needed to show that the agency had implemented it. (Contact the Director for additional information.)
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| Environmental Protection Agency | The Assistant Secretary for OSHA and the Administrator of EPA should ensure that their agencies make public the key general policies and procedures for preparing communication products, including any updated in response to the previous recommendation. | EPA officials agree with the recommendation and on April 22, 2010, provided a link from the EPA web site that the agency says responds to this recommendation: http://www.epa.gov/productreview/archive/guide/index.html. This link refers to EPA's Policy and Implementation Guide for Communications Product Development and Approval that helps agency staff to "plan and create effective hardcopy and Web communications products. It provides a centralized approach to developing communications materials, as well as a database of communication materials planned for dissemination by the agency. This system is called the Product Review Tracking System (PROTRAC). A further update provide by EPA...
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| Environmental Protection Agency | The Administrator of EPA should consider adopting for OPPTS--and other EPA offices, as appropriate--a centralized database or databases to more completely account for the inventory of communication materials disseminated by the agency. | EPA agrees with this recommendation and has a centralized approach to developing communications materials, as well as a database of communication materials planned for dissemination by the agency. This system is called the Product Review Tracking System (PROTRAC). Individual program offices enter planned communications projects into the database and manage them through the clearance process, which is overseen by the Office of Public Affairs. On April 22, 2010, agency officials provided a link from the EPA web site that responds to this recommendation: http://www.epa.gov/productreview/archive/guide/index.html. This link refers to EPA's Policy and Implementation Guide for Communications...
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| Occupational Safety and Health Administration | The Assistant Secretary for OSHA should augment existing OSHA directives on the preparation of SHIBs and other communication products to provide more guidance to OSHA staff on developing a communications strategy during the product development process (for example, to identify who the agency needs to inform of the product, how notification and dissemination will be done, and who will be responsible for specific notification and dissemination tasks). | As of May 2011, OSHA officials had identified policies, guidance and other actions taken by the agency that, in combination, addressed this recommendation. OSHA officials stated that the agency supports the involvement of its Office of Communication (OC) in the development of a communications strategy for compliance assistance materials. In response to this recommendation and to improve coordination, OSHA expects that OC will work more closely with OSHA's Compliance Assistance Coordinating Group and the initiating office in planning, timing, and producing the product. OC would be able to recommend additional means of announcing the new material that may not be traditionally considered by...
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| Occupational Safety and Health Administration | The Assistant Secretary for OSHA and the Administrator of EPA should take steps to ensure that their key general policies and procedures for preparing communication products are fully documented. To the extent feasible, this should include identifying the applicable policies and procedures governing OMB/interagency coordination and reviews of such products, as well as any other key processes that the agencies believe are important to understanding how they prepare their products. | As of May 2011, OSHA officials had identified policies, guidance and other actions taken by the agency that, in combination, addressed this recommendation. OSHA stated that the agency believes that its policies and procedures for preparing compliance assistance materials are fully documented in a series of directives. OSHA instruction IPC 01-00-006 "Safety and Health Compliance Assistance Products" builds on and establishes the procedure for all offices of the agency to obtain approval to develop OSHA safety and health compliance products and the procedures for developing, clearing, distributing and maintaining approved compliance assistance products. Also, OSHA Instruction CPL 2.65A...
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| Occupational Safety and Health Administration | The Assistant Secretary for OSHA and the Administrator of EPA should ensure that their agencies make public the key general policies and procedures for preparing communication products, including any updated in response to the previous recommendation. |
OSHA agreed with this recommendation and provided the documentation needed to show that the agency had implemented it. (Contact the Director for additional information.)
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| Occupational Safety and Health Administration | The Assistant Secretary for OSHA should augment existing OSHA directives on the preparation of Safety and Health Information Bulletins (SHIB) and other communication products to prompt OSHA staff to identify opportunities to solicit input from external parties, as practical, during the preparation of communication products. | As of May 2011, OSHA officials had identified policies, guidance and other actions taken by the agency that, in combination, addressed this recommendation. According to OSHA officials, the agency obtains public input from external parties through the development of compliance assistance materials. Section X(E) in the OSHA Instruction "Safety and Health Compliance Assistance Products" discusses soliciting input from external parties. It specifically states that when appropriate, the originating office may seek review by entities outside the agency and names recognized experts, state or federal agencies, professional organizations, and OSHA cooperative program participants as possible...
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