The Role of Public Comments on U.S. Workplace Injury Reporting Policy – UROP Symposium

The Role of Public Comments on U.S. Workplace Injury Reporting Policy

Isabella Gentry

Research Mentor: Devin Judge-Lord
Mentor Department: , Public Policy
Author(s): Isabella Gentry
Session: Session 7 (4:00 PM – 4:50 PM)
Presentation Type: Poster 30

Abstract

Despite widespread political and policy-related activist movements, research on the efficacy of these movements for policy change remains largely unknown. In particular, the impact of public comments from citizens and organizations on policy drafts is unclear. This study reviews hundreds of comments from individuals, trade associations, corporations, and government officials on OSHA’s Improve Tracking of Workplace Injuries and Illnesses rulemaking. The comments are categorized based on the requested changes made to the policy, as well as how closely the final draft honored these requests, if at all. An analysis of these comments in combination with the final draft of the policy showed that the majority of changes requested were not reflected in the final draft. These comments were largely from trade associations and involved concerns about the privacy of employee records, business confidentiality, and the costs of implementation, all of which were ignored in the final OSHA policy draft. These results potentially indicate that comments on policy drafts may not be an effective method in shaping final policy outcomes. The findings of this study align with results from the broader research project, which includes hundreds of rules and shows that comments that suggest the policy move in the opposite direction are less likely to be adopted than suggestions that push the agency to go further in the same direction.

lsa logoum logo