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74-19,811
HARRIS, Ralph Laurence, 1927THE IMPACT OF THE OSHA ACT ON MICHIGAN FIRMS.
Michigan S tate U n iv e rs ity , P h .D ., 1974
Business Administration

U n iv e rs ity M icro film s, A XEROX Company , A n n A rb o r, M ic h ig a n

©

1974

RALPH LAURENCE H A R R IS

ALL RIGHTS RESERVED

I
I

THE IMPACT OF THE OSHA ACT
ON MICHIGAN FIRMS
By
Ralph L. Harris

A DISSERTATION
Submitted to
Michigan State U n iversity
in p a r t ia l f u l f i l l m e n t o f the requirements
fo r the degree o f
DOCTOR OF PHILOSOPHY
Department of Management
1974

ABSTRACT

THE IMPACT OF THE OSHA ACT
or; M IC H IG A N FIRMS
By
Ralph L. Harris

In 1969, the Congress of the United States passed the
W illiam s-S teiger Occupational Safety and Health Act (Public Law
91-956) which became e f fe c tiv e in May, 1970.

I t was an tic ip a te d

that the OSHA A ct, as the law was c a lle d , would cause almost every
businessman to make s ig n ific a n t adjustments in order to comply with
it.

I t provided a pervasive and coordinated national safety program

for occupational safety and health ful working conditions, and
established minimum consensus standards, and r ig id enforcement and
monitoring procedures.
required.

Accurate safety and health records were

Employees were guaranteed to be kept informed o f company

safety a c t i v i t y , and opportunity to p a r tic ip a te in s e ttin g standards
and to express re lated "grievances11 d i r e c t l y to OSHA o f fic e s .
V i r t u a l l y every company was covered regardless of size.

Only gov­

ernmental units and t h e i r agencies were outside the act.
The purpose o f th is study was to examine the e a rly years of
the OSHA Act in terms o f the impact upon representative firms in the
state o f Michigan.
uncovered l i t t l e

An extensive review o f e x is tin g l i t e r a t u r e

systematic research on the subject.

I t was f e l t

Ralph L. H a rris

th at such description and analysis would provide some in s ig h t into
the probable effectiveness o f the act fo r accomplishment o f i t s
purpose and other possible re lated e ffe c ts on the organizations.
In order to provide a perspective o f why the OSHA Act was so
sweeping, the h is to r ic a l background was examined.

S o c ia l, p o l i t i c a l ,

and economic considerations were discussed in the context of occupa­
tion al safety and h e a lth , in addition to a t t it u d in a l changes,
s t a t is t i c a l comparisons, and governmental a c t i v i t i e s .

There was

also a review o f the l i t e r a t u r e appropriate to the eleven general
areas o f management p rac tice selected fo r study to provide th e o re tic a l
background.
A sample o f 49 firms in the state o f Michigan was used f o r
th is study.

The data were co llected through personal interviews with

various representatives of individual firms using a questionnaire
guide.
The 49 firms were grouped fo r analysis on the basis o f four
c h a ra c te ris tic s th at i t was f e l t might a f f e c t the impact o f the act
on them:
1.

company size in terms o f number o f employees,

2.

in ju r y frequency r a t e ,

3.

type o f o rg an iza tio n , i . e . , "under one ro o f," cor­
porate o f f ic e with plants on the premises, and
d ivision s o f m u lt i-n la n t operations, and

4.

firms targeted by OSHA fo r special a tte n tio n and
inspection due to t h e i r above average in ju ry
frequency r a te .

The major findings in the eleven general areas o f the study
can be summarized as follows:

Ralph L. Harris
1.

Adm inistrative R e sp o n s ib ility and Functional Alignment:

Designated positions or functions responsible fo r safety increased in
number and scope.

There were more f u l l - t i m e safety managers, la rg e r

safety s t a f f s , new safety t i t l e s and p ositions, a lte re d reporting
procedures, and a greater incidence and amount of time spent on
safety.

More people in more jobs were involved in s a fe ty , and there

was increasin gly shared r e s p o n s ib ilit y , p r in c ip a lly among production/
technical positions.

When the personnel department p a rtic ip a te d , i t

was p rim a rily fo r record keeping purposes, although in 75 percent
o f the firms with over 1,000 employees, the safety responsible per­
son reported to the head o f personnel.
2.

Functional Duties o f Safety Designated Persons:

There

were new and increased safety d u tie s , record keeping, p olicy s ta te ­
ments, inspections, safety committee a c t i v i t i e s , cross-referencing
or c la r if y in g OSHA standards, s a fe ty presentations, and tra in in g new
hires in safety work procedures.

In a d d itio n , there were new and

increased budgets for s a fe ty , and a greater tendency fo r requests fo r
funds fo r compliance to the act to be rubber stamped.
3.

Status o f the Safety Function:

Prestige o f the safety

function had been upgraded regardless o f firm s iz e , in ju r y frequency
r a te , organization s tru c tu re , or whether or not the firms were OSHA
targeted.

Firms with under 50 employees were le a s t l i k e l y to show th is

improved status.
4.

Safety Committees:

There were more safety committees, and

those th at had already existed were more form al, re g u la rly scheduled,
included more people, with a broader cross section of functional
r e s p o n s ib ilit ie s , and involved new and expanded a c t i v i t i e s .

There was

Ralph L. H a rris

increased p a rtic ip a tio n by employees, union represen tatives, and
maintenance, plant engineering, and supervision departments.
5.

Procedures, Rules, and Inspections:

Special control and

preventive procedures, inspections and c h e c k lis ts , re p o rts , meetings,
policy statements, safety ru le s , and o rie n ta tio n had been increased
in number and had become more sophisticated.
6.

Awareness, Degree o f Comprehension, and Responsiveness:

Most firms were aware of the OSHA Act.

Management, employees, and

the union professed favorable a ttitu d e s and appeared to take the pro­
visions se rio u s ly , and there was l i t t l e resistan ce, defensiveness, or
production-versus-safety c o n f l i c t .
7.

Investment in Safety:

or Protective Item s:

Appropriations, Equipment, Devices,

There was considerable new or increased in v es t­

ment fo r s a fe ty -re la te d ca p ita l equipment, sa fety devices, personal
pro tective items, plant safety improvements involving a i s le s , la y o u t,
ladders, f i r e equipment, e t c . , and in some cases, a lt e r a t io n o f manu­
facturin g operations.

However, about tw o-thirds o f the firms with

under 1,000 employees spent less than $5,000.
8.

Communication:

Training and P u b l i c i t y :

There were new,

more formal and broader tra in in g and p u b lic ity programs:

committee

p a r tic ip a tio n , safety meetings, seminars, and in -p la n t classes.
Although more people and positions were involved, these were generally
on the management le v e l.

There was also g reater re lia n c e on assistance

from sources external to the firm s.
9.

Union Involvement:

There was new and g reater safety pub­

l i c i t y and o rie n ta tio n fo r union stewards, monitoring of employer
safety a c t i v i t i e s , requests fo r safety clauses in the c o lle c tiv e

Ralph L. H a rri

bargaining agreement, and p a rtic ip a tio n in company safety committees.
However, only 25 percent had membership-oriented safety programs, and
there were some responses in the form o f OSHA-related s t r ik e s ,
grievances, malingering, and other pressures or a g it a t io n .
10.

A ttitu d e Toward Excluding Small Businesses From the A c t:

Every firm but one, regardless o f s iz e , in ju ry frequency r a t e , organi
zation s tru c tu re , or whether or not targeted by OSHA, f e l t small
businesses should not receive special exemptions from the act and
should be forced to comply.
11.
Compliance:

Management A ttitu d e Toward OSHA Standards and Required
There was evidence th a t management lacked f u l l under­

standing and had doubts as to the appropriateness and consistency o f
OSHA standards.

However, there was general acceptance o f the act and

appreciation fo r the long-run b e n e fits , with no s ig n ific a n t evidence
th a t firms were provoked, or th a t they feared OSHA inspections or
compliance requirements.
I t can be concluded on the basis of the re s u lts o f the study
th a t the OSHA Act had s ig n ific a n t impact on the firms surveyed; th is
was true in each o f the eleven areas examined.

In a d d itio n , the

four variables analyzed influenced the nature and extent o f th is
responsiveness.

Small firms with under 50 employees and those

targeted by OSHA reacted m inim ally; those organizations of moderate
size (50-1,000) and under a single roof made s ig n ific a n t adjustments.
Firms with e ith e r high or low in ju ry frequency rates had both the
most and the le a s t changes, depending upon the area studied.

ACKNOWLEDGMENTS

This manuscript represents the f i n a l step in f u l f i l l i n g the
requirements necessary f o r a Doctor o f Philosophy Degree in the
Department of Management at Michigan State U n iv e rs ity .

A fte r some

twenty years in in d ustry, the task was arduous, challen g in g, and
most rewarding.

As can be appreciated, however, the e n t ir e process

could not have been achieved without s ig n if ic a n t personal contribu­
tions by many in d iv id u a ls .
My sincere appreciation goes to three members of industry
who provided background inform ation, factual d ata, and made themselves
a v a ila b le fo r guidance and consultation on a great number of occa­
sions.

These include Mr. LaBart (Skip) M u e lle r, D ir e c to r , Safety and

Plant Production, Excello Corporation; Mr. Bruce Podzius, Safety
D ire c to r, D e tro it D ie s e l-A l1ison D iv is io n , General Motors Corpora­
tio n ; and Mr. V ic to r G irolam i, President, Michigan In d u s tria l Shoe
Company.

My special thanks in p a r tic u la r go to Mr. V icto r G irolam i,

my very close frie n d and neighbor, fo r countless meetings during
evenings and on weekends.
I am very g rate fu l to my d is s e rta tio n guidance committee at
Michigan State U niversity fo r t h e i r valued c o n trib u tio n s.

Dr. George

Vandusen, Assistant Dean o f the College of Engineering, provided
considerable expertise in organization and content, as well as the
encouragement necessary fo r th is manuscript.

ii

Dr. Thomas H. Patten,

Associate D ire c to r, School o f Labor and In d u s tria l R elations, f u r ­
nished and suggested source m aterials and provided professional
counsel.

I am extremely g ra te fu l and indebted to Dr. R o llin H.

Simonds, Professor o f Management and chairman o f the d is s e rta tio n
committee, fo r his expert advice, assistance, and in t e r e s t .

His

d iscretion and supervision guided the p ro ject to a successful com­
p le tio n .

pr. Simonds was one o f the major influences in my decision

to turn to a career in the academia.
My special thanks also go to Mrs. Anna Brown, my former
secretary a t Chrysler Corporation, fo r her dogged determination in
typ ing , co rre c tin g , and e d itin g th is manuscript.
Patience, empathy, and lo y a lty are the c h a ra c te ris tic s which
best describe my w if e , Joan.

Not only did she support me during my

scholastic ca re er, but she did everything from proofreading th is
d is s e rta tio n , to being a temporary fa th e r -s u b s titu te fo r our
c h ild re n , Stephen, Susan, and Catherine.

TABLE OF CONTENTS

Page
LIST OF TABLES............................................................................................................v i i i
Chapter
I.

II.

III.

INTRODUCTION ..........................................................................................

1

Discussion ..........................................................................................
Nature o f the P r o b l e m ................................................................
Purpose of the S t u d y ................................................................
Summary..............................................................• ............................

1
3
10
12

THE HISTORICAL BACKGROUND FOR THE OSHA A C T ..........................

13

Introduction
...................................................................................
Prelude to the Safety Movement .............................................
The Safety Movement......................................................................
Management-Engineering Approach .......................................
Human-Relations Approach
...................................................
Labor-Management Cooperation .............................................
S u m m a ry ..........................................................................................
Government Contributions
..........................................................
In d u s tria l Hygiene Movement ...................................................
Workmen's Compensation ................................................................
Recent Pressures Leading to the OSHA A c t ..........................
Summary................................................................................................

13
14
16
19
20
21
21
22
26
28
31
43

REVIEW OF THE PERTINENT L IT E R A T U R E .......................................

45

Introduction ...................................................................................
Basic Safety Philosophy as Related to the OSHA Act
.
Adm inistrative R esp on sib ility and Functional
A l i g n m e n t ...................................................................................
Personnel or In d u s tria l Relations
................................
Safety D ire cto r
.......................................................................
Safety Committees ......................................................................
Record Keeping .............................................................................
Counseling and Advising ..........................................................
In s p e c t io n s ...................................................................................
Enforcement of Safety Rules and D is c ip lin e
. . .
P u r c h a s i n g ...................................................................................

45
46

iv

48
50
53
55
59
63
64
66
68

Chapter

IV.

Page

Safety Equipment, Devices, or P ro tective Items . . .
Guarding and Safety Equipment .............................................
Personal P rotective Equipment .............................................
Plant Layout and D e s i g n ..........................................................
Training and Communication
...................................................
The People Involved in Safety Training ..........................
Training Techniques ................................................................
Safety Communication and Promotion ................................
Help From Outside S o u r c e s ...................................................
Union P a rtic ip a tio n in Safety Programs
..........................
Implications of Firm Size Upon S a f e t y ................................
Summary................................................................................................

69
70
72
73
73
75
77
79
83
84
87
92

DESIGN OF THE S T U D Y .......................................................................

94

Introduction ...................................................................................
94
Population Sample
......................................................................
94
Experimental Grouping ................................................................
95
Firm S i z e ...................................................................................
96
In ju ry Frequency R a t e .............................................
97
Operations Under "Single Roof" or M u lti-P la n t
.
.
98
Firms "Targeted" fo r Special OSHA A tte n tio n
. . .
98
Data C ollection and Interview Guide
................................
100
P i l o t Study and Other Confirmation .......................................
101
102
S t a t i s t i c a l Technique ................................................................
L im itations o f the S t u d y ................................................................. 103
Summary........................................................................................................104
V.

STUDY F IN D IN G S ...........................................................................................105
Introduction
...................................................................................
105
A d m inistrative Responsibility and Functional
A l i g n m e n t ...............................................................
105
Firm S i z e ...........................................................................................106
In ju ry Frequency R a t e ..................................................... 112
Under Single Roof, D iv is io n , or M u lti-P la n t
O p e r a t io n ...........................................................................................117
Firms Targeted f o r OSHA I n s p e c t i o n ........................................123
Functional Duties
......................................................................
126
Firm S i z e ...........................................................................................126
In ju ry Frequency R a t e ................................................................. 132
Urder Single Roof, D iv is io n , or M u lti-P la n t
O p e r a t io n ...........................................................................................138
Firms Targeted fo r OSHA I n s p e c t i o n ........................................143
Status o f the Safety F u n c t i o n .....................................................145
Safety Committees
.......................................................................
148
Firm Size: Table V - 3 4 ................................................................. 148
In ju ry Frequency Rate: Table V-36
150

v

Chapter

Page

Under Single Roof, D iv is io n , or M u lti-P Ia n t
Operation: Table V - 3 8 ........................................................... 153
Firms Targeted fo r OSHA Inspection: Table V-39 .
.
155
Procedures, Rules, and Inspections ..........................................
155
Firm Size: Table V - 4 0 ................................................................. 157
In ju ry Frequency Rate: Table V-41
Under Single Roof, D iv is io n , or M u lti-P Ia n t
Operation: Table V - 4 2 ........................................................... 159
Firms Targeted fo r OSHA Inspection: Table V-43 .
.
162
Awareness, Degree o f Comprehension, and Responsive­
ness to OSHA R e g u l a t i o n s ...........................................................164
Firm S i z e ...........................................................................................164
In ju ry Frequency R a t e ................................................................. 170
Under Single Roof, D iv is io n , or M u lti-P la n t
O p e r a t i o n s .................................................................................... 175
Firms Targeted fo r OSHA Inspection: Tables V-56
V - 5 7 ................................................................................................. 183
Investment in Safety: Appropriations, Equipment,
Devices, or P ro tective Items .............................................
187
Appropriations to Comply with OSHA: Table V-60 .
.
187
E ffe c t on Purchasing Policy: Table V-61
. . . .
190
Type o f Safety Investment: Table V-62 . .
.
.' .
192
Safety Equipment: Table V-63 .............................................
194
Personal P ro tec tive Equipment: Table V-64
.
.
.
194
F a c i l i t y Changes: Table V-65 .............................................
199
Communication: Training and P u b lic ity
..........................
201
Meetings and Committees: Table V-66
201
Formal In s tru c tio n : Table V-67
203
Type o f Training V ehicle: Table V-68
203
People Involved in Training Exposure: Table V-69 .
206
General Purpose o f T rain in g :
Table V-70 . . . .
208
Supplementary Training Programs: Table V -71 .
.
. 208
Help From Outside Sources: Table V - 7 2 ................................. 211
Union Involvement and S p ec ific A c t iv i t i e s
. . . .
214
A ttitu d e : Table V - 7 3 ................................................................. 214
P o sitive A c t i v i t i e s : Table V - 7 4 .............................................. 214
Negative Response: Table V-75
217
A ttitu d e Toward Excluding Small Businesses From
the A c t ................................................................................................. 219
Management A ttitu d e Toward OSHA Standards and
Required Compliance ................................................................
221
Standards: Table V-77
221
A ttitu d e Toward Safety O rien tatio n o f the Act:
Table V-78
224
General Reaction to the OSHA Act: Table V-79
. .
226
Misgivings About OSHA: Table V-80
................................
228

vi

159

Chapter

V I.

Page

SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS

..........................

231

Summary........................................................................................................231
A dm inistrative R esponsibility and Functional
A lig n m e n t...........................................................................................234
Functional Duties o f Safety Designated Persons . .
235
Status of the Safety F u n c t io n .................................................... 237
Safety Committees .......................................................................
237
Procedures, Rules, and Inspections
................................
238
Awareness, Degree o f Comprehension, and
Responsiveness .......................................................................
239
Investment in Safety: Appropriations, Equipment,
Devices, or P ro te c tiv e Items
.......................................
240
242
Communication: T raining and P u b lic ity ..........................
Union Involvement .
243
A ttitu d e Toward Excluding Small Businesses From
the A c t ...........................................................................................244
Management A ttitu d e Toward OSHA Standards and
Required Compliance
..........................................................
244
C o n c l u s i o n s ...........................................................................................245
Recommendations .............................................................................
248
APPENDICES

................................................................................................. 251

A.

SYNOPSIS;

B.

QUESTIONNAIRE AND INTERVIEW GUIDE .............................................

BIBLIOGRAPHY

THE ACT AND ITS ADMINISTRATION................................. 252

.......................................................................................................

vi i

264
282

LIST OF TABLES

Table

Page
................................

97

................................................................

99

IV -1 .

In ju ry Frequency Rate o f Firms Studied

IV -2 .

Targeted Firms Studied

IV -3.

T i t l e and Number of Persons P a rtic ip a tin g in the
I n t e r v i e w ................................................................................................. 101

V -l.

Responsible Position fo r Safety

.............................................

107

V-2.

Shared Safety R e sp o n s ib ility

...................................................

108

V-3.

S t a f f in g , T i t l e s , Time Devoted to Safety

V-4.

Reporting Procedure and Role o f P e r s o n n e l ................................... I l l

V-5.

Responsible Position fo r Safety

V-6.

Shared Safety R esp on sib ility

V-7.

S t a f f in g , T i t l e s , Time Devoted to Safety

V-8.

Reporting Procedure and Role o f P e r s o n n e l .................................118

V-9.

Responsible Position fo r Safety

...........................

110

.............................................

113

...................................................

114

.........................

116

.............................................

120

...................................................

120

V-10.

Shared Safety R e sp o n s ib ility

V - l 1.

S t a f f in g , T i t l e s , Time Devoted to Safety

V-12.

Reporting Procedure and Role o f P e r s o n n e l ...................................123

V - l 3.

Responsible Position fo r Safety

V-14.

Shared Safety R esp on sib ility

V-15.

S t a f f in g , T i t l e s , Time Devoted to Safety

V -16.

Reporting Procedure and Role of P e r s o n n e l ................................ 126

V-17.

Duties o f Safety Responsible Person

V - l 8.

Safety Expenditures

.

.

.

.

.

122

............................................

124

...................................................

124

.........................

125

......................................

128

.....................................................................

129

v iii

Table

Page

V - l 9.

Purchase o f Safety I t e m s .........................................................................131

V-20.

New D u t i e s .................................................................................................131

V-21.

Duties o f Safety Responsible Person

V -22.

Safety Expenditures

V-23.

Purchase of Safety I t e m s ........................................................................ 136

V-24.

New D u t i e s ................................................................................................ 137

.......................................

133

........................................................................

135

V-25.

Duties of Safety Responsible Person

.......................................

139

V -26.

Safety Expenditures

........................................................................

141

V-27.

Purchase o f Safety I t e m s ........................................................................ 142

V-28.

New D u t i e s .................................................................................................142

V-29.

Duties o f Safety Responsible

V-30.

Safety Expenditures

Person

.......................................

144

........................................................................

144

V-31.

Purchase o f Safety I t e m s ........................................................................ 146

V-32.

New D u t i e s ................................................................................................ 146

V-33.

Status o f th e .S a fe ty Function

V-34.

Safety Committee P a rticip a n ts

...................................................

147

.....................................................

149

V-35.

Safety Committee Purpose .................................................................

150

V-36.

Safety Committee P a rtic ip a n ts

.....................................................

151

V -37.

Safety Committee Purpose .................................................................

152

V-38.

Safety Committee P a rtic ip a n ts and Purpose

...........................

154

V-39.

Safety Committee P a rticip a n ts and Purpose

...........................

156

V-40.

Coordination and C o n t r o l .........................................................................158

V -41.

Coordination and C o n t r o l .........................................................................160

V-42.

Coordination and C o n t r o l ......................................................................... 161

V-43.

Coordination and C o n t r o l ......................................................................... 163
ix

Table

Page

V-44.

Awareness, Comprehension, andA ttitu d e

V-45.

A ttitu d e and S e rio u s n e s s .........................................................................168

V-46.

Involvement and Resistance

...........................................................

169

V-47.

Safety Versus Production .................................................................

171

V-48.

Awareness, Comprehension, andA ttitu d e

172

V-49.

A ttitu d e and S e rio u s n e s s .........................................................................174

V-50.

Involvement and Resistance

...........................................................

176

V-51.

Safety Versus Production .................................................................

177

V-52.

Awareness, Comprehension, andA ttitu d e

179

V-53.

A ttitu d e and S e rio u s n e s s ........................................................................ 180

V-54.

Involvement and Resistance

...........................................................

182

V-55.

Safety Versus Production .................................................................

183

V-56.

Awareness, Comprehension, andA ttitu d e

184

V-57.

A ttitu d e and S e rio u s n e s s .........................................................................185

V-58.

Involvement and Resistance

...........................................................

186

V-59.

Safety Versus Production .................................................................

187

V-60.

Investment to Comply with OSHA............................................................ 188

V-61.

E ffe c t on Purchasing Policy ...........................................................

V-62.

Type of Safety I n v e s t m e n t .................................................................. 193

V-63.

Safety Equipment

V-64.

Personal P ro tective Equipment

....................................................

196

V-65.

F a c i l i t y and Equipment Changes ....................................................

200

V-66.

Meetings and C o m m it t e e s .........................................................................202

V-67.

Formal In s tru c tio n ..............................................................................

V-68.

Type o f Training V e h i c l e .........................................................................205

...................................

....................................

...................................

...................................

..............................................................................

x

165

191

195

204

Page
People Involved in T raining Exposure ..........................

207

General Purpose o f Training .............................................

209

Supplementary T raining Programs

................................

210

.............................................

212

................................................................

215

Help From Outside Agencies
Union Involvement

Union Involvement, P o sitiv e A c t iv i t i e s

216

.

Union Involvement, Negative Response ..........................

218

Inclusion of Small Businesses

220

.......................................

Management A ttitu d e Toward OSHA Standards
Management A ttitu d e Toward Safety O rie n ta tio n

222

.

225

General Reaction to the Act .............................................

227

Misgivings About OSHA ..........................................................

22y

xi

CHAPTER I

INTRODUCTION
Discussion
This was a study to determine how re p resen tative business
firms in the s ta te of Michigan have responded to the W illiam sSteiger Occupational Safety and Health Act o f 1970 (Public Law
91-956).

I t attempted to summarize in a general manner some o f the

s p e c ific changes, adjustments, or new programs and a c t i v i t i e s re lated
to in d u s tria l safety and health th a t may have occurred in whole or
part because of the law.
The OSHA Act, as the law is now c a lle d , represents the most
sweeping, comprehensive, and concerted approach to occupational
safety and health in h is to ry .

Congressman W illiam A. S teig er

(Wisconsin), one of the co-sponsors o f the a c t , indicated to the
National Safety Congress in November, 1972, th a t he f e l t the act was
so revolutionary th a t the ra m ifica tio n s would be profound fo r many
years to come, p rim a rily because i t was the le a s t understood, most
tec h n ic a l, most complex, most thorough, and most exposed o f the
regulatory e f f o r t s o f big government.^
I t may be years before the m a tu rity o f the act permits
measurement of i t s f u l l impact on worker w e ll-b e in g , s a f e ty -s e c u r it y ,
^ a c k R. Nicholas, J r . , "OSHA, Big Government and Small
Business," MSU Business Topics (W in ter, 1973), p. 57.

2

a ttitu d e and awareness o f s a fe ty , working co nditions, and hard
"quantitative" yardsticks such as in ju r y frequency and s e v e rity
rates and re la te d costs can be meaningfully measured.

Current a tte n ­

tion focused upon safety and health standards, s p e c ific compliance
procedures, and equipment or "devices" required.

The number o f

inspections, types o f c i t a t i o n s , and number and size o f fin es were
examined in d e t a i l , but r e l a t i v e l y l i t t l e was r e a l l y known about the
manner in which firms have responded to the act.
There was a real need, however, fo r prompt and continuous
feedback of the impact o f the act upon actual business operations.
The act was so comprehensive and d if f e r e n t th a t there were dramatic
and almost d a ily changes in the law, i t s in t e r p r e t a t io n , and imple­
mentation.

Immediate p re s c rip tiv e y a r d s tic k s , ta r g e ts , and programs

were v it a l to provide p ra c tic a l methods of a llo c a tin g p r i o r i t i e s .
In a d d itio n , f u l l compliance to the requirements of the law was
necessary by 1975 in order to avert severe p e n a ltie s , lengthy work
in te rru p tio n s , or even stopping operations e n t i r e l y .

This involved

substantial immediate investments in e f f o r t , in g e n u ity , and money.
The amount of lead time fo r meaningful response was both urgent and
c ritic a l.
This type of information is also valuable to the business­
man fo r long-range planning.

I t provides awareness and impetus

to develop an a c tiv e and coordinated program to improve occupa­
tional safety and h e a lth fu l working conditions.

Individual

functions o f an organization must be analyzed and restructed where
necessary in terms of the fu tu re .

Management decisions should,

3

th e re fo re , r e la t e to goals, p r i o r i t i e s , p r o f i t s , work r e la tio n s h ip s ,
and c a p it a liz a t io n in terms of r e a l i s t i c compliance to the a c t.
In sh o rt, the OSHA Act w i l l necessitate operational changes
by businessmen, and there was l i t t l e

p ra c tic a l knowledge o f how firms

are c u rre n tly responding to the requirements o f the a c t to guide
them.

I t was from th is frame o f reference th a t th is study was con­

ducted.
Nature o f the Problem
The ra m ific a tio n s o f the OSHA Act were both impressive and
fa r reaching, and w i l l continue to increase s i g n i f i c a n t l y fo r years to
come.

From a broad perspective, the act provided a cornerstone,

foundation, or framework fo r a fre s h , pervasive, and coordinated
national program fo r occupational safety and h e a lth fu l working condi­
tion s.

I t furnished necessary in s tru m e n ta lity to tac kle some of

the more s a lie n t and obdurate obstacles.

I t supplied stimulus fo r

p ositive implementation o f the a c t i v i t i e s necessary to meet the
l e t t e r and the in te n t o f such a program.
More s p e c i f i c a l l y , the law established minimum national
safety and health standards, as w ell as the means by which to
enforce them.

I t also set up the "machinery" to research, form ulate,

c o d ify , and promulgate improved or supplementary standards, to
o u tlin e both employer and employee responsibi1i t y , to generate record
keeping yardsticks f o r feedback and c o n tro l, and to develop a basis
fo r safety education and t r a in in g .
government and business cooperation.

Provisions were made fo r i n t e r ­
Most im portant, a procedure

was sp ecified by which sta te enforced programs with s ta tu to ry

4

minimums can be i n s t i t u t e d .

A d e ta ile d synopsis of some o f the

major features is provided in Appendix A.
E s s e n t ia lly , the provisions and concepts expressed in the
OSHA Act were not r e a l l y new or o r i g i n a l .

The s a fe ty and health

stnadards were l i t e r a l l y the fe d e ra l and consensus standards which
existed before the a c t.

The need f o r minimum standards, enforcement,

inspectio n, documentation, employer and employee r e s p o n s ib i li t y , and
sta te p a r tic ip a t io n had long been recognized.

But what was new, was

(1) the actual existence o f a fed eral law per s e , and the in te g r a tio n
of many sa fe ty and health concepts in to a sin g le workable and mean­
ingful program, (2) r e a l i s t i c s ta te p a r t i c i p a t i o n , (3 ) the r e v i t a l i z a ­
tion o f the s a fe ty movement to cope w ith the problems or challenges
created as a consequence o f the law , and (4 ) the emphasis upon s a fe ty
oriented management technique.

As the fo llo w in g examples in d ic a te d ,

c o l le c t i v e l y they made the OSHA Act a s i g n i f i c a n t , i f not a ra d ic a l
departure from what had become more or less a conservative approach
to sa fety and health in the work environment.
As noted by the Bureau o f National A f f a i r s , the OSHA Act
created, fo r the f i r s t time under a fed eral law , a major and
a c tiv e ro le f o r the government in the area o f occupational sa fe ty
and h ealth .

Previously such a c t i v i t y consisted of s t a t i s t i c a l and

advisory s e rv ic e s , and voluntary standards.

Federal s a fe ty l e g i s l a ­

tion was lim ite d to c e r ta in in d u s trie s covered by fed eral law such
as r a i lr o a d , mining and t e x t i l e , and p ro te c tiv e lab o r laws,
including minimum wages , maximum hours, and age l i m i t a t i o n s .

With

the OSHA Act, Congress expressed ta n g ib le and legal concern fo r

5

individual protection and w elfare and, in a d d itio n , provided fo r
2
related research, in fo rm ation , and education and t r a in in g .
This
and local impetus were necessary fo r both the public and p riv a te
sectors to address themselves in concert to programs r e la t in g to
healthful working conditions and occupational s a fe ty .
State p a r tic ip a tio n in occupational safety and health had
increased in scope, content, and meaningful ness.

One o f the major

provisions of the OSHA Act was th a t s ta te governments were per-’
mitted to develop, ad m in ister, and enforce t h e i r own in d ivid u al
occupational sa fety and health program, providing however, th a t such
plans met or exceeded the federal standards, received federal
approval, and th a t they were clo sely monitored fo r a period o f three
years.

Every sta te had subsequently submitted such a proposal fo r

approval.
accrue.

In e f f e c t , there were two p rin c ip a l advantages which could
F i r s t , lik e the federal law, th is requirement would estab­

lis h a universal sa fety and health " flo o r" from s ta te to s ta te .
Prior to the OSHA Act, s ta te le g is la t io n was e it h e r inadequate,
unenforceable, p o l i t i c a l l y motivated, or f i g u r a t iv e l y nonexistent.
What regulations existed were inconsistent from s ta te to s t a t e , and
could be characterized by varying degrees of len ien cy, com petition,
ju r is d ic tio n a l disputes, and fig h ts to keep compensation rates low.
Second, sta te laws can provide a lo c a lly operated assistance,

2

Bureau of National A f f a i r s , I n c . , The Job Safety and Health
Act of 1970 (Washington, D.C. : Bureau o f National A f f a i r s , 1971).

6

inspection, and enforcement program which is believed to be more
responsive to local needs and problems.

3

The OSHA Act had also served as a c a ta ly s t to r e v i t a l i z e the
safety movement in th is country.

There had been a pronounced t r a n s i ­

tion from an atmosphere in which sa fety was often taken fo r granted,
or given more l i p service than a c tio n , to one in which employee
safety and health o f necessity must be assigned a top p r i o r i t y
among the primary missions o f an organ izatio n .

Most employers have

had to take a d i f f e r e n t look a t t h e i r safety needs, o b lig a tio n s ,
and expenditures, and do things they had not done in the past.
Safety and health standards had suddenly been discovered by many who
hardly knew of t h e i r existence before OSHA,

4

e s p e c ia lly the small

businessman who had scarcely been reached by the safety movement.
In order to f u l l y appreciate the sig n ifica n c e o f these fa c to r s , i t
was helpful to recognize a number o f very compelling reasons why the
act had th is kind o f impact:
1.

V i r t u a l l y every company was covered by the a c t; 57

m illio n non-government workers in 4.1 m illio n companies, regardless
of how small a firm might be.
2.

Minimum safety and health standards were s p e c i f ic a l l y

spelled o ut, and were mandatory ra th e r than voluntary.

3

Roll in Simonds, "What's Ahead in Occupational Safety in
Michigan," The Michigan S tate Economic Record (May-June, 1972),
pp. 3 , 7-8.
^Michael K rik o ria n , "An Analysis o f the Occupational Safety
and Health Act o f 1970," ASSE J o u rn a l. Vol. 18, No. 4 ( A p r i l , 1973),
pp. 15-16.

7

3.
reviewed.

Safety and health records were both required and
This tightened control procedures f o r some companies,

changed computational analysis f o r o th ers, and fo r a great many,
represented t h e i r i n i t i a l exposure to comprehensive data.
4.

OSHA monitored compliance.

The f a c t th at f i e l d repre­

sentatives could make unannounced inspections, subpoena evidence,
issue c it a tio n s , seek in ju n ctio n and/or imposition o f a series of
specified f in e s , prodded organizations to develop organized programs,
and give the safety function bargaining power.
5.

Employers were held accountable fo r employee compliance,

thereby l i t e r a l l y forcing them to monitor t h e i r own safety program.
6.

Employees had the r ig h t to be kept informed as to legal

requirements, p e rtin e n t fa c t s , and subsequent a c tio n , and to p a r t i c i ­
pate in developing standards.

Most im portant, they could express

grievances d ir e c t to OSHA o f f i c e s , and request an inspectio n, without
management recrim inatio n.
7.
dent.

Constructive action to comply with the Act must be e v i ­

Monetary constraints and other " ju s t i f i c a t io n " was unacceptable

fo r noncompliance.

Where necessary, loans were a v a ila b le through the

Small Business Adm inistration.
F in a l l y , a new arsenal o f management techniques was required to
deal with the e n tir e problem of worker safety and health.

New tools

must be developed, and old ones sharpened and re d ire c te d .

The p o tential

problems and/or challenges generated by the OSHA Act were complicated,
bewilderingly v a rie d , and c o s tly .

8

Management decisions such as those r e la t in g to a d m in is tra tiv e
co n tro l, coordination, a u th o rity and r e s p o n s ib ility re la tio n s h ip s ,
personnel p o lic ie s , labor r e la t io n s , machinery design and use, and
even maintenance practices were changing at the same time.

During the

year before OSHA was in fo rc e , Prentice H a l l , Inc. conducted a pre­
enactment survey of personnel adm inistrators.

Less than 10 percent

thought nothing would happen as a r e s u lt o f the a c t , 50 percent said
i t would force them to in te n s ify safety tra in in g e f f o r t s , 16 percent
indicated i t would create new problems fo r supervisors, and 11 percent
said i t would boost costs.

A s im ila r survey during the f i r s t year

since the OSHA Act by Production magazine indicated th at respondents
f e l t the act was more far-reaching in i t s impact on organizations than
anything previously experienced, and was only a r ip p le compared to
5
the wave to fo llo w .
The price tag fo r compliance with the Osha Act was a t best a
guess.

A survey by the National Association of Manufacturers (NAM)

indicated th at the average i n i t i a l cost to an employer o f fewer than
100 employees would be $33,000; fo r those w ith over 100 employees,
$100,000 ''plus"; and fo r employers with over 5,000 employees,
$7,146,000.

One automobile company safety d ir e c to r estimated th at

the added costs would mean a $15 increase in the p rice o f each car
produced.®

^"Living with OSHA," Production, December, 1972, p. 69.
C

Dan Cordtz, "Safety on the Job Becomes a Major Job fo r
Management," Fortune, November, 1972, p. 117.

9

The important point to be made with such cost fig u res was th at
immediate or projected a c t i v i t i e s w i l l requ ire substantial in v e s t­
ments, and subsequent in te rn a l adjustment.
should be put in to perspective.

A c tu a lly , the figures

Seldom did a company s t a r t e n t i r e ly

from "scratch" in i t s sa fety program or a c t i v i t i e s .

S im ila r ly ,

costs w i l l vary not only by s iz e , but by type o f industry or opera­
t io n , and the degree of safety and health s o p h istic atio n o f the safety
provisions already e x is tin g .^

Employers with good safety p ra c tic e s ,

for example, w i l l have less o f an investment to make than those who do
g
not.
In a d d itio n , money spent to improve control over operations
results in savings in work accident costs, workmen's compensation,
insurance premiums, and abnormal operating costs, and these commonly
more than o ffs e t extra expenditures necessitated by compliance to
g
new standards.
One en terp risin g author indicated th a t a worker
making $10,000 who spends two minutes a day worrying about his
s a fe ty , or dodging hazards ju s t to get his work done, accumulates
$333 each year in wasted time.

He fu r th e r stated th a t " i f the

workmen's compensation ra te fo r his work was $3 per $100, you
have another $300 per y e a r."

This represents a to ta l o f $633,

and in a f i f t y man operation, th is is a negative cost of $31 , 6 5 0 ! ^

^Robert D. G id e l, " P r o f it from OSHA Act? I ' l l T e ll You How,"
National Safety News, Vol. 7 , No. 1 (January, 1973), p. 36.
^National Safety Council, "OSHA Act and Today's Safety
Training Needs," National Safety News, Vol. 7 , tNo. 1 (January, 1973),
p. 36.
g
Simonds, op. c i t . , p. 3.
^ G id e l , op. c i t . , p. 43.

10

These fa c to rs added y e t another dimension to the p o te n tia l
parameters of th is study.

Not only was there a need f o r p ra c tic a l

information about how firms were complying to the OSHA Act w ith
almost none a v a ila b le , but the changes or " a lte r a t io n s " required were
so encompassing t h a t they defied any kind o f exhaustive a n a ly s is .
Purpose o f the Study
The purpose o f th is study was to d escrib e, i d e n t i f y , and
measure the impact of the OSHA Act in i t s e a rly years on representa­
t iv e business firm s in the s ta te o f Michigan.

This assessment helps

to discover whether the act is b e n e fic ia l and doing the job intended
or needs substantial re v is io n and change.

While such a study or

undertaking provides some insights in to o rg a n iza tio n a l behavior,
the purpose was a broad d es crip tio n r a th e r than the v e r i f i c a t i o n o f
a s p e c ific hypothesis.
I t was evident th a t any study r e la t in g to the impact o f the
OSHA Act had almost no boundaries in terms o f scope, type o f informa­
t io n , or area o f in t e r e s t or emphasis.

While th is presents a con­

siderable number o f opp ortun ities f o r in v e s t ig a t io n , th ere are
p ra c tic a l lim it a t io n s .

A broad comprehensive study attem pting to cover

everything could r e s u lt in doing nothing w ell or m eaningfully.

In

order to circumvent th is problem, and to provide some systematic
form fo r a n a ly s is , th is study considered eleven general to p ic areas
with high p r o b a b ility o f change.

In a d d itio n , th is study attempted

to examine only those responses which are most p r e v a le n t, conspicuous,

11

and universal in d e t a i l .

A more in-depth study w ith in these areas

was l e f t to other researchers.
On th is basis, the research th ru s t of th is study was directed
at eleven areas to to determine any d is c e rn ib le occupational safety
and health changes as a r e s u lt o f the OSHA Act.

Since i t seems

highly probable th a t (1) firm s i z e , (2) in ju ry frequency ra te s ,
(3) whether a firm is "targeted" by the government fo r inspection
because o f h i s t o r i c a l l y poor s a fe ty records, and (4) whether a
firm is a m u lti-p la n t o p eratio n , or one with a l l operations under
a single ro o f, might s i g n i f i c a n t l y influence the safety compliance
behavior o f an organization to the OSHA A ct, the follow ing eleven
areas were examined in terms o f each o f these four v a ria b le s .
I.

II.

III.
IV.

V.

V I.

Have there been any changes in organization s tru c tu ra l
alignment and a d m in is tra tiv e r e s p o n s ib ilit y , e s p e c ia lly in
regard to such things as new positions and/or fu n ctio n s,
t i t l e s , reporting procedures, dual re s p o n s ib ility with
other fu n c tio n s , and interdepartmental re la tio n s h ip s .
How have functional duties
been affected with respect
a n a ly s is , consultation and
appropriation and c o n tro l,
and tr a in in g .

o f safety designated persons
to lin e and s t a f f re la tio n s h iD S ,
compliance, budget determ ination,
purchasing, and records, p o lic y ,

Has the safety function been upgraded.
What has been the impact upon safety committess in terms o f
new or increased fu n ctio n s, fo r m a lit y , frequency, membership
number, and composition.
Have r u le s , procedures, purchasing p o lic y , control methods,
inspections, rewards or sanctions, and reports been changed
or special a c t i v i t i e s added.
What is the extent o f awareness and comprehension o f compli­
ance requirements.

12
V II.

V III.

Is there new or increased investment in c a p ita l equipment,
safety devices, personal p ro te c tiv e items, "plant'1 changes,
and f a c i l i t y a l t e r a t i o n .
Has there been a change in communication techniques, such as
p u b li c it y , t r a in i n g , and employee feedback, does i t now involve
more or d if f e r e n t people, and is there g re a te r use o f "out­
side" sources fo r "educational" purposes.

IX.

In what manner have the unions in contrast to management
responded: committees, "pressure," inspections, tr a in in g of
stewards or s p e c ia lis t s , and communication to members.

X.

Do firms r e a l l y fee l th at small businesses should be exempt
from the a c t.

XI.

What is the posture o f management in re la tio n s h ip to under­
standing the requirements of the a c t , appropriateness of
standards, employee involvement, expenditures, and general
compliance.
Summary
The OSHA Act o f 1970 represented an approach to occupational

safety and health th a t is so dramatic in concept, comprehensive in
content, extensive in coverage, and rigorous in enforcement th at
v i r t u a l l y every businessman in a supervisory p osition w i l l be affe cte d
in some way.

But the complexities involved make compliance a d i f f i ­

c u lt task even when a l l necessary inform ation is a v a ila b le , or proven
"track records" are observable.

Considering th is background, the

absence of general research d a ta , the newness of the a c t , and
necessary compliance by 1975, there is a v i t a l need f o r feedback on
how firms are responding.

This study w i l l help f i l l

the void of

d es crip tiv e information by a survey o f represen tative firms to
determine responsiveness in eleven key areas o f s a fe ty compliance
behavior.

Chapter I I , which describes the h is t o r ic a l development

o f in d u s tria l safety and the factors which f i n a l l y trig g e re d the
OSHA A c t, w i l l help amplify the importance o f th is law.

CHAPTER I I

THE HISTORICAL BACKGROUND FOR THE OSHA ACT
Introduction
As discussed in the previous chapter, the OSHA Act repre­
sented more than j u s t a law th a t sp e cifie d p a r t ic u la r sa fe ty and
health standards, methods o f enforcement, or "necessary machinery"
fo r implementation.

The overreaching value was th a t i t provided a

single workable federal program f o r occupational safety and h e a lth ,
one designed to stim u late r e a l i s t i c s ta te laws and p a r t ic ip a t io n , a
r e v i t a l i z a t i o n of the safety movement in th is country, and emphasis
upon safety oriented management techniques.

The in te n t o f th is

chapter is to provide a h is t o r ic a l frame o f reference in order to
understand why the OSHA Act is considered re v o lu tio n a ry , and the
an ticip a ted response of business firms so s t a r t l i n g .
six general topic areas:

I t w i l l cover

(1 ) prelude to the s a fe ty movement,

(2) the safety movement, including the evolution o f safety a c t i v i t i e s ,
org an izatio n s, and philosophies, (3) government contributions to
the safety movement, (4) the in d u s tria l hygiene movement, (5) work­
men's compensation, and (6) recent pressures th a t served as c a taly sts
fo r the necessary legal "breakthrough."
The OSHA Act o f 1970 may be looked upon as an idea and a
program "whose time had a r r iv e d ."

F i r s t , a great number o f the

s o c ia l, p o l i t i c a l , and economic problems associated with occupational
13

14

safety and health had long been smoldering, unrecognized or d is re ­
garded.

I t had become both customary and convenient to pay " l i p

service" to these important fa c to r s , and to consider the e n t ir e s i t u ­
ation as r e la tin g s o le ly to business, and dealing with employeremployee re la tio n s h ip s .

Second, there had been an ever-increasing

tendency to th in k o f occupational safety and health in terms o f
phenomena o f the past, associated w ith sweatshops, long working hours,
and ch ild labor.

This was fu rth e r compounded by the inadequacy and/or

apparent lack of sig n ific a n c e of a v a ila b le s t a t i s t i c s on jo b -r e la te d
deaths or i n j u r i e s , e s p e c ia lly in sm aller firm s , or those without
adequate safety programs.

T h ird , where safety and health standards

did e x is t and accident rates were low, i t was assumed th a t th is was a
guarantee o f a good sa fety program.

There was a need to convince

people th a t safety could only be accomplished by employers, employees,
and unions working together and in concert with government and social
agencies.
Prelude to the Safety Movement
Work has always been dangerous, and accompanying occupational
in ju r ie s and diseases prevalent.

But p rio r to the In d u s tria l Revo­

lu tio n there was n e ith e r the in c lin a tio n nor the means to provide an
o rig in a l c o lle c tio n o f in ju ry data necessary to bring w ork-related
i n j u r i e s , permanent physical impairments, or death to the a tte n tio n
of the public.
The introduction o f machinery and tr a n s itio n from manpower
to machine power, and from home production to fa c to ry production,
changed a l l th is in very dramatic fashion.

Large numbers o f new

15
types of hazards and unsafe practices were created, and there was a
tremendous surge in the occurrence of work i n j u r i e s .

Unguarded

moving gears, p a rts , and cu ttin g blades, power operations th a t con­
tinued u n til shut o f f , regardless o f fingers or hands th a t might be
caught, and large concentrations o f in h eren tly dangerous chemicals
and dusts required monumental adjustments.

Factories were poorly

b u i l t , with inadequate l i g h t , h eat, and a is le space.

Coal mining was

characterized by l i t t l e or no known mine safety measures, crumbling
mine ro o fs , suddenly flooded mines, and gas explosions and asphyxi­
a tio n .^

In 1890 only about 10 percent o f railw ay cars were equipped

with automatic couplers.

The others had to be joined by hand w hile

the workers were running between moving cars.
very dangerous.

12

Both operations were

In a d d itio n , the e n tir e problem was compounded by

large groups of workers w ithout tra in in g or experience, long hours of
hard and hazardous work, from sunrise to sunset, and employment of
c h ild re n .^
Two other important phenomena existed:

the emergence o f the

impersonal corporate o rg an iza tio n , and a plethora o f cheap labor from
heavy immigration.

P rio r to 1900 the owner o f a plant usually

operated i t , was re g u la rly in the p la n t, and generally f e l t a sense
of re s p o n s ib ility toward his employees.

But the In d u s tria l Revolution

11

R o llin H. Simonds and John V. G rim ald i, Safety Management
(rev. ed .; Homewood, 111.: Richard D. Irw in , I n c . , 1963), pp. 16-17.
12

Herman Miles Somers and Anne Ramsay Somers, Workmen1s
Compensation (New York: John Wiley and Sons, I n c . , 1954), p. 198.
11

Simonds and G r i m a l d i , op. c i t . , pp. 16-17.

16

introduced the absentee owner, w ith a re s u ltin g decline in the per­
son's sense o f r e s p o n s i b i l i t y . 1**

S im ila r ly , the steady stream o f

penniless immigrants, frequ en tly helpless and w i l l i n g to work under
any conditions, and fu r th e r disparaged because o f n a t i o n a l i t y , con­
trib u te d to the debasement o f the p rice o f human l i f e .
The Safety Movement
In the p o s t-C iv il War period the r a i lr o a d , mining, and t e x t i l e
industries were notoriously hazardous.

Resentment against the death

t o l l was in p art responsible f o r the formation o f a t e r r o r i s t labor
group known as the Molly Maguires, which reacted "in kin d," and
demonstrated some o f the v io le n t consequences which might flow from
poor accident experience.

The Knights of Columbus in New England,

where most t e x t i l e manufacturing was then concentrated, were more
co n stru c tiv e, and in the la t e s ix t ie s and e a r ly seventies pushed fo r
sta te fac to ry-in s p ec tio n laws.

Then, in 1877, Massachusetts passed

a law th a t made i t compulsory to guard dangerous moving machinery,
and two years l a t e r established an enforcement agency to administer
other laws r e la tin g to c h ild la b o r, s a fe ty , and working hours fo r
women.

U n fo rtu n ate ly, i t was soon cle a r these provisions were

confusing, i n e f f e c t i v e , u n r e a li s t i c , non-enforceable, clashed w ith
cost considerations, and were g enerally opposed by industry.

15

The safety movement is often said to have had i t s beginning
in the steel industry about 1900.

Eight years e a r l i e r the J o l i e t

^Somers and Somers, op. c i t . , pp. 8-18.
15 Ib ld . , p. 200.

17

Works o f I l l i n o i s Steel Company established an e f f e c t iv e sa fety
department, and in 1906 the United States Steel Corporation i n i t i a t e d
a committee f o r safety inspection and accident prevention.

The

l a t t e r trig gered a safety program th a t saved hundreds o f m illio n s
o f d o lla r s , and re lie v e d untold s u ffe rin g and economic loss by
employees.^8

Even though general s t a t i s t i c s have been a v a ila b le

only since 1926, i t is believed th a t the peak in in d u s tr ia l accident
rates was reached about 1907-1908, which marked the bleakest period
in terms o f death fo r both ra ilro a d in g and m in in g .1^
In 1907 the Association o f Iron and Steel E le c tr ic a l
Engineers became the f i r s t professional group to appoint a safety
committee.

During the same year a safety e x h ib it was held a t the

American Museum of History of New York.
American Museum o f Safety.

This became the famous

Then in 1912, the F i r s t Cooperative

Safety Congress met to discuss problems o f in d u s tria l s a fe ty .

18

This group was enlarged in 1915 to include other types o f s a fe ty ,
as well as i n d u s t r i a l , and was named the National Safety Council.

19

Led by a dedicated group o f young safety engineers employed by
industry and government, with an o rig in a l membership of only four­
teen, i t became the outstanding safety organization in the nation
with a position o f recognized leadership.

20

^Simonds and G rim ald i, op. ci t . , p. 22.
17

Somers and Somers, op. c i t . , pp. 10-17.

18 I b i d . , p. 200.
19

20

Simonds and G rim ald i, op. c i t . , p. 22.

Somers and Somers, op. c i t . , p. 210.

18

The National Safety Council has a membership o f many thousands
of in d u s tria l and business fir m s , as well as schools and other public
organizations.

I t conducts research, formulates and in te rp re ts

standards, and publishes a large number o f safe practices pamphlets,
and an accident prevention manual.

I t o ffe rs the safety exp ertise o f

its s t a f f , and provides the resources o f what is considered the best
safety l ib r a r y in the world.

The National Safety Council also con­

ducts an annual National Safety Congress with special meetings fo r
sp e cific problems or topics o f in te r e s t.

21

Other organizations have also made s ig n if ic a n t contributions
to the safety movement, and the prevention of in d u s tria l accidents
and illn e s s e s .

The American Society o f Engineers was incorporated in

1915 to develop safety engineering as a profession.

The American

Society o f Mechanical Engineers has had a sa fe ty committee since 1911,
and has helped develop s a fe ty codes f o r b o ile rs and e le v a to rs .

The

In te rn atio n al Association o f In d u s tria l Accident Boards and Commisions
(1914) focused on standardization o f s t a t i s t i c a l methods and work char­
a c te r is tic s re la te d to workmen's compensation.

The Accident Preven­

tion Department (1 9 3 7 ), o r i g i n a l ly the L i a b i l i t y Conference in
1896, is financed by c a p ita l stock insurance companies to research
special problems, and provides l i t e r a t u r e on accident prevention to
industry and schools.

The National Council on Compensation operates

a ra tin g organization and assists members.
21

22

Simonds and G rim ald i, op. c i t . , p. 20.

22Ib id . , pp. 21-22.

19

Inasmuch as the OSHA Act was p r in c ip a lly based upon e x is tin g
consensus safety standards, i t is noteworthy th a t one of the p r in ­
cipal c o n trib u to rs , The American National Standards I n s t i t u t e (ANSI)
was formed during th is period.

I t has continuously developed

standards dealing with safety as w ell as product components; and i t
used consensus methods to encourage voluntary adoption by employers.
In a d d itio n , the National F ir e Protection Association (NFPA) made
s ig n if ic a n t co n tribu tio n s.
government a t a l l

S t i l l other standards have come from

le v e ls , l o c a l , s t a t e , and fe d e r a l.

Federal action

was la rg e ly the r e s u lt o f the Walsh-Healey Public Contracts Act and
s im ila r laws, which gave the fed eral government power to reg u late
the working environment and physical conditions in establishments
doing business w ith the United States government.

23

I t is also appropriate to note th a t throughout the sa fety
movement, p r e v e n t i v e emphasis changed m a t e r ia lly in concept.
There were three d is t in c t approaches.
Management-Engineering Approach
Employers re a liz e d i t was to t h e i r advantage to t r y to pre­
vent accidents by guarding machinery and making i t d i f f i c u l t , i f
not impossible, fo r people to behave in d is c r e t io n a t e ly , ra th e r than
quarrel about who was a t f a u l t .

The e f f e c t was th a t fo r the f i r s t

two decades of the safety movement, emphasis was placed upon safety
engineering, and accidents were assumed to be almost ex clu sively
^ N a tio n a l Safety Council, "OSHA Act Primer Part I I :
Standards," National Safety News, Vol. 7 , No. 2 (February, 1973),
pp. 48-49.

20
mechanically o rien ted .

This posture coincided with and was furthered

by the concepts o f the s c i e n t i f i c management movement, which recog­
nized safety as an essential aspect o f in d u s tria l planning.

The

story of industry between 1910 and 1930 is re p le te with dramatic
improvements in physical la y o u t, machine guarding, and engineering
achievements.

24

Human Relations Approach
During the t h i r t i e s , the thinking prevailed th a t s tr a ig h t
engineering technique r e la t in g to safety was approaching p ra c tic a l
lim it s .

In a d d itio n , the concept of basing workmen's compensation

solely on physical factors was abandoned.
The new ta rg e t was the erra n t "human f a c t o r ."

Here again,

th is coincided with a broad new f i e l d in management, emphasis upon
human re la tio n s .

Personnel departments were brought in to the picture

to stress safety tra in in g and education, contests, and slogans
as means to help combat fa t ig u e , boredom, carelessness, and poor
a ttitu d e and " d is c ip lin e ."

When a "hard core" of accidents remained

in spite o f th is e f f o r t , in d u s tria l psychologists were used to
single out the workers involved fo r special a t te n tio n .

Unions and

other social p re s s u re s --e .g ., World War I I with worker shortages-caused a therapeutic approach, with psychological solutions to give
the worker the desire to perform s a fe ly .

24

25

Somers and Somers, op. c i t . , pp. 201-3.

25Ib id . , pp. 203-5.

21

Labor-Management Cooperation
There was a movement toward labor-management cooperation.

At

this stage i t was f e l t th at one unexplored area o f safety was th a t o f
e n lis tin g the independent judgment and re s p o n s ib ility o f the worker.
But this was d i f f i c u l t on four counts:

(a) i t was e s s e n tia lly p a te r­

n a l i s t i c , (b) management wanted t ig h t c o n tro l, (c) unions did not
demonstrate in t e r e s t , and (d) in a surplus labor market, workers
were e ith e r more in terested in a job and a paycheck, or severely
re s tric te d by the nature of t h e i r jobs.

G radually, in some sections

of industry, a balanced approach to safety emerged, stressing both
physical and personal f a c t o r s , the unsafe co n dition , and the unsafe
act.

Thus, safety clauses in c o lle c tiv e bargaining agreements began

to a p p e a r.^
Summary
I t is d i f f i c u l t to fin d an appropriate perspective in which
to appraise the effectiveness o f the safety movement.

Safety pro­

grams were s ta r te d , associations and organizations formed, standards
developed, and the emphasis

was

redirected from

physical working conditions

and

then the worker to

approach.

accenting so le ly
a morebalanced

But these tended to be somewhat nebulous in the absence

of more q u a n tita tiv e y a rd s tic k s .

Y et, s t a t i s t i c s never t e l l the

complete story in terms of a l l the costs to employers, nor the
burden to workers and t h e i r dependents, or to society.
comparative data was not a v a ila b le .
26I b i d . ,

205-7.

There

In a d d itio n ,

were no continuous series

22
of s t a t i s t i c s , and work in ju r ie s were constantly defined d i f f e r ­
e n tly , or information was incomplete.

Regardless, i t is probably

safe to say th a t there was great o ve rall improvement in the safety
record in the United States u n t il 1956.

The National Safety Council

estimates th at in 1912 the occupational accident death ra te per
100,000 workers was w ith in the range o f 4 9 -5 7 .27
dropped s ig n if ic a n t ly to 21.

28

By 1960 i t had

From then u n t il 1970, there was a

drop to 18, or s l i g h t l y b e tte r than 15 percent.

In ju ry frequency

rates dropped about 80 percent from 1926 to 1961 , from about 32
to 6.
Government Contributions
Government contributions to the safety movement concerning
legal "enforcement" have been lim ite d and in e f f e c tiv e .

At the

state l e v e l , Massachusetts was the f i r s t to act in 1877 with
machine guarding and fac to ry -in s p e c tio n enactments.

This pre­

c ip ita te d subsequent action by other states through 1910.

In

p r in c ip le , i t was established th a t states had the au th o rity to
ascertain and define safety conditions.

In f a c t , the statutes could

not or would not be enforced, because o f constraints re la te d to
money, s t a f f a v a i l a b i l i t y , p o l i t i c a l m o tivatio n, and f i e l d force
inadequacy.

In a d d itio n , some states r e a lly did not address them­

selves to the problem a t a l l .

I t is reported th a t one sta te did

27I b i d . , p. 206.
OQ

National Safety Council, Accident Facts (1972 e d . ) ,
pp. 28-29.

23

not get i t s f i r s t o ccupational-safety s ta tu te u n til 1967,

pq

and

even up u n t il the OSHA A c t, four states had no fac to ry inspections
whatsoever, and only three had over ten inspections.

There were

1,600 s ta te inspectors a t the time o f the OSHA A ct, and th is was
less than h a lf the number of fis h and game wardens in the country.
Many states spent less than one cent per worker fo r health and
safety program s.^
In 1911 Wisconsin established "the technique of adminis­
t r a t iv e regulation" which offered a format th a t a m ajority of
states followed.

F i r s t , i t adopted "blanket" safety provisions to

supersede a l l safety laws which the le g is la t u r e had been passing and
not enforcing fo r years.

Second, a new in d u s tria l commission was

created with q u a s i-le g is la t iv e power to tr a n s la te general l e g is l a t i v e
purposes into separate codes in the form o f a d m in is tra tiv e orders.
Employers and labor unions were in v ite d to p a r tic ip a te in d ra ftin g
the orders, thereby reducing c r itic is m of " a r b itra ry " in te rfe re n c e
with the work o f in s tru c tio n and education.

31

L a te r, many states

i n i t i a t e d special conferences in which technical committees sub­
mitted recommendations covering a gamut o f occupational safety and
health problems.
The re s p o n s ib ility o f the federal government fo r safety and
health was fo r the most part lim ite d to i t s own employees, plus to
varying degrees to in te r s t a t e railw ay workers, a i r trans p o rta tio n
29
30
31

Cordtz, op. c i t . , p. 114.
Bureau o f National A f f a i r s , op. c i t . , p. 14.
Somers and Somers, op. c i t . , pp. 210-11.

24

employees, seamen, and coal miners.

Periodic inspections o f merchant

marine ships are made by the U.S. Coast Guard.

The In t e r s ta t e Com­

merce Commission is responsible fo r in t e r s ta t e ra ilro a d s and motor
c a r r ie r s , the C iv il Aeronautics Board fo r a i r tra n s p o rta tio n .
Other than t h a t , the federal ro le in general in d u s tria l
safety has been t r a d i t i o n a l l y lim ite d to one of promotion, education,
and technical assistance through the Department o f Labor.

The Bureau

of Labor S t a t i s t i c s , which supplies d a ta , depends on voluntary coopera­
tion of industry fo r i t s re p o rts ; the Bureau of Labor Standards
"influences" without enforcement.

The Federal Safety Council was

created to work with states to provide technical and education
services.

32

In a d d itio n , the Public Health Service (established

1902), the Safety Standards Group o f the National Bureau o f Standards,
The Bureau of Mines, and the Federal Interdepartmental Safety Council
also served a b e n e fic ia l ro le in helping to formulate sa fe ty and
health yardsticks.
L e g is la tiv e e f f o r t has g enerally been s p o tty , and concentrated
on selected ind ustries such as longshoring, r a ilr o a d in g , fe d e r a lly
contracted cons true Li on and service s u p p lie rs , atomic energy, and
mining.

33

Regulation o f mine s a fe ty , fo r example, appears to follow

a path d ir e c t ly re la te d to a sequential pattern o f d is a s te rs .

The

i n i t i a l law in 1910 established the Bureau of Mines (Department of
I n t e r i o r ) , but provided no enforcement or inspection a u th o rity .

In

1940 au th o rity was granted to inspect working co n dition s, but not to
32Ib id . , pp. 9-13.
33

Bureau o f National A f f a i r s , op. c i t . , p. 14.

25

enforce standards r e la tin g to them.
Mine Act gave the Bureau the

In 1947-1952 the Federal Coal

a u th o rity to close a mine under f i v e

specified conditions which might lead to a "major" d is a s te r.
in 1969, one year before the

Then

OSHA A ct, Congress passed a compre­

hensive Coal Mine and Safety Act.
As mentioned e a r l i e r , the Walsh-Healey Public Contracts Act
in 1936 prescribed health and safety standards fo r workers engaged in
government contract work.
re lated to wages.

U n fo rtu n a te ly , the p rin c ip a l a p p lic a tio n

Enforcement was again lacking .

Less than three

percent of the firms covered were inspected, and the re s u lts were
mostly in t a n g ib le .34

■

The F a ir Labor Standards Act o f 1938, as amended,

focused on e s tab lis h in g a c e ilin g fo r the number o f hours worked in
one week, without overtim e, by non-exempt employees, as w ell as
child labor standards and age lim it a t io n s .
Both the depression and World War I I

in te r fe r e d w ith o v e ra ll

a c t i v i t y in the health and safety f i e l d , and by the m id -fo rtie s
general a c t i v i t y reached a low ebb, as labor concentrated on wages,
and management on p r o f i t s .

In 1948, however, President Truman

inaugurated a series o f annual meetings known as the President's
In d u s tria l Safety Conference ( l a t e r ca lle d the President's Occu­
pational Safety Conference) th a t continued through the Eisenhower
Administration.

They were supplemented throughout the year by

standing sa fety committees representing in d u s try , lab o r, insurance,
and government.3^
34I b i d . , p. 15.
Simonds and G rim ald i, op. c i t . , p. 23.

26

In 1951 Senator Hubert Humphrey introduced a b i l l

c a llin g

fo r uniform national health and sa fety codes and uniform enforcement
standards, a Bureau o f Accident Prevention and an Accident Pre­
vention Board w ith a d m in is tra tiv e a u th o rity and the power to
assess p en altie s.

Senator James Murray proposed le g is l a t i o n to

f in a n c ia lly as sis t states in estab lishin g a sa fety program which met
minimum requirements.

Like several other b i l l s o ffe re d by others

in the next 10 or 12 ye a rs , they got nowhere.

37

In 1964, President Johnson requested a special President's
Occupational Safety Conference, and th is proved to be the basis fo r
his request in 1968 fo r a comprehensive occupational safety and
health program.
In sh o rt, government a t the s ta te and federal lev e ls had
not yet s ig n i f i c a n t l y addressed i t s e l f to the problem o f enforcing
measures th at would lead to safe working conditions.
In d u s tria l Hygiene Movement
The b ir t h o f the in d u s tria l hygiene movement is usually set
around 1906 or 1910,

OQ

although the Public Health Service was

created by the federal government in 1902 to help overcome a general
ignorance of the su b je ct, and to es tab lis h in d u s tria l causation o f
occupational diseases.

In 1906, the Massachusetts Board o f Health

appointed health o ffic e r s to inspect f a c t o r ie s , workshops, and
Somers and Somers, op. c i t . , p. 213.
37
38

Bureau o f National A f f a i r s , op. c i t . , p. 15.
Somers and Somers, op. c i t . , pp. 215-16.

27

schools and, in 1910, the Governor o f I l l i n o i s appointed the f i r s t
State Occupational Disease Commission.

Also in 1910, the Bureau

of Mines in the Department o f the I n t e r i o r was i n s t it u t e d .

By

1913, progress was so ra p id , the movement was in f u l l swing.
Both federal and sta te programs and non-government programs
were instrumental throughout the development of the in d u s tria l
hygiene movement.

The federal government sponsored research studies

by the Department of Labor, the Public Health Service (D ivis io n o f
Occupational H e a lth ), the Bureau of Mines, and the Atomic Energy
Commission.

In 1914, the O ffic e of In d u s tria l Hygiene and Sanita­

t io n , forerunner of the D ivision of Occupational H ealth, was
established.

In 1935, the Social S ecurity Act gave the Public Health

Service au th o rity to aid states with grants fo r health work.

There

was a President's Commission on Health Needs of the Nation in
1952,

39

even though the major th ru s t was upon medical care and

insurance.
At the s ta te l e v e l , the e a r l i e s t occupational disease laws
in the United States were enacted in C a lifo r n ia in 1917, and Wisconsin
and Connecticut in 1919.

Since then a l l states have included occu­

pational disease as part of t h e i r compensation coverage, although
some specify only c e rta in diseases.

40

However, sta te hygiene units

are frequently hamstrung by l e g i s l a t i v e r e s t r ic t io n s , lack o f resources,
and in s u f fic ie n t medical and professional personnel.41
391bid. , p. 217.
40

Simonds and G rim a ld i, op. ci t . , p. 19.

41Somers and Somers, op. c i t . , p. 217.

28

Non-government programs have also made notable contributions
to the hygiene movement.

Harvard U n ive rsity established a degree

in in d u s tria l hygiene in 1918.

The f i r s t professional s o c ie ty , The

American Association of In d u s tria l Physicians and Surgeons (Indus­
t r i a l Medical Association) was organized in 1915.

Other organizations

include the American In d u s tria l Hygiene Association, and American
Conference of Governmental In d u s tria l Hygienists.

In 1937, the

Council on In d u s tria l Health o f the American Medical Association
was formed, and in 1935 The In d u s tria l Hygeiene Foundation was
created.

In a d d itio n , during World War I I there was emphasis upon

in -p la n t p r e v e n t i v e

health serv ices , involving physicians, nurses,

and sometimes p s y c h ia t r is t s .42
Workmen's Compensation
Workmen's compensation developed from a series of social
needs.

In the pre-compensation period, the worker was without

recourse to provide fo r his own health and w e lfa re .

Likewise the

employer had l i t t l e or no incen tive to r e a l i s t i c a l l y do anything
about providing safe and h ea lth fu l working conditions.
In the case of the worker, common law gave him l i t t l e
or no chance a t compensation.

His r ig h t to obtain indemnity

from in ju ry or wage loss depended upon a favorable court judgment;
this seldom happened.

The concept o f common law o f negligence

or l i a b i l i t y assumed occupational in ju rie s were always someone's
f a u l t , and the burden of proof f e l l to the worker to show

29

employer negligence.

The worker feared employer r e p r is a ls , and

fellow workers did not want to jeopardize t h e i r jobs by t e s t if y i n g
for the injured p arty.

The employer never had to defend him self

and could f a l l back upon (a) a "fello w -se rv an t" r u l e , in which
an employer was not l i a b l e fo r the carelessness or negligence o f
fellow workers; (b) "assumption o f r i s k , " in which the worker
accepted customary risks and hazards when he took the job even
though they

might be e x tra o rd in a ry ; (c) "contributory negligence,"

in which the employer was not responsible regardless o f the extent
of his negligence i f the worker was also neg lig en t.

43

In a d d itio n ,

legal fees were p r o h ib it iv e , and i f the worker d ied , his survivors
and dependents did not have legal recourse.
There was also l i t t l e
introduce preventive measures.

fin a n c ia l stimulus fo r employers to
The development o f insurance to

cover employer l i a b i l i t y , in which the size of premiums were re la te d
to damages paid, introduced such a f a c t o r , as did increasin gly
lib e ra l awards to workers around 1907 to 1910.

U n fortun ately, how­

ever, the number o f employers reached were few, and the re su lts
n e g lig ib le .

Workers who received inadequate or no compensation

became burdens on public or p riv a te r e l i e f agencies.

44

Workmen's compensation introduced a new economic and legal
p r i n c i p i e - - l i a b i 1i t y without f a u l t .

As a matter of social p o lic y ,

in d u s tria l accidents were now regarded as in e v ita b le hazards of
modern in d u s try , and a le g itim a te cost of production, ra th e r than
43

Simonds and G rim a ld i, op. c i t . pp. 17-19.

^Sommers and Sommers, op. c i t . , pp. 25 -2 6 .

30

expenses to be borne by the worker.

Consequently, i t was f e l t th a t

each industry should bear the costs of i t s own occupational r is k s , and
these costs should be included in the price o f the product.

45

In

f a c t , the previous compensation method o f try in g to assign f a u l t is
generally considered a less p r o fita b le concept than seeking causes
of accidents and try in g to elim in ate them.4^
The f i r s t workmen's compensation law in th is country was
passed in 1902, but was so r e s t r i c t i v e as to have no p ra c tic a l
value.

In 1910, New York provided a type of workmen's compensation

that applied to twelve dangerous occupations.

By 1915, t h i r t y

states had passed workmen's compensation laws, and now a l l states
have such sta tu te s.

47

In addition to the elim in atio n o f the issue o f f a u l t or
g u i l t , there are some other very tan g ib le and important advantages
to workmen's compensation laws.

O v e ra ll, they estab lish an admin­

i s t r a t i v e process to make sure the laws are known, observed, and
enforced, and th a t the p a rtie s know t h e i r r i g h t s , and how to obtain
them.
These laws provide fo r the employee predetermined and ade­
quate benefits fo r each in ju r y , and prompt payments, w ithout w a itin g ,
and in regu lar periodic "income" in s tallm en ts.

Wasteful l i t i g a t i o n

and legal fees are elim inated by sp e cifie d coverage and co n straints.
C ertainty o f payment is guaranteed regardless o f employer fin a n c ia l
45Ib id . , p. 27.
4®Simonds and G rim a ld i, op. c i t . , p. 19.
47Ib id . , p. 18.

31

status.

There is assurance o f medical b e n e fits , services, and

r e h a b ilit a tio n .
But there are also advantages and b en efits fo r the employer.
The broadening o f the insurance base to Include many employers, and
the reduction in the number o f l i t i g i o u s issues, lowers costs to
employers.

48

Employers are also made aware th a t in d u s tria l in ju r ie s

and re lated production losses, property damage, and increased
insurance costs are a serious drain on t h e i r p r o f i t s , and th a t i t is
important fo r them to reduce in d u s tria l accidents by taking steps to
elim inate hazards and insure safe practices in t h e i r e s ta b lis h m e n ts .^
Workmen’ s compensation represented a s ig n if ic a n t step
forward in the in te r e s t o f occupational safety and h ea lth .

Workers

were provided with compensation f o r in ju ry or lo s s , and employers
were more oriented to take steps to improve working conditions.
Recent Pressures Leading to the OSHA Act
The previous f i v e sections have traced the h is t o r ic a l pattern
in which occupational sa fe ty and health had become increasin gly
important and there was some attempt to solve or a t le a s t minimize
the more pressing problems.

S t i l l . , there was considerable need fo r

both an in-depth and o v e ra ll program.

Beginning in 1961, the r ig h t

proportions of s p e c ific c a t a l y t i c ingredients c o l le c t i v e l y trig g e re d
the awareness and responsiveness necessary to vigorously ta c k le th is
challenge.
48
49

This section w i l l provide a synopsis of six general fa c to rs .
Somers and Somers, op. c i t . , pp. 19-28.
Simonds and G r i m a l d i , op. c i t . , pp. 19 -2 1 .

32

F i r s t , workplace environments had become more hazardous.
Mechanization o f in d u s try , modern sophisticated technology, and
"chemicalization" increased the hazards o f labor both in number and
v a rie ty f a r beyond a l l previous experience, including the period
following the In d u s tria l Revolution.

Most of the time a worker

could not comprehend or control the vast aggregate and complexity
of machinery involved in his jo b , to say nothing o f the in te rd e ­
pendence with other operations or workers.

Even when c o n tro lle d ,

there could be serious in ju ry through gradual and undramatic
erosion of v i t a l i t y or body damage.

50

In a 1967 study, the Surgeon General estimated th a t 65 percent
of the workers in 1 ,700 in d u s tria l plants were exposed to toxic m a teri­
als or harmful physical agents, y e t only 25 percent were protected
adequately.

In 1968 a study by the Chicago I n s t i t u t e o f Medicine of

803 workplaces, employing 260,000 people in tra n s p o rta tio n , whole­
sale and r e t a i l tra d e , and services such as h o te ls , as w ell as
manufacturing plants showed 73 percent were exposed to p o te n tial
health hazards.

51

I t was fu rth e r estimated th at 390,000 new cases

of occupational disease occurred each year.

Known hazards such as

those leading to lead and muercury poisoning and asbestoses went
unchecked.

The Public Health Service estimates th a t a new p o t e n t ia lly

toxic chemical was introduced in to industry every 20 minutes.
50

52

Somers and Somers, op. c i t . , p. 7.

^R o y Davidson, P e ril on the Job, A Study o f Hazards in the
Chemical Industries (Washington, D .C .: Public A f f a ir s Press, 1970),
p. 5.
52

i

*

Bureau o f National A f f a i r s , op. c i t . , p. 14.

33

I t is v i r t u a l l y impossible under these circumstances fo r the
worker to be aware of the hazards he confronts in the workplace, and
patently impossible fo r him to take r e s p o n s ib ility fo r his own health
and sa fety .
a new man.

Man had created a new environment but he had not created

53

Second, sa fety s t a t i s t i c s made a strong case fo r federal
in te rv en tio n .

There has been a slowly but s te a d ily mounting increase

in frequency and s e v e rity rates in the past twelve years.

In 1958

the in ju ry frequency ra te compiled by the Bureau o f Labor S ta t is tic s
h it i t s lowest p o in t, 11.4 disabling in ju r ie s per m illio n man-hours
worked.

54

Between 1961-1970 the in ju ry frequency rate f o r manufac­

turing rose from 11.8 disabling in ju r ie s per m illio n man-hours
worked to .15.2, an increase of 29 percent.

55

A s im ila r p a tte rn , with

a percentage increase o f 50 percent, is also re fle c te d in National
Safety Council figures fo r the same period.

56

In f a c t , the i n c i ­

dence of in ju r ie s climbed s u b s ta n tia lly f a s t e r than did in d u s tria l
p ro d u c tiv ity , and almost nothing is known about death and disablement
re su ltin g from illn e s s e s induced by to xic substances assim ilated on
the j o b . ^
53

Davidson, op. c i t . , p. 158.

54

U .S ., Department of Labor, Bureau o f Labor Standards,
Safety Standards, Vol. 20 , No. 2 (M a rc h -A p ril, 1971), p. 1.
55

U .S ., Congress, Senate, L e g is la tiv e History o f the Occupa­
tional Safety and Health Act o f 1970, by the Subcommittee on Labor
of the Committee on Labor and Public Welfare (Washington, D.C. :
Government P rin tin g O f f i c e ) , p. 412.
56

National Safety Council, Accident Facts, op. c i t . , p. 28.

^ C o r d t z , op. c i t . , p. 112.

34

Each year an average o f 14,000 workers died from accidents
on the jo b , and 2.2 m illio n were disabled by accidents in the work­
place.

Work re la te d accidents meant annual losses o f $1.5 b i l l i o n

in wages, insurance, and medical expenses, and $8 b i l l i o n in Gross
National Product.

Even these figures undercounted d is ab lin g in ju r ie s

from 8 to 10 percent, according to an unpublished study prepared f o r
the Department o f Labor.

I f in d u s tria l accident s t a t i s t i c s compiled

by the Department included minor nondisabling accidents accounting
for less than a day's work, the to ta l would be 25 m illio n i n j u r i e s ,
CO

or more than ten times the 2 .2 m illio n fig u re commonly used.
In a d d itio n , as the National Safety Council points o u t, these
figures are estim ates, based upon fragmentary reports from a few o f
the more progressive s ta te s .

59

Accident in ju ry records are also

often incomplete and f a l s i f i e d , or not repo rted, and repo rtin g re q u ire ­
ments vary from s ta te to s ta te .

I t is l i k e l y th a t twice as many are

seriously h urt as the records show.

But even i f the figures were

accurate, there is another fa c to r to consider.

Death and in ju r y do

not come in increments o f hundreds o r thousands, but to one person
_.
,.
60
a t a time.
Perhaps the most obstainate o f a l l accident facts is the
continued and seemingly untouchable high ra te among small businesses.
A recent survey indicated th a t firms with under 250 employees had
almost double the number of prorated r e h a b il i t a t i o n cases as did
no

Bureau o f National A f f a i r s , op. c i t . , pp. 14-15.
59

Cordtz, op. c i t . , p. 112.

^ D a v id s o n , op. c i t . , p. 1.

35
large firms with 500 or more employees.®^

Many small firms with

processes not in h e re n tly more dangerous have lacked serious a c c i­
dent control and have accident frequency rates o f 30 to 100 or
greater.

62
T h ird , growing public awareness o f working conditions led to

pressures regarding in d ivid u al r i g h t s , social and "welfare" costs.
As occupational in ju r ie s increased in number, and as workers were
exposed to a g reater v a rie ty o f sa fety and health hazards, simul­
taneously, there occurred a degree o f social awareness o f the r ig h t
of everyone to g reater measure of personal protection th a t p re v i63
ously had not existed.
Workers had progressed, perhaps not
sp ectacu larly, through an extended tr a n s itio n period of social and
p o litic a l transactions:

from acknowledgment by the courts before

the turn of the century o f t h e i r r ig h t to a safe workplace (not
necessarily with corresponding change), to compensable losses
because o f occupational in ju ry or i l l n e s s , to bargaining, only some­
times with success, fo r b e tte r and more comprehensive medical
services, apart from management, and/or changes in oppressive working
conditions, to a somewhat adamant posture f o r a voice in determining
conditions o f the workplace.*^

Workers were aroused because they

f e l t th at l i t t l e would be done v o lu n ta r ily by employers to improve
^ N ic h o la s , op. c i t . , pp. 59-60.
^2Simonds, "What's Ahead," op. c i t . , p. 3.
^ " L iv in g with 0SHA," op. c i t . , p. 69.
^Sheldon W. Samuels, "0SHA in the System o f Social Transac­
tion,". ASSE Journal , Vol. 18, No. 1 (January, 1973), pp. 20-24.

36

working co nditions, remove job hazards, or to acknowledge or accept
re s p o n s ib ility fo r occupational s a fe ty .

An i l l u s t r a t i o n o f what was

occurring was reported in the D e tro it Free Press some time l a t e r .
In a meeting o f representatives of 750 UAW production workers, they
l e f t no doubt th a t workers on the assembly l in e in the fa c to rie s
f e l t they were bargaining fo r l i f e and limb as w ell as wages and
hours
Several other facto rs contributed to mounting s o d a ! pressures
on behalf of occupational s a fe ty and health .

Mass communication and

education broadened day-to-day personal contact and common in t e r e s t.
There were more second-generation workers who, u n like t h e i r fa th e r s ,
were not dependent upon e x is tin g social and p o l i t i c a l in s t it u t io n s .
Workers were younger, more s e n s itiv e , and could examine the q u a lity
of l i f e , and e f f e c t change d ir e c t ly through t h e i r union and/or
personal involvement in the decision making process.

There was

less class consciousness or social s tru c tu re , and the p o te n tia l fo r
social change was enhanced through an educational apparatus to
a c tu a lize change.^
Fourth, the federal government recognized the need fo r (a)
broad horizontal standards which could be u n iv e rs a lly applied to
provide a federal " flo o r" and consistency from s ta te to s t a t e ,
(b) education and t r a in i n g , (c) an inspection and enforcement appa­
ratus to assure compliance, and (d) a mechanism to force employers
6^Remer Tyson, "UAW Workers Speak Out fo r S a fe ty ," D e tro it
Free Press, February 16, 1973, p. 3, Sec. A.
^Samuels, op. c i t . , pp. 20-24.

37

to control employees.

The federal government f o r the f i r s t time

re a lly addressed i t s e l f comprehensively to the problems o f occupa­
tional safety and health .

True, i t had entered the safety and

health area in 1890 with le g is la tio n governing safety standards
and inspections f o r coal mines, again three years l a t e r fo r r a ilr o a d
cars and engines, and then i n i t i a t e d control laws fo r r a ilr o a d s .
But as noted e a r l i e r , occupational health programs consisted mainly
of research and s tu d ie s , and had l i t t l e
scale.

real impact on a national

Most were inadequately financed, and the t o t a l c o lle c tiv e

budget never topped $18 m i l li o n , and they b a re ly '’scratched the
surface" in id e n tify in g hazardous substances and es tab lis h in g human
fi 7
tolerances fo r them.
S im ila r ly , as also mentioned e a r l i e r , s ta te
programs were in e f f e c t iv e or nonexistent.
P o li t i c a l and social pressures were exerted by the appalling
s t a t is t i c a l revelation s regarding in d u s tria l in ju r ie s and deaths,
the sustained and pronounced upsurge in frequency and s e v e rity
ra te s , as well as by workers, c iv ic groups, and professional associ­
ations fo r a sweeping l e g is l a t i v e approach to occupational sa fety and
health.

More s p e c i f i c a l l y , the President's Conference on Occupational

Safety in 1964 was a r a lly in g point f o r polarized e f f o r t on b eh alf
of occupational sa fe ty and h ealth .

F i r s t , i t provided an opportunity

to "take stock" o f the s it u a t io n , and to bring various in te re s ts
together fo r concerted action.

And i t served as a springboard fo r

a l a t e r request by President Johnson in 1968 fo r "the n atio n 's
f i r s t comprehensive Occupation Health and Safety Program to protect
^ C o r d t z , op. c i t . , p. 116.

38

the worker on the jo b ."

68

L a s tly , the subsequent 1968 Congressional

hearings demonstrated d ram atica lly how serious the s itu a tio n had
become, and how the states had f a i l e d to deal w ith i t .
At the same tim e, coal mine explosions in Mannington,
West V i r g in i a , k i l l e d 78 miners, and reve latio n s o f the scandalous
extent of black-lung disease caused enough controversy to prompt the
passage o f the Coal Mine Health Safety Act o f 1969.

This fu rth e r

speeded up and heightened public awareness o f the broad im plications
of in d u s tria l safety and h e a lth , and also generated an environmental
controversy.

In th is atmosphere, le g is la to r s were f o r c ib ly reminded

th at many other workers faced serious hazards.

69

F i f t h , unions became more safety oriented in response to
both worker and management in te re s ts .

During 1969 and 1970, unions

changed from a posture of opposition to one o f strong support f o r
an e f f e c tiv e health and sa fe ty law.

The AFL-CIO-in p a r t ic u la r

became aroused and made th is the number one p r i o r i t y fo r the
N in e ty -F irs t C ongress.^
The i n i t i a l positio n o f opposition re fle c te d a number of
fa c to rs :
(1)

The d o lla rs and cents of sa fe ty l im it s c o lle c t iv e

bargaining as a tool in th is area.

Safety has seldom been a demon­

stra b le fa c to r in p ro d u c tiv ity .

68

Bureau o f National A f f a i r s , op. c i t . , p. 16.

fiQ
Cordtz, op. c i t . , p. 115.
^ N i c h o l a s , op. c i t . , p. 57-64.

39

(2 )

As long as 75 percent o f the work force was unorganized,

unions on an industry-wide basis found i t d i f f i c u l t to show progress/^
(3)

The primary purpose and in te r e s t o f unions was to

negotiate wages, lim it s to hours, and union r ig h ts .
(4 )

72

Unions gen erally lacked e x p e rtis e , tim e, and money

to make a concerted e f f o r t on b eh alf o f safety and h ea lth .

Few had

adequate s t a f f personnel a t the " in te r n a t io n a l11 level to deal with
the problems, to say nothing o f the in d ivid u al lo c a ls .
(5)

Unions had misgivings over the steadfastness o f the

committment of the Department of Labor to f u l l
were even more skeptical o f HEW p a r tic ip a tio n .

implementation, and
73

Not only had the top labor leaders not y e t singled out health
and safety as a major concern, but few unions even saw how serious
the occupational safety and health problem r e a l l y was.

A recent

survey of b lu e - c o lla r workers, fo r instance, indicated th a t the
thing th at concerned them most about t h e i r jobs was good health and
safety p ra c tic e s , followed by compensation f o r in ju r ie s and i l l nesses.

Yet, in the same survey, unions put pay f i r s t .

75

There were, however, both social and pragmatic reasons fo r the
reversal in t h e i r thin kin g.

Public and worker consciousness and

^Samuels, op. c i t . , pp. 20-24.
72

Davidson, op. c i t . , p. 77.

70

"Guenther Resigns, Reflects on OSHA," Occupational Hazards,
Vol. 35, No. 2 (February, 1973), p. 48.
^ C o r d t z , op. c i t . , p. 112.
75"Guenther Resigns," op. c i t . , p. 47.

40

concern, mass communication, education, and a younger, more demanding
work force have been discussed.

There was also an apparent culmina­

tion of a long l e g a l / p o l i t i c a l / s o c i a l strug g le.

The court decisions

in the 1840s recognized the r ig h t of the worker to safe workplace,
safe to o ls , safe work ru le s , and warnings o f danger.

But even though

i t was possible to win in the c o u rt, th is did not necessarily gain a
safe workplace or compensation fo r disease or accidents.

In 1926

William Green, President of the AFL, believed the cost o f compensa­
tion would bring in d u s tria l accidents to the a tte n tio n o f management.
Unfortunately, many s ta te laws inadequately defined compensable
losses, and the primary th ru st of safety programs was centered around
providing p ro te c tiv e equipment and tra in in g in hazard avoidance.

76

In a d d itio n , in most businesses a "management rig h ts " p h ilo ­
sophy permeated; management had the exclusive re s p o n s ib ility fo r
direc tin g the work force and fo r "running" the p la n t.

This a t t it u d e

frequently clashed with unions where they e x is te d , and provided a
s ig n ific a n t u n ila t e r a l power where they did not.

G radually, however,

the scope of union negotiation e f f o r t , with considerable help from
the National Labor Relations A ct, broadened to include pensions,
medical insurance plans, wash rooms, and other things re la te d to
"working con dition s."
Perhaps o f more sig n ific a n c e a t th is tim e, unions were
v i t a l l y concerned th at any le g is la t io n have universal ap p lic atio n
from firm to firm and s ta te to s ta te .

This would assure minimum

standards, and equal treatment fo r workers regardless of where or

7fi

Samuels, op. c i t . , p. 221.

41

under what circumstances they might work, and discourage competitive
short cuts in non-union plants or low labor cost s ta te s .

S im ila r ly ,

a federal program removed jurisprudence from states w ith no safety
programs, or those where they were loosely applied.

At the same tim e,

i t assured unions o f the same rig h ts and obligations as employers,
as well as providing rig h ts as representatives o f employees.
S ix th , employers became more sa fe ty minded and ap p reciative
of economic and human costs.

The snowballing p o l i t i c a l , economic,

s o c ia l, and labor forces increased employer awareness o f the importance
of occupational safety and h ealth .
Many companies h i s t o r i c a l l y had assumed sa fety problems were
minimal, and gave them but ro u tin e a tte n tio n .

Some continued to

believe th at workers were r e a l l y responsible f o r accidents and over­
looked or deemphasized the causal re la tio n s h ip o f hazards in the work
environment.

77

In some instances, safety was looked upon as some­

thing imposed by an outside group such as the union, insurance firm s ,
and government, and not f u l l y re la te d to the firm s ' a c t i v i t i e s .
Safety was also perceived as machine guarding and p la n t inspection.

78

Safety managers were low in the corporate hierarchy, concentrated
in " t r a d i t i o n a l 11 areas, and stayed out of the l in e o f f i r e .
usually had l i t t l e
ness.

a u t h o r it y , and were forced to r e ly on persuasive-

"S afety," goes the slogan, "must be so ld, not to ld ."
77

They

79

Cordtz, op. c i t . , p. 114.

78"News on Osha '7 0 ," ASSE Journal , Vol. 17, No. 2 (February,
1972), pp. 17-18.
79
Co rdtz, op. c i t . , p. 114.

42

Frequently, i t had not been demonstrated to the businessman
that in te rn al sa fety programs were good business.

This made i t

d i f f i c u l t a t times to reconcile the desire to provide safe working
conditions to minimizing human s u ffe rin g and hardship w ith needed
p ro d u ctivity.

Even the best intentioned management must be concerned

with p r o fits i f i t is to manage at all.® ®
Thus i t became evident th a t the prime motivation to provide
safe working conditions was usually the recognition of the c o s t l i ­
ness of accidents, and regulations ra th e r le n ie n t ly enforced by s ta te
agencies.

81

As noted e a r l i e r , insurance premiums fo r workmen's

compensation are predicated upon in ju ry claims fo r which employers
were responsible, and employers were increasingly made aware o f the
re latio n sh ip o f in ju r ie s to production losses, and subsequent reduced
p r o fits .

Even more s i g n i f i c a n t l y , employers were increasin gly using

more sophisticated computational techniques to provide a more
r e a l i s t i c and comprehensive costing a n a ly s is , and discovered how much
could be r e a l l y saved by reducing accidents.
Another fa c to r was equally important.

As public awareness of

occupational safety and health grew, and federal

le g is la tio n became

probable, representatives from business decided i t was to t h e ir
advantage to make constructive recommendations based upon previous
experiences in the enforcement of e x is tin g standards.

80Simonds, "Whats Ahead," op. c i t . , p. 7.
8 1 I b i d . , p. 3.

Those with

43

substantial safety programs in p a r t ic u la r wanted a law which was
compatible with t h e i r e x is tin g programs.

82

Summary
I t was emphasized in th is chapter th a t the challenges re lated
to occupational safety and health throughout the h is to ry o f the
United States have become increasingly complicated and perplexing.
At each step o f the way there were new programs, techniques, and
approaches.

But u n til the OSHA Act, e f f o r t s to coordinate these

a c t i v i t ie s in to a sin g le u n ifie d e f f o r t were fo r a l l purposes nonex­
is te n t.

In a d d itio n , many a c t i v i t i e s , e s p e c ia lly legal impetus,

frequently proved in e ffe c tu a l or lim ite d .
The growth o f in d u s t r i a l i z a t i o n , together with unsafe and
unhealthful working condition s, mushroomed the number o f serious
occupational accidents, d i s a b i l i t i e s , and deaths.

This led to a

safety movement in which special organizations or associations were
formed, and safety programs i n i t i a t e d with balance between emphasis
upon engineering and physical changes, and emphasis upon workers'
attitu d e s and pro tectio n.

S late and Federal government made a t

least some l e g is l a t i v e e f f o r t to fu rth e r worker safety and health .
The concept o f workmen's compensation changed the perspective of
evaluating accidents on the basis o f f a u l t , without worker recourse,
to one o f concentration upon seeking causes and t h e i r eventual
e lim in a tio n , with fin a n c ia l protection fo r the worker.
82

F in a lly ,

U .S ., Congress, House, Congressman W illiam A. Steiger
speaking before the House of Representatives, 92nd Congress, 2nd
sess., March 29, 1972, Congressional Record, Vol. 118, No. 49,
H 2809.

in the years p rio r to the OSHA A ct, i t became d ram atica lly evident
that working environments were, i f anything, even more hazardous.
Rising in ju ry frequency rates a le rte d the government, aroused the
public, awakened the union, and reminded the businessman th a t a
u n ifie d , consistent federal program fo r occupational sa fety and
health was necessary.
In th is manner, the OSHA Act brought changes so sweeping
to the f i e l d o f occupational safety and h e a lth , th a t i t was a n t i c i ­
pated th a t v i r t u a l l y every businessman would be considerably
affected fo r years to come.

The next chapter attempts to estab lish

a backdrop o f safety practices and/or concepts in order to determine
how business firms have responded to the act.

CHAPTER I I I
REVIEW OF THE PERTINENT LITERATURE
Introduction
In the previous chapters, i t was concluded th at the OSHA Act
represented landmark l e g i s l a t i o n , in concept, in comprehensiveness,
and in compliance required.

Because o f both the magnitude and speed

of the an tic ip a te d changes and adjustments business firms would be
required to make, i t was decided to l i m i t this study to eleven s a lie n t
topic areas.

Then, in order to provide a frame o f reference fo r

analysis o f these areas, the h is to r ic a l development o f occupational
safety and health programs, culminating with the OSHA A ct, was d is ­
cussed.

I t is the in te n t of th is chapter to sharpen the eleven

topic areas s t i l l

fu rth e r by showing and developing re latio n sh ip s

to other th e o re tic a l bodies o f knowledge.

In th is way i t w i l l t r y

to furnish a ya rd stic k to determine what factors to examine in
order to meaningfully monitor the impact o f the a c t.
U n fo rtu n a te ly , the OSHA Act was so new there are no s i g n i f i ­
cant research findings as yet w ith which to make comparisons,
develop hypotheses, or make p red iction s.

S im ila r ly , i t is so unique

and d if f e r e n t in approach to occupational safety and h e a lth , i t is
much too e a rly even to f u l l y assess many o f the im p lic a tio n s , or to
explore some o f the more immediate responses in d e t a i l .

The basis

fo r most conclusions in magazine a r t ic l e s are by self-adm ission
45

46

based upon observation in the sense o f one person's opinion or
experience, hearsay, or a few phone c a l ls .

The only survey to

speak o f was a questionnaire sent to 116 personnel managers by the
Bureau o f National A f f a ir s .

The conclusions indicated th a t fo r many

firms safety reports in some form were find in g t h e i r way to the
executive su ite fo r the f i r s t tim e , and th a t p lan t safety rules th a t
were accorded token acceptance but ignored in p rac tice were being
enforced; safety programs were changed, special communications i n t r o ­
duced, new or

ad d itio nal

tra in in g programs i n i t i a t e d , reporting and

record keeping a lt e r e d , and safety equipment and inspection procedures expanded.

83

Basic Safety Philosophy as Related to the OSHA Act
There are some occupational safety and health premises which
are c h a ra c te ris tic o f most good safety programs are are generally
acknowledged by experienced safety pro fession als, and organizations
such as the National Safety Council.

F i r s t , e f f e c t iv e programs and

a c t i v i t ie s in one firm or industry have s im ila r patterns as those in
other firms or in d u s trie s .

Second, safety is no accident.

I t must

be planned, backed, and merchandised as p art o f company p o lic y ,
receive appropriate p r i o r i t i e s and resources, and meaningfully
r e f le c t the in te r e s t o f management at a l l le v e ls .
must be continuously introduced and improved upon.
is a people as well as s itu a tio n a l problem.
oo

Safety p rac tice
T h ird , safety

There must be e f f o r t

"Impact o f OSHA on Personnel Management," B u lle tin to
Management, The Bureau o f National A f f a i r s , I n c . , No. 1204-Part 2,
March 8 , 1973, pp. 1-4.

47

to motivate and s e ll employees to do the r ig h t th in g , and to keep
doing i t .
safety.

Every man must be made a safety "expert" and p ra c tic e
Fourth, management must assume responsibi1i t y fo r a l l

accidents because i t controls the organization resources and p r i o r i ­
t ie s .

Consequently, accidents and in ju r ie s shouldjae in v estig ated

from a reference point o f a cause, not blame.
not an added cost.

F i n a l l y , safety is

I t is an insurance b e n e fit f o r both employee

w ell-being and f o r employer p r o f it s .

84

The OSHA Act is consistent with th is perspective.

I t is

structured to embrace the fo llow ing d o c trin e .
1.

Provide necessary personal p ro te c tiv e equipment and
in s tru ctio n s fo r i t s use and care.

2.

Develop and enforce safety and health ru le s , and
assure employee cooperation as a condition o f
employment.

3.

In v e s tig a te every accident promptly and thoroughly.

4.

Train a l l employees in good sa fe ty and health prac­
t i c e s , and stim u late r e s p o n s ib ility fo r wholehearted
p a r tic ip a t io n .

5.

Provide mechanical and physical safeguards f o r every
job to the maximum extent possible.

6.

Conduct a program o f safety and health inspections to
assure compliance to standards.

7.

Set up an award system to recognize outstanding per­
formance.

8.

Hake employers accept the necessary r e s p o n s ib ility and
leadership fo r an e f f e c t i v e and improved safety and health
program, and supervisory involvement.®®

84

National Safety Council, "OSHA A c t, What I t Should Be,"
National Safety News, Vol. 7, No. 3 (March, 1973), p. 123.
OC

U .S ., Department of Labor, Occupational Safety and Health
Adm inistration, Guidelines fo r Setting Up Job Safety and Health Pro­
grams, October, 1972, p. 6.

48

In response to the act then, i t might be a n tic ip a te d th a t a
firm would make a number o f changes.

For example, there could be

special arrangements to know the provisions o f the act in terms o f
standards, a c c o u n ta b ility , and worker rig h ts and r e s p o n s ib ilit ie s .
Operations, products, and services could be surveyed fo r adherence
to these c o n s tra in ts , and w r itte n safety p o lic ie s , work r u le s , and
purchase order clauses formulated and put in to e f f e c t .

Equipment*

f a c i l i t i e s , or processes might be a lte re d in a n tic ip a tio n o f an
OSHA inspection.

New or ad d itio nal safety t r a in i n g , education,

and in d o c trin atio n programs fo r supervisors and employees a lik e could
be i n i t i a t e d .

Special procedures and records fo r monitoring OSHA

compliance, and measuring p r o f its and saving might be introduced.

OC

I f th is were the case, s ig n if ic a n t adjustments r e la t in g to safety
could be expected in such things as organization repo rtin g proce­
dures, functional r e s p o n s ib ilit y , management and worker understanding,
awareness and a t t i t u d e , expenditures, communication, and union
re la tio n s h ip .

The follow ing sections w i l l discuss some o f these.
ActministraLive R esp on sib ility and
Functional Alignment

A safety program must always s t a r t with top management.
Safety a ttitu d e s are caught, not taught, the saying goes, and the
attitu des of supervisors and those they supervise almost always
r e f le c t th at of management.

I f top management f a i l s to genuinely

assign safety a high p r i o r i t y among the missions o f the o rg a n iza tio n ,
no one else in t h e i r firm is l i k e l y to do so.
®®Gidel, op. c i t . , p. 47.

Conversely, where the

49

ch ief executive becomes personally involved in s a f e ty , his whole
organization is aware o f i t , and notable success in accident prevention usually fo llow s.
be delegated.

87

Top management leadership, then, cannot

The employer, or c h ie f executive, must be w i l l i n g to

accept re s p o n s ib ility fo r occupational safety and health as an
integral part of his job.

He must set sa fe ty p o lic ie s , stim ulate

awareness in o thers, and show his own in te r e s t i f others are to
follow and cooperate to make working conditions safe and h e a lth fu l.

88

Management in te r e s t must be vocal, v i s i b l e , and continuous
throughout the e n tir e o rganization.

This is expressed by seeking

opportunities to be i d e n t if ie d with the safety program, re fe r rin g
to safety in meetings, presentations and special events, i n i t i a t i n g
w ritte n safety p olicy th a t is known to a l l employees, prompt and
immediate action to elim in ate unsafe conditions and to assure good
housekeeping, maintaining a comprehensive sa fety program, meeting
with key personnel,

89

and making necessary appropriations and

expenditures where necessary.

In respect to the Osha A c t, in addi­

tion to these a c t i v i t i e s , evidence o f such involvement might be
expressed by assigning the safety function h ig h e r status in the
organization h ie ra rc h y , creating new positions and/or t i t l e s ,
87

Simonds and G rim aldi, op. c i t . , p. 44.

QO

U .S ., Department o f Labor, "Guidelines fo r S ettin g Up Job
Safety," op. c i t . , p. 1.
OQ

National Safety Council, "Management Po licies on Occupational
Safety, Data Sheet 585, Education and Training Committee, Automotive
and Machine Shop Section, National Safety Council," National Safety
News, Vol. 7, No. 4 ( A p r i l , 1973), pp. 73-74.

50

providing both l in e and s t a f f functions w ith g reater safety and
health r e s p o n s ib ilitie s .

A survey by Fortune Magazine, f o r example,

indicated th a t a t le a s t one executive f e l t th a t in a short time some
corporation w i l l appoint a vice president f o r safety with re al c lo u t
from top management.

90

The re s p o n s ib ility fo r safety and health is c o lle c tiv e
rather than in d iv id u a l.

In only ra re cases can a p a r t ic u la r fo re ­

man, supervisor, plant manager, or corporate president be held
s p e c ific a lly accountable fo r a death or in ju r y .

Nearly a l l of

the abuses to human health come from o v e ra ll a t titu d e s , methods,
p ractices, and approaches followed by the managerial system.

91

An objective o f accident prevention or e lim in a tio n consequently does
not come about unless a l l lev els o f the organization are "tuned i n . "
Organization goes beyond merely drawing of lin e s .

I t attempts to

c reate, f i r s t the lin es of a u th o r ity , and second, the means th at
w il l bring about the o b jec tiv e to be a tta in e d .

More and more

executives are becoming convinced they must maintain organized
team e f f o r t to provide the safety mindedness a t a l l levels necessary
no

fo r the prevention o f accidents. c
The management person responsible fo r operations assigns
sp ecific areas

o

f

safety re s p o n s ib ility to department heads and

s t a f f s p e c ia lis t s , who in turn delegate s p e c ific re s p o n s ib ilitie s
90
91
qp

Cordtz, op. c i t . , p. 117.
Davidson, op. c i t . , p. 4.

Roland P. Blake, In d u s tria l Safety (3rd e d . ; Englewood
C l i f f s , N .J .: Prentice H a ll , I n c . , 1963), pp. 246-47.

51

to subordinates.

The safety engineer is but one a c t i v i t y o f a t o t a l

safety and health e f f o r t .

For example, process engineering is

required to consider s a fe ty and health as re la te d to workplaces and
processes, as w ell as sa fe ty decisions r e la t in g to machines, methods,
and time study.

Unsafe conditions are fre q u en tly the cause fo r

unsafe a c ts , and so i t is essential th a t hazards be considered
before putting in a process.

The work of the maintenance department,

whether ca lle d maintenance superintendent or p la n t engineer, is
extremely important in the prevention o f accidents.

93

S a tis fa c to ry

safety programs are contingent upon b u ild in g s , equipment, machinery,
to o ls , and safety devices th a t are in good and safe working order.
Systematic preventive maintenance avoids in ju r ie s from breakdowns,
obsolescence, confusions, more hazardous operations th at must be
performed against time c o n s tra in ts , and o v e r-re lia n c e on sa fety
equipment as " la s t l in e of defense" between the worker and a
hazard.

Although maintenance is la rg e ly r o u tin e , new s itu a tio n s

and hazards are numerous and an emergency may a ris e at any time.

94

Product research and process research are also f r u i t f u l areas fo r
safety improvement through more r i g id control o f processes, or
elim in ation of hazards.

The c o n t r o lle r and accounting make t h e i r

contribution in the area o f budgets and expenditures fo r s a fe ty .
This necessitates appreciation fo r safety and health requirements,
plus knowledge of accident costs and workmen's compensation in order

93

Simonds and G r i m a l d i , op. c i t . , pp. 46-4 7 .

^ B l a k e , up. c i t . , pp. 143 -4 9 .

52

to put e f f o r t and money in to accident prevention.

Purchasing must

be sure machines, supplies, and services meet s a fe ty standards.

95

Personnel or In d u s tria l Relations
Personnel or in d u s tria l re la tio n s is usually the d iv is io n or
department responsible f o r s a fe ty , and in which the sa fety engineer
or manager is often located.

I t is normally given the r e s p o n s ib ility

fo r coordinating safety oriented re cru itm e n t, s e le c tio n , placement,
counseling, and tr a in in g .

Other a c t i v i t i e s include the development

and adm inistration of the company safety program, sa fety inspections,
accident in v e s tig a tio n , maintaining records and preparing r e p o rts ,
publicizin g sa fe ty m a te ria ls , and checking compliance w ith legal
regulations
Simonds, in a study of 75 small manufacturing companies,
found th a t when companies reached 151 to 200 people, there appeared
to be a range o f tr a n s itio n in which there was a pattern toward
f u ll - t im e personnel managers.

When firms reached 201 to 300

employees, a l l o f the firms in the study had c e n tra liz e d the personnel
function and there was a dominant pattern toward a personnel manager.
Organizations w ith 301 to 500 employees g en erally had a f u l l - t i m e
personnel manager.

97

French also mentions studies th a t suggest th a t

personnel departments begin to emerge when companies reach a size
95

Simonds and G rim a ld i, op. c i t . , pp. 47-51.

9 6 1bid. , pp. 51-67.
9 ^William J. Wasmuth, R o llin H. Simonds, R. L. H i l g e r t , and
Hak Chong Lee, Human Resource A dm inistration: Problems o f Growth and
Change (New York"! Houghton M i f f l i n 19 7), pp. 147-150.

53

of 200 or more employees, and sometimes e a r l i e r .

He also indicates

that sometime before th is stage, various personnel a c t i v i t i e s are
assigned f u l l - t i m e to a t le a s t one employee.

Considered in terms of

d o lla rs , only firms with sales o f $3 m illio n or more were l i k e l y to
have personnel departments.

98

Safety D irecto r
The safety d ir e c to r or engineer has more s p e c ific d u tie s .
He wears many hats from time to time in fo s te rin g safety consciousness;
e . g . , f i r e p ro te c tio n , p lan t s e c u rity , f i r s t a i d , adm inistration of
insurance programs (including workmen's compensation), p a r tic ip a tio n
in community meetings and on committees, lectures to PTA, and issuance
of personal p ro tectiv e equipment.

99

But p r i n c ip a ll y , sa fety engineer­

ing consists o f in te g ra tin g p la n t safety operations and a c t i v i t i e s ,
in v e s tig a tio n , research, and analysis o f accident and health prob­
lems and recommending c o rre c tiv e a c tio n , the design o f physical means
of preventing accidents, helping to develop standards, d ire c tio n o f
educational programs, in te r p r e ta tio n o f accident s t a t i s t i c s and cost
data, and dissemination of safety knowledge.
There have been many attempts to devise a standard formula
to determine how large an establishment must be to j u s t i f y a f u l l - t i m e
go

Wendell French, The Personnel Management Process: Human
Resources Administration (sec. ed. ; Boston: Houghton M i f f l i n Co.,
1970), pp. 590-91.
99
Charles L. Gilmore, Accident Prevention and Loss Control
(American Management Association, 1970), pp. 12-13.
^^R ussell DeReamer, Modern Safety Practices (New York:
John Wiley and Sons, I n c . , 1958), pp. 320-21.

54
V

safety engineer, d ir e c t o r , or supervisor and a t what added increment
size he should be given a f u l l - t i m e as sis tan t or as sis ta n ts .
Elaborate charts have been drawn, but practices s t i l l vary because
of company p o lic ie s and the unique hazards and complexity o f safety
problems and a c t i v i t i e s which ch a rac terize various i n d u s t r ie s .101
In manufacturing, a plant with 1,500 workers w i l l probably have a
f u ll - t im e safety s p e c i a l i s t , w ith anywhere from a h a lf-tim e secretary
to as many as three a s s is ta n ts ; a h ighly mechanized plant handling
dangerous m aterials might have one even with less than 300
employees.

102

The best "ru le of thumb" is probably th a t o f cost

as against d ir e c t and in d ir e c t savings, and such things as employee
morale and improved work methods.

103

F in a l l y , the key lin k in the chain is the f r o n t - l i n e super­
v is o r, the foreman.

He deals d i r e c t l y with the employees, and

bears great r e s p o n s ib ility fo r implementing the sa fety and health
program as well as f o r a l l accidents th at o cc u r.10**

He must

enforce safety re g u la tio n s , in v e s tig a te a l l accidents promptly,
attend safety meetings, know f i r s t aid p ra c tic e s , p rac tice good
housekeeping, and teach employees about safety hazards and equip­
ment.105
101 Ib id . , pp. 354-55.
102
103

Simonds and G rim a ld i, op. c i t . , p. 58.
DeReamer, op. c i t . , pp. 354-55.

104U .S ., Department of Labor, "Guidelines fo r S ettin g Up Job
S afety," op. c i t . , p. 1.
105

National Safety Council, "Management P o lic ie s on Occupa­
tional S a fe ty," op. c i t . , p. 76.

55

Safety Committees
A safety and health committee has three basic o bjec tiv es :

to

aid and advise management on matters of worker safety and h e a lth , to
create and maintain an a c tiv e in te r e s t in s a fe ty , and to reduce a c c i­
dents.

In order to be successful in accomplishing them, i t should

therefore be involved in both the actual planning and implementation
of re la te d programs.
Within a general construct, the safety committee serves in
lieu of a safety department and s p e c ia lis t where none e x is t s ,
formulates and recommends p o lic y , provides advisory or adm inistra­
tiv e services, detects and corrects unsafe conditions and
practices

secures cooperation, coordination, and an exchange

of ideas among people not otherwise re g u la rly thrown to g e th e r,
including non-management or non-safety personnel.

In a d d itio n ,

safety committees can help promote p o s itiv e a ttitu d e s l i k e "acci­
dents can be prevented," and "the company is r e a l l y in te re sted
in s a fe ty , and so are the people who work here."

On a s p e c ific

basis, the safety committee establishes procedures fo r handling
suggestions and recommendations o f the committee, conducts special
inspections fo r special needs, holds re g u la rly scheduled meetings
to discuss safety methods and promotion, investigates and reviews
accidents, and recommends preventive measures.

I t should also

^ ^ N a tio n a l Safety Council, "Safety Committees, Data Sheet
631 (T e n ta tiv e ), Executive Committee o f Automotive and Machine Shop
Section o f the National Safety Council," National Safety News,
Vol. 7, No. 5 (May, 1973), pp. 83-84.
^^Simonds and G rim aldi, op. c i t . , p. 68.

56
provide assistance on the supervisory l e v e l .

Because o f close

day-to-day contact w ith workers, the foreman is a c r i t i c a l fa c to r
in the success o f any safety program.

Yet a l l too fre q u en tly he

has been l e f t to "sandwich in" safety r e s p o n s ib ilitie s w ith other
a c t i v i t ie s .

I t is incumbent upon the safety committee to supply

information, help search out and remove hazards, make recommenda­
tions fo r p ro tectiv e clo thin g and equipment, develop and revise
work ru le s , and encourage safety and f i r s t aid tr a in in g .

108

This is not to say th at committees are any so rt o f panacea
for the problems of working safety and h ealth .

They can be cumber­

some and slow moving, and i t is d i f f i c u l t to get the members
together, bring them up to d a te , and secure m ajority approval.
Members are ir r e g u la r in attendance.
v a rie ty of reasons.

109

Meetings are cancelled f o r a

There is a great amount o f unproductive time

spent ta lk in g about housekeeping items.

I f larg e expenditures are

involved, they can appear on the agenda, only to be eventually
dropped without any action taken.

Rather than i n i t i a t e c o rre c tiv e

action immediately, members avoid reporting unsafe conditions u n t i l
a safety meeting is h e l d . ^ 8

However, committees can also be

excellent instruments where they meaningfully provide the services
previously mentioned, as well as e n lis tin g employee in te r e s t and
p a r tic ip a tio n , and helping supervisors win g reater acceptance o f
108U .S ., Department of Labor, "Guidelines fo r Setting up
Job S afety," op. c i t . , p. 6.
109

Simonds and Grimaldi , op. c i t . , p. 68.
110
.
„_
DeReamer, op. c i t . , p. 76.

57

th e ir leadership and sa fety practices and, most im portant, when
recommendations and suggestions made by the committee receive prompt
co nsideration.111
The c h a ra c te ris tic s and composition of sa fety committees of
necessity conform to the size of the firm or p la n t, and the type of
product manufactured, so ld , or transported.

In some instances, fo r

example, committees may be very informal as in the case o f a small
owner-operated business,

112

very technical as in a chemical p la n t,

or consist o f prescribed and sp ecialized sub-units as in the auto­
mobile industry.

Membership may be composed of management, such

as superintendent, p la n t engineer, maintenance supervisor, depart­
ment supervisor safety p ro fe s s io n a l, purchasing agent, personnel
manager, or people with special e x p e rtis e , employees, and union
representatives.
S im ila r ly , there are a number o f types o f committees or
specialized functions they may serve.

For example, a p o lic y com­

m itte e , on behalf of top management, investigates serious accidents,
makes safety re g u la tio n s , resolves disputes, and reviews and compares
accident experience.
practices.

An inspection committee helps c o rre c t unsafe

An education committee provides the impetus necessary

to promote in te re s t in and compliance with the safety program in a
personal p a r t ic ip a tiv e manner.

A foremen's committee serves the

inspection and communication-indoctrination functions w ith in

111Blake, op. c i t . , p. 254.
^ ^ N a tio n a l Safety Council, "Safety Committees, Data Sheet
631," op. c i t . , p. 83.

58

departments.

113

In a d d itio n , technical committees are formed

fo r special problems f o r which sp ecialized knowledge is needed.
Special purpose committees are set up fo r s p e c ific jobs such as conte s ts , r e h a b i l i t a t i o n , and special in v e s tig a tio n s .

114

Committees with employee representation and labor-management
committees are also much in evidence.

In the case of the former,

employee p a r tic ip a tio n is used to create general safety awareness and
to stim ulate enthusiasm and in t e r e s t in various accident prevention
practices.

This is based on the premise th at by becoming involved,

the employee (a ) receives a s e lf-e d u c atio n in safety th a t w i l l
also be passed on to his fe llo w workers, and (b) safety rules and
practices w i l l more e a s ily be accepted.
a l l levels o f the org an izatio n .

These committees cut across

I t is believed th a t by working

constructively with his supervisor on a matter of common in te r e s t
and v i t a l concern to a l l , the employee w i l l not only fin d a much
needed means fo r s e lf-e x p re s s io n , but he w i l l develop the sense
of personal d ig n ity and pride necessary fo r cooperative prevention
of accidents.

The expectation is th a t th is w i l l carry over to a

re s p o n s ib ility fo r checking hazards and unsafe practices associ­
ated with his j o b J ^
Care must be taken, however, to avoid a number o f p i t f a l l s
associated w ith committees with employee represen tatio n.
113

Only a

Simonds and G rim ald i, op. c i t . , pp. 68-73.

^ B l a k e , op. c i t . , p. 254.
115Richard H. Wood, "How Can Labor-Management Cooperation
Implement Occupational Safety and Health?" National Safety News,
Vol. 7, No. 1 (January, 1973), p. 51.

59

small percentage o f the workforce ever serves on the committee.
Appointments are often on an annual basis, and fre q u en tly the same
people are reappointed.

Supervisors duck re s p o n s ib ility by re fe r r in g

accident prevention matters to the committee.

The l in e o f communi­

cation is often merely between committee members and when i t is
I I C

with workers, the supervisor is by-passed.
usually dominates meetings.

Management also

117

Labor-management safety committees are an outgrowth of an
honest concern by unions to see th at everything possible is done to
prevent i n ju r ie s .

Some managements have welcomed th is p a r t ic ip a ­

tion in accident prevention, and the support fo r p la n t s a fe ty programs
i t represents.

118

Unions can promote safety in t h e i r meetings,

publication s, and other contact.

They encourage f u l l use o f personal

pro tective equipment, recognize the need fo r sound sa fety ru le s ,
and do not impede management when the need fo r d is c ip lin e aris e s .
However, many fe e l safety is the re s p o n s ib ility o f management,
th at equal or b e t te r re s u lts can be achieved without union p a r t ic ip a ­
tio n , and th at e th ic a l compromises would be necessitated by s e ttin g
standards on one hand, and representing workers on the other.

11S

Record Keeping
The three basic p rin c ip le s o f accident prevention— namely,
(1) the creation and maintenance o f employee in t e r e s t in s a fe ty ,
^^DeReamer, op. c i t . , pp. 70-72.
^^Simonds and G rim a ld i, op. c i t . , p. 72.
118I b i d . , pp. 72-73.
119

DeReamer, op. c i t . , pp. 73-75.

60

(2) fa c t fin d in g , and (3) action based on facts--depend upon a sound
knowledge of what an accident i s , how and why i t occurs, the reasons
and incentives fo r prevention, and p ra c tic a l and c o n tro lle d methods
for dealing w ith the problems th a t occur.

120

This requires a

planned and systematic procedure comparable to th a t used fo r control
of such things as q u a n tity , q u a li t y , and costs, regardless o f degree
of the procedures or the size o f the firm .
In f a c t , i t is d i f f i c u l t to b elieve th a t an organization can
provide a safe working environment f o r i t s members, or maintain an
impressive safety performance record, without accurate uprto-date
and p ertin en t information upon which to make management decisions.
C e rta in ly the frequency, nature and c l a s s i f i c a t i o n , s e v e r it y ,
causes, and costs o f accidents represent indispensable c r i t e r i a .
When one views even a minor in ju r y from the standpoint o f cause
and the p o s s ib ilit y of securing clues as to i t s prevention, i t
becomes apparent th a t no matter how l i t t l e

the co st, i t cannot be

ignored i f more serious occurrences and complications are to be
avoided l a t e r .

121

S im ila r ly , the prevention o f losses from property

damage and business in te rru p tio n are equally important.

Property

loss incidents are usually complex and involve an actual or p o te n tia l
cause and e f f e c t beyond the minor loss of a sin gle piece o f equipment.

These must be approached and analyzed l o g i c a ll y .

122

i ?n
H. W. Henrich, In d u s tria l Accident Prevention (4th ed. ;
New York: McGraw-Hill Book C o ., 1959), pp. 8-12.
^ B l a k e , op. c i t . , 276-78.
^2^Gilmore, op. c i t . , pp. 120-21.

61

The value o f reports and records goes f a r beyond cu rren t
needs, however.

Knowledge o f the cause of the loss in c id e n t is

meaningful only when i t becomes the basis fo r preventive e f f o r t .
Consequently, measurement o f the performance and control of the
safety program must be based upon (a) sincere desire to learn the
truth about any patterns or trends, (b ) s ig n if ic a n t amounts of
data so they can be c a r e fu lly c la s s ifie d and e a s ily obtained by
routine methods, (c) easy comprehension by the manager or super­
visor o f the exposed f a c i l i t y ,

(d) s e n s i t iv it y to change so

deviations can be recognized in time fo r c o rre c tio n ,

123

and (e)

the type o f information th a t w i l l permit complete an a ly sis.
With th is as a stepping stone, a number o f b en efits then
accrue.

V i r t u a l l y a l l s ta te in d u s tria l commissions requ ire d e ta ile d

reports covering any in ju ry through which the worker becomes e n t i ­
tle d to workmen's compensation.
incentive.

In a d d itio n , th ere is a f in a n c ia l

Compensation insurance rates increase with only a few

, 124
additional reported accidents, thereby emphasizing b e tte r c o n tro l.
The extensive costs in terms o f medical payments, lo s t tim e, and
production losses are brought out in to the open.

The data estab­

lishes claims fo r medical and wage benefits provided by supplemental
benefit programs.

In v es tig atio n of accidents and co rrectio n o f

causes demonstrate company and supervisor in t e r e s t in workers.

125

An adequate p ic tu re o f each in d ivid u al accident is provided, as
l 2?
124
125

Gilmore, op. c i t . , pp. 39-41.
Davidson, op. c i t . , p. 152.
Gilmore, op. c i t . , p. 49.

62

well as cumulative p a tte rn s , trends f o r each department and the plant
as a whole, and experience comparisons.

Hazards, causal consideration,

and common facto rs are located and brought to the a tte n tio n o f man­
agement.

The information is also used to develop sa fe ty r u le s , and

prepare b u l l e t i n s , posters, and m aterial fo r sa fe ty meetings.

126

Many companies have h i s t o r i c a l l y ignored the advantageous
practice o f a proper accident record-keeping system.
know or understand them or have no records a t a l l .

Others do not
A recent study

in C a lif o r n ia , fo r example, indicated th a t only one out o f every
four firms used published BLS w o rk-in ju ry ra te information to conduct
follow-up safety inspections.

There was also doubt as to the depth

of basic expertise in making d is tin c tio n s and judgment r e la t in g to
sp ecific in ju ry data and reporting forms.

127

Another very big weakness exists in the accident records
themselves.

There is considerable under-reporting.

On each level

of supervisory management, there is reluctance to report a loss th a t
might adversely a f f e c t i t s performance record i f i t can be hidden.
In a d d itio n , d e fin itio n s vary as to what constitutes an in ju r y .

128

As

pointed out in Fortune, many corporate managements view t h e i r safety
record as a kind o f competitive game, and tra n s fe r workers to jobs with
lig h t or nonexistent duties to avoid repo rtin g them as disabled.

129

^ ^ B la k e , op. c i t . , p. 281.
1 27

Jerome B. Gordon, Allan Akman, and Michael L. Brooks,
In d u s tria l Safety S t a t i s t i c s ; A Re-Examination (New York: Praeger
Publishers, 1971), pp. 140-57.
128
Gilmore, op. c i t . , p. 45.

1pa

Co rd tz , op. c i t . , p. 113.

63

Counseling and Advising
I t is essential to an e f f e c t iv e safety program to know how
to (1)

recognize,

(2 ) a n t ic ip a t e , and (3) co rrec t conditions which

might cause or lead to unsafe or unhealthful working s itu a tio n s .
Accident prevention is c e r t a in ly to be preferred to ex post facto
redress.

Yet few firms have s u f f i c i e n t exp ertise in any o f the

three areas.

Even in large firms where safety managers and any

number of s p e c ia lis ts e x i s t , i t is a f u l l - t i m e job to disseminate
inform ation, provide plant-wide technical safety in d o c trin a tio n , and
counsel management and foremen.

For example, the OSHA Act sets fo rth

a voluminous body o f mandatory re g u latio n s .

The general industry

standards (p a rt 1910) alone consist of 19 subparts and occupy
some 250 t i g h t l y packed pages in the Federal R e g is te r.

Some o f the

standards adopt by reference various ANSI and NFPA standards so
that the employer needs more than the Federal Register as a guide
to compliance.

130

In f a c t , an o f f i c i a l o f the Small Business

Administration Association asserts i t would cost over $300 to buy
a l l the needed documents.

131

In a d d itio n , these standards are not orgnized in any log ical
and understandable fashio n, even fo r a professional.
is not only helpful but mandatory.

Reorganization

Standards also do not provide fo r

a lte rn a tiv e and sometimes b e tte r ways of protecting things on a
performance basis.

Some cannot be implemented equally in a l l work

^ ^ N a tio n a l Safety Council, "OSHA Act Primer P art I I :
Standards," op. c i t . , p. 49.
^ C o r d t z , op. c i t . , p. 168.

s itu a tio n s , and there is no way o f knowing which ones to meet.

132

Many standards are simple and c le a r d irec tio n s which can be checked
v is u a lly .

Others requ ire various measuring devices, some r e l a -

t iv e ly sophisticated.

133

No amount of reading, in t e r p r e tiv e w r itin g

seminar attendance, and discussion about OSHA can s u b s titu te fo r the
grindingly hard work o f knowing the actual and d e ta ile d requirements
Another fa c to r is th a t these are performance standards t e l l i n g
results to be accomplished ra th e r than the means by which re su lts
w ill be achieved.
Inspections
Accidents do not ju s t happen.

They are caused by unsafe

conditions or unsafe practices in combination or s in g ly .

A w ell

planned inspection procedure thoroughly and s y ste m a tic ally applied
is an e f fe c tiv e means o f discovering these hazardous s itu a tio n s .
The underlying philosophy is to take a hard look a t every safety
p o s s ib ilit y , item by item , in order to set p r i o r i t i e s and schedule
corrective work and downtime.

135

Whatever the cost in time and

money, correction before accidents occur is less than i t would be
in e v ita b ly i f uncovered.

136

However, inspections are most useful

^32G id e l, op. c i t . , p. 44.
^33National Safety Council, "OSHA-Act Primer Part I I :
Standards," op. c i t . , p. 49.
^34,'Living with OSHA," op. c i t . , p. 70.
135I b i d . , pp. 75-82.
136B la ke , op. c i t . , p. 92.

65

as an integrated part o f the program fo r seeking accident causal
f a c t s . 137
Numerous "hazard check l i s t s " are a v a ila b le to f a c i l i t a t e
a plant sa fety inspection and subsequent a p p ra is a l.

But to be

practical and useful they should be ta ilo r e d fo r each p la n t.
are, however, some basic elements throughout each:

There

properly safe­

guarded equipment, preventing m aterials o f manufacture from becoming
hazards, adequate personal p ro te c tiv e devices and equipment used as
intended, proper condition o f a i s le s , f l o o r s , s t a i r s , and p la n t
layout, safe illu m in a t io n , appropriate v e n tila t io n and noise l e v e ls ,
and work practices according to sa fety standards.

138

Supervisors should make "inspections" d a ily to check fo r
any unsafe conditions.

This continuously demonstrates to subordi­

nates both an in te r e s t in maintaining safety in the department,
and s u f f i c i e n t l y close a tte n tio n to sa fe ty in fra c tio n s th a t they
w ill not be overlooked.

139

But these day-to-day observations should be supplemented
with formalized and re g u la rly conducted inspections.

There should

be plant-wide and department safety tours conducted by the plant
manager and safety personnel as well as each respective supervisor,
periodic and re g u la rly scheduled safety appraisals of s p e c ific types
of equipment and machines, and inspections by s ta te o f f i c i a l s ,

137
138

139

Simonds and G rim a ld i, op. c i t . , p. 183.
DeReamer, op. c i t . , pp. 250-51.
Simonds and G r i m a l d i , op. c i t . , p. 185.

66
insurance re p res en tative s, and special e n g in e e rs .^ ^

Another

successful method o f conducting inspections is by appointing a team
of representative and temporary personnel to meet a t re g u la r i n t e r ­
vals.

As many men as possible would be given the opportunity to

p a r tic ip a t e , thereby helping to develop safety knowledge and p rin ­
cip les.

Where a safety s p e c ia lis t e x is t s , inspections would be

conducted regardless o f whether a team program has been introduced.

141

Enforcement of Safety Rules
and D is c ip lin e
Plant safety rules are necessary fo r good job performance,
o rd erliness, and s e c u rity .

Most organizations recognize th is as p art

of th e ir operating policy and in the c o lle c t iv e bargaining agreement.
On the working . l e v e l , supervisors who b elieve in accident prevention
rather than a f t e r - t h e - f a c t co rrectio n place g rea t stress on the need
fo r motivating employees to work s a fe ly and to fo llo w sa fe ty ru le s .
They have found th a t whenever safety rules are ignored, other rules
are usually ignored, too.

However, once a work group re a liz e s they

have to work according to accepted standards th ere is less temptation to d e lib e r a te ly or subconsciously avoid safe working p ra c tic e s .
In a d d itio n , workers usually p refe r to work by the ru le s , to know
where they stand, and what is expected o f them on a consistent dayto-day b as is , e s p ec ia lly when t h e i r health and safety are involved.

140

DeReamer, op. c i t . , p. 251.

^S im o n d s and G rim a ld i, op. c i t . , pp. 183-84.
142

DeReamer, op. c i t . , p. 95.

142

67
Where sa fety rules are not fo llo w e d , the f a u l t may re s t with
the r u le , the supervisor, or the employee.

Rules should, th e re fo re ,

be few in number and e a s ily understood, and there should be in te n t
to enforce them.

Supervisors and a l l members o f management must set

a good example by follow ing the rules themselves, and they must take
prompt action when prompt compliance is not evident.

F i n a l l y , safety

rules should r e f l e c t a sense o f f a i r play to the extent they do not
in frin g e on the basic rig h ts of in d iv id u a ls .

143

Experience shows th a t beyond a doubt, d is c ip lin e is also a
v it a l p art of safety programs.

There is no such thing as a safety

program th a t has been successful through s e llin g and education alone.
Common sense convinces most workers to fo llow r u le s , but there are
always some who ignore them.

In the fin a l a n a ly s is , action must

be taken to get a t the f i v e or ten percent o f the group who f a i l
to conform before th is increases to fo r t y percent, and ev en tu ally
rules become meaningless.

The choice is to ignore the v i o la t i o n ,

lower the safety standards or i n s is t upon l iv i n g up to the ru le s .
In a d d itio n , c o rre c tiv e d is c ip lin a r y action usually helps prevent
recurrence of the same v io la t io n by c a llin g a tte n tio n to the f a c t
that a safety ru le has been v io la t e d , and impresses employees th a t
safety is part o f t h e i r job.
tions cannot be to le ra te d .

I t also emphasizes th at s a fe ty v i o la ­
I f the ru le is f a i r and im p a r tia lly

and uniformly a p p lie d , i t also builds respect fo r supervisors.

143Ibid. , p. 104.

^441b i d . , pp. 105-7.

144

68
Purchasing
The need f o r appropriate procedures to assure th at equipment,
products, or services purchased conform to necessary s a fe ty standards
has long been recognized.

Regardless o f the extent to which th is

policy is follow ed, i t is not uncommon to fin d the purchasing depart­
ment in s is tin g upon sa fety standards, and safety-resp on sib le persons
to be involved in product s e le c tio n , brand or supplier preference,
review and approval o f purchase orders as they p erta in to sa fety
items, and actual purchase o f both technical and sa fe ty items.
A c tu a lly , the purchasing t r ia n g le of q u a li t y , d e liv e r y , and
price could well be considered a rectangle also including s a fe ty .
The in d u s tria l purchaser is a prime in te rfa c e with s u p p lie rs , and
must insure th a t a l l products meet safety requirements.

145

This

requires a tte n tio n to major safety standards, obsolete standards,
and minor hazards such as housekeeping items and p ro te c tiv e equip­
ment.^®

Compliance to p a r t ic u la r safety standards is often w r itte n

into purchase orders fo r equipment and in to contracts with parts
vendors,147 even though some suppliers may object on the grounds
that a f t e r t h e i r "product" is received i t may be changed or d is mantled fo r a p a r t ic u la r use.

148

145"Purchasing— OSHA's Man in the M iddle," Purchasing, Vol.
74, No. 3 (February 6 , 1973), p. 37.
1dfi
Bernard A. Hoye, "Prevention is the Best Cure," Production,
December, 1972, p. 84.
147National Safety Council, "OSHA Act— What I t Should Be,"
op. c i t . , p. 2.
14®Gerald F. S can nell, "OSHA to Stress Performance Standards,"
Purchasing, Vol. 74, No. 3 (February 6 , 1973), p. 47.

69
There are some p ra c tic a l and v a lid reasons why a purchasing
agent might want to include safety "clauses" in the purchase order.
I t helps to circumvent a hazardous s itu a tio n which might r e s u lt from
noncompliance to prescribed safety standards, and reduces the possi­
b i l i t y th a t safety regulations would be v io la te d .

I t increases the

p ro b a b ility th at products and services conform to safety standards,
by specifying th a t a c t i v i t i e s by su p p lier on his premises are in
accordance with safety rules and regulations o f his f ir m .

149

In

many cases i t means the supplier w i l l indemnify and hold harmless
the buyer from a l l damages.

Such s p e c i f ic it y also assures con­

formance to safety requirements th a t w i l l meet the purchasing fir m 's
in te rp re ta tio n of what is necessary, or the in te r p r e ta tio n of
testing lab orato ries l i k e Underwriter Laboratory or Factory Mutual
Engineering Corporation, ra th e r than some general impression by a
supplier, which may or may not comply w ith the act.

150

Safety Equipment, Devices, or P ro tective Items
Even though a m a jo rity o f occupational accidents have been
a ttrib u te d to unsafe acts o f workers, the importance o f hazardous
physical conditions is extremely important.

There is a high poten-

t i a l of accident s e v e r it y , and i ll- a d iv s e d acts might not

151

or be impossible under a s a fe r set o f physical conditions.

occur
There

are a great many instances o f hazards which are unnoticed, unheeded,
^^John D. Jackson, "Let the Standards Do the T a lk in g ,"
Purchasing, Vol. 74, No. 3 (February 6 , 1973), p. 47.
^^ " L iv in g with OSHA," op. c i t . , p. 79.
1 *11

Simonds and Grimaldi, op. c i t . , p. 197.

70

or not known about.

As mentioned in Chapter I I , 65-75 percent o f the

workers in two d if f e r e n t surveys were exposed to p o te n tia l hazards,
but only 25 percent were protected adequately.
The evaluation and control o f mechanical and physical hazards
encompass design, construction, o peration, and maintenance, and these
functions are mutually interdependent.

Good design can reduce hazards

of construction and operation and w i l l minimize maintenance.

152

However, care must be taken to guard against a "hard hat and goggles
approach" of concentrating on v i s i b l e , simple s a fe ty .

Safety glasses

and hard hats, fo r example, are inexpensive but they are ta n g ib le .
At l i t t l e expense, the company can present visual evidence o f it s
desire to protect the employees, w hile more dangerous hazards remain
uncorrected.

I t costs less to supply a rubber s u i t , mask, and

gloves fo r leaking acids than to re p a ir the equipment.

153

The f r e ­

quent complaint th at safety slows down production is also an
in v alid supposition.
not have th is e f f e c t .

I t can be shown th a t w ell devised designs do
154

Guarding and Safety Equipment
Machine caused in ju r ie s are important because they are more
l ik e l y to be severe, involving permanent or p a r t ia l d i s a b i l i t y to
hands, f e e t , and eyes.

i K-a

1

The argument is advanced th at since the

Davidson, op. c i t . , p. 122.

Jean Surry, In d u s tria l Accident Research, A Human Engineer­
ing Appraisal (Toronto: U n iversity of Toronto, 1969), p. 122.

71

National Safety Council indicates only 15 percent o f a l l accidents
are from mechanical sources,

155

l i t t l e can be gained by guarding,

and the money would be b e tte r spent on prevention o f the other 85
percent, re s u ltin g from unsafe ac ts.

However, these figures r e f l e c t

the records of la r g e r manufacturing firm s , and such firms have gone
much fu rth e r in guarding than the average p la n t, and t h e i r p o lic ie s
represent good or best conditions.

F u rth e r, there are many other

reasons why any w ell rounded safety program would make machine
guarding a primary p re re q u is ite .

The high percentage o f permanent

p a rtia l d i s a b i l i t i e s involve high costs and large time losses.

It

also v i s ib ly shows in t e r e s t in a c tu a lly providing a safe place to
work, which provides a very real psychological impact upon workers.
Machine builders are prodded to redesign equipment to incorporate
new safety fe a tu re s .

F in a l l y , many guards are homemade and b u i l t

within the o rg an iza tio n , thereby g re a tly enhancing cost tra d e­
o f f s . 156
On a general o verall b as is , guarding and/or sa fety equipment
should meet a number o f c r i t e r i a .

I t should protect against energy

sources in as many situ atio n s as possible.

I t should not in t e r f e r e

with performance e it h e r to make the task i n f e r i o r or harder.
should be as fo olproo f as possible.

It

Where an e rro r can possibly be

made, i t is only a matter of time u n til the worker makes i t .

It

should provide comfort to the extent th a t prolonged i r r i t a t i o n is
155National Safety Council, "Osha A c t, What I t Should Be,"
op. c i t . , p. 122.
156Blake, op. c i t . , pp. 175-81.

72
minimized.

I t should be “user independent" so th a t workers, do not

have the option to ignore, fo r g e t, or otherwise not use the equipment or device.

I t should be as inexpensive as possible.

157

Personal P ro tective Equipment
Although the primary th ru st in any accident-prevention e f f o r t
is the correction o f the physical environment so th a t accidents
cannot occur, i t is also necessary fo r economic or expeditious
reasons to safeguard personnel with sp ecialized p ro te c tiv e equipment.

158

But i t should be emphasized th a t personal p ro te c tiv e

devices r e la tin g to head p ro te c tio n , face and eye p ro te c tio n ,
re sp ira to ry p ro te c tiv e equipment, hand, f o o t , and leg p ro tecto rs ,
and p ro tectiv e clothing should always be thought o f as a " la s t thin
lin e of defense."

P ro tective devices do nothing to reduce the

hazard; they merely set up a f r a i l b a r r ie r against i t which must be
constantly maintained, watched, and guarded.

Both employers and

employees should keenly r e a liz e th a t f a i l u r e of the device, or
f a i l u r e to use i t , exposes one to the hazard.

159

The use o f these

devices should not s u b s titu te fo r inspections, corrections o f con­
d itio n s , and introd uctio n o f engineering methods.
In th is co n text, personal p ro te c tiv e equipment is only one
necessary and important consideration in a safety program.
must also be exercised to monitor th is phase o f the program.

"*^Surry, op. c i t . , pp. 120-23.
1R8
l *;q

Simonds and G rim a ld i, op. c i t . , p. 327.

Blake, op. c i t . , pp. 320-21.

Care

73
Employees fre q u e n tly r e s i s t the discomfort o f wearing personal
protective devices, tamper with them, and thereby may not b e n e fit
from the optimum p rotection possible.

I t is v i t a l to determine

th e ir real o b jectio n s, and overcome them through lo g ic and, i f
possible, provide them w ith a choice o f a lte rn a te devices or
designs.^®®
Plant Layout and Design
Plant layout should include f u l l provision f o r the safety
of the worker as w ell as production requirements, and recent trends
indicate th is has influenced a r c h ite c tu ra l designs accordingly.
Factors considered include such things as p lan t size and h e ig h t,
remodeling, e x its and s t a i r s , platforms and flo o r openings, l i g h t ­
ing, v e n t i l a t i o n , and noise.

In s h o rt, the process involves

(a) placing the r ig h t equipment, (b) coupled w ith the r i g h t method,
(c) in the r ig h t place, (d) to permit the processing of a product
u nit in the most e ff e c t iv e manner, ( e j through the sh o rtest possible
distance, ( f ) in the shortest tim e , and (g) w ith a minimum of
hazards and maximum safety."*®'*
Training and Communication
A well rounded and e f f e c t iv e safety program embodies the
selection and placement o f people on the job according to p h y sica l,
s k i l l , and mental a b i l i t i e s ; thorough analysis of jobs w ith s p e c ific
in s tru c tio n s , d ir e c tio n s , and procedures; o rie n tin g people to fo llo w

^®®Simonds and Grimaldi, op. c i t . , p. 355.
*®^Blake, op. c i t . , pp. 124-25.

74
these in s tru c tio n s ; reasonable and knowledgeable supervision;
proper work area la y o u t; and adequate storing and handling o f
m aterials.

162

In order to "touch a l l bases" in the same manner, a

form of systematic tra in in g is an inescapable requirement i f workers
ICO
and management a l i k e are to do t h e i r jobs e f f i c i e n t l y and s a fe ly .
Regardless of how much ap titu d e and experience a person may have
for the job to which he is assigned, i t is necessary to impress
in d e lib ly on his mind th at there is a standard, safe way to carry
on most a c t i v i t i e s .

Faulty safety a t t i t u d e , in a t t e n t io n , lack of

i n t e r e s t , w orry, and impulsiveness are the trig g e rs th a t set o f f
many a c c i d e n t s . W h e n combined w ith a working environment f i l l e d
with hazards, and the i n a b i l i t y to recognize and avoid them, a
combustible s itu a tio n fraught with accident p o te n tia l is created.
Some authors d is tin g u ish between s a fe ty education and
tra in in g .

Within th is framework safety education consists of devel­

oping safety mindedness, awareness and understanding o f the importance
of elim in ating accidents, and mental alertness in recognizing and
correcting conditions and practices th a t might lead to in ju r y .
Safety tra in in g pertains to developing the s k i l l o f a worker in the
use of safe work techniques and p ra c tic e s , and in th is sense,
excludes in s tru c tio n a l programs and courses to increase knowledge.
But in the f i n a l analysis the two are not completely separable;

^^ G id e l , op. c i t . , p. 42.
Io
Simonds and G rim ald i, op. c i t . , p. 381.

I

DeReamer, op. c i t . , p. 64.

each contributes to the o ther.

165

A ll accident prevention work,

whether or not ed ucationally intended, is nevertheless educational
to the employees involved.

Well tra in e d and careful men avoid in ju ry

on dangerous work, and the untrained and careless may be in ju red
in the safest possible conditions.

Safety education, then, does not

re a lly r e f e r to education in i t s commonly understood sense, but to
methods whereby management and i t s supervisory s t a f f t r a i n and
in s tru ct employees and encourage and enforce the observance of safepractice ru le s .

1 fifi

The important underlying premise is th a t i f men

can learn to understand t h e i r responses in terms o f fa tig u e and
moods, i t is believed they w i l l make fewer errors and have fewer
..
. 167
accidents.
The People Involved in
Safety Training
Safety tra in in g varies widely with respect to method,
content, q u a l i t y , q u a n tity , and source of in s tr u c tio n , and according
to size o f company, types of jo b s, and management emphasis. I t
1gg
may be given by supervisors, or by s p e c ia lis t s .
S i m ila r ly , such
tra in in g can be directed a t management or supervisors and/or
employees.

The former deal personally with actual operations and

have close d a ily contact w ith employees.

I t is an important part

of t h e ir re s p o n s ib ility to f i r s t know the proper, e f f i c i e n t , and
^ ^ B la k e , op. c i t . , pp. 259-61.
^ ^ H e in r ic h , op. c i t . , pp. 186-87.

1®7Surry, op. c i t . , p. 109.
I cp
Simonds and Grimaldi, op. c i t . , p. 381.

76
safe way to do each jo b , and then to t e l l employees what to do and
how to do i t , supervise them on the jo b , and " s e ll" them on s a f e t y J 69
This requires th a t supervisors not only be tra in e d to recognize
hazards and elim in ate or control them, but also how to communicate
safety knowledge and p ractices.

In the case o f employees, tra in in g

should teach them not only th a t safety is w orthw hile, but precisely
what dangers in t h e i r l in e o f work should be guarded a g a in s t, those
specific things th a t apply to in d ivid u al tasks th at they must do in
everyday safe p rac tice to avoid i n j u r y . ^ 9
Safety in s tru c tio n should involve new employees, tr a n s fe r s ,
and the re tra in in g o f present employees on a sustaining basis.

For

example, safety rules and procedures should be set down in w ritte n
form covering each jo b , and th is m aterial should be used as a basis
fo r ins tru ctio n fo r new employees before receiving job tr a in in g or
starting w o r k . ^

Studies in d ic a te th a t such tr a in in g reduces the

accident l i a b i l i t y during the f i r s t few months o f employment, which
c h a r a c te r is tic a lly have p a r t ic u la r ly high r a t e s , although i t does
not completely remove the higher i n i t i a l accident l i a b i l i t y compared
to levels achieved l a t e r .

Training also speeds up the ra te o f

acquisition of safety s k i l l s , which also occurs during on-the-job
experience. 172
169U .S ., Department of Labor, "Guidelines fo r S e ttin g Up Job
Safety," op. c i t . , p. 2.
^ ^ H e n ric h , op. c i t . , p. 187.
171
National Safety Council, "Management P o lic ie s on Occupa­
tional S a fe ty," op. c i t . , pp. 78-79.
172

Surry, op. c i t . , p. 131.

77
Retraining is necessary no matter how thorough the o rig in a l
tra in in g .

As time passes, good work habits d e t e r io r a t e , and unsafe

ones are acquired.

Employee turnover changes workforce composition.

Working conditions change, sometimes in such subtle fashion th a t they
go unnoticed.

The r e s u lt is a corresponding reduction in work

q u a lity and increased accident experience.

173

Studies show there

is apparently no long-term e ffe c ts of tr a in in g on accident ra te s .

174

Consequently, i t is considered good p ractice to bring supervisors
together at re gu lar in te rv a ls in order to refresh t h e i r s a fe ty knowl­
edge and in t e r e s t .

As p art o f t h e i r regu lar responsibi1i t y and work

practice they should be required to continuously check worker safety
habits as well as job hazards, to r e t r a in workers and provide sup­
plemental safety re fre sh er meetings, and to reemphasize and enforce
safety rules.

175

Training Techniques
There are many methods fo r imparting in s tru c tio n a l informa­
tio n .

The most prevalent include le c tu re s , shop t r a in i n g , and

discussion groups.

Lectures involve planned programs fo r la rg e r

groups, and are conducted by a speaker.

Shop tra in in g includes

(a) "vestibule" or outside-the-workshop programs fo r introductory
or "breaking in" purposes, and (b) on-the-job in s tr u c tio n , usually
conducted by the supervisor or foreman, fo r the purpose of both
173

Simonds and G rim ald i, op. c i t . , p. 388.

^^Surry, op. c i t . , p. 131.
1 7R

Simonds and Grimaldi, op. c i t . , p. 388.

78

indoctrination and the a c q u is itio n o f a d d itio n a l s k i l l s .

Discussion

groups are generally informal and encourage p a r tic ip a tio n and personal
1 yg

involvement.

O rd in a rily these methods in some way involve

personal contact and meetings, educational m aterial in the form of
posters, pamphlets, tra in in g f i l m s , oral and w r itte n in s tr u c t io n ,
employee handbooks or manuals, b u l l e t i n board n o tice s, and sa fety
record inform ation.
Training fo r supervisors w i l l usually also include safety
courses, contacts with a u th o r itie s and teachers, f i r s t aid in s tr u c tio n ,
meeting with suppliers and public agencies, and subscriptions to
safety publications and p e rio d ic a ls .

Further tra in in g can be gained

through safety inspections, in v e s tig a tin g accidents, and making a
job analysis fo r safety procedures. ^77
There is increasing stress placed upon formal t r a in in g pro­
grams fo r professional s t a f f s , supervisory l e v e ls , and employees,
1 yo

and there are some very important reasons.

F i r s t , a recent survey

in C a lifo rn ia by the BLS shows th ere was only s l i g h t l y g rea ter than
one chance out of ten th a t an employee entering any firm w i l l
receive safety tra in in g in the f i r s t few days o f employment.

The

report suggested th at sta tu to ry provisions to furnish jo b -s a fe ty
and health tr a in in g , and worker recognition o f safety v io la tio n s

176Ib id . , pp. 381-86.
1 77

National Safety Council, "Management P o lic ie s on Occupa­
tional S a fe ty," op. c i t . , p. 79.
^7^National Safety Council, ""OSHA Act and Today's Safety
Training Needs," op. c i t . , p. 47.

and in ju r ie s would help improve upon th is .

179

Second, increased

emphasis is placed on the return of the basics of a good safety
program— the three E 's:

engineering, education, and enforcement.

I gg

Third, working conditions today are so complex and s a fe ty so compre­
hensive, complicated, or new to most firm s , th at such things as
mini-seminars, courses, meetings, luncheons, and committees are needed
to inform management and s a fe ty personnel o f the l a t e s t standards, as
well as surveilance evaluation and protection techniques.

Fourth,

as safety standards have become more complicated, workers have not
necessarily understood the standards, or tra in e d to respond to them
in a meaningful manner.

181

This requires planned day-to-day safety

tra in in g e f f o r t s , not ju s t o rie n ta tio n of new h ire s .

F i f t h , mere

compliance to safety standards does not guarantee a good safety
record.

In summary, there is g re a te r emphasis upon a balanced,
1go
coordinated, formalized s a fe ty program.
Safety Communication and Promotion
Good safety communication is more than a process of conveying
information e ith e r o r a lly or in w r it in g .

I t must be regarded as an

e n tire process which changes a ttitu d e s and influences behavior by
the "whole meanings" th a t are conveyed by words, ac tio n s, expressions,
personalities and moods, and "c lim a te ."
179

Employees respond to safety

Gordon, Akman, and Brooks, op. c i t . , pp. 146-65.

^ ^ N a tio n a l Safety Council, "OSHA Act and Today's Safety
Training Needs," op. c i t . , p. 47.
^ G i d e l , op. c i t . , p. 45.

Living with OSHA," op. c i t . , p. 79.

80
in stru ction in terms of the meaning the t o ta l s itu a tio n has fo r
them.183
Getting men to work s a fe ly is p rim a rily a sales jo b .

Super­

visors can be compelled to estab lis h safe practices or enforce
ru les , and workers to comply accordingly.

But only in t e r e s t and

desire to do so by both can bring superior accomplishment.

In ad d i­

tio n , sa fe ty must be l i t e r a l l y sold to everyone in the o rg an iza tio n .
Top management, fo r instance, must furnish executive leadership fo r
safety to get f a r .

This requires conviction th a t the fir m 's accident

record can be s u b s ta n tia lly improved upon, th a t other organizations
have found th a t safety pays, and they can do lik e w is e , and th a t
reasonable e f f o r t can achieve a good safety performance.

The super­

visory s t a f f ca rrie s out the w i l l and p o lic ie s of management and
w ill devote a tte n tio n to what is emphasized.

They are the planners

and techn ician s, as w ell as being responsible fo r fu rn ishin g d ir e c tions and leadership fo r workers.

184

Workers are keenly aware o f

th e ir a ttitu d e s and how they adhere to s a fe ty rules and p ra c tic e s .

185

Workers themselves must be motivated to perform s a fe ly f o r any
number o f reasons— s e lf-p r e s e r v a tio n , m aterial gain, p ra is e , appro­
bation or d is tin c tio n o r , conversely, disapproval, or a sense of
re s p o n s ib ility or lo y a lt y .

183

1 fifi

DeReamer, op. c i t . , pp. 64-67.

18^Blake, op. c i t . , pp. 222-24.
1R5

DeReamer, op. c i t . , p. 66.

188Blake, op. c i t . , p. 225.

81
S e llin g the concept o f safety and g e ttin g personal involvement
necessitates an integrated and cohesive plan of attack to be success­
f u l.

Such a plan begins with d e f i n i t e tr a in in g courses, personalized

tra in in g and supervision, and by f a c i l i t a t i n g p a r tic ip a tio n in
safety functions such as committee work and inspections.
a c t iv it ie s are supplemented by "safety s e llin g :

These

in the form o f:

plant newspapers containing in fo rm a tiv e , i m p a r t ia l, and p ra c tic a l
information; messages in pay envelopes, e s p e c ia lly those p erta in in g
to special announcements, p riz e s , or fam ily "pressures"; displays o f
interesting objects th a t cause or prevent accidents; b u l l e t i n board
communications r e la t in g to r u le s , standards, or safety performance;
and signs and slogans ap p ro p ria tely lo c ate d , tim ely and p e rtin e n t.
Safety campaigns and contests to achieve a s p e c ific purpose, to
respond to special s itu a t io n s , or to develop a s p i r i t of r i v a l r y in
the in te r e s t o f sa fe ty are also used exten sively and with e ff e c tiveness.

1R7

Visual reminders are the more common methods because

they give factual information which is e a s ily grasped, presented in a
manner which is a t t r a c t iv e to the eye, and e f f e c t i v e .

188

Regardless

of which of these s e llin g techniques is used, however, e it h e r i n d i ­
vid u a lly or in concert, care should be exercised th a t safety programs
should not consist so le ly or d is p ro p o rtio n a lly of the "promotion"
e ffo rts .
The techniques o f tra in in g and the re s u ltin g e ffe c ts have not
apparently been studied in respect to accident reduction.
187Ib id . , p. 231.
188

Simonds and Grimaldi, op. c i t . , p. 393.

I t is often

82
suggested th a t campaigns promoting general safe behavior without
indicating means o f avoidance are not substantial
"Be C a re fu l," "Danger."

e ffe c tiv e ; e .g .,

However, studies show p o s itiv e re s u lts do

occur fo r almost any employee-involving campaign, e s p e c ia lly when
f i r s t inaugurated, but not fo r the obvious reasons (possibly because
of a "Hawthorne E f f e c t " ) .

Other research has shown programs with

sp e cific information and suggested action had lim ite d but p o s itiv e
effectiveness.
In addition to the need fo r sound and p e rtin e n t premises,
studies also in d ica te th a t several d if f e r e n t media should be used,
and "with va ria tio n s on a theme" ra th e r than simple r e p e titio n .
Messages ra ising fears o r displaying horrors are less e f f e c t iv e than
innocuous messages.

Even more re v e a lin g , w hile promoting safety is

excellent fo r facts and inform ation, i t does not d ir e c t ly modify
behavior.

D ire c t appeal to the workers themselves is p referable to

d iffu se or coiranunity appeal.

The higher the relevance the worker

believes the information to have, and the more predisposed an i n d i ­
vidual is to accept safety precautions, the more appropriate the
response.

190

F in a l l y , the more employee p a rtic ip a tio n in a safety program,
the more e f f e c tiv e i t w i l l be.

191

Research indicates behavior modi­

fic a tio n is enhanced by personal involvement in demonstrations,
being asked to t r y various safety practices and fo r opinions, and
189

Surry, op. c i t . , p. 132.

190ibid.
191

Blake, op. c i t . , p. 230.

supplying and loaning necessary equipment.

192

Therefore, the

organized sa fety program should include as many a c t i v i t i e s in which
the workman can p a rt ic ip a t e as possible:

contests and campaigns,

meetings and safety s tu n ts , f i r e brigades, plant inspectio n, accident
in v e s tig a tio n , job safety suggestion systems, safety in v e n to rie s , and
safety committees.

I t also necessitates le g itim a te employee feedback

to gauge reaction to such things as ru le s , safety meetings and/or
committees, and b u lle t in s .

This involves reports from s a fe ty per­

sonnel, inspectors, union re p res en tative s, and the medical s t a f f ,
foreman canvasses, suggestion systems, and a safety inventory or
questionnai re.

193

Help from Outside Sources
Safety engineers, s ta te agencies, insurance companies, pro­
fessional associations, and organizations such as the National Safety
Council have fo r years played an important ro le in the accident pre­
vention programs fo r in d ivid u al firm s.

Many perform periodic

inspections to locate p o tential hazards, t r a in management and
employees, and counsel managements on how to prevent accidents.

It

is not uncommon, fo r example, fo r insurance companies to spend
2 to 2 1/4 percent of the insurance premium d o lla r fo r the prevention
of accidents.

194

Yet a recent survey in C a lifo r n ia

that only o ne-half of

the firms were members o f

l Q?
Surry,

op. c i t . , p. 133.

^ ^ B la k e ,

op. c i t . , p. 230-35.

^^Simonds and Grimaldi, op. c i t . , p. 21.

by

the BLS showed

the Safety Council,

84

and only 34 percent o f the organizations were members o f trade associations, or job safety and health organizations.

195

Union P a rtic ip a tio n in Safety Programs
While organized labor has occasionally been concerned about
safety and h e a lth , h i s t o r i c a l l y i t has not given the subject high
p r io r it y in e it h e r i t s l e g is l a t i v e or i t s c o lle c tiv e bargaining goals.
Members have not asked fo r these services to a great extent and, more
often than n ot, safety and health demands would be traded and bartered
for wages.

In a d d itio n , before the OSHA Act there was l i t t l e

leverage

to use on employers, and the union usually j u s t could not manage the
safety bargaining e f f e c t i v e l y .

Both sides wanted to do something

about s a fe ty , but somehow never did.

196

Those unions th a t have included sa fe ty in the c o lle c t iv e
bargaining process, such as the In te rn a tio n a l Brotherhood o f E le c t r ic a l
Workers (IBEW), public u t i l i t i e s , UAW and Brewery Workers, were f r e ­
quently lim ite d to token clauses in the contract s tip u la tin g the
re s p o n s ib ility of a firm fo r safety in general terms.

197

Usually

there was no one a t the bargaining ta b le q u a lifie d by experience and
tra in in g to specify safety procedures.

198

D if f e r e n t lev els o f safety

consciousness or awareness hindered n eg o tiatio n .
195

The most recent

Gordon, Akman, and Brooks, op. c i t . , pp. 152-53.

1gc

OSHA and the Unions, Bargaining on Job Safety and H e a lth ,
Special Report (Washington, D.C.: Bureau of National A f f a i r s , I n c . ,
1973), pp. 1-7.

197Ibid.
198 Simonds and Grimaldi , op. c i t . , p. 54.

85
Bureau of National A f f a ir s survey of safety and health clauses i n d i ­
cated 65 percent of these sp e cifie d some company r e s p o n s ib ilit y ,
and in tu rn , 70 percent o f the 90 percent were lim ite d to a general
statement of company in t e n t to provide safe and/or h e a lth fu l working
conditions and to e lim in a te causes o f accidents.

In other words,

most contracts recognized management's basic r e s p o n s ib ility fo r
safety and l e f t i t at t h a t .

199

However, i t g en erally is acknowledged th a t i t is necessary
to have union backing in the enforcement of safety re g u la tio n .
Workers re s is t safety rules and p ra c tic e s , and are in c lin e d to
gamble and take a chance, or have a tremendous tolerance fo r unsafe
conditions.

Despite the fa c t th a t management cannot s h i f t i t s

re s p o n s ib ility f o r providing a safe place to work and safe work pro­
cedures, the union must now be more concerned with the w e lfa re of
its members, and thereby also has to shoulder safety r e s p o n s ib ilit ie s ,
including the prodding o f management, in safety matters.
The b uilding trades have made genuine progress in accepting
the challenge o f worker safety and h ealth.

They have added profes­

sionals to t h e ir s ta ffs and are undertaking safety tr a in in g o f t h e i r
?m
members.
The UAW has a s t a f f o f safety o f f i c i a l s a t t h e i r i n t e r ­
national headquarters.

They conduct tra in in g programs fo r local

union represen tatives, and send them a bi-monthly p u b lic a tio n ,
199

OSHA and the Unions, Bargaining on Job Safety and H e a lth ,
op. c i t . , p. 17.
*^Simonds and G rim a ld i, op. c i t . , pp. 54-55.
?m

Guenther Resigns, Ref l ects on OSHA," op. c i t . , p. 49.

86
"Safety and Health News."

Safety engineers and in d u s tria l hygienists

make in -p la n t surveys and channel corrections through p la n t management.

202

However, a t present only f i v e unions out of the approximately

118 national and in te rn a tio n a l unions o f the AFL-CIO have a t le a s t
one f u l l - t i m e occupational safety d ir e c t o r , and only nine additional
unions have the r e s p o n s ib ilitie s assigned to one person on even a
part-time basis.

Only about 20 percent are providing representatives

and fin a n c ia l assistance to p a rt ic ip a te in s e ttin g sa fety and health
standards.

The unions in d ic a te they are over-loaded w ith responsi­

b i l i t i e s , i t is costly to be away from the job (th e company usually
does not pay them), i t is d i f f i c u l t to s e ll other committee members,
or even to prepare p ro p e rly , e it h e r v e rb a lly or in w r i t i n g , and they
may not have people on t h e i r s t a f f who are te c h n ic a lly q u a li f i e d .

203

The federal law on the scope o f the duty o f an employer to
bargain about job sa fe ty and health issues in good f a i t h appears
to be about as c le a r as labor re la tio n s law ever gets.

The NLRB held

safety issues to be mandatory subject to c o lle c t iv e bargaining under
the T a ft-H a r tle y Act.

Safety was no longer an exclusive and non-

deleqatable r e s p o n s ib ility o f a company.

Unions could ask fo r

bargaining, even though a company might consider i t c o n f id e n t ia l,
could request in - t h e - p la n t safety bargaining r ig h t s , could make it s

Peter J. Sheridan, "Woodcock Charts UAW's Safety Objectives
for 1973," Occupational Hazards, Vol. 35, No. 2 (February, 1973),
pp. 39-45.
2<^R obert M. W ilk in s , "Union P a rtic ip a tio n in Developing
Safety Standards," National Safety News, Vol. 7 No. 5 (May, 1973),
pp. 56-57.

87
own time studies when the jobs in question were the subject of pending
safety g rievances.2^*
A recent survey o f labor-management agreements ind icates th a t
there is a broad range o f safety clauses when they are so included.
Sample provisions found in various contracts include:

compliance to

standards, information about hazards to employees, formation of j o i n t
safety and health committees, opportunity of union repres en tative to
make safety inspections, p a r tic ip a te in the in v e s tig a tio n of lo s t time
accidents, and to have access to information about (a) surveys by
state and federal inspectors, (b) measurement o f contaminants, and
(c) company plans and expenditures.

Also covered are company spon­

sored p ro tectiv e equipment, consultation about ru le changes, special
procedures fo r disputes, company pay fo r union representatives on
j o i n t safety committees, and r ig h t o f the employee to be relieved
from unsafe jobs.
there is l i t t l e

Because of sheer volume, i f fo r no o ther reason,

support fo r putting d e ta ile d sa fe ty and health stan­

dards in to management-union contracts.
negotiations on d e ta ile d standards.

Nor is there much support fo r

205

The Im plications o f Firm Size Upon Safety
There is a general tendency fo r the incidence and scope of
one

safety a c t i v i t i e s to increase with the size of a company.
Notwithstanding any differen ces or "exceptions" caused by such things
2t^ QSHA and the Unions, Bargaining on Job Safety and H e a lth ,
op. c i t . , pp. 51-56.
205I b i d . , pp. 17-22.
onfi

Simonds and Grimaldi, op. c i t . , p. 22.

88
as managerial competence or a t t e n t io n , the uniqueness of ind ustries
or plants in terms of technology, the extent and nature o f inherent
work hazards, the presence and activeness of committees, and whether
or not a firm is

a sin gle plant

with operations under onero o f, sup­

porting evidence

is substantial and convincing.

F i r s t , as a recent BLS survey in C a lifo r n ia in d ic a te s , the
larger the firm the g reater the lik e lih o o d th a t job safety and health
resources w i l l be a v a ila b le as part o f the ad m in is tra tiv e overhead o f
the establishment.

In firms of over 250 employees, in nine chances

out of ten there

w i l l be both f i r s t aid stations andsafety committees

present.

other hand, in

On the

companies with 49 or less employees,

there w i l l be seven chances out o f ten th a t n e ith e r a c t i v i t y w i l l be
avai la b le .
Second, the smaller the f ir m , the g re a te r the p ro b a b ility
that no one person has a c tu a lly accepted r e s p o n s ib ility fo r accident
prevention work.

In plants with under 200 employees, i t is l i k e l y

to be the owner or p la n t superintendent, usually with i n f e r i o r
resu lts.

208

In a l l

fa irn e s s , there is usually n e ith e r the time nor

expertise to understand a l l

the safety requirements or to assure f u l l

compliance; he must

re ly h eavily onoutside

s c ru tin iz e supplier

statements and his

advice, and he must

ownproducts

and services sold

^ ,
...
209
to la rg e r firm s.
207

Gordon, Akman, and Brooks, op. c i t . , pp. 146-51.

^^Simonds and G rim aldi, op. c i t . , pp. 59-60.
^ ^ H a r le y N. T r ic e , "Meeting OSHA Act Standards, A Guide fo r
Small Manufacturers," National Safety News, Vol. 107, No. 3 (March,
1973), pp. 50-52.

89
As mentioned e a r l i e r , personnel departments as a c e n tra liz e d
function are not generally the dominant pattern u n til companies reach
a size of 200 employees,

210

and/or sales increase to $3 m illio n .

211

In a d d itio n , even though personnel duties in sm aller firms do not
require f u l l - t i m e e f f o r t , and safety is often the b e n e fic ia r y , f r e ­
quently the personnel manager is h ea vily burdened with o th e r work
which is more pressing.

212

A s im ila r pattern exists in the case of safety s p e c ia lis t s .
A rough rule o f thumb is th a t there may be one f u l l - t i m e s p e c ia lis t
for each 2,000 employees.

However, as also previously discussed, a

plant with 1,500 workers might have a f u l l - t i m e safety s p e c ia lis t
together with a h a lf-tim e secretary and as many as three a s s is ta n ts ,
or a plant handling dangerous m aterial might haveone even though they
have but 300 employees.

Very large companies with s iza b le operations

in several c i t i e s usually have a safety d ir e c to r fo r o v e ra ll super­
vision of the safety program, and a s p e c ia lis t and one or more
assistants a t each p lant.

213

T h ird , as mentioned in Chapter I I , a recent survey indicated
firms with under 250 employees had almost double the number of prorated
re h a b ilit a t io n cases as did large firms with 500 or more employees;
e . g . , 4.95 to 5.75 cases per 10,000 employees as compared to 3.18 cases.
210

Wasmuth e t a l . , op. c i t .

^ ^ F re n c h , op. c i t . , pp. 590-91.
21 2

Simonds and Grimaldi, op. c i t . , p. 60.

^ ^ Ibid. , pp. 57-60.

90
In a d d itio n , the number o f accidents is ju s t as high fo r small size
employers.

214

Many small firms with processes not in h eren tly

dangerous have lacked serious accident control and have accident f r e quency rates o f 30 to 100 or more.

215

I t is fu r th e r estimated th a t

in plants with less than 200 employees these average ten times higher
than in operations with 5,000 or more.

? 1 fi

As pointed out by the American Society o f Safety Engineers
as part o f t h e ir o f f i c i a l p o lic y , there is a p a r t i c u l a r ly real need
fo r a strong safety program th a t would include a l l small businesses,
and i t is e t h ic a lly and morally wrong to omit any employee from such
217

protection.

Employers having less than 19 employees represent

24.5 percent o f a l l workers.

While no o verall data is a v a ila b le on

accident frequency rates fo r small compared to large o rg an iza tio n s,
using the data o f the chemical in d u s try , th is 24.5 percent might
account fo r over o ne -h a lf o f the accidents.

218

I f a l l employers

employing three persons or less were excluded, th is would exempt 47
percent o f the employers and 10 percent of the employees.
214

219

Nicholas, op. c i t . , pp. 59-60.

21 5

Simonds and G rim a ld i, op. c i t . , p. 3.

^ ^ N a tio n a l Safety Council, "OSHA Act, What I t Should Be,"
op. c i t . , p. 123.
217

American Society of Safety Engineers, "Statement of the
American Society o f Safety Engineers on the Occupational Safety and
Health Acts of 1970," ASSE Journal , Vol. 17, No. 9 (September, 1972),
pp. 10-12.
?18

U .S ., Department of Commerce, Economic and Social S t a t i s ­
tic s A dm inistration, S t a t i s t i c a l Abstract of the United S ta te s , 1971
(Washington, D.C.: Bureau o f the Census) , p. 463.

^ ^ N i c h o l a s , op. ci t . , p. 59.

91

Fourth, large concerns employ more workers in s t a f f capaci­
tie s , are in a position to see the economic importance o f accident
prevention, and have developed the best safety programs.

220

As

noted, they are also more l i k e l y to have f u l l - t i m e safety s p e c ia lis t s ,
and a study of Michigan industry shows th is re su lts in s i g n i f i c a n t l y
lower frequency rates:

e . g . , foundries with a f u l l - t i m e safety

s p e c ia lis t averaged 3 . 3 , as compared to 34 w ith o u t; in the automobile
indudstry i t was 1.9 versus 15.7; in the chemical in d u s try , 7.9 to
37.5 versus 2; in f u r n it u r e , 7.9 versus 14.6; and in machinery manu221
facturin g , 3.1 versus 23.
Conversely, there are few fin a n c ia l o r personal resources
available to the small plant fo r safety programs or e x p e rtis e , in
comparison to the tremendous need.
as "Safety Appalachia."

222

These concerns are re fe rre d to

The nature of most small businesses in

which in ju ry frequently is l i k e l y to be d is p ro p o rtio n ate ly larg e is
one involving short run and job shop production with frequent changes.
This makes job hazard analysis and correction d i f f i c u l t , i f not
impossibie.

223

The BLS summarized th a t high accident rates in small firms
can be a ttr ib u te d to a number o f fa c to rs .
220

They do not have f u l l - t i m e

Simonds and G rim ald i, op. c i t . , p. 9.

221 I b i d . , pp. 58-59.
222

Herbert K. Bol1enbacher, "Cooperation Aids Smaller Plants
in OSHA Act Compliance," National Safety News, Vol. 6 , No. 4 ( A p r i l ,
1972), p. 52.
223National Safety Council, "OSHA A ct, What I t Should Be,"
op. c i t . , p. 123.

92
safety personnel, a technical s t a f f , or adequate record keeping or
accounting to determine the costs of accidents.

The small businessman

rarely join s s a fe ty organizations or attends sa fe ty meetings or con­
ferences, thereby lim it in g his access to valuable information and
assistance.

There are few employees in these firm s , and they

normally do not have a s u f f i c i e n t number o f accidents to meaningfully
demonstrate a p attern .

The companies cannot a ffo rd expenditures

unless immediate and prompt fin a n c ia l return is expected.

F in a l l y ,

there are a very large number of such firms and any sa fety communication or promotion is d i f f i c u l t a t b e s t, but usually nonexistent.

224

Most of these postulates were confirmed in an unpublished study in
1971.225
Summary
The in te n t o f th is chapter has been to provide a review o f
related l i t e r a t u r e and studies appropriate to the s p e c ific topic
areas used to describe the manner in which firms have responded to
the OSHA Act.
cussed:

In th is respect, the follow ing subjects were d is ­

ad m in istrative re s p o n s ib ility and functional alignment,

safety committees, record keeping, counseling and ad visin g ,
inspections, enforcement o f safety rules and d is c i p li n e , purchasing,
??4

U .S ., Department of Labor, Bureau o f Labor Standards,
Safety Subjects, B u lle tin No. 67 (re v . 1956; Washington, D.C.:
Government P rin tin g O f fic e , 1958), p. 11.
Yaghoub S h a fa i-S a h ra i, "An Inq uiry In to Factors That
Might Explain Differences in Occupational Accident Experience of
Similar Size Firms in the Same Industry" (unpublished Ph.D. d is s e r­
ta tio n , Michigan S tate U n iv e rs ity , 1971).

93

safety equipment, devices or p ro tectiv e items, t r a in in g and commu­
n ication, union p a r t ic ip a tio n in safety programs, and the im plications
of size upon s a fe ty .

Based upon the discussion in previous chapters

of (a) the im plications and p a rtic u la rs of the OSHA A c t, (b) the
h is to ric a l development o f occupational safety and health programs,
including events leading to law i t s e l f , and now, (c) the th e o re tic a l
background necessary to recognize and understand any re s u ltin g
changes, the next chapters w i l l cover the study i t s e l f .

CHAPTER IV
DESIGN OF THE STUDY
Introduction
This chapter o utlines the general approach taken to s p e c i f i ­
c a lly determine any discernable occupational sa fe ty and health changes
that had occurred as a re s u lt of the OSHA Act in r e la tio n to the
eleven topic areas discussed in Chapter I .

In th is respect the f o l ­

lowing procedures were used and w i l l be discussed accordingly:
selection of a "population" sample, experimentation grouping, data
co lle ctio n and in te rv ie w guide development, p i l o t study and other
confirmation, and s t a t i s t i c a l technique.
Population Sample
The OSHA Act covers a l l non-government employers, fe d e r a l,
s ta te , or lo c a l, whose a c t i v i t i e s a f f e c t commerce, except fo r those
covered by other safety laws, such as those dealing with mining or
certain forms of tra n s p o rta tio n .

There are no exemptions fo r small

firm s, even those with one employee.

Therefore, because of the very

large number o f firm s , types of businesses, in d u s trie s , and/or
manufacturing processes involved, there were obvious and p ra c tic a l
lim ita tio n s r e la t in g to the selec tio n of an appropriate population
sample fo r th is research p ro je ct.
F i r s t , i t was decided to r e s t r i c t th is study to the s ta te of
Michigan.

Then, in order to provide as broad and unbiased a base
94

95

for analysis as possible, special precaution was taken to assure the
selection o f represen tative firm s .

This necessitated developing a

sample based upon s t r a t i f i c a t i o n s r e la t in g to geographical lo c atio n
and in d u s tria l or business c la s s if ic a t io n .

Geographical considera­

tions, fo r example, included a proportionate number o f firms dispersed
throughout the s ta te according to population d e n s ity --la r g e metro­
politan areas such as D e t r o it , and smaller c i t i e s and ru ra l areas
"outstate."

Industry d iffe ren c es encompassed c la s s ific a tio n s such

as automobiles, equipment, paper products, and r e t a i l i n g ; manufacturing
processes fa b r ic a tio n , mass production, stamping, and s p e c ia lty opera­
tions.

The net re s u lt o f th is procedure was a s t r a t i f i e d selectio n

of 49 firms which i t was f e l t would represent a workable and reason­
able sample.
Experimentation Grouping
I t seemed highly probable th a t not only s p e c ific variables
or business firm c h a ra c te ris tie s might appreciably influence sa fety
related organization behavior in response to the OSHA A c t, but also
that some might do so to a g rea ter extent than others.

For example,

such things as lo c a tio n , c i t y population, type o f industry or
"process," could have such an e f f e c t .

As mentioned p re v io u s ly , one

of the reasons fo r s t r a t i f y i n g the sample accordingly was to m in i­
mize the im plications these factors might have.

However, there are

four other c h a ra c te ris tic s which were believed to have much higher
p ro b a b ility of determining the extent or d ire c tio n of any change:
(1) firm s i z e , (2) firm in ju ry frequency r a t e , (3) whether or not a
firm has a l l operations "under a sin gle ro o f," as contrasted to

96
m u lti-p la n t operations* and (4) i f a firm has received high p r i o r i t y
status fo r special a tte n tio n and inspection by OSHA adm in istrators.
This study uses these four factors as a frame of reference
for describing the impact o f the OSHA Act.

But they are used s o le ly

for th is purpose, and do not in the process attempt to prove or
disprove any s p e c ific hypotheses or necessarily provide any q uanti­
fia b le c o rr e la tio n .

The experimental grouping f o r these four factors

is described below.
Firm Size
I t is believed th at because of such things as the p o s s ib ilit y
of a personnel department, a safety manager, or safety program, and
a v a i l a b i l i t y of exp ertis e or funds, i t would seem lo g ica l to cate­
gorize the firms studied in to four size groups and th a t s ize be
determined by number of employees, since they are the major focal
point o f the OSHA Act.

On th is basis, the size groups consist of

firms with (1) under 50 employees, (2 ) from 51 to 250 employees,
(3) from 251 to 1,000 employees, and (4 ) over 1,000 employees.
There are 12 firms in each of these groups except f o r the
51 to 250 group, in which there are 13.

In a d d itio n , each size

group is p ro po rtion ately d is trib u te d by geographic lo c a tio n ; i . e . ,
29 of the firms studied were in D e t r o it , 8 in suburbs of D e t r o it ,
and 20 in "o u t-s ta te " lo c a tio n s , and there are l i k e numbers o f each
size group w ith in each of these three location categories.

97

Injury Frequency Rate
There is a tendency to associate in ju r y frequency ra te with
safety e f f o r t by a f ir m , and more s p e c if ic a lly i t s safety program.
S im ila rly , i t seems p lausible th at the existence o f a safety program
might determine the extent o f the adjustment to the OSHA Act; e . g . ,
well established s a fe ty programs might mean the existence o f
standards already in compliance.
No attempt was made to s e le c t firms by in ju r y frequency
rate since th is information is not generally a v a ila b le .

However,

i t was possible to obtain th is information from a l l but three firms
while gathering the other data fo r the study.

An examination of

U.S. Department o f Labor Records disclosed th a t s im ila r information
was a v a ila b le fo r 25 percent o f the firms studied.

In each case the

figures were id e n tic a l to those supplied by the in d ivid u al firm s.
The following breakdown was used fo r an alysis:
TABLE IV -1 . — In ju ry Frequency Rate o f Firms Studied.
Frequency Rate

Number of Firms

Under 2.0

12

2 .0 - 5.0

3

5 .1 -1 0 .0

10

10.1-15.0

4

1 5 .1 -2 5 .0

3

2 5 .1 -4 0 .0

9

4 0 .1 -7 5 .0

5

Not a v a ila b le

3

T o ta l

49

98

Operations Under “Single Roof"
or M u lti-P Ia n t
I t appeared th a t whether a firm had a l l o f i t s operations
"under a sin gle ro o f," as contrasted to m u lti-p la n t firm s , e ith e r
individual devisions or corporate o ffic e s might influence firm
response.

Such factors could perhaps influence the degree of

independence or s e l f determ ination, or the a v a i l a b i l i t y of resources
or ex p ertis e, fo r example.
this basis.

Here again, firms were not selected on

As i t turned o u t, 28 were "under a sin gle ro o f," 14

were one of several division s o f a company, and 7 were corporate
offices with "on the premises" plants.
Firms "Targeted" fo r Special
OSHA Attention
OSHA has designated f i v e " ta rg e t industries" f o r top p r i ­
o rity in making inspections to assure compliance to the ac t.

These

are determined by a high in ju ry r a t e , almost double the national
average; e . g . , longshoring ( 7 0 ) , roofing and sheet metal ( 4 5 ) , meat
processing ( 4 0 . 4 ) , mobile homes ( 3 9 . 9 ) , lumber and wood products
(3 4 .6 ).
Special e f f o r t was made to s e le c t targed firms f o r th is
study, and to include as many d if f e r e n t industries as possible.
Eleven firms were selected a t random on th is basis, or almost 23
percent o f the 49 firms studied.

TABLE IV-2.--Targeted Firms Studied.
Location

Firm Size
Industry

Firms
Under
50

51250

1

2511,000

Over
1,000

Detroi t

2

Roofing and sheet metal

3

2

Heavy stamping

1

1

Longshoring

1

1

1

Woodworking

1

1

1

Meat processing

2

1

1

Mobile home

3

2

2

----

3

3

*

Total

11

5

Suburb

1

1
1

1
3

-,

4

Out-State

1

6

*Some of the divisions of larger firms were targeted, but these were in other
states.

100
Data Col le c tio n and Interview Guide
The OSHA Act by i t s very nature is comprehensive, complica­
ted, and has innumerable ra m ific a tio n s .

Because i t could a f f e c t

ju s t about anybody in a business f ir m , or any o peratio n, i t was
decided th a t structured interviews during personal v i s i t s to i n d i ­
vidual firms would prove to be o f g reatest value in g e ttin g f u l l y
descriptive m a te r ia l.

F i r s t , the necessary questionnaire was too

lengthy and involved to mail to firms and expect people to volun­
t a r i l y answer the questions and return i t , or to be able to use the
telephone to f i l l
checking.

in any needed info rm ation , except f o r l a t e r cross­

Second, i t was believed th a t personal interviews would

provide the company respondent with the opportunity to id e n t i f y with
the researcher, and th a t the re s u ltin g rapport would "encourage" a
fre e r exchange o f inform ation.

Fourth, the p r o b a b ility was

increased th a t co n fid e n tia l or s e n s itiv e info rm ation , such as in ju ry
frequency ra te s , might be volunteered and be more accurate.

F ifth ,

i t would be possible to more clo sely pinpoint the ap p ro p riately
knowledgeable person from whom to obtain the information o r, in most
cases , p e r s o n s .

The nature of the interview was a two-step process--highly
structured questions in accordance w ith the questionnaire or in te rv ie w
guide, as included in Appendix B, and then open end questions in which
the respondent could express himself in any manner, or on any re la te d
to pic.

The interview ran from two to s ix hours, with the average

about two and o n e -h a lf hours.

Sometimes there were second or t h ir d

interviews o f a more abbreviated duration.

101
The personnel interviewed w ith in any firm depended, o f course,
upon the cooperation of a p a r t ic u la r fir m .

However, attempts were

made to include as wide a spectrum as possible.
the people who were interview ed.

Table IV -3 in d ic a te s

The t o ta l exceeds the number o f

firms because u su ally more than one person was in te rv ie w e d .
P i l o t Study and Other Confirmation
At the onset o f th is study, th ere were two questions o f con­
siderable importance.

Would the firms contacted have the background,

knowledge and, perhaps more c r u c i a l , the w illin g n e s s to spend timeto (a ) answer the questions and (b ) speak openly and can didly.

Would

the information received have enough substance to be useful?
A ffirm a tiv e answers were forthcoming in a p i l o t study o f s ix firm s ,
and through other co n firm atio n.

TABLE I V - 3 . —T i t l e and Number o f Persons P a r t ic ip a t in g in the
In te rv ie w .
T itle
President or vice president
P lant or production manager
Personnel manager
In d u s tr ia l re la tio n s manager
Safety manager
Chief engineer
Maintenance supervisor
Legal adviser
Purchasi ng
O ffic e manager
Others
T o ta l

Number
17
15
10
3
19
6
4
1
3
3
3
82

102
P r io r to s t a r tin g a p i l o t study, however, a sample question­
naire was "market tested" on th ree firms not included in the study,
and changes were made where ap p ro p ria te .

In a d d itio n , a t the sugges­

tion of the Chairman o f the review committee f o r th is study, two
safety managers o f leading corporations and th e president o f a
safety equipment company reviewed i t from an ind ustry or respondent
point o f view.

Each of these men is n a tio n a lly known in industry

fo r his s a fe ty e x p e r tis e , and has over 20 years of experience in
the f i e l d o f in d u s tr ia l s a fe ty .

This is also mentioned because

during the f i r s t few months o f the study they were consulted on a
bi-weekly and sometimes weekly basis regarding the type o f inform a­
tion received.

I n i t i a l l y there were also p erio d ic reviews w ith

representatives from the D e tr o it OSHA o f f i c e , and the G reater D e t r o it
Safety C o u n c il.
S t a t i s t i c a l Technique
As ind icated in Chapter I , the purpose o f th is study is to
provide an overview o f the ways in which re p re s e n ta tiv e business
firms have responded to the OSHA Act.
ta n t factors had to be considered.

Because of t h i s , f i v e impor­

F i r s t , i t was a n tic ip a te d th a t

the inform ation th a t could be obtained from the study would be
general in nature.

Second, concise evidence was not a v a ila b le to

determine why p a r t ic u la r changes might have occurred.

T h ir d , the

act i t s e l f was so new i t might have been premature to draw hard
conclusions, i f not impossible to get the necessary data to t e s t
s p e c ific hypotheses.

Fourth, the sample s ize in e ig h t o f the

103

s t r a t if ic a t io n s necessary ( s i z e , c i t y population, lo c a tio n , e t c . )
did not lend i t s e l f to meaningful regression analysis or other
techniques.
On th is basis i t was decided to use numerical d e s c rip tiv e
data in which the information could be cross ta b u la te d , and charted,
and where f e a s ib le , provide percentages.
Lim itations of the Study
At th is point i t might seem appropriate to comment on some
of the major lim ita tio n s and d i f f i c u l t i e s encountered in th is study.
Assuming manpower and fin a n c ia l resources were a v a ila b le as
previously discussed, the sample s ize could be much la r g e r.

I t was

extremely d i f f i c u l t w ith only 49 firms to make allowances fo r a l l the
variables such as s iz e , lo c a tio n , and in d u s try , to keep the sample
"re p re s e n ta tiv e .11 S im i l a r l y , a considerably la r g e r sample size would
permit more meaningful analysis o f the e f f e c t of in d iv id u a l v a ria b le s .
In a d d itio n , i t would f a c i l i t a t e p re d ic tiv e analysis fo r the e n tir e
population o f business firm s.
This study was conducted during the e a rly part o f the m aturity
of the act.

I t is conceivable th a t many o f those interviewed might

not have f u l l y appreciated i t s f u l l

impact as y e t.

Because the act

is so new, there had been a great deal of adverse p u b li c it y , and
response to the act was often traum atic.

I t is conceivable th at

this might have influenced some answers, even though special a tte n ­
tion was devoted to th is aspect in the interview s.

There is also a

danger in depending upon information received in response to d ir e c t
questions, and by a lim ite d number of people, even though the same

104

questions were asked in the same o rd er, and usually more than one
person was interviewed in a firm .
This is not to say th a t these lim ita tio n s are unique to th is
study.

They are general to most any study under s im ila r circumstances.

Moreover, i t is believed th a t necessary precautions were taken to
minimize these fa c to r s , and th a t there has been l i t t l e or no e ff e c t
upon the re su lts of th is study.
Summary
This chapter o utlined the step-by-step procedure used to
conduct th is research p ro je c t.

I t discussed how a population sample

of 49 business firms were selected randomly w ith in s t r a t i f i c a t i o n s
re la tin g to such things as location and in d u s try , and then grouped by
s ize , in ju ry frequency r a t e , s tru c tu ra l considerations (operations
"under one ro o f," e t c . ) , and firms targeted by OSHA.

I t then

described how data was co llected through personal interviews with
various members o f individual firm s , using a q uestionnaire/guide,
and a p i l o t study.

Special stress was placed upon sustained consul­

tatio n and review o f the information as i t was received with
experienced industry safety people, and public safety agencies.

The

need fo r s t a t i s t i c a l l y d e s c rip tiv e technique was reviewed.

F in a l l y ,

some of the major lim ita tio n s of the study were discussed.

The next

chapter w i l l

in d ica te the re su lts derived from fo llow ing th is plan.

CHAPTER V

STUDY FINDINGS
Introduction
This chapter summarizes the re su lts o f personal interviews
with various representatives o f the 49 business firms contacted to
determine responsiveness to the OSHA Act.

As discussed p rev io u sly,

this research p ro je c t was confined to 11 areas of general in t e r e s t .
In a d d itio n , the findings were in te rp re te d as re la te d to the f o l ­
lowing:

(1) firm size in terms o f number of employees, (2 ) in ju ry

frequency r a t e , (3) whether the firm is under a "single roof" or a
"m ulti-p lant" operation in n atu re, and (4) i f the firm is in an
industry targeted f o r special a tte n tio n and inspection

by OSHA. The

format to be follow ed, then, is to discuss the findings by topic
area, in terms o f each of the four v a ria b le s .
Admi ni s t r a t i ve Responsib i l i t y and
Functional Alignment
I t appeared th a t there had been s h ift s in organization
structure to comply with the OSHA Act from the standpoint of safety
re s p o n s ib ility , reporting procedures, creatin g new positions or
t i t l e s , s t a f f increases, and increasing time devoted to s a fe ty .
people in more d if f e r e n t jobs were involved in s a fe ty ,

More

and there was

greater dual r e s p o n s ib ility , with safety being added to some other
job.

There was also evidence that the safety responsibi1i t y fo r

105

106
compliance p r i n c ip a ll y involved positions and functions o th e r than
personnel departments.

Firms interviewed suggested th a t the very

lim ite d r o le o f personnel r e fle c t e d the emphasis upon technical
standards, p lan t and equipment adjustments, in s p e ctio n s , and more
lin e and prestigiou s implementation o f s a fe ty programs.
Firm Size
The manner in which a firm had responded to the OSHA Act in
terms of a d m in is tra tiv e r e s p o n s ib ilit y and fu n c tio n a l alignment seems
to have been to a considerable exten t dependent upon how large or
smal1 i t was.
The p o sitio n responsible f o r s a fe ty :

Table V - l . — In firms

with under 50 employees, s a fe ty r e s p o n s ib ilit y and compliance to the
act was vested s o le ly w ith the p la n t or production manager, and there
was no in d ic a tio n o f shared r e s p o n s ib ilit y o f s a fe ty w ith another job
or functio n.

In many cases, th ere had been but lim ite d sa fe ty emphasis

p rio r to the a c t.

In 75 percent o f the firms w ith 51-250 employees,

the plant production manager, c h ie f en g in eer, and " s a fe ty manager"
were in c re as in g ly responsible.

In the case of the " s a fe ty manager,"

this was found to be a p a rt-tim e job with dual r e s p o n s ib i li t y .

In

firms o f 251-1,000 employees, the s a fe ty r e s p o n s ib ilit y had become
more evenly dispersed among personnel, in d u s t r ia l r e l a t i o n s , sa fety
manager, p la n t or production manager, c h ie f en g in eer, or maintenance,
although the number o f firms in which the p la n t production manager
or safety manager was responsible f o r compliance to the ac t was
double th a t f o r any o th e r s in g le category.

The combining o f s a fe ty

107

TABLE V - l . — Responsible P osition f o r S a fe ty.
Company Size
Position

r r C L j u c i iL y

51250

Under
50

2511 ,000

Over
1 ,000

Personnel

3

0

1

2

0

In d u s tria l re la tio n s

4

0

1

2

1

Safety manager

19

0

4

5

10

Plant/production
manager

19

12

4

3

0

Chief engineer

7

0

4

2

1

Maintenance

3

0

1

2

0

55

12

15

16

12

6

0

2

3

0

49

12

13

12

12

Sub-total
Less j o i n t
resp o nsib i1i t y
Total firms

with another function was also now more e v id e n t.

However, firms of

th is s iz e had a f u r t h e r and more pronounced tendency toward a t le a s t
a p a rt-tim e s a fe ty d ir e c t o r and, in one in s ta n c e , th ere was a f u l l time s a fe ty responsible person.

Safety a c c o u n ta b ility in the

maintenance department was also more pronounced.

In firms w ith over

1,000 employees, 85 percent had a s a fe ty manager.
Shared s a fe ty r e s p o n s ib ilit y :

Table V - 2 . — Shared s a fe ty

r e s p o n s ib ility consisted o f those instances where the r e s p o n s ib ility
and a u th o r ity fo r sa fe ty was divided between two or more people in
d i f f e r e n t jobs.

I t had occurred le a s t in firm s with under 50

employees (8 percent) and "over 1,000" firm s .

In c o n tra s t, about

108

TABLE V -2.--S h ared Safety R e s p o n s ib ility .
Company Size
Position

Frequency
Under
50

51250

2511,000

Over
1,000

Personnel

4

0

2

2 (1)

0

In d u s tria l r e la tio n s

2

0

0

1

1

12

1

8 (5)

3 (2)

0

Chief engineer

4

0

0

3 (3)

1

Maintenance

3

0

1 (1)

1 (1 )

1 (1 )

O ffice manager

1

0

1 (1)

0

0

1

12 (6)

Plant/production
manager

Total firms

26 (14)

Not a p p lic a b le

23

11

1

12 (7)
2

3 (1 )
9

( ) indicates new safety r e s p o n s ib ilit y since 0SHA Act.

92 percent of the firms in both 51-250 and 251-1 ,000 iemployees ca tegories had shared r e s p o n s ib ilit y

In the case o f firm s w ith 51 -250

employees, the p la n t/p ro d u ctio n manager was now involved in th ree out
of four cases, w ith personnel and maintenance combining f o r the
balance.

Among firms w ith 251-1,000 employees, th ere appeared to be

balanced d is t r ib u t io n among personnel o r in d u s tr ia l r e l a t i o n s , p la n t /
production manager, c h ie f engineer, and maintenance.

The p rin c ip a l

d iffe re n c e between the two groups seemed to be the g re a te r p a r t i c i p a ­
tion of p la n t managers in the 51-250 group.

As in d ica te d by the

notation ( ) , about o n e -h a lf o f the shared re sp o n s ib i1i t y has occurred
since the 0SHA Act.

109

S t a f f i n g , t i t l e s , time devoted to s a fe ty :

Table V - 3 . — The pos­

s i b i l i t y o f a f u l l - t i m e person devoted to s a fe ty began to show up in
firms w ith 51-250 employees (one f i r m ) , increased in the 251-1,000
group (two f i r m s ) , and jumped to 75 percent o f the firms in the over
1.000 group.

F u rth e r, in the over 1,000 group, only one f ir m (8%) i n d i ­

cated changes in s tr u c tu r a l r e s p o n s ib ilit y f o r s a fe ty .

Put another

way, 92 percent o f the firms in t h is group made the accommodation to
0SHA w ith in e x is tin g a u t h o r it y - r e s p o n s i b il i t y re la tio n s h ip s .
About 25 percent o f the firms w ith under 50 employees, 54
percent o f the 51-250 group, and 75 percent o f the 251-1,000 group
indicated they had made o rg a n iz a tio n a l changes as a r e s u lt o f the
act.

In the under 50 group, 25 percent created new s a fe ty p o s itio n s ,

and one firm new s a fe ty -o r ie n te d t i t l e s ;

in the 50-251 group, 70

percent created new positions and 30 percent new t i t l e s ; in the 2511.000 group, almost 60 percent created new positio ns and 50 percent
new t i t l e s .

S t a f f increases re la te d to s a fe ty did not occur in the

small fir m s , but did show up in the 51-250 group (two f i r m s ) , in
50 percent o f the 251-1,000 group, and in 25 percent o f the over
1.000 f i rms.
Table V-3 also shows th a t the time devoted to s a fe ty by the
safety designated person increased in most firm s regardless o f s iz e .
Further, both the lik e lih o o d o f th is o cc u rrin g , and the amount o f
increase appeared to increase w ith s iz e ; e . g . , 60 percent o f the
under 50 firms had spent more time on s a f e t y , a l l w ith less than a
10 percent in c re as e, 75 percent o f the 251-1,000 groups devoted more
tim e, w h ile 70 percent o f these experienced an increase o f over

110
TABLE V - 3 . - - S t a f f i n g , T i t l e s , Time Devoted to S a fe ty.
Company Size
Type of Change

Frequency
Under
50

51250

2511 ,000

Over
1 ,000

Number of firms in
sample

49

12

13

12

12

F u ll-tim e sa fety
manager

12

0

1

2

9

New t i t l e

12

1

4

6

1

New position

20

3

9

7

1

S ta ff increases

12

0

2

6

4

Structural change

19

3

7

8

1

Time devoted to sa fe ty by sa fety responsible person
No change

12

5

4

3

0

0-9% change

11

7

3

1

0

10-24% change

12

0

5

3

4

25-50% change

6

0

1

3

2

50%-full change

8

0

0

2

6

10 percent, and a l l o f the over 1,000 group in d ica te d an in c re as e, a l l
with over 10 percent increases.
Reporting procedure and ro le o f personnel:

Table V - 4 . - -The

safety responsible persons in firms with under 50 employees always
reported to top management, in most cases the president or general
manager.

In both the 50-250 and 251-1,000 groups, 83 percent reported

to top management, 17 percent to personnel; in the over 1,000 group,
25 percent reported to top management and 75 percent to personnel.
These re s u lts can be f u r t h e r re fin e d by considering only
those firms w ith personnel departments.

There were no firms with

Ill

TABLE V -4 .--R e p o rtin g Procedure and Role o f Personnel.
Company Size
Reports to

Frequency
Under
50

51250

2511 ,000

Over
1,000

Number of firms in
_ sample

49

12

13

12

12

Personnel

13

0

3

2

8

Top management

27

4

9

10

4

9

8

1

0

0

President

Function o f personnel department i f not sa fe ty
Personnel departments

26

0

3

11

12

Record keeping

11

0

2

5

4

Publici ty

1

0

0

1

0

Training

1

0

0

1

0

Commi tte e

2

0

0

2

0

19

3

7

8

1

3

0

1

2

0

Structural change
None

personnel departments in the under 50 employees group.

In firms w ith

51-250 employees, personnel had no sa fe ty fu n c tio n , or• i t s d uties were
lim ite d to record keeping (two o f three f ir m s ) .

In firms w ith 251-

1,000 employees, in two fir m s , or 18 percent, personnel had no sa fe ty
re s p o n s ib ility whatsoever, although one o f these firm s had a safety
manager.

In an a d d itio n a l 46 percent o f the fir m s , personnel per­

formed s o le ly record keeping functions (only one o f these had a sa fe ty
manager).

O v e r a ll, s l i g h t l y less than h a l f o f the personnel dep art­

ments were involved in p u b l i c i t y , t r a i n i n g , and committee work.

In

firms w ith over 1,000 employees, 25 percent 1imi ted the s a fe ty responsi­
b i l i t y o f personnel to record keeping, although in th ree o f four

112
instances th is might be explained by the f a c t t h a t th ere was a
safety manager who reported to top management r a th e r than personnel.
Inju ry Frequency Rate
Change in a d m in is tra tiv e r e s p o n s ib ilit y and fu n c tio n a l
alignment seemed to r e l a t e to the s iz e o f the in ju r y frequency r a t e ,
and the p r o b a b ility o f an e x is tin g s a fe ty program and s a fe ty per­
sonnel .
The positio n responsible fo r s a fe ty :
low in ju r y frequency rates under 15.0

Table V - 5 . — Firms w ith

had d ir e c t s a fe ty responsi­

b i l i t y vested w ith personnel and in d u s t r ia l r e l a t i o n s , a s a fe ty
manager or c h ie f engineer, in a d d itio n to pi an t/prod uction manager.
When the p ian t/p ro d u ctio n manager was excluded, on the basis of
number o f firms in each in ju r y frequency group, th e re were more posi­
tions responsible f o r s a fe ty in firms w ith rates under 1 5 .0 , as
compared to firms w ith higher ra te s .

In 77 percent o f these firms

this involved personnel, in d u s tr ia l r e l a t i o n s , or a s a fe ty manager.
The incidence o f the pi an t/prod uction manager being responsible fo r
safety tended to be higher in the high in ju r y frequency groups.
Shared s a fe ty r e s p o n s ib ilit y :

Table V - 6 . — Where s a fe ty

re s p o n s ib ility was shared, the p la n t/p ro d u ctio n manager was most
l i k e l y to be involved in one o f every two firm s .
p pc

A lso, 64 percent

An in ju r y frequency ra te o f 15 was used because the
national average f o r a l l in d u s trie s in 1972 as in d ic a te d by the
National Safety Council was approximately 1 0 .0 , and i t s members
generally represent firm s w ith b e t t e r than average s a fe ty records.

TABLE V-5.--Responsible Position fo r Safety.
Injury Frequency Rate
Position

Frequency
Under
2.0

2.05.0

5.110.0

10.115.0

15.125.0

25.140.0

40.175.0

Personnel

3

0

0

1

0

1

1

0

Industrial relations

4

1

1

0

2

0

0

0

Safety manager

18

5

3

4

3

0

2

1

Plant/production manager

18

5

0

2

1

3

4

3

Chief engineer

6

0

1

3

0

0

2

0

Maintenance

3

1

0

1

0

0

0

1

Sub-total

52

12

5

11

6

4

9

5

6

0

2

1

2

1

0

0

46

12

3

10

4

3

9

5

Less jo in t responsibility
Total firms*

*Three firms did not supply frequency rate.

TABLE V-6.--Shared Safety Responsibility.
Injury Frequency Rate
Position

Number of firms*

Frequency

46

Under
2.0

2.05.0

5.110.0

10.115.0

15.125.0

25.140.0

40.175.0

12

3

10

4

3

9

5

Personnel

4 (1)

0

0

2

1

0

1

0

Industrial relations

3

1

0

0

1

0

0

0

12 (7)

0

2

2

0

2

5

1

Chief engineer

4 (3)

1

0

2

0

0

1

0

Maintenance

3 (3)

0

0

1

0

1

0

1

Office manager

1

0

0

1

0

0

0

0

2

2

8

2

3

7

3

12

1

2

2

0

2

3

Plant/production manager

Total forms

26 (14)

Not applicable

23

*Three firms did not supply frequency rates.
{ ) indicates new safety responsibility since OSHA Act.

115

of these were plants w ith high in ju r y frequency rates o f over 15.0
with a p ro p o rtio n a te ly higher number in each in ju r y frequency group.
When shared r e s p o n s ib ilit y involved personnel, in d u s tr ia l r e l a t i o n s ,
or the c h ie f engineer, the frequency r a te is g e n e ra lly low.

Shared

re s p o n s ib ility in v o lv in g maintenance tended to appear in firm s with
high ra te s .

The n otation ( ) in d ica te s new s a fe ty r e s p o n s ib i li t y

since OSHA.
S t a f f i n g , t i t l e s , time devoted to s a fe ty :

Table V - 7 . “ -There

appeared to be about twice as much s tr u c tu r a l change as a r e s u l t of
OSHA in firms w ith a frequency r a te over 15.0 as compared to those
with lower r a t e s , even though th ere were only h a l f the number o f
firms in th is group.

Possibly t h is re fle c te d to some ex te n t the

p rio r existence o f s a fe ty functions in firms w ith low ra te s .

For

example, th re e -fo u rth s o f the firms under 15.0 had f u l l - t i m e s a fe ty
mangers.

The under 2 .0 group had no new t i t l e s or p o sitio ns whereas

in c o n tra s t, about 60 percent o f the new s a fe ty t i t l e s
firms w ith rates over 1 5 .0 .

occurred in

P osition changes and s t a f f increases

were about equal above and below 15 .0 .

On an in d iv id u a l group b a s is ,

the g r e a te s t, o v e ra ll changes occured in the 2 5 .1 -4 0 .0 group and,
to some e x te n t, the 5 .1 - 1 0 .0 group.
Table V-7 also shows th a t increases in the time devoted to
safety occurred p ro p o rtio n a te ly more often in the groups under 1 5 .0 ,
with the le a s t change, considering the number o f f ir m s , occurring in
the over 40.1 group.

However, i t was noteworthy th a t considerable

change did occur over 2 5 .1 .

Those firm s w ith low frequency rates

also had the g re a te s t amount o f increase in time devoted to s a fe ty .

TABLE V -7 .--S ta ffin g , T itle s , Time Devoted to Safety.
Injury Frequency Rate
Type of Change

Frequency

Under
2.0

2.05.0

5.110.0

10.115.0

15.125.0

25.140.0

40.175.0

Number of firms*

46

12

3

10

4

3

9

5

Full-time safety manager

12

4

1

2

2

0

2

1

New t i t l e

10

0

1

3

1

0

4

1

New position

18

0

2

5

2

1

6

2

Staff increase

11

3

1

2

1

1

2

1

No change

13

4

2

1

1

1

3

1

0-9% change

11

3

0

2

1

1

2

2

10-24% change

11

1

0

4

1

1

4

0

25-50% change

5

2

0

2

0

0

0

1

50%-full change

6

2

1

1

1

0

0

1

Time devoted to safety

*Three firms did not supply frequency ra te .

117

They also had the la r g e s t number o f firms in d ic a tin g no change, or
indicating a f u l l - t i m e s a fe ty manager.
Reporting procedure, ro le o f personnel:

Table V -8 . - - I n

respect to the s a fe ty fu n ctio n re p o rtin g to top management, except
fo r the 2 .0 group, there was no p attern r e l a t i n g to the s iz e o f
the in ju r y frequency r a te .

However, about 80 percent o f the firms

with rates under 15.0 had s a fe ty re p o rtin g to personnel, or the
person responsible f o r s a fe ty was the president or general manager.
In firms w ith rates over 1 5 .0 , almost 70 percent reported to top
management.

Table V-8 also shows th a t firms w ith low frequency

rates were more l i k e l y to have a personnel department.

(An i n t e r ­

esting point to note is th a t about 90 percent o f the firms in th is
study with personnel departments had over 251 employees.)

There

appeared to be no p a r t i c u l a r p attern regarding the function o f
personnel when i t was not d i r e c t l y responsible f o r s a fe ty .

How­

ever, the highest incidence o f l im it i n g personnel to record keeping,
and the g re a te s t occurence o f s tr u c tu r a l change, was in the over
25.0 groups.
Under Single Roof, D iv is io n , or
M u lti-P la n t Operation
Single p la n t firms "under one roof" appear to have responded
to a g rea ter extent to the OSHA Act than corporate o ffic e s w ith
plants "on-the-prem ises," or d iv is io n locations of m u lt i- p la n t opera­
tions.

I t was suggested by some respondents th a t th is could be re la te d

to the g e n e ra lly sm aller s iz e o f the firms and/or the absence of mean­
ingful s a fe ty programs, and the evidence tended to support t h i s .

TABLE V-8.--Reporting Procedure and Role of Personnel.
Injury Frequency Rate
Reports to

Frequency
Under
2.0

2.05.0

5.110.0

10.115.0

15.125.0

25.140.0

40.175.0

Number of firms*

46

12

3

10

4

3

9

5

Personnel

13

4

0

4

2

0

2

1

Top management

23

3

2

5

1

3

6

3

President

10

5

1

1

1

0

1

1

Function of personnel department i f not safety
26

6

1

9

4

1

3

2

Record keeping

9

1

0

2

1

1

2

2

Publicity

1

0

0

1

0

0

0

0

Training

1

0

0

0

0

1

0

0

Committee

2

0

0

1

0

1

0

0

Structural change

2

0

0

1

0

1

0

0

None

3

1

1

0

0

0

1

0

Personnel departments

*Three firms did not supply frequency rate .

119

Position responsible f o r s a fe ty :

Table V - 9 . —This ta b le

compares d ir e c t s a fe ty r e s p o n s ib ilit y w ith the type o f o rg a n iza tio n
s tr u c tu r e --s in g le s e lf-c o n ta in e d p la n ts , d iv is io n s o f co rp o ra tio n s ,
and corporate o f f i c e .

Because d i f f e r e n t numbers o f each were in c lu ­

ded in the survey, d ir e c t comparisons are d i f f i c u l t .

However, in

single plant f i r m s , 75 percent had sa fe ty vested w ith maintenance,
chief engineer, or pi an t/prod uction manager, 17 percent w ith a
safety manager, and 10 percent w ith personnel or in d u s t r ia l r e l a ­
tions.

A ll but two o f the firms in the e n t i r e group had under

1,000 employees.

Nevertheless, in 27 p ercen t, or one o f fo u r o f these

firm s, safety r e s p o n s ib ilit y did involve personnel, in d u s tr ia l r e l a ­
tio n s, and/or a s a fe ty manager.

In d iv is i o n s , which show a balanced

dispersion in a l l fo u r employee size groups, 70 percent o f the time
a safety manager was involved , 30 percent o f the time a p la n t/p ro d u c­
tion manager, and 23 percent o f the time in d u s tr ia l r e l a t i o n s .

This

to ta ls over 100 percent because in 30 percent o f the cases th ere
was j o i n t r e s p o n s ib i li t y , which in i t s e l f is four times g re a te r than
for the s in g le p la n t or corporate c l a s s if i c a t io n s .

Corporate o ffic e s

most fre q u e n tly had a sa fety manager, and when they did n o t, respon­
s i b i l i t y was evenly d is tr ib u te d .
Shared s a fe ty r e s p o n s ib ilit y :

Table V - 1 0 . — Instances where

safety r e s p o n s ib ilit y was now combined w ith some other job occurred
in almost 60 percent o f the s in g le plant fir m s , and involved the
plant/production manager in o n e -h a lf of these; the balance g en erally
included personnel, the c h ie f engineer, and maintenance.

About one-

h a lf o f the d iv is io n s had dual r e s p o n s ib i li t i e s , w ith the p la n t /

120

TABLE V - 9 . — Responsible P o sitio n fo r S a fe ty .
g f B !J » g .T lT T .^ T

O rganization S tru ctu re
Position

Frequency
Corpo­
ra te

D iv i­
sion

One
P la n t

Personnel

3

1

0

2

In d u s tria l r e la tio n s

4

0

3

1

Safety manager

19

5

9

5

Plant/production manager

19

1

4

14

Chief engineer

7

1

1

5

Maintenance

3

1

0

2

Sub-total

55

9

17

29

6

2

3

1

49

7

14

28

Less j o i n t r e s p o n s ib ilit y
Total

TABLE V -1 0 .— Shared Safety R e s p o n s ib ility .
O rganization S tru ctu re
Position

Frequency
Corpo­
ra te

D iv i­
sion

One
P lan t

Personnel

4

0

2

2

In d u s tria l re la tio n s

2

0

2

0

12

0

4

8

Chief engineer

4

1

0

3

Maintenance

4

2

0

2

O ffic e manager

1

0

0

1

Total firms

27

3

8

16

Not ap p lic ab le

22

4

6

12

49

7

14

28

Plant/production manager

Total

121
production manager accounting fo r 50 p ercen t, and personnel and
in d u s tria l r e la tio n s the balance.

Three o f the e ig h t corporate

offices had dual r e s p o n s i b i l i t i e s , e i t h e r the c h ie f engineer or
maintenance.
S t a f f i n g , t i t l e s , time devoted to s a fe ty :

Table V - l l . —

Structural changes occurred in 43 percent o f the s in g le p la n t firm s ,
38 percent o f the d iv is io n s , and 25 percent o f the corporate firm s .
In single p lan t firms only 10 percent had f u l l - t i m e s a fe ty managers.
As a r e s u lt o f OSHA, 40 percent created new positions or fu n c tio n s ,
21 percent new t i t l e s , and 10 percent had s t a f f increases.

In the

"divisions" categ o ry, 84 percent now had f u l l - t i m e s a fe ty managers*,
53 percent created new positions or fu n c tio n s , 30 percent new t i t l e s ,
and 46 percent had s t a f f increases.

In corporate f ir m s , o n e -h a lf

had f u l l - t i m e s a fe ty managers, 12 percent created new positions or
functions, 12 percent new t i t l e s , and 38 percent had s t a f f increases.
In sin g le p la n t firm s 71 percent increased the time devoted
to s a f e ty , w ith 80 percent o f th is now in the range o f up to 24 per­
cent.

About 80 percent o f the d iv is io n s devoted more time to s a f e ty ,

in almost a l l

instances th is represented an increase o f over 10 per­

cent, and fre q u e n tly over 50 percent.

Three o f four corporate firms

increased time devoted to s a fe ty ; a l l had a t le a s t a 10 percent
increase, and some 40 percent of the firms had over a 50 percent
increase.

122
TABLE V - l l . — S t a f f i n g , T i t l e s , Time Devoted to S a fe ty .
* ,L.-|

1' -'T-glf-rrrtgJ "m 1
r.

liJLi 'L,E

O rganization S tru ctu re
Type o f Change

Frequency
Corpo­
ra te

D iv i­
sion

One
Plant

Number o f firms

49

8

13

28

F u ll-tim e s a fe ty manager

12

4

5

3

New t i t l e

12

2

4

6

New position

20

2

7

11

S t a f f increases

12

3

6

3

Structural changes

19

2

5

12

No change

12

1

3

8

0-9% change

11

0

1

10

10-24% change

12

2

4

6

25-50% change

6

1

2

3

50%-full change

8

3

4

1

Time devoted to safety

Reporting procedure and r o le o f personnel:

Table V -1 2 .-- I r .

single p la n t firm s about 86 percent of the sa fety responsible people
people reported to top management, or were top management.
percent reported to personnel.

But 14

Tn d iv is io n s 62 percent reported to

top management and 32 percent to personnel.

In corporate firms the

reporting procedure was evenly s p l i t between top management and
personnel.
In s in g le p lant firms w ith personnel departments, tw o -th ird s
had no s a fe ty r e s p o n s i b i l i t y , or i t was lim ite d to record keeping.
This was 30 percent in d iv is io n s and 40 percent in corporate firm s .

T

123
TABLE V - 1 2 . — Reporting Procedure and Role o f Personnel.

O rganization S tru c tu re
Reports to

Frequency
Corpo­
ra te

Divi ■
sion

One
P lant

Number of firms

49

7

14

28

Personnel

13

3

6

4

Top management

27

4

8

15

9

0

0

9

President

Function o f personnel department i f not sa fe ty
Personnel department

26

7

10

9

Record keeping

11

3

3

5

P u b lic ity

1

0

0

1

Training

1

1

0

0

Commi tte e

2

1

0

1

19

2

5

12

3

1

0

2

Structural change
None

Firms Targeted fo r OSHA Inspection
Firms in in d u s trie s re ce ivin g special a t te n tio n by OSHA
appeared more responsive in making changes in a d m in is tra tiv e respon­
s i b i l i t y and fu n c tio n a l alignment.
P osition responsible fo r s a fe ty :

Table V - 1 3 . - -Firms targeted

for OSHA inspection did not have personnel, in d u s tr ia l r e l a t i o n s , main­
tenance o r , fo r the most p a r t , a c h ie f engineer d i r e c t l y responsible
fo r s a fe ty .

About 73 percent assigned th is r e s p o n s ib ilit y to the

p lant/production manager, and 23 percent had a s a fe ty manager.
Shared s a fe ty r e s p o n s ib ilit y :

Table V - 1 4 .--When the sa fe ty

r e s p o n s ib ility was shared w ith some other fu n c tio n , i t was the

124

TABLE V -1 3 .— Responsible Position fo r S afety.
P osition

OSHA Targeted

Personnel
In d u s tr ia l r e la tio n s

0
-

1

Safety manager

2

P lan t/p ro d uctio n manager

8

Chief engineer

1

Maintenance

0

O ffic e manager

0

Not a p p lic a b le

0

Sub-to tal
Less j o i n t r e s p o n s ib ilit y
Total

12
1_
11

TABLE V - l 4 . --Shared Safety R e s p o n s ib ility .
Position

OSHA Targeted

Personnel

0

In d u s tria l re la tio n s

1

Safety manager

0

P lan t/p ro d uctio n manager

5

Chief engineer

0

Maintenance

0

O ffic e manager

0

Not ap p lic ab le

5

Total

11

125

plant/production manager.

G e n e ra lly , targeted firms were s m a ll,

without s a fe ty functions per se or s p e c ia lize d e x p e rtis e .
S t a f f i n g , t i t l e s , time devoted to s a fe ty :

Table V - 1 5 .—

One-third o f the firms targeted f o r OSHA inspection had experienced
some s tru c tu ra l change.

About 17 percent now have f u l l - t i m e safety

managers, 25 percent created new p o s itio n s , 25 percent new t i t l e s ,
and 9 percent have had s t a f f increases.

Over o n e -h a lf o f the firms

were devoting more time to s a f e t y , although i t was g e n e ra lly less
than a 25 percent increase.
Reporting procedure and r o le of personnel:

Table V-16 . - -

All of the firms targeted f o r OSHA inspection had less than 1,000
employees.

Two o f the eleven firms had personnel managers, but one

of these had no safety r e s p o n s ib ilit y other than th a t o f record
keeping.

The sa fe ty responsible person in each firm was the p re s i­

dent or reported to top management.
TABLE V -1 5 .— S t a f f i n g , T i t l e s , Time Devoted to S a fe ty .
Type of Change
Firms

OSHA Targeted
11

F u ll-t im e s a fe ty manager

2

New t i t l e

3

New position

3

S t a f f increases

1

Time devoted to sa fety
No change

5

0-9% change

3

10-24% change

2

25-50% change

0

50% -full change

1

126
TABLE V - 1 6 .-- R e p o r t in g Procedure and Role o f Personnel.

Reports to

OSHA Targeted

Number o f firms

11

Personnel

0

Top management

8

President

3

Function o f personnel department i f not s a fe ty
Personnel department

2

Record keeping

2

P u b lic it y

0

Train in g

0

Commi tt e e

0

S tru c tu ra l change

5

Functional Duties
I t appeared th a t firms had responded to the OSHA Act by
changing fu nctio nal duties as re la te d to s a fe ty .

Increased a c t i v i t y

and a u th o rity was evident in the areas o f s a fe ty a n a ly s is , co nsulta­
tion and compliance, purchasing o f s a fe ty equipment or m a te r ia ls ,
record keeping, and budget d e te rm in a tio n , a p p ro p ria tio n , and c o n tro l.
Duties had increased in number and v a r ie ty .
Firm Size
Changes in fu n ctio n al duties do not appear to be c h a ra c te r­
i s t i c o f firms of any p a r t i c u l a r s i z e , except fo r the very la rg e or
very small firm s — e . g . , under 50 employees or over 1,000 employees.

127

Duties o f s a fe ty responsible person:

Table V - 1 7 . - -There had

been new or increased r e s p o n s ib ilit ie s f o r the s a fe ty designated
person as re la te d to (1 ) a n a ly s is , (2) c o n s u lta tio n , (3) a u t h o r ity
to make the f i n a l decision when s a fe ty is in v o lv e d , and ( 4 ) a u th o r ity
to force compliance to s a fe ty reg u latio n s in an average o f two o f
every three firm s .

From a s iz e standpoint th ere was reasonable con­

sistency in a l l groups except f o r the group w ith over 1,000 employees.
This group showed considerably less change than the others.

In the

area o f budgetary control the only change appeared in the under 50
employees and the 50-250 groups, w ith the l a t t e r being by f a r the
most pronounced.
I t is noteworthy th a t th e re was no r e s p o n s ib ilit y f o r s a fe ty
analysis in 10 percent o f the firm s in the study, f o r s a fe ty consul­
ta tio n in about 20 percent of the fir m s , no a u th o r ity to make the
f in a l decision in 14 percent o f the fir m s , and no budget control in
about 35 percent, and th is was tru e ir r e s p e c tiv e o f employee group
size.
Safety expenditures:

Table V - 1 8 .—Almost a l l fir m s , regard­

less o f s i z e , used a c e n tra l fund and special app ro priatio n s when
making s a fe ty expenditures to comply w ith the a c t.

Except f o r the

under 50 group, almost a l l budgetary requirements f o r s a fe ty had to
be re q u is itio n e d or recommended, and were subsequently "rubber
stamped" by top management.
complete budgetary control
group fo r a l l

In only the under 50 group was there
(50% o f these f ir m s ) .

Only the over 1,000

in te n t operated on a p r o f i t center basis.

128

TABLE V -1 7 .— Duties o f Safety Responsible Person.
Company Size
Item

Frequency
Under
50

51250

2511 ,000

Over
1 ,000

49

12

13

12

12

Analysi s

37

10

11

10

6

Advisory

31

9

7

10

5

Final decision

30

8

8

8

6

Force compliance

36

8

10

11

7

Budget control

15

3

7

3

2

Analysi s

5

1

1

2

1

Advi sory

9

2

3

2

2

Final

7

0

3

2

2

2

0

1

0

1

17

2

5

5

5

Number of firm s
New or increased r e s p o n s ib ility

No r e s p o n s ib ility

decision

Force compliance
Budget control

129

TABLE V -1 8 .— S afety Expenditures.
Company Size
Item

Frequency
Linder
50

51250

49

12

13

12

12

6

6

0

0

0

Requisition and recommend

37

4

11

10

12

Exclude c a p ita l expenditure

17

1

6

7

3

Rubber stamped

43

7

12

12

12

Central fund

48

12

13

11

12

Special appropriations

46

12

12

11

11

P r o f it center

11

0

1

1

9

32

5

12

6

9

5

0

0

3

2

12

7

1

3

1

Number of firms

2511 ,000

Ovei
1 ,00(

Safety expenditures
Complete control

Safety budqet
New or increased
No change
None

130

There were new or increased budgets expressly fo r safety in
65 percent of the firms interview ed, with the la rg e s t incidence in
the 51-250 group (93 percent) and over 1,000 group (75 p erc en t).
Over one-half o f the firms w ith under 50 employees had no such budget,
while in the 250-100 firms there was no budget in 25 percent of
the cases, or no change in an additional 25 percent.

Less than 17

percent o f the over 1,000 firms had no such budget, and a l ik e
percentage had made no changes.
Purchase o f sa fe ty items:

Table V -1 9 .— In only the over 1 ,000

employee group were there instances in which the safety designated
person had no purchasing r e s p o n s ib ility f o r sa fety re la te d items (25
percent of the firm s ).

Conversely only 17 percent of the firms o f

this size had complete purchasing a u t h o r it y , as compared to about 50
percent fo r the 51-250 and 251-1,000 groups and 100 percent fo r those
firms with under 50 employees.

S im ila r ly , as the s iz e decreased,

the influence over selectin g (a) products and (b) suppliers increased.
Over 81 percent o f a l l firms had th is c h a r a c te r is t ic .
New d u ties;

Table V -2 0 .—There had been a considerable

increase in safety re la te d duties since the OSHA Act.
order these consisted o f:

In descending

paper work (85 percent o f a l l

f ir m s ) ,

policy statements (74 p e rc e n t), inspections (75 p e rc e n t), safety
committees (65 p e rc e n t), c la s s if ic a t io n or cross-referencing standards
(59 p erc en t), safety presentations (45 p e rc e n t), tr a in in g new hires
(35 p ercen t), and general tra in in g (29 p ercent).

Firms in a l l s iz e

groups increased record keeping d u tie s , but the p rin c ip le changes

131
TABLE V -1 9 .— Purchase o f S a fe ty Items.

Company Size
Item

Frequency
Under
50

51250

2511 ,000

Over
1 ,000

49

12

13

12

12

Personal items

10

0

5

3

2

Major

11

0

3

3

5

Complete

25

12

5

6

2

3

0

0

0

3

Selects products

40

12

13

8

7

Selects suppliers

37

12

11

8

6

Requisition but handle
process

7

0

4

1

2

Blanket order

3

0

1

0

2

Number of firms
Authority and re s p o n s ib ility

None

TABLE V -2 0 .— New d u tie s .
Company Size
I tern

Frequency
Under
50

51250

2511 ,000

Over
1 ,000

Number of f i rms

49

12

13

12

12

Paper work

42

8

11

12

11

Inspecti ons

36

3

12

11

10

Pol icy

36

2

12

10

12

Commi tte e

32

2

12

8

10

C la r ify standards

29

2

5

11

11

Presentati on

22

1

2

9

10

New hires

17

2

2

3

10

Training

14

2

2

4

6

3

0

0

2

1

Design equipment

132
in committee a c t i v i t i e s , inspections, and p olicy statements occurred
in firms with over 50 employees.

Firms with under 50 employees

reflected some change (17 p e rc e n t), but in comparison th is was
minimal.

Most firms in the 251-1,000 and over 1,000 groups increased

safety presentations and c l a r i f i c a t i o n o f standards; o n e -th ird o f the
firms in the 51-250 group i n i t i a t e d a procedure fo r cross-referencing
and cla s s ify in g standards.
Injury Frequency Rate
Analyses of response to the OSHA Act according to in ju ry
frequency rates were somewhat mixed.

A ll firms regardless o f r a t e ,

for example, indicated changes in paper work, c l a r i f y i n g standards,
procedures fo r budget expenditures to reasonably the same e x te n t.
However, there was less change in the very high and very low groups
re la tin g to committees, inspections, p o lic y , control over purchasing,
and complete budgetary control than in the other groups, and less
change in duties in firms with low ra tes .
Duties o f sa fety responsible person:

Table V -21. —There were

s ig n ific a n t increases in safety a n a ly s is ,. co n s u lta tio n , decision
making, and a u th o rity to force compliance in a l l in ju r y frequency ra te
groups.

While comparison was d i f f i c u l t because of a disporportionate

number o f firms in each group, i t appeared th a t w hile s t i l l s u b s ta n tia l,
the le a s t change was evident in firms with rates under 5 .1 .

In

examining the "no re s p o n s ib ility " answers, the fo llow ing pattern was
evident:

over 75 percent o f the firms in d ic a tin g no safety analysis

and 67 percent having no say in the f in a l decision had in ju ry f r e ­
quency rates over 25.0.

TABLE V-21.— Duties of Safety Responsible Person.

Injury Frequency Rate
Item
Under
2.0

2.15.0

5.110.0

10.115.0

15.125.0

25.140.0

40.175.0

12

3

10

4

3

9

5

Analysis

9

2

8

3

3

6

4

Advi sory

7

1

6

2

3

6

4

Final decision

6

1

8

3

2

6

2

Force compliance

7

1

8

3

3

8

4

Budget control

2

2

5

1

1

1

2

Analysis

1

0

0

0

0

2

1

Advisory

2

0

2

2

0

0

1

Final decision

0

0

1

0

1

2

2

Force compliance

0

0

1

0

0

0

0

Budget control

3

0

3

3

2

4

0

Number of firms (46 total)*'
New or increased responsibility

No responsibility

*Three firms did not indicate rates.

134

Safety expenditures:

Table V-2 2 .— Considering the number of

firms in each in ju ry frequency group, over 90 percent of the firms
in each group increased a c t i v i t i e s r e la t in g to recommending and
requisition in g funds, management "rubber stamping" these requests,
necessary funds f o r compliance coming from a separate fund, and
funding based upon special appropriations*, and the percentage of
firms was approximately the same in each group.

Complete budgetary

control existed in the very low (under 2 .0 ) and very high (over
25.1) groups.

New or increased budgets expressly f o r s a fe ty were

evident in a l l in ju ry frequency groups.
in safety budgets, they
15.0.

Where there were no changes

occurred s o le ly in firms with rates under

The group with the la rg e s t percentage o f firms with no such

budgets were those with under 2.0 ra te s .
Purchase o f safety items:

Table V - 2 3 . - -Based upon the number

of firms in each group, the greatest increase in exercising complete
control over the purchase o f safety items was evident in firms with
under 5.0 and over 40.1 in ju ry frequency ra te s .

There has also been

from a 50 to 92 percent increase in the influence o f the s a fe ty
designated person in the selectio n of both products and suppliers
as related to s a fe ty .
New d u ties:

Table V -2 4 .—A ll in ju ry frequency s iz e groups

have a high percentage o f firms with increased paper work, over 70
percent in each.

The increased incidence o f safety committee a c t i v i ­

t i e s , inspections, and p olicy statements occurred to the g reatest
extent w ith in a range from 2.0 to 25.0.

Conversely, the le a s t change

TABLE V-22.--Safety Expenditures.

Injury Frequency Rate
Item
Under
2.0

2.05.0

5.110.1

10.115.0

15.125.0

25.140.0

40.175.0

12

3

10

4

3

9

5

Complete control

3

0

0

0

0

1

2

Requisition and recommend

7

2

8

5

3

7

3

Exclude capital expenditure

2

2

4

1

2

3

3

Rubber stamped

11

3

8

4

3

7

4

Central fund

12

3

9

4

3

8

5

Special appropriations

12

3

8

4

3

7

5

4

0

2

1

2

0

1

New or increased

5

2

8

3

1

6

5

No change

2

1

0

1

0

0

0

None

6

0

1

1

2

2

0

Number of firms (46 t o ta l) *
Safety expenditures

P ro fit center
Safety budget

*Three firms did not indicate rates.

TABLE V-23.-Purchase of Safety Items.

Injury Frequency Rate
Item
Under
2.0

2.05.0

12

3

Personal items

3

Major

10.115.0

15.125.0

25.140.0

40.175.0

10

4

3

9

5

0

2

0

2

3

0

2

1

3

1

0

2

1

Complete

8

2

4

2

1

3

4

None

0

0

0

2

0

0

0

Selects products

11

3

9

2

3

5

5

Selects suppliers

11

3

8

2

3

5

4

Requisition but handle process

1

1

1

0

2

2

0

Blanket order

2

0

1

0

0

0

0

Number of firms (46 t o ta l)*

5.1 10.0

Authority and responsibility

*Three firms did not indicate rates.

TABLE V-24.— New Duties.

Injury Frequency Rate
Item
Under
2.0

2.05.0

5.110.0

10.115.0

15.125.0

25.140.0

40.175.0

12

3

10

4

3

9

5

Paper work

9

2

9

4

3

7

5

Inspections

8

3

9

3

3

5

3

Policy

6

3

9

4

2

7

2

Committee

7

2

9

3

2

4

3

C larify standards

6

2

7

4

1

5

2

Presentation

6

0

6

3

1

4

1

New hires

5

0

5

4

0

1

1

Training

4

1

2

1

1

2

2

Design equipment

1

0

1

1

0

0

0

Number of firms (46 to ta l) *

*Three firms did not indicate rates.

138
occurred in the under 2 . 0 , 2 5 .1 - 4 0 .0 , and 4 0 .1 -7 5 .0 groups, although
even then there was a change in 40 to 75 percent o f the firm s.
Increased a c t i v i t y in c l a r i f y i n g standards ranged from 40 to 70
percent of the firm s , and was f a i r l y consistent fo r a l l groups.

Gen­

e r a l l y , the lower the in ju ry frquency r a t e , the higher the use o f
safety presentations.
Under Single Roof, D iv is io n , or
M u lti-P la n t Corporate Operation
There have been changes in d u tie s , sa fety expenditures, pur­
chasing o f safety items, and new duties regardless of organization
structure.

There were some areas where increased a c t i v i t y in these

areas would vary by s tru c tu re , however.

More corporate o ffic e s and

divisions had changes in the duties o f the safety responsible person;
divisions and plants "under a single roof" had increases in pur­
chasing co.ntrol; a la r g e r percentage o f firms under one ro o f had
increases in budget c o n tro l.
Duties of sa fe ty responsible person:

Table V -2 5 .- - I n over 60

percent of the firm s , whether considered as a corporate o f f i c e w ith
plants "on the premises," d ivision s of m u lti-p la n t o rg an iza tio n s, or
individual plants with a l l operations under a single ro o f, the safety
designated person had new or increased re s p o n s ib ility fo r safety
analysis, c o n s u lta tio n , the au th o rity to make the f in a l decision when
safety was involved, or to force compliance to safety re g u la tio n s .
"Corporate" firms were le a s t a c tiv e in conducting safety analysis
(60 percent o f these f ir m s ) , as were division s in providing safety

139

TABLE V -2 5 .— Duties o f Safety Responsible Person.
O rganization S tru ctu re
Item
Corporate

D ivis io n

7

14

Analysis

4

11

22

Advisory

5

5

21

Final decision

6

8

16

Force compliance

6

8

22

Budget control

0

3

4

Analysis

1

0

4

Advisory

1

3

5

Final decision

1

0

6

Force compliance

1

0

1

Budget control

4

4

9

Number o f firms

One Plant
28

New or increased r e s p o n s ib ility

No r e s p o n s ib ility

140

consultation (30 p erc en t).

Increased budget control did not occur

in "corporate" f ir m s , and in but 13 percent of the other two groups.
Safety expenditures:

Table V - 2 6 .— There was no apparent

discernible p attern regarding re q u is itio n in g and recommending funds
for s a fe ty , re ce ivin g "rubber stamped" budget approval, u t i l i z a t i o n
of a central fund f o r sa fety expenditures, and the use o f special
appropriations.

Where the sa fety designated person exercised com­

plete budget c o n t r o l, th is occurred in the "sin g le p lant" group
(21 p ercent).

P r o f i t center operations were most evident in the

"corporate" group (86 p ercen t).

There were new or increased s a fe ty

budgets in over o n e -h a lf o f the fir m s , regardless of org an izatio n
structure.
Purchase of safety items:

Table V -2 7 .— Changes in the ro le

of the safety designated person in the purchasing function appeared
to vary w ith the type of o rg an iza tio n .

Control o f the complete pur­

chasing process, s e le c tio n o f products and s u p p lie r increased in
the d iv is io n and s in g le p la n t groups to a considerably la rg e r extent
than was the case f o r the "corporate" groups, in which there were
also increases.
New d u tie s :

Table V -2 8 .— A ll firms ind icated increases in

a ll the duties described.

Paper work had increased regardless o f

organization s tr u c tu r e , with 80 percent o f sin g le p la n ts , over 90
percent o f the " d iv is io n s ," and 100 percent o f the "corporate" firms
showing increases.

The same pattern was evident fo r p res en tatio n s ,

policy statements, and c l a r i f i c a t i o n o f standards.

The le a s t change

141

TABLE V - 2 6 . — S a fe ty Exp end itu res.

Item

Organization S tru ctu re
-------------------------------------------------------------Corporate
D iv is io n
One Plant

7

14

28

Complete control

0

0

6

Requisition and recommend

7

10

20

Exclude c a p ita l expenditure

2

4

11

Rubber stamped

7

13

23

Central fund

7

13

28

Special appropriations

6

13

27

P r o f it cen ter

6

3

2

New or increased

4

11

17

No change

2

2

1

None

1

1

10

Number o f firms
Safety expenditures

Safety budget

142
TABLE V -2 7 .— Purchase o f S afety Items.

Organization Structure
Item
Corporate

D ivision

One Plant

7

14

28

Personal items

1

4

5

Major

2

3

6

Complete

2

6

17

None

2

1

0

Selects products

4

11

25

Selects suppliers

4

10

23

Requisition but handle process

1

2 1

4

Blanket order

1

2

0

Number of firms
Authority and re s p o n s ib ility

TABLE V -2 8 .— New Duties.
Organization Structure
I tern
Corporate

D ivision

One Plant

Number of firms

7

14

28

Paper work

7

13

22

Inspections

5

14

17

Pol icy

7

13

16

Commi tte e

4

13

15

C la r ify standards

7

9

13

Presentation

5

8

9

New hires

4

6

7

Traini ng

3

5

6

Design equipment

1

1

1

143

was in single p la n ts , next " d iv is io n s ," and f i n a l l y "corporate"
o ffices-

More d ivision s had increased inspection (100 p e rc e n t), then

"corporate" o ffic e s (70 p e rc e n t), and single plants (over 60 p erc en t).
"Divisons" and "corporate o ffic e s had greater incidence in tr a in in g
new employees.
Firms Targeted fo r OSHA Inspection
There were s ig n if ic a n t increases in safety re la te d duties
among OSHA targeted firm s , e s p e c ia lly in such things as sa fety
analysis, expenditures and purchasing procedures.

However, only

one-half of these firms experienced increases in a u th o rity to force
compliance, safety budgets and budget c o n tro l, safety committees,
inspections, and p olicy and c l a r i f i c a t i o n of safety standards.
Duties o f sa fe ty responsible person:

Table V -2 9 .—Almost

a l l firms targeted fo r OSHA inspections increased sa fety analysis
and consultation a c t i v i t i e s .

Almost th re e -fo u rth s increased the

au th ority of the sa fe ty designated person to make the f in a l decision
related to s a fe ty , and a l i t t l e over o ne-half increased the respon­
s i b i l i t y to force compliance to safety re g u latio n s .

In only one of

eleven firms was budget control re la te d to sa fety increased.
Safety expenditures:

Table V -3 0 .—About 80 percent o f the

OSHA targeted firms increased the process of re qu isi toning and
recommending expenditures, having them rubber stamped by management,
operating from a cen tral fund, and special ap p ropriations.

In

only four of eleven firms did the safety responsible person have
complete budget c o n tro l.

About o n e -h a lf had new or increased

144

TABLE V - 2 9 .— Duties o f S afety Responsible Person.

Item

OSHA Targeted

Number of firms

11

New or increased re s p o n s ib ility
Analysis

10

Advisory

10

Final decision

6

Force compliance

8

Budget control

1

No r e s p o n s ib ility
Analysis

0

Advisory

0

Final decision

2

Force compliance

0

Budget control

2

TABLE V -3 0 .— Safety Expenditures.
"

—

■'

....

... *

I tern
Number o f firms

*

OSHA Targeted
11

Safety expenditures
Complete control

4

Requisition and recommend

8

Exclude c a p ita l expenditure

4

Rubber stamped

9

Central fund

10

Special appropriations

9

P r o f i t center

0

Safety budget
New or increased

6

No change

2

None

3

145

budgets expressly fo r s a fe ty .

About one o f three s t i l l

had no

safety budget.
Purchase o f safety items:

Table V - 3 1 . - -There had been

increases in providing complete purchasing control of s a fe ty re la te d
items, and in the selectio n of safety products and t h e i r suppliers
in over 77 percent o f the firms.
New d u tie s :

Table V - 3 2 . - -While the amount o f record keeping

and paper work had increased in 77 percent o f the firm s , only
s lig h t ly b e tte r than o ne-half o f the firms had increased a c t i v i t y in
committee, inspection, p o lic y , and c l a r i f i c a t i o n o f standards
a c tiv itie s .

Only about one in four increased tra in in g a c t i v i t y .
Status of the Safety Function

I t appeared th at as a r e s u lt o f the OSHA A c t, the s ta tu s ,
s ta tu re , or prestige o f the safety function in firms has been
enhanced.

As indicated in Table V-33, safety has been upgraded

regardless of firm s iz e , in ju ry frequency, the type o f organization
s tru c tu re , in ju ry frequency r a t e , and whether or not firms have been
targed fo r special a tte n tio n and inspection by OSHA.

A number o f

firms indicated t h e i r safety programs were good to begin w it h , and
consequently no upgrading was necessary or possible.

This was

p a r t ic u la r ly true in firms with low in ju ry ra te s , in corporate
o ffic es with plants "on the premises," single plants with "operations
under one ro o f," and even one-fourth o f the targeted firm s .

There

was no change in 25 percent of the firms w ith under 50 employees,

146

TABLE V-31. — Purchase o f Safety Items.
Item
Number of firms

OSHA Targeted
11

A uthority and r e s p o n s ib ility
Personal items

1

Major

2

Complete

8

None

0

Selects products

9

Selects suppliers

9

Requisition but handle process

1

Blanket order

0

TABLE V -3 2 .— New Duties.
Item
Number of f i rms

OSHA Targeted
11

Paper work

8

Inspections

6

Pol icy

6

Commi tte e

6

C l a r i f y standards

5

Presentations

2

New hires

1

Trai ni ng

3

Design equipment

0

TABLE V-33.--Status of the Safety Function.
_r
quency

Number of firms

49

Safety upgraded

34

Company Size
Under
50

12

51250

2511,000

13

6 1 0 1 0

Good now
No change

*Three firms did not indicate rates.

12

Injury Frequency Rate*
Over Under
1,000 2.0

12

8

12

7

2.05.0

3

0

5.1- 10.110.0 15.0

10

7

4

3

15.125.0

Organization Structure
25.1- 40.140.0. 75.U

Corporate

qs^ a

D iv ision

One
Plant

iargel

11

3

9

5

7

14

28

3

6

5

4

9

21

148

in about 20 percent o f the firms with in ju ry frequency rates below
15.1, and in 29 percent of the “d iv is io n type" organization s tru c ­
ture.
Safety Committees
Safety committees and correspondingly re la te d a c t i v i t i e s have
apparently increased in number and f o r m a lit y , include a broader cross
section of the firm 's employees and/or functional r e s p o n s ib i li t i e s ,
and have an enlarged scope or purpose.
Firm Size:

Table V-34

The extent o f change connected with safety committees appears
to vary somewhat with the size of the firm interviewed.

The highest

incidence o f increased a c t i v i t y was an approximate 75 percent o f the
firms with 51-250 and 251-1,000 employees, and in some 40 percent o f
the firms with over 1,000.

However, only 16 percent o f the under 50

employees group had such changes.

In f a c t , 84 percent o f th is group

had no committee a c t i v i t i e s .
Except f o r the firms with under 50 employees, there was a
broad cross section o f organization levels and functions comprising
the membership o f safety committees.

Approximately the same per­

centage o f firms with safety committees in each group had
representatives from management, a safety manager, personnel,
maintenance or plant engineer, and p lan t manager.

Both the under 50

group and over 1,000 group were le a s t l i k e l y to have union members,
and the over 1,000 group was u n lik e ly to have employee representation.

149

TABLE V -3 4 .— Safety Committee P a rtic ip a n ts .
Company Size
Frequency

Under

51_

251_

Qver

50

250

1 ,000

1 ,000

Number o f firms

49

12

13

12

12

Safety committees

34

2

12

9

11

Management

18

2

5

5

6

Safety d ire c to r

17

0

4

4

9

Personnel

10

0

3

3

4

Ind. r e l .

9

0

1

5

3

Supervisi on

27

1

9

7

10

M a in t., plant eng.

18

1

6

5

6

6

0

1

0

5

Plant manager

23

1

8

6

8

Union

15

1

8

4

2

Employees

12

2

3

5

2

1

0

0

0

1

None

15

10

1

3

1

No change

10

0

3

1

6

New increased

24

2

9

8

5

Participants

Special departments

Purchasing
Activi tie s

150

Committee purpose:

Table V - 3 5 . - -Most firms with sa fety com­

mittees increased committee a c t i v i t y to provide OSHA i n t e r p r e t a t i o n ,
inspections, p olicy fo rm u la tio n , and special problems.

This

occurred about equally in a l l size groups, except fo r those with
under 50 employees.

There were but a small number o f firms which

used safety committees fo r tr a in in g or d is c ip lin e purposes.

Where

i t did occur, i t was in 25 percent of the 251-1,000 and over 1,000
groups.
Injury Frequency Rate:

Table V-36

Membership o f safety committees is somewhat mixed in respect
to the in ju ry frequency ra te of a firm .

Firms with rates of over

15.1 had the le a s t p a rtic ip a tio n by management, a safety d ir e c t o r ,

TABLE V -3 5 .— Safety Committee Purpose.
Company Size
I tern

Frequency

Under
50

51250

2511,000

Over
1 ,000

Number o f firms

49

12

13

12

12

Safety commi ttees

34

2

12

9

11

OSHA in te rp re ta tio n

31

1

10

9

11

Inspecti on

34

2

12

9

11

Poli cy

28

1

9

9

9

8

1

1

3

3

27

1

9

7

10

9

1

2

3

3

Purpose

T rain i ng
Special problems
Complaints, d is c ip lin e

151

TABLE V - 3 6 . — S a f e ty Committee P a r t i c i p a n t s .

In ju ry Frequency R ate*
Item

Under
2.0

2 .0 5.0

5 .1 10.0

10 .115.0

1 5 .1 25.0

2 5 .1 40.0

4 0 .1 75.0

12

3

10

4

3

9

5

7

3

9

4

2

4

3

Management

5

1

4

3

1

2

1

Safety d ire c to r

4

2

7

2

0

1

1

Personnel

3

0

4

1

0

1

0

Ind. r e l .

1

1

2

3

0

1

1

Supervision

6

2

7

3

1

4

2

M a in t., p la n t eng.

4

1

3

3

2

2

2

Special departments

3

0

2

0

0

0

1

Plant manager

3

3

7

3

1

3

1

Union

1

1

5

2

0

3

1

Employees

3

2

2

0

0

4

0

Purchasing

0

0

0

1

0

0

0

None

5

0

0

0

1

3

2

No change

3

2

3

1

0

1

0

New increased

4

1

6

3

2

3

3

Number of firms
Safety committees
Participants

Activi tie s

*Three firms did not in d ic a te ra te s .

152

personnel or in d u s tr ia l r e l a t i o n s , special departments, and pur­
chasing.

Firms w ith rates o f less than 10.0 had the le a s t

p a rtic ip a tio n by maintenance, p la n t en g in eerin g, unions, and
employees.
New or increased s a fe ty committees occurred to the g rea tes t
extent in firms w ith in ju r y frequency rates o f 5 .1 -1 0 (67 p e rc e n t),
10.1-15.0 (75 p e rc e n t), and 15 .1-2 0 (67 p e rc e n t); and about 30 percent
in groups above and below these ra te s .

The g re a te s t incidence o f

"no sa fety committees" was evident in firms with rates under 2 .0
(40 percent) and those over 25.1
Committee purpose:

(30-40 p e rc e n t).

Table V - 3 7 . — In firms with s a fe ty com­

m ittees, there were a wide v a r ie ty o f a c t i v i t i e s th a t increased fo r

TABLE V - 3 7 .- -S a f e t y Committee Purpose.
In ju r y Frequency Rate *
I tern

Under
2 .0

2 .0 5.0

5 .1 10.0

1 0 .1 15.0

1 5 .1 25.0

2 5 .1 40 .0

4 0 .1 75.0

12

3

10

4

3

9

5

7

3

9

4

2

4

3

OSHA In t e r p r e ta tio n

6

3

9

4

2

3

2

Inspecti on

7

3

9

4

2

4

3

Pol icy

6

3

7

3

1

4

2

Training

2

1

2

1

0

2

0

Special problems

5

3

8

4

0

3

2

Complaints, d is c ip lin e

2

0

2

2

0

1

0

Number of firms
Safety committees
Purpose

*Three firms did not in d ic a te r a t e .

153

groups in a l l in ju ry frequency ra te s ; e . g . , OSHA in te r p r e ta t io n ,
inspection, and handling special problems.

While tra in in g and safety

d is c ip lin e as committee a c t i v i t i e s did increase in some firm s , the
change was smal1.
Under Single Roof, D iv is io n , or
M u lti-P la n t Operation:
Table V-38
New or increased safety committee a c t i v i t y existed in a l l types
of organization stru c tu re .

The g reatest extent was in "d iv is io n "

operations (about 80 percent of the firm s ).

About 40 percent o f the

"under single roof" firms and 30 percent o f the "corporate" firms had
no safety committees.
There was no re a d ily d is c e rn ib le pattern or comparison regard­
ing membership in sa fety committees w ith in firms o f a p a r t ic u la r
organization s tru c tu re , other than to again say there is a cross
section representation o f d if f e r e n t functions.

Within "corporate"

firms the safety d ir e c t o r , supervisor, and plant manager were most
frequently involved in 60-70 percent o f the firms with committees;
in "divisions" 60-70 percent o f the firms had representatives from
these functions, plus personnel, maintenance or plant engineering,
and the union; about 60-70 percent of the firms also included
employees.

In "under single roof" firms the same positions were

represented as in the other two groups.

However, the average p a r t i c i ­

pation fo r each o f these functions was 25-40 percent o f the firms
surveyed.
From 70-80 percent of the firms in both "corporate" and
"division" type organizations re fle c te d increased safety committee

154
TABLE V - 3 8 . — Safety Committee P a r t i c i p a n t s and Purpose.

Item

Organization Structure
------------------------------------------------------------Corporate
D ivision
One Plant

Number of firms

7

14

28

Safety committees

5

14

15

Management

3

8

7

Safety d ir e c to r

4

8

5

Personnel

2

6

2

Ind. r e l .

1

3

5

Supervision

4

11

12

M a in t., plant eng.

2

6

10

Special departments

1

3

2

Plant manager

5

9

9

Union

1

8

6

Employees

2

5

5

Purchasing

0

1

0

None

2

0

13

No change

3

3

4

New increased

2

11

11

OSHA in te rp re ta tio n

5

12

14

Inspection

5

14

15

Policy

3

12

13

Training

1

3

4

Special problems

4

13

10

Complaints, d is c ip lin e

1

6

2

Participants

Activi tie s

Purpose

155
a c t iv it y in the areas o f OSHA in t e r p r e ta t io n , and inspection.

Almost

a ll "divisions" had increased a c t i v i t y r e la tin g to p o lic y statements
and special problems, as did upwards to 50 percent o f the "under single
roof" p lants.

T rain in g and d is c ip lin e a c t i v i t i e s , w hile increased in

some firm s , were minimal.
Firms Targeted f o r OSHA Inspection:
Table V-39
Approximately o n e -h a lf of the OSHA targeted firms have
increased sa fety committees; almost a l l o f the other firms have no
such committees.

Where such committees existed they almost always

involved supervision, maintenance or plant engineering, the plant
production manager, and employees.

However, there was broad repre­

sentation in some cases involving management, sa fe ty d ir e c t io n ,
ind ustrial r e la t io n s , and union.

The purpose o f these safety com­

mittees almost always involved OSHA i n t e r p r e ta t io n , in s p e ctio n ,
policy fo rm ulation, and special problems; 25-50 percent o f the time
i t encompassed tra in in g and d is c ip lin e .
Procedures, Rules, and Inspections
The study showed th a t there had been s ig n if ic a n t changes
since the OSHA Act in terms o f special control and preventive pro­
cedures, inspections, re p o rts , meeting, and p olicy statements.
Safety rules seemed to have been tig h ten ed , or more form alized:
safety reports and meetings were more frequ en t, and to some extent
there had been g re a te r emphasis upon safety practices regarding
new h ir e s , job a n a ly s is , and other a c t i v i t i e s .

156

TABLE V - 3 9 . — S a f e ty Committee P a r t i c i p a n t s and Purpose.

Item
Number o f firms
Safety committees

OSHA Target
11
6

P a rticip a n ts
Management

2

Safety d ir e c to r

1

Personnel

0

Ind. r e l .

2

Supervision

5

Maint. , plant eng.

4

Special departments

0

Plant manager

5

Union

3

Employees

4

Purchasing

0

A c t iv it ie s
None

5

No change

1

New increased

5

Purpose
OSHA in te r p r e ta tio n

6

Inspection

6

Pol icy

5

Training

3

Special problems

4

Complaints, d is c ip lin e

2

157
Firm Size :

Table V-40

The size o f the firm in terms o f employees did not a f f e c t
the response of firm s , except o f those with under 50 employees.
Over 75 percent of the firms in each s ize category, except f o r firms
with under 50 employees, increased control and preventive measures,
counseling and ad v is in g , reports and a n a ly s is , special forms and
check l i s t s , meetings and committee a c t i v i t i e s .

The highest incidence

of safety p olicy statements was in the over 1,000 employees group,
and the highest incidence o f meetings and committees in the 51-250
employee group.

The study indicated th a t these were usually expanded

a c t i v i t ie s ra th e r than new ones.

Where new procedures were i n i t i a t e d

they occurred in the under 50 employees (one o f four firm s ) and 51-250
employees group.

While new or increased inspections, simulated OSHA

inspections and/or special preparation fo r OSHA inspections were
evident in a l l firm s , w ith a few exceptions, the la rg e r the number
of employees the g rea ter the number o f firms th a t had made such ad ju s t­
ments.

Safety o rie n ta tio n involving new h ir e s , job evaluation

physicals, etc. were most evident in firms w ith over 1,000 employees.
The previous paragraph discussed new or increased a c t i v i t i e s
since OSHA.

In the follow ing areas there were no programs e x is t in g ,

or a c t i v i t i e s were unchanged regardless of OSHA.

Over 75-85 percent

of the firms w ith under 50 employees had made no adjustments in
almost every a rea , with the exception of safety counseling and
advising, and reporting procedures.

This was also tru e f o r the

moderate size firms (51-250 and 251-1,000) in the areas involving

158
TABLE V - 4 0 . — Coordination and C o n t ro l.

Item

Number o f firms

Frequency

Company Size
---------------------------------------------------Under
51251Over
50
250
1 ,000
1 ,000

49

12

13

12

12

Control and prevention

30

6

7

9

8

Counsel and advise

37

7

10

11

9

Special

5

3

2

0

0

Reports

43

9

12

11

11

Forms and checklists

25

1

8

8

8

Policies

25

1

8

6

10

Meetings

27

2

11

7

7

Commi ttees

32

2

12

9

11

4

0

1

1

2

New or increased

36

4

13

9

10

Simulated OSHA

2b

2

9

5

10

Special preparation

19

1

4

4

10

15

0

3

3

9

7

0

0

0

7

Administrative

Computerize records
Inspections

Employees
New hire
Job a n a ly s is , evaluation
Employee signature

2

1

1

0

0

Physicals

5

O

3

1

1

159
employee o r ie n ta t io n , job a n a ly s is , and in from o n e -th ird to oneh alf these firms in respect to p o licy and meetings.
Injury Frequency Rate:

Table V-41

The study revealed moderate differen ces in how the firms
responded to the OSHA Act when they were grouped by in ju ry frequency
ra te , and considered on a basis o f the number o f firms in each group.
For example, almost a l l firms increased reporting procedures; a l l
increased counseling and advising a c t i v i t i e s , w ith the le a s t change
in the under 2.0 group, and even there three o f four firms had such
changes.

In each group about 50 percent of the firms increased the

number o f meetings.

Control and preventive methods, forms, check

l i s t s , policy statements had the g re a te s t increase in the "in-between"
rate groups o f from 5.1 to 25.0.

The under 2.0 group had the le a s t

incidence of increased committees (one o f every two firm s ).
Special procedures were i n i t i a t e d in f r e q u e n t ly , but when they
were, they surfaced in firms with rates over 15.1.
inspections were randomly dispersed.

New or increased

However, simulated OSHA inspec­

tions and special preparation fo r OSHA inspections were le a s t evident
in firms with an in ju ry frequency o f over 15.1.

This same group

(over 15.1) was also le a s t l i k e l y to have safety o rie n ta tio n fo r
new h ir e s , in job a n a ly s is , etc.
Under Single Roof, D iv is io n , or
M u lti-P la n t Operation:
Table V-42
While there had been increased a d m in is tra tiv e a c t i v i t y ,
inspections, and employee safety re la te d e f f o r t in a l l firms regardless

160

TABLE V - 4 1 . - - C o o r d i n a t i o n and C o n t r o l.

In ju r y Frequency Rate *
Item

Under
2.0

2 .0 - ■ 5 . 1 5 .0
10.0

1 0 .1 15.0

1 5 .1 25.0

2 5 .1 40.0

4 0 .1 75.0

12

3

10

4

3

9

5

Control and prevention

7

1

7

3

2

3

4

Counsel and advice

7

2

9

3

2

8

5

Speci al

1

0

1

0

1

1

1

Reports

11

3

8

5

3

6

5

Forms and ch ecklists

4

1

8

4

1

6

1

Policies

5

0

7

4

2

3

1

Meetings

6

3

6

2

1

5

3

Committees

9

3

8

4

2

5

3

Computerize records

2

0

0

1

0

0

1

New or increased

8

3

9

4

3

5

2

Simulated OSHA

5

3

6

4

1

2

1

Special preparation

6

0

7

1

0

3

2

New h ir e

4

0

5

3

0

2

1

Job analysis evaluation

5

0

1

1

0

0

0

Employee signature

0

0

1

0

0

0

1

Physicals

1

1

1

1

1

0

0

Number o f firms
Adm inistrative

Inspections

Empl o.yees

*Three firms did not in d ic a te r a t e .

161

TABLE V - 4 2 . - - C o o r d i n a t i o n and C o n t r o l.

O rganization S tru ctu re
Item

;-------Corporate

D iv is io n

One P lan t

7

14

28

Control and prevention

6

7

17

Counsel and advise

6

Special

0

1

4

Reports

7

14

22

Forms and c h e c k lis ts

5

9

11

Policies

5

10

10

Meetings

3

12

12

Commi ttees

5

13

16

Computerize records

1

2

1

New or increased

6

13

17

Simulated OSHA

5

11

10

Special preparation

4

6

9

New h ire

3

6

6

Job a n a ly s is , evaluation

3

4

0

Employee signature

0

1

1

Physicals

1

2

1

Number o f firms
Adm inistrative

11

20

Inspections

Employees

162

of organization s tru c tu re , some changes occurred more fre q u en tly in
one p a r tic u la r type o f s tru c tu re than in others.

Over 85 percent o f

the "corporate" firm s , fo r instance, had increased control and
preventive measures, counseling and ad visin g , re p o rts , new or increased
inspections, and simulated OSHA inspections.

S im ila r percentages

were evident in "divisions" fo r a l l o f these a c t i v i t i e s , with the
exception o f control preventive methods (50 percent o f the f i r m s ) ,
and the incidence o f increased safety meetings (92 percent) was double
that fo r corporate s tru c tu re s .

In both groups about 50 percent o f the

firms increased the use o f firm s , c h e c k lis ts , and p o lic ie s .

In con­

t r a s t , the "under sin g le roof" organizations had a lower percentage
of the firms showing increases fo r a l l a c t i v i t i e s .
Firms Targeted fo r OSHA Inspection:
Table V-43
There were some areas in which firms targeted f o r OSHA inspec­
tion had appreciably responded to the a c t; e . g . , 100 percent o f the
firms increased reporting procedures, about 80-90 percent increased
inspections and simulated OSHA inspections, and from 50-60 percent
had greater counseling and ad visin g , forms and c h e c k lis ts , and
meetings and committee functions.

However, from 40-80 percent had no

programs whatsoever fo r forms and c h e c k lis ts , p o lic ie s , meetings,
committees, simulated OSHA inspections, or special preparation fo r
OSHA inspections.
oriented programs.

Almost none o f the OSHA targeted firms had employee

163

TABLE 4 3 . — Co ordina tion and Control

Item
Number o f firms

OSHA Target
11

A d m in is tra tiv e
Control

and prevention

4

Counsel

and advise

7

Special

3

Reports

11

Forms and c h e c k lis ts

7

P o lic ie s

4

Meetings

6

Committees

6

Computerize Records

0

Inspecti ons
New or increased

8

Simulated OSHA

9

Special preparation

2

Employees
New h ir e

2

Job a n a la y s is , evalu ation

0

Employee signature

1

Physicals

1

164

Awareness, Degree o f Comprehension, and
Responsiveness to OSHA Regulations
Awareness, comprehension, understanding, and knowledge o f the
requirements o f the OSHA Act were apparent.

For the most part the

a ttitu d e toward the a c t was fa v o ra b le , and management, employees, and
unions took i t s e rio u s ly .

Although each o f these three groups also

p articipated and became involved in compliance a c t i v i t i e s , manage­
ment a c t i v i t y was considerable, th a t o f the unions moderate, and
a c t i v i t ie s o f employees considerably less.

There was l i t t l e

con­

f l i c t involving safety motives and production o b je c tiv e s , nor was
there any appreciable resistance or defensiveness.
Firm Size
There appeared to be no s ig n if ic a n t p attern in respect to s ize
as re la te d to knowledge, understanding, involvement, and seriousness
in terms o f the posture o f management, employees, and unions.
exceptions included:

Notable

"organization" o f safety re g u la tio n s ,

knowledge, and understanding increased with s iz e ; management under­
standing decreased as s iz e increased; employee p a r tic ip a tio n was
less in both the large and small firm s ; and to some extent there were
more sa fe ty vs. production c o n flic ts in firms with over 1,000
employees.
Knowledge and understanding o f the requirements:

Table V -4 4 .—

As the size group of an organization increased in terms o f number o f
employees, the study indicated a more comprehensive knowledge o f the
requirements o f th OSHA Act.

For example, 70 percent o f the 51-250

size group, about 80 percent of the 251-1,000 s ize group, and

165

TABLE V - 4 4 . — Awareness, Comprehension, and A t t i t u d e .

Item

Frequency

Company Size
---------------------------------------------------Under
51251Over
50
250
1 ,000
1 ,000

Number of firms

49

12

13

12

12

Number o f unions

37

6

12

8

11

5

3

2

0

0

Some d e ta il

24

5

9

6

4

Comprehensive

15

0

2

5

8

5

4

0

1

0

Reviewed and discussed

33

2

9

10

12

Corp. in d o c trin a tio n

12

1

2

2

7

Management

30

12

7

8

3

Employees

18

4

3

5

6

Uni on

18

3

8

3

4

13

0

3

1

9

Employees

1

0

0

0

1

Union

7

0

0

0

7

6

0

3

3

0

Employees

30

8

10

7

5

Union

16

5

4

7

0

Knowledge of OSHA
Awareness

L i t t l e or none

Basic understanding

Comprehensive understanding
Management

No understanding
Management

166

100 percent of the over 1,000 s ize group had reviewed and discussed
the provisions.

Comprehensive knowledge existed in 15 percent o f the

51-250 group, 41 percent o f the 251-1,000 group, and 75 percent of
the over 1,000 group.

In the group with under 50 employees, 25

percent o f the firms had merely a basic awareness; an a d d itio n a l
33 percent had l i t t l e or no knowledge.

Where the organization stru c­

ture was corporate in n atu re, there was generally some form o f
"indoctrination" program.
Table V-44 also provides a breakdown on the degree o f
understanding by (1 ) management, (2) employees, and (3 ) unions.
Management had a basic understanding
under 50 group, in 50

in a l l o f the firms in the

percent of the 51-250 firm s , and 75

percent o f

the 251-1,000 firm s; in 75 percent of the over 1,000 group management
had comprehensive understanding.

The only instances where management

had no understanding was the 51-250 and 251-1,000 groups (25 percent
of the firm s ).
Employee understanding increased with firm s iz e .

From 25

percent in the under 50 group to 50 percent in the over 1,000 group
had a basic understanding.
comprehensive understanding.

There were v i r t u a l l y no instances of
In f a c t , in about three of every four

firms with under 1,000 employees there was no understanding; in the
over 1,000 group i t was evident in 41 percent o f the firm s.

In

respect to unions, 64

percent o f the over 1,000 group had

compre­

hensive understanding

understanding, but 45-65 percent o f

the firms

with under th is number o f employees had no understanding.

167

Favorable a t t it u d e and degree of seriousness:

Table V -4 5 .—

Management was g en erally found to favor the OSHA Act and i t s goals
in almost a l l firm s.

The exception was in the under 50 group where

some 60 percent favored i t .

This does not mean, however, th a t those

not "favoring" the act were opposed to i t , and th is w i l l be discussed
la te r.
On the basis o f (a) "takes s e rio u s ly ," (b) "neutral a t t i t u d e , "
and (c ) "do not take s e rio u s ly ," the management in most firms (over
75 percent) took i t serio usly regardless o f s iz e group.

Approximately

the same thing is tru e fo r employees, except fo r the under 50 group
where in only 50 percent o f the firms employees took i t se rio u s ly .
Most unions were found to "take i t seriously" regardless of size
group.

Most instances where the act was not taken se rio usly by

management, employees, or unions occurred in the under 50 and 51-250
groups, although th is was also tru e fo r employees and unions in the
over 1,000 groups.
P a rtic ip a tio n and involvement in compliance:

Table V - 4 6 . - -

Management p a rtic ip a te d in compliance a c t i v i t i e s in almost a l l firms
regardless o f s iz e .

In the case o f employees and unions, they

p articipated in a l l firms in the 51-250 group and 251-1,000 group, in
42 percent o f the firms over 1,0 00 , and very l i t t l e
under 50 employees.

in firms with

Conversely, in terms o f resistance and defensive­

ness regarding the requirements o f the a c t , there was v i r t u a l l y no
resistance by management in any size group, by most unions, and by
employees in approximately 50 percent o f the firms in a l l groups,
except fo r the 51-250 group, where one o f three had no resistan ce.

168

TABLE V - 4 5 . — A t t i t u d e and Seriousness.

Company Size
Item

Frequency
Under
50

51250

2511 ,000

Ove
1 ,00i

Number of firms

49

12

13

12

12

Number o f unions

37

6

12

8

11

Management

41

9

10

11

11

Employees

34

6

9

10

9

Union

22

3

7

5

7

Management

5

1

2

1

1

Employees

7

3

1

2

1

10

2

3

3

2

Management

3

2

1

0

0

Employees

8

3

3

0

2

Union

5

1

2

0

2

Take seriously

Neutral a t tit u d e

Union
Do not take seriously

169

TABLE V - 4 6 . — Involvement and Resistance.

Item

Frequency

Company Size
---------------------------------------------------Under
51251Over
50
250
1 ,000
1 ,000

Number of firms

49

12

13

12

12

Number o f unions

37

6

12

8

11

Management

45

8

13

12

12

Employees

34

3

13

12

6

Union

26

1

12

8

5

Management

45

11

12

11

11

Employees

20

6

4

5

5

Union

28

4

10

7

7

3

1

0

1

1

15

2

5

4

4

3

0

2

0

1

1

0

1

0

0

14

4

4

3

3

5

0

0

2

3

P a rticip a tio n and involvement

No resistance

Moderate resistance
Management
Employees
Union
Resist and defensive
Management
Employees
Uni on

170

Safety vs. production:

Table V -4 7 .- - I n firms w ith under 1,000

employees there was g e n e ra lly no c o n f l i c t between s a fe ty and produc­
tions by management, employees, o r unions.

Even in the over 1,000

group there was no re sis ta n ce in about 65-75 percent o f the firm s .
Inju ry Frequency Rate
When firms are grouped by in ju r y frequency r a t e , th e re is both
consistency w ith in groups and some areas in which p a r t i c u l a r behavior
appears to correspond to the s iz e o f the r a t e .

For example, the same

pattern was ev ident w ith in groups in terms o f:

the degree o f discus­

sion about the provisions o f the a c t , basic understanding, fav o rab le
a t t i t u d e , defensiveness and re s is ta n c e , p a r t ic ip a t io n and involvement,
and sa fe ty versus production o r ie n t a t io n .

Conversely, the most com­

prehensive knowledge was in the low ra te groups, and the le a s t
discussion in the h ighest.

Management and union understanding was

was g re a te s t in low ra te firm s .

The " le a s t" fav o rab le a t t i t u d e

occurred in firms w ith very large and very small r a t e s ; the le a s t
seriousness corresponded w ith very high ra te s .

Employees p a r t i c i ­

pated and were involved less in firms w ith both very larg e and
small ra te s .

Union a c t i v i t y was less in firms w ith very small ra te s .

Knowledge and understanding o f the requirements:
Better than tw o -th ird s o f the firms in a l l

Table V - 4 8 . —

in ju r y frequency ra te

c la s s if ic a t io n s had reviewed and discussed the provisions o f the a c t ,
except f o r those w ith a r a t e of 4 0 . 1 - 7 5 . 0 , in which but 40 percent
had done so.

The most pronounced groups with comprehensive knowledge

(30-50 percent) f e l l below rates o f 1 0 .0 ; most o f the balance in a l l

171

TABLE V - 4 7 . — S a f e t y Versus Production.

Item

Frequency

Company Size
----------------------------------------------------Under
51251Over
50
250
1 ,000
1 ,000

49

12

13

12

12

7

6

12

8

11

Management

5

0

3

1

1

Employees

6

1

2

2

1

Union

3

0

1

1

1

Management

5

0

1

0

4

Employees

5

0

2

0

3

Union

5

0

1

0

4

Management

39

12

9

11

7

Employees

38

11

9

10

8

Union

28

4

10

8

6

Number o f firms
Number o f unions
Safety vs. production

L i t t l e s a fe ty vs. production

No safety vs. production

172

TABLE V - 4 8 . — Awareness, Comprehension, and A t t i t u d e s .

In ju r y Frequency Rate*
Item

Under
2 .0

2 .0 5.0

5 .1 10.0

1 0 .1 15.0

1 5 .1 25.0

2 5 .1 40.0

4 0 .1 75.0

12

3

10

4

3

9

5

Awareness

2

0

1

0

0

0

1

Some d e t a il

4

2

3

3

2

6

3

Comprehensive

5

1

5

1

1

0

1

L i t t l e or none

2

0

0

1

0

2

0

Reviewed and discussed

7

2

8

4

2

6

2

Corp. in d o c trin a tio n

6

1

2

1

0

1

0

Management

6

2

5

2

2

6

4

Employees

7

2

4

0

0

5

0

Union

2

1

3

3

1

3

2

Number of unions

9

2

7

4

3

6

4

Comprehensive understandi "9
Management
o

0

3

1

0

2

1

Employees

0

0

1

0

0

0

0

Union

4

0

2

0

0

0

1

Management

0

1

2

1

1

1

0

Employees

5

1

5

4

3

4

5

Union

3

1

2

2

2

3

1

Number o f firms
Knowledge o f OSHA

Basic understanding

No understanding

*Three firms did not in d ic a te ra te s .

173

rate groups had some d e ta ile d knowledge.

Corporate in d o c trin a tio n

occurred in the lower ra te groups.
When considering the understanding o f the requirements o f the
act on a basis o f management, employees, or unions, the fo llo w in g
pattern emerged.

When management had comprehensive understanding i t

generally was evident in firms w ith in ju r y frequency rates under 2 . 0 ,
and th is accounted f o r 50 percent o f the firm s in t h is group.
E s s e n tia lly , however, in 50 to 80 percent o f the firms in each group
there was a basic understanding.

As f a r as employees were concerned,

there was v i r t u a l l y no comprehensive understanding, and a t le a s t
50 percent in each ra te group had no understanding a t a l l .

In respect

to unions, comprehensive understanding occurred in firm s w ith low
rates and, as in the case of employees, the balance is evenly s p l i t
between basic understanding and no understanding.
Favorable a t t i t u d e and degree o f seriousness:

Table V - 4 9 .—

Since management in most instances favors the OSHA A c t, th ere is no
notable p attern as re la te d to in ju r y frequency ra te groups, w ith two
exceptions.

About 60 percent o f the firms in the under 2.0 group and

over 40.1 groups fa v o r the a c t.

In almost a l l

firms in each group

but those w ith over 40.1 rates (40 p e rc e n t), the ac t was taken
seriously by management.

In a l l

but the under 2 .0 group (63 percent)

and over 40.1 group (40 p e rc e n t), employees took the act s e rio u s ly .
In the very low groups under 2 . 0 , and very high groups over 4 0 .1 ,
union a t t i t u d e was evenly divided between tak in g the act s e rio u s ly
and a neutral a t t i t u d e .

Unions in the m a jo r ity o f the firms in the

other groups took the a c t s e rio u s ly .

174

TABLE V - 4 9 . — A t t i t u d e and Seriousness.

In ju r y Frequency Rate ★
Item

Number o f firms

Under
2.0

2 .0 5 .0

5 .1 10.0

1 0 .1 15.0

1 5 .1 25.0

2 5 .1 40.0

4 0 .1 75.0

12

3

10

4

3

9

5

Number o f unions

9

2

7

4

3

6

4

Management favors

7

3

8

4

3

8

3

10

3

8

4

3

7

2

Employees

7

2

9

3

2

7

2

Unions

4

0

6

2

1

5

2

Management

1

0

0

0

0

2

3

Employees

3

0

0

1

1

0

2

Union

4

1

0

1

2

0

2

Management

1

0

1

0

0

0

0

Employees

2

1

1

0

0

1

1

Union

1

1

1

1

0

1

0

Takes se rio u s ly
Management

Neutral a t t it u d e

Do not take s e rio u s ly

*Three firms did not in d ic a te ra te s .

175
P a r t i c i p a t io n and involvement in compliance:

T ab le V - 5 0 . - -

Management p a r tic ip a te d and became involved in a c t i v i t i e s r e la te d to
OSHA compliance in almost a l l

f ir m s .

Except f o r the under 2 .0 group

(50 percent) and over 40.1 group (60 p e r c e n t), so did employees.
Union p a r t i c ip a t i o n and involvement was very high in a l l

ra te

groups, except those under 2 . 0 , where about one o f fo u r firm s had
union a c t i v i t y (55 percent had no involvem ent, the balance had
little

p a rtic ip a tio n ).

There was v i r t u a l l y no re s is ta n c e o r defen­

siveness by management re g ard less o f in ju r y frequency r a t e .

The

only union re sis ta n ce to speak o f was in the under 2 .0 group (one
of three firm s ) and over 40.1 group (one o f two f i r m s ) .
S a fe ty versus production:

Table V- 5 1 .

I n almost a l l

firm s

there were no s a fe ty versus production problems in v o lv in g management,
employees, and unions.

The one lone exception was the 5 . 1 - 1 0 . 0

in ju ry frequency r a t e group.

About 50 percent o f the firm s had

management, employee, and union s tr u g g le s , and these were s p l i t evenly
between much and l i t t l e

in degree.

Under S ing le Roof, D iv is io n , o r
M u lt i-P la n t Operations
In the areas o f knowledge and understanding, management
p a r t i c ip a t i o n , and involvement, the study revealed l i t t l e

o r no

d iffe re n c e between o rg a n iz a tio n s tru c tu re s which were c o rp o ra te ,
" d iv is io n s " or m u ltip le plants o r firms "under a s in g le r o o f ."
However, g e n e ra lly th ere was a s m a lle r percentage o f firm s in the
under a s in g le ro o f category t h a t had OSHA r e la t e d d is cu ss io n s,
general knowledge o f the a c t , and management understanding and

176

TABLE V - 5 0 . — Involvement and Resistance.

In ju r y Frequency Rate*
Item

Under
2 .0

2 .0 5.0

5 .1 10.0

1 0 .1 15.0

1 5 .1 25.0

2 5 .1 40.0

4 0 .1 75.0

12

3

10

4

3

9

5

9

2

7

4

3

6

4

10

3

9

4

3

7

5

Employees

6

3

8

2

3

7

3

Union

2

2

6

2

3

6

3

3

9

4

3

7

5

Number of firm s
Number of unions
P a rtic ip a te and involve
Management

No resistance
Management

n

Employees

6

1

1

2

1

3

2

Union

6

2

6

3

2

4

2

Management

0

0

0

0

0

1

0

Employees

3

1

4

1

1

1

2

Union

1

1

1

1

0

1

1

Management

1

0

1

0

0

1

0

Employees

3

1

4

1

1

4

1

Union

1

0

0

0

1

1

0

Resist and defensive

Moderate resistance

*Three firms did not in d ic a te ra te s .

177

TABLE V - 51 . - - S a f e t y Versus Prod uc tion .
. a i ■ ■ i-

w

t

In ju r y Frequency Rate*
Item

Under
2.0

2 .0 5 .0

5 .1 10.0

1 0 .1 15.0

15 .1 25.0

2 5 .1 40.0

4 0 .1 75.0

12

3

10

4

3

9

5

9

2

7

4

3

6

4

Management

1

0

2

1

0

0

0

Employees

1

0

2

1

0

1

0

Union

1

0

1

1

0

0

0

Management

0

0

2

1

0

1

1

Employees

0

1

2

0

0

1

1

Union

1

0

2

0

0

0

1

Management

12

3

5

3

3

7

4

Employees

12

2

5

4

3

6

4

7

2

4

3

3

6

3

Number o f firms
Number o f unions
Safety vs. production

L i t t l e sa fe ty vs. production

No safety vs. production

Union

*Three firms did not in d ic a te ra te s .

178

p a rtic ip a tio n .

There was also less seriousness and responsiveness.

Corporate firms had less p a r t ic ip a t io n , and g rea ter resistance and
defensiveness.
Knowledge and understanding o f the requirements:

Table V - 5 2 . - -

There was a d is c e rn ib le pattern r e la t in g to organization s tru c tu re
when considering knowledge o f the OSHA Act.

"Corporate" and " d i v i ­

sion" structures reviewed and discussed the a c t , whereas but 5 percent
of the "under single roof" firms did so.

In about 30 percent o f the

firms in each group, management had comprehensive understanding o f
the a c t , and most of the balance had a basic understanding.

However,

14 percent in each o f the "divisio n s" and "under sin gle roof" plants
had no understanding.

Employees a t best had basic understanding,

and in 60 percent o f the "corporate," 43 percent o f the " d iv is io n ,"
and 70 percent o f the "under sin gle roof" firms they had none.
Unions had no understanding in 14 percent o f the "divisio n s" and
64 percent o f the "under sin g le roof" firm s .
Favorable a t t it u d e and degree of responsiveness:

Table V - 5 3 .—

The incidence of favorable a ttitu d e s was higher in "corporate"
structures (100 percent) than in "divisions" (80 percent) or "under
single roof" firms (75 percen t).

A s im ila r pattern existed regarding

how seriously management regards the OSHA Act:

"corporate," 100

percent; " d iv is io n ," 86 percent; "under s in g le ro o f," 80 percent.
On the same basis, employees averaged about 70 percent o f the firms
in each category; unions about 60 percent in each type of stru c tu re .
Instances o f not taking the ac t serio usly by employees were

179
TABLE V - 5 2 . — Awareness, Comprehension, and A t t i t u d e .
O rg a n iz a t io n S t r u c t u r e

Item
Corporate

D ivis io n

One Plant

Number o f firms

7

14

28

Number o f unions

5

12

20

Awareness

0

2

3

Some d e ta il

4

6

14

Comprehensive

3

6

6

L i t t l e or none

0

0

5

Reviewed and discussed

6

13

14

Corp. in d o c trin a tio n

4

8

0

Management

5

7

18

Employees

3

8

7

Union

3

8

7

Management

2

5

6

Employees

0

0

1

Union

2

2

2

Management

0

2

4

Employees

4

6

20

Union

0

2

9

Knowledge o f OSHA

Basic understanding

Comprehensive understanding

No understanding

180

TABLE V - 5 3 . - - A t t i t u d e and Seriousness,

Item

O rganization S tru ctu re
--------------------------------------------------Corporate
D ivis io n
One P lan t

Number of firms

7

14

28

Number of unions

5

12

20

Management favors

7

11

21

Management

7

12

22

Empl oyees

5

9

20

Union

3

7

12

Management

0

1

4

Employees

1

1

5

Union

2

2

6

Management

0

1

2

Employees

1

4

3

Union

0

3

2

Management

7

14

24

Employees

3

12

19

Union

2

9

15

Takes se rio usly

Neutral a t t i t u d e

Do not take se rio u s ly

P a rtic ip a te and involve

181
29 percent o f the "divisio n s" and 10 percent o f the "under s in g le
roof" firm s ; fo r unions i t was 20 percent o f the " d iv is io n s ," and 7
percent o f the "under s in g le roof" firm s .
P a r tic ip a tio n and involvement in compliance:

Table V - 5 4 .—

Management p a rtic ip a te d and had become involved in almost a l l

firm s .

On the o ther hand, employees did so in 43 percent o f the "corporate"
firm s, 86 percent o f the " d iv is io n s ," and 67 percent o f the "under
a single roof" o rg an iza tio n s.
percent, re s p e c tiv e ly .

For unions i t was 18, 6 4 , and 53

There was some re sis ta n ce to the OSHA Act on

the part o f management and the unions in about 70 percent o f the
"corporate" and "d iv is io n " firm s , and 50 percent o f the "under a sin g le
roof" o rg an iza tio n s.
Safety versus production:

Table V -5 5 .— There appeared to be

no safety versus production problems in v i r t u a l l y a l l

" d iv is io n " and

"under s in g le roof" firm s on the p a rt of management, employees, and
unions.

However, th is was tru e in only about o n e -h a lf o f the

"corporate" firm s .

182

Table V - 5 4 . — Involvement and Resistance.

O rganization S tru ctu re
Item
Corporate

D iv is io n

One Plant

Number o f firms

7

14

28

Number of unions

5

12

18

Management

7

14

24

Employees

3

12

19

Union

2

9

15

Management

6

13

26

Employees

4

7

9

Union

5

9

14

Management

0

1

Employees

2

2

Union

0

1

Management

1

0

2

Employees

1

5

9

Union

0

2

1

P a rtic ip a te and involve

No resistance

Resist and defensive
0
10
4

Moderate resistance

183

TABLE V - 5 5 . — S a f e t y Versus Production.

O rganization S tru c tu re
icem
Corporate

D ivisio n

One P lan t

Number of f i rms

7

14

28

Number of unions

5

12

20

Management

1

2

2

Employees

1

2

3

Union

1

2

0

Management

3

1

1

Employees

2

0

3

Union

2

1

2

Management

3

11

25

Employees

4

12

22

Union

3

9

18

Safety vs. production

L i t t l e safety vs. production

No sa fety vs. production

Firms Targeted f o r OSHA Inspection:
Tables V-Sb and V -57
Less than o n e -h a lf o f the firms targ eted fo r OSHA inspection
had reviewed and discussed the a c t.

Y e t, some 64 percent had some

d e ta ile d knowledge, and an a d d itio n a l 27 percent had comprehensive
knowledge.

In only 18 percent o f the firms did management have a

comprehensive understanding and, in about 70 percent, a basic
understanding.

In about 64 percent of the f ir m s , there was no

employee understanding, and in 50 percent o f those with unions there

184
TABLE V - 5 6 . — Awareness, Comprehension, and A t t i t u d e .

Item
Number o f firms
Number o f unions

OSHA Target
11
8

Knowledge o f OSHA
Awareness

1

Some d e t a il

7

Comprehensive

3

L i t t l e or none

0

Reviewed and discussed

5

Corporate in d o c trin a tio n

1

Basic understanding
Management

8

Employees

4

Union

4

Comprehensive understanding
Management

2

Employees

0

Union

1

No understanding
Management

1

Employees

7

Union

3

185

TABLE V - 5 7 . - - A t t it u d e and Seriousness.
Item

OSHA Target

Number o f firms

11

Number o f unions

8

Takes s e rio u s ly
Management

9

Empl oyees

8

Union

4

Neutral a t t i t u d e
Management

1

Employees

1

Union

3

Do not take se rio u s ly
Management

1

Employees

2

Union

1

was no understanding.
of the a c t.

Almost th ree o f our firm s favored the provisions

In respect to taking the act s e r io u s ly , th is was tru e

fo r management in 82 percent o f the f ir m s , employees in 64 p ercen t,
and unions in 45 percent.

There was almost no resistan ce o r defen­

siveness by management or in 60-70 percent o f the firms by the
employees or the union (Table V -5 8 ).

There was v i r t u a l l y no s a fe ty

versus production d i f f i c u l t y on the part o f management, employees,
or unions (Table V—59).

786

TABLE V - 5 8 . — Involvement and Resistance.

Item
Number o f firm s
Number o f unions

OSHA Target
11
8

P a r t ic ip a t e and involve
Management

9

Employees

7

Union

5

No resistan ce
Management

10

Employees

6

Union

7

Resist and defen sive
Management

0

Employees

3

Union

1

Moderate resistance
Management

1

Employees

2

Union

0

187

TABLE V - 5 9 . - - S a f e t y Versus Produc tion .

Item

OSHA Target

Number o f firms

11

Number o f unions

8

Safety vs. production
Management

0

Employees

0

Union

0

Number o f unions

8

L i t t l e s a fe ty vs. production
Management

0

Employees

1

Union

0

No sa fe ty vs. production
Management

11

Employees

10

Union

8

Investment in S afety: A p p ro p ria tio n s, Equipment,
Devices, or P ro te c tiv e Items
There was considerable new or increased investment f o r s a fe ty related c a p ita l equipment, s a fe ty devices, personal p r o te c tiv e item s,
"plant" changes, and f a c i l i t y a l t e r a t i o n .
Appropriations to Comply w ith OSHA:
Table V-60
Every firm had made s p e c if ic d o l l a r investments to comply w ith
the OSHA Act.

G e n e ra lly , as the size o f the firm increased, the

expenditures increased.

About 84 percent o f the firms w ith under 50

TABLE V-60---Investment to Comply w ith OSHA.

I tew

Number o f firms

Fre­
quency

49

Injury Frequency Rate*

Company Size
Under
50
12

51250
13

2511,000
12

Unde
2.C

.0 -

5,1-

.0

12

12

3

Over
1,00 0

Organization Structure
Corpo­
ra te

D ivi­
sion

1 0 .0

.115.0

15.125.0

25.150.0

40.175.0

10

4

3

9

5

7

14

23

1 0

One
Plant

Target

11

Appropriations
Not available
Under $5,000

0

4

2

0

1

2

1

0

1

1

3

1

2

2

10

7

3

0

8

2

2

1

2

2

3

1

4

15

5

6

0

20

5

0

3

2

0

0

0

2

0

0

3

0

0

2

3

2

$10,000-25,000

4

2

2

0

0

0

0

1

0

1

2

0

0

0

4

2

$25,000-50,000

1

0

0

1

0

0

0

0

0

0

0

0

0

1

0

0

$50,000-100,000

2

0

1

1

0

0

0

0

n

0

1

0

f)

0

2

0

$100,000-500,000

6

0

0

1

5

2

0

3

i

0

0

0

2

3

1

0

Over $500,000

5

0

0

0

5

2

0

0

l

0

0

1

1

3

1

0

Rubber stamp funds

44

8

12

12

12

12

3

8

4

3

7

3

7

13

24

9

OSHA speeded exp.

38

10

11

10

12

2

6

4

1

6

4

5

11

22

8

Awaiting inspection

22

2

2

2

0

4

3

2

16

5

9

7
5

*Three firms did not indicate rates.

5

3

9

4

188

$5,000-10,000

189

50 employees and 38 percent o f the re p o rtin g firms in the 251-1,000
group spent under $5 ,00 0.

An a d d itio n a l 16 percent o f the under 50

group, 38 percent o f the 51-250 group, and 25 percent o f the 51-250
group spent as much as $25,000.

About 38 percent o f those re p o rtin g in

the 251-1,000 group spent $25-500,000.

A ll the re p o rtin g firm s in the

over 1,000 employee group spent more than $1 00 ,00 0, and o n e -h a lf
of those spent over $500,000.
When considering in ju r y frequency, 75 percent o f the under
2.0 group spent under $5,000 and 25 percent spent over $100,000.

In

the 5 .1 -1 0 .0 group, 25 percent o f those re p o rtin g spent under $ 5 ,0 0 0 ,
37 percent spent

from $ 5 -2 5 ,0 0 0 , and 38 p erc en t, $100-500,000. About

67 percent o f the 1 0 .1 -1 5 .0 group spent over $100,000.

In high ra te

groups, 47 percent spent less than $ 5 ,0 0 0 , and an a d d itio n a l 27
percent from $5,000 to $25,000.
In respect to org an izatio n s t r u c tu r e , 75 percent o f the
"corporate" firms re p o rtin g spent over $100,000.

Expenditures by

"division" firm s were dispersed evenly below $10,000 and above
$100,000.

About58 percent o f those re p o rtin g in the "under a s in g le

roof" firms spent under $5 ,00 0, an a d d itio n a l 27 percent from
$5-25,000, and the balance more than $50,000.
In firm s targ eted by OSHA some 55 percent o f the re p o rtin g
firms spent less than $5,000 w ith the balance evenly d ivided
between $5,000 and $10-25,000.
Most firms "rubber stamped" expenditures regardless o f s i z e ,
in ju ry frequency r a t e , o rg an izatio n s tr u c tu r e or i f they were OSHA
targeted firm s .

The one exception was in the firms w ith under 50

190

employees, where th is occurred in 75 percent o f the fir m s .

A

heavy percentage in every category f e l t OSHA speeded up the timing o f
expenditures f o r s a fe ty .

About 75 percent o f the under 50 group,

40 percent o f the 51-250 group, 63 percent o f the 251-1,000 group, and
30 percent o f the over 1,000 group ind icated they were aw aitin g an
OSHA inspection before making a l l necessary expenditures.
p a r tic u la r ly tru e f o r firm s w ith in ju r y frequency rates

o

This was
under 2 .0

f

(75 p e rc e n t), firms "under a s in g le roof" (61 p e rc e n t), and about
one-half o f the OSHA targ eted firm s .
E ffect on Purchasing P o lic y :
Table V-61
As a r e s u l t o f the OSHA Act most firm s s p e c ifie d on t h e i r
purchase orders th a t equipment or services must conform to OSHA
standards.

This breaks down as fo llo w s :

A ll firms in the over 1,000

group, about 60 percent o f the 251-1,000 and 30 o f the 51-250 groups;
v irtu a lly a ll

firm s w ith accident frequency rates under 2 .0 and

approximately 30 to 50 percent o f a l l other groups, except f o r 1 0 .1 15.0 (100 percent) and over 40.1 (20 p e rc e n t); almost a l l

"corporate"

firms, and s l i g h t l y over 60 percent o f " d iv is io n " and "under sin g le
roof" firm s ; 75 percent o f OSHA targ eted firm s .
A few firms claimed th a t such purchasing clauses are i n e f f e c ­
t i v e , th a t i t a ffe c t s p rice and/or d e l iv e r y , and others th a t t h e i r
customers required such standards to be met.
pattern to t h i s , however.

There is no s i g n i f i c a n t

In only a few instances had suppliers

"updated" equipment as a r e s u l t o f the a c t , or was the s a fe ty desig­
nated person given a u th o r ity to approve purchases o f s a fe ty

TABLE V-61.--Effect on Purchasing Policy.
Pre_
Ite "

quency

Company Size
Under
50

Number of firms

49

12

P.O. Specifies

31

8

51250

2511,000

In ju ry Frequency Rate*
Over Under 2.01,000 2.0
5.0

5.1- 10.110.0 15.0

Organization Structure

15.125.0

25.140.0

40.175.0

13

12

12

12

3

10

4

3

4

5

4

7

12

11

1

5

4

2

4

1

Corporate

D iv ision

One
Plant

Target

14

28

11

9

16

8

7

6

Doesn’ t work

3

0

1

0

3

0

0

2

0

0

0

0

1

0

2

0

Affects price delivery

7

2

1

1

3

2

0

2

1

0

1

0

1

2

4

0

Customer requires

5

3

1

1

0

2

0

1

0

0

1

1

0

0

5

3

Supplier updated
equipment

5

1

2

2

0

1

0

0

0

2

2

0

0

0

5

2

Safety eng. approves

3

1

0

2

1

0

0

*Three firms did not indicate rates.

1

2

1

0

0

1

0

0

0

192

equipment ( p r i n c ip a l l y la rg e r firm s , with "d iv is io n " or "under
single roof" s tru c tu re s ).
Type o f Safety Investment:
Table V-62
Few firms discarded c a p ita l equipment as a r e s u lt o f the
OSHA Act, and there was l i t t l e d iffe re n c e among those th a t did in
respect to firm s iz e , in ju ry frequency r a t e , organization s tr u c tu r e ,
or whether or not the firm was targeted fo r OSHA inspection.

About

75 percent o f the firms with over 51 employees, from 50 to 100 per­
cent of those with in ju r y frequency rates under 1 5 .0 , 75 percent of
the "division" fir m s , 50 percent o f the "single plant" fir m s , and
about 50 percent o f the OSHA targeted firms purchased new ca p ita l
equipment.

Conversely, the le a s t a c t i v i t y was in firms w ith under

50 employees, in ju ry frequency rates over 1 5 .1 , and corporate
structures.
I t was d i f f i c u l t to gen eralize about the o v e ra ll purpose o f
this investment because of the differences in plant operation or
industry.

However, noise, l i f t i n g equipment, and housekeeping were

more c h a ra c te r is tic of la rg e r firm s , those w ith a low in ju r y f r e ­
quency, and "d ivisio n s" or "under sin gle roof" org an izatio n s.
A c tiv itie s re la te d to presses were more prevalent in sm aller firm s ,
with higher in ju ry frequency r a te s , and in "under sin g le roof"
operations.

In t e r e s t in g ly , fewer than o n e -th ird of the OSHA

targeted firms made changes in any o f these areas.

TABLE V-62.—Type of Safety Investment.

Item

Fre­
quency

Number of firms

49

In ju ry Frequency Rate*

Company Size
Under
50

12

51250

13

2511, 0 0 0

12

Over
1.00C

12

Under
2.0

2.0- 5.1- 10.1- 15.15.0 10.0 15.0 25.0

12

3

10

4

3

Organization Structure
25.140.0

40.175.0

Corporate

D iv ision

One
Plant

9

5

7

14

3

0

3

2

7

28

Tar9et

11

Purpose of expenditures
Discarded capital
equipment

12

3

2

5

2

2

2

2

2

Bought new capital
equipment

27

2

9

8

8

6

3

7

4

1

4

2

3

10

14

Noise related

18

2

4

5

7

6

3

4

2

1

0

1

3

6

9

2

7

1

0

2

4

3

0

1

2

0

0

1

0

3

4

1

L iftin g equipment

2

5

V entilation

21

0

7

7

7

4

2

7

1

c

3

2

4

7

Presses

12

4

3

2

3

2

1

2

2

0

4

1

1

2

9

3

F irs t aid

10

1

3

2

4

2

2

2

2

0

2

0

1

5

4

4

Housekeeping

12

1

4

4

3

2

3

1

3

1

1

1

1

5

6

3

*Three firms did not indicate rates.

10

2

y?
co

194
Safety Equipment:

T a b le V-63

Almost a l l firm s interview ed had made adjustments r e la te d to
guarding, cranes, and f o r k - l i f t tru cks.

G e n e ra lly , the la r g e r the

firm , the lower the in ju r y frequency r a t e , and those firms " d iv is io n "
and "under a s in g le roof" in o rg an izatio n s tr u c t u r e , the g re a te r
was the tendency to emphasize dual controls f o r presses.

OSHA

targeted firms made adjustments in each a re a , but the g re a te s t
change was in guarding, e l e c t r i c a l components, and l i f t i n g equip­
ment.
Personal P ro te c tiv e Equipment:
Table V-64
For convenience, th is an alysis was broken down in to seven
general areas:
physicals.

h a ts , e a rs , eyes, face masks, h a i r , shoes, and

In a d d itio n , a general approach was taken in the review

of the data since the type of p la n t or operation fre q u e n tly d e te r ­
mined the nature o f the personal p ro te c tiv e equipment re q u ire d .
H ats. — New or increased programs in v o lv in g hard hats were
introduced in to one o f three firms in the two group sizes w ith
under 250 employees, and approximately one o f two in the 251-1,000
and over 1,000 group s iz e s .

The degree of th is change was i n f l u ­

enced, of course, by e x is tin g programs.

Conversely, t h e r e fo r e ,

one-half o f the firm s w ith under 50 employees, 30 percent o f the
51-250 group, and 25 percent o f the over 1,000 group had no such
programs.

The under 2 .0 in ju r y frequency group had the highest

percentage o f firms (42 percent) w ith both new or increased programs,
and w ith no such programs a t a l l .

TABLE V-63.--Safety Equipment.

Item

Fre­
quency

Injury Frequency Rate*

Comoany Size
Under
50

51250

2511, 0 0 0

Over
1 ,0 0 0

Under
2 .0

. 0 -• 5.15.0
1 0 .0

2

Organization Structure

.1 15.0

15.125.0

25.140.0

40.175.0

1 0

Corpo­
rate

Divi
sion

One
Plant

OSH/
Targe

49

12

13

12

12

12

3

10

4

3

9

5

7

14

28

11

Guards, rests

46

11

13

11

11

12

3

8

5

3

8

4

6

14

26

11

Dual controls

22

3

5

7

7

7

0

5

3

0

5

1

1

8

13

3

Blow guns

10

7

2

1

0

6

0

2

0

1

0

1

0

2

8

2

1

3

1

2

3

1

0

0

1

1

1

0

3

4

2

8

Number of firms
Guards and alterations

Platforms

7

E le ctrical

26

5

11

4

6

6

2

4

3

2

6

2

3

Cranes, fork l i f t

36

6

11

9

10

8

2

9

4

3

6

3

6

*Three firms did not indicate retes.

10

15

7

20

9

196

In terms o f o rg an izatio n s tr u c t u r e , 50 percent of the firms
in each o f the "corporate" and "under sin gle roof" groups had new o r
increased programs.

The highest incidence o f "no programs" was in

"division" firms (about 35 percent) and "under a s in g le ro o f" (30
percent).

About o n e -h a lf o f the OSHA targeted firm s introduced or

increased the use of hard hats.
Ear plugs or m u ffs .— Equipment
a l l groupings.

f o r ear p ro tectio n

occurred in

However, almost 60 percent o f the firms w ith over

1,000 employees had new or increased programs; 67 to 75 percent o f the
firms under th is size used no such p ro te c tio n .

The g re a te s t percentage

of firms w ith no such pro tectio n were those groups w ith high in ju r y
frequency ra tes above 1 5 .1 , and in firms "under a s in g le ro o f" (75
percent).

Most OSHA targeted firm s had no such p ro te c tio n .

However,

i t is conceivable th a t the nature o f the work in these firms did not
warrant such equipment.
Eye glasses and g o g g le s .--New or increased programs were e v i ­
dent most fre q u e n tly in firms w ith under 50 employees or in the group
with 251-1,000 persons.

About 25 percent o f the firm s w ith over 1,000

employees had made such equipment mandatory (a l i k e percentage had
no such program).

For the most

in ju ry frequency ra te firms had

p a rt a g re a te r percentage o f high
new or increased programs.

Almost

a l l firms t h a t made wearing such equipment mandatory had rates under
2 .0 .

O ne-half o f the "under a s in g le roof" firm s had new or

increased programs, as did the same percentage o f OSHA targeted

firms .

197

Face masks.— There was r e a l l y no d is c e r n ib le p attern regard­
ing face masks.

Only 10 percent o f a l l firm s had new or increased

programs, and 65 percent had no such programs.
H air c o v e rin g .— About 20 percent o f a l l firm s had new or
increased programs involving h a ir nets or something s i m i l a r , as
contrasted to only one o f the 49 firms having an e x is tin g program.
G enerally, the new or increased programs were in firms o f medium
size (50-250 and 2 5 1 -1 ,0 0 0 ) and w ith low in ju r y frequency ra te s .
Shoes. — Over 25 percent o f the firm s surveyed had new or
increased programs involvin g s a fe ty shoes, w ithout any re al
d istinguishable p attern r e la t in g to firm s i z e , in ju r y frequency
ra te , o rganization s tr u c tu r e , or those targ eted by OSHA.

However,

when considering firms th a t did not have a s a fe ty shoe program, they
were l i k e l y to be firms w ith under 250 employees, and o n e -h a lf o f
the firms in each group f o r " d iv is io n ," "under a s in g le r o o f ," and
OSHA targeted .
Physicals . ---Very few firms had added physical examinations
to t h e i r sa fety programs (6 p e rc e n t), and th ere were no re al con­
clusions in th is area.
Firm su b sid y .—Almost a l l

firm s , regardless o f the basis f o r

analysis had increased or i n i t i a t e d subsidies f o r (1) g lasses,
goggles, or s h ie ld s , and (2 ) shoes.

TABLE V -6 4 .--P e rs o n a l P ro te c tiv e Equipment.

Item

Fre
quency

Company Site

Injury Frequency Rate*

Organization Structure

One Target
Plant

Under
50

SI250

49

12

13

12

12

12

3

10

4

3

9

5

7

14

2B

11

Hats—new or increased
Handatory
New or mandatory
Existing
None

IB
3
1
13
14

4
1
0
1
6

3
1
0
5
4

6
1
0
4
1

5
0
1
3
3

5
0
1
2
5

2
0
0
0
1

4
0
0
3
2

1
0
0
2
2

1
0
0
1
1

4
2
0
1
1

0
1
0
3
1

5
0
1
0
1

2
1
0
6
5

11
2
0
7
8

5
1
0
3
2

tars—new or increased
Handatory
New or mandatory
Existing
None

14
0
3
5
26

2
0
1
0
9

3
0
0
3
7

2
0
0
2
8

7
0
2
1
2

4
0
2
2
5

1
0
0
0
2

3
0
1
2
3

2
0
0
1
2

0
0
0
0
3

2
0
0
0
6

2
0
0
0
3

3
0
1
0
3

4
0
1
3
6

7
0
1
3
17

1
0
1
0
9

Eyes—new or increased
Mandatory
New or mandatory
Exfsting
None

6
6
5
14
a

3
3
0
I
2

2
2
0
6
2

1
1
1
5
0

0
0
4
2
4

2
3
4
2
2

2
0
0
0
1

2
1
1
3
2

1
0
0
3
1

1
0
0
2
0

4
2
0
1
1

3
0
0
2
0

0
0
2
0
3

2
2
2
6
4

4
4
1
8
1

6
1
0
3
1

Hasks—new or increased
Mandatory
New or mandatory
Existing
None

5
i
0
li
32

1
1
0
2
8

1
0
0
3
9

1
0
0
3
3

2
0
0
3
7

1
0
0
3
9

0
0
0
0
3

1
0
0
5
3

1
0
0
1
3

1
0
0
0
2

1
1
0
1
5

0
fl
U
1
1

2
0
0
n
5

0
0
0
5
9

3
1
0
6
18

2
1
0
2
R

>air—new or increased
Mandatory
New or mandatory
Existing
None

9
0
1
1
3B

0
0
1
0
II

4
0
0
0
9

5
0
0
0
7

0
0
0
1
11

1
0
1
0
11

2
0
0
0
1

3
0
0
0
6

0
0
0
0
5

1
0
0
0
2

1
0
(I
0
7

0
0
0
1
4

2
0
n
ti
5

4
0
0
0
in

3
0
1
1
21

1
0
0
0
M

Shoes—new or increased
Handatory
New or mandatory
Existing
None

10
2
0
20
17

3
0
0
2
7

0
1
0
5
7

2
1
0
6
3

5
0
0
7
0

3
0
0
6
3

0
0
0
2
1

3
1
0
3
3

1
0
0
1
2

1
0
0
0
2

3
1
0
3
2

1
0
0
3
1

2
0
0
5
0

3
0
0
5
6

S
2
0
10
11

2
0
0
4
5

Physicals—new or Increased
Mandatory
New or mandatory
Existing
None
New or larger subsidy—
glasses
New or larger subsidy—
shoes

3
0
1
1
44

0
0
0
0
12

3
0
0
0
10

0
0
1
0
11

0
0
0
1
11

0
0
0
0
13

0
0
0
0
3

3
0
0
1
5

0
0
1
0
4

0
1}
0
0
3

0
0
0
0
8

0
0
0
n
5

(I
0
0
1
6

2
0
1
0
11

1
I)
0
0
27

0
0
1
0
10

43

11

11

10

11

13

3

5

5

3

6

5

b

12

25

11

38

12

7

8

11

12

2

3

4

3

6

5

7

10

21

9

Nurtser of firms

251- Over Under 2.0- 5.1- 10.1- 15.1- 25.11,000 1,000 2.0 5.0 10.0 15.0 25.0 40.0

40.175.0

Corpo­
rate

Divi­
sion

Personal Equipment

•Three firms did not indicate rate.

VO
00

199
F a c i l i t y Changes:

Table V-65

About 14 percent o f the firms surveyed had made b u ild in g
a lte ra tio n s or design changes since the OSHA Act was passed.

This

was g en erally in la r g e r firms w ith over 251 employees, w ith no c le a r
d is tin c tio n with regard to the percentage o f firms according to
inju ry frequency r a te s , e tc .
S i m i l a r l y , about 14 percent o f the firms had changed the
sequence o f manufacturing o perations.

While the find in g s revealed no

s ig n ific a n t p attern regarding s i z e , in ju r y frequency r a t e , o r OSHA
targeted firm s , i t did occur in a higher percentage o f the "under a
single roof" firm s .

About one in f i v e firms changed p a in tin g opera­

tio n s , p r in c ip a lly in the 51-250 and 251-1 ,000 groups, firms with
inju ry frequency rates o f 5 . 1 - 1 0 .0 to 2 5 .1 - 4 0 , and "under s in g le
roof" firm s.
Table V-65 indicates the s p e c ific physical changes th a t had
occurred.

For example, the most pronounced a lt e r a tio n s were:

equipment (80 percent o f a l l

fire

fir m s , p a r t i c u l a r l y those w ith low

in ju ry r a t e s ) ; signs (70 p e rc e n t), a i s l e markings, and s iz e (about
60 percent, w ith the g re a te s t change in the 51-250 and 251-1,000
groups and in firms w ith higher in ju r y frequency r a t e s ) ; and noise
c o n tro l, p la n t la y o u t, and a d d itio n a l rooms ( e . g . , f i r s t a i d , guard
r a i l s , and la d d e rs ).

On an o v e ra ll b as is , th ere were appreciable

changes fo r a l l categories o f a n a ly s is .

TABLE V - 6 5 . — F a u i i t / and i gn i, v e n t change'.

Item

'lumber of firms

Fi f;quenry

49

Company Size
Under
50

51250

12

13

2511, 0 0 0
12

It.jjr

Over
1 ,00 0

12

Ur.der

/

2 .0

5.0

5 110.0

12

3

m

4

2 .0

Organization Structure

r ’ eqaeti" /

in l- 15 115.0 26.u

tlorpo'’ate

D ivision

One
Plant

,a r 9 et

25.140.0

40.175.0

9

5

3

2

5

6

10

2

U

28

11

- a c ilit y Changes
Ventilation

21

0

5

7

8

4

2

6

2

Noise

27

1

9

7

10

6

3

6

4

1

3

2

4

11

12

2

Equip, placement

13

1

4

3

5

4

0

0

0

3

3

6

4

1

A isle—Markings

28

2

5

3

3

2

3

6

2

3

17

1

7

5

V
%J

1

3

0

0

3

9

14

i

13

0

5

4

4

3

0

3

1

1

l
H

4

0

1

1

2

1

0

2

0

0

f)

Layout, rooms

26

6

B

6

6

6

2

6

3

0

b

0
3
0
0
1

Fire equipment

38

10

11

7

10

11

3

7

4

c

4

3

7

10

Signs

34

8

12

6

8

10

2

7

1

2

6

3

3

8

23

a

la ils

25

2

7

8

8

5

3

6

2

0

-t

3

5

6

14

6

Housekeepings

19

6

3

6

4

6

2

2

1

0

’■
>

9

2

5

12

6

Lighting

10

0

4

5

1

0

0

4

0

4

9

1

3

6

1

Ladders

25

8

6

6

b

2

5

2

1

5

3

3

5

17

7

Storing

12

6

4

5
1L

U

2

2

1

1

0

4

2

1

2

9

6

Size
Mirrors

11

10

6

5
10

Furniture

5

1

2

1

1

1

0

1

0

1

0

2

0

1

4

0

MFG sequence

7

3

1

2

1

2

0

0

1

0

1

2

0

2

5

2

Painting

9

1

5

3

0

1

0

4

0

1

3

0

2

7

Moved operations

2

0

0

1

1

1

0

0

0

0

0

0
0

1

1

0

•Three firms did not indicate rates.

0

200

21

5

201
Communication:

T rain in g and P u b lic ity

There were changes in communication techniques such as pub­
l i c i t y and t r a in i n g .

New or more formal programs had been introduced.

A broader cross section o f people and positions were involved.
of more and d i f f e r e n t kinds o f "news" media was e v id e n t.

Use

Meetings,

the use o f sa fe ty committees, and the incidence o f formal in s tru c tio n
occurred le a s t fre q u e n tly in firms w ith under 50 employees and those
with operations "under a sin g le r o o f."
media increased with firm s iz e .

The use o f s a fe ty educational

OSHA targeted firms used l i t t l e but

basic communication techniques.
Meetings and Committees:

Table V-66

Corporate meetings occurred in approximately 60 percent o f
the firms with over 1,000 employees, as compared to less than 18
percent in each o f the s iz e groups w ith a fewer number.

When th is is

considered in terms o f o rg an izatio n s t r u c t u r e , over 70 percent o f the
"division" group had such meetings, and about 43 percent of the
"corporate" o ffic e s had them.

Such meetings were also more evident

in the lower i n j u r y frequency groups.
Over tw o -th ird s o f the firms in the study had increased s a fe ty
committee a c t i v i t y .

This was most evident in firms w ith (a ) over

50 employees (o n ly two o f twelve firms with under 50 employees had
them), (b) in in ju r y frequency ra te groups above 2 .0 and below
25 .1, although i t was tru e fo r b e t t e r than o n e -h a lf o f the firms in
the other groups as w e l l , (c ) in over o n e -h a lf o f the OSHA targeted
firm s , and (d) in "d iv is io n " firm s .

Regular meetings re s u lte d in

TABLE V-66.--Meetings and Committees.
r?.e_
Nuency

49

Corp. meeting

13

Committees

33

Reg. meeting

37

Und(?r

Injury ^reqnenc/ Mote*

g i_

251_

Qver

!Jmler

G_ 5 J _ ] Q ] _

5U

253

1,000

1,000

2.0

5.0

10.0

12

13

12

12

12

3

i-J

2

12

9

10

7

3

9

11

11

'rganization Structure

... .

^ ^

J ; u _ c-jrpo_

g -v i _

'"■5.0

10.0

75.(1

sion

:i

i

9

5

3

?

4

3

15.•'

rate

Cng

OSHA
Target

Plant

14

11
202

Number of firn s

Company Size

*Three firms did not indicate rates.

1

14
14

17

203

most firms in a l l categ o ries o f a n a ly s is , except fo r firms with
under 50 employees.

Also, s l i g h t l y less than o n e -h a lf o f the "under

a single roof" firms had n e ith e r committees nor re g u la r meetings.
Formal In s tru c tio n :

Table V-67

The use o f colleges f o r s a fe ty t r a in in g was evident in 10
percent of the firm s .

Where i t did occur, the firms had over 251

employees, and in ju r y frequency rates below 2 .0 and over 2 5 .1 .
Almost 70 percent o f a l l firm s surveyed p a rtic ip a te d in seminars.
This occurred le a s t in firms w ith under 50 employees (25 p e rc e n t), and
in "under a s in g le roof" organizations (60 p erc en t).

S l i g h t l y more

than o n e -h a lf o f the firms studied conducted in - p la n t classes.

How­

ever, th is was tru e in only one firm in the under 50 group, o n e -h a lf
o f those in the 21-250 group, fewer than 40 percent in e i t h e r the
under 2 . 0 , 2 5 .1 - 4 0 . 0 , or 4 0 .1 -7 5 .0 groups, and less than 25 percent
of the "under a s in g le ro o f" and OSHA targeted firm s .
Type of T rain in q V e h icle:
Table V-68
The most fre q u e n tly used media f o r communicating s a fe ty
messages were the b u l l e t i n board (90 percent o f the f i r m s ) , public
b u lle tin s (75 p e rc e n t), company b u lle t in s (55 p e rc e n t), l i t e r a t u r e
(40 p e rc e n t), film s (30 p e rc e n t), lec tu res (30 p e rc e n t), and news­
papers (22 p e rc e n t).

Except fo r the b u l l e t i n board and b u l l e t i n s ,

the use o f these vehicles g e n e ra lly increased with the s iz e o f the
firm .
Examination o f the p rin c ip a l media used as re la te d in in ju r y
frequency rates revealed no p a r t ic u la r p a tte r n .

Newspapers were used

TABLE V-67.--Formal Instruction.

14 .
Item

t,uency

Injury Frequency Rate*

Company Size

Fre-

2.05.0

5.1- 10.110.0 15.0

15.125.0

25.140.0

40.175.0

Corporate

D iv ision

One
Plant

Target

51250

2511,000

49

12

13

12

12

12

3

10

4

3

9

5

7

14

28

11

5

0

0

2

3

2

0

0

0

0

1

1

1

2

2

0

Seminar class

35

3

10

11

U

8

2

8

4

3

5

3

6

12

17

8

In-plant class

25

1

6

8

10

5

2

7

3

2

3

2

5

9

11

3

College

*Three firms did not indicate rates.

204

Under
50

Number of firms

Over Under
1,000 2.0

Organization Structure

TABLE V-68.--Type of Training Vehicle.
Fre­
quency

Item

Injury Frequency Rate

Comoany Size
Under
50

51250

2511 ,000

Over
1,000

Under
2.0

2.0-■ 5.15.0
10.0

Organization Structure

10.115.0

15.125.0

25.140.0

40.175.0

Corpo­
rate

Divi
sion

One
Plant

OSHA
Target

49

12

13

12

12

12

3

10

4

3

9

5

7

14

28

11

Board

44

8

13

12

11

9

3

9

4

3

7

5

7

12

25

11

Public b u lle tin s

37

7

9

11

10

10

2

6

4

2

7

3

5

11

21

9

B u lle tin

27

2

6

10

9

6

2

7

3

1

4

2

6

7

14

7

7

0

3

2

2

0

0

3

1

0

2

0

0

3

4

1

20

1

6

4

9

7

2

4

1

1

2

2

4

7

9

3

Consultant

1

0

1

5

8

0

0

0

0

0

0

1

0

1

0

0

Film s e lf

8

0

0

0

8

4

0

3

0

0

0

1

3

3

2

0

Film supplier

16

3

4

3

6

5

0

3

0

0

6

2

2

4

10

4

Film agency

16

0

2

8

6

4

1

4

1

1

2

2

4

5

7

3

Lectures

15

3

3

2

7

3

0

5

0

1

2

2

3

4

8

2

Contests

7

0

2

2

3

2

1

3

0

0

1

0

1

3

3

0

Newspapers

14

0

1

5

8

4

0

5

3

0

0

1

4

6

4

1

Suggestions

10

0

2

4

4

1

0

4

0

0

3

1

2

1

7

2

Pay envelope
Literate

*Three firms did not indicate rates.

205

Number of firms

206

to a lesser extent by "under a sin gle roof" firm s , and b u lle t in s more
by "corporate" firm s.

Aside from use o f b u l l e t i n boards, public

b u lle tin s , and firm b u l l e t i n s , l i t t l e was done by OSHA targeted firm s.
People Involved in Training
Exposure: Table V-69
In response to the OSHA A ct, safety tra in in g a c t i v i t i e s were
expanded to include a number o f positions and/or functions.
these were:

Overall

supervisor (73 percent o f the f i r m s ) , management (65

percent), safety manager (60 p e rc e n t), personnel (43 p e rc e n t), plant
engineer or maintenance (30 p e rc e n t), union committee p a r tic ip a tio n
(28 percent), and employees (55 p ercent).

However, o ne -h a lf o f the

time involvement consisted so le ly of committee work.
observations were apparent:

Two other

there was a r e l a t i v e lack o f union

involvement (th is w i l l also be discussed under union response to the
OSHA Act) and, aside from the few employees who p a rtic ip a te d on
committees, employees in only one of four firms received any safety
training exposure as a re s u lt of the OSHA Act.
Firms with under 50 employees did not have the safety t r a i n ­
ing involvement as was found in other size groups.

S im ila r ly ,

special departments were involved in safety in firms o f increasing
size.

Considering the number o f firms in each category, there did

not appear to be a s ig n if ic a n t pattern r e la t in g to in ju ry frequency
rate.

From the standpoint of organization s tr u c tu r e , "divisions"

had higher incidence o f involvement by safety manager, management,
personnel, and employee committees.

"Under a single roof" firms

had the le a s t percentage of p a rtic ip a tio n by management and

TABLE V-69t~People Involved in Training Exposure.

Item

Fre­
quency

Company Size
Under
50

51250

49

12

Safety manager

29

0

Management

32

5

8

Supervision

36

3

11

Personnel

21

0

3

9

Plant eng., maint.

15

1

4

3

0

Special departments

11

1

Ovet Under
. 0 0 C 2.0

2.0- 5.1- 10.1- 15.15.0 10.0
15.0 25.0

Organization Structure
25.140.0

40.175.0

Corporate

D ivision

One
Plant

Target

12

12

12

3

10

4

3

9

5

7

14

28

11

8

11

6

2

8

3

1

5

3

4

11

14

4

7

12

8

2

8

4

0

4

4

5

12

15

5

12

6

3

8

3

3

6

0

7

11

18

8

9

5

0

6

4

1

3

1

5

10

6

1

5

3

4

0

3

1

1

4

1

2

4

9

4

0

0

3

2

0

0

0

0

0

0

1

2

0

0

0

3

2

6

3

0

4

0

1

2

0

3

2

6

2

10

10

r-

Field sp e cia list

4

0

2

1

1

0

0

1

1

0

1

0

1

1

2

2

Union (committee)

14

1

7

5

1

0

1

5

1

1

5

1

1

5

3

2

Empl. (committee)

13

2

L

5

2

3

2

3

0

1

3

0

1

5

7

4

Empl. (not committee)

14

4

5

2

3

6

0

4

0

0

2

2

0

5

9

2

*Three firms did not indicate rates.

207

Number of Firms

Medical

13

2511, 0 0 0

In ju ry Frequency Rate*

208

supervisors.

"Corporate" categories had almost no union or employee

involvement.

Except f o r increased exposure o f supervisors to s a fe ty

t r a in in g , less than 40 percent o f the OSHA targ e ted firm s had t r a i n ­
ing fo r any o ther p ositio n or fu n c tio n .
General Purpose o f T rain in q :
Table V-70
The p rin c ip a l o b jec tiv es o f the increased s a fe ty t r a in in g
re su ltin g from the OSHA Act centered around providing inform ation and
generating sa fe ty awareness.

In the case o f the form er, th ere was a

f a i r l y consistent p attern in a l l categories o f a n a ly s is , except fo r
firms w ith under 50 employees, w ith in ju r y frequency rates o f 4 0 .1 75.0, and "under a s in g le ro o f" o rg a n iza tio n s .

From the standpoint

of building awareness, only o n e -th ird o f firms w ith under 50 employees
made such e f f o r t s .

Only 10 percent o f a l l firms t r i e d to get

employee feedback other than through committees.

A ll these firms

had over 50 employees, and i n j u r y frequency rates o f 5 .1 - 1 0 .0 .
Supplementary Train in q Programs:
Table V-71
Aside from safety t r a in in g and education of a general n a tu re ,
a large number o f firms also had supplementary t r a in in g programs fo r
s p e c ific purposes.
cases were:

Table V-71 indicates the p rin c ip a l goals in such

fo rk l i f t

truck (73 p e rc e n t), f i r s t aid (59 p e rc e n t),

new employees (37 p e rc e n t), f i r e control
equipment (18 p erc en t).

(33 p e rc e n t), and p ro te c tiv e

F i r s t aid tr a in in g occurred le a s t in the

groups w ith under 50 and over 1,000 employees.

Safety o r ie n ta tio n

for new h ires was s i g n i f i c a n t l y most frequent in firms w ith over

TABLE V-70.—General Purpose of Training.
pre

Company Size

Injury Frequency Rate*

Organization Structure

Item
quency

Under
50

51250

49

12

13

Information

38

8

10

Awareness

34

10

10

12

12

11

11

10

7

2.05.0

5.1- 10.110.0 15.0

13

*Three firms did not indicate rate.

15.125.0

25.140.0

40.175.0

10

1
5

Feed back
Feed back-committee

12

Over Under
1,000 2.0

0

0

0

0

Corporate

D ivision

One
Plant

7

14

28

7

11

20

10

18

Tarset

11

8

209

Number of firms

2511,000

TABLE V-71.—Supplementary Training Programs.
Injury Frequency Rate*
____________________

Company Size
Item
quency

binder
50

2511,000

13

12

12

12

11

8

Number of firms

49

Fork l i f t

36

3

12

10

F irs t aid

29

4

10

10

New hire

18

1

3

3

9

3

2

2

16

3

6

4

Protect, equipment
Fire control

12

♦Three firms did not indicate rate.

Over Under
1,000 2.0

2.05.0

5.1- 10.1- ib . l10.0 15.0 25.0

25.140.0

40.175.0

Corporate

D iv iSion

One
Plant

OSHA
Target

10

4

3

9

5

7

14

28

11

2

9

4

3

9

5

6

13

17

S

5

2

7

3

2

5

4

4 '

8

17

8

7

0

5

3

0

2

1

4

7

7

2

2

2

0

4

2

)

1

0

1

2

6

1

3 .

3

2

2

2

1

5

1

1

6

9

6

5
11

210

51250

Organization Structure

1,000 employees, le a s t frequent in firms with in ju r y frequency rates
over 1 5 .1 , in "under a sin gle roof" o rg an iza tio n s, and in OSHA
targeted firm s.

In s tru c tio n in p ro te c tiv e equipment was low in a l l

categories o f analysis.
Help from Outside Sources:
Table V-72
The study indicated th a t the firms interviewed had increased
th e ir re lia n c e on expertise external to t h e i r o rganization to f a c i l i ­
ta te compliance to the OSHA Act.

While th is involved sa fe ty engineers,

consultants, s ta te agencies, insurance companies, and professional
associations, there seemed to be some in te re s tin g p atterns.

The

principal source o f assistance involved the Michigan Bureau o f Safety
and Regulation under the Michigan Department o f Labor, insurance
companies and, to a much les se r e x te n t, suppliers and various sa fety
counci 1s .
For example, about 72 percent (35) o f a l l firms r e lie d on
state safety inspections, one-fourth o f whom also u t i l i z e d s ta te
train ing help.

Use o f s ta te inspections occurred most fre q u en tly

in firms with over 50 employees (over 75 percent as compared to
50 percent o f those with less than 50 employees), in firms with
lower in ju ry frequency r a te s , and in tw o-thirds o f the OSHA targeted
firms.

No firms with under 50 employees or OSHA targeted organiza­

tions used the safety tra in in g services.
About 72 percent o f the firms u t i l i z e d insurance company
inspections and/or suggestions, with s l i g h t l y b e tte r than o n e -h a lf o f
these also using insurance companies f o r sa fety tra in in g as w e ll.

TABLE V-72.—Help From Outside Agencies.
F
Item

"
quency

Company Size
--------------------------------------Under
51251- Over
50
250 1,000 1,000

Injury Frequency Rate*
Under
2 .0

Organ. S truct,

.0 5.0

5.110 .0

.115.0

15.125.0

25.140.0

40.175.0

3

10

4

3

9

5

7

14

1

2

1 0

Corpo­
rate

D iv i­
sion

OSHA
Target

49

12

13

Chamber of Couwerce

8

0

2

3

3

2

1

3

1

0

1

1

i

1

1

Luncheons

9

1

0

1

7

2

0

2

2

0

1

2

3

3

3

Safety Council

20

1

9

4

6

5

2

7

0

1

3

1

3

6

2

Industry assoc.

9

3

3

1

2

3

0

0

0

1

1

1

1

2

5

Fire Dept., Red Cross

9

3

3

3

0

3

2

1

1

0

1

1

2

4

3

10

1

1

1

7

1

0

2

0

1

3

2

2

2

0

Consultants

4

0

1

3

0

0

0

0

1

0

2

1

0

2

0

Unions

6

1

3

0

2

2

1

1

0

0

2

0

1

1

2

Suppliers

24

3

7

8

6

5

2

7

1

1

5

3

4

4

5

State inspect.

35

5

9

12

8

0

2

Insur. inspect.

34

6

11

Insur. sug.

28

4

8

Insur. tra in .

o9

2

7

Number of firms

12

12

12

Professional asso cia tion

State tra in .

‘ Three firms did not indicate rates.

9

11

2

8

4

2

6

2

5

9

7

3

1

0

4

0

2

I

1

1

2

0

10

7

10

3

6

2

1

7

5

4

8

9

10

6

7

2

5

2

1

6

5

4

6

9

3

3

2

4

0

1

5

3

2

4

7

3

7

212

ASSE, AMA

213

Such p a r tic ip a tio n occurred in almost a l l firm s w ith 51-250 and 2511.000 employees, and in about 50 percent o f the firms above and below
these groups in s iz e .

I t also happened most fre q u e n tly in firms w ith

low in ju ry ra te frequency ra tes o f under 5 . 0 , or high ones w ith over
25.1, and in over 80 percent o f the OSHA ta rg e te d firm s .

ABout one-

h a lf o f the firm s r e lie d h e a v ily on s u p p lie r s , mainly firms w ith
over 50 employees, in ju r y frequency rates below 10.0 and above 2 5 .1 ,
"corporate" and "under a s in g le roof" f ir m s , and about o n e -h a lf o f
the OSHA targeted firm s .
the firms interview ed.

Safety councils were used by 40 percent o f
This included 70 percent o f the firm s w ith

51-250 employees, about o n e -h a lf o f those w ith 251-1,000 and over
1.000 workers, but almost no firms with under 50 employees.

I t also

occurred mostly in firms w ith low in ju r y frequency rates o f under
10.0.

Only about 20 percent o f the OSHA targ eted firms took advantage

of such services.
Use of the chamber o f commerce, special OSHA-oriented
luncheons, professional associations such as industry and trade
groups, American Society o f Safety Engineers, Red Cross, or f i r e
department, were r e lie d upon in about 25 percent o f the firms in
each group.

When the chamber o f commerce was in v o lv ed , th is occurred

in firms w ith over 50 employees, and with in ju r y frequency rates under
10.0.

Luncheons u su ally were confined to firm s w ith over 1,000

employees.

Industry associations and o rg anizations such as the Red

Cross were found most fre q u e n tly in small firm s w ith under 1,000
employees, and in about 30-45 percent of the OSHA targeted firm s .

214

The use o f consultants ex tern a l to the f ir m occurred in
only four o f the 49 firm s .

Three o f these firm s were in the 251-

1,000 employee group, and the o ther in the 51-250 group.

Three o f

these had in ju r y frequency ra te s o f over 2 5 .1 .
Union Involvement and S p e c ific A c t i v i t i e s
There was evidence o f increased union p a r t i c ip a t i o n in s a fe ty
a c t i v i t i e s in g e n e ra l, and OSHA Act compliance in p a r t i c u l a r .

This

encompassed c rea tin g union s a fe ty and/or OSHA s p e c i a l i s t s , o r ie n ta tio n
for stewards, providing general p u b li c it y and education f o r members
(workers), monitoring s a fe ty a c t i v i t i e s , covering s a fe ty in the
c o lle c tiv e bargaining agreement, and p a r t i c ip a t i o n or committees.
There were also increased n egative responses such as grievances and
strik es which re s u lte d .

The fo llo w in g analysis summarizes the

findings in the 37 firm s th a t had unions.
A ttitu d e :

Table V-73

In only 25 percent o f the firm s were unions e n th u s ia s tic
about the a c t , w ith no s i g n i f i c a n t p a tte rn fo r firm s i z e , in ju r y
frequency r a t e , o rg an izatio n s t r u c t u r e , or s e n s i t i v i t y to OSHA.
About 62 percent were " c o o p e ra tiv e ,” w ith higher p ro p o rtio n ate
incidence in firms w ith over 50 employees, in ju r y frequency rates
below 5 . 0 , and in o n e -h a lf o f the OSHA targeted firm s .

In d iffe re n c e

or resistance occurred in sm aller firm s o f under 1,000 employees.
Po sitive A c t i v i t i e s :

Table V-74

S l ig h t ly less than o n e -h a lf o f the firms w ith unions had
(a) established a union sa fe ty s p e c i a l i s t , and (b ) provided s a fe ty

TABLE V-73.--Union Involvement.

Fre­
quency

Item

Number of firms

Injury Frequency Rate*

Company Size
Under
50

51250

13

2511, 0 0 0

49

12

Have unions

37

6

Enthusiastic

9

1

3

1

Cooperative

23

3

8

In d iffe re n t

3

1

Resistant

1

0

Over
1 ,0 0 0

12

12

8

11

Under
2 .0

12

. 0 -• 5.15.0
1 0 .0

2

3

10

Organization Structure

.1 15.0

15.125.0

25.140.0

40.175.0

4

3

9

5

7

14

28

12

20

1 0

Corpo­
rate

Divi
sion

Gne
Plant

OSHA
Target

11

Union a ttitu d e
9

2

7

4

3

6

4

5

4

1

0

4

1

0

2

1

2

3

4

1

5

7

7

2

3

2

3

1

2

3

4

6

1

1

0

1

0

0

0

0

1

2

0

0

3

1

0

1

0

0

0

0

1

0

0

0

0

1

0

0

12

*Three firms did not indicate rate.

n

8

TABLE V-74.—Union Involvement, Positive A c tiv itie s .
tt i t

Item

Fre­
quency

Injury Frequency Rate*

Company Si2 e
Under
50

51250

13

2511, 0 0 0

Number of firms

49

12

Have unions

37

6

Created specialists

18

6

5

2

Steward orientation

17

6

4

Member p u b lic ity

10

6

Member education

9

Monitors firm

Over
1 ,0 0 0

12

12

8

11

Under
2 .0

12

. 0 -■ 5.11 0 .0
5.0

2

3

10

Organization Structure

iO .l15.0

15.125.0

25.140.0

40.175.0

4

3

9

5

Corpo­
rate

OSHA
Target

Divi
s i on

One
Plant

7

14

28

12

20

8

1

10

2

11

9

2

7

4

3

6

4

5

5

6

1

3

3

0

2

2

2

8

2

5

5

0

2

9

2

2

•i
a

3

4

0

1

3

4

0

0

3

0

1

2

2

2

6

1

6

1

0

2

4

0

0

7
<_

0

2

1

2

c

5

1

21

6

8

5

2

4

1

3

4

j

4

3

0
t.

7

8

6

0

0

2

4

0

0

1

1

>
c

1

5

1

16

0

8

5

3

1

1

6

2

1

2

8

6

2

12

3

Positive a c tiv itie s

C. B. agreement
On committee

♦Three firms did not indicate rate.

}

2

)
1

12

J

217
orien tatio n f o r union stewards.

While th ere was no apparent r e l a ­

tionship to s i z e , th ere was markedly less a c t i v i t y in firms w ith
251-1,000 employees.

There seemed no r e la t io n s h ip f o r in ju r y f r e ­

quency r a t e , o rg a n iza tio n s t r u c t u r e , or OSHA targeted firm s .
O v e r a ll, l i t t l e b e t t e r than one-fourth o f the unions had
member oriented p u b li c it y o r educational programs.

A ll union firms

with under 50 employees had them, and about 16 percent o f those w ith
over 1,000 employees.

They were p ro p o rtio n a te ly most frequent (3 0 -

40 percent) in firms w ith in ju r y frequency rates o f under 2 . 0 , or
those with over 2 5 .1 , and in those o f "under a s in g le roof" type (one
of f i v e f ir m s ).
Increased s a fe ty committee membership by unions was evident
in 41 percent o f the fir m s , a l l with over 50 employees, and p r i n c i ­
p ally in the groups ranging from 51-250 and 251-1,000 employees.
There was increased s a fe ty coverage in the c o l le c t i v e b ar­
gaining agreement in two o f the eleven firms in the over 1,000
group.
Negative Response:

Table V-75

In about 60 percent o f the firms w ith unions, the OSHA Act
was used as a "club" to improve s a fe ty c o n d itio n s .

About 57 percent

had more s a f e t y - r e la t e d grievances, about o n e -h a lf used OSHA to
malinger or a g i t a t e , and about o n e -th ird used i t fo r p o l i t i c a l
poses.

pur­

In about 25 percent o f the firms there were OSHA r e la te d s t r ik e s .
A ll union firm s w ith under 50 employees in d ica te d negative

responses in each o f the categories mentioned above.

About o n e -h a lf

of the 51-250 and over 1,000 employee groups in d ica te d OSHA was

TABLE V-75.—Union Involvement, negative Response.
Fre_
q,jency

Company Size
Under
50

Number of firms

40

12

Have unions

37

6

Strikes

8

Grievances

51250

2511,0 0 0

13

12

In ju ry Frequency Rate*
Over
1,0 0 0

12

Under
2 .0

2.05.0

12

3

5.1-

Organization Structure

10 .0

10.115.0

15.125.0

25.140.0

40.175.0

Corporate

D ivision

One
Plan)

10

4

-i>

9

5

7

14

28

12

20

!

9

2

7

4

3

fi

4

5

0

2

4

0

0

I

0

1

1

1

2

5

2

4

9

7

0

4

4

0

3

2

4

9

8

6

3

2

7

6

1

1

4

1

2

3

3

6

9

6

0

1

5

6

0

1

2

0

1

2

2

4

6

7

1

0

0

4

1

0

1

0

1

1

0

1

7

6

6

3

7

7

1

3

4

1

2

4

L

12

8

5

0

21

6

Malinger, agitate

18

P o litic a l

12

1

Negative response

Depends on mgt.
OSHA a “club"

8

22

*Three firms did not indicate rates.

■>

8

12

219

used as a "c lu b ."

The over 1,000 group in d ica te d grievances (80

percent), malingering and a g ita tio n (60 p e rc e n t), and p o l i t i c a l
a c t i v i t ie s (45 p e rc e n t).

The use o f OSHA as a "club" also occurred

most often in firm s with in ju r y frequency ra tes o f under 2 .0 and
over 4 0 .1 , and in " d iv is io n " arid "under a s in g le ro o f" type of
organizations.

S trik e s were most evident in firms w ith in ju r y f r e ­

quency rates under 2 .0 and "under a s in g le roof" f ir m s ; grievances,
in firms w ith in ju r y frequency o f under 2 . 0 , and in " d iv is io n " and
"under a sin g le roof" type firm s .

Malingering and a g it a t io n was

most prevalent when i n j u r y frequency was under 5 .0 and over 2 5 . 1 ,
and in a l l

types o f firm s .
A t t itu d e Toward Excluding Small
Businesses From the Act

As Table V -76 in d ic a te s , every firm but one, regardless o f
s iz e , in ju r y frequency r a t e , o rg an iza tio n s t r u c t u r e , or whether or not
they were targed f o r OSHA in s p e c tio n , f e l t th a t a l l
should be forced to comply with the a c t .

small businesses

About o n e -h a lf o f the firms

interviewed volunteered t h a t (a ) small businesses have never made
necessary s a fe ty changes, and should be forced to do so, (b) th a t
OSHA standards are e s p e c ia lly needed to ensure an adequate s a fe ty
program in marginal fir m s , and (c ) th a t i t is t h e i r own f a u l t i f
compliance causes changes in o rder to meet minimal standards.

About

one in seven stated th a t the small businessman lacks common sense in
regard to occupational s a fe ty .

There was no appreciable d iffe re n c e

re la tin g to firm s ize in making these a d d itio n a l comments.

Those with

both high and low in ju ry frequency rates p ro p o rtio n a te ly expressed

TABLE V-76.--Inclusion of Small Businesses.

Item

Fre­
quency

Iniury frequency Rate*

Company Size
Under
50

51bU

2

2511 ,000

Over Undi
1,00 0

2.1

2.05.0

5.1- 10.1- 15.1lil.O 15.0 25.u

Organization Structure
25.14l'.0

40.175.u

..jrporitf*

D ivis i on

One
Plant

7arget

49

12

i:i

12

12

12

3

10

4

3

0

5

7

19

28

11

In c l. small business

48

11

13

12

12

12

3

10

4

3

9

4

7

14

28

11

Never made necessary
changes

24

4

6

9

5

5

2

4

3

2

5

1

3

9

1?

6

Especially need for
marginal

24

6

3

8

7

6

1

2

2

2

5

2

4

8

12

6

Own fa u lt

20

5

5

4

6

8

1

2

3

3

14

1

1

5

0

0

0

1

6

Lack common sense

7

4

‘ Three firms did not indicate rate.

3

1
1

0

1

4
0

2

6

3

220

Number of firms

221
such sentiments.

A l i k e percentage o f each o f the d i f f e r e n t

organization s tru c tu re groups and about 55 percent o f the OSHA
targeted firms volunteered these comments.
Management A tt it u d e Toward OSHA Standards
and Required Compliance
There was evidence th a t management fre q u e n tly lacked f u l l
understanding and had doubts as to the appropriateness and consis­
tency o f OSHA standards.

However, there was general acceptance o f

the ac t and ap p reciation f o r long-range b e n e fits which might accrue
because of i t .
Standards:

Table V-77

About 79 percent o f the firms interview ed f e l t the OSHA
standards were ambiguous, 86 percent th a t they were hard to index in
some usable form, 57 percent th a t they were d i f f i c u l t to use, and
57 percent th a t they tended to " n i t p ic k ."

In a d d itio n , 40 percent

thought a p p lic a tio n o f the standards should be tempered; one o f fo u r
firms f e l t i t was c o s tly j u s t to buy m a te ria ls necessary to explain
the standards f o r t h e i r f i r m , and one o f fo u r in d ic a te d i t was hard
to s e ll the a p p lic a tio n and methods required to management,
employees, and unions.
There was no real d is c e r n ib le d iffe r e n c e as re la te d to company
s iz e , w ith the fo llo w in g exceptions.

The g re a te s t in d ic a tio n o f " n i t

picking" was described in firms w ith over 1,000 employees, the le a s t
in firms in the 251-1,000 employee group.

The g re a te s t incidence of

d i f f i c u l t y in using the standards, and expense o f gathering appro priate

TABLE V-77.--Management A ttitude Toward OSHA Standards.
Fre­
quency

I tem

Injury Frequency Rate*

Company Size
Under
50

51250

2511, 0 0 0

Organization Structure

.0 5.0

5.1-

2 .0

1 0 .0

.1 15.0

15.125.0

25.140.0

40.175.0

12

12

3

10

4

3

9

5

10

11

1

8

4

1

8

11

12

2

8

4

2

7

8

2

7

3

10

2

5

2

Over
1,00 0

Under

2

1 0

Corpo­
rate

OSHA
Target

Divi
sion

One
Plant

7

14

28

5

6

10

23

7

8

5

7

11

24

9

1

5

2

5

8

15

15

1

3

2

4

6

17

4

2

1

3

5

12

1

49

12

13

Ambiguous

39

11

9

Hard to index

42

11

D iff. use

28

5

7

9

N it pick

27

7

7

3

Temper applic.

20

4

5

4

7

6

2

5

2

Honey to find STD

12

2

2

5

3

3

1

3

1

1

2

I

4

1

7

0

Hard to sell

12

0

5

4

3

2

0

6

1

1

1

1

1

4

7

0

Number of firms

12

11

Standards

10

9
10

10

Interpretation

31

8

9

9

5

8

1

8

2

1

7

4

3

6

22

7

Trade term.

20

7

3

5

5

7

0

2

1

1

4

3

2

4

14

6

Inappropriate

19

6

3

5

5

6

0

4

1

1

3

3

2

2

15

5

Changing

18

2

7

6

3

5

2

5

0

1

3

1

2

5

11

2

State standards

16

2

3

6

5

4

0

5

1

0

3

2

3

2

11

2

Supplier interp.

4

2

0

1

1

3

0

0

0

0

1

O

0

1

3

Short run apl.

9

4

3

1

1

4

2

1

0

0

2

O

0

2

. 7

Regional interp.

5

0

0

0

5

3

0

1

1

0

0

0

3

2

*Three firms did not indicate rate.

0

1

3
0

222

Inconsistent standards

223

material to implement the standards, was in the 251-1,000 employee
group.

The fewest comments about d i f f i c u l t y in using the standards

was in firms w ith under 50 employees (45 percent o f th is group).
In r e la tio n s h ip to in ju r y frequency r a t e s , a g re a te r per­
centage o f firm s w ith high rates o f over 25.1 and under 2 .0 found the
standards ambiguous and hard to index.

Firms w ith higher rates

(over 15 .1) commented p ro p o rtio n a te ly le a s t o fte n on the d i f f i c u l t y
of implementing the standards, and the need to temper the standards.
Firms w ith rates under 5 .0 had less tendency to f a u l t the standards
on a basis o f " n i t p ic k in g ."
The only p attern r e la t in g to o rg an iza tio n s tr u c tu r e was th a t
"division" and "under a sin g le roof" type o f firm s experienced more
d i f f i c u l t y in " s e llin g " the a p p lic a tio n o f the standards, and
"corporate" (about 60 percent o f the firm s ) and "under a s in g le roof"
(25 percent o f the firm s ) mentioned the expense o f purchasing
materials necessary to in t e r p r e t or apply the standards.

The only

s ig n ific a n t in d ica tio n s by OSHA firms were th a t the standards were
ambiguous (64 percent o f the f i r m s ) , hard to index (80 percent o f
the f i r m s ) , and " n i t picking" (36 percent o f the fir m s ) .
Table V-77 also breaks down the a t tit u d e s of the firms
interviewed in to why firms might fe e l OSHA standards were considered
inconsistent.

About 63 percent o f the firms mentioned general m isin­

t e r p r e t a t io n , 40 percent discrepancies w ith trade term inology, 39
percent inappropriateness f o r t h e i r business, 37 percent th a t the
standards were constantly changing, and 34 percent inconsistency with
state standards.

There was no s ig n i f i c a n t p a tte rn when considering

224
firms by in ju r y frequency r a t e groups.

However, in almost each area

of comment, "under a sin g le roof" type o rg an iza tio n s tru c tu re s had
proportionately a more su b sta n tial number o f firms in d ic a tin g these
d iffic u ltie s .

OSHA targeted firms responded as fo llo w s in regard to

in h ib itin g fa c to r s :

in t e r p r e t a t io n (63 p e rc e n t), tra d e terminology

differences (53 p e rc e n t), and inappropriateness (46 p e rc e n t).
A ttitu d e Toward S a fe ty O rie n ta tio n o f
the Act: Table V-78
About 79 percent o f the firms interviewed sta te d t h a t the
OSHA Act stressed s t a t i s t i c s r e la t in g to in ju r y occurrence ra th e r than
the actual s a fe ty o f the worker.

This was p revalent to a g re a te r

degree in firm s w ith over 50 employees, in firms w ith accident f r e ­
quency ra tes from 2 5 . 1 - 4 0 . 0 , as w ell as in almost a l l OSHA targeted
firm s.

F u rth e r, 45 o f the t o t a l o f 49 firms stated th a t such fig u re s

were not meaningful.
Other comments included:

55 percent said employees do not

understand the need fo r and meaning o f the law, w ith no d is c e rn ib le
pattern f o r s i z e , in ju r y frequency r a t e s , e t c . ; 29 percent th a t s a fe ty
adaptations would place l im it s on job scope or e ffe c tiv e n e s s , p r i n c i ­
p ally firms w ith under 50 employees, those w ith in ju r y frequency rates
under 2 .0 and "under a sin g le roof" type o f o rg a n iza tio n s .

Almost

20 percent o f the firms c ite d the lack o f employee c o n t r o l , mainly
firms w ith under 50 employees, as did about 45 percent o f the OSHA
targeted firm s .

.Only 14 percent o f the firms suggested OSHA advisory

inspections; only 10 percent th a t employees were not s a fe ty minded

TABLE V-78.—Management A ttitude Toward Safety O rientation.
Company Size

In ju ry Frequency Rate*

Under
50

57250

2511,000

Number o f firms

49

12

13

12

Emphasis on s ta tis tic s
not worker

39

S ta tis tic s not mean­
ingful

45

10

12

12

9

2

2

1

4

Paperwork

7

12

9

Over Under 2.01,000 2.0
5.0

5.1- 10.1- 15.110.0 15.0 25.0

25.140.0

40.175.0

10

4

3

9

5

Corporate

D iv ision

One
Plant

Target

7

14

28

11

12

12

3

11

10

1

8

4

3

5

5

5

12

22

10

11

11

3

9

4

2

8

5

7

13

25

10

4

0

1

2

1

0

0

3

2

4

3

6

5

No empl. control

10

5

0

2

3

4

0

0

3

0

1

2

1

3

No employee
understanding

27

5

9

8

5

5

2

5

3

1

5

4

4

8

15

6

5

3

1

1

0

2

0

0

0

1

1

1

0

0

5

2

14

8

2

1

3

6

0

2

2

0

2

1

1

1

Advisory inspections

7

1

3

2

1

1

1

2

1

0

1

1

1

4

2

0

Asked OSHA fo r help

3

3

0

0

0

1

0

0

0

0

2

0

0

0

3

1

Not safety minded
Limits job

*Three firms did not indicate rates.

12

3

225

quency

Organization Structure

226

(in sm all, “under a s in g le roof" f i r m s ) ; and only 6 percent had
requested assistance from OSHA.
General Reaction to the OSHA Act:
Table V-79
Only one firm in d ica te d " fe a r" re la te d to the need to comply
with the OSHA A c t, and even in th is instance th is was not pronounced.
Further, only two firms said they had any misapprehension about OSHA
inspections, although f i v e said they were not looking forward to them.
These reactions were expressed e a rly in the in te rv ie w and reasserted
la t e r during more in te n s iv e in q u ir y .

In f a c t , a l l but th ree firms

indicated they would r e l y on changes already made and were w i l l i n g to
risk the re s u lts o f an OSHA inspectio n.
lonq-run sa fe ty value o f the a c t.

A l i k e number stressed the

Not one firm knew o f a company th a t

“had gone out o f business" as a r e s u l t o f

the a c t. Only one had lo s t

business

stamping d ie s ) .

( i t had to switch to progressive

this f ir m was s t i l l

However,

fav o rab le to the act because , i t was f e l t t h a t the

loss o f business would "even out" when competition was forced to
make such changes.
Table V-79 in d ica te s u n s o lic ite d comments by the firm s i n t e r ­
viewed.
About 67

(The absence o f comments does not mean a negative response.)
percent o f the firms sta ted th a t

and th is included nine o f the

eleven OSHA

OSHA was doing a good jo b ,
targeted firm s .

About 71

percent said they thought t h a t OSHA was experiencing “growing pains,"
and when these were overcome, the law would be e f f e c t i v e .
e s p e c ia lly tru e o f firms w ith over 251 employees.

This was

TABLE V - 7 9 . - - G e n e r a l Reaction t o the Act.
.■*. t r ■*. ' *-«

Freuency

Under
50

51250

/

2511, 0 0 0

Over Under
1,000

2.0

!. 0 -■ 5.110 .0
i.O

.115. 1

15. 125.0

25.140.0

4U. 175.0

1 0

Corpo­
rate

Divi
sion

One
Plant

OSHA
Target

3

10

4

3

9

5

7

14

28

0

0

1

0

0

0

0

0

0

1

0

0

1

0

0

0

0

0

0

0

0

1

0

12

11

11

3

9

3

3

9

5

6

13

49

12

13

12

12

12

Fear OSHA

1

1

(1

0

0

Fear OSHA inspection

1

1

0

0

W ill ris k inspection

46

10

13

Number of firm';

Organization Structure

Injury Frequency Rate

Size

27

11

n

6

1

3

1

2

9

3

9

3

2

8

4

0

2

4

0

Just bad p u b licity

7

1

3

2

1

1

1

3

0

0

2

0

1

1

5

2

Know firm out of
business

0

0

O

0

0

0

0

0

0

0

0

0

0

0

0

0

Lost business

1

0

0

1

0

0

0

0

0

0

1

0

0

0

1

0

9

10

8

3

6

3

3

5

3

7

12

18

9

9

2

8

3

3

5

4

5

12

18

7

Good job

33

9

9

Growing pains

35

8

3

Reasonable inspection

27

6

5

5

11

6

2

6

4

2

2

3

i

10

10

8

Firms OSHA inspected

29

6

o

6

11

7

2

6

4

?

2

3

7

12

10

8

Long-run cost reduc.

24

4

5

8

7

5

3

5

3

1

4

3

3

8

13

7

More spec, compre.

43

12

12

10

9

11

3

7

4

2

8

5

5

13

25

11

Forced state and ins.

43

12

12

10

9

11

3

7

4

2

8

5

5

13

25

11

Provided guidelines

39

11

3

6

4

2

6

5

5

14

20

11

0

3

0

0

0

1

0

2

10

9

Posit i ve effects

S ignificant law

7

9
1

11
1

*Three firms did not indicate rates.

9
2

10

3

3

5

0

L

Z

Not look forward

Z

Item

1 ’ **

Coiif

228

There were 29 firms th a t had been exposed to OSHA in spectio ns,
14 in Michigan plants and 15 in plants in other s ta te s .

A ll but two

of these firms f e l t th a t OSHA was reasonable in i t s inspections.
Over 88 percent o f the firms interview ed f e l t th a t OSHA
standards were more s p e c ific and comprehensive than s ta te or insurance
company standards, and a l i k e percentage f e l t th a t as a r e s u l t o f these
standards s ta te or insurance standards were more demanding.

In ad d i­

tio n , 80 percent o f the firm s thought OSHA instrumental in s e ttin g
forth safety g u id e lin e s .

About o n e -h a lf o f the firms c ite d long-run

cost reductions as a r e s u lt of the a c t.

This was most pronounced in

large s iz e firms w ith over 251 employees, and 64 percent o f the OSHA
targeted firm s .

About one firm in seven thought OSHA was the most

s ig n ific a n t sa fe ty law ever.

This was mainly in firm s w ith over 251

employees and w ith in ju r y frequency rates below 10 .0.
Misgivings About OSHA:

Table V-80

About 53 percent o f the firms interviewed commented about
lack of understanding by employees.

This included a l l

firms in the

51-250 employee group, and o n e -h a lf o f those firms w ith more employees,
and i t was more evident in firms w ith higher in ju r y frequency rates
of over 10 .1.

From 14 to 18 percent w orried about (a ) the amount of

the expenditures required to comply w ith the a c t , or (b) the timing
of these expenditures.

This was more prevalent in firms w ith low

inju ry frequency rates below 15.0.
Approximately 30 percent of the firm s with unions mentioned
that these unions used the OSHA Act f o r harassment.

One o f seven

TABLE V-80.—Misgivings About OSHA.
Ccmpany Size
uem

quency

Under
50

SI250

251-

Injury Frequency Rate
Over Under

1,000 1,000

2.0

Organization Structure

2.0- 5.1- 10.1- 15.1- 25.1- 40.1- Corpo­
5.0
10.0 15.0 25.0 40.0 75.0
rate

D ivi­
sion

One
Plant

Target

49

12

13

12

12

12

3

10

4

3

9

5

7

14

28

11

Employee-no under­
standing

26

2

11

7

6

2

2

5

3

3

4

4

4

8

14

3

Unions harass

11

0

3

1

7

3

1

1

2

1

1

2

3

4

4

0

Horry expen. amount

9

n

4

0

3

4

1

3

0

0

0

1

1

3

5

0

Horry expen. timing

7

2

3

0

2

2

1

1

2

0

0

1

0

3

4

0

Internal cost absorb.

5

1

1

1

2

3

0

1

0

0

0

1

2

1

2

0

Bad p u b lic ity

7

1

3

2

1

1

1

3

0

0

2

0

1

2

4

2

Supplier scare

4

0

1

2

1

2

1

1

0

0

0

0

0

2

2

0

Causes problems

3

2

0

0

1

3

0

0

0

0

0

0

0

1

2

1

Employee compl. gr.

1

0

0

0

1

0

0

1

0

0

0

0

1

0

0

0

Employee—bundle

2

0

1

1

0

0

0

0

1

0

0

1

0

0

1

1

Hidden costs

1

0

0

0

1

1

0

0

0

0

0

0

0

1

0

0

*Three firms did not indicate rates.

229

Number of firms

230

of a l l firms suggested th a t OSHA had merely received bad p u b li c it y .
Less than 10 percent o f a l l firm s mentioned i n d i v i d u a l l y the fo llo w ­
ing:

concern over the a b i l i t y to absorb compliance costs i n t e r n a l l y

with su p plies, m a t e r ia ls , or la b o r , s u p p lie r scare t a c t i c s , other
problems th a t might be caused by OSHA, employee com plaints, employees
in te rp re tin g s a fe ty expenditures as in d ic a tiv e o f high p r o f i t s , or
resu ltin g "hidden" or nonconspicuous re la te d costs.

CHAPTER VI

SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS
Summary
In 1969 the Congress o f the United States passed the W illia m s Steiger Occupational S afety and Health Act (P u b lic Law 9 1 -9 5 6 ), and i t
became e f f e c t i v e in May o f 1970.

The OSHA A c t, as the law was c a l l e d ,

represented a concerted and dramatic new approach in concept, a t t i t u d e ,
content, coverage, and enforcement.

I t was a n tic ip a te d t h a t v i r t u a l l y

every businessman would be a ffe c te d in some manner, and t h a t most
would be required to make s i g n i f i c a n t adjustments in order to comply
to the OSHA A ct.
The OSHA Act provided a pervasive and coordinated n a tio n a l
safety program f o r occupational s a fe ty and h e a lth fu l working condi­
tio n s , as w ell as the in s tru m e n ta lity fo r implementing the program.
Almost every company was covered regardless o f s i z e , since the ac t
included a l l non-government employees except those few covered by
other fed eral s a fe ty laws, and th ere were no exceptions f o r small
firm s , even those w ith one employee.

The a c t es tab lish ed minimum

consensus standards f o r s a fe ty and h e a lth .

Accurate s a fe ty and

health records were both required and reviewed.

Compliance was

monitored, and employers were held l e g a l l y responsible f o r a f f i r m a t i v e
safety programs and adherence to the conditions and standards s e t
forth by the A ct.

Employee rig h ts to be kept informed o f company
231

232

safety a c t i v i t y , to p a r t ic ip a t e in s e ttin g standards, and to express
related "grievances" d i r e c t l y to OSHA o f f ic e s were guaranteed.
The purpose o f t h is study was to examine the e a rly years o f the
OSHA Act in terms o f the impact upon re p re s e n ta tiv e firm s in the s ta te
of Michigan.

An extensive review o f e x is tin g l i t e r a t u r e uncovered

l i t t l e systematic research on the su b ject.

I t was f e l t th a t such

description and analysis would provide some in s ig h t in to the notable
effectiveness o f the act f o r accomplishment o f i t s purpose and o th e r
possible re la te d e ffe c ts on the o rg a n iz a tio n .

S p e c i f i c a l l y , eleven

general areas o f management p ra c tic e were selected f o r observation.
1.

A d m in is tra tiv e R e s p o n s ib ility and Functional Alignment: new posi­
tio n s , fu n c tio n s , t i t l e s , re p o rtin g procedures, dual r e s p o n s ib i li ­
t i e s , interdepartm ental re la tio n s h ip s .

2.

Functional Duties o f S a fe ty Designated Persons: l in e and s t a f f
r e la t io n s h ip s , s a fe ty a n a ly s is , c o n s u lta tio n , and compliance,
s a fe ty budget determ ination and c o n tr o l, purchasing o f s a fe ty
re la te d equipment, record keeping, s a fe ty p o lic y , and t r a in i n g .

3-

Status o f the Safety F u n ctio n :

4.

Safety Committees:
s itio n .

5.

Procedures, Rules, and In s p e c tio n s : s a fe ty co n tro l methods,
rewards or san ctio n s, re p o rts , special safeth a c t i v i t i e s .

6.

Awareness, Degree o f Comprehension and Responsiveness to the A c t :
re la te d knowledge, a t t i t u d e , r e s is ta n c e , p a r t i c ip a t i o n .

7.

Investment in S a fe ty : c a p ita l equipment, s a fe ty d evices, personal
p ro te c tio n , f a c i l i t i e s .

8.

Communication, T ra in in q , and P u b l i c i t y : meetings and committees,
formal i n s t r u c t io n , media used, people in v o lv ed , purpose o f s a fe ty
t r a i n i n g , help from outside sources.

9.

Involvement and S p e c ific A c t i v i t i e s by Unions:
responsiveness,
committees, in s p e ctio n s , t r a i n i n g , and communication f o r stewards
and members.

changes in s ta tu r e and p re s tig e .

new or increased, purpose, membership compo­

233

10.

Compliance by Small Businessmen
ac t.

should they be covered by the

11.

Management A t titu d e Toward Standards and Compliance: c l a r i t y ,
consistency, s a fe ty o r i e n t a t i o n , meaningful ness, general re a c tio n .
In order to f u l l y understand why the OSHA Act was considered

so sweeping, and the im p lic atio n s so complicated and p e rp le x in g , the
h is to ric a l background leading up to the ac t was examined.

Thus, s o c ia l,

p o l i t i c a l , and economic considerations were discussed to g e th e r w ith
a tt it u d in a l changes, s t a t i s t i c a l comparisons, and government a c t i v i t y
re la tin g to occupational s a fe ty and h e a lth .

S i m i l a r l y , th ere was a

review o f the l i t e r a t u r e a p p ro p ria te to the eleven general areas
selected fo r study to provide a t h e o r e tic a l background fo r recognizing
changes which might be a t t r ib u t e d to the a c t.
A sample o f 49 firm s in the s ta te o f Michigan was used fo r
this study.

The data was c o lle c te d through personal

interview s w ith

various members o f the in d iv id u a l fir m s , using a q u e s tio n n a ire /g u id e .
The 49 firm s studied were grouped f o r s p e c ific a n a ly s is on
the basis o f fo u r c h a r a c te r is t ic s i t was f e l t might lead to v a r ia tio n s
in the impact o f OSHA on them:

(1 ) company s iz e in terms o f number

of employees, (2 ) in ju ry -fre q u e n c y r a t e ,

(3) type o f o r g a n iz a tio n ,

e . g ., under a s in g le ro o f, corporate o f f i c e w ith p la n ts "o n -th e premises," and d iv is io n s o f m u l t i- p la n t o p e ra tio n s , and (4) firm s
targeted by OSHA f o r special a tt e n t io n and inspection because o f
th e ir higher than average in ju r y frequency r a t e .

On t h is b as is ,

the major fin d in g s o f the study can be summarized as fo llo w s below.

234

Administrative R e s p o n s ib ility and
Functional Alignment
Designated p o sitio ns or functions responsible fo r s a fe ty
increased in both number and scope.

Firms had added f u l l - t i m e safety

managers, new s a f e t y - r e la t e d t i t l e s , and created new s a fe ty p o s itio n s .
Safety s t a f f s had been increased and the re p o rtin g procedure in the
chain o f command changed f o r the s a fe ty designated person.

Both

the incidence and the actual time devoted to s a fe ty by the sa fe ty
responsible person was increased s i g n i f i c a n t l y .
were two other re la te d c h a r a c t e r is t ic s .
jobs were now involved in s a fe ty .

In a d d it io n , th ere

F i r s t , more people in more

S afety r e s p o n s ib ilit y was in c re a s ­

ingly shared w ith some other fu n c tio n a l duty, p r i n c ip a ll y w ith p la n t
production, su p ervision , c h ie f engineer, and/or maintenance d ep art­
ment.

Second, personnel was not appreciably involved.

When personnel

did p a r t i c i p a t e , i t was p r im a rily f o r record keeping purposes.

The

positions now mainly responsible fo r s a fe ty were in the production/
technical re la te d areas.
The s iz e o f the firm as determined by the number of employees
influenced the degree and nature o f the changes discussed.

Large

firms w ith over 1,000 employees had more people in more jobs involved
in s a f e t y , a g reater lik e lih o o d o f a s a fe ty manager, a la r g e r amount
of time devoted to s a f e t y , and conversely, fewer changes r e l a t i v e to
reporting procedures and d u tie s .

Firms in both the 251-1,000 and

50-250 categories had a g re a te r tendency to share s a fe ty w ith some
other jo b , to increase s a fe ty s t a f f s , to add more new p o s itio n s , and
to a l t e r the e x is tin g repo rtin g procedures.

235

The in ju r y frequency ra te was also an important basis f o r
analysis.

Firms w ith high in ju r y frequency rates experienced more

change in terms o f increased safety r e s p o n s i b i l i t y , a lte re d re p o rtin g
procedures, new positions and t i t l e s , and involved the p la n t manager
to a g reater e x te n t.
these firm s.

The r o le o f personnel was also more lim ite d in

In c o n tra s t, those firms w ith lower rates had

more and d i f f e r e n t positions and functions responsible f o r s a fe ty ,
and g reater use o f s p e c ia lis ts such as noise, l i g h t i n g , and sa fe ty
consultants.
Single p la n t firm s "under one roof*1 responded to the act to
a greater extent than corporate o f fic e s w ith plants "on the premises,"
or division s o f m u lt i- p la n t o perations.

Safety a c t i v i t i e s were also

more l i k e l y to be vested w ith the plant manager, and the re po rtin g
procedure to involve top management.
Firms targeted by OSHA fo r inspection because o f high in ju r y
frequency rates responded by c re a tin g f u l l - t i m e s a fe ty managers, new
safety positions or t i t l e s , and by devoting more time to s a fe ty .
g en erally, th is represented less than o n e -th ird o f the OSHA t a r ­
geted firms studied.
Functional Duties of Safety
Designated Persons
A f t e r the a c t , there were new and increased s a fe ty d u tie s .
These consisted o f paperwork, record keeping, p o licy statem ents,
inspections, s a fe ty committee a c t i v i t i e s , cross referen cin g or
c l a r i f y i n g OSHA standards, s a fe ty p re s e n ta tio n s , and t r a in in g new
hires in sa fe ty work procedures.

S i m i l a r l y , changes were also

But

236

evident in the areas o f s a fe ty a n a ly s is , co n su ltatio n and compli­
ance, and budget d eterm in atio n , a p p ro p r ia tio n , and c o n tr o l.

In

addition, there were new and increased budgets fo r s a fe t y , and a
greater tendency f o r requests f o r expenditures fo r OSHA compliance
to be rubber stamped.

The safety responsible person also had more

influence and control over the purchase o f s a fe ty equipment and/or
personal p ro te c tiv e devices and the s e le c tio n o f the ap p ro p ria te
supplier.
This change was not re la te d to firm s iz e .

However, firms

with under 50 employees and over 1,000 employees had considerably
less change than those w ith 51-250 and 251-1,000 employees.
Regardless o f in ju r y frequency r a t e , firms in d ic a te d an
increase in paperwork, changes o f paperwork co n ten t, and the need
to c l a r i f y OSHA standards and make special budget expenditures.
However, there was less change in firm s w ith very high o r very low
frequency rates in regard to s a fe ty committees, in s p e ctio n s , p o licy
statements, and control o f purchasing o f s a fe ty items.

Firms w ith

low rates had fewer changes in the sa fe ty duties mentioned.
While there were changes fo r a l l types o f o rg an iza tio n
s tru c tu re , more o f the (a) corporate and (b) d iv is io n groups e x p e ri­
enced changes in duties o f the s a fe ty responsible person (p o lic y
statements, records, e t c . ) .

More firm s "under a s in g le roof" had

increases in purchasing and budget c o n tro l.
OSHA targeted firms experienced s i g n i f i c a n t increases
in s a fe ty -r e la te d d u tie s , expenditures, and purchasing procedures.
However, only o n e -h a lf o f these firms in d ica te d increases in a u th o r ity

237

to force compliance to the requirements o f the a c t and to determine
safety budgets and budget c o n tro l.

A l i k e number had introduced or

increased sa fe ty committees, in s p e ctio n s , p o lic y statem ents, and
c l a r i f ic a t i o n o f s a fe ty standards.
Status o f the Safety Function
The s ta tu re or p re s tig e o f the s a fe ty fu nctio n had been
upgraded regardless o f f ir m s iz e , in ju r y frequency r a t e , organiza­
tion s tr u c tu r e , or whether or not the firms were OSHA ta rg e te d .
Firms under 50 employees were le a s t l i k e l y to show t h is improved
status.
Safety Committees
There were more s a fe ty committees as a r e s u l t o f the a c t ,
and those t h a t did e x is t were more fo rm a l, r e g u la r ly scheduled,
included more people, w ith a broader cross section o f functional
r e s p o n s ib ilit ie s , and involved more a c t i v i t i e s .

For example, s a fe ty

committees were now charged with the r e s p o n s ib ilit y o f OSHA i n t e r ­
pretations and had a d d itio n a l or expanded a c t i v i t i e s r e l a t i n g to
safety inspections, p o licy statements, t r a i n i n g , handling special
problems, and resolving complaints.

Broadened p a r t ic ip a t io n now

included employees, union re p re s e n ta tiv e s , special departments such
as maintenance, and p la n t engineering and supervision.
The g rea tes t change was evident in moderately sized firm s ,
and the le a s t in those w ith under 50 and over 1,000 employees.
Smaller firms had l i t t l e

committee a c t i v i t y .

In a d d it io n , both the

238

very larg e and very small firm s were le a s t l i k e l y to have employee
or union representation on s a fe ty committees.
New and increased s a fe ty committees were evident in a l l
firms regardless o f in ju r y frequency, with no p a r t i c u l a r l y d is c e rn ib le
pattern.
Safety committee a c t i v i t y increased in a l l types o f o rganiza­
tion s tr u c tu r e , but most fre q u e n tly in d iv is io n o p e ra tio n s , as
compared to corporate or "under a s in g le roof" firm s .

There was

no s ig n if ic a n t p attern to membership composition by type o f organiza­
tion.
O ne-half o f the OSHA targeted firms had increased safety
committee a c t i v i t y .
mittee a c t i v i t y .

Almost a l l o f the balance had no s a fe ty com­

Where committees e x is te d , there was broad membership

re presen tatio n, and the

purpose was p r i n c ip a ll y OSHA i n t e r p r e t a t i o n ,

inspection, p o lic y fo rm atio n , and special problems.
Procedures, Rules, and Inspections
Special s a fe ty control and p reventive procedures, inspec­
tio n s , re p o rts , meetings, p o lic y statem ents, s a fe ty r u l e s , and
o rie n ta tio n had been increased in number and tig h te n e d .
In most cases, s iz e did not seem to make a d if f e r e n c e ,
except f o r firms w ith under 50 employees, in which changes were
sid erab ly less than in la r g e r firm s .

con­

G e n e ra lly , the la r g e r the number

of employees the g re a te r the number o f special s a fe ty a c t i v i t i e s and
inspections.
There were moderate d iffe re n c e s r e la t in g to in ju r y frequency
ra te o f a firm .

Changes in

c e n tra l and preven tive methods,

239

checklists, and p o lic y statements were g re a te s t in the range from
5.1 to 2 5 .0 .

The under 2.0 firm s had fewer committee fu n c tio n s ,

and l i k e l y , in firms w ith rates over 1 5 .1 .
Corporate type firms had the g re a te s t incidence o f increased
control, counseling, and re p o rts .

"Under a s in g le roof" firms

showed less responsiveness f o r a l l a c t i v i t i e s .
OSHA targeted firms reacted s i g n i f i c a n t l y in re p o rtin g pro­
cedures and inspections.

However, over o n e -h a lf had as y e t no

programs fo r counseling, c h e c k lis ts and forms, meetings, and
committees.
Awareness, Degree o f Comprehension,
and Responsiveness
Most firms were aware o f the OSHA Act.

Management,

employees, and the union had fav o rab le a t t i t u d e s , took the p ro v i­
sions s e rio u s ly , and th e re was l i t t l e

re s is ta n c e , defensiveness, or

production versus s a fe ty c o n f l i c t .
General knowledge and understanding o f the act increased w ith
firm s iz e , except th a t non-safety and personnel management in la rg e
firms w ith over 1 ,000 employees did nol 'nave d e ta ile d knowledge o f
the a c t , probably due to t h e i r lim ite d ro le in s a fe ty a d m in is tra tio n .
Employee awareness was less in firms w ith under 50 and over 1,000
employees, p a r t i c u l a r l y in the sm aller group.
When considering in ju r y frequency r a t e , there were no appre­
ciable d iffe ren c es among firms in respect to the awareness o f the
act.

However, the most comprehensive knowledge was in firms w ith

low ra te s .

The le a s t fav o rab le a t t i t u d e and le a s t employee awareness

240

was in firms w ith very la rg e and very small ra te s ; the le a s t union
safety a c t i v i t y was in firm s w ith low ra te s .

And the le a s t serio us­

ness about the ac t occurred in firms w ith high ra te s .
There was l i t t l e relevancy to type o f o rg a n iza tio n s t r u c tu r e ,
except th a t a sm aller percentage o f firm s "under a s in g le ro o f" had
OSHA re la te d discussions, knowledge, understanding, and responsive­
ness.

Corporate o f fic e s w ith plants on the premises had less

involvement in s a fe ty a c t i v i t i e s and g re a te r re sis ta n ce to the a c t.
Less than o n e -h a lf o f the OSHA targ eted firm s had discussed
and reviewed the a c t w ith in t h e i r re s p e c tiv e fir m s , had comprehensive
knowledge, or management, employee, or union understanding.

However,

the OSHA Act was g e n e ra lly favored, taken s e rio u s ly , and not re s is te d .
Investment in Safety: A p p ro p ria tio n s ,
Equipment, Devices, or P ro te c tiv e Items
There was considerable new or increased investment f o r s a fe ty related c a p ita l equipment, s a fe ty or guarding d evices, personal
protective items, p la n t s a fe ty improvements in v o lv in g a i s l e s , la y o u t,
ladders, f i r e equipment and, in some cases, moving or changing the
sequence of s p e c if ic operations.
As the s iz e o f the fir m increased, expenditures also increased.
About tw o -th ird s of the firms w ith under 1,000 employees spent less
than $5,000.

When considering in ju r y frequency r a t e s , a high per­

centage o f firms w ith very low and very high rates spent less than
$5,000.

Firms "under a s in g le roof" spent considerably less fo r OSHA

compliance (38 percent under $5,000 and 27 percent from $5,000 to
$2 5,0 00 ), and corporate o ffic e s w ith plants on the premises spent

241

considerably more (75 percent over $ 1 ,0 0 0 ,0 0 0 ).

Over o n e -h a lf o f

all the OSHA targ eted firms spent less than $ 5 ,0 0 0 , and the balance
between $5,000 and $25,000.
The g re a te s t incidence o f change in purchasing procedures
and s p e c ific a tio n s to f a c i l i t a t e OSHA compliance was in firms w ith
under 50 and over 1,000 employees, in ju r y frequency rates under
2.0 ( le a s t l i k e l y with rates over 4 0 . 0 ) , in corporate fir m s , and
in th ree -fo u rth s o f the OSHA targ eted firm s.
Few firm s discarded c a p ita l equipment in order to comply with
the a c t.

Firms le a s t l i k e l y to purchase new c a p ita l equipment were

those with under 50 employees, in ju r y frequency rates over 1 5 .1 ,
corporate o rg an iza tio n s tru c tu re s , and o n e -h a lf o f the OSHA targeted
f i rms.
Many firms had new or increased programs r e l a t i n g to personal
protective equipment such as hard hats (45 p e rc e n t), ea r (35 p e rc e n t),
eye (55 p e rc e n t), face (14 p e rc e n t), and fo ot (25 percent) p ro te c tio n .
I t was not possible to f u r t h e r i n t e r p r e t th is inform ation because o f
already e x is tin g programs and the nature o f work being performed in a
p a rtic u la r fir m .

Almost a l l firms had increased or i n i t i a t e d sub­

sidies fo r glasses or goggles and shoes.
About 14 percent o f the firm s studied had made f a c i l i t y
a lt e r a t io n s , g e n e ra lly those firms w ith over 250 employees and "under
a single ro o f."

Other physical changes involved f i r e equipment (80

percent o f the f i r m s ) , signs (70 p e rc e n t), a is le s (60 p e rc e n t),
noise c o n tr o l, a d d itio n a l rooms, guard r a i l s , and ladders.

242

Communication:
Publicity

T ra in in g and

There were new, more formal and broader t r a in in g programs
such as seminars, in - p la n t classes and, in a few cases, co lleg e
courses.

The t r a in in g and p u b li c it y a c t i v i t i e s involved more people

and p o s itio n s , although these were u su ally on the management le v e l .
A large number and d i f f e r e n t kinds of news and t r a in in g media
were used.

There was also a g re a te r amount o f committee a c t i v i t y

with broader membership re p res en tatio n and more frequent s a fe ty
meetings.
The incidence o f formal t r a in in g programs was evenly d is ­
persed in firms w ith over 51 employees, both corporate and d iv is io n
type o rganization s tr u c tu r e s , in firms w ith in ju r y frequency rates
below 2 5 .1 , and in about 73 percent o f the OSHA targeted firm s .
The p rin c ip a l purpose o f the s a fe ty t r a in in g was to provide
information and c re a te s a fe ty awareness.

Such e f f o r t s by firms w ith

under 50 employees, w ith in ju r y frequency rates o f 40.1 to 7 5 .1 ,
and "under s in g le roof" organizations were considerably less than in
other firm s .

Few companies t r i e d to get employee feedback.

There was increased re lia n c e on e x p e rtis e external to a
p a r tic u la r f ir m , p r i n c ip a ll y the Michigan Bureau of Safety R egu lation ,
insurance companies and, to a le s s e r e x t e n t, suppliers and s a fe ty
councils.

The use o f s ta te inspection services occurred most f r e ­

quently in firm s w ith over 50 employees, those w ith low in ju r y
frequency r a t e s , and in tw o -th ird s o f the OSHA targeted firm s .
However, no firm w ith under 50 employees or OSHA targeted firm used
the s a fe ty t r a in in g services o ffe re d .

Use of insurance company

243

inspections was evident in 72 percent of the firm s , w ith o n e -h a lf
of these using tr a in in g services as w e l l .

Firms w ith less than 1,000

employees, those w ith in ju r y frequency rates below 5.0 or over 2 5 .1 ,
and OSHA targeted firms were most fre q u e n tly involved.
Only one in four firm s u t i l i z e d outside agencies or profes­
sional as so ciatio n s.

Usually th is involved firms w ith over 50 and

under 1,000 employees, in ju r y frequency rates under 1 . 0 , and in
30-45 percent o f those targeted by OSHA.
Union Involvement
There was increased union p a r tic ip a t io n in company s a fe ty
committees.

G reater p u b li c it y and o r ie n ta tio n fo r union stewards

and s p e c i a l i s t s , monitoring o f a f ir m 's sa fe ty a c t i v i t i e s , and
requests fo r s a fe ty clauses in the c o lle c t i v e bargaining agreement
were also e v id e n t.

However, in only 25 percent of the firms were

unions e n th u s ia s tic about the a c t ; tw o -th ird s were coo perative.
Less than 50 percent introduced or expanded s a fe ty a c t i v i t i e s .

Less

than 25 percent had membership o rien ted s a fe ty programs, and th ere
were some negative responses in the form o f s tr ik e s and grievances.
B e tte r a tt it u d e s were evident in firms w ith over 50 employees,
with in ju r y frequency rates below 5 . 0 , and in o n e -h a lf o f the OSHA
targeted firm s .

Union firms w ith both less than 50 employees and

more than 1,000 had g rea ter incidence o f use of OSHA as a weapon
for grievances, m a lin gerin g, and a g it a t io n .

This was also tru e fo r

firms w ith in ju r y frequency rates under 2.0 and above 4 0 .1 , in
d ivision s and plants "under a s in g le r o o f."

244

Attitude Toward Excluding Small
Businesses From the Act
Every firm but one, regardless o f s i z e , in ju r y frequency

r

a

t

e

,

organization s t r u c tu r e , or whether or not targeted by OSHA, f e l t
small businesses should be forced to comply w ith the a c t.
Management A ttitu d e Toward OSHA
Standards and Required
Compliance
There was evidence th a t management lacked f u l l under­
standing and had doubts as to the appropriateness and consistency o f
OSHA standards.

However, there was general acceptance o f the a c t and ■

appreciation f o r the long-run b e n e fits .

There was also no evidence

of fe a r of OSHA inspections or compliance and no " f i r s t hand"
knowledge o f firms going out o f business.
The firms w ith over 1,000 employees, and those w ith in ju r y
frequency rates under 2.0 and over 2 5 .1 , complained the most o f " n i t
picking."

Those firms with 251-1 ,000 employees, and corporate and

"under a s in g le roof" organization s tr u c tu r e s , were concerned about
gathering necessary s a fe ty inform ation.

And those firms with under

50 employees were the least l i k e l y to express d i f f i c u l t y
with the a c t.

in complying

About th re e -fo u rth s o f a l l firms were c r i t i c a l o f the

act in emphasizing meaningless s t a t i s t i c s r a th e r than s a fe ty o f the
worker, p a r t i c u l a r ly those with over 50 employees, in ju r y frequency
rates from 2 5 .1 - 4 0 .0 , and most OSHA targeted firm s .

245
Conclusions
I t can be concluded, based on the re s u lts o f the study, t h a t
the OSHA Act had s ig n i f i c a n t impact on the firms stu d ie d ; th is was
true in each o f the eleven areas examined.

In a d d itio n , there are

some general conclusions th a t are noteworthy.
1.

The degree or ex te n t o f the adjustment required may have

been determined by the v a ria b le s o f firm s i z e , in ju r y frequency r a t e ,
organization s tr u c tu r e , and those firms targeted by OSHA f o r inspec­
tion because o f high in ju r y frequency ra te s .
a.

Small firms w ith under 50 employees were the le a s t

a ffe c te d in most areas o f a n a ly s is , and moderates iz e firms
w ith 51-1 ,000 employees the most.
b.

Firms w ith high in ju r y frequency r a t e s , and those w ith

low in ju r y frequency r a t e s , tended to have both the g re a te s t
and le a s t change, although q u ite often th ere appeared to be
no s ig n i f i c a n t r e la tio n s h ip to in ju r y frequency r a t e .
c.

Firms "under a s in g le roof" experienced the g re a te s t

changes in a d m in is tra tiv e r e s p o n s ib ilit y and fu n ctio n al
alignm ent, but spent considerably less f o r compliance and
had less tr a in in g than did d iv is io n -ty p e o rg a n iza tio n s .

For

example, there were more new and increased sa fe ty d u tie s ,
sa fe ty committee a c t i v i t i e s , safety meetings, formal sa fety
in s tru c tio n programs, and union and employee p a r t ic ip a t io n .
Awareness and degree of comprehension o f the a c t was also
g re a te r.

Corporate stru c tu res w ith on-the-premises plants

experienced the g re a te s t change in procedures, ru les and

246

in s p e c tio n s , awareness and degree o f comprehension o f the
a c t , investment f o r compliance to the a c t , new c a p ita l
equipment, and purchasing procedure.
d.

OSHA ta rg e te d firms did respond to the ac t w ith new

o r increased a c t i v i t y in each o f the eleven areas stu d ie d .
But such a c t i v i t y involved less than 50 percent o f these
firm s .

In a d d itio n , most ta rg e te d firm s spent very l i t t l e

money (le s s than $5,000) f o r compliance.
2.

Small firm s w ith under 50 employees and OSHA ta rg e te d

firms had responded only m inim ally to the a c t.

This is d e s p ite the

fact th a t these firm s professed a fa v o ra b le a t t i t u d e toward the a c t ,
and f e l t t h a t al 1 businesses, regard less o f s iz e or type o f in d u s try
or "manufacturing" process, should be forced to comply w ith the
standards set f o r t h .
3.

More people in more jobs were involved in s a f e t y , p r in ­

c ip a lly in p ro d u c tio n /te c h n ic a l areas; th e re was more j o i n t or shared
safety r e s p o n s i b i l i t y , again encompassing these p o s itio n s .
most evident in moderately sized firm s .

This was

The r o le o f personnel was

minimal, except in some cases f o r record keeping d u tie s .
4.

There was a pronounced need f o r a m p lif ic a t io n o f the OSHA

standards w ith sim pler procedures and e a s ie r c ro s s -re fe re n c in g o f the
many requirements f o r compliance.

S i m i l a r l y , the a c t was in te r p r e te d

as stressin g paperwork, s t a t i s t i c s , and in s p e c tio n s , as contrasted
to safe work procedures, p r a c tic e s , and t r a in i n g .
5.

While OSHA was e f f e c t i v e as a c a t a l y s t fo r s a fe ty

a c t i v i t i e s , the ac t s t i l l

requires more thorough a p p lic a tio n and

247

enforcement.

Many firm s made cursory e f f o r t s a t compliance and

admitted th a t they awaited an OSHA inspection before making a d d itio n a l
changes, even though they might be fin e d .
6.

Small firms spent l i t t l e money f o r OSHA compliance.

In f a c t , tw o -th ird s o f the firms w ith under 1 ,000 employees spent
less than $5,000.

In a d d itio n , budgets and expenditures were on

a task-accomplishment basis ra th e r than as p a rt o f programmed
safety e f f o r t .
7.

There was l i t t l e

evidence th a t general employees, as

contrasted to "management," had been appreciably the re c ip ie n ts
or p artic ip an ts in

OSHA-related

t r a in in g and/or o r ie n ta tio n

programs.
8.
act.

Unions were not p a r t i c u l a r l y e n th u s ia s tic about the

In a d d itio n , less than h a l f had introduced or expanded s a fe ty

a c t i v i t ie s such as committee p a r t ic ip a t io n and inspectio ns.

Less

than one-fourth had membership and steward o rie n te d p u b l i c i t y ,
promotion, and t r a in i n g .
9.

Firms were not provoked by the OSHA Act.

Nor was there

resistance, production versus s a fe ty c o n f l i c t s , or fears o f lost
business because o f compliance, or o f OSHA inspections themselves.
Almost a l l

firms f e l t th a t small fir m s , regardless o f s iz e or type

of process or in d u s try , should be p a r t i c u l a r l y compelled to comply
to the act in order to f a c i l i t a t e the s a fe ty o f t h e i r employees.

248

Recommendations
Based upon the data and conclusions from th is study there are
several recommendations th a t can be made.

Some r e l a t e to general e f f o r t s

to make the act more e f f e c t i v e , others to areas f o r possible fu tu re
research.
From the standpoint o f general a c t i v i t y , special a tte n tio n is
needed to both a s s is t and monitor small fir m s , as well as those w ith
high in ju r y frequency rates such as OSHA targ eted o rg a n iza tio n s .

What is

required is more knowledge o f the a c t , personal contact w ith OSHA rep­
resentatives, and actual use o f a v a ila b le inform ation o r assistance.

A

concerted in d o c trin a tio n program, an understandable s te p -b y-s tep pro­
cedure f o r compliance, and the a p p lic a tio n of an ap p ro p riate and
re a lis tic

enforcement program is e s s e n tia l.

Since few firms had made any s i g n i f i c a n t e f f o r t to provide s a fe ty
in d o c trin a tio n , t r a i n i n g , and education f o r employees, and the act i t s e l f
is somewhat vague in t h is re s p e c t, a more s p e c ific addendum to the act
is required in t h is respect.

Also, monitoring o f such e f f o r t s alone

probably w i l l not be s u f f i c i e n t .
be implemented w ith

S p e c ific workshop techniques th a t can

minimum loss of production are re q u ire d .

In

ad d itio n , a format or " s c rip t" f o r t r a in in g m a te ria ls and p u b li c it y at
the employee could be developed,

and in some instances actual m a te ria ls

supplied f o r d is t r i b u t i o n .
When considering areas f o r a d d itio n a l

research or study, i t

should be possible to provide more d e f i n i t i v e in fo rm a tio n , in d ic a tio n s
of possible tre n d s , and even g re a te r s t a t i s t i c a l c o r r e la tio n as the f u l l
im plications o f the act unfo ld .

For example, t h is study should be

249

replicated, and i f possible use a la r g e r sample s i z e , and include
f

firms in states other than Michigan.
Future studies should also is o la t e on p a r t i c u l a r r a th e r than
general responses.

Continuous and more in-depth feedback o f the s a fe ty

responsiveness o f small firm s is needed, as is some measure o f the
effectiveness o f r e la te d a c t i v i t i e s , and, where p o s sib le , a r e a l i s t i c
cost appraisal fo r compliance when comparable firms implement such
safety programs.
I t is also important to determine the p o s s i b i l i t y o f any trends
in respect to shared sa fe ty r e p o n s i b i l i t y , the involvement o f more and
d iffe re n t positions and fu n c tio n s , and p a r t i c u l a r l y the r e la tio n s h ip o f
production/technical and peronnel areas.
causal fa c to rs should be examined.

S i m i l a r l y , the v a l i d i t y o f any

This would include such things as the

need fo r making l i n e p ositions more responsible f o r s a fe ty ; th ereb y,
giving the s a fe ty function more s ta tu re and p re s tig e in the o rg a n iza ­
tion hierarchy, and the emphasis upon complex standards, s t a t i s t i c s and
"physical" compliance which stressed techn ical e x p e rtis e .
Few firms in Michigan had been inspected by OSHA.

A more

intensive before and a f t e r OSHA inspection is required to document the
value and r ig o r o f the enforcement apparatus provided by the a c t.
Union a c t i v i t y r e la t in g to the act appeared minimal in the
areas of p u b li c it y , promotion, t r a in in g committees and inspection
a c tiv itie s .

This response should be f u r t h e r examined, and y a rd stic ks

provided fo r the development of a meaningful and e f f e c t i v e program f o r
union involvement.

250

F i n a l l y , many compliance a c t i v i t i e s and re la te d expenditures
centered around the most conspicuous s a fe ty needs, e .g . personal pro­
tective items, some guarding, a i s l e s , f i r e equipment, e tc .

More study

is required to determine whether o r not s a fe ty adjustments w i l l become
more comprehensive once the newness o f the ac t fades and some o f the
more pressing problems resolved.

APPENDICES

APPENDIX A
SYNOPSIS:

THE ACT AND

ITS ADMINISTRATION

252

APPENDIX A
SYNOPSIS:

THE ACT AND ITS ADMINISTRATION

The W il1iam s-Steiger Occupational Safety and Health Act
(Public Law 91-956) was passed by the United States Congress in l a t e
1970, signed by the President on December 29, 1970, and became
e ffe c tiv e A p ril 28, 1971.

The fo llo w in g synopsis summarizes some o f

the more important provisions o f the a c t.
Purpose:

Assure safe and h e a lth fu l working conditions fo r

every working man and woman in the nation . . .

by s p e llin g out in

great d e t a il universal consensus standards, what employees themselves
are required to do to make themselves s a f e , and enforcement p en altie s
and procedures; s tim u la te s ta te sa fe ty and health programs, and to
establish an agency (NIOSH) to research health hazards and causes,
and suggest s o lu tio n s .
Coverage :

A ll non-government employers, fe d e ra l * lo c a ls or

s ta te , whose a c t i v i t i e s a f f e c t commerce (which means p r a c t i c a l l y a l l
employees), except fo r those covered by o th e r fed eral s a fe ty laws,
such as those dealing w ith mining and c e r ta in forms o f tra n s p o rta tio n .
There are no exemptions fo r small firm s .

Even a concern w ith one

employee is covered.
D u tie s :

An employer is to "furnish to each o f his employees

employment and a place o f employment which are fre e from recognized
hazards th a t are causing or are l i k e l y to cause death or serious
253

254

physical harm . . . and to comply w ith occupational s a fe ty and
health standards and a l l r u le s , re g u la tio n s , and orders issued pur­
suant to the ac t which are a p p lic a b le to his own a c tio n s ."
Although both employer and employee have d u t ie s , a l l p e n a ltie s
prescribed f o r noncompliance to standards and re gu lation s are invoked
against the employer.
show th a t a l l

The only way to avoid such assessment is to

reasonable actions to in s tr u c t and d is c i p li n e employees

were taken.
Employee R ig h ts :

Employees or t h e i r re p res en tative s can

p a rtic ip a te in the standard-development process;

They must have

access to inform ation about s i g n i f i c a n t s a fe ty and health provisions
and changes introduced by t h e i r employer, and a summary o f accident
experiences and s a fe ty v io la tio n s in the establishm ent.
There is a procedure to permit employees to make c o n fid e n tia l
complaints, to the Department o f Labor about any deviance from the
standards prescribed in the a c t by his employer.

Subsequent inspec­

tions can be requested, and the employee or a re p re s e n ta tiv e may
accompany compliance o f f i c e r during inspections.

There is also a

safeguard ag ain st employer r e p r is a ls f o r any o f these a c t i v i t i e s .
Standards:

S p ec ified Safety and Health Standards are manda­

tory f o r in d u s try , and in general form Part 1910 o f Chapter XVII
of T i t l e 29 o f The Federal R egulations, as published in the Federal
Register o f May 27, 1971 and updated October 18, 1971.
The i n i t i a l standards promulgated by the Secretary o f Labor
are recognized consensus-standards r e s u ltin g from a com pilation o f
recommendations from standards-producing o rganizations such as the

255

American National Standards I n s t i t u t e (ANSI), National F ir e Associ­
ation (NFA), The National Safety Council (NSC), Walsch-Healey
standards, plus recommendations by industry which they might consider
essential in t h e i r special s itu a t io n .

The standards are continuously

critiqued, augmented, and supplemented by advisory committees,
standards-writing groups, and the National I n s t i t u t e of Occupational
Safety and Health (NIOSH) of HEW.

They must by law represent the view­

point. of employees, and workers must be represented on standardsetting committees.
There are two kinds o f standards:

s p e c ific a tio n standards

(which set fixed requirements or dimensions) and performance
standards (emphasizing the re s u lts to be achieved ra th e r than the
method of achievement).

Most o f these are "ho rizo ntal" and apply to

a wide v a rie ty o f work s it u a t io n s , in almost a l l establishments.
But there are some th a t are " v e r t ic a l" and apply to s p e c ific industries
or occupations; e . g . , co n stru c tio n , longshoring, and maritime.

Where

no standards e x is t the employer must make reasonable e f f o r t to provide
a place o f employment fre e from recognizable hazards.
Where employers are not able to comply to the act by v ir tu e o f
u n a v a ila b ility o f technical personnel, or necessary m aterials or
equipment, a variance is possible providing they in d ic a te a construc­
tive plan to achieve compliance with dates f o r completion o f each
step.

In the case o f a request fo r permanent variance, the applicant

must show condition s, p ra c tic e s , means, and methods which are as safe
and h ea lth fu l as the e x is tin g standards.
reasons is not perm itted.

Noncompliance f o r economic

256

Records:

Each establishment or local workplace employing

eight or more employees is required to m aintain and produce upon
request, and r e ta in f o r f i v e y e a rs , three basic types o f i n j u r y /
illness records.
1.

A log o f Occupational I n j u r i e s or Illn e s s e s (Form 100)

or any p r i v a t e l y prepared e q u iv a le n t, th a t records every (a ) f a t a l i t y ,
regardless o f time between in ju r y and death , (b) lo s t workday cases
other than f a t a l i t i e s , ( c ) n o n -fa ta l cases w ithout lo s t workdays
that requ ire t r a n s f e r to another j o b , r e s u l t in disch arge, medical
treatment, loss o f consciousness, or r e s t r i c t i o n o f work or motion.
2.

A supplementary Record o f Occupational In j u r i e s and

Illnesses (OSHA form 1 0 1 ) , or any other comparable form; e .g . ,
workmen's compensation or insurance company th a t provides a s e p ara te,
d e ta ile d , and in d iv id u a l record o f each accid en t.

This may be kept

elsewhere by an outside source such as a medical c l i n i c , provided
a ll inform ation can be furnished f o r inspection w ith in s ix working days,
and the complete log is a v a ila b le w ith in 45 days.
3.

An Annual Summary of Occupational In ju r ie s and Illn e s s

(OSHA form 102) th a t s t a t i s t i c a l l y shows a cross ta b u la tio n o f a l l
recorded in ju r y cases during the y e a r , broken down by category
( i n j u r y , type o f i l l n e s s ) .

This must be posted by February 1st in a

prominent lo c a tio n accessible to a l l employees, such as a b u l l e t i n
board or a t the " tim e -c lo c k ," and remain posted u n t il March 1s t.
Each y e a r , OSHA samples employers and makes studies o f a c c i­
dent experiences.

P a r t ic ip a tio n by employers is o b lig a to ry .

Employers wishing to compare rates w ith these samples use the

257

occurrence o f such i n j u r i e s and illn e s s e s per year per 200,000 manhours of employee exposure (In c id e n t Rate equals the number o f
Recordable In ju r ie s and Illn e s s e s times 200,000 Divided by the number
of Employee Exposure Hours).
In s p e c tio n :

The Secretary of Labor is authorized to e s ta b lis h

regional OSHA a d m in is tra tiv e o ffic e s w ith compliance o f f i c e r s .

Upon

presenting appro priate c re d e n tia ls to the owner or agent o f an estab­
lishment, a compliance o f f i c e r can e n te r the establishm ent w ith o u t
delay or advance n o t ic e , a t reasonable tim e s , and in a reasonable
manner, to inspect o r in v e s tig a te working c o n d itio n s , equipment,
records, in te rv ie w employees, and question the owner.

He must be

allowed f u l l and u n in h ib ite d access to the whole establishm ent.
The compliance o f f i c e r closes his v i s i t w ith a conference
in which he notes apparent v io la tio n s and discusses c o rre c tiv e
measures, but he does not have a u th o r ity to make formal charges,
issue c i t a t i o n s , nor assess p e n a ltie s .

He may, however, in d ic a te

that he w i l l recommend them to the regional OSHA a d m in is tra to r who
does have th is a u th o r ity .

In the case o f imminent danger he may seek

immediate voluntary compliance, or u lt i m a t e l y , a court in ju n c tio n to
close the firm down.
Inspection P r i o r i t y :
F ir s t:

Accidents in v o lv in g previous complaints a lle g in g

imminent danger, or w i l l f u l and repeated v io la t io n s .
Second:

In response to f a t a l i t i e s and m u ltip le ( f i v e or more)

h o s p ita liz a tio n accid en ts, or extensive property damage w ith proba­
b i l i t y o f these having occurred.

258

T h ir d :
Fourth:

In response to employee complaints.
In f i v e " ta r g e t in d u s tr ie s ," as determined by a high

injury frequency r a t e .

These ra te s are more than double the national

average, and represent la rg e employee exposure to both accidents and
health hazards; e . g . , longshoring ( 7 0 ) , roofing and sheet metal ( 4 5 ) ,
meat processing ( 4 0 . 4 ) , mobile homes ( 3 9 . 9 ) , lumber and wood products
(34 .6).
F i f t h : Otherestablishm ents selected a t random.
S i x t h : Re-inspections to check corrected v io la tio n s where they
were

f o

u

n

d

in the f i r s t inspectio n.

Enforcement:

The regional OSHA D ire c to r is au th orized to

issue c it a tio n s when v io la tio n s o f safety and health standards are
found, set time l im it s f o r abatement, and when the s it u a t io n w arran ts,
issue fin e s .

There are no exemptions fo r f i r s t o ffe n s e s , and the

employer is considered responsible f o r employee compliance.

Each

c ita tio n must be prominently posted near the place where the v i o la ­
tion occurred.
1.

C ita tio n s :

These n o t i f y employers in w r i t in g as to the

exact nature o f alleged v i o la t i o n s , and the period o f time OSHA
feels reasonable f o r i t s co rrec tio n (abatement p e rio d ).

They may

be concerned w ith the general duty o f providing a workplace fre e
from hazards, or Safety and Health Standards and R egulations, and
they may a lle g e v io la tio n s o f the fo llow ing types:
a.

Imminent danger:

which could reasonably be expected

to cause death or serious harm.

In the absence o f immediate

voluntary compliance, a n o tic e o f imminent danger is posted

259

near the danger, and a recommendation is sent to a c i v i l
court f o r an in ju n c tio n to shut down the o p e ra tio n .
b.

Serious v i o l a t i o n :

in which (1 ) th e re is p r o b a b ilit y

o f death or serious (permanent) physical i n j u r y , and ( 2 ) the
employer did not ex ercise reasonable d ilig e n c e .
c.

Non-serious v i o l a t i o n :

in which a co n d itio n e x is ts

where an i n j u r y , but not death o r serious physical harm can
occur, o r i f the employer did not know o f the hazard; e . g . ,
t r ip p in g on a le v e l su rfa c e .
d.

DeMinimis v i o l a t i o n :

in which a s i t u a t i o n has imme­

d ia te and d ir e c t r e la tio n s h ip to s a fe ty and h e a lth ; e . g . ,
s a n ita ry t o i l e t f a c i l i t i e s .
e.

W illfu l v io la tio n :

where an employer is aware o f the

standard and makes no reasonable e f f o r t to comply.
f.

Repeated v i o l a t i o n :

in which a second c i t a t i o n is

issued f o r the same standards.
2.

P e n a lt i e s :

When p e n a ltie s are proposed, a w r i t t e n n o tice

is sent to the employer.

A serious v io la t io n must be assessed a

monetary penalty not exceeding $ 1 ,0 0 0 ; a non-serious v i o l a t i o n may
be assessed up to $1,000.

C i v i l p e n a ltie s up to $10,000 f o r each

v io la tio n may be proposed when they are w i l l f u l o r repeated.

In

the event o f a d ea th , a f in e up to $10,000 or imprisonment f o r six
months may be imposed.

An employer f a i l i n g to c o r r e c t an uncon­

tested v i o la t i o n w ith in a s p e c ifie d abatement period may be assessed
up to $1,000 a day f o r each day the v i o la t i o n continues beyond th is
date.

260

The regional OSHA D ire c to r determines the amount o f p e n a ltie s
for non-serious a lleg ed v io la tio n s on the basis o f (1 ) the p r o b a b ilit y
of in ju ry or i l l n e s s , ( 2 ) the s e v e r it y o f such an i ll n e s s o r i n j u r y ,
(3) the extent to which the act was v io la te d .

Each c i t a t i o n is rated

accordingly, "A" (no f i n e ) , "B" ($ 1 0 0 -$ 2 0 0 ), "C" ($ 2 0 1 -5 0 0 ), and "X"
($500-1,000).

Downward adjustments as g re a t as 50 percent o f each

d o llar amount may then be made f o r good f a i t h , and the e x te n t and
history o f previous v i o la t i o n s , and a f u r t h e r reduction o f 50 percent
of the "adjusted" amount can be made i f the employer co rrects the
v io la tio n w ith in the abatement period.
3.

Contested Cases:

Uncontested c it a tio n s become orders.

However, both employers and employees may contest s itu a tio n s and
penalties i f the regional OSHA o f f i c e is n o t i f i e d w ith in 15 working
days.

Employees are lim it e d to co n testin g the d u ratio n o f the

abatement p e rio d , but the employers may contest the c i t a t i o n , pro­
posed p a n a lty , n o tic e o f f a i l u r e to c o rre c t v io la t io n o r time
a l lo t t e d .
A hearing is then held by a review commission (0SHARC)
judge.

Cross examination is p e rm itte d , and only what is on the

record is considered.

The recommendations o f the judge are subse­

quently sent to a three-man commission, which w i l l a f f i r m , void or
modify a c i t a t i o n o f p e n a lty .

The f i n a l o rd e r, in t u r n , may be

appealed to a C i r c u i t Court o f Appeals.
S tate P a r t i c i p a t i o n :

The act provides t h a t s ta te s may take

over a l l or p a rt o f the OSHA r e s p o n s ib ilit y f o r enfo rcin g s a fe ty
and health standards.

However, any s t a t e program must be a t le a s t

C om pliance Program

INSPECTIONS,
INVEST1GATIJNS

PRIORITIES

j

REINf PECT10N

ALLEGED
VIOLATIONS
iw s s m

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CITATIONS

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48

GOVERNMENT AGENCY
MAJOR FUNCTION
DESCRIPTIVE INFORMATION
EMPLOYER REQUIREMENT
COMPLIANCE

Nay 1973, HATIOHAL SAFETY HEWS

262

as e f f e c tiv e in a l l areas as the f l o o r provided by the OSHA program
i t replaces.

As in c e n tiv e to the s t a t e s , th e ac t contains g r a n t - i n - a id

provisions, in which the Federal government reimburses up to 90 percent
of the cost o f preparing a plan f o r s ta te enforcement, and up to 50
percent o f the cost o f m aintaining a program once i t has received
Federal a p p ro va l.
A d m in is tra tiv e Functions:

OSHA headquarters are located in

Washington, D .C ., and is headed by the A s s is ta n t Secretary o f Labor.
There are ten regional o f fic e s throughout the country.
The National I n s t i t u t e o f Occupational S a fe ty and Health was
established w ith in the Deartment o f H e a lth , Education and W elfare
under the OSHA Act.

I t has the r e s p o n s ib ilit y o f conducting research

for new occupational s a fe ty and health standards, and making subse­
quent recommendations to the Department o f Labor.

The primary th r u s t

of most o f i t s research la b o ra to rie s throughout the United States is
to study the e f fe c t s (p h y s ic a l, p sy ch olo gical, m o t iv a tio n a l, and
behavioral fa c to r s ) o f hazardous substances such as asbestos, noise,
lead, those leading to "black lung" disease.
In a d d itio n , NIOSH develops major education and t r a in in g
programs to produce on a sustained basis a balanced number o f q u a l i f i e d
personnel to both deal w ith the problems o f occupational s a fe ty and
h e a lth , and to carry out the purposes o f the OSHA Act.

I t p a rtic i­

pates in a t r a in i n g 'g r a n t program to develop tw o -y ea r, b ac ca la u rea te,
and graduate programs in colleges and u n i v e r s it i e s .
The Bureau o f Labor S t a t i s t i c s has been assigned OSHA act
r e s p o n s ib ilit ie s in connection w ith s t a t i s t i c s on occupational s a fe ty
and h e a lth .

263

Occupational S a fe ty and Health Review Cotrmiission (OSHRC),
located in Washington, D . C . , has a number o f judges who hold hearings
on contested cases a t lo c a tio n s near to the establishm ents in v o lv ed .
The Small Business A d m in is tra tio n is au th o rize d to gran t
long-term loans to pay f o r changes in equipment and operations
necessary to bring an establishm ent in t o compliance.
Enforcement procedures become immediately a p p lic a b le to
the Walsh-Healey P u b lic Contracts A c t, and the OSHA Act provisions
supersede any standards s e t f o r t h by the a c t , or th e McNamara-0'Hara
Services C ontract A c t , N ational Foundation on Arts and Hum anities,
and Longshoremen's and Harbor Workers' Compensation A c t, when the
secretary determines the OSHA Act to be more e f f e c t i v e .

APPENDIX B

QUESTIONNAIRE AND
INTERVIEW GUIDE

264

APPENDIX B

QUESTIONNAIRE AND INTERVIEW GUIDE

DATE: _________________
CODE: _________________
CITY: _________________
LOCATION:

POPULATION:
1.

Under I ,000

Detroi t

2.

1-15,000

Suburb

3.

15-25,000

O utstate

4.

25-50,000

5.

50-125,000

6.

125-150,000

7.

Over 1,000,000
TYPE OF ORGANIZATION:

FIRM SIZE:
1.

Under 50

1.

Corporate O ffic e

2.

51-250

2.

D i v i s io n /M u lt i - P l a n t

3.

251-1 ,000

3.

Under a S in g le Roof

4.

Over 1,000

TYPE OF INDUSTRY:
1.

Auto t r a i l e r s

4.

Roofing, Sheet Metal

2.

Auto components

5.

Food Processing

3.

T ools, Equip.
Computer, Hdlg.

6.

Bldg. M a te ria ls

265

266

TYPE OF INDUSTRY (Continued)
7.

Mobile Homes_______ _________

10.

U tilitie s

8.

Paper P ro d ./
P rin tin g ___________ ________

11.

Longshoring

12.

Woodworking

9.

R e ta il______________ _________

TYPE OF PROCESS OR MANUFACTURE:
1.

Fab/Mfg/Production ________

6.

Food Process

2.

Forging, Casting

7.

Construction

3.

Stamping___________ _________

8.

R e ta ilin g

4.

Machining

_________

9.

U tilitie s

5.

S p ec ia lty

________

10.

OSHA TARGETED:

________

Yes

No

1.

Under 2 .0

________

2.

2 .0 - 5 .0

________

3.

5 .1 -1 0 .0

________

4.

1 0 .1 -1 5 .0

_________

5.

1 5 .1 -2 5 .0

________

6.

2 5 .1 -4 0 .0

_________

7.

4 0 .1 -7 5 .0

________

8.

Over 75.0

_________

Longshoring

267
I.

GENERAL INFORMATION

A.

B.

Company
1.

Name o f Company ____________________________________

2.

Address ____________________________________Zip code

3.

Phone Number _______________________________________

Interview ee
1.

Name

T i t l e Code No.
1

Responsible f o r Safety
2.

No
T i t l e Code No.

Name
Responsible f o r Safety

3.

Yes

Yes

No
T i t l e Code No.

Name
Responsible f o r Safety

Yes

T i t l e Code:
1.

Pres./Top Management

2.

Personnel

3.

In d u s t r ia l Relations

4.

Safety M g r/D ir/E n g .

5.

Plan t/P ro d Mgr/ Supt

6.

C h ief Engineer/M aster Mech.

7.

Maintenance

8.

Legal

No

268

I I . EXPOSURE TO SAFETY INSPECTION
A.

S ta te :

Last 6 mos.

Longer

None

B.

Insurance:

Last 6 mos.

Longer

None

C.

Corporate:

Last 6 mos.

Longer

None

D.

OSHA in Michigan:

E.

OSHA out o f Michigan:

F.

Reason f o r OSHA in s p e ctio n :

G.

H.

none

none____

1.

Union

2.

Employee Complaint

3.

F a ta lity

over 3

1-3

1-3____

_____

over 3____

N/A

4. In ju r y ____________ __
5.

_____

Targ et Ind u s try

6. Routine

__
__

Results o f OSHA in s p e c tio n :
1.

C ita tio n

2.

Fined

Hearing/Appeal
____

_____

Appeal Sustained_____

Impressions o f OSHA inspections:
1.

Reasonable

Yes

No

No comment

2.

Doing good job

Yes

No

No comment

3.

N i t pick

Yes

No

No comment

4.

In specto r poor a t t i t u d e

5.

Other

Yes

No

No comment

269

III.

ADMINISTRATIVE RESPONSIBILITY AND FUNCTIONAL ALIGNMENT
A.

Responsible f o r Safety
1.

J o in t_____ Yes_____ Time______New____ No_

Personnel

Not d i r e c t l y ____
2.

Ind. Rel.

J o in t_____ Yes_____ Time______New____ No_
Not d i r e c t l y ____

3.

P lant/P rod Mgr.

J o in t_____ Yes_____ Time______New____ No
Not d i r e c t l y ____

4.

Safety Mgr/
D ire c to r

■J o in t

Yes

Time

New

No_

Not d i r e c t l y ____
5.

Chief Eng/Mech.

J o in t_____ Yes_____ Time______New____ No
Not d i r e c t l y ____

6.

Maintenance

J o in t_____ Yes_____ Time______New____ No
Not d i r e c t l y ____

7.

Legal_____________ J o in t_____ Yes_____ Time_____ New____ No
Not d i r e c t l y ____

8.

O ffic e Manager

J o in t_____ Yes_____ Time______New____ No
Not d i r e c t l y ____

B.

Shared S a fe ty R e s p o n s ib ility
1.

Personnel

5.

Maintenance

2.

In d u s tr ia l Relations

6.

Legal

3.

P it/P ro d

7.

S e c u rity

4.

C h ief Enq/Mechanic

8.

Other

Mqr/Supt.

270

C.

S t a f f in g , T i t l e s , Time Devoted to Safety
1.

F ull time s a fe ty manager:

2.

New t i t l e :

3.

New p o s itio n :

4.

New Reporting Procedure (s tr u c tu r e change) Yes

5.

S t a f f increases:

6.

Time devoted to s a fe ty by s a fe ty person:

7.
D.

Yes

No___________ %_____

Name___________________________ no_____ none_

a.

No change

b.

0-9%

c.

10-24%

Name

no

Yes_____

Number_____

_________

d.

No

No_____

25-50%
e.

none__

_____

5 0 -F u ll time

_____

G reater sa fe ty r e s p o n s ib ilit y :

Yes______ No_____

Reporting procedure and Role o f personnel
1.

Safety responsible person reports to :
a.

Personnel or is personnel

_____

b.

In d u s tr ia l Relations

_____

c.

Plant Manager

_____

d.

Top Management/President

_____

e.

Is President

_____

f.

Other________________________________

E.

Personnel Department/Mgr:

Yes_____ No______ P a rt-tim e ______

F.

Function o f personnel i f not s a fe ty :
1.

Record Keeping__________ _____

2.

P ro m o tion /P ub licity

_____

3.

Education and T rain in g

_____

4.

Committee

_____

5.

Other

_____

_

271

IV.

FUNCTIONAL DUTIES
A.

Duties o f s a fe ty responsible person
1.

Analysis

Same

Increase

New

None

2.

Advising

Same

Increase

New

None

3.

Final Decision

Same

Increase

New

None

4.

Force Compliance

Same

Increase

New

None

Safety Expenditures
1.

Complete control

Yes

No

Other

2.

Requi s i t i o n and Recommend

Yes

No

Other

3.

Exclude C apital Equipment

Yes

No

Other

4.

Rubber Stamp Request

Yes

No

Other

5.

Central Fund

Yes

No

Other

6.

Special Apporpriations

Yes

No

Other

7.

P r o f i t Center

Yes

No

Other

Safety Budget:
D.

No change

New or1 Increased

None

A u th o rity and r e s p o n s ib ilit y fo r purchase o f s a fe ty items
1.

Personal Items

5.

Selects Products

2.

Major Items

6.

Selects Suppliers

3.

Complete Control

7.

Requisitions but
Handles

4.

No In fluen ce

8.

Blanket order

New Duties
1.

Paper Work

6.

Presentations

2.

Inspections

7.

New O rie n ta tio n

3.

Pol icy

8.

Educati on/Trai ni ng

4.

Commi t t e e

9.

Design Equipment

5.

C l a r i f y Standards

10.

Other

272

STATUS OF THE SAFETY FUNCTION

V.

Safety Upgraded

Good Now

No Change

SAFETY COMMITTEE ACTIVITY

VI.

Acti vi t i e s :
•

None_____

No Change_____

New, Increased

P a rtic ip a n ts

■

7.

Special Depts

8.

P it/P ro d Mgr

Personnel

9.

Union

4.

Ind. R e l.

10.

Employees

5.

Supervision

11.

Purchasing

6.

M a i n t /P l t Eng

_____

12.

Other

_____

4.

Education /Trainin g

_
_

1.

Management

2.

Safety M g r/D ir

3.

_____

Purpose
1.

In te r p r e ta t io n

2.

Inspection

5.

Special Problems

3.

P o lic y Formulation

6.

Compla i nts/D i s c i p i 1ne

PROCEDURES, RULES AND INSPECTIONS

V II.
.

A d m in is tra tiv e
1.

Control and Prevent. New

Increased

Unchanged

None___

o
C.i

Counsel and Advice

Mnw
llWII

Increased

Unchanged___ None

3.

Special

New

Increased

Unchanged

4.

Reports

New

Increased

Unchanged___ None

5.

Forms and Checklists New

Increased

Unchanged

None

6.

Poli ci es

New

Increased

Unchanged

None '

7.

Meetings

New__

Increased

Unchanged

None

8.

Committees

New

Increased

Unchanged___ None

9.

Computerized Records New

Increased

Unchanged

None
1

None

:

273

B. Inspections

C.

V III.
A.

B.

1.

New

Increased

Unchanged

2.

Simulated OSHA

3.

Special Preparation f o r OSHA

Yes

None
No_____

Yes

No___

Employees
1.

New H ire O rie n ta tio n

Yes

No

2.

Job A n a ly s is , Evaluation

Yes

No

3.

Signature on Medical Form

Yes

No

4.

Physicals

Yes

No

5.

Other

INVESTMENT IN SAFETY
Appropriations to Comply w ith OSHA
1.

Not A v a ila b le

5.

$25-50,000

2.

Under $5,000

6.

$50-100,000

3.

$5-10,000

7.

$100-500,000

4.

$10-25,000

8.

Over $500,000

E ffec ts on Purchasing Policy
1.

Purch Order S p ec ifies OSHA

_____

2.

Purchase Order Does Not Work

_____

3.

P r ic e /D e liv e r y ______________________

4.

Customer Requires___________________

5.

S u p p lie r Updated Equipment

6.

Safety Engineer Approves______ _____

7.

Other

_____

274

C.

D.

E.

Purpose o f Expenditures
1.

Discard C apital Equipment _____

6.

Presses

2.

Bought C apital Equipment

_____

7.

F i r s t Aid

3.

Noise Related

_____

8.

Housekeeping

4.

L if t i n g Equipment

_____

9.

Other

5.

V e n t ila t io n

_____

Guards and A lte r a tio n s
1.

Guards, Rests

5.

E le c t r ic a l

2.

Dual Controls

6.

Cranes, F o r k l i f t

3.

Blow Guns

7.

Other

4.

Platforms

_____

Personal Protection
1.

Hats

New___ Increased

Mandatory

N o n e/Iso lated

2.

Ears

New

Increased

Mandatory

N o n e/Iso lated

3.

Eyes

New

Increased

Mandatory___ N o n e/Iso lated

4.

Face

New

Increased

Mandatory

5.

H air

New

Increased

Mandatory___ None/Isolated

6.

Feet

New___ Increased

Mandatory

N o n e/Iso lated

7.

Hands

M

Increased

Mandatory

N o n e/Iso lated

8.

Physicals New

Increased

Mandatory

N o n e/Isolated

9.

Firm Subsidy

N o n e/Iso lated

a.

Glasses/Goggles

New

Increased

None

b.

Shoes

New

Increased

None

275
F.

G.

F a c i l i t y o r Process Changes

1.

Mfg Sequence____________

2.

Painting________________

3.

Moved Operati ons

4.

Bldg Design_____________

5.

Bldg A lt e r a t io n ________

6.

Other

Physical Adjustments
1.

V e n t ila tio n

8.

Housekeeping

___

2.

Noise

9.

L ig h tin g

___

3.

Equipment Placement

10.

Ladders

___

4.

Layout, Rooms

11.

S to ri ng

5.

F ire Equipment

12.

F u rn itu re

___

6.

Signs

13.

A is le Markings

___

7.

Rails

Size
14.

IX.

M irrors

Other

AWARENESS, DECREE OF COMPREHENSION, AND RESPONSIVENESS
A.

B.

Knowledge o f OSHA
1.

Awareness

2.

Some D e ta il

3.

Comprehensive

4. L i t t l e or None

Understand Requirements
1.

ManagementComprehensive

2.

EmployeesComprehensive

3.

Union

Basic
Basic

None
None

Comprehensive_____ Basic______ None

276

C.

D.

E.

Takes S eriously
Management

2.

Employees Comprehensive

3.

Union

X.

Basic____________ None

Comprehensive_____ Basic______ None

P a r tic ip a tio n and Involvement
1.

ManagementComprehensive

2.

Employees Comprehensive

3.

Union

Basic

None

Basic____________ None

Comprehensive_____ Basic______ None

Resistance and Defensiveness
1.

F.

Comprehensive_______ Basic______Norte

1.

ManagementComprehensive

Basic

None_

2.

Employees

Comprehensive

’ Basic

None

3.

Union

Comprehensive_____ Basic______ None

Safety vs Production
1.

ManagementComprehensive

2.

EmployeesComprehensive

3.

Union

Basic
Basic

None
None

Comprehensive_____ Basic______ None

COMMUNICATIONS, TRAINING, AND PUBLICITY
A.

B.

Meetings and Committees
1.

Safety Committee

Yes

No_____ Unchanged____

2.

Corp Meetings

Yes'_____No_____ Unchanged____ N/A

3.

Regular Meetings

Yes____ Noj._____ Unchanged____

Formal In s tru c tio n
1.

College

_____

2.

Seminars, Class

_____

3.

In -P la n t Classes

_____

4.

Lectures

_____

5.

Others

__________

277

C.

D.

E.

F.

Type o f T rain in g Vehicle
1.

Company Film

9.

2.

S upplier Film

10.

B u l le t in Board

3.

Agency Film

11.

Pay Envelope

4.

L it e r a tu r e

12.

Contests

5.

Consultants

13.

Suggestions

6.

Newspaper

14.

Others

7.

Special Promotion

8.

B u lle tin s

_____

Public B u lle tin s

15.
16.

People Involved in T ra in in g Exposure
1.

Safety M g r/D ir

7.

Special Depts.

_

2.

General Management

8.

F ie ld Personnel

_

3.

Supervisors

9.

Union

_

4.

Personnel/Ind. R e l.

10.

Employees: Committee

_

5.

M a i n t . / P l t Eng.

11.

Employees: Non-Commi tte e

6.

Medical

12.

Others___________________

_____

General Purpose o f T ra in in g
1.

Inform ation

4.

Committee Feedback

2.

Awareness

5.

Other

3.

General Feedback

_____

S p e c ific T rain in g
1.

Fork L i f t Trucks

5.

F ir e Control

2.

F i r s t Aid

6.

Other

3.

New H ire

7.

4.

P ro te c tiv e Equipment

_____

8.

_

278

G.

Help from Outside Sources
1.

Chamber o f Commerce________ Much____ L i t t l e _____ None

2.

Luncheons___________________ Much____L i t t l e ______ None

3.

Professional Associations Much

L i t t l e _____ None

a.

Safety Council_________ Much____ L i t t l e _____ None

b.

Industry

c.

F ir e Dept. RedCross

d.

ASSE, AM A ,________

Much___ L i t t l e ____ None
Much

L ittle

None

Much____ L i t t l e _____ None

4.

Consultants

Much___ L i t t l e _____ None

5.

Unions

Much___ L i t t l e ____ None

6.

Suppliers

Much___ L i t t l e ____ None

7.

S ta te :

8.

Inspection

Much___ L i t t l e ____ None

T rain in g

Much___ L i t t l e _____ None

Insurance Company:
Inspection_________ Much___ L i t t l e ____ None
T rain in g

XI.

Much___ L i t t l e ____ None

UNION INVOLVEMENT
A.

Union Posture

3.
B.

In d iffe re n t

P o s itiv e A c t i v i t i e s

2.

Steward O rie n ta tio n

4.

Member T raining

5.

Monitors Firm

7.

On Committee

279

C.

X II.

Negative Response
1.

S trik e s ____________ _____

5.

Depends on Mgt

2.

Grievances

_____

6.

OSHA a Club_______ _____

3.

M alin g er, A g ita te

_____

7.

Other___________________

4.

P o litic a l

_____

8.

.

_____

.________

ATTITUDE TOWARD EXCLUDING SMALL BUSINESSES
A.

Should be Excluded

B.

Comments, or Why This Answer:

X III.
A.

MANAGEMENT ATTITUDE TOWARD OSHA STANDARDS AND REQUIRED COMPLIANCE
Standards— General
1.

Ambiguous

Volunteered

No

No Mention

2.

Hard to Index

Volunteered

No

No Mention

3.

D i f f i c u l t to Use

Volunteered

No

No Mention

4.

N i t Pick

Volunteered

No

No Mention

5.

Should Temper

Volunteered

No

No Mention

6.

Costly to Find Stds

Volunteered

No

No Mention

Hard to S e ll

Volunteered

M
*-,
riO

I1U

t

.

8.

B.

Yes_____ No______ Limited______

riCllltllHl

Other Comments:

Incon sisten t Standards
1.

No Mention or Disagree

5.

In a p p ro p ria te

2.

In te r p r e ta tio n

6.

Changing

3.

Trade Terminology

7.

Follow S ta te Stds

4.

Regional In te r p r e ta tio n

8.

Short Run

280

1.

S t a t i s t i c s Meaningful

Volunteered

No___ No Mention____

2.

Paperwork

Volunteered

No

No Mention___

3.

No Employee Control

Volunteered_

No

No Mention___

4.

No Employee Understanding Volunteered

No___ No

5.

Employees Not S a fe ty Minded

Volunteered

No

No Mention__ ^

6.

Lim its Job

Volunteered

No

No Menti on

7.

Have Advisory Inspections Volunteered

No__

No Mention___

8.

Ask OSHA f o r Help

No

No Mention

9.

Other

Volunteered

Mention___

General Reetion to Act
1.

Fear o f OSHA

Ves

No

Uncertain

2.

Fear o f OSHA Inspection

Yes

No

Uncertain

3.

W illin g to Risk Inspection

Yes

No

Uncertain

4.

Look Forward to Inspection

Yes

No

Uncertain

5.

OSHA Doing Good Job

Yes

No

Uncertain

6.

Reasonable Inspections

Yes

No

Uncertain

7.

Experiencing Growing Pains

Yes

No

Uncertai n

8.

Bad P u b l i c i t y , Gossip

Yes

No

Uncertain

9.

Know Firm Out o f Business

Yes

No

Uncertain

10.

Lost Business

Yes

No

Uncertain

11.

Other

P o s itiv e E ffects
1.

Long Run Safety

Volunteered

No_

No Mention

2.

Long Run Cost Reduction

Volunteered^

No

No Mention

3.

More S p e c if ic , Comprehensive Volunteered

No

No Mention

281
4.

Forced S tate and In s . Co. Volunteered

5.

Provided Guidelines

Volunteered___ No___ No Mention___

6.

Most S ig n if ic a n t Law

Volunteered

No

No Mention

7.

Other

8.

Other

9.

Other

10.

Other

1.

No Employee Understanding Volunteered

No

No Mention

2.

Union Harassment

Volunteered

No

No Mention

3.

Amount o f Expenditure

Volunteered

No

No Mention

4.

Timing o f Expenditure

Volunteered

No

No Mention

5.

In te rn a l Cost Absorption

Volunteered

No__

No Mention___

6.

Bad P u b lic ity

Volunteered

No

No Mention

7.

S u p p lier Scare Tactics

Volunteered

No__

No Mention

8.

Causes Other Problems

Volunteered___ No

No Mention

9.

Employee Grievances

Volunteered

No

No Mention

10.

Employee A t t itu d e

Volunteered

No

No Mention

11 .

Hidden Costs

Volunteered___ No

No Mention

12.

Other

13.

Other

14.

Other

No___ No Mention___

Misgivings About OSHA

XIV.

OTHER COMMENTS

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