Wayne B. Gray

Does regulatory enforcement work? A panel analysis of OSHA enforcement

This study tests the impact of OSHA enforcement on workplace injuries. Using data on injuries and OSHA inspections for a panel of 6,842 large manufacturing plants between 1979 and 1985, we find significant specific deterrence effects. Inspections imposing penalties induce a 22% decline in injuries in the inspected plant during the following few years. We suggest that narrow deterrence perspectives have led to unduly pessimistic assumptions about enforcement effectiveness and that a managerial attention model is more consistent with our findings. In a technical appendix we describe the Chamberlain technique, a powerful analytic approach for panel data that provides tests and corrections for potential biases endemic in enforcement studies, including unmeasured heterogeneity among units, serially correlated dependent variables, and endogeneity of inspections. We argue that more empirical studies of enforcement impacts are necessary to provide an appropriate perspective for descriptive and analytic studies appraising regulatory behavior.

The Effectiveness of Environmental Monitoring and Enforcement: A Review of the Empirical Evidence

Regulatory punishment for pollution violations is a mainstay of nearly every industrialized nations environmental policy. This article reviews the existing empirical evidence on the impacts of environmental monitoring and enforcement actions. We first provide context by investigating the U.S. regulatory setting. We then briefly discuss how economists think about environmental enforcement. We next consider recent empirical evidence linking regulator actions to subsequent pollution discharges and compliance behavior. Since the literature primarily studies U.S. institutions, our review focuses mainly on the effects of Environmental Protection Agency and U.S. state activities. The consistent findings from this literature review are as follows: (1) environmental monitoring and enforcement activities generate substantial specific deterrence, reducing future violations at the targeted firm; (2) environmental monitoring and enforcement activities generate substantial general deterrence, reducing future violations at facilities other than the targeted one; and (3) environmental monitoring and enforcement activities generate not only reductions in violations but also significant reductions in emissions. We conclude by discussing policy implications and identifying gaps in the current state of knowledge.

Enforcement of Pollution Regulations in a Declining Industry

An examination of the effect of EPA enforcement activity as it relates to company plant-closing decisions and company compliance decisions in the U.S. steel industry, finding fewer enforcement actions taken toward plants with an already high probability of closing.

OSHA Enforcement and Workplace Injuries: A Behavioral Approach to Risk Assessment

We develop a model of risk assessment that incorporates assumptions from the behavioral theory of the firm into conventional expected utility models of compliance, and test the model using data on injuries and OSHA inspections for 6842 manufacturing plants between 1979 and 1985. Four hypotheses are supported-the specific deterrence effect of an inspection, the importance of lagged effects of general deterrence, the asymmetrical effects of probability and amount of penalty on injuries, and the tendency of injury rates to self-correct over a few years. The model estimates that a 10% increase in enforcement activities will reduce injuries by about 1% for large, frequently inspected firms. Prior analyses reporting lower impacts (Smith, 1979; Viscusi, 1986a) are replicated to distinguish between sampling and modeling differences. The results suggest that further compliance theory needs more detailed models of risk-assessment processes to be tested on samples of firms most affected by enforcement.

The Declining Effects of Osha Inspections on Manufacturing Injuries: 1979 to 1998

This study examines the impact of OSHA inspections on injuries in manufacturing plants. The authors use the same model and some of the same plant-level data employed by several earlier studies that found large effects of OSHA inspections on injuries for 1979–85. These new estimates indicate that an OSHA inspection imposing a penalty reduced lost-workday injuries by about 19% in 1979–85, but that this effect fell to 11% in 1987–91, and to a statistically insignificant 1% in 1992–98. The authors cannot fully explain this overall decline, which they find for nearly all subgroups they examine—by inspection type, establishment size, and industry, for example. Among other findings are that, across the years studied, inspections with penalties were more effective than those without, and the effects on injury rates were greater in smaller plants and nonunion plants than in large plants and union plants.

The Environmental Performance of Polluting Plants: A Spatial Analysis

This paper uses plant-level EPA and Census data to examine spatial factors affecting environmental performance, as measured by air pollutant emissions and regulatory compliance. We find significant effects for compliance, but not for emissions. Compliance is positively spatially correlated, partly explained by spatial correlations in observed plant characteristics, suggesting influences of industry agglomeration. The use of spatial econometric methods shows only small effects of spatially lagged compliance status, and does not greatly change the estimated contributions of other spatially explicit factors. Regulatory activity has the expected effect of increasing environmental performance, both at the inspected plant and at neighboring plants, but only for plants in the same state, demonstrating the importance of jurisdictional boundaries.

Can Government Facilitate Cooperation? An Informational Model of OSHA Enforcement

Theory: Government can facilitate cooperation between private parties in collective action dilemmas. Regulatory agencies provide a bargaining arena to establish common expectations, and enforcement activities aid in monitoring cooperative agreements. Hypotheses: We compare two enforcement models of the impact of OSHA inspections on workplace safety. The deterrence model assumes that enforcement rests on coercion, so only inspections imposing sanctions should reduce injuries in inspected plants. The collective action model assumes that enforcement can also facilitate cooperation by providing information, so complaint inspections that signal worker mistrust can decrease injuries even without sanctions. Methods: We test the impact of OSHA inspections on injury rates at 6,842 plants during 1979-85, using maximum likelihood regression analysis to analyze the panel data. Results: Inspections initiated by workers reduce injuries regardless of penalty, suggesting that information rather than coercion is the critical factor in complaint inspections. Regular inspections reduce injuries only when penalties are imposed, which is consistent with both models. We conclude that both coercive and facilitative models are needed to understand regulatory behavior.

Longitudinal Patterns of Compliance with Occupational Safety and Health Administration Health and Safety Regulations in the Manufacturing Sector

We examine the impact of Occupational Safety and Health Administration enforcement on compliance with agency regulations in the manufacturing sector, with a unique plant-level data set on inspections and compliance during 1972-83, the first 12 years of the agency. The analysis suggests that, for an individual plant, the effect of OSHA inspections during this period was to reduce the level of citations on average by 3.1-3.5, or approximately half of the first inspection average of 6.3 citations. The total effect on expected citations of OSHA inspections can be decomposed into two parts: evaluated at the mean of the sample predictions, half of the total reduction in citations occurred due to previous violators coming into compliance and half was due to a reduction in citations among plants that continued to violate the standards.

Toil and toxics : workplace struggles and political strategies for occupational health

comment on the challenges that lie ahead in a declining and increasingly polarized economy. The strength of this book is its feminist perspective on pay equity provided by contributors who have had practical experience with the issue and can also place it in the larger picture of a feminist agenda. The message that emerges is that the legal, technical, and implementation complexities of pay equity are substantial but must be dealt with-and managed-if the policy is to be used as one of a variety of means to further feminist objectives. I recommend Just Wages, then, not only to persons interested in a feminist perspective on pay equity, but also to those interested in the practical legal, technical, and implementation issues that are emerging in Canada.

What Determines Environmental Performance at Paper Mills? The Roles of Abatement Spending, Regulation, and Efficiency

Abstract This paper examines the determinants of environmental performance at paper mills, measured by air pollution emissions per unit of output. We consider differences across plants in air pollution abatement expenditures, local regulatory stringency, and productive efficiency. Emissions are significantly lower in plants with a larger air pollution abatement capital stock: a 10 percent increase in abatement capital stock appears to reduce emissions by 6.9 percent. This translates into a sizable social return: one dollar of abatement capital stock is estimated to provide an annual social return of about 75 cents in pollution reduction benefits. Local regulatory stringency and productive efficiency also matter: plants in non-attainment counties have 43 percent lower emissions and plants with 10 percent higher productivity have 2.5 percent lower emissions. For pollution abatement operating costs we find (puzzlingly) positive, but always insignificant, coefficients.