Identification of data sources and trends for federal rulemaking in occupational safety and health

Background: Occupational health and safety data is collected by various sources that contribute to federal agency rulemaking. These sources include, but are not limited to, trade unions and associations; industry; academia; medical facilities; state health programs and surveillance; and federal training and enforcement programs. During the rulemaking process, public sources submit information pertaining to work practices and tasks potentially exposing workers to hazards; health and safety outcomes; control and protection methods; medical surveillance; communication to employees; training; and recordkeeping relating to a particular hazard. Such information is used to shape the scope and application; quantitative risk; effectiveness for risk reduction; technological feasibility; consideration and engagement of stakeholders; and other aspects of a proposed rule. The purposes of this session are to identify sources of data submitted to the public docket for rulemaking, highlight variability in types and sources of data submission, and examine data trends among the various stages of an example agency rulemaking action.

Methods: The public record was examined for data submitted in response to OSHA's federal rulemaking action for hexavalent chromium. For this case study, submissions were categorized according to data type and source. Routine action stages of the regulatory process were utilized to appropriately structure the data contributions.

Conclusions: The results provide a better understanding of data sources and stakeholder engagement that influence rulemaking at the federal level and shape agency decisions, particularly for occupational health and safety. Identification of data source gaps may influence public participation in OSHA's future information gathering activities.