OSHA Instruction PAE 1.2A June 25, 1984 Directorate of Field Operations

Subject: Program Development Coordinating Requirement

A. Purpose. This instruction develops a formal system to ensure that all planned National Office programs, policies and procedures that impact field resources will first be compared to field plans through the Directorate of Field Operations.

B. Scope. This instruction applies OSHA-wide.

C. Cancellation. OSHA Instruction PAE 1.2, April 19, 1979, is canceled.

D. Action. National Office Directorates and Regional Administrators shall ensure that the procedures in paragraph E. are followed.

E. Procedure.

1. When there is a program or an activity impacting professional field compliance and/or monitoring resources, the initiating office shall submit and outline (in duplicate) to the Directorate of Field Operations which describes the following:

a. The proposed action.

b. The probable impact by Regions.

c. The time required.

d. The number, experience level and type of personnel required.

e. The goal or objective desired.

f. The recommended priority of the new task.

g. The proposed implementation date.

2. Based upon the decision a recommendation from the Directorate of Field Operations, the Division of Field Performance Evaluation will prepare an impact report containing information about the effect of the proposal against Regional operating plans. When applicable, an evaluation method that could be used to measure the proposed activities will be developed.

3. The Directorate of Field Operations will notify the initiating office and the Regional Offices affected of the final priority, resource allocation and recommended evaluation method.

F. Background. One of the primary considerations before implementing any changes in Federal compliance activities, State program monitoring activities, etc., is to assess the impact of the proposed changes on the effective utilization of OSHA's available resources. To this end, each Regional Office prepares and submits at the beginning of each fiscal year, to the Directorate of Field Operations, an operational plan projecting Regional and Area Offices objectives and allocations of resources to meet those objectives.

1. Quarterly reviews, analyses and comparisons of the estimated plans and actual results with national evaluation measures of effectiveness then are made by the Division of Field Performance Evaluation to provide continuous assessments of program performance.

2. Policy decisions and new programs have been and are being implemented which have a significant impact on field resources. These actions are not being compared with the plans of the areas affected before implementation. Thus, the resources required for future programs may not be available for satisfactory implementation.

3. Also, high priority programs are being implemented without an evaluation system to measure their effectiveness.

G. Explanation. Any programmed strategy relative to compliance operations, State program monitoring or other activities that place demand on professional field staff could result in the ineffective and inefficient assessment of available resources. Also, any such programmed strategy which causes deviations from the Regions' projected yearly operational plans without the prior review of the Director of Field Operations could have the same results. Further, it could produce inaccurate and indefensible data projections in budget justifications.

Patrick R. Tyson Deputy Assistant Secretary

DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors

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