OSHA Instruction PUB 8.4A July 8, 1985 Office of Information and Consumer Affairs

Subject: OSHA's Periodicals, Pamphlets and Audio-visual Control Plan

A. Purpose. This instruction transmits procedures to be followed by OSHA In the initiation of any product for publication or duplication.

B. Scope. This instruction applies OSHA-wide. It applies to training materials, periodicals, pamphlets and audio-visual materials (including off-the-shelf purchases). It does not apply to single-sheet 81/2" x 11" flyers, Federal Registers and Federal Register reprints, OSHA Training Institute curricular materials or congressionally mandated publications.

C. Cancellation. OSHA Instruction PUB 8.3, June 24, 1981, and PUB 8.4, February 22, 1982, are cancelled.

D. Action. All OSHA employees planning to produce periodicals, pamphlets or audio-visual programs must follow the procedures outlined in this instruction.

E. Background. In accordance with the requirements of OMB Bulletin 81-16 and other related documents, the attached control plan is designed to accommodate the program, policy and management needs of OSHA.

The plan gives a step-by-step process (outlined in Appendix A), from concept to final product, that must be followed to produce or purchase any periodical, pamphlet or audio-visual product.

F. Procedures.

1. Concept Origination.

a. Description. A concept will originate within a program or functional unit. It may originate in the national office or in a region. All levels of review and approval are required for both national office and regional initiation of proposals.

 

A concept proposal must contain the following elements:

(1) Description of the proposed audio-visual, periodical, pamphlet or series.

(2) Explanation of the need.

(3) Identification of a specific message or communications goal related to an OSHA program.

(4) Indication of appropriate audience(s), any known market research, demographic or socioeconomic information about audience(s) and why particular audience(s) should receive the message.

 

(5) Estimate of when the message should be delivered and why.

(6) Explanation of the advantage of proposed format, as opposed to other forms.

(7) Discussion of product's cost effectiveness, baked on an estimated cost per viewer.

 

(8) Description of proposed test-market audience (see step 8).

(9) Proposed plans for its distribution and delivery, as well as any strategy for promoting the product (see step 9).

(10) Description of proposed post-production evaluation (see step 10).

(11) A completed Department of Labor Form 1-2026 (DL 1-2026).

b. Control Position. The highest ranking official of the originating unit will review and approve initial proposal.

c. Documentation. Prepare the initial proposal using DL 1-2026 and include all of the above items. The memorandum should identify by name and title the additional positions within OSHA which must review and approve the proposal. (See Appendix B.)

2. Supervisory Review.

a. Description. This process represents the various stages of review and approval necessary beyond that of the originating office. The head of the directorate in which the originating office is located will determine the highest level of concept review needed for an individual project. He or she may retain that responsibility within his/her own office or designate a lower ranking official within the directorate. Several levels of review may be reviewed before a proposal reaches the directorate head or his/her designated official. For example, the originating office may need to obtain review of division and branch levels before it reaches the directorate head or his/her designee.

b. Control Position. The directorate head or his/her designee holds the control position.

c. Documentation The necessary levels of review and appropriate signatures are found in lines 10a. and 10b. of DL 1-2026.

3. Office of Information and Consumer Affairs Needs Assessment and Analysis.

a. Description. Since the Office of Information and Consumer Affairs (OICA) serves as a central point for OSHA's information activities, this office will review the proposal for any overlap or complementary uses. An OICA staff member will be available to provide guidance and assistance in the following areas:

(1) Review of existing products available from government or private-sector sources which might serve the same need.

(2) Refinement of message or communications goal to be achieved.

(3) Investigation, analysis, and thorough review of available marketing research pertinent to targeted audience(s).

(4) Recommendation of whether or not original marketing research must be undertaken before further product development is initiated.

(5) Review and, if necessary, further investigation and development of the factors addressed in initial proposal, including:

 

(a) Selection of medium or format.

 

(b) Estimated cost of production and delivery.

(c) Review of alternative methods of production and cost effectiveness of the selected method in proposal.

 

(d) Analysis of the justification of need.

(e) Review and modification, if necessary, of proposed timetables for delivery and length of use.

(6) Recommendation for method or source of production, i.e., in-house, contract or off-the-shelf purchase, and appropriate fulfillment of other requirements, such as mandatory title check with National Audio-visual Center (SF 282) and OMB requirements.

(7) Review of distribution and delivery plan for product dissemination.

 

(8) Review of promotion strategy for delivery.

(9) Review of the means to be used for conducting the post-production evaluation.

b. Control Position. The highest ranking official of the originating office is responsible for supplying all pertinent information and cooperating fully with the needs assessment and analysis effort. The OICA director is responsible for ensuring that all control needs are satisfied.

c. Documentation. Needs assessment shall be determined based on the information contained in DL 1-2026 as well as all necessary attachments such as printing and graphics estimates.

4. Office of Financial Management Budget Review.

a. Description. The Office of Financial Management will review all cost estimates to ensure they are reasonable and realistic. It will verify whether or not sufficient funds are available to cover complete cost of the product; and if not, indicate amount which could be used if a more limited effort might be desired.

b. Control Position. The Office of Financial Management will perform this review and the final review and control authority will be provided by an administrative and/or management officer.

c. Documentation. Financial Management will certify whether sufficient funds are available or whether a limited amount may be used. (See DL 1-2026, line 10c.)

5. OSHA Management Review Committee Review and Approval of Concept, Policy and Plans.

a. Description. This phase will be performed by OSHA's Management Review Committee (OMRC). (This step only applies for projects with total costs of $2,500 or more.) The review will consider whether or not the proposal:

(1) Reflects a legitimate need.

(2) Is within the legal, regulatory and customary scope of OSHA's authority and mission.

(3) Is consistent with OSHA and Administration goals, priorities and policies.

 

(4) Is an appropriate and desirable use of OSHA funds.

 

(5) Includes appropriate timeframes for delivery.

 

(6) Warrants development in relation to other OSHA activities.

 

(7) Should involve other OSHA or Departmental offices.

(8) Conforms with all other existing policies and requirements of OSHA.

b. Control Position. The OSHA Management Review Committee will review and approve all concepts, policies and plans.

c. Documentation. Appropriate signatures must be obtained for approval. OMRC may consider documenting specific elements of the review in an accompanying memorandum.

6. Departmental Office of Information and Public Affairs Review of Concept, Policy and Plans.

a. Description. Departmental review of concept, policy and plans will be carried out by the DOL Office of Information and public Affairs (OIPA). This Office serves as a central coordination point for DOL' s public information activities. As many Departmental programs either overlap or are of a complementary nature, several centralized services as well as a required control point can be provided by OIPA.

To ensure objectivity and independent review, two separate areas within OIPA will perform analysis and review functions.

(1) A Management Analysis Officer in the Division of Audio-visual and Communications Services will be available to provide guidance and assistance, also the required review and control in the following areas:

(a) Evaluation of existing products, including development of a centralized source of available public and private-sector resources.

 

(b) Review and certification of the cost estimates.

(c) Analysis of the cost effectiveness and cost comparisons of alternative methods of production.

 

(d) Review and evaluation of cost/viewer statements.

 

(e) Review and evaluation of proposed production.

(2) The Communications Policy and Planning Officer in the Office of the Director of OIPA will review the following aspects:

 

(a) Justification of need and communications goals.

 

(b) Targeted audience(s).

 

(c) Need for any original market research.

 

(d) Identification of test-market audience.

 

(e) Description of distribution and delivery systems.

 

(f) Timeframes for product's availability and lifespan.

(g) Promotion strategy.

 

(h) Post-production evaluation mechanisms to be used.

b. Control Position. Review, evaluations and recommendations of the Management Analysis Officer will be forwarded to the Communications Policy and Planning Officer who will incorporate the findings with his/her own conclusions and will prepare a final report and recommendation for the Director of OIPA, who has final responsibility for all controls at this level.

c. Documentation. All necessary and appropriate memoranda, documents, reports, forms, data, etc., must be attached to the final proposal package which is reviewed and cleared by the Director of OIPA.

7. Initiation of Production.

a. Description.

(1) Regardless of whether production is carried out in-house, on contract, through a combination of the two or by way of an interagency service agreement, OSHA control criteria include:

(a) Compliance with all OSHA, Departmental and OMB requirements and procedures.

 

(b) Periodic review of work in progress.

(c) Management approval of all departures from approved proposal.

(d) Submission of the post-production Audio-visual Product Report (SF 202) to the National Audio-visual Center.

(2) If the project involves work to be done on contract, the following criteria must be met:

(a) Coordination between program, technical and contracting specialists in the preparation of solicitation documents and management approval.

(b) Sufficient competition for goods and/or services being acquired.

 

(c) Full justification for non-competitive acquisitions.

(d) Adequate lead time for contractor proposal preparation.

(e) Complete and impartial evaluation of all contractor proposals.

 

(f) Periodic review of contractor's performance.

(g) Compliance with all requirements of the Federal Procurement Policy and other arms of government.

(h) Compilation of accurate and complete reports from contracting office or the contractor.

b. Control Position(s). A project officer will be responsible for fulfilling all requirements of the control system.

For contract work, the Contracting Officer's Technical Representative (COTR) will be responsible for fulfilling the requirements specific to that procurement. The COTR and project officer may or may not be the same person, depending on the nature of the project. If two individuals are assigned, then they must work closely and coordinate with each other.

Also, there should be cooperative working arrangements with appropriate contract and/or administrative officers at the OSHA level and approval of all contracts or procurement through an authorized official (s).

c. Documentation. The project officer and/or COTR will be responsible for ensuring that all necessary paperwork, forms and documentations are adequately prepared and that all required signatures for approval are obtained before production is begun. All necessary material should be packaged with a cover memorandum authorizing initiation of the project. The authorization memorandum must be signed by the project officer and/or the, the supervisory official(s) and the contract or administrative officer in the case of work to be performed through a commercial source.

8. Test-Marketing and Completion of Production

a. Description. Before production starts the product may be sent, in draft form, to various interested labor unions, trade organizations and professional associations for review and to ascertain whether or not it will be a useful product. This will aid in meeting our goal(s) objectively and with a product that can endure the passage of time.

Once the test-marketing and production are completed, the final product will be delivered to the requestor for review of:

 

(1) Comparison of finished product with original request.

 

(2) Verification of the quantity provided.

b. Control Position. The test-marketing requirements are the responsibility of the project officer and/or (if service is provided as part of a contract) and will be carried out in cooperation with the director of OICA. Results must be approved by the supervising official(s) of the project officer and/or the COTR.

The office requesting the product is responsible for the completeness and reliability controls. A staff member with no involvement in the project should be assigned to review the product for reliability and quantity delivered.

c. Documentation. The project officer and/or the COTR is responsible for preparing a report on the test-marketing phase. The test-marketing report with all appropriate signatures should be attached to other materials in the package pertaining to the complete product. The report, in memorandum form, should describe:

(1) Method used.

(2) Number of persons involved, and their reaction to the product.

(3) The impact of the message.

(4) Whether or not recommendation for production is based on the test-marketing result.

9. Promotion, Distribution/Delivery and Public Dissemination.

a. Description. Promotional activities, distribution of the product, and delivery of the product to the public should be carried out in conformance with:

 

(1) The approved method outlined in the proposal.

(2) OMB Circular A-114.

(3) Federal procurement regulations on printing or audio-visual duplication.

b. Control Position. The highest ranking official in the originating office of the proposal is responsible for assuring that promotion, distribution and delivery to the public are carried out.

c. Documentation. This should consist of a memorandum describing the method used and confirming that approved plans were adequately followed.

10. Post-Production Evaluation.

a. Description. Analysis and evaluation should be performed to determine whether the product was effectively used and if the defined objectives were met.

Post-production evaluations will be used to advise management on the outcome of the project, degree of success in accomplishing stated objectives, results achieved and possible application for future efforts.

 

The evaluation should include the following factors:

(1) Distribution of materials to audience(s) indicated in the initial proposal.

 

(2) Receipt of materials within specified timeframe.

 

(3) Impact of the message on the audience(s).

 

(4) Usefulness and comprehension of the information imparted.

(5) Information lacking, if any.

(6) Changes resulting from the dissemination of the information.

 

(7) Success of the product in achieving desired goal(s).

(8) Any other essential information pertinent to the particular product.

b. Control Position. The evaluation should be carried out or supervised by an official not directly involved in the particular activity. The Department's Office of Information and Public Affairs will be available to assist OSHA with this evaluation.

c. Documentation. Detailed reports of the evaluation should be made to all management levels involved in the project, as well as to OIPA. The report should be signed by the individual performing or overseeing the work and by the highest ranking official in that staff member's work unit.

Rcbert A. Rowland Assistant Secretary for OSHA

Distribution: National, Regional, and Area Offices

 

APPENDIX A

 

OSHA CONTROL PLAN

_____ __________________________________________________________________

| |1 CONCEPT ORIGINATION | | |________________________________________________________________| | |2 | | | | V | | | SUPERVISORY REVIEW | | |________________________________________________________________| | |3 | | | | V | | | OFFICE OF INFORMATION AND CONSUMER AFFAIRS | | | Needs Assessment and Analysis | | |________________________________________________________________| | |4 | | | | V | | | FINANCIAL MANAGEMENT | |_____ |________________________________________________________________| | V __________________________________________________________________

|5 OSHA MANAGEMENT REVIEW COMMITTEE | | Review of Concept, Policies and Plans | | (For Projects Totaling $2,500 and Over) | |________________________________________________________________| | V ___________________________________________________________________

|6 DOL OFFICE OF INFORMATION AND PUBLIC AFFAIRS | | Review and Approval of DL 1-2026 | |_________________________________________________________________| Steps 1-5 to be repeated if | major changes are made. | V __________________________________________________________________

|7 INITIATION OF PRODUCTION | |________________________________________________________________| | V __________________________________________________________________

|8 TEST MARKET | |________________________________________________________________| | V __________________________________________________________________

|9 PROMOTION, DISTRIBUTION AND | | DELIVERY, AND PUBLIC DISSEMINATION | |________________________________________________________________| | V __________________________________________________________________

|10 POST-PRODUCTION EVALUATION | |________________________________________________________________|

 

APPENDIX B

 

CONTROL SYSTEM PROPOSAL FORM

 

(For Appendix B, see printed copy)

 

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