If like me you wonder what is happening over at MSHA, here is a partial picture of the situation. Go to an obscure White House website ExpectMore.com. This site appears to be run by the U.S. Office of Management and Budget (OMB) and Federal Agencies. They tell us that their function is to assess federal programs. Here are their words:
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The Federal Government wants programs to work. It is assessing all programs to make sure they are working well for the American people. We use a standard questionnaire called the Program Assessment Rating Tool, or PART, for short. The PART asks approximately 25 important, yet common sense, questions about a program’s performance and management. For each question, there is a short answer and a detailed explanation with supporting evidence. The answers determine a program’s overall rating. Once each assessment is completed, we develop a program improvement plan so we can follow up and improve the program’s performance. PART assessments help us learn how we can achieve better results for the American people – we are always striving to make improvements, regardless of whether a program performs well or not.
We will give them credit for trying. Seems they have rated MSHA and given them an Adequate rating. OMB defines the rating of Adequate in these words:
“This rating describes a program that needs to set more ambitious goals, achieve better results, improve accountability or strengthen its management practices.”
So in typical government-speak, the rating Adequate means, in fact, totally inadequate. That’s what I was begining to suspect of MSHA. Nice to have White House confirmation of my suspicions and fears.
Here is a copy of what OMB says on a separate page about MSHA — I promise I have copied it correctly. Any vagueness, non-sequitur, double-speak, or illogicality is indeed in the original. After all this is the government at work, not Target, not Wal-Mart, and not the Wall Street Journal. Let me warn you that what follows is a tough read; but this is what keeps miners alive or let’s conditions exist that kill them, so I plead with you to persist.
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The Mine Safety and Health Administration promotes compliance with the Federal Mine Safety and Health Act of 1977 and the Mine Improvement and New Emergency Response (MINER) Act of 2006. The MINER Act requires modernization of mine safety practices and calls for the development of enhanced communication technology. Although MSHA has been effective in reducing the number of mining related fatalities and injuries through mandatory inspections, MSHA’s ability to allocate additional resources to high risk mines beyond the minimum requirements of the Mine Act is limited. The quality of MSHA’s regulations and the public’s ability to assess regulatory proposals would be improved by preparing an analysis of the costs and benefits of all of its regulatory proposals. Although the program has established new efficiency measures, they are limited in scope. Currently, the agency’s measures focus solely on processing Quarterly Mine Accident, Injury and Illness, Employment, and Coal Production Reports, which represents less than one percent of the program’s budget. We are taking the following actions to improve the performance of the program:(1)Continuing targeted enforcement and compliance assistance actions at high-risk mines beyond the requirements of the Mine Act with initiatives such as the Cooperative Accident Reduction Effort. (2) Including an analysis of the costs and benefits of major regulatory alternatives in the agency’s Regulatory Impact Analyses for proposed regulations. (3) Implementing the provisions of the MINER Act of 2006.
I confess I do not know if the above is an analysis of the situation, a justification for the Totally Inadequate Rating, a proposal to look into things, or just words filling up a web page. Let me know if you can see the truth shining through this mist.
