Pub Date : 2025-01-26DOI: 10.1177/10482911241312387
Stephanie Premji, Momtaz Begum, Kishower Laila
Employers sometimes hinder the appropriate reporting of claims to workers' compensation, a phenomenon termed claim suppression. While the magnitude of claim suppression is difficult to quantify, various reports have identified it as a significant concern. In response, several Canadian jurisdictions, such as Ontario in 2015, introduced legislation addressing claim suppression. This article first discusses the legislative and policy context that influences claim suppression in Ontario, including concerns concerning the scope, interpretation, and enforcement of the law. It then presents qualitative findings from a community-based study with members of the Toronto Bangladeshi immigrant community that documented varied forms of employer claim suppression in precarious work, as well as facilitators of claim suppression within the workers' compensation and health care systems. Our findings and those of other research suggest that the scope of claim suppression is broader than that contemplated by the legislation. Our article proposes recommendations for the conceptualization of claim suppression and for legislation, policies, practices, and interventions that are grounded in workers' lived experiences.
{"title":"Claim Suppression of Occupational Injuries and Illnesses Among Precariously Employed Immigrant Workers in Ontario.","authors":"Stephanie Premji, Momtaz Begum, Kishower Laila","doi":"10.1177/10482911241312387","DOIUrl":"https://doi.org/10.1177/10482911241312387","url":null,"abstract":"<p><p>Employers sometimes hinder the appropriate reporting of claims to workers' compensation, a phenomenon termed claim suppression. While the magnitude of claim suppression is difficult to quantify, various reports have identified it as a significant concern. In response, several Canadian jurisdictions, such as Ontario in 2015, introduced legislation addressing claim suppression. This article first discusses the legislative and policy context that influences claim suppression in Ontario, including concerns concerning the scope, interpretation, and enforcement of the law. It then presents qualitative findings from a community-based study with members of the Toronto Bangladeshi immigrant community that documented varied forms of employer claim suppression in precarious work, as well as facilitators of claim suppression within the workers' compensation and health care systems. Our findings and those of other research suggest that the scope of claim suppression is broader than that contemplated by the legislation. Our article proposes recommendations for the conceptualization of claim suppression and for legislation, policies, practices, and interventions that are grounded in workers' lived experiences.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"10482911241312387"},"PeriodicalIF":1.8,"publicationDate":"2025-01-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"143048230","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2025-01-26DOI: 10.1177/10482911251314183
Marion Endicott
An examination by a community legal worker in Ontario, Canada, of the premises of the experience rating system introduced into the Ontario Workers Compensation system and its negative effects on injured workers and their families, on the workers compensation system itself, and on occupational health and safety.
{"title":"Perverse Outcomes: Notes From the Field on How Financial Incentives in Ontario's Workers' Compensation System Cause Harm to a Public Institution and Create a New Occupational Hazard.","authors":"Marion Endicott","doi":"10.1177/10482911251314183","DOIUrl":"https://doi.org/10.1177/10482911251314183","url":null,"abstract":"<p><p>An examination by a community legal worker in Ontario, Canada, of the premises of the experience rating system introduced into the Ontario Workers Compensation system and its negative effects on injured workers and their families, on the workers compensation system itself, and on occupational health and safety.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"10482911251314183"},"PeriodicalIF":1.8,"publicationDate":"2025-01-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"143048231","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2025-01-23DOI: 10.1177/10482911241311200
Maryth Yachnin
This article explores the challenges facing injured migrant farm workers in the workers' compensation system in Canada's province of Ontario, with a focus on their fight for return to work justice. Told from the perspective of one of the lawyers who represented the workers, it highlights a recent victory achieved by 4 workers in the Seasonal Agricultural Worker Program in defending their rights to workers' compensation support. The workers' compensation tribunal decided that the workers' compensation board must evaluate these workers' ability to return to work, access retraining, and receive compensation based on their labor markets in Jamaica-instead of based on fictional job prospects in Ontario. The tribunal also called out the need to consider systemic anti-Black racism in workers' compensation law and policy. The article analyzes how this legal victory could reshape workers' compensation policy in Ontario for injured migrant farm workers. It also discusses the implications of the win for injured workers in other temporary work programs and precarious employment sectors.
{"title":"From Worker Victory to Policy Reform: Injured Migrant Workers Fight for Return to Work Justice in Workers' Compensation in Ontario, Canada.","authors":"Maryth Yachnin","doi":"10.1177/10482911241311200","DOIUrl":"https://doi.org/10.1177/10482911241311200","url":null,"abstract":"<p><p>This article explores the challenges facing injured migrant farm workers in the workers<i>'</i> compensation system in Canada's province of Ontario, with a focus on their fight for return to work justice. Told from the perspective of one of the lawyers who represented the workers, it highlights a recent victory achieved by 4 workers in the Seasonal Agricultural Worker Program in defending their rights to workers' compensation support. The workers' compensation tribunal decided that the workers' compensation board must evaluate these workers<i>'</i> ability to return to work, access retraining, and receive compensation based on their labor markets in Jamaica-instead of based on fictional job prospects in Ontario. The tribunal also called out the need to consider systemic anti-Black racism in workers' compensation law and policy. The article analyzes how this legal victory could reshape workers<i>'</i> compensation policy in Ontario for injured migrant farm workers. It also discusses the implications of the win for injured workers in other temporary work programs and precarious employment sectors.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"10482911241311200"},"PeriodicalIF":1.8,"publicationDate":"2025-01-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"143025058","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-11-01Epub Date: 2024-08-06DOI: 10.1177/10482911241268495
{"title":"Founder of SHARP Program, Barbara Silverstein, Passes.","authors":"","doi":"10.1177/10482911241268495","DOIUrl":"10.1177/10482911241268495","url":null,"abstract":"","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"224-226"},"PeriodicalIF":1.8,"publicationDate":"2024-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141894568","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-11-01Epub Date: 2024-09-19DOI: 10.1177/10482911241276377
Viviane de Freitas Cardoso, Cristiane Shinohara Moriguchi, Tatiana de Oliveira Sato
For many women, house cleaning is an important way to participate in the labor market. In Brazil, there are 2 types of domestic workers: housekeepers have relatively secure employment and house cleaners are day laborers. The aim of this hypothesis-generating study was to describe the sociodemographic, occupational and health profile of a sample of domestic workers in Brazil. House cleaners received lower wages, had longer daily working hours and worked in a larger number of homes each week in comparison to housekeepers. About 51% of the domestic workers in this sample reported the use of pain medication and 34% reported spinal problems. Musculoskeletal symptoms were frequent in the lower back and upper limbs. Forty-seven percent reported high blood pressure. This study highlights the vulnerability of domestic workers, especially house cleaners, regarding workload, salary, and health conditions. Level of education is a contributing factor to this vulnerability.
{"title":"Sociodemographic, Occupational, and Health Profile of Brazilian Housekeepers and House Cleaners-A Hypothesis-Generating Study.","authors":"Viviane de Freitas Cardoso, Cristiane Shinohara Moriguchi, Tatiana de Oliveira Sato","doi":"10.1177/10482911241276377","DOIUrl":"10.1177/10482911241276377","url":null,"abstract":"<p><p>For many women, house cleaning is an important way to participate in the labor market. In Brazil, there are 2 types of domestic workers: housekeepers have relatively secure employment and house cleaners are day laborers. The aim of this hypothesis-generating study was to describe the sociodemographic, occupational and health profile of a sample of domestic workers in Brazil. House cleaners received lower wages, had longer daily working hours and worked in a larger number of homes each week in comparison to housekeepers. About 51% of the domestic workers in this sample reported the use of pain medication and 34% reported spinal problems. Musculoskeletal symptoms were frequent in the lower back and upper limbs. Forty-seven percent reported high blood pressure. This study highlights the vulnerability of domestic workers, especially house cleaners, regarding workload, salary, and health conditions. Level of education is a contributing factor to this vulnerability.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"213-223"},"PeriodicalIF":1.8,"publicationDate":"2024-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"142298188","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-11-01Epub Date: 2024-09-27DOI: 10.1177/10482911241273628
Adam M Finkel
The controversy over whether repeated head impact (RHI)-a feature of occupations including professional contact sports, military service, firefighting, and logging-can cause the neurodegenerative disease now known as CTE (chronic traumatic encephalopathy) has thrust many positive epidemiologic studies into the spotlight. Various skeptics who dispute that the relationship is strong and causal continue to raise objections to these studies and their interpretation. The arguments these skeptics use remind other observers of many past sagas of "manufactured doubt," particularly the history of attempts to cast doubt on the propensity of tobacco products to cause lung cancer. A recent article in the Journal of Science and Medicine in Sport3 complained that drawing the parallel between RHI and cigarettes is unhelpful, concluding that "the time for politically motivated analogies has now passed." This author disagrees, and explains in detail 2 scientific aspects of risk assessment and management that make the analogy apt and instructive for the future. In particular, I argue that the problem of "manufactured doubt" here is two-fold: it relies on various fallacies of reasoning discussed herein, but more importantly, it seeks to divert and delay the utilitarian imperative-while we grope toward the ever-elusive certainty, there are many low-regret actions we can and should take on the basis of persuasive signals of harm.
反复头部撞击(RHI)--职业接触性运动、服兵役、消防和伐木等职业的一个特征--是否会导致现在被称为 CTE(慢性创伤性脑病)的神经退行性疾病,这一争议将许多积极的流行病学研究推到了聚光灯下。各种怀疑论者质疑这种关系的牢固性和因果性,并继续对这些研究及其解释提出反对意见。这些怀疑论者所使用的论据让其他观察者想起了过去许多 "制造怀疑 "的传奇故事,尤其是试图对烟草产品导致肺癌的倾向提出质疑的历史。最近,《体育科学与医学杂志》(Journal of Science and Medicine in Sport)3 上的一篇文章抱怨说,将 RHI 与香烟相提并论是无益的,并得出结论:"出于政治动机进行类比的时代已经过去了"。本文作者不同意这一观点,并详细解释了风险评估和管理的 2 个科学方面,这些方面使得这种类比非常恰当,并对未来具有指导意义。特别是,我认为这里的 "制造怀疑 "问题有两个方面:它依赖于本文所讨论的各种推理谬误,但更重要的是,它试图转移和拖延功利主义的必要性--当我们向着永远难以捉摸的确定性摸索时,我们可以而且应该根据有说服力的危害信号采取许多低遗憾的行动。
{"title":"We Should Celebrate, Not Censor, Learning From Epidemiologic History.","authors":"Adam M Finkel","doi":"10.1177/10482911241273628","DOIUrl":"10.1177/10482911241273628","url":null,"abstract":"<p><p>The controversy over whether repeated head impact (RHI)-a feature of occupations including professional contact sports, military service, firefighting, and logging-can cause the neurodegenerative disease now known as CTE (chronic traumatic encephalopathy) has thrust many positive epidemiologic studies into the spotlight. Various skeptics who dispute that the relationship is strong and causal continue to raise objections to these studies and their interpretation. The arguments these skeptics use remind other observers of many past sagas of \"manufactured doubt,\" particularly the history of attempts to cast doubt on the propensity of tobacco products to cause lung cancer. A recent article in the <i>Journal of Science and Medicine in Sport</i><sup>3</sup> complained that drawing the parallel between RHI and cigarettes is unhelpful, concluding that \"the time for politically motivated analogies has now passed.\" This author disagrees, and explains in detail 2 scientific aspects of risk assessment and management that make the analogy apt and instructive for the future. In particular, I argue that the problem of \"manufactured doubt\" here is two-fold: it relies on various fallacies of reasoning discussed herein, but more importantly, it seeks to divert and delay the utilitarian imperative-while we grope toward the ever-elusive certainty, there are many low-regret actions we can and should take on the basis of persuasive signals of harm.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"154-160"},"PeriodicalIF":1.8,"publicationDate":"2024-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"142356074","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-11-01Epub Date: 2024-08-08DOI: 10.1177/10482911241267347
James T Brophy, Margaret M Keith, Michael Hurley, Craig Slatin
The well-being of health care workers (HCWs) and the public in Ontario, Canada is at risk as the province's health care system is strained by neoliberal restructuring and an aging population. Deteriorating working conditions that preceded the COVID-19 pandemic further declined as the added challenges took their toll on the work force, physically and mentally. The pandemic-weary hospital staff, predominantly women, many racialized, are facing unprecedented challenges. They are experiencing stress, anxiety, and burnout from staffing shortages and the resulting increased workloads, long hours, and violence. Comprehensive telephone interviews were conducted with 26 HCWs from less highly paid occupations in a range of hospitals across the province. Thematic analysis reveals a critical need for policies and legislation ensuring increased funding, hospital capacity, and reduced wait times while providing HCWs with fair and equitable wages, increased staffing, mental health supports, greater respect and acknowledgment, and strong protections from violence and other workplace hazards.
{"title":"Running on Empty: Ontario Hospital Workers' Mental Health and Well-Being Deteriorating Under Austerity-Driven System.","authors":"James T Brophy, Margaret M Keith, Michael Hurley, Craig Slatin","doi":"10.1177/10482911241267347","DOIUrl":"10.1177/10482911241267347","url":null,"abstract":"<p><p>The well-being of health care workers (HCWs) and the public in Ontario, Canada is at risk as the province's health care system is strained by neoliberal restructuring and an aging population. Deteriorating working conditions that preceded the COVID-19 pandemic further declined as the added challenges took their toll on the work force, physically and mentally. The pandemic-weary hospital staff, predominantly women, many racialized, are facing unprecedented challenges. They are experiencing stress, anxiety, and burnout from staffing shortages and the resulting increased workloads, long hours, and violence. Comprehensive telephone interviews were conducted with 26 HCWs from less highly paid occupations in a range of hospitals across the province. Thematic analysis reveals a critical need for policies and legislation ensuring increased funding, hospital capacity, and reduced wait times while providing HCWs with fair and equitable wages, increased staffing, mental health supports, greater respect and acknowledgment, and strong protections from violence and other workplace hazards.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"182-197"},"PeriodicalIF":1.8,"publicationDate":"2024-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141903186","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-11-01Epub Date: 2024-08-09DOI: 10.1177/10482911241269313
Michael Chidera Ofonedu, Jodi J Frey, Orrin D Ware, Kathleen Hoke, Clifford S Mitchell, Marianne Cloeren
This paper describes the work-related information collected in several important U.S. national health and behavior surveys, to highlight data gaps that prevent identifying responses by vulnerable workers in the gig economy, with emphasis on the growing digital platform sector of the work force. The national information systems used to understand health status and health behaviors, including drug use, rely on outdated census categories for self-employed workers. This paper describes the importance of understanding the needs of this growing part of the labor sector and describes how some of the most well-known and utilized national surveys fail to meet this need. For the agencies conducting national health and behavior surveys, we propose revisions to the categories used to classify type of worker and recommend adoption of a new Worker-Employer Relationship Classification model.
{"title":"Improving Identification of Gig Workers in National Health and Behavior Surveys.","authors":"Michael Chidera Ofonedu, Jodi J Frey, Orrin D Ware, Kathleen Hoke, Clifford S Mitchell, Marianne Cloeren","doi":"10.1177/10482911241269313","DOIUrl":"10.1177/10482911241269313","url":null,"abstract":"<p><p>This paper describes the work-related information collected in several important U.S. national health and behavior surveys, to highlight data gaps that prevent identifying responses by vulnerable workers in the gig economy, with emphasis on the growing digital platform sector of the work force. The national information systems used to understand health status and health behaviors, including drug use, rely on outdated census categories for self-employed workers. This paper describes the importance of understanding the needs of this growing part of the labor sector and describes how some of the most well-known and utilized national surveys fail to meet this need. For the agencies conducting national health and behavior surveys, we propose revisions to the categories used to classify type of worker and recommend adoption of a new Worker-Employer Relationship Classification model.</p>","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":" ","pages":"172-181"},"PeriodicalIF":1.8,"publicationDate":"2024-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141907963","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-09-18DOI: 10.1177/10482911241273914
Holly Blake, Vinishaa Premakumar, Abishaa Premakumar, Aaron Fecowycz, Sala Kamkosi Khulumula, Wendy Jones, Sarah Somerset
Ethnic minority healthcare workers (EMHCW) are at high risk of COVID-19 infection and adverse health outcomes, but vaccine uptake is low among ethnic minority communities, including EMHCW. We explored the views of EMHCW towards COVID-19 Vaccine Education (CoVE), a digital training resource to improve knowledge and confidence for promoting the COVID-19 vaccine. Thirty EMHCW completed CoVE, then participated in a semi-structured qualitative interview. Principles of framework analysis were used to deductively analyse data using concepts from the Kirkpatrick New World Model of training evaluation. CoVE was viewed to be engaging, accessible and relevant to EMHCW. This training increased EMHCW perceived knowledge and confidence to provide evidence-based information to others, dispel myths, and reduce vaccine hesitancy. Participants reported changes in vaccine promotion behaviours and vaccine uptake. CoVE could be used to help improve vaccine literacy among EMHCW, enhance health communications about vaccines, and ultimately help facilitate uptake of occupational vaccination programs.
{"title":"A Qualitative Study of the Views of Ethnic Minority Healthcare Workers Towards COVID-19 Vaccine Education (CoVE) to Support Vaccine Promotion and Uptake","authors":"Holly Blake, Vinishaa Premakumar, Abishaa Premakumar, Aaron Fecowycz, Sala Kamkosi Khulumula, Wendy Jones, Sarah Somerset","doi":"10.1177/10482911241273914","DOIUrl":"https://doi.org/10.1177/10482911241273914","url":null,"abstract":"Ethnic minority healthcare workers (EMHCW) are at high risk of COVID-19 infection and adverse health outcomes, but vaccine uptake is low among ethnic minority communities, including EMHCW. We explored the views of EMHCW towards COVID-19 Vaccine Education (CoVE), a digital training resource to improve knowledge and confidence for promoting the COVID-19 vaccine. Thirty EMHCW completed CoVE, then participated in a semi-structured qualitative interview. Principles of framework analysis were used to deductively analyse data using concepts from the Kirkpatrick New World Model of training evaluation. CoVE was viewed to be engaging, accessible and relevant to EMHCW. This training increased EMHCW perceived knowledge and confidence to provide evidence-based information to others, dispel myths, and reduce vaccine hesitancy. Participants reported changes in vaccine promotion behaviours and vaccine uptake. CoVE could be used to help improve vaccine literacy among EMHCW, enhance health communications about vaccines, and ultimately help facilitate uptake of occupational vaccination programs.","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":"3 1","pages":""},"PeriodicalIF":2.3,"publicationDate":"2024-09-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"142260588","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2024-09-12DOI: 10.1177/10482911241273603
James Goodwin
For public interest advocates engaged on issues of worker health and safety and environmental protections, regulatory cost–benefit analysis has long been seen as an obstacle to meaningful progress. In November 2023, the Biden administration overhauled Circular A-4, which provides guidance to agencies on how to perform cost–benefit analyses for their rules. The reforms seek to make cost–benefit analysis less biased against worker safety, public health, environmental, and other protective safeguards. As such, the new version of Circular A-4 offers important new levers to agencies to justify more stringent protections. By extension, those in the public interest community can use agency implementation of the new Circular A-4 as part of their advocacy efforts for specific rules they are tracking. This article seeks to support this tactic by providing a roadmap for advocates on how to incorporate into their comments critiques of agencies’ cost–benefit analyses based on the Circular A-4 revisions.
{"title":"How Advocates Can Use the Revised Circular A-4 Means to Push for Stronger Worker and Environmental Protections","authors":"James Goodwin","doi":"10.1177/10482911241273603","DOIUrl":"https://doi.org/10.1177/10482911241273603","url":null,"abstract":"For public interest advocates engaged on issues of worker health and safety and environmental protections, regulatory cost–benefit analysis has long been seen as an obstacle to meaningful progress. In November 2023, the Biden administration overhauled Circular A-4, which provides guidance to agencies on how to perform cost–benefit analyses for their rules. The reforms seek to make cost–benefit analysis less biased against worker safety, public health, environmental, and other protective safeguards. As such, the new version of Circular A-4 offers important new levers to agencies to justify more stringent protections. By extension, those in the public interest community can use agency implementation of the new Circular A-4 as part of their advocacy efforts for specific rules they are tracking. This article seeks to support this tactic by providing a roadmap for advocates on how to incorporate into their comments critiques of agencies’ cost–benefit analyses based on the Circular A-4 revisions.","PeriodicalId":45586,"journal":{"name":"New Solutions-A Journal of Environmental and Occupational Health Policy","volume":"149 1","pages":"10482911241273603"},"PeriodicalIF":2.3,"publicationDate":"2024-09-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"142211401","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}