August 7, 1998

August 7, 1998 | Backgrounder on Jobs, Jobs and Labor Policy

Labor-Health-Education Appropriations:  Eliminating Waste andEnhancing Accountability

A balanced federal budget and projections of a $1.6 trillion surplus over the next ten years have encouraged many Washington policymakers to find more and more ways to pour tax dollars into new and bigger government programs. Consider the following:

  • Between fiscal year (FY) 1997 and FY 1998, federal domestic discretionary spending adjusted for inflation will increase $3.3 billion to reach $228.3 billion. President Clinton wants an additional $6 billion to reach a record $234.3 billion in federal spending in FY 1999.

  • FY 1998 discretionary spending for the Departments of Labor, Health and Human Services, Education, and related agencies (Labor-HHS-Education) is expected to reach $80.4 billion. The President requests an additional $1.5 billion in FY 1999 to increase spending to $81.9 billion.

Dozens of reports by such government watchdogs as the U.S. General Accounting Office (GAO) and various agency inspectors general, however, demonstrate that many federal programs are not working. In addition, Congress now has in hand agencies' five-year strategic plans and FY 1999 annual performance plans, as required by the Government Performance and Results Act (Results Act) of 1993. These plans reinforce the concerns of many Americans that federal agencies are plagued by serious problems.1

Fortunately, the House of Representatives has become far less willing to continue to feed the appetite of an ineffective, bloated federal bureaucracy. The House Appropriations Committee has taken a bold first step by reporting an FY 1999 Labor-HHS-Education appropriations bill that begins to hold agencies accountable for poor performance, eliminates programs that are wasteful or no longer needed, and demands results from those that continue. It would either terminate or reduce funding levels and reform many of the following programs because of their poor track records:

House Appropriations Committee-Recommended Programs
That Should Be Terminated, Reformed or Granted No Signficant Increase

Fiscal Year 1998 Fiscal Year 1999
Summer Youth Employment and Training $871 million $0
School-to-Work $400 million $150 million
Low-Income Home Energy Assistance $1 billion $0
Head Start $4.4 billion $4.5 billion
Goals 2000 $491 million $246 million
Eisenhower Professional Development $335 million $285 million
Federal Regional Education Laboratories $56 million $56 million
Occupational Safety and Health Administration (OSHA) enforcement and compliance strategy and health and safety standards $286.1 million $286.2 million
National Labor Relations Board (NLRB) jurisdictional thresholds $175 million $175 million
Bilingual Education $354 million $354 million

 

































PROGRAMS THAT SHOULD BE TERMINATED OR GRANTED REDUCED FUNDING

Summer Youth Employment and Training Program





















The Summer Youth Employment and Training Program, funded under Title II-B of the Job Training Partnership Act (JTPA), provides jobs and training during the summer months for economically disadvantaged youth aged 14-21. For FY 1998, the Department of Labor is obligating $871 million to the states through block grants.

As the GAO points out, however, there already are 19 federal programs that focus directly on youth training and employment.2 Together, these programs spend $2.8 billion per year, and this does not include the $1.0 billion spent on vocational education programs.3 Almost half of the youth in the summer jobs program are 14 and 15 years old, and are essentially paid to go to summer school to learn what they should have learned during the regular school year.

  • A report by then-Secretary of Labor Robert B. Reich acknowledges that summer jobs programs do not work.4 The study notes that subsidized work experience has not been successful in improving the employability of youths once the subsidized job has ended. The graduation rates and grades of participants do not improve, and young girls in the program are just as likely to become pregnant as those that do not participate in the program.

  • A national controlled scientific study of JTPA reported that youth programs had no statistically significant effect on either the average earnings of young females or their employment.5 Even worse, the programs had a large negative effect on the earnings of young males and no effect on their employment.

Many Members of Congress realize that basic education reform, and tax and regulatory reform, are the best ways to strengthen the ability of all young Americans to find gainful employment. Accordingly, the House Appropriations Committee has eliminated the Summer Youth Employment and Training Program to make it easier to pursue initiatives that support economic growth and more effectively create the jobs that young Americans want and need.

School-to-Work Programs





















Since the program was created in 1994, 43 states have received School-to-Work implementation grants. In FY 1997 and FY 1998, $400 million was appropriated each year for these programs. School-to-Work's authorization is scheduled to expire on October 1, 2001.

Proponents claim that the program focuses on building school, business, and community partnerships; academic and occupational integration; the integration of school and work-based learning; and connections to post-secondary education. However:

  • Since FY 1994, the U.S. Department of Education has granted the states money from other federal programs--$4.4 billion in vocational education grants, $1.1 billion in professional development grants, and $1.3 billion in program innovation grants--to do the same things the School-to-Work program does.

  • Of the $200 million appropriated in FY 1998 for the Department of Education's responsibilities under the School-to-Work Opportunities Act, less than one-half (about $93 million) actually is used in classrooms, according to the Congressional Research Service.6

  • A preliminary report on how states have implemented School-to-Work programs already has concluded that efforts to raise academic and vocational standards are peripheral to School-to-Work priorities and that the links between school and worksite learning are limited.7

The $2.8 billion currently planned to be spent on School-to-Work programs between 1994 and 2001 will continue to have a negligible effect on teaching the basic skills that employers require. In the first-ever national evaluation of school-to-work programs, Mathematica Policy Research, Inc., is assessing the states' progress in creating these systems for the U.S. Department of Education. It will measure, among other things, the outcomes students achieve in high school and post-secondary education and employment. (The study does not use a rigorous control group evaluation methodology, however, and this raises serious concerns about its ultimate usefulness.8 )

States and localities should have the flexibility to establish their own core curricula, use proven teaching methods, set high expectations, and improve discipline. Primary and secondary schools should concentrate on improving key areas such as these instead of devoting scarce resources to interagency collaboration and the formation of local partnerships. Thus, the House Appropriations Committee has proposed significant reductions in School-to-Work funding.

Low-Income Home Energy Assistance Program

The Low-Income Home Energy Assistance Program (LIHEAP) provides federal funding to help pay home energy costs (heating and cooling) for some low-income households. Funds are distributed through annual block grants to states, the District of Columbia, more than 100 eligible Indian tribes, two commonwealths, and four territories. Up to 10 percent of the funds payable to a state may be used to pay planning and administrative costs.

The United States has spent over $27.1 billion on LIHEAP since the program began in 1982. As the Congressional Budget Office points out:

LIHEAP was created in response to the rapid increases in the price of energy used in the home in the late 1970s and early 1980s. Since 1981, however, inflation in fuel prices has lagged far behind general inflation: fuel prices are up about 25 percent since 1981 in comparison with an overall inflation rate of 70 percent. That fact might now warrant either eliminating or reducing LIHEAP.9

The LIHEAP program is now obsolete. The extreme conditions it was created to address no longer exist. In addition, the states have been given more discretion over how they use federal welfare money, and this has enabled them to address the needs of low-income Americans more creatively. Continuing the LIHEAP program would needlessly preserve a federal bureaucracy to manage the program and drain resources that more appropriately should be available to states, local communities, and families. The House Appropriations Committee, therefore, has proposed to terminate funding for LIHEAP in FY 1999.

Head Start10

Since 1965, the Head Start program has served more than 15 million children at a total cost of over $30 billion. The program's general purpose is to provide comprehensive health, social, educational, and mental health services to disadvantaged students.11 According to the GAO, however, the early childhood development program has continued to operate without any valid, useful study of how well it works.12

The Clinton Administration has asked Congress to increase funding for the program from $4.4 billion in FY 1998 to $4.7 billion in FY 1999. With these funds, the government anticipates serving an additional 30,000 to 36,000 children, raising the total number of children served annually to approximately 860,000.

Yet, in its five-year strategic plan submitted to Congress on September 30, 1997, Head Start's parent agency, the Department of Health and Human Services, was unable--after more than 30 years--to describe precisely what the program is supposed to accomplish.13 Worse, the agency's FY 1999 annual performance plan makes no mention of what American parents and taxpayers reasonably might expect in return for the $4.7 billion the Administration is asking them to give.14

The House Appropriations Committee bill proposes to fund a study by HHS, but this study--the Family and Child Experience Survey (FACES)--has serious methodological shortcomings.15 In June 1998, the GAO testified before Congress that "we are not convinced that [HHS] initiatives will provide definitive information on impact, that is, on whether children and their families would have achieved these gains without participating in Head Start."16 Thus, Congress also should require HHS to perform the following much-needed analyses:

  • Evaluate the differential effects of Head Start on participants' income as shown by its Survey of Income and Program Participation (SIPP).

  • Use the National Longitudinal Survey of Youth (NLSY)--which since 1988 has gathered data on children who attended Head Start--to study a wide range of outcomes, including cognitive, socio-emotional, behavioral, and academic development, while controlling for such factors as family background and the mother's IQ and level of education.

  • Employ the Survey of Program Dynamics, a new longitudinal survey required by the 1996 welfare reform act, to conduct an additional study of Head Start.

  • Mandate that the Survey of Program Dynamics be linked with the NLSY at least once by the use of a common performance test. This would enable greater generalization of NLSY Head Start data.

After 30 years and more than $30 billion, Congress would be wise to demand that HHS competently study and effectively demonstrate that the Head Start program produces results.

Goals 2000

Enacted in 1994, the Goals 2000: Educate America Act is expected to provide $491 million in FY 1998 to states and local districts. Under the program as recently amended, states and local school districts may apply to the U.S. Department of Education for funds to be applied to academic standards, model curricula, staff training, student assessments, technology, or magnet and charter schools.

Goals 2000 funding, however, duplicates other federal programs or pays the states to do what they already are doing. Moreover, states are paying the federal government at least 13 percent of the program money--$67 million of the $491 million in FY 1998--to maintain this duplicative federal bureaucracy.17

A 1994 survey by the Council of Chief State School Officers, conducted after the passage of Goals 2000, found that virtually all states had implemented or were formulating curriculum content and pupil performance standards. There is little evidence that any reforms currently are taking place that would not have been implemented if Goals 2000 had not been enacted.

Continued high levels of funding for Goals 2000 will only maintain and strengthen the federal government's control over local reform efforts and hamper grassroots reform initiatives. Washington does not need to pay the states to do what they already are doing and waste money on maintaining an unnecessary federal bureaucracy. Accordingly, the House Appropriations Committee has proposed significantly reduced funding for this program.

Eisenhower Professional Development Program

The Eisenhower Professional Development Program, funded at $335 million in FY 1998, provides grants to state and local education agencies, state agencies for higher education, institutions of higher education, and qualified nonprofit organizations to support professional development in core academic subjects.

While the Department of Education currently funds several professional programs, it "does not have an estimate of the amount expended for teacher professional development under these programs."18 It also does not keep records on funding provided for these purposes by other agencies, such as the National Aeronautics and Space Administration and the National Science Foundation.19 Despite this duplication and the lack of any clear demonstration of need, Congress has increased funding for the Eisenhower program steadily since 1992.

The Department of Education proposes to use some of the Eisenhower program's funding to support the National Board for Professional Teaching Standards, which administers a voluntary assessment and certification process based on national standards of excellence developed by the National Commission on Teaching and America's Future (NCTAF). The Department of Education has requested that funding for the Board's certification process be doubled to $5 million in FY 1999, arguing that this increase is needed to reach the NCTAF's goal of certifying 105,000 teachers by 2006.

However, a recent appraisal of NCTAF's goal by University of Missouri economists Dale Ballou and Michael Podgursky raises important questions about who really stands to benefit. Noting the close ties between teacher unions and the NCTAF, the authors point out that NCTAF has yet to prove whether the achievement of this goal, other than simply generating a larger number of teachers, actually will improve the quality of teaching in a way that demonstrably benefits children and whether it can accomplish this in a cost-effective way.20

The House Appropriations Committee has proposed reduced funding for this program. States should be allowed to use funds for professional development as they deem appropriate. For example, state and local education agencies should have the freedom to use federal funds for scholarships to encourage teachers to study core subjects at area universities and community colleges.

Federal Regional Education Laboratories21

The regional education laboratories have been around for more than 32 years and have received over $750 million in federal funding. Although the ten regional laboratories seem to be doing interesting work, their impact on education reform has been small; in some cases, their work may even have undermined efforts at reform. Among the many problems associated with the work of these labs are the following:

  • Evidence of waste and abuse has been reported by the Department of Education's own inspector general.

  • Research is of questionable quality and value. Nearly half of the states and districts that have had contact with regional labs have found them to be of little or no help in understanding or implementing comprehensive standards-based reform.22

  • A review of lab Internet sites indicates a lack of objectivity, with few details on free-market ideas or the many recent studies on school choice.

  • The labs tend to promote education fads at the expense of sound policy.23

The House Appropriations Committee bill takes a modest first step toward eliminating this redundant and ineffective program by refusing to increase program funding in FY 1999. Ultimately, the private sector, as well as other agencies, should be allowed to compete for funds targeted to the work of these labs, with funding based on individual projects.

Education research is best conducted by private and independent organizations that are funded based on their ability to translate research findings into successful methodology and practice. The sole determinant in deciding whether a program will be implemented in the schools should be an increase in academic scores, not how much the educational bureaucracy or lobbyists may like the program.

PROGRAMS IN NEED OF REFORM

Bilingual Education24

The House Appropriations Committee bill contains several measures designed to improve the education of Limited English-Proficient (LEP) students. Research and evaluation on methods of second language instruction have been inconclusive at best.

In 1997, the Department of Education and several independent foundations evaluated the available research on English language instruction. One of the reports concluded that nearly $100 million and 30 years of research and evaluation had yielded scant results in terms of classroom achievement.25 Not surprisingly, the Department of Education's FY 1999 annual performance plan fails to include the measurements it will use to determine what, if anything, the program actually accomplishes.26

The Department of Education has been inattentive to the results of its own in-house research projects and has failed to build upon original research.27 For example, during a 1992 audit of Office of Bilingual Education research, a budget analyst from the Department of Education's Office of the Under Secretary discovered that, of the 91 research evaluations or studies funded with $47 million of Title VII appropriations from 1980 to 1991, 40 of the final reports had been discarded or lost. Of the remaining 51 studies available, just 29 were relevant to policy formation and only 12 were described as "large-scale policy-relevant studies."28

Before giving more money to bilingual education, Congress would be wise to:

  • Block grant to states all current federal funding for bilingual and immigrant education, giving states more flexibility develop ways to help their Limited English-Proficient students make the transition to English-language fluency while requiring that 90 percent of the grant go directly to classroom instruction.

  • Allow the local education agencies to select which method of English language instruction to use and secure parental consent before placing a child in the program. Parents would have the right to remove their child from the program at any time and would be able to select the method of English language instruction if more than one were offered.

  • Void all previous compliance agreements that mandate bilingual education between the Department of Education and districts receiving funds and prohibit the Office of Civil Rights from entering into any new compliance agreements until the Secretary sets new regulations.

The House Appropriations Committee takes several steps to give states more flexibility to design the best models for their students, while at the same time assuring that these students exit the program within two to four years. The bill requires the Secretary of Education to give priority to funding state grant proposals that focus on the most rapid transition to English.

Occupational Safety and Health Administration: Enforcement and Compliance Strategy

The Occupational Safety and Health Administration (OSHA) has been enforcing safety and health standards for 27 years. There are serious questions, however, as to whether it has improved worker safety.

Too often, OSHA pits the employer against the inspector, a model that fosters distrust and suspicion and flies in the face of true partnership efforts that are the key to worker safety. The threat of large fines for non-compliance, when millions of safety-conscious employers do not know how to comply, undermines the enhancement of worker safety and protection. OSHA should concentrate on working with employers who are concerned about worker safety and health and encouraging them voluntarily to seek expert advice on how to comply with OSHA's regulations. It also should provide adequate funding for its compliance assistance programs.

To this end, Congress passed, and the President signed on July 16, 1998, the OSHA Compliance Assistance Act (PL 105-197). This law codifies OSHA's consultation program, which provides states with funding to perform on-site consultations, as well as other education and training activities. Employers who voluntarily requested a consultation would be able to work with the state to correct any hazards and safety violations; only if they failed to correct hazards would enforcement authorities be notified. Employers who corrected hazards identified in the consultative visit would be exempt from subsequent "general schedule" inspections for one year.

Since the 1970s, Congress has allotted money for a small grant program--now codified by PL 105-197--under which state agencies provide these services to a limited number of small businesses. But this program has been chronically underfunded. In some states, employers requesting consultation assistance must wait more than one year, and sometimes two; this denies employees vital safety and health protections.

In addition, while overall funding for compliance assistance has increased in the past few years, nearly all of the increase has been kept in Washington. Among other problems, this federalizing of compliance assistance means that employers and employees in nearly half of the states do not receive any benefit from the funding.

Funds for federal enforcement activities should be redirected to consultation grants that go directly to states.29 The House Appropriations Committee's bill holds back a requested funding increase for FY 1999 and sends an important message to OSHA by shifting more of OSHA's funding away from enforcement programs and into compliance activities.

Occupational Safety and Health Administration:
Health and Safety Regulations

The FY 1999 House appropriations bill for OSHA sets aside $300,000 for the peer review of safety and health standards. Peer review is widely recognized in professional and academic circles, where it is viewed as a linchpin of quality assurance.

The Presidential/Congressional Commission on Risk Assessment and Risk Management has recognized the importance of peer review:

Peer review is an important and effective mechanism for evaluating the accuracy or appropriateness of technical data, observations, interpretations, and the scientific and economic aspects of regulatory decisions. Peer review should provide balanced, independent views. When used well, peer review can serve as a system of checks and balances for the technical aspects of the regulatory process.30

The peer review provision in the House Appropriations Committee bill, however, needs to define the kind of quality review that Congress has in mind. For peer review to be effective, it must be conducted through independent panels and expert bodies that are broadly representative and involve participants with relevant expertise. The peer review process should provide for the timely completion of the review and contain a balanced presentation of the weight of scientific evidence and all other considerations, including minority reports and an agency response to all significant peer review comments.

National Labor Relations Board:
Jurisdictional Thresholds

The House Appropriations Committee has included a provision in the Labor-HHS-Education appropriations bill that requires the National Labor Relations Board (NLRB) to adjust its jurisdictional thresholds for inflation.

The NLRB is the government agency designated to settle labor disputes between unions and management. Most of its jurisdictional thresholds were set in 1959 and are based on the gross receipts of a business. Labor disputes involving businesses below the threshold are subject to resolution in state courts rather than by the NLRB. The threshold for non-retail businesses is currently $50,000-$310,000 in 1997 dollars.

With no adjustment for inflation, businesses and the NLRB have been caught in "bracket creep." As inflation has increased since 1959, the NLRB has acquired jurisdiction over smaller and smaller businesses, needlessly increasing both its own and businesses' workloads. Congress never intended for businesses with as few as two employees to be covered by the NLRB, but up to 20 percent of the NLRB's workload now involves small businesses, and its budget has grown to $145 million.

The NLRB claims it cannot change its jurisdiction without an act of Congress. The corrective language in the appropriations bill does exactly that. By indexing jurisdiction to the rate of inflation, the NLRB once again will be able to focus on the larger businesses for which the law originally was written. At the same time, the corrective language continues the NLRB's current authority to adjudicate egregious cases below the thresholds and does nothing to alter the right of workers to organize or bargain collectively.

CONCLUSION

There is an old saying that the closest thing to immortality is a government program. But programs created to address problems the nation faced decades ago will not meet the needs of Americans in the 21st century. As Congress considers the FY 1999 Labor-HHS-Education appropriations bill, it should take steps to terminate such obsolete, redundant, and ineffective programs as School-to-Work, Goals 2000, and federal regional education laboratories (among others) and fundamentally reevaluate the goals, priorities, and results of these federal agencies.

--Mark Wilson is a former Labor Economist at The Heritage Foundation; Nina H. Shokraii is former Education Policy Analyst at The Heritage Foundation; and Angela Antonelli is the former Director of the Thomas A. Roe Institute for Economic Policy Studies at The Heritage Foundation.

Endnotes

1. The Government Performance and Results Act requires all agencies to submit to Congress strategic plans that outline their missions, goals, objectives, and performance measures. For more information on the Results Act and agency plans, see http://www.freedom.house.gov/results.

2. U.S. General Accounting Office, Information Crosswalk on 163 Employment Training Programs, GAO/HEHS-95-85FS, February 14, 1995. This group of 19 programs does not include many other programs that also provide services to youth.

3. Ibid.

4. "What's Working (and What's Not): A Summary of Research on the Economic Impacts of Employment and Training Programs," U.S. Department of Labor, January 1995.

5. U.S. Department of Labor, Employment and Training Administration, The National JTPA Study: Title II-A Impacts on Earnings and Employment at 18 Months, 1993.

6. Memorandum from Wayne Riddle, Specialist in Education Finance, Education and Public Welfare Division, Congressional Research Service, to the Honorable Joseph Pitts, April 28, 1998, p. CRS-4.

7. Alan Hershey, "Partners in Progress: Early Steps in Creating School-to-Work Systems," Mathematica Policy Research, Inc., April 1997.

8. The only method for evaluating training programs effectively is to conduct an experimental design study that randomly assigns individuals either to a treatment group that can receive services from the program under study or to a control group that cannot, and then evaluate the outcomes. See Orley Ashenfelter, "The Case for Evaluating Training Programs with Randomized Trials," Economics of Education Review, Vol. 6, No. 4 (1987).

9. Congressional Budget Office, Reducing the Deficit: Spending and Revenue Options, August 1996, p. 305.

10. For more information, see Nina H. Shokraii and Patrick F. Fagan, "After 33 Years and $30 Billion, Time to Find Out If Head Start Produces Results," Heritage Foundation Backgrounder No. 1202, July 15, 1998.

11. See U.S. General Accounting Office, Head Start: Participant Characteristics, Services, and Funding, GAO/HEHS-98-65, March 31, 1998, for detailed information on the populations that receive Head Start services, what types of services are delivered, and when and where such services are available.

12. U.S. General Accounting Office, Head Start: Research Provides Little Information on Impact of Current Program, GAO/HEHS-97-59, April 15, 1997, p. 4.

13. The Department of Health and Human Services' strategic plan can be found on the Internet at http://aspe.os.dhhs.gov/hhsplan. Of the 24 strategic plans graded by Congress, this plan ranked 13th with a failing grade of 43 out of a possible 100 points.

14. HHS's annual performance plan can be found at http://www.hhs.gov/progorg/fin/99perfpl.html. Of the 24 performance plans graded by Congress, this plan ranked 14th with a failing grade of 36.5 out of a possible 100 points.

15. GAO, Head Start: Research Provides Little Information on Impact of Current Program, p. 4.

16. Carlotta Joyner, "Challenges Faced in Demonstrating Program Results and Responding to Societal Changes," testimony before the Subcommittee on Early Childhood, Youth and Families, Committee on Education and the Workforce, U.S. House of Representatives, 105th Cong., 2nd session, GAO/T-HEHS-98-183, June 9, 1998.

17. Memorandum from Wayne Riddle, Specialist in Education Finance, Education and Public Welfare Division, Congressional Research Service, to the Honorable Joseph Pitts, April 28, 1998, p. CRS-4.

18. Departments of Labor, Health and Human Services, Education and Related Agencies Appropriation Bill, 1997, Report No. 104-659, Committee on Appropriations, U.S. House of Representatives, 104th Cong., 2nd Sess., July 8, 1996, p. 132.

19. Ibid.

20. Dale Ballou and Michael Podgursky, "Reforming Teacher Training and Recruitment: A Critical Appraisal of the Recommendations of the National Commission on Teaching and America's Future," Government Union Review, Vol. 17, No. 4 (November 1997), p. 43.

21. For more information, see Nina H. Shokraii, "Why Congress Should Overhaul the Federal Regional Education Laboratories," Heritage Foundation Backgrounder No. 1200, July 2, 1998.

22. Nancy Kober, From Promise to Practice: Stories from the Regional Education Laboratories, U.S. Department of Education, Office of Educational Research and Improvement, September 1996. See http://www.ed.gov/prog_info/Labs/Promise/overview.html.

23. See http://www.ed.gov/prog_info/Labs/Profiles/nwrel.html.

24. For more information, see Nina H. Shokraii and Sarah E. Youssef, "What Congress Can Do to Help Limited English-Proficient Children Learn English," Heritage Foundation Backgrounder No. 1206, July 23, 1998.

25. Charles Glenn, A Review of the National Research Council Study: Improving Schooling for Language Minority Children: A Research Agenda (Amherst, Mass.: Institute for Research in English Acquisition and Development, May 1997), p. 2.

26. U.S. Department of Education, FY 1999 Plan, Vol. 2, Program Performance Plans, February 25, 1998. Available at http://www.ed.gov/PDFDocs/apvol2.pdf.

27. Ibid., p. 315.

28. Ibid.

29. House appropriators have redirected $5.6 million from federal enforcement activities to state consultation grants in the Labor-HHS-Education appropriations bill. Even with this reallocation of resources, however, total spending on federal and state enforcement activities will still be 6.4 percent higher than 1996.

30. Presidential/Congressional Commission on Risk Assessment and Risk Management, Risk Assessment and Risk Management in Regulatory Decision-Making, Vol. 2, 1997, p. 103. Available on the Internet at http://www.riskworld.com/Nreports/1997/risk-rpt/volume2/html/v2epaa.htm.