Public Information Systems
Perhaps the most promising possibility for government action suggested by this study is an information strategy. The government has a clear comparative advantage in generating two types of information particularly important to setting safety standards: applied research and feedback on real-world experience. The private sector is lacking in its capacity to generate such information. Government overcomes the "free rider" problem that plagues private efforts to produce so-called public goods. Government is also the only avenue for collecting vital information such as medical records that are otherwise protected by privacy laws.
The potential for influencing private standards-setting with information about real-world experience is significant. The private sector has demonstrated its willingness to alter standards in light of relevant information. A former CPSC voluntary standards coordinator cites numerous examples where the private sector responded to public information. Liability law also helps provide an incentive for the private sector to respond to injury information. Unfortunately, it also provides a countervailing incentive against collecting it. What you know can hurt you. In any case, the incentive to respond depends on the quality of information. Industry feels no need to respond to many of the existing CPSC data because they are so clearly inadequate.
Perhaps the most influential government organization involved in collecting information is the National Transportation Safety Board. The NTSB has no decisionmaking power, but its recommendations carry considerable weight. The NTSB was split off from the FAA "so that the same person … was not both promulgating civil air regulations and investigating the accidents they might cause." Avoiding this "conflict of interest," whether real or imaginary, seems to have bolstered the NTSB's clout. The FAA adopts many NTSB recommendations in short
order. Others are eventually adopted under pressure from members of Congress who use these authoritative recommendations to register support for the popular cause of aviation safety. "Without the NTSB," muses a lobbyist for the Association of Flight Attendants, "the FAA could turn all of these issues into technical mush." Devoting a specific organization to the collection and analysis of injury data would probably improve standards-setting in other areas as well.
Government could also exert a more positive influence on private standards-setting by doing more applied research. Most private standards-setting organizations would gladly replace various "engineering judgments" with decisions based more on science—so long as someone else shoulders the research costs. Voluntary associations such as NFPA do almost no applied research; they do not have the resources. Testing labs occasionally conduct such research, but seldom in connection with a single standard. Perhaps the best policy for government is to increase funding for the National Bureau of Standards. Not only does NBS have the necessary technical capability and reputation to conduct useful research and development, but it offers the right institutional setting for developing an intelligent research strategy. The cases demonstrate that prolonged NBS involvement can help improve private standards. The agency combined its technical knowledge and reputation to bring about beneficial changes in NFPA 211 and ANSI/AGA Z21.11.2. "Engineering needs a loyal opposition," argues Edwin Layton in a prominent book on the profession. Engineers face issues that are technical and political, in an organizational context that profoundly shapes personal incentives. They can best be kept in check by other engineers with the technical knowledge and institutional independence to challenge them. The National Bureau of Standards (now the National Institute of Standards and Technology) fits the bill, although its budget is still minuscule compared to its potential agenda.