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Field Notes · Issue 016

“Spillover Effects of Regulatory Inspections: Evidence from OSHA” by Matthew S. Johnson, David I. Levine and Michael W. Toffel, NBER Working Paper 35646 and Harvard Business School Working Paper 27-014, released September 2026

September 14 to 18, 2026

Every piece this week dealt with a number nobody had looked underneath, from a manufacturing productivity ratio held up by shrinking hours to a pilot readout taken before the tool had settled in. The Field Note adds a study of workplace safety inspections whose biggest payoff landed at sites nobody inspected, where the obvious measurement found essentially nothing.

Field Notes: September 19, 2026
This week's reading
Update
September 13, 2026

Take Care of It, Please

The Assessment in Issue 014 was about Chuck Smith, the band director who lent me his own trombone in 1991. I went to his celebration of life on September 13, and his trombone case was the first thing on display when I walked in. I also learned I was not the only student he lent it to. I added a short update to the piece, with a photo, and if you read the original it is worth the two minutes.

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The Field Note

The week, read against the grain

“Spillover Effects of Regulatory Inspections: Evidence from OSHA” by Matthew S. Johnson, David I. Levine and Michael W. Toffel, NBER Working Paper 35646 and Harvard Business School Working Paper 27-014, released September 2026

The Occupational Safety and Health Administration long kept a yearly list of roughly 3,500 workplaces reporting the highest injury rates, and on the lists from 2001 to 2010, whether a workplace landed just above or just below the line was close to chance. A paper by Matthew Johnson, David Levine and Michael Toffel, released this month, uses that line to ask what an inspection did for the workplaces nobody walked into. The Labor Department, which houses OSHA, helped fund it.

Quite a lot. One inspection cut injuries serious enough to keep someone off work by about 11 percent at other establishments in the same ZIP code, averaged over the next four years. That comes to roughly three fewer of those injuries a year across the neighbors. Against their earlier estimate of about half an injury a year at the inspected site, the authors put the spillover at several times the direct effect.

The obvious comparison, workplaces with more inspected neighbors against those with fewer, finds essentially nothing. The authors trace that to inspections going where injury rates were unusually high, plausibly because of local conditions the neighbors shared.

The scribe study earlier this week had the same shape, since its first reading undercounted what the tool would give back. I think this is the costlier kind of mistake, because an audit judged only by what changed where it looked will read as overhead the first time somebody hunts for savings. The authors do not test why the neighbors improved; one candidate they list is managers expecting to be next. My bet is that a good share of what an audit function accomplishes works that way.

The inspections are at least fifteen years old, so I would not carry the exact ratio into a budget meeting. I would carry the direction.

When you last weighed an audit or review function, did anyone measure what it changed in the teams it never visited?
Sources
  1. Johnson, M. S., Levine, D. I., & Toffel, M. W. (2026). Spillover effects of regulatory inspections: Evidence from OSHA (NBER Working Paper No. 35646). National Bureau of Economic Research. (Working paper, not peer reviewed; NBER lists an August 2026 issue date and posted it in September 2026. Uses the injury-rate cutoff for OSHA's Site-Specific Targeting inspection list, 2001 to 2010 target lists, to estimate effects of inspections on neighboring establishments. Supported by the U.S. Department of Labor's DOL Scholars Program, part of the department that houses OSHA, and funded in part by Harvard Business School; OSHA supplied the injury data and target lists under a memorandum of understanding.) https://www.nber.org/papers/w35646
  2. Johnson, M. S., Levine, D. I., & Toffel, M. W. (2026). Spillover effects of regulatory inspections: Evidence from OSHA (Harvard Business School Working Paper No. 27-014). Harvard Business School. (Version dated September 10, 2026, the full text read for this issue; its abstract matches the NBER release. The direct effect at the inspected establishment, 0.48 fewer annual injuries, is the authors' estimate from their earlier study in American Economic Journal: Applied Economics, 2023.) https://www.hbs.edu/faculty/Pages/download.aspx?name=27-014.pdf
High Road Conversations
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High Road Conversations

Michael J. Pope was twenty, sitting in the front row at his grandfather's funeral in 1994, when the floor was opened to anyone who wanted to share remarks, and he stayed in his seat and listened to other people say the things he had meant to say. He calls it one of his greatest blessings now, because it eventually led him to Toastmasters, where his first speech went to a room of maybe ten or twelve people and, in his words, “those 4 minutes felt like 4 hours.” On High Road Conversations he talks with Evangeline Pescasio and me about what hesitation has cost him and the unglamorous habits he built to stop doing it.

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Lunch and Build
Skool
Lunch and Build

I don't just talk about Agile and leadership, I put it into practice in my Skool, building and shipping real products with Claude every Thursday at 12:30pm EST.

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From the book
Agile Sucks!

Most of this week's pieces turned on a number that looked like progress, and James Wright and I took on that trap in a section of Agile Sucks! (When You Do It Wrong) called Outcome Over Output. Our line there is that “not everything that’s counted counts,” and that a team can “ship every story, close every ticket, and hit every KPI” and still miss the point. It includes a test you can run this week: look at your last two weeks of effort and ask whether you can point to how it moved the company closer to its stated objectives.

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