Over the last few decades, officials in environmental, health, and safety agencies at the federal
and state levels have tried to promote public health protection through voluntary programs
designed to encourage effective safety and environmental management by recognizing qualifying
businesses as high-performing leaders. Multiple sources of evidence from two flagship
voluntary programs—the Environmental Protection Agency’s National Environmental Performance
Track and the Occupational Safety and Health Administration’s Voluntary Protection
Programs—are used in this paper to address two main questions: (1) Do such programs promote
exemplary environmental and safety leadership as they purport to do, or are they instead
promoting more of a type of “public relations”? (2) Can these programs scale up to a level that
would make them a potentially significant alternative form of governance? We conclude that
neither of these programs in practice live up to their designs nor constitute viable alternative
strategies to public regulation.
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