The Occupational Safety and Health Act is the primary federal law which governs occupational health and safety in the private sector and federal government in the United States. It was enacted by Congress in 1970 and was signed by President Richard Nixon on December 29, 1970. Its main goal is to ensure that employers provide employees with an environment free from recognized hazards, such as exposure to toxic chemicals, excessive noise levels, mechanical dangers, heat or cold stress, or unsanitary conditions. The Act created the Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Heal th (NIOSH).

The Act can be found in the United States Code at title 29, chapter 15.

History of federal workplace safety legislation

Efforts by the federal government to ensure workplace health and safety were minimal until the passage of OSHA. The American system of mass production encouraged the use of machinery, while the statutory regime did nothing to protect workplace safety. For most employers, it was cheaper to replace a dead or injured worker than it was to introduce safety measures. Tort law provided little recourse for relief for the survivors of dead workers or for injured employees. After the Civil War, some improvements were made through the establishment of state railroad and factory commissions, the adoption of new technology (such as the railway air brake), and more widespread availability of life insurance. But the overall impact of these improvements was minimal.

The first federal safety legislation was enacted in the Progressive period. In 1893, Congress passed the Safety Appliance Act, the first federal statute to require safety equipment in the workplace (the law applied only to railroad equipment, however). In 1910, in response to a series of highly publicized and deadly mine explosions and collapses, Congress established the United States Bureau of Mines to conduct research into mine safety (although the Bureau had no authority to regulate mine safety). Backed by trade unions, many states also enacted workers' compensation laws which discouraged employers from permitting unsafe workplaces. These laws, as well as the growing power of labor unions and public anger toward poor workplace safety, led to significant reductions in worker accidents for a time.

Industrial production increased significantly in the United States during World War II, and industrial accidents soared. Winning the war took precedence over safety, and most labor unions were more concerned with maintaining wages in the face of severe inflation than with workplace health and safety. After the war ended, however, workplace accident rates remained high and began to rise. In the two years preceding OSHA's enactment, 14,000 workers died each year from workplace hazards, and another 2 million were disabled or harmed. Additionally, the "chemical revolution" introduced a vast array of new chemical compounds to the manufacturing environment. The health effects of these chemicals were poorly understood, and workers received few protections against prolonged or high levels of exposure. While a few states, such as California and New York, had enacted workplace safety as well as workplace health legislation, most states had not changed their workplace protect ion laws since the turn of the century.

Passage

In the mid-1960s, growing awareness of the environmental impact of many chemicals had led to a politically powerful environmental movement. Some labor leaders seized on the public's growing unease over chemicals in the environment, arguing that the effect of these compounds on worker health was even worse than the low-level exposure plants and animals received in the wild. On January 23, 1968, President Lyndon B. Johnson submitted a comprehensive occupational health and safety bill to Congress. Led by the United States Chamber of Commerce and the National Association of Manufacturers, the legislation was widely opposed by business. Many labor leaders, including the leadership of the AFL-CIO, did not fight for the legislation, claiming workers had little interest in the bill. The legislation died in committee.

On April 14, 1969, President Richard Nixon introduced two bills into Congress which would have also protected worker health and safety. The Nixon legislation was much less prescriptive than the Johnson bill, and workplace health and safety regulation would be advisory rather than mandatory. However, Representative James G. O'Hara and Senator Harrison A. Williams introduced a much stricter bill similar to the Johnson legislation of the year before.

Companion legislation introduced in the House also imposed an all-purpose "general duty" clause on the enforcing agency as well. With the stricter approach of the Democratic bill apparently favored by a majority of both chambers, and unions now strongly supporting a bill, Republicans introduced a new, competing bill. The compromise bill established the independent research and standard-setting board favored by Nixon, while creating a new enforcement agency. The compromise bill also gave the Department of Labor the power to litigate on the enforcement agency's behalf (as in the Democratic bill). In November 1970, both chambers acted: The House passed the Republican compromise bill, while the Senate passed the stricter Democratic bill (which now included the general duty clause).

A conference committee considered the final bill in early December 1970. Union leaders pressured members of the conference committee to place the standard-setting function in the Department of Labor rather than an independent board. In return, unions agreed to let an independent review commission have veto power over enforcement actions. Unions also agreed to removal of a provision in the legislation which would have let the Secretary of Labor shut down plants or stop manufacturing procedures which put workers in "imminent danger" of harm. In exchange for a Republican proposal to establish an independent occupational health and safety research agency, Democrats won inclusion of the "general duty" clause and the right for union representatives to accompany a federal inspector during inspections. The conference committee bill passed both chambers on December 17, 1970, and President Nixon signed the bill on December 29, 1970. According to the New York Times, labor and environment act ivist Tony Mazzocchi was a "principal force behind the legislation".

The Act went into effect on April 28, 1971 (now celebrated as Workers' Memorial Day by American labor unions).

Description

In passing the Act, Congress declared its intent "to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources."

The Act created the Occupational Safety and Health Administration (OSHA), an agency of the Department of Labor. OSHA was given the authority both to set and enforce workplace health and safety standards. The Act also created the independent Occupational Safety and Health Review Commission to review enforcement priorities, actions and cases.

The Act also established the National Institute for Occupational Safety and Health (NIOSH), an independent research institute in the then Department of Health, Education & Welfare now under-Centers for Disease Control and Prevention.

The Act defines an employer to be any "person engaged in a business affecting commerce who has employees, but does not include the United States or any state or political subdivision of a State." The Act applies to employers as diverse as manufacturers, construction companies, law firms, hospitals, charities, labor unions and private schools.

Churches and other religious organizations are covered if they employ workers for secular purposes. The Act excludes the self-employed, family farms, workplaces covered by other federal laws (such as mining, nuclear weapons manufacture, railroads and airlines) and state and local governments (unless state law permits otherwise). The Act covers federal agencies and the United States Postal Service.

Section 5 of the Act contains the "general duty clause." The "general duty clause" requires employers to 1) Maintain conditions or adopt practices reasonably necessary and appropriate to protect workers on the job; 2) Be familiar with and comply with standards applicable to their establishments; and 3) Ensure that employees have and use personal protective equipment when required for safety and health. OSHA has established regulations for when it may act under the "general duty clause." The four criteria are 1) There must be a hazard; 2) The hazard must be a recognized hazard (e.g., the employer knew or should have known about the hazard, the hazard is obvious, or the hazard is a recognized one within the industry); 3) The hazard could cause or is likely to cause serious harm or death; and 4) The hazard must be correctable (OSHA recognizes not all hazards are correctable).

Although theoretically a powerful tool against workplace hazards, it is difficult to meet all four criteria. Therefore, OSHA has engaged in extensive regulatory rule-making to meet its obligations under the law.

Due to the difficulty of the rule-making process (which is governed by the Administrative Procedures Act), OSHA has focused on basic mechanical and chemical hazards rather than procedures. Major areas which its standards currently cover are: Toxic substances, harmful physical agents, electrical hazards, fall hazards, hazards associated with trenches and digging, hazardous waste, infectious disease, fire and explosion dangers, dangerous atmospheres, machine hazards, and confined spaces.

Section 8 of the Act covers reporting requirements. All employers must report to OSHA within eight hours if an employee dies from a work-related incident, or three or more employees are hospitalized as a result of a work-related incident. Additionally, all fatal on-the-job heart attacks must also be reported. Section 8 permits OSHA inspectors to enter, inspect and investigate, during regular working hours, any workplace covered by the Act. Employers must also communicate with employees about hazards in the workplace. By regulation, OSHA requires that employers keep a record of every non-consumer chemical product used in the workplace. Detailed technical bulletins called material safety data sheets (MSDSs) must be posted and available for employees to read and use to avoid chemical hazards. OSHA also requires employers to report on every injury or job-related illness requiring medical treatment (other than first aid) on OSHA Form 300, "Log of Work-Related Injuries and Illnesses" (k nown as an "OSHA Log" or "Form 300"). An annual summary is also required and must be posted for three months, and records must be kept for at least five years.

Section 11(c) of the Act prohibits any employer from discharging, retaliating or discriminating against any employee because the worker has exercised rights under the Act. These rights include complaining to OSHA and seeking an OSHA inspection, participating in an OSHA inspection, and participating or testifying in any proceeding related to an OSHA inspection.

Section 18 of the Act permits and encourages states to adopt their own occupational safety and health plans, so long as the state standards and enforcement "are or will be at least as effective in providing safe and healthful employment" as the federal OSH Act. States that have such plans are known as "OSHA States." As of 2007, 22 states and territories operated complete plans and four others had plans that covered only the public sector.

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The Food Safety Modernization Act (FSMA) was signed into law by President Barack Obama on January 4, 2011. The FSMA has given the Food and Drug Administration (FDA) new authorities to regulate the way foods are grown, harvested and processed. The law grants the FDA a number of new powers, including mandatory recall authority, which the agency has sought for many years. The FSMA requires the FDA to undertake more than a dozen rulemakings and issue at least 10 guidance documents, as well as a host of reports, plans, strategies, standards, notices, and other tasks.

The law was prompted after many reported incidents of foodborne illnesses during the first decade of the 2000s. Tainted food has cost the food industry billions of dollars in recalls, lost sales and legal expenses.

This bill is similar to the Food Safety Enhancement Act which passed the House in 2009. It is considered the first major piece of federal legislation addressing food safety since 1938. It is also the first piece of legislation to address intentional adulteration and Food Defense.

Background

The Center for Disease Control and Prevention (CDC) estimated in 2011 that each year 48 million people (1 in 6 Americans) get sick, 128,000 are hospitalized, and 3,000 die of foodborne diseases. The CDC estimates that there are two major groups of foodborne illnesses: Known foodborne pathogens and Unspecified agents. 31 pathogens are notorious for causing foodborne illness. Unspecified agents have insufficient data to estimate with certainty the agent-specific burden. Known agents that have not been identified as causing foodborne illness include microbes, chemicals, or other substance known to be in food. The ability for these known agents to cause illness has not been proven so they remain unidentified. Considering the fact that, about 30% of the population is at risk for food borne sicknesses, over 14% of food supply to the United States is imported from other countries, and also new and more food items are becoming more complex or intricate, the FSMA was indeed needed. The FD A Food Safety Modernization Act (FSMA), enables FDA to better protect public health by strengthening the food safety system. It enables the FDA to focus more on preventing food safety problems rather than relying primarily on reacting to problems after they occur.

Over the past few years, high-profile outbreaks related to various foods, from spinach and peanut products to eggs, have underscored the need to make continuous improvements in food safety. Under this law the FDA will be allowed to mandate a system that is based on science and addresses the hazards from farm to table. This means that the FDA has the power to oversee how foods are produced and how they are maintained in food markets. This puts greater emphasis on preventing food-borne illness. The reasoning is simple: The better the system handles producing, processing, transporting, and preparing foods, the safer our food supply will be.

Under the new law, the FDA will now have new prevention-focused tools and a clear regulatory framework to help make substantial improvements in their approach to food safety. For example, for the first time, the FDA has a legislative mandate to require comprehensive, preventive-based controls across the food supply chain. Preventive controls include steps that a food facility would take to prevent or significantly minimize the likelihood of problems occurring. The new law also significantly enhances the FDA’s ability to achieve greater oversight of the millions of food products coming into the United States from other countries each year.

Legislative history

The events of Sep 11, 2001 reinforced the need to enhance the security of the United States. Congress responded by passing the Public Health Security and Bioterrorism Preparedness Response Act, 'the Bioterrorism Act', which President Bush signed into law June 12, 2002. The Bioterrorism Act of 2002 granted the FDA administrative detention authority over food items if there is credible evidence or information that indicates the food presents a threat of serious adverse health consequences or death to humans or animals. The new (FSMA) law broadens that authority, allowing for administrative detention based on ‘reason to believe’ that the food item has been misbranded or adulterated’ and thus violates a legal standard for the product.

The first version of the law, the Food Safety Enhancement Act, passed the House on June 9, 2009. However, negotiations with the Senate led to the final product, the 'Food Safety and Modernization Act.' The bill was passed by the Senate in November 2010 by a vote of 73â€"25. However, because of a tax provision added to the bill, (which is constitutionally required to begin in the House), the vote did not count. There was concern that with the short time left in the lame-duck session, the bill would not get the time needed to be voted on and passed. Attempts to add the bill to the continuing resolution for government funding were scrapped over the objection of Senator Tom Coburn. Eventually, however, the Senate moved on December 19, 2010 to pass the fixed bill by unanimous consent by a voice vote. The House went on to approve the bill by a vote of 215 to 144 on December 21, 2010. President Barack Obama signed the bill into law on Tuesday, January 4, 2011.

Although this bill is meant to address food safety, there are, according to food safety advocate Bill Marler, some issues with its effectiveness. Many facilities, such as farms, restaurants, and nonprofit food establishments in which food is prepared for or served directly to the consumer are exempt from the requirements of the bill. Also exempt are facilities that produce food solely for non-human animals.

Tester-Hagan Amendment

Senators Jon Tester and Kay Hagan sponsored two amendments that removed vital local food growers and processors from federal oversight, leaving themâ€"as they currently areâ€"within the existing regulatory framework of state and local health and sanitation laws and rules.

The amendment will offer protections for operations (a.k.a. “qualified facilities”) that make less than $500,000 a year and sell most (greater than 50%) of their products directly to consumers in the same state and within a 400-mile radius. The amendment also applies to all operations that the FDA classified as a "very small business." Small, local farmers would not necessarily need to comply with some of the requirements and produce safety regulations implemented under S. 510. Instead, these small-scale producers (like those who sell their goods at farmers' markets or roadside stands) would continue to be regulated by local and state entities. In addition, consumers would know whom they are buying from either by direct sales or clear labeling.

Farmers who qualify must provide documentation that the farm is in compliance with state regulations. Documentation may include licenses, inspection reports, or other evidence that the farm is in compliance with State, local, county, or other applicable non-Federal food safety law. The farm must also prominently and conspicuously display the name and address of farm/facility on its label. For foods without a label then by poster, sign, or placard, at the point of purchase or, in the case of Internet sales, in an electronic notice, or in the case of sales to stores and restaurants, on the invoice.

Provisions

Impact and fees

The legislation affects every aspect of the U.S. food system, from farmers to manufacturers to importers. It places significant responsibilities on farmers and food processors to prevent contaminationâ€"a departure from the country's reactive tradition, which has relied on government inspectors to catch tainted food after the fact The legislation requires food producers and importers to pay an annual $500 registration fee, which would help fund stepped-up FDA inspections, enforcement and related activities such as food-safety research About 360,000 facilities in the United States and abroad would be subject to the fees. The Congressional Budget Office reported that the fees would not cover the cost of the new system, leaving the FDA to incur a net cost of $2.2 billion over five years.

Prevention

For the first time, the FDA will have a legislative mandate to require comprehensive, science-based preventive controls across the food supply, including pet food and animal feed.

• Mandatory preventive controls for food facilities

Food facilities are required to implement a written Hazard Analysis and Risk-based Preventive Controls (HARPC) plan. This involves: (1) evaluating the hazards that could affect food safety, (2) specifying what preventive steps, or controls, will be put in place to significantly minimize or prevent the hazards, (3) specifying how the facility will monitor these controls to ensure they are working, (4) maintaining routine records of the monitoring, and (5) specifying what actions the facility will take to correct problems that arise. Animal food manufacturers must implement current Good Manufacturing Practices and Preventive Controls.(Final rule published September 17, 2015)

• Mandatory produce safety standards

The FDA must establish science-based, minimum standards for the safe production and harvesting of fruits and vegetables. Those standards must consider naturally occurring hazards, as well as those that may be introduced either unintentionally or intentionally, and must address soil amendments (materials added to the soil such as compost), hygiene, packaging, temperature controls, animals in the growing area and water. (Final regulation due about 2 years following enactment)

• Radiological hazards

For the first time, firms must explicitly consider radioactive contamination as part of their hazard analysis, under chemical safety. The FDA does not anticipate that this will be a hazard that requires continuous monitoring with a Geiger counter. Rather, as an example, a firm that uses spring water in its products should consider having the water tested regularly for the presence of dissolved radon, tritium and heavy metal contaminants.

• Authority to prevent intentional contamination

The FDA must issue regulations to protect against the intentional adulteration of food, including the establishment of science-based mitigation strategies to prepare and protect the food supply chain at specific vulnerable points. (Final rule due 18 months following enactment) This is the first time language involving Food Defense has been incorporated into law.

Inspection and compliance

The FSMA recognizes that preventive control standards improve food safety only to the extent that producers and processors comply with them. FSMA provides the FDA with new authority to conduct inspections and ensure compliance.

• Mandated inspection frequency

The FSMA establishes a mandated inspection frequency, based on risk, for food facilities and requires the frequency of inspection to increase immediately. All high-risk domestic facilities must be inspected within five years of enactment and no less than every three years thereafter. Within one year of enactment, the law directs the FDA to inspect at least 600 foreign facilities and double those inspections every year for the next five years. To accomplish this projected goal, the USFDA and other agencies in the United States will work in partnership or collaborate with foreign governing bodies for help, due to lack of resources to meet the demand.

• Records access

FDA will have access to records, including industry food safety plans and the records firms will be required to keep documenting implementation of their plans.

• Testing by accredited laboratories

The FSMA requires certain food testing to be carried out by accredited laboratories and directs the FDA to establish a program for laboratory accreditation to ensure that U.S. food testing laboratories meet high- quality standards. (Establishment of accreditation program due 2 years after enactment)

Response to contaminants/violations

The bill gives the FDA the authority to recall food in the case of contamination or illness. In addition, it requires farms to track their food and implement plans to deal with recalls or outbreaks of disease. FDA officials will also be given access to food growers records in the case of an outbreak. The bill also requires food importers to verify that they meet US food safety standards. Small farms that sell locally or sell less than $500,000 a year are exempt from these new rules. New authorities include:

• Mandatory recall

The FSMA provides the FDA with authority to issue a mandatory recall when a company fails to voluntarily recall unsafe food after being asked to by the FDA.

• Expanded administrative detention

The FSMA provides the FDA with a more flexible standard for administratively detaining products that are potentially in violation of the law (administrative detention is the procedure the FDA uses to keep suspect food from being moved).

• Suspension of registration

The FDA can suspend registration of a facility if it determines that the food poses a reasonable probability of serious adverse health consequences or death. A facility that is under suspension is prohibited from distributing food. (Effective 6 months after enactment)

• Enhanced product tracing abilities

The FDA is directed to establish a system that will enhance its ability to track and trace both domestic and imported foods. In addition, FDA is directed to establish pilot projects to explore and evaluate methods to rapidly and effectively identify recipients of food to prevent or control a food borne illness outbreak. (Implementation of pilots due 9 months after enactment)

• Additional Record keeping for High Risk Foods

The FDA is directed to issue proposed rule making to establish record keeping requirements for facilities that manufacture, process, pack, or hold foods that the Secretary designates as high-risk foods. (Implementation due 2 years after enactment).

Additional information on imported goods

The FSMA gives the FDA authority to better ensure that imported products meet U.S. standards and are safe for U.S. consumers, with the vision that imported foods should be held to the same standards as domestic foods. These standards will be met by implementing the following components:

• Importer accountability

For the first time, importers have an explicit responsibility to verify that their foreign suppliers have adequate preventive controls in place to ensure that the food they produce is safe. (Final regulation and guidance due 1 year following enactment)

• Third Party Certification

The FSMA establishes a program through which qualified third parties can certify that foreign food facilities comply with U.S. food safety standards. This certification may be used to facilitate the entry of imports. (Establishment of a system for the FDA to recognize accreditation bodies is due 2 years after enactment)

• Certification for high risk foods

The FDA has the authority to require that high-risk imported foods be accompanied by a credible third party certification or other assurance of compliance as a condition of entry into the U.S.

• Voluntary qualified importer program

The FDA must establish a voluntary program for importers that provides for expedited review and entry of foods from participating importers. Eligibility is limited to, among other things, importers offering food from certified facilities. (Implementation due 18 months after enactment)

• Authority to deny entry

The FDA can refuse entry into the U.S. of food from a foreign facility if the FDA is denied access by the facility or the country in which the facility is located.

Enhanced partnerships

The FSMA builds a formal system of collaboration with other government agencies, both domestic and foreign. In doing so, the statute explicitly recognizes that all food safety agencies need to work together in an integrated way to achieve our public health goals. The following are examples of enhanced collaboration:

• State and local capacity building

The FDA must develop and implement strategies to leverage and enhance the food safety and defense capacities of State and local agencies. The FSMA provides the FDA with a new multi-year grant mechanism to facilitate investment in State capacity to more efficiently achieve national food safety goals.

• Foreign capacity building

The law directs the FDA to develop a comprehensive plan to expand the capacity of foreign governments and their industries. One component of the plan is to address training of foreign governments and food producers on U.S. food safety requirements.

• Reliance on inspections by other agencies

The FDA is explicitly authorized to rely on inspections of other Federal, State and local agencies to meet its increased inspection mandate for domestic facilities. The FSMA also allows the FDA to enter into inter-agency agreements to leverage resources with respect to the inspection of seafood facilities, both domestic and foreign, as well as seafood imports.

Employee protections

The FSMA also includes provisions that protect employees who try to prevent food safety problems. Section 402 of the FSMA prohibits employers engaged in the manufacture, processing, packing, transporting, distribution, reception, holding or importation of food from retaliating against employees who disclose violations of the Federal Food, Drug, and Cosmetic Act. This particular portion of the FSMA is administered by the U.S. Department of Labor.

Implementation

Now that the Act is in place, the FDA must begin the rulemaking process to codify how they intend to enforce the new laws.

Effective June 12, 2011, many food companies will be required to develop food safety plans based on an evaluation of hazards related to food manufactured, processed, packed or held in all registered facilities. Following a hazard analysis, firms must identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards. Examples of preventive controls include sanitation procedures for food contact surfaces; employee hygiene training; environmental monitoring to verify pathogen controls; a recall plan; supplier verification activities; and a food allergen control program.

Even after the rulemaking process is complete, it will likely be some time before the FDA is fully equipped to enforce the new laws. The agency estimates that it will need at least 1,000 more inspectors and $1.4 billion over the next five years, and it is certainly not a sure thing that Congress will appropriate such funds given the current economic climate and calls for spending cuts and smaller government.

Rules

The first public comment period occurred in 2013, and the agency received tens of thousands of comments in that period. The FDA previously submitted their proposed regulations to the Office of Management and Budget (OMB) for review, and in that process the OMB weakened the regulations in a variety of ways.

In 2012, the FDA was sued by consumer groups the Center for Food Safety (CFS) and the Center for Environmental Health for its failure to meet deadlines. In settling the litigation, the agency agreed to deadlines in 2015 and 2016 for certain rules.

FSMA progress report

Now, the FDA has planned to make available to the general public and to Congress significant progress they have made towards implementing the FSMA. In March 2012, the FDA’s Senior Advisor, Coordinated Outbreak Response and Evaluation Network, Sherri McGarry, on a blog reported the types of foods to be used in the pilot project on tracing products to prevent illnesses. The list includes Tomatoes, Frozen Kung Pao-style dishes, and Jarred peanut butter and dry, packaged peanut/spice. Tomatoes both sliced and whole was chosen because of the significant number of outbreaks recorded; it mirrors a multifaceted food supply chain and it was recognized by majority of the food industry associations as the number one food product to be used in the pilot program.

The Frozen Kung Pao-style dishes have ingredients such as chicken, red pepper spice and peanut products which are foods that are involved in outbreaks, for this reason they are in the pilot project. In addition, it is supplied to diverse food chain distribution channels which could be involved in imported and domestic products. To increase the intricacy of the pilot project, the jarred peanut butter and dry, packaged spice peanut were included. This summer, the pilot projects results will be accomplished with hopes of developing a complete product tracing system with the information received.

Funding

The Safety Act was signed into law along with the Government Performance and Results Modernization Act of 2010. The cost for the first five years is projected to be $1.4 billion and is not yet fully funded.

Food facility registration

Since October 22, 2012, the updated food facility registration system by the US FDA is available. This update requires all facilities previously registered prior to October 1, 2012 to renew registration. Failure to do so is a prohibited act and will lead to refusal of entry for foreign products and illegal trade for domestic facilities. Every 2 years in even numbered years, every registered facility needs to renew its registration between October 1 and December 31. Registration is accepted by fax, mail and electronics means on the FDA food facility registration website.

As of January 22, 2014 there were 195,518 food facilities registered with the FDA.

Reaction and controversy

According to maplight.org, large trade organizations have joined public health advocates in supporting the bill, while groups aligned with individuals and small farms have generally opposed it. However, after Senate adoption of Jon Tester's amendment, which allows for the possible exemption of producers that sell less than $500,000 a year, many large food companies objected, arguing that the exemption puts consumers at risk.

A year after enactment the agency has fallen behind on expected progress. It has yet to implement "a specific timetable for issuing" a process to create rule for science-based produce standards, has not completed rules for foreign supplier verification, and must still create a guidance that will help schools and childcare programs lessen allergy risks for school-age children.

A similar set of New Zealand rules, the Food Bill 160-2, is moving towards passage since 2010. The primary effects expected are to tie New Zealand to Codex Alimentarius and the World Trade Organization permanently, although those international agreements will be constantly adjusted. Despite its 366 pages, Food Bill 160-2 cannot directly resolve many threats to food safety, as there is no added Produce traceability nor methods to control Antibiotic resistance. Controversy has been intense in NZ regarding introduction of genetic engineered plants and animals (GE); concern is that WTO and Codex will require opening up NZ to GE. The Soil & Health Association of New Zealand would not be able to complete their campaign towards making New Zealand organic by 2020.

Alcoholic beverage facilities exemption

There has been criticism that the FDA's proposed rule would be prohibitively expensive on the practice of alcoholic beverage facilities selling spent grain to farmers for animal food. Under current law, alcoholic beverages, such as beer, wine, cider and spirits, are exempt from the FDA's normal oversight of food products. The FDA will open up the rule to comments again this summer and then revise the proposal, which is due to be finalized by August 2015.

The proposed rules regulate the "good manufacturing practice in manufacturing, processing, packing or holding of animal food" and "require that certain facilities establish and implement hazard analysis and risk-based preventive controls for food for animals", but animal food at alcoholic beverage facilities would not be exempt pursuant to section 116 of FSMA since "those spent grains are not alcoholic beverages themselves, and they are not in a prepackaged form that prevents any direct human contact with the food".

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The Beverly Hills Playhouse is an acting school with theaters and training facilities in Beverly Hills, California, and also in Los Angeles, San Francisco, and New York City. It is one of the oldest acting schools and theatres in Los Angeles County, California. It is located at 254 South Robertson Boulevard in Beverly Hills.

The early years

The location was originally home to the respected Bliss-Hayden School of Acting run by a husband and wife team of motion picture actorsâ€"actress Lela Bliss with over 45 credits stretching from 1915 to 1965, and her husband actor Harry Hayden with over 260 credits from 1936 to 1955. Veronica Lake, Mamie Van Doren and many other professional actors studied there.

In 1954, the Bliss-Hayden Theatre was acquired by Douglas Frank Bank and Jay Manford, and renamed The Beverly Hills Playhouse. This was a showcase for many productions written by Douglas Bank (The Preacher, and Journey to a Lonely Star) as well as well-known plays of the time including Jenny Kissed Me, Room Service, The Lawyer, Harvey, and The Second Man. Many actors had performed there including Stanley Adams, Anne Baxter, Ken Mayer, Michael Fox and Louella Parsons, and directors Larry Stewart and Arthur M. Lowe, Jr., as well as others. They owned the theatre until 1959.

Modern era

In 1978, Milton Katselas, the noted director and acting teacher, moved his already established and renowned acting classes to the location. For the next 30 years he taught such stars as George Clooney, Alec Baldwin, Giovanni Ribisi, Tom Selleck, Michelle Pfeiffer, Ted Danson, Tony Danza, Jeffrey Tambor, Gene Reynolds, Tyne Daly, Mel Harris, Catherine Bell, Sofia Milos, Christy Carlson Romano, Jenna Elfman, Doris Roberts, Patrick Swayze, Miguel Ferrer, James Cromwell, Anne Archer, Larry Miller, John Glover, James Wilder, Jennifer Aspen, Jorge Garcia, Lana Parrilla.

The Beverly Hills Playhouse (BHP) Acting School

The Beverly Hills Playhouse is one of the city's oldest and most respected. The BHP is one of only a few schools that not only teaches the craft of acting, but also attitude and administration. With regard to acting technique, the BHP uses Katselas' approach, which is decidedly independent of the major acting philosophies of Stanislavski, Strasberg, Adler, Meisner, Hagen, etc. His experience as a director led him to a highly individual and adaptive way of training actors, mostly based in the simple observation and recreation of human behavior, along with an understanding of what's happening in the story. It is a down-to-earth training, with vastly reduced emphasis on exercises, and with techniques to create full, believable performances that enlighten and entertain.

There has been some controversy regarding the BHP and Scientology. This was because Milton Katselas was a well-known Scientologist, and as such drew the favor of Scientologist actors such as Anne Archer, Giovanni Ribisi, Marisol Nichols, Catherine Bell, Jenna Elfman and others who were his students as well. Some of the teachers on the staff of the school were Scientologists. During Milton's life there were persistent rumors that he was trying to proselytize his religion through his teaching - but the total percentage of students who had any connection with Scientology was never more than 10%, and in 2004 Katselas in fact fell out of favor with Scientologist celebrities. By 2007, almost all those involved with the movement left the school. Also, as Katselas was highly respected by countless non-Scientologist actors such as Doris Roberts and John Glover, his reputation remained primarily that of a first rate teacher above all else. Since Katselas' death in 2008, the BHP has been run by his longtime administrators Allen Barton, Gary Grossman and Art Cohan - longtime teachers in their own right at the school, and the BHP's connection with Scientology appears currently to be zero.

The BHP operates out of its headquarters in Beverly Hills, but also has a satellite operation in Los Feliz at the Skylight Theatre, as well as programs in San Francisco and New York City. Since 1984, it has also had an in-house non-profit theatre company (currently called The Skylight Theatre Company), which has produced hundreds of theatre productions, largely originated and fulfilled by the talent and interests of the BHP students. Its current focus under the leadership of Gary Grossman is the development of new plays, using the full array of talent available in the Los Angeles theatre community.

Notable Productions

A Christmas Held Captive

Further reading

• Oppenheimer, Mark (September 9, 2007). "Friends, thetans, countrymen". The Daily Telegraph. Telegraph Media Group Limited. Archived from the original on September 12, 2008. Retrieved 2008-10-18. 

References

External links

• Beverly Hills Playhouse web site
• Katselas Theatre Company - Theatre Company of the Beverly Hills Playhouse
• Lela Bliss at the Internet Movie Database
• Harry Hayden at the Internet Movie Database
• Milton Katselas at the Internet Movie Database

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The Beverly Hills Playhouse is an acting school with theaters and training facilities in Beverly Hills, California, and also in Los Angeles, San Francisco, and New York City. It is one of the oldest acting schools and theatres in Los Angeles County, California. It is located at 254 South Robertson Boulevard in Beverly Hills.

The early years

The location was originally home to the respected Bliss-Hayden School of Acting run by a husband and wife team of motion picture actorsâ€"actress Lela Bliss with over 45 credits stretching from 1915 to 1965, and her husband actor Harry Hayden with over 260 credits from 1936 to 1955. Veronica Lake, Mamie Van Doren and many other professional actors studied there.

In 1954, the Bliss-Hayden Theatre was acquired by Douglas Frank Bank and Jay Manford, and renamed The Beverly Hills Playhouse. This was a showcase for many productions written by Douglas Bank (The Preacher, and Journey to a Lonely Star) as well as well-known plays of the time including Jenny Kissed Me, Room Service, The Lawyer, Harvey, and The Second Man. Many actors had performed there including Stanley Adams, Anne Baxter, Ken Mayer, Michael Fox and Louella Parsons, and directors Larry Stewart and Arthur M. Lowe, Jr., as well as others. They owned the theatre until 1959.

Modern era

In 1978, Milton Katselas, the noted director and acting teacher, moved his already established and renowned acting classes to the location. For the next 30 years he taught such stars as George Clooney, Alec Baldwin, Giovanni Ribisi, Tom Selleck, Michelle Pfeiffer, Ted Danson, Tony Danza, Jeffrey Tambor, Gene Reynolds, Tyne Daly, Mel Harris, Catherine Bell, Sofia Milos, Christy Carlson Romano, Jenna Elfman, Doris Roberts, Patrick Swayze, Miguel Ferrer, James Cromwell, Anne Archer, Larry Miller, John Glover, James Wilder, Jennifer Aspen, Jorge Garcia, Lana Parrilla.

The Beverly Hills Playhouse (BHP) Acting School

The Beverly Hills Playhouse is one of the city's oldest and most respected. The BHP is one of only a few schools that not only teaches the craft of acting, but also attitude and administration. With regard to acting technique, the BHP uses Katselas' approach, which is decidedly independent of the major acting philosophies of Stanislavski, Strasberg, Adler, Meisner, Hagen, etc. His experience as a director led him to a highly individual and adaptive way of training actors, mostly based in the simple observation and recreation of human behavior, along with an understanding of what's happening in the story. It is a down-to-earth training, with vastly reduced emphasis on exercises, and with techniques to create full, believable performances that enlighten and entertain.

There has been some controversy regarding the BHP and Scientology. This was because Milton Katselas was a well-known Scientologist, and as such drew the favor of Scientologist actors such as Anne Archer, Giovanni Ribisi, Marisol Nichols, Catherine Bell, Jenna Elfman and others who were his students as well. Some of the teachers on the staff of the school were Scientologists. During Milton's life there were persistent rumors that he was trying to proselytize his religion through his teaching - but the total percentage of students who had any connection with Scientology was never more than 10%, and in 2004 Katselas in fact fell out of favor with Scientologist celebrities. By 2007, almost all those involved with the movement left the school. Also, as Katselas was highly respected by countless non-Scientologist actors such as Doris Roberts and John Glover, his reputation remained primarily that of a first rate teacher above all else. Since Katselas' death in 2008, the BHP has been run by his longtime administrators Allen Barton, Gary Grossman and Art Cohan - longtime teachers in their own right at the school, and the BHP's connection with Scientology appears currently to be zero.

The BHP operates out of its headquarters in Beverly Hills, but also has a satellite operation in Los Feliz at the Skylight Theatre, as well as programs in San Francisco and New York City. Since 1984, it has also had an in-house non-profit theatre company (currently called The Skylight Theatre Company), which has produced hundreds of theatre productions, largely originated and fulfilled by the talent and interests of the BHP students. Its current focus under the leadership of Gary Grossman is the development of new plays, using the full array of talent available in the Los Angeles theatre community.

Notable Productions

A Christmas Held Captive

Further reading

• Oppenheimer, Mark (September 9, 2007). "Friends, thetans, countrymen". The Daily Telegraph. Telegraph Media Group Limited. Archived from the original on September 12, 2008. Retrieved 2008-10-18. 

References

External links

• Beverly Hills Playhouse web site
• Katselas Theatre Company - Theatre Company of the Beverly Hills Playhouse
• Lela Bliss at the Internet Movie Database
• Harry Hayden at the Internet Movie Database
• Milton Katselas at the Internet Movie Database

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The SAT (/ɛs eɪ ti/; es-AY-tee) is a standardized test widely used for college admissions in the United States. Introduced in 1926, its name and scoring have changed several times; originally called the Scholastic Aptitude Test, it was later called the Scholastic Assessment Test, then the SAT I: Reasoning Test, then the SAT Reasoning Test, and now, simply the SAT.

The SAT is owned and published by the College Board, a private, not-for-profit corporation in the United States. It is developed and administered on behalf of the College Board by the Educational Testing Service. The test is intended to assess students' readiness for college. The SAT was originally designed not to be aligned with high school curricula, but several adjustments have been made for the version of the SAT introduced in 2016, and College Board president, David Coleman, has said that he also wanted to make the test reflect more closely what students learned in high school.

On March 5, 2014, the College Board announced that a redesigned version of the SAT would be administered for the first time in 2016. The current SAT, introduced in 2016, takes three hours to finish, plus 50 minutes for the SAT with essay, and as of 2017 costs US$45 (US$57 with the optional essay), excluding late fees, with additional processing fees if the SAT is taken outside the United States. Scores on the SAT range from 400 to 1600, combining test results from two 800-point sections: mathematics, and critical reading and writing. Taking the SAT, or its competitor, the ACT, is required for freshman entry to many, but not all, universities in the United States.

Function

The SAT is typically taken by high school juniors and seniors. The College Board states that the SAT measures literacy and writing skills that are needed for academic success in college. They state that the SAT assesses how well the test takers analyze and solve problemsâ€"skills they learned in school that they will need in college. However, the test is administered under a tight time limit (speeded) to help produce a range of scores.

The College Board also states that use of the SAT in combination with high school grade point average (GPA) provides a better indicator of success in college than high school grades alone, as measured by college freshman GPA. Various studies conducted over the lifetime of the SAT show a statistically significant increase in correlation of high school grades and college freshman grades when the SAT is factored in. A large independent validity study on the SAT's ability to predict college freshman GPA was performed by the University of California. The results of this study found how well various predictor variables could explain the variance in college freshman GPA. It found that independently high school GPA could explain 15.4% of the variance in college freshman GPA, SAT I (the SAT Math and Verbal sections) could explain 13.3% of the variance in college freshman GPA, and SAT II (also known as the SAT subject tests; in the UC's case specifically Writing, Mathematics IC or IIC, plus a third subject test of the student's choice) could explain 16% of the variance in college freshman GPA. When high school GPA and the SAT I were combined, they explained 20.8% of the variance in college freshman GPA. When high school GPA and the SAT II were combined, they explained 22.2% of the variance in college freshman GPA. When SAT I was added to the combination of high school GPA and SAT II, it added a .1 percentage point increase in explaining the variance in college freshman GPA for a total of 22.3%.

There are substantial differences in funding, curricula, grading, and difficulty among U.S. secondary schools due to U.S. federalism, local control, and the prevalence of private, distance, and home schooled students. SAT (and ACT) scores are intended to supplement the secondary school record and help admission officers put local dataâ€"such as course work, grades, and class rankâ€"in a national perspective. However, independent research has shown that high school GPA is better than the SAT at predicting college grades regardless of high school type or quality.

Historically, the SAT was more widely used by students living in coastal states and the ACT was more widely used by students in the Midwest and South; in recent years, however, an increasing number of students on the East and West coasts have been taking the ACT. Since 2007, all four-year colleges and universities in the United States that require a test as part of an application for admission will accept either the SAT or ACT, and hundreds of colleges and universities do not require any standardized test scores at all for admission.

Structure

SAT consists of three major sections: Critical Reading, Mathematics, and Writing. Each section receives a score on the scale of 200â€"800. All scores are multiples of 10. Total scores are calculated by adding up scores of the three sections. Each major section is divided into three parts. There are 10 sub-sections, including an additional 25-minute experimental or "equating" section that may be in any of the three major sections. The experimental section is used to normalize questions for future administrations of the SAT and does not count toward the final score. The test contains 3 hours and 45 minutes of actual timed sections; most administrations (after accounting for orientation, distribution of materials, completion of biographical sections, and fifteen minutes of timed breaks) run for about four and a half hours. The questions range from easy, medium, and hard depending on the scoring from the experimental sections. Easier questions typically appear closer to the beginning of the section while harder questions are toward the end in certain sections. This is not true for every section (the Critical Reading section is in chronological order) but it is the rule of thumb mainly for math, grammar, and the 19 sentence-completions in the reading sections.

Critical Reading

The Critical Reading section of the SAT is made up of one section with 52 questions, which should be completed in 65 minutes, with varying types of questions, including sentence completions and questions about short and long reading passages. Critical Reading sections normally begin with 5 to 8 sentence completion questions; the remainder of the questions are focused on the reading passages. Sentence completions generally test the student's vocabulary and understanding of sentence structure and organization by requiring the student to select one or two words that best complete a given sentence. The bulk of the Critical Reading section is made up of questions regarding reading passages, in which students read short excerpts on social sciences, humanities, physical sciences, or personal narratives and answer questions based on the passage. Certain sections contain passages asking the student to compare two related passages; generally, these consist of shorter reading passages. The n umber of questions about each passage is proportional to the length of the passage. Unlike in the Mathematics section, where questions go in the order of difficulty, questions in the Critical Reading section go in the order of the passage. Overall, question sets near the beginning of the section are easier, and question sets near the end of the section are harder.

Mathematics

The mathematics portion of the SAT is divided into two sections: Math Test â€" Calculator and Math Test â€" No Calculator. In total, the SAT math test is 80 minutes long and includes 58 questions: 45 multiple choice questions and 13 grid-in questions. The multiple choice questions have four possible answers; the grid-in questions are free response and require the test taker to provide an answer.

• The Math Test â€" No Calculator section has 20 questions (15 multiple choice and 5 grid-in) and lasts 25 minutes.
• The Math Test â€" Calculator section has 38 questions (30 multiple choice and 8 grid-in) and lasts 55 minutes.

Several scores are provided to the test taker for the math test. A subscore (on a scale of 1 to 15) is reported for each of three categories of math content: "Heart of Algebra" (linear equations, systems of linear equations, and linear functions), "Problem Solving and Data Analysis" (statistics, modeling, and problem-solving skills), and "Passport to Advanced Math" (non-linear expressions, radicals, exponentials and other topics that form the basis of more advanced math). A test score for the math test is reported on a scale of 10 to 40, and a section score (equal to the test score multiplied by 20) is reported on a scale of 200 to 800.

Calculator use

All scientific and most graphing calculators, including Computer Algebra System (CAS) calculators, are permitted on the SAT Math â€" Calculator section only. All four-function calculators are allowed as well; however, these devices are not recommended. All mobile phone and smartphone calculators, calculators with typewriter-like (QWERTY) keyboards, laptops and other portable computers, and calculators capable of accessing the Internet are not permitted.

Research was conducted by the College Board to study the effect of calculator use on SAT I: Reasoning Test math scores. The study found that performance on the math section was associated with the extent of calculator use: those using calculators on about one third to one half of the items averaged higher scores than those using calculators more or less frequently. However, the effect was "more likely to have been the result of able students using calculators differently than less able students rather than calculator use per se." There is some evidence to suggest that the frequent use of a calculator in school outside of the testing situation has a positive effect on test performance compared to those who do not use calculators in school.

Writing

The writing portion of the SAT, based on but not directly comparable to the old SAT II subject test in writing (which in turn was developed from the old Test of Standard Written English (TSWE), includes multiple choice questions and a brief essay. The essay subscore contributes about 28% to the total writing score, with the multiple choice questions contributing 70%. This section was implemented in March 2005 following complaints from colleges about the lack of uniform examples of a student's writing ability and critical thinking.

The multiple choice questions include error-identification questions, sentence-improvement questions, and paragraph-improvement questions. Error-identification and sentence-improvement questions test the student's knowledge of grammar, presenting an awkward or grammatically incorrect sentence; in the error identification section, the student must locate the word producing the source of the error or indicate that the sentence has no error, while the sentence improvement section requires the student to select an acceptable fix to the awkward sentence. The paragraph improvement questions test the student's understanding of logical organization of ideas, presenting a poorly written student essay and asking a series of questions as to what changes might be made to best improve it.

The essay section, which is always administered as the first section of the test, is 25 minutes long. All essays must be in response to a given prompt. The prompts are broad and often philosophical and are designed to be accessible to students regardless of their educational and social backgrounds. For instance, test takers may be asked to expand on such ideas as their opinion on the value of work in human life or whether technological change also carries negative consequences to those who benefit from it. No particular essay structure is required, and the College Board accepts examples "taken from [the student's] reading, studies, experience, or observations." Two trained readers assign each essay a score between 1 and 6, where a score of 0 is reserved for essays that are blank, off-topic, non-English, not written with a Number 2 pencil, or considered illegible after several attempts at reading. The scores are summed to produce a final score from 2 to 12 (or 0). If the two reader s' scores differ by more than one point, then a senior third reader decides. The average time each reader/grader spends on each essay is less than 3 minutes.

In March 2005, Les Perelman analyzed 15 scored sample essays contained in the College Board's ScoreWrite book along with 30 other training samples and found that in over 90% of cases, the essay's score could be predicted from simply counting the number of words in the essay. Two years later, Perelman trained high school seniors to write essays that made little sense but contained infrequently used words such as "plethora" and "myriad". All of the students received scores of "10" or better, which placed the essays in the 92nd percentile or higher.

Style of questions

Most of the questions on the SAT, except for the essay and the grid-in math responses, are multiple choice; all multiple-choice questions have four answer choices, one of which is correct. The questions of each section of the same type are generally ordered by difficulty. However, an important exception exists: Questions that follow the long and short reading passages are organized chronologically, rather than by difficulty. Ten of the questions in one of the math sub-sections are not multiple choice. They instead require the test taker to bubble in a number in a four-column grid.

The questions are weighted equally. For each correct answer, one raw point is added. No points are deducted for incorrect answers. The final score is derived from the raw score; the precise conversion chart varies between test administrations.

Logistics

The SAT is offered seven times a year in the United States; in October, November, December, January, March (or April, alternating), May, and June. The test is typically offered on the first Saturday of the month for the November, December, May, and June administrations. In other countries, the SAT is offered on the same dates as in the United States except for the first spring test date (i.e., March or April), which is not offered. The test was taken by 1,698,521 high school graduates in the class of 2015.

Candidates wishing to take the test may register online at the College Board's website, by mail, or by telephone, at least three weeks before the test date.

The SAT costs $45 ($57 with the optional essay, plus additional fees if testing outside the United States) as of 2017. The College Board makes fee waivers available for low income students. Additional fees apply for late registration, standby testing, registration changes, scores by telephone, and extra score reports (beyond the four provided for free).

Candidates whose religious beliefs prevent them from taking the test on a Saturday may request to take the test on the following day, except for the October test date in which the Sunday test date is eight days after the main test offering. Such requests must be made at the time of registration and are subject to denial.

Students with verifiable disabilities, including physical and learning disabilities, are eligible to take the SAT with accommodations. The standard time increase for students requiring additional time due to learning disabilities or physical handicaps is time + 50%; time + 100% is also offered.

Raw scores, scaled scores, and percentiles

Students receive their online score reports approximately three weeks after test administration (six weeks for mailed, paper scores), with each section graded on a scale of 200â€"800 and two sub scores for the writing section: the essay score and the multiple choice sub score. In addition to their score, students receive their percentile (the percentage of other test takers with lower scores). The raw score, or the number of points gained from correct answers and lost from incorrect answers is also included. Students may also receive, for an additional fee, the Question and Answer Service, which provides the student's answer, the correct answer to each question, and online resources explaining each question.

The corresponding percentile of each scaled score varies from test to testâ€"for example, in 2003, a scaled score of 800 in both sections of the SAT Reasoning Test corresponded to a percentile of 99.9, while a scaled score of 800 in the SAT Physics Test corresponded to the 94th percentile. The differences in what scores mean with regard to percentiles are due to the content of the exam and the caliber of students choosing to take each exam. Subject Tests are subject to intensive study (often in the form of an AP, which is relatively more difficult), and only those who know they will perform well tend to take these tests, creating a skewed distribution of scores.

The percentiles that various SAT scores for college-bound seniors correspond to are summarized in the following chart:

The older SAT (before 1995) had a very high ceiling. In any given year, only seven of the million test-takers scored above 1580. A score above 1580 was equivalent to the 99.9995 percentile.

In 2015 the average score for the Class of 2015 was 1490 out of a maximum 2400. That was down 7 points from the previous class’s mark and was the lowest composite score of the past decade.

SAT-ACT score comparisons

The College Board and ACT, Inc. conducted a joint study of students who took both the SAT and the ACT between September 2004 (for the ACT) or March 2005 (for the SAT) and June 2006. Tables were provided to concord scores for students taking the SAT after January 2005 and before March 2016.

In May, 2016, the College Board released concordance tables to concord scores on the SAT used from March 2005 through January 2016 to the SAT used since March 2016, as well as tables to concord scores on the SAT used since March 2016 to the ACT.

History

Many college entrance exams in the early 1900s were specific to each school and required candidates to travel to the school to take the tests. The College Board, a consortium of colleges in the northeastern United States, was formed in 1900 to establish a nationally administered, uniform set of essay tests based on the curricula of the boarding schools that typically provided graduates to the colleges of the Ivy League and Seven Sisters, among others.

In the same time period, Lewis Terman and others began to promote the use of tests such as Alfred Binet's in American schools. Terman in particular thought that such tests could identify an innate "intelligence quotient" (IQ) in a person. The results of an IQ test could then be used to find an elite group of students who would be given the chance to finish high school and go on to college. By the mid-1920s, the increasing use of IQ tests, such as the Army Alpha test administered to recruits in World War I, led the College Board to commission the development of the SAT. The commission, headed by Carl Brigham, argued that the test predicted success in higher education by identifying candidates primarily on the basis of intellectual promise rather than on specific accomplishment in high school subjects. In 1934, James Conant and Henry Chauncey used the SAT as a means to identify recipients for scholarships to Harvard University. Specifically, Conant wanted to find students, other tha n those from the traditional northeastern private schools, that could do well at Harvard. The success of the scholarship program and the advent of World War II led to the end of the College Board essay exams and to the SAT being used as the only admissions test for College Board member colleges.

The SAT rose in prominence after World War II due to several factors. Machine-based scoring of multiple-choice tests taken by pencil had made it possible to rapidly process the exams. The G.I. Bill produced an influx of millions of veterans into higher education. The formation of the Educational Testing Service (ETS) also played a significant role in the expansion of the SAT beyond the roughly fifty colleges that made up the College Board at the time. The ETS was formed in 1947 by the College Board, Carnegie Foundation for the Advancement of Teaching, and the American Council on Education, to consolidate respectively the operations of the SAT, the GRE, and the achievement tests developed by Ben Wood for use with Conant's scholarship exams. The new organization was to be philosophically grounded in the concepts of open-minded, scientific research in testing with no doctrine to sell and with an eye toward public service. The ETS was chartered after the death of Brigham, who had oppo sed the creation of such an entity. Brigham felt that the interests of a consolidated testing agency would be more aligned with sales or marketing than with research into the science of testing. It has been argued that the interest of the ETS in expanding the SAT in order to support its operations aligned with the desire of public college and university faculties to have smaller, diversified, and more academic student bodies as a means to increase research activities. In 1951, about 80,000 SAT tests were taken; in 1961, about 800,000; and by 1971, about 1.5 million SAT tests were being taken each year.

A timeline of notable events in the history of the SAT follows.

1901 essay exams

On June 17, 1901, the first exams of the College Board were administered to 973 students across 67 locations in the United States, and two in Europe. Although those taking the test came from a variety of backgrounds, approximately one third were from New York, New Jersey, or Pennsylvania. The majority of those taking the test were from private schools, academies, or endowed schools. About 60% of those taking the test applied to Columbia University. The test contained sections on English, French, German, Latin, Greek, history, mathematics, chemistry, and physics. The test was not multiple choice, but instead was evaluated based on essay responses as "excellent", "good", "doubtful", "poor" or "very poor".

1926 test

The first administration of the SAT occurred on June 23, 1926, when it was known as the Scholastic Aptitude Test. This test, prepared by a committee headed by Princeton psychologist Carl Campbell Brigham, had sections of definitions, arithmetic, classification, artificial language, antonyms, number series, analogies, logical inference, and paragraph reading. It was administered to over 8,000 students at over 300 test centers. Men composed 60% of the test-takers. Slightly over a quarter of males and females applied to Yale University and Smith College. The test was paced rather quickly, test-takers being given only a little over 90 minutes to answer 315 questions.

1928 and 1929 tests

In 1928, the number of sections on the SAT was reduced to seven, and the time limit was increased to slightly under two hours. In 1929, the number of sections was again reduced, this time to six. These changes were designed in part to give test-takers more time per question. For these two years, all of the sections tested verbal ability: math was eliminated entirely from the SAT.

1930 test and 1936 changes

In 1930 the SAT was first split into the verbal and math sections, a structure that would continue through 2004. The verbal section of the 1930 test covered a more narrow range of content than its predecessors, examining only antonyms, double definitions (somewhat similar to sentence completions), and paragraph reading. In 1936, analogies were re-added. Between 1936 and 1946, students had between 80 and 115 minutes to answer 250 verbal questions (over a third of which were on antonyms). The mathematics test introduced in 1930 contained 100 free response questions to be answered in 80 minutes, and focused primarily on speed. From 1936 to 1941, like the 1928 and 1929 tests, the mathematics section was eliminated entirely. When the mathematics portion of the test was re-added in 1942, it consisted of multiple choice questions.

1941 and 1942 score scales

Until 1941, the scores on all SAT tests had been scaled to a mean of 500 with a standard deviation of 100. Although one test-taker could be compared to another for a given test date, comparisons from one year to another could not be made. For example, a score of 500 achieved on an SAT taken in one year could reflect a different ability level than a score of 500 achieved in another year. By 1940, it had become clear that setting the mean SAT score to 500 every year was unfair to those students who happened to take the SAT with a group of higher average ability.

In order to make cross-year score comparisons possible, in April 1941 the SAT verbal section was scaled to a mean of 500, and a standard deviation of 100, and the June 1941 SAT verbal section was equated (linked) to the April 1941 test. All SAT verbal sections after 1941 were equated to previous tests so that the same scores on different SAT tests would be comparable. Similarly, in June 1942 the SAT math section was equated to the April 1942 math section, which itself was linked to the 1942 SAT verbal section, and all SAT math sections after 1942 would be equated to previous tests. From this point forward, SAT mean scores could change over time, depending on the average ability of the group taking the test compared to the roughly 10,600 students taking the SAT in April 1941. The 1941 and 1942 score scales would remain in use until 1995.

1946 test and associated changes

Paragraph reading was eliminated from the verbal portion of the SAT in 1946, and replaced with reading comprehension, and "double definition" questions were replaced with sentence completions. Between 1946 and 1957 students were given 90 to 100 minutes to complete 107 to 170 verbal questions. Starting in 1958 time limits became more stable, and for 17 years, until 1975, students had 75 minutes to answer 90 questions. In 1959 questions on data sufficiency were introduced to the mathematics section, and then replaced with quantitative comparisons in 1974. In 1974 both verbal and math sections were reduced from 75 minutes to 60 minutes each, with changes in test composition compensating for the decreased time.

1960s and 1970s score declines

From 1926 to 1941, scores on the SAT were scaled to make 500 the mean score on each section. In 1941 and 1942, SAT scores were standardized via test equating, and as a consequence, average verbal and math scores could vary from that time forward. In 1952, mean verbal and math scores were 476 and 494, respectively, and scores were generally stable in the 1950s and early 1960s. However, starting in the mid-1960s and continuing until the early 1980s, SAT scores declined: the average verbal score dropped by about 50 points, and the average math score fell by about 30 points. By the late 1970s, only the upper third of test takers were doing as well as the upper half of those taking the SAT in 1963. From 1961 to 1977, the number of SAT tests taken per year doubled, suggesting that the decline could be explained by demographic changes in the group of students taking the SAT. Commissioned by the College Board, an independent study of the decline found that most (up to about 75%) of the te st decline in the 1960s could be explained by compositional changes in the group of students taking the test; however, only about 25 percent of the 1970s decrease in test scores could similarly be explained. Later analyses suggested that up to 40 percent of the 1970s decline in scores could be explained by demographic changes, leaving unknown at least some of the reasons for the decline.

1994 changes

In early 1994, substantial changes were made to the SAT. Antonyms were removed from the verbal section in order to make rote memorization of vocabulary less useful. Also, the fraction of verbal questions devoted to passage-based reading material was increased from about 30% to about 50%, and the passages were chosen to be more like typical college-level reading material, compared to previous SAT reading passages. The changes for increased emphasis on analytical reading were made in response to a 1990 report issued by a commission established by the College Board. The commission recommended that the SAT should, among other things, "approximate more closely the skills used in college and high school work". A mandatory essay had been considered as well for the new version of the SAT; however, criticism from minority groups as well as a concomitant increase in the cost of the test necessary to grade the essay led the College Board to drop it from the planned changes.

Major changes were also made to the SAT mathematics section at this time, due in part to the influence of suggestions made by the National Council of Teachers of Mathematics. Test-takers were now permitted to use calculators on the math sections of the SAT. Also, for the first time since 1935, the SAT would now include some math questions that were not multiple choice, instead requiring students to supply the answers. Additionally, some of these "student-produced response" questions could have more than one correct answer. The tested mathematics content on the SAT was expanded to include concepts of slope of a line, probability, elementary statistics including median and mode, and counting problems.

1995 recentering (raising mean score back to 500)

By the early 1990s, average total SAT scores were around 900 (typically, 425 on the verbal and 475 on the math). The average scores on the 1994 modification of the SAT I were similar: 428 on the verbal and 482 on the math. SAT scores for admitted applicants to highly selective colleges in the United States were typically much higher. For example, the score ranges of the middle 50% of admitted applicants to Princeton University in 1985 were 600 to 720 (verbal) and 660 to 750 (math). Similarly, median scores on the modified 1994 SAT for freshmen entering Yale University in the fall of 1995 were 670 (verbal) and 720 (math). For the majority of SAT test takers, however, verbal and math scores were below 500: In 1992, half of the college-bound seniors taking the SAT were scoring between 340 and 500 on the verbal section and between 380 and 560 on the math section, with corresponding median scores of 420 and 470, respectively.

The drop in SAT verbal scores, in particular, meant that the usefulness of the SAT score scale (200 to 800) had become degraded. At the top end of the verbal scale, significant gaps were occurring between raw scores and uncorrected scaled scores: a perfect raw score no longer corresponded to an 800, and a single omission out of 85 questions could lead to a drop of 30 or 40 points in the scaled score. Corrections to scores above 700 had been necessary to reduce the size of the gaps and to make a perfect raw score result in an 800. At the other end of the scale, about 1.5 percent of test takers would have scored below 200 on the verbal section if that had not been the reported minimum score. Although the math score averages were closer to the center of the scale (500) than the verbal scores, the distribution of math scores was no longer well approximated by a normal distribution. These problems, among others, suggested that the original score scale and its reference group of about 1 0,000 students taking the SAT in 1941 needed to be replaced.

Beginning with the test administered in April 1995, the SAT score scale was recentered to return the average math and verbal scores close to 500. Although only 25 students had received perfect scores of 1600 in all of 1994, 137 students taking the April test scored a 1600. The new scale used a reference group of about one million seniors in the class of 1990: the scale was designed so that the SAT scores of this cohort would have a mean of 500 and a standard deviation of 110. Because the new scale would not be directly comparable to the old scale, scores awarded on April 1995 and later were officially reported with an "R" (for example, "560R") to reflect the change in scale, a practice that was continued until 2001. Scores awarded before April 1995 may be compared to those on the recentered scale by using official College Board tables. For example, verbal and math scores of 500 received before 1995 correspond to scores of 580 and 520, respectively, on the 1995 scale.

1995 re-centering controversy

Certain educational organizations viewed the SAT re-centering initiative as an attempt to stave off international embarrassment in regard to continuously declining test scores, even among top students. As evidence, it was presented that the number of pupils who scored above 600 on the verbal portion of the test had fallen from a peak of 112,530 in 1972 to 73,080 in 1993, a 36% backslide, despite the fact that the total number of test-takers had risen over 500,000.

2002 changes â€" Score Choice

In October 2002, the College Board dropped the Score Choice Option for SAT-II exams. Under this option, scores were not released to colleges until the student saw and approved of the score. The College Board has since decided to re-implement Score Choice in the spring of 2009. It is described as optional, and it is not clear if the reports sent will indicate whether or not this student has opted-in or not. A number of highly selective colleges and universities, including Yale, the University of Pennsylvania, and Stanford, have announced they will require applicants to submit all scores. Stanford, however, only prohibits Score Choice for the traditional SAT. Others, such as MIT and Harvard, have fully embraced Score Choice.

2005 changes, including a new 2400-point score

In 2005, the test was changed again, largely in response to criticism by the University of California system. Because of issues concerning ambiguous questions, especially analogies, certain types of questions were eliminated (the analogies from the verbal and quantitative comparisons from the math section). The test was made marginally harder, as a corrective to the rising number of perfect scores. A new writing section, with an essay, based on the former SAT II Writing Subject Test, was added, in part to increase the chances of closing the opening gap between the highest and midrange scores. Other factors included the desire to test the writing ability of each student; hence the essay. The essay section added an additional maximum 800 points to the score, which increased the new maximum score to 2400. The "New SAT" was first offered on March 12, 2005, after the last administration of the "old" SAT in January 2005. The mathematics section was expanded to cover three years of high school mathematics. The verbal section's name was changed to the Critical Reading section.

Scoring problems of October 2005 tests

In March 2006, it was announced that a small percentage of the SATs taken in October 2005 had been scored incorrectly due to the test papers' being moist and not scanning properly, and that some students had received erroneous scores. The College Board announced they would change the scores for the students who were given a lower score than they earned, but at this point many of those students had already applied to colleges using their original scores. The College Board decided not to change the scores for the students who were given a higher score than they earned. A lawsuit was filed in 2006 on behalf of the 4,411 students who received an incorrect score on the SAT. The class-action suit was settled in August 2007 when the College Board and Pearson Educational Measurement, the company that scored the SAT tests, announced they would pay $2.85 million into a settlement fund. Under the agreement each student could either elect to receive $275 or submit a claim for more money if he or she felt the damage was greater. A similar scoring error occurred on a secondary school admission test in 2010-2011 when the ERB (Educational Records Bureau) announced after the admission process was over that an error had been made in the scoring of the tests of 2010 (17%) of the students who had taken the Independent School Entrance Examination for admission to private secondary schools for 2011. Commenting on the effect of the error on students' school applications in The New York Times, David Clune, President of the ERB stated "It is a lesson we all learn at some pointâ€"that life isn't fair."

2008 changes

In late 2008, a new variable came into play. Previously, applicants to most colleges were required to submit all scores, with some colleges that embraced Score Choice retaining the option of allowing their applicants not to have to submit all scores. However, in 2008, an initiative to make Score Choice universal had begun, with some opposition from colleges desiring to maintain score report practices. While students theoretically now have the choice to submit their best score (in theory one could send any score one wishes to send) to the college of their choice, some colleges and universities, such as Cornell, ask that students send all test scores. This had led the College Board to display on their web site which colleges agree with or dislike Score Choice, with continued claims that students will still never have scores submitted against their will. Regardless of whether a given college permits applicants to exercise Score Choice options, most colleges do not penalize students w ho report poor scores along with high ones; many universities, such as Columbia and Cornell, expressly promise to overlook those scores that may be undesirable to the student and/or to focus more on those scores that are most representative of the student's achievement and academic potential. College Board maintains a list of colleges and their respective score choice policies that is recent as of November 2011.

2012 changes

Beginning in 2012, test takers are required to submit a current, recognizable photo during registration. Students are required to present their photo admission ticket â€" or another acceptable form of photo ID â€" for admittance to their designated test center. Student scores and registration information, including the photo provided, are made available to the student’s high school. In the event of an investigation involving the validity of a student’s test scores, their photo may be made available to institutions to which they have sent scores. Any college that is granted access to a student’s photo is first required to certify that they are all admitted students.

2016 changes, including the return to a 1600-point score

On March 5, 2014, the College Board announced its plan to redesign the SAT in order to link the exam more closely to the work high school students encounter in the classroom. The new exam was administered for the first time in spring 2016. Some of the major changes are: an emphasis on the use of evidence to support answers, a shift away from obscure vocabulary to words that students are more likely to encounter in college and career, a math section that is focused on fewer areas, a return to the 1600-point score scale, an optional essay, and the removal of penalty for wrong answers (rights-only scoring). To combat the perceived advantage of costly test preparation courses, the College Board announced a new partnership with Khan Academy to offer free online practice problems and instructional videos.

Name changes

The SAT was originally known as the Scholastic Aptitude Test. In 1990, a commission set up by the College Board to review the proposed changes to the SAT program recommended that the meaning of the initialism SAT be changed to "Scholastic Assessment Test" because a "test that integrates measures of achievement as well as developed ability can no longer be accurately described as a test of aptitude". In 1993, the College Board changed the name of the test to SAT I: Reasoning Test; at the same time, the name of the Achievement Tests was changed to SAT II: Subject Tests. The Reasoning Test and Subject Tests were to be collectively known as the Scholastic Assessment Tests. According to the president of the College Board at the time, the name change was meant "to correct the impression among some people that the SAT measures something that is innate and impervious to change regardless of effort or instruction." The new SAT debuted in March 1994, and was referred to as the Scholastic As sessment Test by major news organizations. However, in 1997, the College Board announced that the SAT could not properly be called the Scholastic Assessment Test, and that the letters SAT did not stand for anything. In 2004, the Roman numeral in SAT I: Reasoning Test was dropped, making SAT Reasoning Test the new name of the SAT.

Mathâ€"verbal achievement gap

In 2002, Richard Rothstein (education scholar and columnist) wrote in The New York Times that the U.S. math averages on the SAT and ACT continued its decade-long rise over national verbal averages on the tests.

Reuse of old SAT exams

The College Board has been accused of completely reusing old SAT papers previously given in the United States. The recycling of questions from previous exams has been exploited to allow for cheating on exams and impugned the validity of some students' test scores, according to college officials. Test preparation companies in Asia have been found to provide test questions to students within hours of a new SAT exam's administration.

Perception

Association with culture

For decades many critics have accused designers of the verbal SAT of cultural bias as an explanation for the disparity in scores between poorer and wealthier test-takers. A famous (and long past) example of this bias in the SAT I was the oarsmanâ€"regatta analogy question. The object of the question was to find the pair of terms that had the relationship most similar to the relationship between "runner" and "marathon". The correct answer was "oarsman" and "regatta". The choice of the correct answer was thought to have presupposed students' familiarity with rowing, a sport popular with the wealthy. However, according to Murray and Herrnstein, the black-white gap is smaller in culture-loaded questions like this one than in questions that appear to be culturally neutral. Analogy questions have since been replaced by short reading passages.

Association with family income

Parents with a higher income can afford to spend money on their child’s education if they are not satisfied with it, while families with a lower income cannot. Families that have a higher family income can purchase multiple prep books, more specifically the College Board one. They can also pay for tutors, prep classes, and other resources. These resources not only prepare the students for the knowledge required in the test, but also provide practice tests and sample problems that can be studied and possibly be seen on the real exam. Another source of this difference comes from the quality of schooling as family income increases. Those with higher income families, “tend to have better teachers, more resource-rich educational environments, more educated parents who can help them with school and, sometimes, expensive SAT tutoring.” The quality of education the student receives greatly affect the success during the test because the school not only relates to the student’s know ledge but also many times correlates with the students study habits and motivation to succeed. As with racial bias, this correlation with income could also be due to the social class of the makers of the test, although empirical research suggests that poorer students actually perform worse on 'neutral' than such 'privileged' questions.

Association with gender

The largest association with gender on the SAT is found in the math section where male students, on average, score higher than female students by approximately 30 points. In 2013, the American College Testing Board released a report boys outperformed girls on the mathematics section of the test.

Association with race and ethnicity

African American, Hispanic, and Native American students, on average, perform an order of one standard deviation lower on the SAT than white and Asian students.

Researchers believe that the difference in scores is closely related to the overall achievement gap in American society between students of different racial groups. This gap may be explainable in part by the fact that students of disadvantaged racial groups tend to go to schools that provide lower educational quality. This view is supported by evidence that the black-white gap is higher in cities and neighborhoods that are more racially segregated. It has also been suggested that stereotype threat has a significant effect on lowering achievement of minority students. For example, African Americans perform worse on a test when they are told that the test measures "verbal reasoning ability", than when no mention of the test subject is made. Other research cites poorer minority proficiency in key coursework relevant to the SAT (English and math), as well as peer pressure against students who try to focus on their schoolwork ("acting white"). Cultural issues are also evident among bla ck students in wealthier households, with high achieving parents. John Ogbu, a Nigerian-American professor of anthropology, found that instead of looking to their parents as role models, black youth chose other models like rappers and did not put forth the effort to be a good student. However, they felt that racism was wrong.

One set of studies has reported differential item functioning - namely, some test questions function differently based on the racial group of the test taker, reflecting some kind of systematic difference in a groups ability to understand certain test questions or to acquire the knowledge required to answer them. In 2003 Freedle published data showing that Black students have had a slight advantage on the verbal questions that are labeled as difficult on the SAT, whereas white and Asian students tended to have a slight advantage on questions labeled as easy. Freedle argued that these findings suggest that "easy" test items use vocabulary that is easier to understand for white middle class students than for minorities, who often use a different language in the home environment, whereas the difficult items use complex language learned only through lectures and textbooks, giving both student groups equal opportunities to acquiring it. The study was severely criticized by the ETS boar d, but the findings were replicated in a subsequent study by Santelices and Wilson in 2010.

There is no evidence that SAT scores systematically underestimate future performance of minority students. However, the predictive validity of the SAT has been shown to depend on the dominant ethnic and racial composition of the college. Some studies have also shown that African American students under-perform in college relative to their white peers with the same SAT test scores; researchers have argued that this is likely because white students tend to benefit from social advantages outside of the educational environment (for example, high parental involvement in their education, inclusion in campus academic activities, positive bias from same-race teachers and peers) which result in better grades.

Christopher Jencks concludes that as a group African Americans have been harmed by the introduction of standardized entrance exams such as the SAT. This, according to him, is not because the tests themselves are flawed, but because of labeling bias and selection bias; the tests measure the skills that African Americans are less likely to develop in their socialization, rather than the skills they are more likely to develop. Furthermore, standardized entrance exams are often labeled as tests of general ability, rather than of certain aspects of ability. Thus, a situation is produced in which African American ability is consistently underestimated within the education and workplace environments, contributing in turn to selection bias against them which exacerbates underachievement.

Affirmative Action has allowed blacks to get into top colleges with lower scores. In The Bell Curve, Richard J. Herrnstein and Charles Murray writes the 1985 average SAT-Math score for black males at MIT was 659, below the 25th percentile at MIT. Moreover, at nine top colleges, blacks scored more than 200 points below whites on the combined Math and Verbal SATs. At Berkeley, there was a 288 points difference. Asians scored slightly better than whites.

Dropping SAT

A growing number of colleges have joined the SAT optional movement. These colleges do not require the SAT for admission.

One example of a college that did this is Drew University in New Jersey. After they adopted an optional SAT policy, they had a 20% increase in applications. Dean of Admissions Mary Beth Carey says that "Our own research showed us that high school grade point average is by far the most important predictor of success in college." The college reported that they accepted their most diverse class ever as a result of the policy.

In a 2001 speech to the American Council on Education, Richard C. Atkinson, the president of the University of California, urged dropping the SAT as a college admissions requirement:

Anyone involved in education should be concerned about how overemphasis on the SAT is distorting educational priorities and practices, how the test is perceived by many as unfair, and how it can have a devastating impact on the self-esteem and aspirations of young students. There is widespread agreement that overemphasis on the SAT harms American education.

In response to threats by the University of California to drop the SAT as an admission requirement, the College Entrance Examination Board announced the restructuring of the SAT, to take effect in March 2005, as detailed above.

In the 1960s and 1970s there was a movement to drop achievement scores. After a period of time, the countries, states and provinces that reintroduced them agreed that academic standards had dropped, students had studied less, and had taken their studying less seriously. They reintroduced the tests after studies and research concluded that the high-stakes tests produced benefits that outweighed the costs.

IQ studies

Frey and Detterman (2003) investigated associations of SAT scores with intelligence test scores. Using an estimate of general mental ability, or g, based on the ASVAB test battery, which can be best thought of as representing crystallized intelligence (learned abilities), they found SAT scores to be highly correlated with g (r=.82 in their sample, .857 when adjusted for non-linearity) in their sample taken from a 1979 national probability survey. Additionally, they investigated the correlation between SAT results, using the revised and recentered form of the test, and scores on the Raven's Advanced Progressive Matrices, a test of fluid intelligence (reasoning), this time using a non-random sample. They found that the correlation of SAT results with scores on the Raven's Advanced Progressive Matrices was .483. They estimated that this latter correlation would have been about 0.72 were it not for the restriction of ability range in the sample. They also noted that ther e appeared to be a ceiling effect on the Raven’s scores which may have suppressed the correlation. Beaujean and colleagues (2006) have reached similar conclusions to those reached by Frey and Detterman.

Preparation

SAT preparation is a highly lucrative field and many companies and organizations offer test preparation in the form of books, classes, online courses, and tutoring. The test preparation industry began almost simultaneously with the introduction of university entrance exams in the U.S. and flourished from the start.

The College Board maintains that the SAT is essentially uncoachable and research by the College Board and the National Association of College Admission Counseling suggests that tutoring courses result in an average increase of about 20 points on the math section and 10 points on the verbal section. Other studies have shown significantly different results. A longitudinal study from Ohio State showed that taking private SAT prep classes correlated with scores higher by ~60 points. A study from Oxford showed that coaching courses boosted scores by an average of 56 points.

Montgomery and Lilly (2012) performed a systematic literature review of all published SAT coaching research in search of high quality studies (defined as those with randomized controlled trials). They found that the randomized treatments resulted in V/M gains of +23/32 points for a total of +56; the high quality study that showed the highest score increase was Johnson (1984; San Francisco) which was based on a 30-hour prep course that showed an average increase of 178 points. The Johnson San Francisco study was also the only high quality study found on a prep course of 30 hours or more in length, although validity of this outlier study is uncertain due to the attrition of half the participants.

Use by high-IQ societies

Certain high IQ societies, like Mensa, the Prometheus Society and the Triple Nine Society, use scores from certain years as one of their admission tests. For instance, the Triple Nine Society accepts scores of 1450 on tests taken before April 1995, and scores of at least 1520 on tests taken between April 1995 and February 2005.

The SAT is sometimes given to students younger than 13 by organizations such as the Study of Mathematically Precocious Youth, Johns Hopkins Center for Talented Youth, Duke TIP, and other organizations who use the results to select, study and mentor students of exceptional ability.

Writing section

In 2005, MIT Writing Director Pavan Sreekireddy plotted essay length versus essay score on the new SAT from released essays and found a high correlation between them. After studying over 50 graded essays, he found that longer essays consistently produced higher scores. In fact, he argues that by simply gauging the length of an essay without reading it, the given score of an essay could likely be determined correctly over 90% of the time. He also discovered that several of these essays were full of factual errors; the College Board does not claim to grade for factual accuracy.

Perelman, along with the National Council of Teachers of English also criticized the 25-minute writing section of the test for damaging standards of writing teaching in the classroom. They say that writing teachers training their students for the SAT will not focus on revision, depth, accuracy, but will instead produce long, formulaic, and wordy pieces. "You're getting teachers to train students to be bad writers", concluded Perelman.

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