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ASSE President Rick Pollock Urges Obama Administration to Adopt I2P2 Standard for Workplace Safety

Posted in on Thu, May 16, 2013

President Barack Obama
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500

Dear President Obama:

I am writing to thank you and to ask for your help.  On behalf of the 35,000 member of the American Society of Safety Engineers (ASSE), thank you for your leadership in making the trip last month to honor the victims and meet with the families of the April 17 West, TX, fertilizer explosion.  At a time when the nation’s attention was focused on the senseless loss of life in Boston, it was important that you and the First Lady commemorate the likewise senseless loss of fourteen of our fellow Americans, including ten first responders, in West.  Both these deaths and those in Boston deserved the nation’s deepest sympathy and appropriate responses.

ASSE and our member safety, health and environmental (SH&E) professionals will watch with keen interest to see what can be learned from the investigations already underway in West.  With any new knowledge that may be gained in the investigations, they will work with employers and employees across the nation to make sure that whatever did go wrong is prevented from happening again.  What we hope is not lost in the aftermath of this costly destruction is that this explosion occurred in a workplace.

As a nation, we look from afar at the recent appalling loss of worker lives in the Bangladesh garment factory tragedies and assume such an incident cannot happen here.  The tragedy in West reminds us that, despite our significant advances in workplace safety, this nation is not immune from incidents that result in multiple deaths in workplaces.  We can and must do better to prevent such tragedies.  But we also must remind ourselves that, every day, this nation loses nearly thirteen Americans in its workplaces, a number that nearly equals the loss of life in West.  Unlike the tragedies in West and Bangladesh, though, these are deaths that typically occur one at a time, out of sight, and in incidents that rarely receive the public’s attention.  Yet each loss impacts families and communities no less terribly than those that gain front page headlines. It is appalling that, in our modern society, we are not doing our best to stop this daily tragedy.

In response to this ongoing loss of life in and around our nation’s workplaces, ASSE believes that you could to take one action today that would significantly improve employers’ attention to safety and health risks in their workplaces that kill and injure far too many Americans.  On the regulatory agenda of the U.S. Department of Labor is rulemaking by the Occupational Safety and Health Administration (OSHA) that would require every employer to develop an injury and illness prevention (I2P2) program, helping ensure that every employer takes responsibility both for identifying safety and health risks in each workplace and establishing specific controls to manage those risks.

The adoption of a well-written I2P2 standard by OSHA can be a game-changing step forward by helping establish a more effective dialogue between the employer, employees and regulators.  Instead of the current interaction that focuses far too often on the smallest details of compliance to specific rules, an I2P2 standard could better focus both regulator and employer efforts on the most important risks in each workplace.  This regulatory approach, already used by our key trading partners across the world, would more closely align with the best practices of our profession and the risk-management practices of the nation’s best employers with proven track records of success in protecting workers.  Despite its promise, this rulemaking is stalled in your Administration.

Respectfully, to ensure we are doing our very best to find a better way to protect workers, ASSE requests that you direct your Administration to move forward immediately OSHA’s Injury and Illness Prevention Program rulemaking.  Stakeholder meetings were held in June 2010 and the latest Unified Agenda stated that the SBREFA process was to begin in January of this year.  A national debate on that standard is much needed and long overdue.

We recognize that no single action alone will reduce adequately the injuries, illnesses and deaths in our nation’s workplaces, not even an I2P2 standard.  Greater resources for federal safety and health agencies, meaningful enforcement, expanded employer and employee education about hazards and risks, cooperative programs, greater public awareness, and an increased commitment among employers to protect workers using a risk-based approach are all important.  Every death in a workplace, though, is caused by a failure to properly identify and manage a risk, and an I2P2 in every workplace would greatly increase the identification and management of those risks.

In our roles as professionals and leaders, and as neighbors, colleagues and friends of those impacted by the failure to keep workplaces safe and healthy, we share a duty of care.  We know you also take that duty seriously.  An order by you to move OSHA’s I2P2 rulemaking forward will provide a practical step forward in protecting workers and, after a national event like West, signal that the nation is serious about taking a significant step forward in its commitment to the lives and wellbeing of its workers.

Thank you for your attention to our request.



Richard A. Pollock, CSP


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