I am Chris Patton, CSP, and, as President of the American Society of Safety Engineers, I am proud to be here today to share the views of my fellow 32,000 member safety, health and environmental (SH&E) professionals and commend OSHA for listening to us. We appreciate this unprecedented opportunity to join with other stakeholders to share some thoughts about the issues facing OSHA and the entire occupational safety and health community.
ASSE has asked that OSHA be a leader in bringing this community together, and we hope OSHA can hold similar opportunities to share views on issues this community finds difficult to address – PELs, updating OSHA standards with voluntary consensus standards, and even ergonomics, to name a few.
My brief remarks only highlight the many detailed ideas we have submitted for the record of this meeting. But each idea reflects the hard-won experience gained by our members on the front lines helping manage the safety and health risks that threaten workers and keep companies from achieving the bottom line results they need to be competitive in today’s global marketplace.
Our members experience first-hand when OSHA works well and when it does not. They deal with highly competent field staff and those who fail to understand fully the real risks in a workplace. They live with OSHA standards that help them protect workers and standards that make their work unnecessarily complicated. They see OSHA build relationships to advance safety and, also, see OSHA drive employers away from any interest in reaching out to OSHA. But, make no mistake, they want OSHA to work well.
While not easy to summarize in this short time, ASSE’s detailed comments can be brought together into several broad ideas.
To the first question you asked, what can be done to improve employer and employee efforts to identify and address workplace hazards?
The answer is clear to our members – adopt a safety and health program rule. The risk assessments throughout US workplaces such a standard would cause is by far be the best way to address both current and emerging hazards for which OSHA will find it increasingly difficult to set standards. ASSE is pleased that the current leadership of OSHA has stated an interest in such a standard, and we look forward to supporting that effort.
Also, moving towards the adoption of performance-based OSHA standards would be a significant help. Performance-based standards encourage employers to take responsibility for addressing risks that being told to follow a proscriptive standard cannot do. Not only are proscriptive standards difficult to meet across varying workplaces, they will not meet future needs. Our members already are being asked by employers to meet growing international performance-based standards. OSHA needs to move forward in this direction as well.
The answer to your third question, how can the agency improve its efforts to engage stakeholders in programs and initiatives?
Our members value greatly OSHA’s cooperative programs. ASSE is proud to be an Alliance partner, and we know the cooperation it has fostered. From our perspective, the Alliance has helped many OSHA staff feel much more a part of the profession, an important part of staff development we urge OSHA to support even more than it has.
While funding in the proposed FY 2011 budget for compliance assistance is not insignificant, ASSE is troubled by OSHA’s unwillingness to support the Voluntary Protection Program. VPP helps our members solidify and expand their employers’ commitment to safety, often not easy to achieve in even the best corporations. ASSE understands OSHA’s intent to better reach employers not committed to safety. But, turning its back on a program that directly helps our members do their work is short-sighted. OSHA will not “improve its efforts to engage stakeholders” by failing to support VPP.
As to improving the standard development process, one of the key challenges facing OSHA is its inability to keep up with the relatively rapid advancements in occupational safety and health voluntary consensus standards. ASSE generally supported the performance-oriented approach that would set a general requirement coupled with a non-mandatory appendix of appropriate national consensus standards proposed in its rulemaking Updating OSHA Standards Based on National Consensus Standards; Personal Protective Equipment (OSHA-2007-0044). We urge OSHA to move that proposal forward. A solution is long overdue.
Throughout our submitted comments are repeated calls from our members for OSHA to move quickly into the future. Whether performance based standards, looking to control banding to deal with exposure limits, or addressing nanotechnology and other emerging technologies, they want OSHA to join them where their employers are already demanding that they be.
They particularly want OSHA and its staff to join them in the social media revolution occurring all around us. They want to engage OSHA in a new level of shared professionalism and openness.
We SH&E professionals may be the most dynamic profession on the globe, constantly reacting to change. If OSHA cannot keep up with the same demands we face, it risks irrelevance.
Finally, long overdue by OSHA and, admittedly, ASSE also is a thoughtful examination of what constitutes a “competent person” in OSHA standards. In most fields, research and commitment to professional standards has resulted in a fairly clear understanding of the levels of responsibility appropriate for certain levels of training and experience. That does not exist in occupational safety and health. When so much attention is given to how to protect workers through standards, we are missing a needed discussion about who provides the professional leadership to ensure a standard is appropriately met. ASSE looks forward to working with OSHA and NIOSH to begin to examine this issue.
Again, we appreciate this opportunity to share in this dialogue and look forward to future opportunities to talk in depth about the issues we’ve shared here today. Thank you.