October 29, 1999

U.S. Department of Labor (S-2315) DOL/OSHA
Attn: Mr. Charles Jeffress, Assistant Secretary of Labor
Occupational Safety and Health Administration (S-2315)
200 Constitution Ave., NW
Washington, DC 20210


Assistant Secretary Jeffress:

The American Society of Safety Engineers (ASSE) appreciates the opportunity to provide comment on the revised OSHA Strategic Plan. We see this as an invitation to further improve the ASSE-OSHA relationship. We point out that ASSE continues to participate very intensively with OSHA-related initiatives. Such participation with OSHA is important for ASSE as the Agency is one of the key areas where the Society lives and works. Generally, the ASSE input to the public policy safety and health process has been positively acted upon, ranging from incorporation of our comments on the abatement rule to the industrial truck regulation. If there are public hearings, ASSE will, at least, be present and, if warranted, provide input to the deliberations.

The purpose of this letter is to submit technical comments from the American Society of Safety Engineers (ASSE) addressing the revised OSHA FY 1999-2004 Strategic Plan:

Strategic Plan Insights
The intent of ASSE is not to speak either for or against the plan, but rather to make comments based upon our member views, existing data, and anecdotal information. Based upon this collective insight, we submit the following:

  • The Strategic Plan is easy to follow and is understandable to virtually all stakeholders. We believe the objectives are short, to the point, and address the key issues impacting the enhancement of occupational safety and health. We found the revision to be much more concise and understandable than the original document. What is of importance is that the document will be reviewed by those outside of the safety and health community, and it is important that these stakeholders be able to understand what the Agency is hoping to accomplish. We see this document as a step in the right direction.

  • Mission Statement (Page 1) - ASSE has no insights to offer other than the Mission Statement is concise and offers a clear view of what the Agency is trying to accomplish.

  • Vision Statement (Page 1) - While we recognize the fact that OSHA is in the Department of Labor (DOL), ASSE does commend OSHA for at least attempting to recognize employers in the Vision Statement. With the significant changes currently taking place in the American economy/society it is important that all private and public sector organizations work together. We see such acknowledgment as being important since through partnership with employees, employers, professional societies, and the government we can further enhance occupational safety and health. The employer/employee viewpoint might be a primary reason why OSHA faces a myriad of concerns from the business community. OSHA has ambitious goals for safety and health performance, and it is crucial that employers also be actively involved, in addition to employee participation, if the plan is to succeed. Our suggestion is that OSHA specifically increase recognition of employers and increase its business relations/outreach efforts. Such expansion will only lead to the enhancement occupational safety and health.

  • The Challenge (Page 3) - We suggest that one of the greatest challenges currently facing OSHA is Doing More With Less. OSHA should specifically recognize that resources, in real dollars, continues to be cut while the Agency continues to have its mission expanded.

  • As the Society pointed out in its 7/21/98 comment addressing PPE, the Agency should consider indicating to all impacted stakeholders how the proposal is of direct economic benefit to the country. Our observation is that the Agency spends a great deal of time indicating how much an employer will have to spend to be in compliance or the expected decrease in cost to employers for lower numbers of injuries, illnesses, and fatalities. However, we maintain that a whole industry has grown around the enactment of safety and health proposals. We suggest that OSHA work with ASSE and organizations to research how much new product, jobs, and consulting opportunities will be generated by OSHA initiated proposals, and how do these increases contribute to the country's overall economic well being.

  • OSHA Strategic Goal #1 (Page 6)- The second sentence of the first full paragraph of OSHA Strategic Goal #1, should state: Workplace injuries, and illnesses, and fatalities…

  • Perhaps we missed it in this document, but ASSE recommended in its original comment that since OSHA is apparently increasing its level of participation with safety and health on the international level (e.g.: Globalized Harmonization System), the Strategic Plan should at least mention involvement with international issues.

  • ASSE pointed out in its original comment that we found little text in the Strategic Plan indicating how OSHA intends to work with voluntary national consensus standards development organizations like ANSI, ASTM, NFPA, etc… We found few changes in the revision, and this continues to puzzle us when one reviews currents standards/regulations and sees the number of voluntary national consensus standards being cited by reference. OMB A-119 and Public Law 104-113 call for the increased utilization of voluntary national consensus standards. It would make sense to us to have some type of plan to accommodate the increased usage of voluntary national consensus standards. This is especially true since the Strategic Plan is to remain in effect through the year 2004. With government agencies placing more and more emphasis on the use of voluntary national consensus standards, it would be appropriate for OSHA to consider them for inclusion in the Strategic Plan. We believe more needs to be written on the use of voluntary national consensus standards in the Strategic plan. Also, we suggest that one of the specific strategies should be that the Agency meet with other executive branch agencies with similar legislative mandates to ascertain how these agencies use the national voluntary consensus standards in its regulations and in implementing the provisions the Morella Amendment to the Technology Transfer Act (Public Law 104-113) and OMB Circular A-119. Finally, a strategy should be that the Agency needs to appoint a specific liaison for the voluntary national consensus standards facilitating bodies, (e.g. ANSI).

  • We commend the Agency for including in Strategic Goal #3 (Page 12), that one of the strategies to achieve Outcome Goals 3.2B and 3.2C is: Develop a strategic human resources plan, a set of core competencies for OSHA staff, and a career development plan for achieving those competencies. ASSE also appreciates the efforts of the Agency in acting upon our suggestion that the Agency support its safety and health professionals earning accredited professional certification, and that OSHA employees be active in the professional safety and health societies/associations, (Revised Strategic Plan Pages 40-41). We believe such support is important since it will lead to a professional OSHA staff possessing cutting edge knowledge of safety and health science and technology. The key to success will be the introduction of proactive mechanisms to encourage safety professionals employed by OSHA to pursue accredited certification or engineering registration. As ASSE also suggested in its 9/22/99 NACOSH testimony, the Agency should reestablish the OSHA Office of Professional Affairs or other name of this former office wherein the professional societies and associations would have an official entrée to the agency.

  • ASSE is also the secretariat for the American National Standard, Z590 Criteria for Establishing Levels of Competence and Certification in the Safety Profession. When this draft standard is approved we suggest that the Agency consider using the standard as a model for evaluating professional development programs for OSHA safety and health professionals. Finally, we suggest that OSHA work with the Office of Personnel Management to revise job descriptions GS-0018, GS-803, and GS-0019 to be more reflective of the credentials required for job placement in the private sector. ASSE commented to the Office of Personnel Management on 2/10/99 addressing this very issue. The comment can be found in the governmental affairs section of the ASSE website in the folder holding correspondence and statements, (http://www.asse.org).

  • Perhaps we missed it in the revised document, however, we continue to see little direct recognition of the third party concept. ASSE understands that OSHA has concern with third party audit and evaluations, however, many agencies in the federal government are either utilizing, or considering using, private sector consultants. ASSE maintains its position that OSHA should at least consider explicitly recognizing the third party issue in the Strategic Plan as a discussion point. We are convinced that the best way to address this issue is through discussion and partnership. Finally, OSHA just released several proposals addressing consultation and the private/public sector. If anything it indicates that the Agency is aware of outside developments and is looking at creative/proactive methods to improve safety and health in the workplace. Finally, such inclusion would be good public relations for the Agency and would indicate to this country's elected leaders that the Agency is willing to work with the private sector on the consultation issue.

We thank you for your attention to this matter, and if you should have any questions or concerns please feel free to contact the Society.

Sincerely Yours,

Frank H. Perry, PE, CSP
Society President, 1999-2000

Copy To:        ASSE Board of Directors
                        ASSE Council on Professional Affairs
                        ASSE Governmental Affairs Committee
                        ASSE Contact List
                        OSHA Docket Office, Docket #C0-5, Room #N-2625


Click here to go back to the ASSE Correspondance, Statement, and Testimony page.