February 10, 1999

Office of Personnel Management
Attn: Ms. Janice R. Lachance, Director
Theodore Roosevelt Federal Building, (#5305)
1900 E. Street, NW
Washington, DC 20415

DOL/OSHA POSITION ANNOUNCMENT
#DA 96-32, GS-803, GS-018, AND GS-019

Director Lachance:

The purpose of this letter from the American Society of Safety Engineers (ASSE) is to request your assistance in obtaining a revision to the position classification standards for GS-803 Safety Engineering Series, GS-018 Occupational Safety and Health Management Series, and GS-019 Safety Technician Series. ASSE recently received a copy of OSHA/DOL Announcement DA 96-32. These standards exclude significant numbers of qualified safety professionals from the position.

ASSE is committed to enhancing professionalism in the safety profession for federal employees. Our research indicates that only way to resolve such issues is to request that GS-803, GS-018, and GS-109 be revised. However, before beginning allow me to introduce the American Society of Safety Engineers (ASSE) of which I have the honor of serving as its President:

INTRODUCTION
The American Society of Safety Engineers (ASSE), is the oldest and largest Society of Safety Professionals in the world. Founded in 1911, ASSE represents in excess of 32,000 dedicated safety professionals. Included in this membership are Certified Safety Professionals, Professional Engineers, ergonomists, academicians, fire protection engineers, system safety experts, industrial hygienists, physicians, occupational nurses, and an impressive collection of other disciplines, skills, and backgrounds. We pride ourselves on our dedication to excellence, expertise, and commitment to the protection of people, property, and environment on a world-wide basis.

ASSE serves as Secretariat of seven (7) American National Standards Institute Committees (ANSI) developing safety and health standards which are used by private sector organizations as well as state/Federal governmental agencies such as MSHA, OSHA, etc... ASSE members also sit on over forty (40) additional standards development committees and the Society sponsors educational sessions on standards development. The Society also has eleven (11) technical divisions consisting of: Construction, Consultants, Engineering, Environmental, Health Care, International, Management, Public Sector, Risk Management and Insurance, Mining, and Transportation. The ASSE members included in these divisions, which includes many federal employees, are leaders in their field with the knowledge and expertise needed to move safety and health forward on a global level, (Attachment #1).

GS-803 ISSUE OF CONCERN
Enclosed with this letter is Position Announcement #DA 96-32 which was posted at the OSHA Dallas/Fort Worth Area Office, (Attachment #2). The announcement is several years old, however, this is an excellent example of the concerns we are trying to raise. ASSE's recommendation is that the Office of Personnel Management use this flawed announcement as a justification to revise GS-803 along the suggestions cited in this letter. ASSE maintains this position description inappropriately excludes significant numbers of qualified safety professionals. The result is that agencies such as DOL/OSHA are encouraged to employ Professional Engineers (PE) regardless of their overall background in the safety profession. Specifically, we offer the following on Position Announcement DA 96-32:

  • In Section (A) Degree: ASSE maintains that safety degrees which are accredited by the Accreditation Board for Engineering and Technology (ABET) should be recognized. In fact, we are puzzled why any engineering degree is accepted, but an ABET accredited degree in the field of safety is not. We also recommend the GS-803 Standard be revised to include safety degrees which are accredited by ABET. We have included the curriculum guidelines required for a safety degree to be accredited by ABET, (Attachment #3).
  • Registration in Section (B-1) as a Professional Engineer is acceptable. However, we recommend that the emphasis be placed on registration as a PE in Safety. At the current time, only Massachusetts offers the PE in Safety registration, and California continues to maintains registrations of a significant number of PEs in safety. We question why any P.E. registration would be acceptable. As an example, there are a number of states considering whether software engineers should be licensed/registered, thus, making them, as uniquely as it seems, eligible. Under these same guidelines an individual with background, experience, and credentials in the safety profession would be excluded. Several states have also considered licensing safety professionals.
  • We suggest that the GS-803 Standard be changed to indicate that a safety professional licensed by any state would meet the intent of the standard. Such an approach is an efficient/effective proactive way to prepare for future safety and health legislation and regulation impacting the issue of competence in the safety profession.
  • We recommend that professional certification should also be considered in Section (B-1), and specifically the CSP or other nationally recognized and accredited certifications, (CESB or NCCA, Guidelines attached as Attachment #4). We have heard some views expressed that the GS-803 standard is necessary to ensure those holding the position have sufficient engineering knowledge and background. If this indeed, a serious concern, then we would recommend that any CSP passing the Comprehensive Exam, the Engineering Specialty Examination, or Systems Safety Examination qualify under Section (A). ASSE also points out that the Certified Hazardous Materials Manager (CHMM), sponsored by the Institute of Hazardous Materials Management (IHMM), is also another certification worthy of review since it has been accredited by the CESB. We have attached information on the CHMM as Attachment #5.
We offer the following to support our request on the CSP:

The Board of Certified Safety Professionals (BCSP) administers a widely accepted and internationally recognized professional certification offering the designation of Certified Safety Professional (CSP). Applicants must satisfy stringent formal education, work experience, and continuing educational requirements for maintenance of the designation. Individuals are also required to complete two (2) comprehensive "day long" examinations, adhere to a written code of ethics, and continue maintenance of their certification through other educational means, (Attachment #6).

In order to qualify to take the CSP exam an individual must possess at least an associates degree in safety, a baccalaureate degree in safety or the other "hard" sciences from an accredited university, four years of professional safety experience acceptable to the Board of Certified Safety Professionals, and achievement of passing scores on each of the two (2) written exams. ASSE maintains that it makes more sense from a public policy perspective to include CSPs than provide blanket acceptance of any Professional Engineer regardless of background or experience. The current GS-803 Standard, in effect, excludes the very people most qualified to enhance safety engineering. As additional support we have also included a collection of different state/national pieces of legislation and regulation which recognize the importance of the CSP to safety engineering and safety and health management. Some of the key examples include:

  • The New York State Engineering Registration Board reviewed the BCSP Comprehensive Practice Examination and several of the specialty examinations. The Registration Board determined these examinations have a level of rigor comparable to the Principles of Practice Examination used to license engineers in the state of New York, (Attachment #7).
  • The Registration Division of the Commonwealth of Massachusetts uses the BCSP Comprehensive Examination, or, BCSP Specialty Examinations in Engineering Aspects, Product Safety Aspects, and Systems Safety Aspects for the Massachusetts Principles and Practices of Engineering (PPE) Examination in Safety Engineering. If a CSP is certified through one of the above listed examinations, the PPE examination is not required, (Attachment #7).
  • Licensing of safety professionals has been considered in two (2) states (New York and Texas). Both of the proposals specifically recognized the CSP, and the duties and responsibilities cited in this legislation was consistent with the duties and responsibilities cited in Position Announcement DA 96-32, (Attachment #7).
  • The CSP is recognized in a variety of different national standards regulated by agencies such as OSHA, EPA, and the DOD. State legislation protecting the CSP has also been introduced in fourteen states, and enacted in four of them, (Attachment #7).
  • The U.S. Department of the Interior, Bureau of Reclamation accepts the CSP for positions in the GS-803 series, (Attachment #7).
  • Numerous federal agencies, even including the Central Intelligence Agency and the U.S. State Department, accept and recognize the CSP. For many position openings the CSP is either preferred or a requirement, (Attachment #7).
ASSE truly believes that the Office of Personnel Management excluded CSPs from GS-803 due to a simple oversight. We recommend that either the CSP be included overall or any CSP passing the Comprehensive Exam or either the Engineering or Systems Safety Examination be automatically included.

GS-018 AND GS-019 CONCERNS
ASSE was very concerned to read in the GS-018 Occupational Safety and Health Management Series and GS-019 Safety Technician Series there are meager, if any specific, requirements listed for a person to work in the safety profession as a federal employee. This is of serious concern since these individuals have the mission of protecting the safety and health of the American workforce.

During the past several years, federal and state legislators and administrators of regulatory agencies throughout the country have debated issues of safety and health. The central issue primarily focuses upon and galvanizes around those who deliver or provide such services, the safety professional. These discussions and debates, when reaching a final analysis and conclusion, have invariably addressed the competencies, credentials, education, experience, and continuing professional development of these persons. We are puzzled as to why the U.S. Office of Personnel Management also does not recognize these factors and work to raise the level of professionalism of safety professionals in the federal government.

The American Society of Safety Engineers (ASSE), in recognition of these state and national concerns as well as existing and emerging public policy has published a draft voluntary national consensus standard Z590 Establishing Levels of Competence and Certification in Safety Profession. The draft standard is attached for your review (Attachment #8), and we urge you to review the draft standard as it provides a balanced approach to establishing competence for safety professionals, safety practitioners, and safety technicians. Such a document should be considered during revision of GS-018 and GS-019.

In addition, ASSE has recently (1/18/99) launched a new initiative which should provide assistance in the area of professional competence and recognition. This new initiative is titled the National Registry of Safety Professionals and Other Registrants. We have attached a copy of the Candidate Handbook for your review, (Attachment #9). This Candidate Handbook sets forth the criteria whereby affected individuals can submit their application for inclusion in the National Registry of Safety Professionals and Other Registrants.

A registry is an official record where individuals are enrolled at a fee and their qualifications/credentials are filed for later verification by a registering authority or association. Registries are different in concept from directories. A directory differs from a registry in that it is an alphabetical index of the names and addresses of persons in an area, organization, or category of people. The National Registry of Safety Professionals and Other Registrants creates the means and methodology whereby any qualified safety professional and other registrants meeting the criteria can elect to be listed in the Registry. Serving as Registrar is the American Society of Safety Engineers. The Registry has the capability to be categorized by state and enables safety professionals and other registrants to accomplish several objectives:

  • Public policy makers like yourself and private sector entities can obtain a numerical listing of registered safety professionals and other registrants at both state and national levels.
  • When commenting on legislation and regulation the Registrar would be able to provide and offer specific data involving safety professionals, safety practitioners, and safety technicians/technologists affected by legislation and/or regulation in different states or on the national level.
  • As we move to a global economy, there will arise a need to reach across national borders to provide services by qualified safety professionals and other registrants.
  • There are significant internal and external drivers in safety and health for such a program, (e.g.: governmental regulation, professional recognition issues), and the Registry provides an efficient and effective means of meeting these drivers.
  • With such a national recognition tool in place, safety professionals and other registrants will be more informed to be proactive in issues affecting the profession.
We urge the Office of Personnel Management to review this document as a measurement tool for future hiring and promotion of individuals for the GS-018 and GS-019 series. In addition, We have also enclosed the following ASSE materials as Attachment #10:
  1. ASSE Scope and Functions of the Safety Professional
  2. Careers in the Safety Profession
  3. Career Guide to the Safety Profession
During April, 1999, our Governmental Affairs Committee annually meets in Washington, DC. We would like to have the opportunity at that time to meet with appropriate staff members as to how these classification series can be revised.

We thank you for your attention to this matter, and look forward to working with you in the future on this issue.

Sincerely Yours,

Fred F. Fleming, CSP, OHST
Society President 1998-1999

FF/TRF/CORRS1101


     

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