April 30, 2001
The Honorable Arlen Specter, Chairman
The American Society of Safety Engineers (ASSE) is pleased to comment on the proposed budget for the U.S. Occupational Safety and Health Administration (OSHA). Since ASSE already enjoys a professional relationship with you, through your Pennsylvania constituents, we will forego an introduction and instead enclose a fact sheet on the Society. However, we would like to point out that ASSE, founded in 1911, and now with almost 33,000 members, is the world's oldest, largest, and most diverse society of safety professionals.
We believe that OSHA plays a significant role in maintaining a national focus on the importance of occupational safety and health, thus, it is imperative the Agency be funded in an appropriate manner. We note that the current proposal basically leaves OSHA funding at its previous levels ($400,000 increase), but eliminates 94 full time employees (FTEs). Our research and feedback would appear to indicate that the proposed appropriation is responsible and reasonable and will not hamstring the Agency from being able to function in a proactive manner. The ASSE is only concerned that the proposed flat level of funding not becomes an ongoing pattern. We are steadfast in that belief that OSHA should be evaluated and subsequently funded at an appropriate level, which supports its statutory mission of preventing workplace injuries, illnesses, and fatalities.
ASSE was enthused to see that the statistical area would receive a $700,000 increase under the current proposal. Improvement in statistical evaluation of safety performance will go a long way in improving the USA's competitive position in the world economy, and should hopefully ensure that the United States continues to be a leader in business, education, industry, science, and technology. The view of the Society is that this proposal can go a long way in improving the quantitative and qualitative data used by the public sector in future rulemaking and policy making. Accordingly, sound public policy can only be created if it is based on good science and sound technology. This increase will provide better access to the data and statistics needed to create such policy.
One of our primary concerns with the budget is the proposed $500,000 cut in technical support. We are going to ask the Bush Administration for specific clarification on what areas will be specifically targeted for reductions. We would be reticent to see any cuts impact the OSHA website, which we consider to be of high caliber and quality. The site is accessed on a regular basis by thousands of our members. Access to cutting edge regulatory information is an important function of our profession. We do not want to see this exchange of cutting edge information impeded in any manner. In addition, OSHA and the EU (European Economic Union), recently launched a joint website on international occupational safety and health regulations in different countries. This website is of benefit to a wide range of OSHA stakeholders, and indicates the Agency can provide significant benefits for American commerce and business from the perspective of international business advocacy. These are the types of technological initiatives we are reticent to see cut through the current budget. Finally, with the country placing more and more emphasis on technology, it makes good sense from a public policy perspective to invest in technical support for regulatory agencies such as OSHA including the enhancement of this website.
We also noted that the Safety and Health Standards Directorates are looking at approximately an 8% cut in funding, but the level of activity is expected to increase from five standards to six. ASSE has maintained in the past that OSHA's Safety Standards Directorate is not being adequately funded. This shortfall must change since adequate funding will further assist in reducing the number of fatalities and injuries. However, ASSE is a strong proponent of the concept of doing more with less, consequently these Directorates must be funded in a manner enabling them to produce six standards. If the proposed funding enables the Agency to complete its regulatory agenda, then ASSE is satisfied with the budget for the Directorates.
ASSE is were under the impression that one of the significant issues in Congress regarding this year's OSHA budget would be whether to shift money away from enforcement and federal compliance assistance to State consultation. We note that the current balance between enforcement and consultation remains unchanged from previous years, it is good public policy, and it should be maintained in future appropriation cycles. There have been a number of consultation program administrators pointing out that without credible enforcement there will be less incentive for employers to use consultative services in either the public or private sector. The current balance maintains the national focus on occupational safety and health, yet encourages increased usage of on-staff safety and health professionals in addition to both private and public sector consultation services. Finally, maintaining the existing balance would assist Federal OSHA in improving its image from that of workplace safety policeman to a full service agency, which wants to go beyond compliance.
Finally, ASSE would like to see more direct financial support to promote professional development opportunities for safety and health professionals employed by government agencies including encouragement of professional certification for public sector employees. Professional certification requires adequate education, experience, ongoing training, and passage of rigorous examinations. Supporting professional certification of public sector safety and health professionals will greatly benefit the country. We continue to see little of this philosophy being supported in the budget. But, we believe it should be since it would represent good public policy and a sound investment in the enhancement of occupational safety and health through those who enforce compliance but would now be able to explain how an employer goes from compliance to excellence.
We thank you for your attention to this matter. If the Society can be of any further assistance on this matter please feel free to contact the Society at 847/699-2929.
Samuel J. Gualardo, CSP
ASSE Board of Directors
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