May 7, 2001

National Aeronautics and Space Administration (NASA)
Attn: Mr. Jeff Cullen
NASA Headquarters Office of Procurement
Contract Management Division, (Code H-K)
Two Independence Square
300 E-Street. S.W.
Washington, DC 20546

FEDERAL REGISTER ANNOUNCEMENT - APRIL 5, 2001
SAFETY AND HEALTH SHORT FORM
Volume 66, Number 66, Pages 18051-18053

Dear Mr. Cullen:

As President of the American Society of Safety Engineers (ASSE) for 2000-2001, it is my honor to speak on behalf of the Society. This formal comment addresses the NASA interim rule changes, cited in caption, which impact occupational safety and health performance by contractors. Specifically, ASSE is commenting on the importance being placed on occupational safety and health by NASA. We are not commenting on the aspects of the rule addressing award fees, penalties, or contract structure, as we believe these are outside our purview. Thus, it is important that ASSE be clear in that we do not speak either for or against this interim rule, but rather on the overall concept and philosophy of this initiative.

Since NASA and ASSE already enjoy a strong professional relationship, 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. Many of our members have interest in contractor safety management programs, wherein the goals of NASA falls into the ASSE mission of protecting people, property, and the environment.

ASSE understands and appreciates the intent of NASA in promulgating this interim rule. Improvement in safety performance of NASA work sites will go a long way in improving our position in the world as the leader in aeronautical technology, engineering, and achievement. There is a strong need for NASA to take proactive steps to support and promote safety and health programs based on good science, sound technology, and recognized professional practices. Since almost 80% of NASA's budget is used for contractors, it makes sense to take steps to encourage the best occupational safety and health management programs.

Our membership knows from experience that effective safety and health management programs are a significant plus to any company or organization. We are dedicated to enhancing safety in the workplace and are committed to showing that effective overall safety and health programs, including contractor safety management can positively impact an organization's bottom line. It is also important to note that the interim rule attempts to address the issue of synergy between the public and private sectors to enhance and increase occupational safety and health by illustrating that it should be an integral strategy to the success of an organization.

In conclusion, ASSE continues to have significant interest in this issue and plans on communicating this information to our membership. If you should have any questions, please feel free to contact the Society.

Sincerely Yours,

Samuel J. Gualardo, CSP
ASSE President, 2000-2001

Copy To:

ASSE Board of Directors
ASSE Council on Professional Affairs
ASSE Governmental Affairs Committee
ASSE Public Relations

SJG/CORRS1447
Encl.

     

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