September 10, 2001

The Honorable Thomas E. Petri
Chairman, House Committee on Education and the Workforce
2462 Rayburn House Office Building
Washington, DC 20515-4906


Dear Chairman Petri:

The American Society of Safety Engineers (ASSE) is pleased to comment on your recently proposed legislation (H.R.2235), which would codify the OSHA Voluntary Protection Program (VPP). Since we already enjoy a relationship with you and your staff members, we will forego an introduction of ASSE and instead enclose a fact sheet on the Society for your review and reading interest. ASSE has made a conscientious decision to comment on all safety and health related legislation, as we believe it is important to support initiatives, which maintain the national focus on occupational safety, health, and environmental issues.

In regard to H.R. 2235, ASSE has significant interest in this legislation since it codifies the OSHA Voluntary Protection Programs. These programs have been proven to reduce injury and illness rates, while increasing employee morale at the more than 750 sites currently participating in the program. The ASSE membership has long been involved in VPP, as many of our members are responsible for VPP-Star and VPP-Merit Programs with their employers. The current Administrator of the ASSE Management Practice Specialty, Don Jones, also serves on the VPPPA (Voluntary Protection Programs Participants' Association) Board of Directors.

Of additional interest to ASSE members is that the legislation would encourage expansion of the program to smaller businesses. While there has been some debate whether small business would have the resources to qualify, we believe a committed small business operator could participate in VPP if also provided with the appropriate level of support. In fact, there are small businesses that have successfully achieved VPP status, and formal efforts are underway to further increase small business participation in the programs over the next three years. For all of these reasons ASSE has historically taken this position on VPP codification:

ASSE encourages the codification of the "Voluntary Protection Program". It has shown itself to be an excellent tool to reduce workplace injuries/fatalities. The criteria to be accepted into VPP are stringent, and we believe it provides a good balance between both the employers and employees.

This legislation can be of benefit to employees, employers, professional safety and health organizations, government, and the country overall when enacted. ASSE will continue to support the creation of feasible safety and health public policies, which are based on good science, sound technology, and recognized professional practices. This legislation appears to meet these important tenets necessary to generate our support.

We thank you for your attention to this matter, and if we can be of assistance please feel free to contact the Society.

Sincerely yours,

M.E. "Eddie" Greer, CSP
Society President, 2001-2002

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