Testimony of the

American Society of Safety Engineers (ASSE)

Concerning

The Use of Voluntary National Consensus Standards to Enhance Safety and Health in American Workplaces

to the

Committee on Education and Workforce

U.S. House of Representatives

November 1, 2001

Chairman and Members of the Committee:

The American Society of Safety Engineers (ASSE) is the oldest and largest society of safety professionals in the world. Founded in 1911, ASSE represents more than 33,000 dedicated safety professionals, and our members are proud of the accomplishments we have made in safeguarding workplaces for the American worker.

ASSE is pleased to offer this testimony in full support of voluntary national consensus standards. The current process of determining voluntary standards is more than adequate to enhance safety and health in the workplace and to ensure fairness, openness, and due process in establishing such standards.

As the secretariat of eight (8) American National Standards (ANSI) committees and projects, ASSE understands fully the voluntary consensus standard process. Nearly forty (40) Society members serve on various ANSI, NFPA, ASME, and ASTM committees involved in setting voluntary standards. These are the organizations that safety professionals rely on when considering safety and health standards, but there are also other highly regarded organizations developing standards impacting occupational safety and health, including the American Dental Association.

ASSE supports the increased utilization of consensus standards in the formulation of legislation and regulation for occupation safety and health. Governmental agencies such as OSHA, CPSC, and NHTSA should be encouraged to utilize these consensus standards as they provide an efficient and effective alternative to traditional public sector rule making.

ASSE also commends public policies such as Public Law 104-113, "The National Technology Transfer and Advancement Act of 1995," and OMB Circular "A-119 Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities." ASSE has commented to a variety of agencies about the use of OMB A-119 in various safety and health venues, and the response has generally been very positive. Some of these agencies include OSHA, MSHA, and the U.S. Department of Defense.

ASSE encourages the utilization of national consensus standards as an effective and efficient option for meeting the demand of increased regulation and legislation in occupational safety and health for the following reasons:

  • the consensus method provides for a balance between competing interests;
  • the voluntary nature of consensus standards enables users to adapt provisions to meet unusual circumstances; and
  • much lower standards development costs are achieved.
ASSE historically has supported standards created through ANSI because of the rigorous process maintained by ANSI that ensures due process. It is important to note that the concept of consensus and the required input of most, if not all, materially interested parties required by ANSI is critical to the consensus system. ANSI also requires the exercise of care in the makeup and organization of consensus committees to assure the integrity of the process. Without such careful dedication to fairness and due process, the validity of a consensus standard would be suspect. It is important to safeguard the opportunity stakeholders have to make their views known and to pursue due process if they question the fairness of their treatment.

For the Committee's further information, enclosed is a September 1999 statement ASSE made to NACOSH concerning the Use of Voluntary National Consensus Standards to improve the regulatory process. The statement reflects how ASSE has been able to work together with federal agencies on safety, health, and environmental rulemaking. When both the private and public sectors are able to rely on an accepted standard-making process, effective standards based on good science and technology result.

As always, ASSE and its members stand ready to assist in the Committee's efforts to understand fully the value of the long-established voluntary standard-setting process in the private sector.



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