California ASSE Chapters and The Work at Home Issue

January 8, 2000

John J. Howard, MD., Chief
Division of Occupational Safety and Health
P.O. Box 420603
San Francisco, California 94102
Dear Dr. Howard:

ISSUE

Home Work Safety Rules.

The incredible events of the past week regarding Federal OSHA's issuance of a Standards Interpretation regarding OSHA Policies Concerning Employees Working At Home (on 01/04/2000), should send a message to us all. This is an issue that without fail will not go away. Further, it is our opinion that this is an issue that will be actively pursued by diverse groups of individuals in our State and we had better be prepared for the deliberation. We believe that California will be the site for deliberation on this issue.

The point of this communication is to request that, as the head of Cal-OSHA, you include our group (the ASSE–California Governmental Affairs Council) as designated participants for appointment to any established or newly created Advisory Committee, Task Force, or other "groups", formed by Cal-OSHA to address this important issue. We offer valuable resources and expertise to your Agency, and we are certain that our representation and participation with any Cal-OSHA "group" will be a positive addition to the to deliberations that will be required.

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 worldwide basis.

State Membership Breakdown

The 11 California ASSE Chapters are active participants in a wide variety of public and private sector policy issues. There are approximately 2750 ASSE members in our state working to protect people, property, and the environment.

ASSE-California Governmental Affairs Council (CGAC)

The CGAC was officially formed in January 1999. This current organization (CGAC) represents a recreation of the "old" California Governmental Affairs Committee, formed in 1984 when the geographic area of Region I – ASSE was the entire State of California. This "committee" was disbanded when the geographical area of Region was changed to include California, Oregon, Washington, Alaska and Hawaii (June 1997).

Our current organization, The American Society of Safety Engineers-California Governmental Affairs Council, hereafter CGAC, is a coalition of California Chapters of the American Society of Safety Engineers formed for the purpose of addressing Governmental and Legislative Affairs within California. As stated in our bylaws, "All California Chapters of the American Society of Safety Engineers are members of CGAC. Each California Chapter can appoint one representative, called Council Member, to represent their interests in CGAC." Also included in our bylaws, is the provision that on all official business matters, the President of the ASSE-CGAC (or designee) will be the designated spokesperson for the Council.

In closing, we want to once again, acknowledge you and the Agency for all of the "good work" you have done for the benefit of the regulated community. The value of a sound Workplace Safety and Health effort is a central belief that we all have devoted our efforts toward. We sincerely appreciate the Cal-OSHA contributions.


Respectfully,

ASSE Region I-California Governmental/Legislative Affairs Committee

Frank E. Wente, CSP

pc:

***Response from the California Department of Industrial Relations, Division of Occupational Safety and Health***

18 January 2000

Dear Mr. Wente:

Thank you for your letter 8 January 2000 offering the participation of the ASSE California Governmental Affairs Council on any advisory group or task force on the work-at-home issue. If the Division of Occupational Safety and Health hosts any formalized advisory group or task group on the work-at-home issue, I would be pleased to include the ASSE California Governmental Affairs Council.

U.S. Secretary of Labor, Alexis Herman, announced on 5 January 2000 in a Press Release that she had asked the National Economic Council to convene and interagency working group to examine the broad social and economic effects of telecommuting. I also understand that several committees of Congress will conduct hearings in February and March 2000 on the work-at-home issue. I would encourage the ASSE-California Governmental Affairs Council to participate in these important public policy debates.

Meanwhile, I would like to encourage the ASSE-California Governmental Affairs Council to actively participate in the Division's rulemaking to amend Title 8 of the California Code of Regulations, Sections 334, 335.1, and 336. I am enclosing a copy of the rulemaking Notice of Proposed Action and Notice of Public Hearing, Initial Statement of Reasons and the Text of the Proposed Regulations for your group's review. See enclosures. Thank you again for your letter.

Sincerely,

John Howard, Chief

 

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