Correspondence, Statements, and Testimony

December 12, 2000

Texas Worker Compensation Commission
Attn: Mr. Joel "Burt" Terrill, Chairman
Southfield Building, MS-3
4000 S. IH-35
Austin, TX 78704-7491


Dear Chairman Terrill:

We appreciate the consideration your department has given in the past to the positions and requests of the American Society of Safety Engineers (ASSE). The purpose of this letter is to request that the Texas Worker Compensation Commission (TWCC) recognize and include the ASSE National Registry of Safety Professionals and Other Registrants in TWCC Rule 166.8, Qualification as a Field Safety Representative.

ASSE is the oldest and largest society of safety professionals in the world. Founded in 1911, ASSE represents almost 33,000 dedicated safety professionals. Falling under the ASSE membership are Certified Safety Professionals, Certified Industrial Hygienists, Professional Engineers, ergonomists, academicians, fire protection engineers, system safety experts, health professionals, 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 state, national, and even world-wide basis.

National Registry of Safety Professionals and Other Registrants
During the past several years, federal and state legislators and administrators of regulatory agencies throughout the country have debated issues of safety and health. The central issue primarily focuses upon and galvanizes around those who deliver or provide such services, the safety professional. These discussions and debates, when reaching a final analysis and conclusion, have invariably addressed the competencies, credentials, education, experience, and continuing professional development of these persons. Some states, through their workers compensation systems, have established registries of these individuals. The American Society of Safety Engineers (ASSE), in recognition of this national concern as well as existing and emerging public policy, established a National Registry of Safety Professionals and Other Registrants. The attached Candidate Handbook sets forth the criteria whereby affected individuals can submit their application for inclusion in the National Registry of Safety Professionals and Other Registrants. In addition, there is also the option of an applicant registering as either a safety practitioner or safety technician/technologist. As you know, a registry is an official record where individuals are enrolled and their qualifications/credentials are filed for later verification by a registering authority or association. The National Registry of Safety Professionals and Other Registrants creates the means and methodology whereby qualified safety professionals and other registrants meeting the criteria can elect to be listed in the Registry.

The Registry has the capability to be categorized by states and enables safety professionals and public policy makers to accomplish several objectives:

* Public policy makers and private sector entities can obtain a numerical listing of registered safety professionals and other registrants at both state and national levels. This is available on the ASSE website at

* When reviewing regulatory action, policy makers will be able to provide and offer specific data involving safety professionals, safety practitioners, and safety technicians/technologists affected by legislation and/or regulation in different states or on the national level.

* As we move to a global economy, there will arise a need to reach across national borders to provide services by qualified safety professionals and other registrants. The Registry has the ability to meet this need.

A review of the National Registry will indicate that if a person is registered as a safety professional or a safety practitioner, they are more than equal to some of the qualifications recognized, and permitted, in the TWCC 166.8 Regulation. The emphasis for registration is placed on accredited certification, licensing, education, experience, or an appropriate combination of education and experience. Of even more significance is the fact that the Registry is available on-line as a complementary service to interested employers or members of the general public. Perhaps the greatest indicator of this commitment to quality was the recent move by The Hartford Financial Services Group, Inc. of The Hartford, Connecticut. The Hartford made a strategic decision to register all of its loss control personnel with the Registry. The Hartford is the first major insurance carrier in the country to use the Registry to formally attest to and promote the knowledge and credentials of its safety professionals who provide loss control consultation across the country.

The foregoing illustrates that inclusion of the Registry in TWCC Rule #166.8 makes sense from an economic, professional, public, and worker protection point of view. A favorable response to our request will benefit your department, safety professionals, and most importantly the Texas workforce we all are dedicated to protect.


Samuel J. Guarlado, CSP
Society President
Michael W. Thompson, CSP
Vice President, ASSE Region III
Houston, Texas


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