June 4, 1999

ASSE COMPREHENSIVE POSITION STATEMENT

APPROPRIATIONS FOR SAFETY AND HEALTH AGENCIES

The purpose of this statement from the American Society of Safety Engineers (ASSE) is to offer insight on the need for increased appropriations to support the U.S. Occupational Safety and Health Administration (OSHA), U.S. Mine Safety and Health Administration (MSHA), National Institute for Occupational Safety and Health (NIOSH), U.S. Chemical Safety and Hazard Investigation Board (CSB), and the U.S. Environmental Protection Agency (EPA).

INTRODUCTION

Founded in 1911, our membership currently numbers over 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 world-wide basis.

SOCIETY SUPPORT FOR SAFETY AND HEALTH AGENCIES

ASSE supports federal safety and health agencies such as OSHA, MSHA, NIOSH, CSB, and EPA. We believe these organizations help maintain a national focus on the importance of occupational safety and health.

OSHA AND MSHA APPROPRIATIONS

We point to the following key points of consideration for OSHA/MSHA appropriations:

  • OSHA and MSHA are the primary government agencies enforcing this countryís safety and health laws.

  • OSHA and MSHA educate professionals, provide training, and develop innovative solutions to occupational safety and health problems. One example of such proactive efforts has been the 1997 Ergonomics Best Practices Conference. OSHA and MSHA have committed themselves to working with a variety of partners to design programs which stress efficient/effective safety and health compliance being conducted in the spirit of partnership.

  • OSHA assistance to small business through consultation and educational/informational contact has been successful, and could be utilized in any independent peer review process, (e.g.: SBREFA).

  • Significant OSHA and MSHA training initiatives help ensure that the body of knowledge needed to prevent fatalities, injuries, and illnesses is enhanced.

  • OSHA has continued to work with NIOSH to support NORA. NORA is an excellent example of the private/public sector partnership encouraged by this countryís congressional leaders.

  • Innovative public sector safety and health administrators are looking at new ways to reinvent their agencies and create a new spirit of partnership.

 

OSHA FUNDING

OSHA is presently looking at a proposed 10% budget increase of $35 million. Most of this funding has apparently been earmarked to add 119 positions for compliance assistance, enforcement, and alternative dispute resolution programs.

ASSE also maintains that OSHA appropriate $500,000 for the following issues:

  1. OSHA needs to conduct a formal comparison/study of DOL/OSHA safety and health professionalsí salaries to the private sector. The Society maintains that the agency, and specifically the state-plan-states, are not able to offer competitive salaries to high quality safety and health professionals. Such a comparison/study will enable the agency to more efficiently/effectively monitor their ability to recruit and hire cutting edge professionals. Our position is that the agencies should be in the position to competitively recruit the nationís best trained professionals. It has been consistently been brought to our attention that some of the countryís finest safety and health professionals working with government agencies do not make a career of civil service due to the significant disparity in salaries.
  2. Advocate professional certification for safety and health professionals employed by the agency. One of ASSEís biggest concerns is our belief that OSHA employees are not as likely to pursue professional certification as their private sector counterparts. Professional certification requires adequate education, experience, ongoing training, and being able to pass a series of rigorous examinations. Supporting private sector certification is of benefit to the country. These appropriations should be used to hold workshops on the need for certification, reimburse OSHA employees for exam and registration fees, and the purchasing of study materials. ASSE estimates that the cost of professional certification for one professional is $1,500.
  3. Increase training opportunities for OSHA personnel outside of the agency. Most OSHA training is directed at compliance related issues. If the agency is to get involved in consultation, there will be a significant need for additional knowledge besides that of compliance. The private sector has the ability to provide this knowledge in an efficient/effective manner. OSHA safety and health professionals need financial support if they are to be able to access this knowledge.

ASSE has concern with the apparent expansion of OSHA compliance assistance services. In the 2/3/99 issue of the BNA Safety and Health Reporter, there is a statement which reads as follows:

An additional 67 staff positions are budgeted for the program, and they would allow the agency to place a technical specialist "within reach of every American business" Jeffress said.

While we encourage compliance assistance, ASSE is opposed to what we perceive to be movement toward expansion of complimentary safety and health consultation services. ASSE maintains the following:

  • OSHA should work with ASSE on a program to encourage private sector consultation. Receiving additional appropriations to duplicate what already exists is not good public policy and undercuts the private sector.

  • OSHA compliance/consultation would be geared strictly toward compliance. A private sector consultation would focus on compliance, and the overall enhancement/improvement of an organizationís safety and health program. Our concern is that such a program might encourage some employers to pursue government consultation if it is complimentary. ASSE believes compliance with OSHA on some occasions is the bare minimum of an occupational safety and health program.

  • We think it would make more sense from a public policy perspective for the Agency to work with the Internal Revenue Service on a system that would award tax credits for those organizations choosing to use the services of safety and health consultant.

Future Issues for the OSHA Safety Standards Directorate

The Society maintains that the OSHA Safety Standards Directorate is not being funded to reach its key objective - the reduction of traumatic fatalities and injuries. The following are areas which should specifically receive additional support:

  • The number of staff positions working on safety standards needs to be increased. For example, ASSE understands that there are only two (2) electrical engineers with safety experience working in the Directorate. We see this as being woefully inadequate. In addition, at this time, approximately thirty (30) positions are allocated to safety standards development. We believe this is inadequate since this Directorate addresses a diversity of issues ranging from that of confined spaces to electrical safety. We also recommend that the Directorate have staff specifically dedicated to risk assessment as applied to standards and efficient/effective guidelines for use in reducing hazards.

The Safety Standards Directorate needs additional funding to support ongoing efforts for using data to guide policy making decisions. Professional judgment is required during the standards development process, however, there needs to more focused attention on significant hazards which can be reduced in an efficient/effective manner. The Safety Standards Directorate needs to explore how data can be used to drive more effective/efficient safety standards.

Finally, ASSE opposes any rider on OSHA which would prohibit the Agency from pursuing a standard addressing cumulative trauma disorder/ergonomics. ASSE believes there is adequate science supporting the development of a standard. While we agree that there should be ongoing research, the pursuit of such a standard should not be delayed.

MSHA FUNDING

MSHA is currently being planned for a total budget of $227 million which is $13 million higher than FY 1999 funding levels. ASSE also believes that increased appropriations should go to the following areas since these programs will impact the country in a beneficial manner:

  • Expand outreach to specific hazard programs
  • Continue the development of an efficient/effective cost accounting system

ASSE also recommends encouragement of professional certification for safety and health mining professionals employed by MSHA. Professional certification requires adequate education, experience, ongoing training, and being able to pass a series of rigorous examinations. Supporting private sector certification is of benefit to the country. Appropriations should be used to hold workshops on the need for certification, reimburse MSHA employees for exam and registration fees, and the purchasing of study materials. ASSE estimates that the cost of professional certification for one professional is $1,500.

NIOSH APPROPRIATIONS

We point to the following key points of consideration for NIOSH appropriations:

  • NIOSH is the only government entity conducting valuable research into the causes of occupational fatalities, injuries, and illnesses and how they can be avoided.

  • NIOSH educates professionals, provides training, and develops innovative solutions to occupational safety and health problems. Examples of such proactive efforts have been the National Occupational Research Injury Research Symposium (NOIRS), 1998 Control Technologies Symposium, the 1997 Ergonomics Best Practices Conference, and the 1997 Silicosis Conference. For each event NIOSH worked with a variety of partners to design a conference which stressed efficient/effective safety and health results, rather than regulatory compliance.

  • NIOSH assistance to small business through consultation, and education, and additional information has been successful, and could also be utilized in any independent peer review process.

  • NIOSH occupational safety and health training through Educational Resource Centers (ERCs) at academic institutes across the country has created a pool of significant talent to help reduce occupational fatalities, injuries, and illnesses.

  • NIOSH has had direct positive impact on the United States through its proactive work in crafting a National Occupational Research Agenda (NORA). NORA is an excellent example of the private/public sector partnership encouraged by this countryís congressional leaders.

  • NIOSH funds high quality peer-reviewed scientific research, and uses NORA to guide the national focus on occupational safety and health to research to where it will provide the most benefit. This research translates into information, technologies, and programs which assists U.S businesses in protecting the safety and health of employees.

  • The world-wide need for safety professionals is expanding. We would like to point out that in the past, NIOSH provided grants to institutions of higher learning for the funding of curricula in occupational safety and health. When a significant portion of this funding ceased, many of these university programs were terminated, resulting in the current short-fall of occupational safety and health professionals entering the field.

ASSE strongly recommends the following:

  • An additional $20 million increase in the research budget for NIOSH is appropriate in order to support the ongoing activities related to NORA ($15 million) and the Educational Research Centers ($5 million). This increase will enable the United States to guide occupational safety and health research over the next decade and enhance worker protection in an efficient/effective manner.

  • The NIOSH Safety Research Division needs to be appropriately funded to reach its key objective - research into effective/efficient ways of reducing traumatic occupational fatalities and injuries. We maintain NIOSH needs to plan additional expenditures for the following areas:

  1. The Safety Research Division has experienced significant success in conducting follow-up interviews with injured workers. The result has been reliable data and anecdotal information which can be used for researching effective hazard controls. ASSE maintains that such information is of value in both the public and private sectors as it can assist in developing proactive hazard control methods, and reducing the direct/indirect costs of workplace injuries and/or fatalities. Past estimates indicated that expansion of the program requires an additional $500,000 in appropriations. This investment in the future will provide direct and tangible benefit to employees, and improve the competitive advantage of American companies in domestic and international markets.
  2. ASSE is a strong supporter of the NIOSH FACE Program (Fatality Assessment and Control Evaluation Program). FACE personnel conduct epidemiological investigations of fatal workplace traumatic injuries. The results of the program have been impressive. NIOSH works with state health department through cooperative agreements to support state-based FACE program. The FACE program includes surveillance, prevention, and investigation. ASSE believes there is a strong need to expand the program nationally. Once again, we see such an appropriation as being an investment in the safety and health of the workforce and improving the competitive advantage of American companies in the foreign and domestic market. FACE is being expanded in the proposed budget, but we suggest that further expansion of the FACE program to the national level would require an additional appropriation of $3.5 million.
  3. There is a significant need for the Safety Research Division to conduct additional research into the evaluation of the effectiveness of injury/fatality prevention measures. Specifically, we are recommending that research needs to be conducted into the evaluation of the effectiveness of employer safety programs. This would include effective safety training. Safety training is an important issue to this countryís safety professionals. We need to know what works and what does not, and be aware of how effective training can be conducted with workplace efficiency. This type of research provides direct and tangible benefits to both employees and employers. To conduct this type of beneficial research would necessitate an appropriation of an additional $2.5 million.

We point out that the Safety Research division currently receives approximately $13 million per year in appropriations. The recommended increases would bring the total to approximately $20 million. ASSE maintains that the safety of the American workforce and improving this countryís to ability to compete on a national level warrants additional investment.

CSB APPROPRIATIONS

After reviewing the proposed administration budget numbers for the CSB we put forth the following position:

The administrationís proposed budget for the CSB is far below the expectations of this countryís safety professionals, and we are very concerned this shortfall is a serious obstacle in preventing injuries, illnesses, and fatalities due to chemical incidents and releases. The Administration budget request of $7.5 million for the Chemical Safety Board does not say much to the public sectorís commitment in maintaining a national focus on the importance of occupational safety and health. We call on you to ensure that this new agency is funded in a manner which allows the CSB to meet its key objectives which are based on congressional mandates. Under the current budget scenario we see this as not possible, thus, leaving the American worker and general public open to potentially serious or catastrophic harm.

We point to the following key points of consideration for CSB appropriations:

  • CSB has already initiated nine investigations and 21 Reviews of Chemical Incidents. ASSE perceives these actions as an important consideration since the agency is maintaining a significant level of activity with inadequate funding. This indicates to us that the agency is a well run organization from both private and public sector perspectives.

  • With limited funding the CSB developed a basic infrastructure for operations which is consistent with its Congressional mandate.

  • The CSB implemented a business plan which enables it to meet the legal requirements established under the enabling legislation.

  • CSB has made extraordinary attempts to include key public and private stakeholders, such as professional safety and health organizations, organized labor, industry and commercial representation, administration officials, and members of Congress.

  • The CSB is the first National Repository of Chemical Safety Information and has established the First Consolidated Statistical Database.

We point out that the CSB operated with $4 million for nine (9) months in 1997 and $6.5 million in 1998. The administrationís current budget request is $7.5 million for CSB, which is woefully inadequate for the agency to achieve its basic chemical safety goals. Our request is that your committee appropriate an additional $5 million to increase the CSB budget for a total of $12.5 million. This increase will enable the United States to guide occupational safety and health investigations and research involving chemicals over the next decade and enhance worker protection in an efficient/effective manner.

EPA APPROPRIATIONS

ASSE supports the Environmental Protection Agency since it helps maintain a national focus on the importance of occupational safety and health. In fact, ASSE member surveys indicate that next to OSHA, EPA is the agency our members believe has the most impact on safety and health in the workplace. We acknowledge that many of the activities conducted by EPA do not necessarily relate directly to our members professional functions, there are EPA programs which have direct on workplace safety, (e.g.: Risk Management). Of specific interest is the fact that while this country has some of the toughest environmental protection laws in the world, our economy is very strong, (this year an $80 billion surplus expected).

ASSE is encouraged by proactive EPA initiatives which enhance occupational safety and health. Some of these initiatives include:

  • EPA Environmental Leadership Program Proposal
  • Pilot Program for Voluntary Third Party Audit/Evaluations
  • EPA Risk Management

Of specific interest is the fact that EPA appears to be committed to working with the private sector on cooperative initiatives to enhance safety and health. We see this as a win-win strategy for EPA, enhancement of safety and health, and an improved environment for the American people. ASSE supports increased appropriations to the following areas:

  • Clean Air Partnership Fund
  • Proactive Efforts to Increase the Utilization of Third Party Audits/Evaluations
  • Chemical Safety Enhancements
  • Ongoing Research Efforts

ASSE also recommends encouragement of professional certification for safety and health professionals employed by EPA. Professional certification requires adequate education, experience, ongoing training, and being able to pass a series of rigorous examinations. Supporting private sector certification is of benefit to the country. Appropriations should be used to hold workshops on the need for certification, reimburse EPA employees for exam and registration fees, and the purchasing of study materials. ASSE estimates that the cost of professional certification for one professional is $1,500.

We thank you for your attention to this matter. If the Society can be of any further assistance on this matter please feel free to contact the Society at 847/699-2929.

Sincerely,

Fred F. Fleming, CSP, OHST

Society President 1998-1999

Copy To:
ASSE Board of Directors
ASSE Council on Professional Affairs
ASSE Governmental Affairs Committee
ASSE Contact List

FF/TRF/CORRS1183


     

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