AMERICAN SOCIETY
OF SAFETY ENGINEERS

1800 East Oakton Street
Des Plaines, Illinois 60018-2187
847.699.2929
FAX 847.296.3769
www.asse.org

June 8, 2006

The Honorable Samuel Wright Bodman
Secretary
U.S. Department of Energy
Forrestal Building
1000 Independence Avenue, SW
Washington, DC 20585-1000

RE: Merging Office of Environment, Safety and Health into Office of Safety and Security Performance Assurance

Dear Secretary Bodman:

The American Society of Safety Engineers (ASSE) is the oldest and largest society of safety professionals in the world. Founded in 1911, ASSE represents 30,000 dedicated safety, health and environmental (SH&E) professionals, including Certified Safety Professionals, Certified Mine Safety Professionals, Certified Industrial Hygienists, Professional Engineers, academicians, fire protection engineers, and system safety experts, among others. Our members are committed to excellence in carrying out their professional responsibilities for protecting people, property and the environment throughout the world and in every industry, including the federal government.

On behalf of our members, ASSE strongly urges you to reconsider the Department of Energy (DOE) plans to merge its Office of Environment, Safety and Health into the newly established Office of

Safety and Security Performance Assurance. If any agency reorganization can result in more efficient use of resources to assist DOE safety and health professionals in improving DOE workplace safety and health, ASSE would support it. Unfortunately, we have seen nothing to support the idea that this reorganization will bring about improvements in DOE safety and health capabilities.

We are concerned that the merger of these two offices will only confuse the two vitally important safety missions of DOE. Ensuring safety of DOE nuclear facilities and ensuring safety and health of DOE employees are entirely different responsibilities addressing different risks in different ways and by different professional disciplines. In resources and focus, the natural tendency will always be to give more attention to nuclear risks over the seemingly less immediate workplace risks to individuals and other DOE property. Also, in an organization as large as DOE, submerging employee safety and health within another organizational entity can only result in employee confusion about where to go for assistance in addressing concerns and risks. Any DOE reorganization that does not maintain organizational clarity between nuclear and employee safety is certain to result in greater risks to employee safety and health. This cannot be allowed to happen, especially in an organization that has had to address so many challenges to the safety and health of employees and others over the years.

If greater efficiencies are needed at DOE, instead of looking towards unnecessary and unwise organizational changes, DOE management should be working with its highly qualified safety and health professionals to ensure that the resources being expended on safety and health are used efficiently and strategically to help reduce the costs DOE may be incurring from risks to its workers and government property. As the enclosed ASSE white paper on the Return on Investment for Safety, Health and Environmental Management Programs indicates, investment in safety and health results in greater efficiencies for organizations.

Before this merger is considered further, ASSE urges you to demonstrate to Congress exactly what better safety and health capabilities DOE will achieve by merging the Office of Environment, Safety and Health into the Office of Safety and Security Performance and how DOE will ensure that worker safety and health will not take a back seat to nuclear safety and security. ASSE looks forward to that explanation.

If the Society or its members can be of any help to you in addressing these issues, I urge you to contact Dave Heidorn, Manager of Government Affairs and Policy at dheidorn@asse.org or 847/768-3406.

Sincerely,

Jack H. Dobson, Jr., CSP

President

cc: Senator Jeff Bingaman