AMERICAN SOCIETY
OF SAFETY ENGINEERS

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

October 5, 2006

Carolyn W. Merritt

Chairman

US Chemical Safety and Hazard Investigation Board

2175 K Street, NW Suite 650

Washington, DC 20037-1809

RE: FY 2007-2012 Strategic Plan

Dear Chairman Merritt:

The American Society of Safety Engineers (ASSE) has long supported the mission and work of the U.S. Chemical Safety and Hazard Investigation Board (CSB). From the CSB’s inception, our members have understood the agency’s unique value in investigating chemical accidents and making recommendations to help ensure that the same accidents do not occur again. ASSE is proud to share what CSB learns with its members. Without a doubt, CSB’s work helps ASSE’s member safety, health and environmental (SH&E) professionals fulfill their responsibility for preventing death, injury and illness in the workplace.

In general, the draft Strategic Plan for Fiscal Years 2007-2012 should be commended. It reflects an apparently honest assessment of CSB’s strengths and some weaknesses. If followed, ASSE has little doubt that the CSB can succeed in continuing to address the risks of chemical accidents.

ASSE does have one area of concern, however, and urges you to address the concern in a final draft. In at least two goals, the CSB itself raises a concern about appropriate staffing. Under Goal 2, the draft states, “The CSB has lacked a specialized staff for conducting safety studies…” And in Goal 5, it states, “(A) major challenge is to recruit and develop the skills necessary to implement the human capital vision.”

To address these concerns, ASSE urges you to add to Key Strategies under both these goals increased support for staff as well as Board members’ pursuit of volunteer safety and health professional certifications from organizations like the Board of Certified Safety Professionals (BCSP) and American Board of Industrial Hygiene (ABIH). These are both organizations that offer highly respected and widely accepted professional certifications and are both accredited by the National Commission for Certifying Agencies (NCCA) and Council of Engineering and Science Specialty Boards (CESB). The requirements for continued certification will offer both staff and Board members the opportunities to continue to develop the skills necessary to fulfill CSB’s mission. In addition, professional certification would encourage staff and Board members to be more fully involved in the SH&E profession, giving CSB another means to build relationships with industry and practitioners.

We particularly encourage the Strategic Plan to include Board members in this strategy. While no doubt excellent leaders who each bring unique capabilities to CSB, several current Board members do not come from out of the traditional SH&E profession. Pursuit of safety and health professional certifications would provide a broad understanding of the variety of issues at play in any chemical accident in a workplace and send a signal of commitment CSB’s overall mission to the safety and health community.

Thank you for this opportunity to comment. ASSE looks forward to continued cooperation with CSB and looks forward to five more years of success in carrying out CSB’s vitally important mission.

Sincerely,

Donald S. Jones, Sr., CSP, PE

President