August 9, 2000

DOL/OSHA, Room #S-2315
Attn: Mr. Charles Jeffress
Assistant Secretary of Labor, OSHA
200 Constitution Avenue, NW
Washington DC, 20210


Assistant Secretary Jeffress:

The purpose of this letter is to comment on a public policy issue of importance to members of the American Society of Safety Engineers (ASSE). This issue is the release of safety and health audits records.

As you know from recent interaction with our staff members, ASSE is not completely satisfied with OSHA's final self-audit policy published in the Federal Register on July 28, 2000. It is an improvement over the original draft, yet we still have concerns. There is still a difference of opinion on issues such as the use of the term "routine" and OSHA's reticence to use an Administrative Law Judge.

However, it is also important to note that several of ASSE's insights and suggestions were favorably acted upon. Revising the definition of a "self-audit" to include audits conducted by a third party will encourage employers not having on-staff safety professionals to utilize qualified safety consultants. This action is a positive development by the Agency. Addressing the training needs of compliance officers is also a positive first step in a long road that must be traveled by OSHA. It would also be of significant benefit to compliance officers if they actively participated in professional safety organization such as ASSE. When participation and synergy is increased, there is more opportunity for compliance officers to reach out to industry safety professionals to receive additional education and training. Likewise, our members can also significantly benefit by networking with them and learning their points of view. This is a continuation of growing toward a partnership role as opposed to an adversarial role.

ASSE was extremely disappointed to learn that the reference to safety professionals was struck from Section [1-C]. Our membership was originally very pleased to read that OSHA recognized the importance of using competent safety professionals to either conduct or direct audits. Here was an excellent opportunity for OSHA to encourage employers to use staff safety professionals, or contract with those safety professionals who have the competence and expertise to conduct safety audits. It is imperative that OSHA recognize the importance of using competent safety professionals to foster and enhance credible audits. We urge the Agency to not abandon this effort and strongly recommend that the language on safety professionals be reinstated. Such action would be good policy and would provide for safer and more healthful workplaces.

Thank you for your attention to this matter. ASSE will continue to comment on such initiatives in the hope it will lead to a more effective and efficient agency. If you should have any questions, please feel free to contact the Society.

Sincerely Yours,

Samuel J. Gualardo, CSP
ASSE President, 2000-2001


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