ASSE Chapter GA Chairs:

Attached below is letter ASSE sent to NASA under the signature of ASSE 2000-2001 President Sam Gualardo. The issue addresses the new NASA guidelines which include occupational safety, health, and environmental management in the Agency's contracting and procurement guidelines. The ASSE statement has been well-received by a significant and diverse number of NASA stakeholders. Of importance - ASSE is commenting that it is good public policy to incorporate safety, health, and environmental management at all levels of the organization. We are not commenting on the penalties, awards, or the structure of the contract. These issues were seen as being outside the purview of the Society and they are not addressed.

We have also sent this letter to our Public Relations Department for distribution to the general public and the media. However, this issue should be reviewed with your chapter members at the next meeting. In addition, this information should be shared with senior management in your organization as well. The intent is to show:

1. That SAFETY PAYS and that there is synergy between the public and private sectors to enhance and increase occupational safety and health and show it should be an integral strategy to the success of an organization.

2. The Society speaks for the safety profession and the need to recognize that there is professional and technical knowledge required to effectively and efficiently manage occupational safety and health issues.

3. The U.S. government can be of significant assistance to safety professionals in raising awareness of occupational safety and health as an important business strategy.

Thanks, Tim at ASSE...

***Statement Follows Here***

August 18, 2000

National Aeronautics and Space Administration
Attn: Mr. James H. Dolvin
NASA Headquarters Office of Procurement Contract Management Division
(Code H-K)
Two Independence Square
300 E-Street. S.W.
Washington, DC 20546

Volume 65, Number 114, 48 CFR, U.S. #26505

Dear Mr. Dolvin:

As President of the American Society of Safety Engineers (ASSE) for 2000-2001, it is my honor to speak on behalf of the Society. This formal comment addresses the above cited NASA interim rule changes which impact safety, security (including information technology security), health, export control, and damage to the environment, within the acquisition process. Specifically, we are commenting on the importance being placed on occupational safety, health, and environmental management. We are not commenting on the aspects of the rule addressing award fees, penalties or contract structure, as we believe these are outside our purview.

Since we have not had a previous opportunity to interact with you and your office, please allow me to provide a brief introduction of our society. The American Society of Safety Engineers (ASSE), is the oldest and largest society of safety professionals in the world. Founded in 1911, ASSE represents almost 33,000 dedicated safety professionals. Within 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 world-wide basis.

ASSE commends NASA for this initiative. There is a strong need for NASA to take proactive steps to support safety and health programs based on good science, sound technology, and recognized professional practices. It is this type of initiative that enhances occupational safety and health professional practices in the United States, and will be of significant assistance in fostering the space program.

Section 1811.101
The interim rule sets forth the following requirement:

1811.101 (b) When establishing product descriptions in either a solicitation or contract, contracting officers shall include safeguards, as applicable, to ensure safety, security, and environmental protection.

We consider Section 1811.101 as providing the best public policy aspect in the interim rule. ASSE strongly endorses the NASA approach for one very basic reason. We know from ninety years of experience that SAFETY PAYS. Safety should be an integrated component of all business plans and operations. This is an excellent example of how NASA requires that safety be part of day-to-day operations. While the interim rule goes into significant detail on the aspects of safety and health performance, we believe it is important to focus on the overall direction of the interim rule.

Finally, ASSE supports the language in the rule fostering proactive communication between NASA and its contractors and stakeholders. This well thought out public policy will help increase synergy between NASA and the contractors it interacts with. Interaction will allow for more effective and efficient hazard evaluation and abatement. The bottom-line result is going to be an enhanced NASA and that is of benefit to all Americans.

In conclusion, ASSE commends NASA for this initiative as it represents sound public policy. We are convinced that such activities will only lead to a more effective and efficient national space program. 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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