March 13, 2001

National Institute for Occupational Safety and Health (NIOSH)
Attn: Ms. Anne Connor, CDC Assistant Reports Clearance Officer
1600 Clifton Road, MS-D24
Atlanta, GA 30333

PUBLIC COMMENT OPPORTUNITY
TOOL BOX SAFETY TRAINING

Dear Ms. Connor:

The purpose of this correspondence is to comment on the 2/13/2001 Federal Register Notice (Pages 10021-10022), seeking comment on a proposed project titled: Evaluating Toolbox Training Safety Program for Construction and Mining. CDC/NIOSH, no-doubt so we hope, is already well aware of ASSE since we have enjoyed a mutually beneficial relationship. We will pass on a long introduction of ASSE, but have enclosed a Fact Sheet on the Society to provide current information on our membership numbers, chapters, practice specialties (technical divisions), and standards development activities.

We learned of the upcoming evaluation pilot program through the Federal Register announcement, and do have considerable interest in this issue. In the future ASSE would request that we be contacted earlier in such a process to assist in shaping the Federal Register Notice. Earlier contact could help enhance acceptance and recognition of the pilot program and study. It is important to point out that ASSE does not speak either for or against the program/study, but we do want to ensure our members are aware of this initiative and will have the opportunity to participate.

This announcement was circulated to the Construction and Mining Practice Specialties (technical divisions), with a request for feedback and comments. Insight from construction safety professionals should be of value to NIOSH in structuring such a study. Toolbox sessions generally, are held weekly, and are considered to be an "all hands meeting". The attendees are briefed on an important safety message and the impact it has on them, their associates, and the worksite. The average session runs from 10-20 minutes depending on the message that needs to be conveyed. Topics pertinent to the current work activities and environment are chosen for discussion.

The construction and mining industries are fast-paced, performance-oriented environments. Since these environments are dynamic, and constantly changing, the use of toolbox talks is an innovative and effective way to impart important occupational safety and health messages to those on-site. The key issue is to ensure that the session is effective in imparting important information. The intention of a toolbox talk is not to replace OSHA required training. Given the short timeframe of the sessions, they are a good tool to use in raising awareness reviewing a specific hazardous condition or an incident on the site.

The use of these toolbox talks have become very commonplace in the industry, but the overriding concern of many ASSE members in the construction and mining industries is that those workers on-site may perhaps not receive additional detailed training needed to prevent injuries, illnesses, and fatalities from hazards, which they could face on a daily basis. The other concern raised by members in the construction and mining industries is that some small to medium range firms may not use toolbox sessions at all. When NIOSH launches this study it will be very important to strike the appropriate balance to ensure small, medium, and large firms are encouraged to participate.

Most significantly to this proposal is that ASSE serves as secretariat of the accredited Z490 American National Standards Institute (ANSI) Committee, which produced the Z490.1 draft standard, Accepted Best Practices in Safety, Health, and Environmental Training. The ANSI Z490.1 project was accredited by ANSI on 4/1/98 grew out of the recognized need for improvement in safety, health, and environmental training. Quality training is required to ensure that workers and safety, health, and environmental professionals have the knowledge, skills, and abilities necessary to protect themselves and others in the workplace. Regulatory agencies such as OSHA have continued to wrestle with training issues on both an internal and external basis for many years. This includes everything from training requirements for specific standards to the potential accreditation of specific training programs. We would also like to point out that NIOSH has two outstanding representatives on the ANSI Z490 Committee, Dr. Michael Colligan and John Palassis, in addition to representation from other government agencies, (Dr. Chip Hughes, National Institute of Environmental Health Sciences, NIEHS).

The rationale we offered ANSI in filing the application for establishing the project was that these safety, health, and environmental training standards would improve areas of competence, quality and effectiveness. Their potential is to obtain standards of quality, which ensure that safety and health-training providers meet such standards. These standards can help employers and consumers of training services select quality safety and health training materials, instructors, and other program components. Once established, and we are only weeks away from approval, these standards can be used to audit, monitor, evaluate, analyze, etc. national, industry-wide training of large and small training service providers as well as corporations and government entities seeking third-party review of their employee training activities. Accordingly the Z490.1 Standard:

  • Provide a measurement and benchmark for evaluating training

  • Is a consolidation of the basic body of knowledge for training.

  • Identifies a level of performance whereby training quality can be judged and objectively evaluated

  • Establishes auditable criteria to evaluate current accepted practices in training.

  • Recommends, in a consultative mode, an authoritative reference for selling recommendations to management

  • Describes, at this point in time, the best in safety/health/ environmental training

  • Provides models of training, which are transferable to almost all industries

We specifically request that NIOSH review the draft standard and then use it as one of the review tools to evaluate the training in this proposed pilot program. A copy of the draft standard is enclosed for the use of NIOSH in completing this project. In addition, we respectfully request to work with your office in recognizing the draft standard and include it in any publications addressing the general issue of training.

We thank you for your attention to this matter and look forward to working with you in the future. A favorable response to our request will benefit your agency, safety professionals, and most importantly the workforce and the general public whom we all are dedicated to protect.

Sincerely,

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

Copy to:

ASSE Board of Directors
L. Fine, Director of NIOSH
(Letter Only) ASSE Council on Professional Affairs
ASSE Governmental Affairs Committee

SJG\TRF\CORRS1420
Encl. Z490.1 Draft Standard

     

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