National Skills Standards Board (NSSB)
Attn: Ms. Edie West, Executive Director
1441 L Street, N.W.
Washington, DC 20005-3512

Dear Ms. West:

We appreciate having the opportunity is to formally comment on the NSSB proposed draft standard, HSE-1: Concentration Area for Healthy, Safety, and Environmental Assurance, which was published in the Federal Register on 1/26/2001, Pages 8070 to 8071. We also obtained a copy of the draft standard off of the NSSB website. The following is offered:

Introduction
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. Falling under 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 serves as Secretariat of seven (7) American National Standards Institute Committees (ANSI) developing safety and health standards which are used by private sector organizations as well as state/Federal governmental agencies such as MSHA, OSHA, etc... ASSE members also sit on over forty (40) additional standards development committees and the Society sponsors educational sessions on standards development. The Society also has twelve (12) Practice Specialties (technical divisions) consisting of: Construction, Consultants, Engineering, Environmental, Health Care, Industrial Hygiene, International, Management, Public Sector, Risk Management and Insurance, Mining, and Transportation. The ASSE members in these divisions are leaders in their field with the knowledge and expertise needed to move safety and health forward on a global level.

Key Position
ASSE understands and appreciates the intent of NSSB. We are in strong support of the NSSB mission to improve our competitive position in the world economy. The NSSB concept has great promise for business, industry, workers, and the country overall. We salute your efforts to ensure that the United States continues to be a leader in business, education, industry, science, and technology. It is also important to recognize that NSSB has attempted to partner with professional safety and health groups to create this standard. You can count on the ASSE to support your efforts to enhance these crucial areas of our economy and society.

General Insights
From our first review, the impression is that even though this initiative is a voluntary standard, it could be a future bottom-line measurement tool for safety, health, and environmental (SHE) professionals. The ASSE Governmental Affairs Committee (GAC) reviewed the standard in detail, and other related NSSB materials, but we are still unclear if the standard is to serve as an outline of SHE functions performed by manufacturing employees, or if it is a standard addressing standardized competencies for safety, health, and environmental (SHE) professionals. This is an area the NSSB should clarify through a scope statement. There are numerous inferences to these activities being performed by an employee or supervisor in addition to their other functions. The interpretation by some readers could be that NSSB is trying to obviate the need for an organization to have a full-time SHE professional on staff. We believe this issue is very significant and also needs to be clarified.

If the proposed standard is to serve as an outline of SHE functions that should be performed by manufacturing employees, it is too complex, and not appropriate, for a part-time function. If the intent is to address SHE professionals, then it omits necessary skills and abilities, which need to be recognized in the standard. In addition, there is also a significant partnership opportunity here for NSSB, since the approach of the standard duplicates efforts already taking place in the private sector. We see significant opportunity for NSSB to work further with safety, health, and environmental professionals and their respective organizations on the proposed standard. Also, included with this letter is the ASSE publication, Scope and Functions of the Professional Safety Position. This brochure will be of assistance in providing further insight on the issue of SHE functions.

Voluntary National Consensus Standards Initiatives
Our view is the proposed draft standard could be better coordinated with existing voluntary national consensus standards and projects accredited by the American National Standards Institute (ANSI) and other standards development organizations. Some of these standards are:

• ANSI Z490.1: Accepted Practices in Safety, Health, and Environmental Training
  
• ANSI Z590.1: Levels of Competence and Certification in the Safety Profession.
  
• ANSI Z590.2: Scope and Functions of the Professional Safety Position
  
• ANSI Z590.3: Accepted Practices to Initiating and Completing Voluntary Occupational Safety and Health Audits, Assessments, and Evaluations.
  

We understand that the NSSB is a quasi-public/private sector body, and the document is voluntary in nature. However, it would be good public policy for NSSB to follow the tenets of the Morella Amendment of the Technology Transfer Act of 1995 (Public Law 104-113) and the 2/19/98 Office of Management Budget Circular A-119; Federal Participation in the Development and use of Voluntary Consensus Standards and in Conformity Assessment Activities.

Some basic observations include:

• The Section, Conduct Health, Safety, and/or Environmental Incident and Hazard Investigations. There is a reference made to ISO standards for occupational health and safety. At this point in time, there are no ISO standards covering occupational safety and health.

• NSSB should cite knowledge of ANSI, ASME, ASTM, or NFPA standards. Not only are these standards widely cited in federal, state, and local regulation and legislation, they are the driving force for voluntary national consensus standards impacting safety, health, and environmental issues.

• The Section, Conduct Preventive Health, Safety, and/or Environmental Inspections. There is an opportunity for NSSB to coordinate its activities with the voluntary national consensus standards published by the American Society for Testing and Materials (ASTM) E-50 Committee. This committee is chartered to write voluntary national consensus standards for environmental assessments, inspections, and evaluations.

• NSSB cited meters as "needed tools and equipment", but did not include other crucial pieces of equipment such as fall protection, eye-wear, respirators, etc… While there is a need to limit such a list for the sake of efficiency, there are additional pieces of equipment, which should be recognized.

Sections of the draft standard addressed the issue of certification, which by implication could include SHE professional certifying bodies. We did observe from our research that NSSB website has a referral service for certifying bodies. Our position is any SHE certification recognized by NSSB, must be accredited by a recognized third party accreditation body. For example, ASSE recognizes only those certifications, which are accredited by either the Council on Engineering and Scientific Specialty Boards (CESB) or the National Commission on Certifying Agencies (NCCA). We have included information on these accrediting bodies for your review as well.

We conclude this letter by pointing out that ASSE is committed to assisting with any initiative that will enhance and improve the SHE profession. Thank you for your attention to this matter, and we look forward to working with you in the future.

Sincerely Yours,

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

SJG/TRF/CORRS1422
Encl.