March 13, 2001
National Skills Standards Board (NSSB)
Attn: Ms. Edie West, Executive Director
1441 L Street, N.W.
Washington, DC 20005-3512
COMMENT - 1/26/2001 FEDERAL REGISTER ANNOUNCEMENT
PARTNERSHIP ORGANIZATION - SOLICITATION OF COMMENTS
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:
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.
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.
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
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
- ANSI Z590.1: Levels of Competence and Certification in the Safety
- 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
- 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
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.
Samuel J. Gualardo, CSP
ASSE President, 2000-2001
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