May 6, 1999
U.S. Occupational Safety and Health Administration
Mr. Charles Jeffress, Assistant Secretary of Labor
200 Constitution Avenue, NW
Washington, DC 20210
OSHA STRATEGIC PLAN
Assistant Secretary Jeffress:
The American Society of Safety Engineers (ASSE) would like to thank
you for giving us the opportunity to offer comment on the OSHA 1999-2000
Strategic Plan. We believe this request for insight is an excellent example
of the Agency's dedication to working with the private sector on ways
to enhance the national focus on occupational safety and health. To this
end, we present the following:
ASSE takes the position that the Strategic Plan is easy to follow and
is understandable to virtually all stakeholders. We agree with the three
(3) primary strategic goals as they are listed in the plan, (Section #3,
Page 7). We believe they are short, to the point, and address the key
issues impacting the enhancement of occupational safety and health.
Perhaps we missed it in the document, but our review indicated that international
issues were not addressed even though OSHA is apparently increasing its
level of participation with safety and health on the international level.
An excellent example is the work taking place with the Globalized Harmonization
System. Since the plan is designed to address issues up to the year 2004,
it might be appropriate to at least include the international issue in
the Strategic Plan.
Voluntary National Consensus Standards
We found little in the Strategic Plan which indicates how OSHA intends
to work with voluntary national consensus standards development organizations
like ANSI, ASTM, NFPA, etc… This is puzzling when one reviews currents
standards/regulations and sees the number of voluntary national consensus
standards cited by reference. OMB A-119 and Public Law 104-113 call for
the increased utilization of voluntary national consensus standards. It
would make sense to us to have some type of plan to accommodate the increased
usage of voluntary national consensus standards. This is especially true
since the Strategic Plan is to remain in effect through the year 2004.
With government agencies placing more and more emphasis on the use of
voluntary national consensus standards, it would be appropriate for OSHA
to consider them for inclusion in the Strategic Plan.
OSHA Outcome Goal #1.1 (Page 8)
The Society is puzzled as to why OSHA picked lead and silica exposure
as two of the three injuries/illnesses it will focus its attention on
during the performance period of the Strategic Plan. We believe this is
inconsistent since the Agency has identified ergonomics as a top priority
for the Agency, thus, why would ergonomic injuries not be one of the priorities?
ASSE also questions why asbestos is a priority. While we recognize that
asbestosis is still a concern in this country, we are not sure if it should
be considered as one of the Agency's top three priorities for the strategic
Human Resources (Section #10, Page 40)
ASSE was chagrined that there is nothing in the Strategic Plan addressing
the crucial need to increase the level of professionalism of Compliance
Officers. This is not a new issue, and has not been addressed. Redesigning
offices might help with customer relations, however, we do not see how
this will lead to true improvement in the perception of OSHA by the private
sector. We think this will take place when OSHA commits itself to supporting
its employees in acquiring recognized credentials, (e.g.: CSP, CIH, PE,
etc…). At the 1998 ASSE Professional Development Conference you (Assistant
Secretary Jeffress), stated that the Agency is committed to supporting
accredited certification and/or registration by OSHA personnel. Our belief
is that this is an issue which is not going to go away. We specifically
think OSHA consider the following for inclusion in the Strategic Plan:
While we also recognize there are some obstacles facing OSHA in encouraging
active participation (reimbursement for dues), in professional organizations
like ASSE, we also think it would be appropriate to include something in
the Strategic Plan indicating the Agency support of its employees being
involved with professional organizations. Active involvement is a win-win
strategy for the Agency, and we think this should be considered for inclusion
in the Strategic Plan.
- Have a statement indicating future support for accredited certification
- Introduce proactive mechanisms to encourage safety professionals employed
by OSHA to pursue accredited certification or engineering registration.
- Provide support for such initiatives, and give financial rewards for
successful completion of the credentialling process.
Third Party Audit and Evaluations
ASSE understands that OSHA has concern with third party audit and evaluations.
However, many agencies in the federal government are either utilizing,
or considering using, private sector consultants. The U.S. Environmental
Protection Agency is looking at a pilot program beginning 6/99 in the
state of Delaware. EPA also includes the third party concept in programs
such as the Environmental Leadership Program and Underground Storage Tanks
(UST). In fact, EPA addresses the issue of third party and USTs in a publication
titled, Part 1, Thinking About Third-Party Service Provider Programs.
ASSE suggests that OSHA at least consider including the issue into the
Strategic Plan as a discussion point. ASSE is willing to work OSHA on
creative approaches to the third party concept. We are convinced that
the best way to address this issue is through discussion and partnership.
Thank you for the opportunity to provide comment on the Strategic Plan,
and if we can be of any further assistance please feel free to contact
Fred F. Fleming, CSP, OHST
Society President, 1998-1999
Copy To: ASSE Board of Directors
Council on Professional Affairs
Governmental Affairs Committee
White, Co-Chair, Strategic Planning Workgroup
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