May 6, 1999

U.S. Occupational Safety and Health Administration
Mr. Charles Jeffress, Assistant Secretary of Labor
OSHA/DOL (S-2315)
200 Constitution Avenue, NW
Washington, DC 20210


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:

Overall Position
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.

International Issues
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 plan.

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:

  1. Have a statement indicating future support for accredited certification and/or registration.
  2. Introduce proactive mechanisms to encourage safety professionals employed by OSHA to pursue accredited certification or engineering registration.
  3. Provide support for such initiatives, and give financial rewards for successful completion of the credentialling process.
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.

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 the Society.

Sincerely Yours,

Fred F. Fleming, CSP, OHST
Society President, 1998-1999

Copy To:       ASSE Board of Directors
                        ASSE Council on Professional Affairs
                        ASSE Governmental Affairs Committee
                        Paula White, Co-Chair, Strategic Planning Workgroup



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