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March 22, 2002

The Honorable John Henshaw
Assistant Secretary of Labor
Occupational Safety and Health Administration -- Room S2315
U.S. Department of Labor
200 Constitution Avenue
Washington, D.C. 20210

VIA FAX: 202/693-2106

RE: OSHA Compliance Officer Internship Proposal

Dear Assistant Secretary Henshaw:

In many of your recent public presentations, you have inquired as to the feasibility of compliance officers completing an internship in private industry or on construction sites. The American Society of Safety Engineers (ASSE) commends you for your creative leadership in being willing to propose and examine new ideas and innovative methodologies to enhance the education and training of enforcement officers and encourage their professional development.

In response to your suggestion, ASSE's Government Affairs Committee has both discussed the internship idea in its recent meeting and informally sought out the opinion of a sampling of the Society's members. We have received many comments, both pro and con, to the possibility of internships. While the Society and its members would like to be as supportive as possible of your overall efforts to enhance training of enforcement officers, a variety of concerns with the program have been identified:

1. liability, both for the sponsoring company and the OSHA intern;

2. the potential for conflict of interest when an intern encounters a perceived compliance deficiency on a job site;

3. concerns for the privacy of a company's information, which could be proprietary; and

4. issues that companies might have in dealing with their own customers and consultants when an OSHA intern is involved.

Because of these concerns, ASSE recommends that you consider the following suggestions, which we believe will help you meet your goal of adding to the training opportunities of OSHA enforcement officers that we all share:

1. request that only VPP "Star" sites participate in the process because these are enlightened employers who will see the value in such an innovative approach;
2. require that new compliance officers participate in a minimum number of VPP audit team reviews to demonstrate a fundamental understanding of the inspection/compliance paradigm;

3. require that a candidate for OSHA compliance officer employment has completed a safety internship at the college level to be considered for a position, thereby ensuring that practical experience will be gained without causing the various conflicts noted above that arise from OSHA employment;

4. require OSHA interns to sign a liability waiver and confidentiality agreement prior to commencing work on-site;

5. encourage colleges and universities offering qualified safety degree programs to develop new courses addressing issues in industry, academia, research and government that would be useful and relevant to an OSHA enforcement officer; and

6. utilize third-party consultants to develop training courses and seminars for OSHA enforcement officers; as a proven, long-time provider of a wide range of substantive training opportunities for safety professionals, ASSE stands ready to help your Department in establishing relevant training programs.

No matter the difficulties involved, your hope to provide real-world experience to OSHA enforcement officers is laudable and, if approached carefully, feasible. As the largest professional safety society with over 30,000 members, we would like the Society and our members to participate in achieving your goal of encouraging OSHA staff to become better educated and more involved in professional activities.

As President of the Society, I am available at your convenience to talk about these concerns and suggestions. Thank you for your time.


M.E. Greer, CSP
Society President 2001-2002

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