That's the argument put forward by ORC Worldwide (ORC), an international management consulting firm formerly known as Organization Resources Counselors Inc.
In a paper released on the eve of the election, ORC worries that because of OSHA's lack of leadership, U.S. companies are increasingly finding themselves affected by international safety health policies over which they have little control.
There was no immediate comment from OSHA on the ORC paper.
While praising OSHA's new emphasis on partnerships and guidance documents, ORC criticized the agency for focusing more on "process" and less on "issues."
"OSHA's historic leadership on issues such as hazard communication, chemical process safety and the early development of occupational safety and health management systems has not been as evident during the last dozen years," the group noted.
While OSHA took the lead in pushing safety and health management systems, the agency "effectively took itself out of the game in failing to move forward on a Safety and Health Program Standard or even updated guidelines," said ORC. As a result, the International Organization for Standardization (ISO) attempted, and failed, to fill the void.
The British Standards Institute and the International Labour Organization have both now issued safety and health management systems guidelines. According to ORC, businesses around the world, including a growing number of U.S. companies, are beginning to look at these more recent products as the official templates for their own management efforts.
But while U.S. companies, because of the global nature of the economy, are increasingly drawn into these international safety frameworks, ORC believes the emerging situation creates a "dilemma" for American companies.
While the American rulemaking process ensures the full participation of U.S. companies, international initiatives lack such guarantees for American businesses.
ORC identifies a number of emerging occupational safety and health issues currently under development in international forums that will have a big impact on U.S. businesses:
- Accelerating European efforts to address workplace stress and psychosocial factors;
- Development of the European Union (EU) REACH directive requiring the testing and control of hazardous chemicals;
- EU protocols for performing risk assessments in workplaces;
- The decision of the ISO to develop a standard on corporate responsibility;
- The Global Reporting Initiative's recently developed metrics for effective safety and health performance.
To respond to the new situation, ORC urges OSHA to engage the EU and nongovernmental organizations on a broader range of issues, to secure an institutional voice on international trade issues, and to place a senior-level representative with international expertise in the Office of the Assistant Secretary of Labor for OSHA.