Dear Editor;
I have been a long-time subscriber and never felt the need to send a critique before now. However, the article ASSE: Management-Based Safety Can Take Your Program to New Heights (www.occupationalhazards.com/articles/13615) deserves comment, in that, although the concepts recommended by Gualardo are sound, the premise for his conclusion that the airlines are safer than U.S. workplaces is based on a false analogy.
Gualardo compares the product safety record of airlines with the occupational safety record of industry, which is an "apples to oranges" comparison. He asserts that in 2002, the airlines flew millions of miles for millions of hours without a fatality and that "... by contrast...U.S. workplaces in 2002 experienced 4.7 million OSHA recordable injury and illness cases...," yielding a case rate of 5.3. Mr. Gualardo seems to argue not only that product safety can be compared to workplace safety, but that product fatalities are somehow comparable to occupational injuries.
Although I did not locate the BLS 2002 data, I am confident the rates for air transportation and general industry did not change significantly from 2002 to 2003. The BLS statistics for 2003 (the latest available records) reveals that 12 occupational fatalities occurred in the air transportation, scheduled flight sector. In fact, according to the BLS, the occupational injury/illness rate for air transportation (SIC 481100) was 11.7 in 2003 as compared to 5.0 for all industry in 2003. According to that data, airline occupational safety is more than twice as bad as U.S. industry workplace safety as a whole!
I believe Gualdrdo's claim that the airline industry (workplace) is safer than that of the rest of industry is unsupported by the data. One cannot claim superior safety performance based on a comparison of product safety and workplace safety. Product safety is very different than occupational safety.
I admire the safety record of airline passenger safety and have no desire to minimize that industry's accomplishments. However, it is a disservice to the EHS profession to misrepresent performance as the subject article did.
Very Sincerely,
Robert Eaton
EHS Manager
Eaton Automotive
Athens, Georgia
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