ORC Worldwide Vice President Frank White in the letter implores OSHA to reassert its leadership in updating the PELS, which White contends are "woefully outdated" and "not sufficiently protective of worker health."
Noting that the Foulke has a "window of 2 years or less to make a mark on worker safety and health," White calls upon the OSHA chief to move swiftly on his agenda. Among the items requiring urgent attention, in the eyes of White and ORC Worldwide, is the integration of the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals into the agency's Hazard Communication Standard.
Also, White points out that "opening up" the 1989 Safety and Health Program Management Guidelines and other related management system resources to consider the impact of new developments such as the recently issued American National Standards Institute (ANSI) Occupational health and Safety Management Systems (OHSMS) Standard Z10-2005 would provide the public with access to additional up-to-date resources and information.
"ORC is gratified that Mr. Foulke has emphasized early in his tenure that he wants to make progress o the implementation of the GHS and find a solution to the PEL dilemma," White wrote. "We think a similar OSHA focus on updating its pioneering work on safety and health management systems could provide businesses, especially small and medium-sized enterprises, with new tools to improve safety and health performance."
The letter to Foulke acknowledges both the policy decisions and resource constraints that shape OSHA's current direction.
"In recent years, OSHA has charted a clearly articulated path of maintain a 'baseline' of strong, fair, targeted enforcement," White wrote, "and at the same time emphasizing a wide array of outreach compliance assistance and cooperative and voluntary programs."