In addition to providing the highest ranking overall EHS issues, AIHA also identified the top public policy issues in individual categories for 2011-2012.
“There seem to be a lot of individual issues our members are concerned about,” Aaron Trippler, AIHA director of government affairs, told EHS Today. “But it’s very difficult for OSHA to act on all these issues” due to process and time limitations – which means the agency may need to reevaluate its process and priorities.
For example, while OSHA has considered diacetyl regulation for the last several years, Trippler says the agency has realized that this issue impacts only a small percentage of the working population. OSHA therefore may question whether focusing on diacetyl would offer the best return on investment for the agency’s time and resources and may focus instead on the issues that have the biggest impact on the American work force.
According to the AIHA survey, members have the following top EHS issues in their sights for 2011-2012:
Updating Permissible Exposure Limits (PELs) – PELs are consensus-based limits that indicate how long an individual can be exposed to a particular substance without experiencing harmful effects. While the EHS profession largely considers PELs to be one of the most basic tools needed to protect workers, many PELs have not been updated since the 1960s and 1970s, AIHA pointed out. Science in this area has matured, but the PELs have not. AIHA continues to work with OSHA, Congress and others to reach a consensus on the best way to update the PELs.
“OSHA has realized they’ve come up against a brick wall” regarding PELs, Trippler said. He was pleased, however, to see OSHA create an internal advisory group to discuss this challenge, and the Injury and Illness Prevention Program might be one way to address the issue.
Injury and Illness Prevention Program (I2P2) – OSHA is developing a rule to require employers to establish and maintain an Injury and Illness Prevention Program. This would involve identifying and controlling hazards as well as planning, implementing, evaluating and improving processes and activities that protect employee safety and health. AIHA supports the need to define effective occupational health and safety programs, as well as the acceptance in the safety community that hazard assessment and implementation of a written safety and health program are parts of minimum acceptable professional practice on any work site.
Trippler told EHS Today that AIHA has submitted an I2P2 white paper for board approval. If approved, AIHA will share this white paper with OSHA to offer recommendations and considerations for the Injury and Illness Prevention Program.
“We think we have a lot to offer OSHA on this issue,” said Trippler. “We feel we have a responsibility to come out with more detailed information [for I2P2].”
Material Safety Data Sheets (MSDS)/Globally Harmonized System (GHS) – AIHA supports efforts to improve the accuracy of MSDS and supports efforts to improve hazard communication for employers and employees. Such efforts also are a crucial element in protecting workers and others in case of national emergencies. A major part of improving hazard communication is adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). AIHA supports adoption of the GHS.
Professional Recognition/Title Protection – Professional recognition/title protection allows industrial hygienists and others who have met minimum educational and experience requirements (such as certified industrial hygienists and certified safety professionals) to be legally defined and recognized as competent to perform certain work without the need for additional requirements. One area of concern is the continued influx of specific occupational health and safety titles that are awarded by non-accredited bodies and the attempt to recognize these titles in various policy-making activities. AIHA continues to educate federal and state policymakers about the importance of recognizing those professionals who have received education and certification from nationally recognized and accredited organizations.
OSHA Reform and NIOSH Recognition – Each year, Congress introduces and considers legislation to amend the Occupational Safety and Health Act. This legislation addresses many parts of the OSH Act, including criminal penalties, whistleblower protections, expansion of coverage and the Voluntary Protection Program. AIHA supports efforts to review and amend the OSH Act if changes provide added protection for workers. AIHA also supports efforts to protect the National Institute for Occupational Safety and Health (NIOSH) from attempts to diminish the importance of the Institute and its research.
According to Trippler, the members’ survey responses showed “concern for the future of OSHA and NIOSH.” AIHA supports appropriations to adequately fund both OSHA and NIOSH.
Laboratory Accreditation – Accredited laboratories are the best way to ensure that test samples of potential workplace hazards are analyzed correctly. AIHA continues working to see that the AIHA laboratory accreditation program is internationally recognized and noted in federal and state legislation and regulation as one of the programs with recognition and acceptance.
In addition to these top issues, the survey also identified the most important issues in individual categories pertaining to OSHA, legislative activity, EPA and AIHA itself.
- Updating PELs
- Injury and Illness Prevention Program (I2P2)
- GHS for Classification/Labeling of Chemicals
- Risk Assessment
- Combustible Dust
- Federal/State Legislative Issues
Federal and/or State Legislative Activity Issues:
- Updating PELs
- Appropriations for OSHA, MSHA, NIOSH, EPA
- Federal Contracting (must comply with OSHA regulations to receive)
- Professional Recognition/Title Protection
- Expansion of OSHA coverage to all employees
- Hazardous and Toxic Waste
- GHS for Classification/Labeling of Chemicals
- Clean Air Act
- Clean Water Act
The top issues of overall importance to AIHA:
- Collaboration with other EHS organizations
- Professional Ethics
- Standards (ANSI, ASTM, etc.)
- Injury and Illness Prevention Program
AIHA will review existing white papers and position statements, as well as draft new position statements, to determine the appropriate response to each of the issues.