The leading topics ASSE discussed included leadership; standards; risk-based safety and health management approaches; global harmonization rulemaking; third-party consultation; ergonomics; workplace transportation fatalities; strengthening support for state OSHA programs; cooperation with the National Institute of Occupational Safety and Health (NIOSH); and continued support for cooperative programs like the Voluntary Protection Program (VPP) and OSHA alliances with businesses that advance employer understanding of the positive impact of EHS on an employer’s bottom line.
ASSE stressed the following:
Standards – An examination of how OSHA standards are pursued must be undertaken. OSHA should lead efforts to develop cooperative mechanisms to help counter the division that has limited OSHA’s ability to update standards and permissible exposure limits (PELs).
Advance risk-based safety and health management approaches – OSHA should encourage employers to take proactive responsibility for safety and health through risk-based regulatory approaches and compliance assistance resources. Europe, Japan, China and committed U.S. employers already use such approaches. OSHA is falling behind the world in not incorporating risk-based safety and health management approaches.
OSHA can help U.S. companies save jobs – Rulemaking on global harmonization of US hazard communications (GHS) will help U.S. employers compete across the globe and should be completed. An engaged OSHA can help ensure OSH issues are addressed fully in US trade agreements.
Cooperative Programs – Cooperative programs like VPP and the OSHA alliances, which continue to advance employer understanding that safe workplaces save lives and positively impact an employer’s bottom line, should continue to be supported.
Third party consultation – ASSE supports extending OSHA effectiveness by establishing a program to allow third party safety audits of companies under strict requirements to ensure professionalism and maximize effect, thereby expanding OSHA’s reach beyond the limits of its current enforcement and cooperative programs.
Ergonomics – If ergonomics emerges as a regulatory goal, ASSE will not be able to support a prescriptive approach. ASSE members’ knowledge and experience indicate that ergonomic problems are addressed through specific job and workplace fixes. Any approach to ergonomics must be risk-based, encourage cooperation, and avoid prescriptive, one-size-fits-all solutions that cannot work.
Harmonization with voluntary consensus standards – OSHA should increase its participation level in the voluntary consensus standard community and comply fully with the Technology Transfer Act's mandate to consider consensus standards when engaged in rulemaking. Use of such standards, like ANSI/ASSE Z117 (confined space standard) and ANSI/ASSE Z490.1 (safety training), will help expedite rulemaking and keep pace with current safety practices.
Transportation-related deaths – These deaths continue to be the leading cause of workplace fatalities in the United States OSHA should examine its current efforts and engage employers, employees and other federal agencies to create a new emphasis on addressing this problem.
Cooperation with NIOSH – OSHA’s relationship with NIOSH envisioned by the 1970 OSH Act should be increased so that NIOSH’s work, including key EHS research, can support and contribute to OSHA’s standards and other activities.
Improve support for state programs – OSHA’s ability to support and encourage state program effectiveness must be strengthened.
ASSE noted in particular that federal safety and health agencies should be led by safety, health and environmental professionals who have the leadership capabilities to build relationships across the spectrum of occupational safety and health stakeholders.
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