ORC Recommends OSHA Shift Focus to Risk Reduction – OSHA Chief Avows Interest in Management Systems

At the “OSHA Listens” public meeting, held March 4 in Washington, DC and attended by a large number of OSHA stakeholders, ORC Senior Vice President Frank White outlined three ways the agency could improve its policies and programs.

Moving to a risk assessment approach, as opposed to OSHA’s traditional focus on compliance with OSHA standards, is the single most important step the agency could take to improve its programs, according to Mr. White. “OSHA should begin now to shift its focus to risk assessment and control by promoting and incentivizing the adoption of safety and health management systems,” said Mr. White.
Mr. White praised OSHA for holding the meeting and said he hopes the agency will continue to develop a “more collaborative infrastructure.” ORC is encouraging OSHA to work collaboratively with stakeholders in developing its policies because ORC believes in the long run OSHA will be a more effective agency if it develops a culture that is more transparent and publicly accountable.
“The perplexing dilemma of OSHA’s permissible exposure limits,” (PELs) was the third issue raised by Mr. White at the public meeting. He pointed out that virtually all OSHA stakeholders agree the agency’s PELs are out of date, leading to an unacceptable gap in worker protection. Mr. White called on OSHA to lead a new effort to update the PELs. “
ORC believes that it still may be possible to craft a viable approach, but doing so will require OSHA leadership and active engagement in its development.
Mr. White appeared on a panel with three other business leaders: Marc Freedman, U.S. Chamber of Commerce; Keith Smith, National Association of Manufacturers; and Stephen Sandherr, Association of General Contractors. After all the panel members had delivered their remarks, they were questioned by a panel of OSHA officials: Assistant Secretary of Labor for OSHA David Michaels; Rich Fairfax, Director of Enforcement Programs; and Dorothy Dougherty, Director of Standards and Guidance.  
Dr. Michaels asked about the metrics OSHA should use to measure its success and the success of employers. He also asked what data would be best in targeting OSHA enforcement efforts. Instead of relying solely on injury and illness rates, Mr. White recommended evaluating employers by looking at leading metrics that can reduce risk and prevent incidents. He cited worker training in injury and illness prevention and near-miss data as examples of leading indicators.
Ms. Dougherty asked how the OSHA standards process could be improved. Mr. White said OSHA has never done a good job at providing information and guidance about how to comply with a standard until after the standard is promulgated. He agreed with a point made earlier by Mr. Freedman that employers are more likely to accept standards if they understand them better and have enough lead time to comply.
Dr. Michaels closed this portion of the meeting by returning to the issue of reducing risk through safety and health management systems. “I’m certainly drawn to what Frank [White] and many others have suggested, that this is something employers should take on themselves,” said Dr. Michaels. “Every employer has an injury and illness prevention system, but some of you don’t know it. So I’ll be interested in continuing the dialog around this issue.”

A written transcript of the meeting, along with an archive of the live Webcast may be accessed through the OSHA Web site: http://www.osha.gov/as/opa/osha-listens.html The complete text of Mr. White’s testimony is available here:ATTACHMENT

OSHA Listening session_ORC statement_Oral remarks.doc47.5 KB