There is increased activity on occupational health and safety (OHS) programs in OSHA under its new administration. The agency’s new director is addressing and improving the safety culture in companies. One vehicle to do this is addressing comprehensive OHS programs. There was activity in the mid- to late 1990s in this area with attempts to codify the highly regarded Voluntary Protection Program and elevate the status of OSHA’s 1989 Program Guidelines. These efforts morphed into attempts in federal OSHA to adopt a national Illness and Injury Prevention Program (IIPP) found in a handful of states, including California.
In a March 25, 2010 speech to a joint meeting of local sections of the ASSE and AIHA, David Michaels, assistant secretary of labor for occupational safety and health, discussed how OSHA inspectors are increasingly looking at how companies “are taking steps to improve the overall [OHS] performance, reduce risk, and make prevention a daily part operations.” He said that there is a more “intense look at whether there is in place a comprehensive safety and health management system, and asking ‘is it being implemented, and are management and workers working together toward continuous improvement.’”
It is unclear from Dr. Michaels’s comment if this means inspectors are giving recommendations or guidance to companies, or possibly issuing General Duty Clause-based citation. At this time, there is no formal or regulatory-based foundation within OSHA enforcement other the General Duty Clause. It is anticipated that the agency will begin rulemaking in this area in the near future.
In the mid-1990s, in response to the 104th Congress’ focus on regulatory reform, OSHA began an effort to develop an assessment approach that could be used by inspectors to measure OSH program/system activities. This approach was called the PEP (Performance Evaluation Profile). The PEP format followed the OSHA-consulting Form 33. The score from a PEP assessment was to be used as a weighting factor against potential fines. As the 1990s progressed, the PEP effort lost steam and was not used beyond its initial pilot efforts.
Regardless of how OSHA proceeds, EHS professionals can find value in the agency’s VPP and SME (small to medium enterprise) model (SHARP) to improve worker safety and health. The agency also offers some very effective e-tools to assist in this area.
On another front, in large companies that have developed and implemented an EHS management system , the question often arises how to address a small site where the full-blown EHSMS may be too much. One approach to addressing this is through the application of IIPP-like concepts and approaches within the EHSMS.
Please contact us if you’d like more information on some of the source documents discussed in this post.
© Redinger EHS, Inc. (2010)
[...] link: OSHA Program Standard Activity | Strategic EHS Share and [...]