I saw several tweets flying around about “OSHA Listens” and read a few articles / blog posts about it as well. It seems the future of VPP is a hot topic… Here’s my problem, shouldn’t OSHA always be listening? Why is this news? So I went to their website and gathered some additional information. The “OSHA Listens” event was a full day held March 4th from 9AM to 6PM covering a variety of topics. OSHA wanted input on 9 specific questions which are outline on their website. Here are the 9 questions and my responses follow…in case they want to listen to me as well.
1. What can the agency do to enhance and encourage the efforts of employers, workers and unions to identify and address workplace hazards?
2. What are the most important emerging or unaddressed health and safety issues in the workplace, and what can OSHA do to address these?
3. How can the agency improve its efforts to engage stakeholders in programs and initiatives?
4. What specific actions can the agency take to enhance the voice of workers in the workplace, particularly workers who are hard to reach, do not have ready access to information about hazards or their rights, or are afraid to exercise their rights?
5. Are there additional measures to improve the effectiveness of the agency’s current compliance assistance efforts and the on site consultation program, to ensure that small businesses have the information needed to provide safe workplaces?
6. Given the length and difficulty of the current OSHA rulemaking process, and given the need for new standards that will protect workers from unaddressed, inadequately addressed and emerging hazards, are there policies and procedures that will decrease the time to issue final standards so that OSHA may implement needed protections in a timely manner?
7. As we continue to progress through a new information age vastly different from the environment in which OSHA was created, what new mechanisms or tools can the agency use to more effectively reach high risk employees and employers with training, education and outreach? What is OSHA doing now that may no longer be necessary?
8. Are there indicators, other than worksite injuries and illness logs, that OSHA can use to enhance resource targeting?
9. In the late 1980s, OSHA and its stakeholders worked together to update the Permissible Exposure Limits (PELs) (exposure limits for hazardous substances; most adopted in 1971), but the effort was unsuccessful. Should updating the PELs be a priority for the agency? Are there suggestions for ways to update the PELs, or other ways to control workplace chemical exposures?
Here are my answers…
1. Reward positives, create competition to be the best (positive peer pressure), and realize that people are involved (that should be taken several ways). Ok, those are my generic positive approaches. Here is a specific approach – buy the domain www.reportmyworkplace.com (I checked it out on Go Daddy, you can see in the picture that it is available) and have people anonymously upload pictures and videos from their workplace. Use the court of public opinion to shame the worst offenders. Here’s the tough part – don’t fine them – go in and help them – turn this negative into a positive. Think how it will look in 6 months when an update video can be posted with the positive changes in the workplace, employee interviews speaking of improved morale, manager interviews speaking of commitment to safety. This workplace can become a leader for safety. Additionally, this will improve the image of OSHA as an agency who is here to making a difference in the lives of the worker.
2. In my world it would be the level of safety in emerging energy facilities. I’ve worked in a refinery and in an ethanol plant – night and day – enough said.
3. Become approachable, have a face, a personality, use humor, etc. There are many things to be learned from leaders in social media that can be applied to engage the individuals who make up OSHA in the EHS conversation. Engage us on a personal level and the people who make up OSHA will gain insights into our thoughts on your programs and initiatives. Specifically, Jordan Barab had a great blog Confined Space (it’s still #3 on Google for keyword “confined space”!) that ended in 2007. Mr. Barab you have engaged a community before, please do it again…This is an open invitation to OSHA and Jordan Barab to engage EHS professionals here on Today in EHS (Video, UStream, let’s do something).
4. Enlist individual volunteer advocates who truly care. A federal enforcement agency may/will NEVER be able to reach the hard to reach; but there are those of us who want to make the workplace better who would volunteer to help. If someone at OSHA reads this…I’m offering my services, time, and talent; let’s find a way to reach those in need.
5. Yes, improve your marketing – do a better job of reaching the groups and industries that need help. This could be tricky because if marketed well more on site consultants would need to be hired and with great success ultimately total fines would be reduced. The new measure of success would become declining fines…
6. I’m on the other end of this one – the minimum is not enough / meaning compliance is not enough – best practice is the only way to work. I wish I had a good answer for this one but I don’t.
7. I think OSHA wants to hear some web based computer type answer here (my opinion), but technology should be leveraged to create personal contact. Nothing will reach the hard to reach more effectively than someone looking them in the eyes and saying I care about your wellbeing. Some online community training site will never do this. Also, I think my answers in questions 1 and 4 are applicable here – create safety leaders through helping those workplaces in need and enlist volunteers who care.
8. Yes, perception surveys, balance sheets, public opinion, public surveys, etc. Perception is not always reality but people know the facilities in their communities that need targeted. Also, bad balance sheets mean cut backs…
9. YES update them, I’m on the other end of this one again, we use the latest TLVs. I don’t have any good ideas here on how to update the PELs…
Ok I gave it my best in answering these questions, too idealistic? Do you have any better answers/ideas? Please leave them in the comments!
Here is the link to the OSHA Listens event – http://www.osha.gov/as/opa/osha-listens.html
When videos are posted from the event I will link to them on this website.
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Sam:
I enjoyed reading your answers and agree with most of what I read. I think some were too idealistic but nothing beyond what most of us wish would happen. I will comment item by item.
1. OSHA will never let go of the “hammer”. If for some reason, they did not fine a company they would, at least, want to threaten them.
2. I would say it is ergonomics. Not that I want new regs, (let’s not go through that again) but for a subject that affects us all, it’s ergonomics.
3. Nothing to add here.
4. I may be a bit cynical, but I believe that, in this age of uber-information, a large portion of those who have been called unreachable want it that way. A lot of workers really choose to put in their shift and go home and forget about it. They may be ignorant of current trends and regulations but that is because they want it that way.
5. It is going to be very hard to improve marketing when the “new sheriff in town” is so proud of 6 and 7 figure fines. If it were me, I would be ashamed at my agency’s failure at having to resort to such fines.
6. To come right out and say it, I don’t care if it takes 5 years to finalize a rule. I am not in the business of compliance. My job is to keep workers safe. The two are not the same. I need to do all I can to keep all our employees working. Not because OSHA says so, but because injured workers have a huge impact on the bottom line. No one wants people hurt. But if we are honest, we simply can’t afford injuries.
7. OSHA should become more like consultants or advisors. Be a guiding force not an inforcer. Show us how we can do a better job of keeping our workers healthy. If we get fined out of existance, then you (OSHA) no longer care if the people who used to work here are healthy or not.
8. Exactly! Ask people what they think. Then listen to the answers.
9. I agree. We also use TLVs. I really do not see the need for PELs.
Everything above is my personal opinion. I have worked a lot of years making safer workplaces. I became active in plant safety soon after OSHA was hatched. You know how us old men are. All of us have opinions, some just smell worse than others.
This comment originally posted on SafetyCommunity.com.
Bill – Great comments! I love this quote “I am not in the business of compliance. My job is to keep workers safe. The two are not the same.” I have a new idea for OSHA – more practical – Stay tuned I will post it next week!
Like the rest of our current government, OSHA has been taken over by an academic elitist who, unlike real world practitioners cannot relate to everyday chalenges to overcome resistance to working safely. Excess Fines are a testimonial to two things – the current effort at redistributing wealth (socialism) and the failure of OSHA to work effectively with safety professionals in the field in an effective collaborative manner.
Why should government work hard at anything when you can simply penalize people into submission – just tell everyone it for their own good and they will certainly all believe it. OSHA is now just another repressive arm of the government takeover of the ecomomy – currently at 51% and growing. Safety – yeh , right.
Good ideas. But do you really think that a government agency will implement anything that makes sense?
OSHA will take decades to change.
Now they just make a lot of noise and beat their chest about all the fines and violations they have issued. And make threats.
Martin / safemba,
Unfortunately many EHS professionals’ greatest challenge is management commitment and OSHA does have its place (including their fines)…don’t want to get over political, but I think I will write an article on this to explain my views. Thanks for the comments! Let’s have some real discussion on this when I post that article!
A Top 5 most popular article on Today in EHS – What do you think? – http://todayinehs.com/2010/03/osha-listens-to-me/ #OSHA #Safety
This comment was originally posted on Twitter