When OSHA released its Spring Regulatory Agenda, the Injury/Illness Prevention Program had been moved to Long Term Action. In the immediately previous regulatory agenda, I2P2 had been on the proposed rule schedule for September 2014.
Aaron Trippler’s commentary on “When OSHA Wins By Losing” (ISHN OSHA Regulatory Alert—03-17-14) was interesting. However, I believe the winners when OSHA loses have not been appropriately identified. The real winners are: 1. S&H Excellence/Sustainability and 2. S&H Professionals.
OSHA may be “puny” relative to other government agencies but it is far from puny for its regulated community jurisdiction, particularly, for safety professionals and our employers, when the leadership of OSHA is all about radical left wing political agenda.
I am Tom Lawrence from the St. Louis, MO area. I have chemical engineering degrees and 43 years’ experience as a safety professional. I am here today to vigorously oppose this proposed regulation.
The current administration looks to Saul Alinsky’s “Twelve Rules for Radicals” for their guidance. OSHA has now stepped in this direction and away from safety principles. Their first foray was the Shaming Press Releases.
This is the time of year when OSHA announces their top ten citations of the past fiscal year. There are few changes in this top- ten list year after year. Even though the list is of the complete standard’s name, it is usually only one or two sections of a standard that repeatedly makes this list.
There was a statement in a commentary in the Wall Street Journal a couple of months ago: "A fundamental principle in medicine is that if you get the diagnosis wrong, you'll probably apply the wrong therapy. A corollary is that if the therapy isn't working, increasing the dose may make things worse."
When Secretary of Labor Hilda Solis resigned her position, the talk became what might happen to OSHA’s planned Injury/Illness Prevention Standard (I2P2). Secretary Solis had announced this initiative in early 2010. The stated purpose was to require employers to establish a plan that would prevent violations of OSHA standards and that would protect workers from violations of their workplace rights.
One objection of mine to adding more OSHA standards is that the standards cited frequently (top ten in frequency) remain generally the same year to year. Sometimes they shift position in frequency order. Sometimes the numbers of citations trend up or down, but generally it all remains in a controlled range.
