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Why can't OSHA just reissue the Program Guidelines and Program Evaluation Profile? Makes sense from a safety and health standpoint but fails the political context.

I think, for the most part, that the priorities for OSHA were about where we all feel they should be. I am pleasantly surprised to see that a General Industry Combustible Dust Standard made the top five.

Regarding OSHA's ability to impact safety culture, in 1986, the American Dental Association unsuccessfully sued OSHA to block the Bloodborne Pathogens Std (BBP). The ADA argued before the US Court of Appeals that if OSHA forced dentists to wear gloves, patients would be freaked out and no one would go to the dentist.

Regarding regulations being unable to elicit culture change, it reminds me of an issue that goes still further back. I remember when the Civil Rights laws were passed some people complained that you can’t force (white) people to like or be nice to (black) people. This has to come from the heart, and laws can’t help, and may make things worse.

On the one hand, providing business (and government) leaders with a template (I2P2) on “what good looks like” in terms of leadership, participation, organizing, facilitating, and measuring organizational safety systems using contemporary strategies makes sense.

Regarding the proposed I2P2 requirements; once it is a standard, that opens a number of potential problems. And once that door is open, it cannot be shut.

I have been around since the beginning of OSHA and it is interesting to read thoughts from safety professionals on influencing OSHA, or the inability to influence OSHA.

Full disclosure: I am a white, 59 year old, 30+ year safety guy. As you could guess from my age, my degree is not safety. I have worked in engineering, construction, a university-based state OSHA consultation program, and for a very large manufacturer. Politically, I am a conservative-leaning moderate. That said, I have some problems with David Michaels when I hear him or read what he says.

Bureaucrats like Michaels and Barab say they don’t believe the (injury and illness) numbers industry is submitting to them so the answer is more bureaucracy. Safety and health pros have become wallpaper hangers. I’ll tell you, no one is going to enter this field in the future and OSHA is doing its level best to destroy small companies with fines and drive large companies overseas with administrative nonsense.