Thursday, January 15, 2009

In the beginning...

This should be an interesting experiment. Woodrow Wilson once said "I have always been among those who believed that the greatest freedom of speech was the greatest safety, because if a man is a fool, the best thing to do is to encourage him to advertise the fact by speaking." It is time to see if I am a fool.

The purpose of this blog is to allow me to vent some of my frustration with what Kane at OSHA Underground sometimes says.

Before I do that, however, I would like to first encourage everyone to read that blog, it has a lot of good information and some good commentary. And yes, even Kane usually provides good information and occasionally provides insightful commentary.

Having said that, however, WE do have problems with how shrill Kane often sounds. WE have noticed that he is usually critical, but rarely offers alternatives. Reasoned criticism followed by rational solutions or alternatives is great, and very welcome. But HE doesn't do that, HE simply complains.

Does our agency have issues? Damned right WE do. Have WE suffered under the Bush administration? Absolutely. But, as they say, if you aren't part of the solution, you're part of the problem, and WE haven't seen Kane offer many solutions.

Let's start with a recent posting on the SST program. On the blog Kane says, "WE did about over 10000 of these long inspections because it was Foulke's idea."

Wow, where to begin with this one. First, in all of Foulke's time with the agency WE didn't do 10,000 SST inspections. In fiscal year 07 WE did about 2060 SST inspections (that extrapolates to about 5,000 during Foulke’s tenure). Second, this program didn't start under Foulke, it wasn't his idea, it started under the Clinton administration, specifically under Charles Jeffress. Anyone remember the CCP program and before that Maine 200? The DC Circuit Court overturned the CCP, hence the SST was born. From April 1999 through April 2000, WE did about 2450 SST inspections. Notice the anything? WE are actually doing fewer SST inspections now than WE were then!

Kane goes on to say "
WE cannot show it had any effect on the safety of the companies WE inspected." Well, yes and no. Direct evidence? There's not much out there and what there is, isn't easy to get to (there are some inspection sites that end up on the list year-after-year, so if WE had an adequate data system WE could compare a company's performance over time). Anecdotally, WE think that most companies on the list do make progress over time. Beyond that, there are the BLS numbers (which many question, but that's for another rant) and the fact that WE simply don't see the huge injury rates that WE used to. Remember the days when WE would go to a site and see LWDII rates of 80 or 100 or more? Those used to be common, not so any more. And WE are not talking about self reported rates, WE are talking about CSHO evaluated rates.

Is the SST having an impact? Yes, it is. Could it be more or bigger? Probably. It would be helpful if some smart people out there could identify better methods of targeting, but WE have what WE have.

"WE saw ergo constantly show up on the 300 logs. Yet we have no standards." Has he not heard of the Congressional Review Act? The duly elected members of Congress, in early 2001 determined that WE should not have an ergonomics standard. Do WE agree with that? Nope, nor do any of my friends within the agency, or for that matter, my friends outside of the agency. But whether or not WE agree with it is irrelevant, the people have spoken (which doesn’t mean, of course, that they can’t change their minds, hint, hint Congress).

“WE don't even get the data to measure the results. It is "not important" as some key players said.” WE desperately want to know who those “key players” are and where they’re quoted as saying it’s “not important.” As with many things he say, WE think Kane is inferring things, instead of having hard facts.

“Eventually smarter CSHO's just cited a couple items and ran to the next inspection.” Hmmm. WE have dozens of friends who are CSHOs and know hundreds more. All of the smart ones WE know actually believe in what they do and do their jobs to the best of their ability. Now, there are some lazy CSHOs out there, and they will often only worry about getting their three citations per inspection before moving on and once in awhile you may even find a CSHO who has retired in place who does the same thing. But act like Kane suggests? No, most CSHOs aren’t like that.

WE don’t know where Kane, if he’s in a Regional Office or the National Office, he’s getting a very distorted view of a CSHO’s world. If he’s in an Area Office, he’s in a really crappy one.

Finally, many of the people I know who read the OSHA Underground blog despise the use of the royal WE, and the implication that Kane speaks for all CSHOs. Quite simply, Kane’s views rarely reflect the majority of the CSHOs, and for him to imply that he does is arrogant presumption.

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