Monday, April 20, 2009

Follow-up to Comments

I received a couple of comments on my last post that I want to share and comment on. First:
"Many clarifications are needed for the artile on safety and health. The one that most upsets me is that OSHA watches OSHA. If you are VPP Star or attempting such, you are audited by private industry (SGEs). That is correct. And let me tell you - they send the "top guns" to audit you. Safety and health is work both in government and private industry. If you want to be the best you must put forth the extra effort - just like the "outside"!"
I agree that it looks... questionable that OSHA evaluates itself for VPP, but then again I don't think we should be in VPP. VPP is about recognizing those who take safety and health above and beyond, but I think OSHA should do just that, without being recognized for it.

As for sending out the SGE "top guns" I have wonder about that. Under Henshaw we practically gave VPP away. Not including employees in the S&H process? No problem, you're doing everything else, so here's your Star. No respirator program? That's OK, we trust you to write one, so here's your Star. Obviously I'm indulging in a little hyperbole, but not much. There are companies that got into VPP with higher than industry average injury rates. How? By showing they had a good program on paper. Don't misunderstand, I love VPP, but it has to be earned, not bestowed.
"A national OSHA Safety & Health Program is so needed. I have reviewed the regional programs and the Chicago plan is by far the best. “One card does not make a deck.” To the Agencies benefit, some safety & health has already been integrated into directives, but it is not the way to go. Also, OTI addresses CSHO safety in many of their courses. However, it is a start and needs uniformity in terms of policy and procedures.

For example, how many folks know & follow the electrical best practices contained in NFPA 70E? Are all the CSHOs aware that the Construction Directorate incorporated 70E-2004 provisions as national policy (by interpretation letter)? Do CSHOs know these guidelines, including how to follow the arch flash boundary guidelines or that they need to wear FR clothing protective equipment when inside the flash boundary radius? Clearly, OSHA needs to improve with respect to its people being "qualified" to perform electrical inspection and testing activities?

On a positive note, OSHA can utilize experienced staff to develop an overall safety & health program elements – that is, someone other than a Program Analyst or professional without any field experience. The Region 5 program is a start and the Agency should expend resources to accomplish this important endeavor on a national basis."
I'm not sure a big national S&H program for OSHA is the answer. Certainly it doesn't hurt, but most of us have inspected large companies that have numerous work sites and have great written corporate S&H programs, but which aren't being implemented locally (nursing homes are notorious for this). Why? Because the local manager isn't committed to S&H. OSHA is no different than any large organization with numerous locations, the commitment to S&H goes only as far as the AD takes it, which is typically only as far as the RA takes it.

As for the arch flash boundary, I know it exists, but I don't know how far it extends. But then again, I'm and IH and if it takes more than a Woodhead, I'm making a referral. Part of any good S&H program is teaching people what they don't know, so they don't get themselves into trouble. I'm not qualified to inspect a crane, or an electrical junction box, or commerial SCUBA diving, so I won't put myself in those situations.


  1. The OSHA offices that have achieved VPP status do not evaluate themselves. The evaluation team is made up entirely of SGEs. That is what the commenter was referring to when they stated that the SGEs for the OSHA visits are the top guns. I do agree with you that OSHA should not have its own offices in VPP. We administer the program. We should not be a particpant. It just leaves too many people questioning the validity of the program. We do however need to implement a safety and health management system that is better than what we would expect to see in the best corporations. Safety and health is the reason for our existence. It is ridiculous that we don't take the lead.

  2. Only one comment. With OSHA's infinite wisdom in purchasing FR clothing, it was - one size fits all!!! Has anyone ever looked at the OSHA offices - tell me everyone was "one size fits all"!

    CSHOs can't get the work done because the legs are too long and no one can find FR thread to alter the jumpsuits. Some alternation places will not alter them because it is FR and do not want the liability of compromising it.

    Can we start with something simple first?