OSHA's Own S&H

I received a couple of comments on how we deal with our own safety and health. Here's the first comment:

"I agree. I think that we should step up to the plate and demonstrate to employers that we are leaders. Does any one know what our TCIR/MSDs/etc rates are for the field? NO?

We should do everything that is required of the employers that we enforce. I can already hear the naysayers.... don't kid yourselves. We aren't any better (on average) than many companies out there. We're not. Fact.

So, why don't we start focusing this strong enforcement effort on ourselves? Who's with me...????"

Are you nuts? All Federal Agency injury rates are posted (I did a quick Google search and found them). The incident rate for all private industry was 4.2 in 2007. The incident rate for all of the federal government was 4.2 in FY 08. The incident rate for OSHA in FY 08 was 2.1. Yes, one-half the private industry and government rates. In FY 08 we had a total of 19 injuries that had lost time, 19! I've been in places that had that many injuries every week. Our lost time rate was 0.91, for all government it was 1.74 and for private industry it was 2.1. Unfortunately there is no breakdown of the causes of injuries. By the way, we had no fatalities in FY08, in fact, the data goes back to 1998, and we haven't had a fatality in all of that time.

So when the commenter says "We aren't any better (on average) than many companies out there. We're not. Fact." The judges say "Bzztt. Sorry, wrong answer." We are, in fact, better than most companies out there.

The second commenter responded to the first comment with:

"As long as OASAM has jurisdiction over OSHA, forget any real enforcement. They won't do squat. Further DOL is a certified Federal agency with a Safety and Health Committee, meaning that OSHA has no jurisdiction over the agency unless the S&H committee requests an OSHA inspection. Even then, OASAM has no real power and the RA's that won't rat on each other.

Thanks to the NCFLL, they bargained away the regional S&H committees in the last contract negotiations, so in effect, there is only one group running all of the S&H for the entire DOL(the S&H national committee). They are so in the pocket of anything OSHA needs to do that they are useless.

NCFLL you blew it! You gave away safety. You made OSHA and the rest of DOL weak safety organizations. This is to include MSHA.

OSHA will talk about what a great job they are doing in several of the regions, but what real oversite do they have? Anything comperable to what private sector has? The answer is no, and when they claim to be VPP don't believe them. Who is really evaluating their VPP status?

Answer======Other OSHA folks.

Hmmm. Duh they make STAR status VPP."

First, read the Directive: Federal Agency Safety and Health Programs, specifically section H.4. We can, in fact, file a complaint against ourselves. Why anyone would do this is beyond me, but it can be done.

Yes, the agency has a responsibility to protect my safety and health. To that end, I have great equipment, and excellent training. What more can they do? Region 5 requires their CSHOs to hang sampling pumps on themselves whenever they sample employees. Maybe that could be a national policy. Automobile accidents are probably our biggest threat, and certainly that is something that should be addressed. But what more should OSHA do for me?

My question is, where does our responsibility to protect ourselves lie? We expect companies to train their workers in hazard recognition and the controls used to protect themselves, but aren't we already trained? If I inspect a site and review a training record that has my education/training/experience I can guarantee that I would consider that employee adequately trained for almost any job out there.

When it's said that OSHA requires an employer to do this or that, is it really some nebulous concept of the agency or is it the CSHO? The "Agency" isn't doing the inspection, I am. The "Agency" isn't writing the violations, I am. The "Agency" isn't testifying before the ALJ, I am. I tell employers all the time, through citations, what they have to do to protect their employees, how can I, as a CSHOs, not be expected to do the same thing to protect myself?

I have certainly put myself in situations that I shouldn't have been in, situations that my AD would have chewed my ass off for if he knew. But I knew when I did it that it was something I shouldn't be doing, it was a conscious decision. If a CSHO puts themselves in harms way without realizing it, I have to wonder how good their hazard recognition skills really are.