"Why would I report the lack of audiograms when the same people know I never had one in 5 years? Everyone who was in the field should be tested. The agency just does not want to eat the comp claims right now."You do understand that the agency doesn't pay WC claims, right? That's been one of the biggest obstacles in getting federal agencies interested in workplace safety and health, the claims don't come out of operating budgets. You know what you need to do, tell your AD or RA or the agency's Medical Officer. If you won't do that, it's on you, so step up and take some responsibility for your own safety and health. Second:
"Welcome back Abel. Glad to see that you have reassumed your duty station here."Thanks, but I never left it, we don't all get to work in an office every day. Next:
"And thanks for reminding us ALL that employers are responsible for safety and health in the workplace. Now, how about tackling the issue of small employers who are unable to pay OSHA penalties in these economic times. Or, in fact, larger employers who are in similiar circumstances. We're giving the auto industry so much money--do you think we might give employers a penalty break for a while. Not a break on making the workplace safe, just a break on the fines."NO! Not just no, HELL NO! We only fine companies when they aren't doing the right thing (contrary to popular belief, most of us don't actually enjoy that part of the job). If a company isn't doing the right thing it deserves the penalties, regardless of the current economic times. Besides, if a company is running so close to the edge that our paltry fines impact their bottom line that much, they are doomed anyway. No, in the same way that we all have to pay the parking ticket regardless of our financial situation, companies have to be held accountable for worker safety and health even in hard times. And finally:
"Not an idiot. 7.5 million workplaces with 1,000 inspectors plus not responsible for worker safety and health adds up to the definition of a paper tiger. It's not like you're the EPA.Ah, you're making a common mistake when it comes to OSHA's impact, you assume that the only impact we have is the direct impact from an inspection, but that's not the case. Think about it:
As far as impact of OSHA, if you point me to a study tracking back before OSHA was created that shows an increase in declining rates, I'll be happy to recant.
That doesn't mean OSHA is useless -- far from it. I see you folks more as the equivalent of that guy who sees one million starfishes on the beach, and throws one back. What are you doing? a friend asks. You'll never be able to throw them all back. And the guy says, yeah, but it makes a difference to this starfish.
That is, OSHA has an impact on specific companies, and that's worth doing. I didn't mean to imply OSHA's useless. Just too small for its task."
- In today's workplaces, how many companies don't have a HAZCOM program and MSDSs? The answer is not many (percentage-wise). I'm not suggesting every company is diligent about their HAZCOM program or MSDS's, but they have something.
- Most of the trenches I drive by today are sloped or have a trenchbox, it's a long way from 100% compliance, but it's a lot better than it was 20 years ago.
- How many scaffolds do we inspect that aren't fully planked, or don't have mid- and top-rails? Certainly a few, but now we typically find that one or two mid-rails are missing, compared to 20 years ago when it was common to find a scaffold with no mid-rails. And other fall protection, especially harnesses, are very common today, even if the lanyard is worn and may not hold.
- Find me a chemical plant that doesn't have a PSM program, including those we've never been to.
- What about healthcare? Safer medical devices are now the norm, not the exception (and that in just 10 years), Hepatitis B vaccinations are almost universal in healthcare, most hospitals have removed latex gloves by now, and more nursing homes than not, now have modern resident lift assist devices (not the old Hoyer lifts, which were just a modified car mechanic's engine lift).
- Check out the materials that were developed for the spray-on-bed-lining industry through the Alliance Regions V and VI had with the Center for the Polyurethanes Industry. Some of these efforts have lead the manufacturers to make process or equipment changes. Now convince me that materials like this that come from an industry association doesn't have an impact.
- Speaking of manufacturers making changes, 30 years ago if you walked into the local home improvement store of your choice, how likely were you to find a guard on a table saw? Now I'm not sure you can buy a saw without one. And the next time you buy a can of paint, ask the seller for an MSDS, I'll bet they give you one.
- Take recordkeeping, even with all of the discussion we've been having about hiding injuries on the logs, the fact is that most places don't hide injuries, and they have the logs!
I'll leave this with one final thought on this topic (for now at least), if we're so totally ineffective, why do the US Chamber of Commerce and National Association of Manufacturers (amongst others), work so hard to get rid of us?
As for the studies that show an increase in declining rates, that will have to wait (if it ever happens) I don't really have the time to go back through all of the journals to find them. If anyone knows of specific articles, forward them to me and I'll post them.
By the way, I agree that we, as an agency, are too small.