When I started this blog, I promised myself that I would never delete any posted comments (just SPAM). Part of what I had hoped to accomplish here was to have a frank discussion about safety and health and OSHA's role in protecting workers, but the last few comments that people have left have been mean spirited and way off topic, so I broke my promise and deleted two comments.
From this point forward, I'm going to refocus the blog towards OSHA's role in safety and health (including what OSHA could do better), which means no politics beyond those that relate directly to OSHA, and I will be the sole arbiter of what is or is not directly related. If you want to have a discussion of government's role in or lives, you need to go somewhere else, because it won't happen here. I am not singling any one commenter, the two posts I deleted were from opposite sides of the political spectrum.
This is where the mea culpa comes in, this blog got off track because I allowed it to, but the bigger sin was that I made it worse, and for both of those reasons I'm sorry.
To the commenter I dubbed The Anarchist, calling you that was every bit as mean spirited as what I accuse you and the other commenter of being, and I'm sorry. If you want to continue a discussion about governments role in our lives, please e-mail me or start you own blog and I'll subscribe. Maybe in the future I can act more like an adult.
I said this once before, and I hope I mean it this time: And now, back to our regularly scheduled programming.
Good job in stepping up, Abel. Here's an atta-boy.
ReplyDeleteThanks Abel, I appreciate that the focus is on the important discussions related to occupational health and safety.
ReplyDeleteHi Abel - why is Eula Bingham not in your poll of favorite former OSHA heads?
ReplyDeleteJust because I needed to cut it off at some point, so I decided to include only those appointed after 1980. If I included her then I would have needed to include all of them. Besides half of our CSHOs weren't even born when she was appointed (that's unbelievably depressing for old farts like me).
ReplyDeleteHi Abel. I am the "Anarchist" and your deleting my post was totally appropriate. However, to call my post "mean spirited" is to fail to recognize that I am the Jungian "Shadow" created by OSHA. OSHA "eats its own". In other words, I am programmed- as are you, to be critcally thinking, discerning, analytical, and observant. I am very impressed with the intellectual caliber of those who post at this site! Nevertheless, I do not tolerate the blanket dismissal of contributors like Kane, and the sophmoric diatribes and Ad Hominim Fallacies leveled at those who have been in the National Office and observed the sentient as well as the so called dead wood, which in many instances, happen to be belt way bandits (Contractors) who lack the philosphical foundations, technical background, and professional committment to the OSHA family in terms of protecting America's Work Force. Indeed, I called out one of your posters because they irritated me because they were reminscent of a faction of imposters that are ananthema to me. I will not apologize for that, since it would be hypocritical. However, I do aplogize for not sticking to the substantive issues at hand, and for my indulgence. Thanks for providing this extremely valuable forum/venue! I am honored to read the postings, and to participate. Abel, you and Kane are Yin and Yang -- dynamic and inspiring complements to one another.
ReplyDeleteRegards,
O'Shaman
O'Shaman, I'm glad you haven't abandoned the blog, I like it when people make us think.
ReplyDeleteIt's also interesting that you invoked Jung, since he also believed that our "shadow aspect" is where creativity comes from.
Hi Abel. That is an affirmative about the Shadow! As you know, it is part of both our personal and collective unconscious. It harbors the seeds of creation and destruction. It helps guide us during inspections. We have all probably had that subtle prompting when we stop before leaving an area, and decide to go back, and there it is, that hazard which was recognized at the unconscious level, and the prompting bringing it to the attention of the consious mind. What we need now is some of that creative aspect of the Shadow side to provide some safety archetypes to serve as guidance for the much needed paradigm shift within the agency, as well as within the various industries. We can progress toward being less adversarial, and still be an effective enforcement agency. I certainly hope that the so called self desribed "new Sheriff in town" doesn't send a message that OSHA is going to become heavy handed across the board, and that it is clearly communicated that OSHA will continue to work with Associations and Industry, but that "bad actors" will receive our attention in terms of escalated enforcement (inspections) and that imposed penalties will be determinded by compliance history.
ReplyDeleteRegards,
O'Shaman
Wow! Jung at its cutting edge and applied to organizational psychology! This is a must with respect to understanding OSHA and any organization. We must be aware of our own shadow and the individual shadow of others, as well as the collective shadow of the organization(s) we work for, and the organizations that we visit and for which we provide Compliance and Consultation Services. The previous poster is on spot! Its about time we move beyond the mere mechanical and outdated linear and concrete understanding of both individuals and organizations. We must learn to embrace systems theory, which is hinted at in the OSHA PSM Standard. Good Show O'Shaman! We must understand the import and tremendous influence that unconscious motivations and drives have on Safety. Quiz: to what extent can the unconscious discern between diametrically opposed or conflicting directives such as: Really assist employers in making workers safe and creating safe workplaces, and simply getting numbers to have a good evaluation and be held in good stead by your manager and/or supervisor etc.
ReplyDeleteRegards,
AHSO
AHSO! You are in league with the devil! There is no unconscious mind. Freud and Jung were nuts. Don't try to apply psychology to OSHA -- Clever -- AHSO --OSHA spelled backwards. You are backward.
ReplyDeleteGreetings! AHSO is really my name, so please do not make disparaging remarks about it. My ancestors may haunt you in your dreams. By the way, one of them invented the Fire Extinguisher used on aircraft! Anyway, I respect your right to express your opinion, but I do not agree with you that Freud and Jung had nothing relevant to say.
ReplyDeleteHowever, if you do not try to become aware of your unconscious biases and influences, the you may be a slave to them, and they could lead to your demise professionally and in the phenomenal world as you know it.
AHSO
AHSO, systems theory is too convoluted for an organization like OSHA to use. Also, it seems to me that the theory breaks down too easily with small organizations, like most of the employers we deal with. With chemical plants or auto manufactures it might work, but not Bob's Welding Shop.
ReplyDeleteAnd to the anonymous commenter who replied to AHSO, Jung and Freud may be nuts, but that doesn't make them wrong. I think the best CSHOs have an understanding of psychology. Whether they get that understanding innately, or though education or experience, an understanding of why an employer gets angry allows us to better deal with the situation.
Hi Abel. PLease expound on why you think systems theory is too convoluted for application to small mom and pop businesses. Whether CSHOs like it or not, they are at times practicing Psychology, Anthropology, and Political Science regardless of any formal training in these disciplines. The Process SAfety Management paradigm can be scaled down to fit any type and size of operation can it not...Regards,
ReplyDeleteAHSO
AHSO, first off, I am no expert in systems theory, it's not something they taught us back when I was in college.
ReplyDeleteHaving said that, and with my limited understand of the theory, I think it's too convoluted for OSHA precisely because most of us, especially us oldsters, have never studied it, at least not by that name, so we would have to reeducate the entire agency. But what do we educate ourselves in, and how? You’re talking about teaching a practical understanding of dozens of disciplines. I doubt a 2 week OTI course would be enough.
Beyond that, to answer your other question, I do not think the PSM paradigm can be scaled down far enough to address any operation. The PSM standard assumes a certain amount of knowledge in the areas of engineering and S&H. Even scaled down, it would still assume S&H knowledge. Bob's welding shop has 2 employees, and no expertise in S&H. They can't afford the ANSI standards or a consultant. They have a high turnover rate because the pay is only average for the county, which means Bob can't afford to spend 6 weeks training a new employee. Maybe it’s his personality or maybe it’s because he isn’t a good businessman, but everything about Bob stands in defiance of a systemic approach, his is a world of chaos, not order. Bob does not want performance standards, he wants specification standards, HAZCOM drives him crazy. This is part of the reality that CSHO’s face every day.
I do think that good compliance officers practice psychology, anthropology and political science, as you say, but you’re missing our overriding discipline: Law. As much as we would prefer to think of ourselves as being in the profession of public health, the simple fact is we aren’t, we are an enforcement agency.
I apologize for the delay in responding. Please note that Law and the enforcement do not operate in a vacuum, and are affected by the other disciplines such as Anthropology, Psychology, Politcal Science, History,Philosophy, Science and Engineering etc. OSHA Standards have underpinnings, which are predicated on these other disciplines. Why do we have Law? Why do we have certain OSHA Standards? As for systems, a crane for example is a mechanical system, and OSHA and ASME have Standards for cranes that are based on "physical laws". Safety Programs are systems and so are (Safety) cultural and organizational sytems, so why is this so mystifying. The politics of power plays a tremendous role in organizations, and it markedly affects safety and health. As for overriding priciple, Law does not over-ride the Anthropological domain, but to the contrary, Law and the other disciplines can logically and righfully be subsumed under Anthropology. Since Law is predicated on both the written and spoken "word", it is within the domain of Linguistics, which includes psycholinguistics, transformational grammar, Cultural Lingisuistics, and Sociolingusitics. As we all know, Psychology and Politics play a huge role in the ways in which we express ourselves within the socio-political arena. Further, by virtue of the fact that OSHA has an enforcement function does not preclude it from functioning to promote "public" and occupational health. Enforcement is only one means to achieve the goal, and effective enforcement makes use of the opportunity to further occupational health by assisting employers in identifying defriciencies in their S & H programs, organization, and Culture. To be sure, this requires knowing about the organization and culture, as well as having a good model to compare it to -- the concept of what constitutes "good" is Philosphical Question is it not. Isn't the form 33 System for evaluating S & h programs predicated on certain assumptions with respect to what consitutes good? After all, you have to score the company(s) nummerically on attrubutes, as well as provide a synthesis score. How does one arive at this whithout making value judgements? I believe too much blind patriotism to this kind of "system" may be dangerous. Hm, there I used the word system again.
ReplyDeleteAHSO
PS, the PSM sytem is a very logical system for safety that can an should be applied to smaller operations, but which only needs to be scaled down. Every Comprehensive Inspection within OSHA, the NRC, EPA etc. utilizes the systems approach, which is succintly outlined in the PSM standard. We are not talking here about the individaul requirements of the standard, but the overall concept and approach. This is rudimentary inspection process and technique.
ReplyDeleteNEO
I agree with Neo and ASHO. Too many inspections are being done haphazardly "willy nilly' without attention to the logical sequence -- raw material stock comes in the door, material is acted upon by a various processes, then it goes out the door. Those various processes can be viewed as activity variables that affect and are affected by other variables. Knowing what the variables are and how they interact is knowing about the "system." The various disciplines are components of the system that interact in order to achieve safe conditions as well as regulatory compliance or not.
ReplyDeleteO'Shaman
Ya'll are taking this way too seriously, and being too academic. Everybody knows that to survive in OSHA you have to dumb yourself down,i.e., shuck and jive -- smile in their face -- all the time you want to take their place --we eat our own and are backstabbers to be sure. We prey on the pride and vanity of others, as well as insecurity, which really makes folks dangerous, especially when they know they our incompetent. Yes want to look good for superiors and to climb up the down ladder. Ya, we talk about safety like bible thumping preachers, and we have turned it into a commodity with cookie cutter boiler plate S & h programs and inspection check list inspections. Dome folks just walk through and don't see anything, others write up the entire universe and bury themselves until they get burned out or promoted to a management position for which they are not qualified. OSHA is broken! Now let's hear some real discussion on how to get real and fix it -- or not.
ReplyDeleteBubba a.k.a Fumin'Neumann'
Nothing personal, but your diatribe is really sour grapes and should be removed from this board. There is absolutely no value or merit in degrading and criticizing the agency that employs you. You get to travel, have a secure job, (unless you screw up and openly criticize your superiors and the agency), you get training, and the opportunity to grow professionally. There is nothing wrong with understanding the intellectual and philosophical underpinnings our our undertaking. If you think that the discussion is too academic, then perhaps you are trapped in the Ostrich Syndrome,i.e., if you don't look anymore and think about the possibility of change, then you can slack-off because "reality is perception" and you have the right to your solipsic world view. Understanding systems theory is an integral part of being a CSHO. It may be couched in other terms, but you are dealing with it and talking about it all the time. A wire rope is a "system". To operate a crane safely you must know about mechanical systems and geometry, which also ties into the company organizational
ReplyDeletesystems, safety programs (systems), etc. The concept of "Safety Culture" is predicated on cultural systems that involve communication (specialized language) values, shared ideas and beliefs, technology, and organizational structure etc. The various components of the system interact and affect one another. Someone mentioned scaling down the PSM approach, which really is what we do if we evaluate a S & H program an identify hazards and root causes of accidents. There are different levels of abstract ability and cognitive styles that exist, and each must be honored. Our differences are what make us more adaptable a a species, for if we were all the same, then we would certainly lose a great deal of flexibility, since we learn from one another, and survive by sharing. Yes, I know political ambitions and power enter into it, and hinder the open sharing of information and/or knowledge,i.e., knowledge can be power. One- up-man-ship is not good for teams, and really does result in an "OSHA eats its own" phenomenon. However, we need grow in terms of our personal and collective self concept, and to have the functional ego strength to help one another actualize our full potential without being threatened. We should all be facilitators for the excellence in others, which does come back around in an ideal world. Ok, the world is not ideal, but we have to engage in relations with those who are sincere, honest, and real Safety and Health Professionals, as well as those who are not whereby we can only lead by example!
Doc
Hi Doc. Sort of disjointed comment,however, it was filled with good insights and a measure of wisdom. You alluded to the "politics of safety", and that is very real. Example, Tom Ridge recently revealed that he was pressured into raising the threat level presumably to help the Bush rats to get re-elected. We all know that money (bottom line) and politics (power) play a huge role with respect to the role of OSHA. Powerful lobbyist acting in the interest of large companies and corporate interest weigh-in on the S & H Standards that are promulgated. Yes, and when combined with the inertia of our agency, slow advance of scientific data (some research is credible and some is deeply flawed), and the process of rule making, worker S & H suffers. OSHA also vacillates between getting too chummy with industry, which horrifies the unions, and being to adversarial. It really is a question of balance is it not. Recently I learned about a State Plan State Director who wanted to nominate a large company by virtue of the fact that they have a great deal of political clout. Other companies that had better S & H records were not considered simply because the Director did not deem them fit due to lacking the ability to make him look good in the eyes of the Labor Commissioner and new Governor. This would have been done if not for the fact that the Director had to provide the Labor Commissioner with justification based on TRC and DART rates. The company the Director wanted to receive the S & H award had extremely high TRC and DART rates. By the way, a company that originally had been submitted for consideration by a CSHO had TRC and DART rates of "Zero" !!! This example is not intended to defame a Program Director, who is in a precarious position by virtue of his position being a politically "Appointed" position in a "Right to Work State" (Few Unions), but only to illustrate a point. The state where this Director has "control" recently lost its governor, and the new Governor has publicly indicated that his bias is for Business. Typically, this has meant that the state OSHA has been relegated to the status of paper tigers,i.e., only do enough inspections to keep the State Program from falling into the hands of Federal OSHA, since they would beef up enforcement and cost Business too much in fines. Further, a strong regulatory agency would discourage companies from coming to the state and providing more jobs due to the fear of enforcement. The poor Director of the State Program is between a rock and a hard place due to the new Sheriff in Town (Secretary and Asst. Secretary of Labor) position toward enhanced enforcement and increased penalties for bad actors.
ReplyDeleteRookie
Rookie. I have heard about the state you writing about, and the CSHOs are really demoralized, since they work hard to do bullet proof inspections providing huge amounts or supporting documentation in narratives and on the OSHA 1B only to have the penalties drastically reduced even for employers who have previously been granted a penalty reduction. Further, if employers want to make an Informal Settlement Agreement, they have to agree to work with the State's Consultation Program, which from what I understand, is located in the same facility. Some see this as not really being a voluntary participation in Consultation, but a form of coercion that affects the dynamic of the employer Consultation relationship. The reply to this from the Compliance Manager and Director is that they don't have to agree to take the settlement. This has resulted in many inspections being done superficially by enforcement, since they erroneously think that Consultation will come in and address all items by completing a Comprehensive Survey, which is not always the case due to the employer dictating the scope of the Visit. This system is seriously flawed. I have heard that Consultants are losing professional respect for compliance officers that go in with blinders so they can go on to the next employer to pump up numbers. Recently, it was reported that the Director and Compliance Manager indicated that the Compliance "Big Four" Initiative had conducted a multitude of inspections in Residential Construction that resulted in "file only" inspections,i.e., no alleged violations. A cursory drive around in the same areas is enough evidence that all is not well, and that the Director is grossly misinformed by the "numbers". Tell your inspectors to do "file only" inspections to pump up numbers and Form 55s and that is exactly what you will get. However, those who have a sense of professional ethics that refuse to be included in this shameless practice receive negative sanctions such as being threatened with disciplinary action and termination. By the way, another confounding variable the down turn in the Economy.
ReplyDeleteKing Fat
Wuz up King Fat. Yo - I know the dik-potato- ya'll jackin' jaw about in salt rock city. All show no go -- there it is check it out-- no honor -- just talk shit. Full of themself fascist all about numbers and fame game.
ReplyDeleteWall of fear
Shed not a tear
Cause the Bogeyman man is comin' to get ya!
Paper claws and clay built jaws
embrace the abyss of political dementia
Dictators bliss
You are so amiss
Your Cuban cigar smells just like stale piss
Golf clubs in window are just for show
The numbers game is all know
Wow! In the world of safety and health, what do the initials LS stand for? What State Program Director shows up and gives boring, insincere, long winded, and empty speeches. Clue, he breaks not his arm , but his Achilles heel patting himself on the back for his self indulgent spectacular performance? He doesn't even ensure that CSHOs (industrial hygienist) are provided physicals because they are too costly and interfere with his budget to print bullshit pamphlets that he thinks are going to save the workers. Safety begins at home, and CSHOs are workers too.
ReplyDeleteIs Salt Rock City derived from Salt Lake City?
ReplyDeleteThey have a new Mayor. PLease Clarify. I have friends who recently went to training there, they were treated great. The City was clean and beautiful. However, some CSHOs at that that office expressed chagrin about the state of affairs. Folks were concerned that local (state) politics would gut their program, since the Director seems to concerned with his own politcal positioning. In all fairness,State PRogram Directors are political appointees so they do have to keep the Boss' Boss Happy,eh.
Sounds like you are Canadian Mate. Me too, I love the US and OSHA -- left Canada -- but have some misgivings about the political influence of Safety.
ReplyDeleteAbel. You have missed the point. The PSM scaled down has to do with the approach of the CSHO or Consultant in terms of evaluating the S & H program , identifying hazards, accident root causes, and the "nature" nature of the Safety Culture. I say nature because we could state that there is a positive or well developed Safety Culture (formed), one that is in the formative stages, or one that is or reflects a poor Safety Culture. To be sure, there is a culture, but one could say that there is a negative Safety Culture where safety is of little value or concern, as opposed to the general typological category of presence or absence of a Safety Culture. All of this begs the question, what is culture in the fist place. Hmmm --- Anthropologists have several definitions for Culture, and cultural theories are legion. Hence, how do we define and evaluate a Safety Culture within the Safety and Health Profession? Do banners and slogans about safety fill the bill? Do the rehearsed and glib company S & H Policies , Mission Statements, and jingoistic slogans cut the mustard? Nay, what are the realtime actual values, beliefs, and conduct of employees and mangement which demonstrate the companies Cultural Domain called "Safety". A small company may not have a written program,but they may have a program that is clearly communicated to the employees that implement it, and who along with management create a good Safety Culture. Inspections are by their very nature an Anthroplogical enterprise.
ReplyDeleteDon Juan
Now we are getting somewhere! OSHA has actually had some great ideas over the last 30 something years, which even othre agencies have adopted and implemented. However, OSHA has often failed to benefit from its own insights. Why?
ReplyDelete"That's just the way it is -- somethings will just never change..."
ReplyDeleteThat is a cynical view isn't. We have to believe in the possibility of change like our forefathers.
ReplyDeleteA paradigm shift or revolution within the agency is in order. Change is possible, but many are burned out from the 60's and 70's. We forget how much change has occurred due to folks "hippies" joining the system in order to change it from within. Where and who are these unsung heroes?
I agree with Abel, all this theory can boggle the mind, and not all of us were exposed to systems theory in college. CSHO training does not address this, and typically only CSHOs with a certain talent and who have been with the agency a long time get to go to PSM training. I will someone could develop a class where the key concepts are presentd that we can use during our inspections without having to go the PSM course.
ReplyDeleteYea, I would like to thank Abel for this site where we can discuss our agency and professional ideas and concerns.
ReplyDeleteNeo
I voted that Abel is Shrill, but I believe this is a compliment, since it is good to have intensity,as as well as being "able" to lay it on the line. Many are unwilling to expose themselves for fear of criticism. Abel gives it out, but he can take it as well!
ReplyDeleteAHSO
I disagree, Abel is not shrill, but very much a gentleman and very bright individual.
ReplyDeleteO'Shaman
Wow, so much to catch up on, I'm going to have to figure out a way to keep my AD from sending me on the road.
ReplyDeleteFirst let me step back to NEO and O'Shaman's 8/19 responses to ASHO 7/24 response. NEO, not every comprehensive inspection uses a systems approach, as O'Shaman points out, some are done “willy nilly.” I would argue, however, that “willy nilly” doesn't automatically equate to bad. Keep in mind that not everyone thinks the same, some people think logically and some people think perceptively, it's the left brain/right brain theory of psychology. In my Legal Aspects course, a psychologist broke us into groups, gave each group a jar of M&Ms and told us to work together to describe what we saw. The groups dominated by logical thinkers said things like “There are approximately x number of peanut M&Ms, in a homogeneous mixture with a color ratio of approximately... etc.” The groups dominated by preceptive thinkers said things like “Rainbow, kaleidoscope, starburst, etc.” It was a very vivid demonstration of the different ways people think. My personal observation is that logical thinkers are good at finding physical evidence to reconstruct an accident, whereas perceptive thinkers are good at interviewing witnesses to reconstruct an accident. Both end up at the same place in the end. I am a logical thinker, and when I walk into a plant, like O'Shaman, I start at the beginning, but I've been with CSHOs who walk in, look around, and say “We'll start there.” Again, in the end, we still ended up at the same place. When I first started doing inspections, it drove me crazy to work with perceptive thinkers, but as I've gotten more experienced, I've learned to use that CSHO's skills to compliment my own.
That's not to say the everyone who works “willy nilly” is thinking perceptively, I know some CSHOs who are so disorganized and scatter-brained that they need to write “left” or “right” on their shoes.
Bubba, I will never, ever, dumb myself down, for anyone (some might argue that I won't dumb myself down because I can't dumb myself down any further and still keep breathing). But I do agree with you that a few practical suggestions would be nice.
Doc, I agree with much of what you said, but Bubba gets to keep his rant, he didn't attack an individual and he kept the rant focused on OSHA.
I'm going to set aside the state plan state issue for the moment, except to say I liked the poem, I just wished I spoke 20-something, yo.
Don Juan, I think I get what ASHO is trying to get to, I'm just not sure it's practical. The majority of my inspections are not comprehensive, most of them are complaints where the employee doesn't really know much about S&H. If I get a complaint about the temperature in an office building, am I really expected to take a systems approach to investigate it, when I can just take the temperature and says, “Here's some literature,” and be done? Or if I do a drive-by and see a trench or bad scaffold? Maybe I should take a systems approach to those inspections, but to me that seems be taking time away from other inspections. Maybe I'm just too old school.
ASHO, it's shill, not shrill. Shill is bad, shrill is simply not good.
And finally, I disagree with the commenter who said nothing will ever change. I've said it before, the agency today isn't the same as it was when I started.
Abel. You are instrumental to the whole of the Safety and Health profession! The way I see it, you assist me in and others in seeing beyond our shadow and blind spot. I am foever in you personal debt. Thank you for the service that you have done for our safety "Tribe"!
ReplyDeleteO'Shaman
I have to get some chow -- but Amen to O'Shaman's words. Abel -- you are indeed the voice of reason in the wilderness! Thanks for the all that you do!
ReplyDeleteAbel. I just checked in to see what condition my condition was in - and ya or yeah!
ReplyDeleteThank you for all that you do and for this website! O'Shaman said it for me -- you are truly a treasure. I like your objective and sincere opinions! You are like the Walther Cronkite of OSHA -- the person we trust to be non-partisan and objective in terms of interpreting the world of S & H aka OSHA. Thanks for being here! PS I like Kane too, and you are both essential to the balance!
AHSO
O'Shaman, Anonymous, AHSO, Thanks.
ReplyDelete