tag:blogger.com,1999:blog-32296656657132250602012-02-16T07:23:21.273-05:00A (hopefully thoughtful and thought provoking) view of OSHA from the inside.Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.comBlogger931100tag:blogger.com,1999:blog-3229665665713225060.post-52183935578113702082010-09-30T17:00:00.000-04:002010-09-30T17:00:08.299-04:00

I got a request to start a new thread on the Crane standard, but since I'm an IH and don't have much crane experience (and no experience yet with the new standard) I'm posting the request here in the hopes that others can bring about a discussion: I have a suggestion for a new blog thread. Why has OSHA adopted new technology for insulated links for use with cranes without doing sufficient

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-13874794378964546952010-09-29T17:27:00.000-04:002010-09-29T17:27:50.897-04:00

So this morning I had a radical idea on how to deal with our PELs.  Everyone on the planet knows our PELS are horribly out of date, they're from 1968 or 1970 (general industry vs construction) and many don't take into account health effects that may occur at lower exposures.  So here's the idea: Withdraw the standards, both 1910.1000 and 1926.55.Totally insane isn't it?  When it first occurred

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com4tag:blogger.com,1999:blog-3229665665713225060.post-42001362134206313232010-08-19T15:51:00.000-04:002010-08-19T15:51:24.810-04:00

The last poll is closed and a new one has been opened:  Should OSHA Exist? The last poll was close, 68 to shut 'er down, 67 to keep trudging on.  Since the poll was really about finding out if people are still reading, I'm keeping the blog.  Keep the comments coming, even those that disagree with me, just be respectful of me and others reading and commenting (you'll notice that 4 of the 5 I

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com15tag:blogger.com,1999:blog-3229665665713225060.post-60594302506716160572010-07-23T17:19:00.001-04:002010-07-23T17:20:03.890-04:00

Below are my Top 10 Things Every Young CSHO Needs to Know Before They are Let Loose on the World. Never Lie.  Beyond the moral and ethical aspects of honesty is a practical one, if you get caught lying during deposition or as a witness, you are done professionally.  You probably won’t be fired, but every opposing attorney in the area will know what you’ve done and your contest rate will skyrocket

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com26tag:blogger.com,1999:blog-3229665665713225060.post-25901441742587611912010-07-12T12:57:00.000-04:002010-07-12T12:57:42.057-04:00

This is one of the comments from my previous post: "The problem with the slow exchange of thoughts and ideas is just that, it's slow. I think most people would like a larger volume of subject matter at a faster pace with some bad ideas (and even some disrespectful material) versus a limited volume at a slower pace." The commenter makes a fair point, the problem is I'm not willing to

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com19tag:blogger.com,1999:blog-3229665665713225060.post-44317592377616750562010-07-07T13:54:00.000-04:002010-07-07T13:54:25.435-04:00

Please note the new poll.  Since I changed the look of the blog my Google Analytics are gone so I can't tell if anyone is even reading any more.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com9tag:blogger.com,1999:blog-3229665665713225060.post-24670562294045608322010-06-27T19:46:00.003-04:002010-06-27T20:18:41.748-04:00

PAWA, aka Protecting America's Workers Act, aka H. R. 2067. I finally had a chance to read through PAWA today and what I read was both good and bad. The bill has some 20 plus sections, of which I thought 10 were significant. One part, Section 203, I didn't bother reading, it has to do with discrimination, which is something I don't know much about (for those who may not know, OSHA uses

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com7tag:blogger.com,1999:blog-3229665665713225060.post-22640631523274824282010-06-20T16:57:00.002-04:002010-06-20T17:23:49.517-04:00

What must it be like to be an industrial hygienist or safety specialist for BP right now?You probably thought by the headline that I was going to bash BP on their safety record like everyone else, didn't you? Well I'm not going to do that, enough people are doing that already. Nor am I going to try defend the indefensible, but what of the honest people who work for BP?I realize that no body

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com5tag:blogger.com,1999:blog-3229665665713225060.post-62564100748705005482010-06-20T15:34:00.002-04:002010-06-20T15:39:00.972-04:00

People constantly disappoint me. I have left the comment section open so anyone could post a comment without my interference, but I did so with the hope that people would be respectful, but the Trolls have proven that civility is beyond their capability, so I have closed the comments down. For those who choose to participate and agree to be respectful I'll post your comments when I can. Keep

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com3tag:blogger.com,1999:blog-3229665665713225060.post-39347697921956123692010-05-12T10:39:00.002-04:002010-05-12T11:27:38.534-04:00

Every day OSHA sends it's staff an e-mail with a list of S&H/OSHA related links to articles gathered from the Internet. One of the article today really got my attention: UMW, Upper Big Branch victims' relatives sue MSHA.It's not that MSHA is being sued, that happens all the time to both MSHA and OSHA, it's just part of the job. The part that makes me uncomfortable is that UMW is asking a judge

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com47tag:blogger.com,1999:blog-3229665665713225060.post-33101271967302845022010-04-06T11:56:00.003-04:002010-04-07T14:05:38.808-04:00

People drive me crazy. They complicate things that don't need to be complicated and simplify things that can't be simplified. The graph I referred to in my last post was from an article by Charles C. Johnson at Andrew Breitbart's Big Government website. Hmmmm, imagine that, an anti-government website saying bad things about a government agency, I'm shocked. I'm also not going to get into

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com110tag:blogger.com,1999:blog-3229665665713225060.post-68326787862689396782010-04-06T11:28:00.003-04:002010-04-06T11:55:46.600-04:00

Sorry for the long absence, busy. I know, I've already used that excuse, and I've said I would try to do better, but I have been busy and I will try to do better.In my last post I said I wanted to have a S&H contest, but I can't seem to find the right show on TV. I thought it would be best if we could use a show/video that is posted on the internet instead of having to record something. So far

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-7086823130738118052010-02-22T13:28:00.002-05:002010-02-22T16:07:20.274-05:00

No, I haven't abandoned the blog, I've been very busy, those newbies can't train themselves. Actually, I'm not sure I can train them either. The kids right out of school think they know everything and can't seem to comprehend that they're actually pretty stupid. Those who came from consultation or private industry spend half their time complaining about the amount of documentation needed for

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com19tag:blogger.com,1999:blog-3229665665713225060.post-67871159915078632122010-01-14T10:39:00.002-05:002010-01-14T10:44:09.823-05:00

Please people, I'm begging you, stop with the political commentary, this isn't the place for it. All anti-government, conservative vs liberal, Democrat vs Republican rhetoric will be deleted!

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com23tag:blogger.com,1999:blog-3229665665713225060.post-49046426704401592392010-01-06T10:22:00.002-05:002010-01-06T12:20:34.043-05:00

Any one who follows OSHA's press releases has probably noticed a recent jump in the number of sig-cases (a sig or significant case is any OSHA case where the proposed penalty exceeds $100,000). I've certainly noticed a jump, although I don't have the numbers to back it up.The left-wing politicos will, of course, claim it's the current administration doing what the previous one failed to do. And

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com37tag:blogger.com,1999:blog-3229665665713225060.post-64698642845653159942009-12-14T11:30:00.002-05:002009-12-14T14:12:23.391-05:00

As anyone who follows OSHA knows by now, Dr. David Michaels was nominated and confirmed as the new Assistant Secretary for OSHA. Someone recently posted a comment asking me what I thought of Dr. Michaels, and in one of the strangest moments in my life, I realized I have no real opinion!I had never heard of Dr. Michaels before his nomination, but I guess my sense is that he is a good selection.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com9tag:blogger.com,1999:blog-3229665665713225060.post-18254236629981878462009-11-10T14:04:00.002-05:002009-11-10T14:36:42.436-05:00

Some of you have been asking what happened to the OSHA Underground, and I think I've figured out why that site went down. I got this e-mail from Google, the owners of Blogger:Hello,Google has received a subpoena for information related to anonymous comments posted on your blog. The case is entitled Secretary of Labor v. Wal-Mart Stores, Inc., United States Occupational Safety and Health Review

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com44tag:blogger.com,1999:blog-3229665665713225060.post-86287155753983982522009-10-30T16:56:00.002-04:002009-10-30T17:17:27.733-04:00

The Houston South Area Office issued BP a record citation today: $87,000,000. That's right 87 million dollars!Some people who support the current administration are going to jump up and down and say "See, I told you!" But I would note one thing, this case was built on the 2005 case (actually the settlement agreement from that case), whcih was conducted under the previous administration. The

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com18tag:blogger.com,1999:blog-3229665665713225060.post-45223074612465727372009-10-28T15:46:00.002-04:002009-10-28T17:44:38.629-04:00

First let me add my congratulations to the OSHA Underground for being named to the LexisNexis Top 25 List of Workplace related blogs. It's great that they got that recognition!Next, from a commenter:"Thanks for posting again! I was hoping my comment would elicit a post by you....how about distracted driving as a topic? Apparently it is the #1 killer in the workplace- The US DOT had a summit 2

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com17tag:blogger.com,1999:blog-3229665665713225060.post-41331881171578452942009-10-16T14:57:00.003-04:002009-10-16T17:36:25.949-04:00

Anonymous said:"This has nothing to do with the post, but Abel, where are you? You have not posted in a month! We miss you...."Thanks, since I've never had an employer open up his arms and say "Glad to see you," it's kind of nice to be missed by at least one person who reads the blog.You know how fraternities and sororities have Hell Week? CSHOs have Hell Month. And it's not a one time event,

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com10tag:blogger.com,1999:blog-3229665665713225060.post-29404588674383933582009-09-14T17:05:00.003-04:002009-09-14T18:33:45.432-04:00

I have a question: What happens to workplace safety and health if health care reform actually goes through? Has anyone thought about it?Please don't jump in and leave comments about how health care reform is good or bad for the country, I'll just delete those posts. My question is not whether or not we should have health care reform, my question is what happens to safety and health if it comes

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com19tag:blogger.com,1999:blog-3229665665713225060.post-11506738228518894462009-09-13T07:41:00.002-04:002009-09-13T07:59:36.284-04:00

Yesterday, after noticing that the last post has generated 34 comments, I decided that maybe we need to have a better way to discuss things than on the back pages of a blog, so I've set up a forum, the OSHA Above Forum. The web site is http://oshaabove.freeforums.org/.There are a couple of downsides to this new forum, first, because it's free, there will be ads. If enough people use the forum

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com8tag:blogger.com,1999:blog-3229665665713225060.post-1440083708211213822009-09-01T18:15:00.002-04:002009-09-01T18:39:31.073-04:00

The poll results are in, and I have to admit I'm a little surprised by them. Not the "Is Abel a Shill?" poll, I kind of expected that, although I find it somewhat counterintuitive that someone would view me that way and still read the blog. If I though someone was shilling, I wouldn't read their blog.For me the surprise was what standard people thought OSHA should work on next, the results are

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com40tag:blogger.com,1999:blog-3229665665713225060.post-45646830953530497232009-08-24T01:57:00.001-04:002009-08-24T01:59:17.215-04:00

I got this comment last week, and the commenter asks a great question:"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?"Any ideas?

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com9tag:blogger.com,1999:blog-3229665665713225060.post-34325445624475180672009-08-12T11:24:00.004-04:002009-08-12T13:44:13.553-04:00

From a commenter:AbelYou sound like a schill for OSHA. You point out OSHA problems but you defend OSHA always in the end. You are biased and have no creditability. You can delete this post since it is to you, but you have been revealed. You are 100% bureaucrat and apparently can't help it. You probably think HR 3200 would be a great health plan since the government would run things.Amusing.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com12tag:blogger.com,1999:blog-3229665665713225060.post-21681985394336090652009-08-11T13:16:00.002-04:002009-08-11T18:20:21.237-04:00

Part of a comment from the last post:"Most of the attorneys I have worked with have been really great. Some cases, CSHOs are permitted to contact SOL in advance for advice - you need this or that, shore this up, etc. It's been a great relationship. Of course, there's a few that you grimace when you hear who drew your case."It was kind of buried in the last post, but I did say "It's also important

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com5tag:blogger.com,1999:blog-3229665665713225060.post-50093011460985428282009-08-04T10:27:00.000-04:002009-08-04T10:30:50.376-04:00

It seems that we, as an agency, are sitting around holding our collective breaths waiting for an Assistant Secretary. With the nomination of Dr. David Michaels, and after having been stuck in neutral for almost a year (and something like 21/2 of the last 5 years), we're finally one step away from having some direction. For some of us who have been around for awhile, which direction isn't

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com10tag:blogger.com,1999:blog-3229665665713225060.post-53781135252466035682009-08-03T15:47:00.002-04:002009-08-03T15:56:29.166-04:00

The newest poll is up.I thought the latest poll results were interesting, the "None" response had more votes than "Big" and "Huge" combined. It's too bad the polls don't allow for some minimal demographics. I would bet Jordan Barab's salary that most, if not all, of the OSHA people who voted for Big or Hugh changes had less than 10 years with the agency.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-973557319389775892009-07-28T18:02:00.003-04:002009-07-28T18:17:47.717-04:00

The White House issued a press release a little while ago announcing the nomination of Dr. David Michaels to be the head of OSHA. Congratulations Dr. Michaels, and welcome to a world where public health, science, politics, law and bureaucracy all collide into the big mangled pile of frustrations, forgotten dreams, lost ideas, fading idealism, and reality that is OSHA.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com6tag:blogger.com,1999:blog-3229665665713225060.post-59943824819395267082009-07-24T14:38:00.004-04:002009-07-24T17:24:41.026-04:00

The OSHA Underground asked an interesting question today:"WE wonder after 39 years, why don't we have standard penalties for routine violations?An unguarded press would be worth the same in Maine to Florida."I would like to hear what others think, but obviously I have to put in my two cents.I have never agreed that all violations are created equal. If I inspect an injection molding shop that has

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com8tag:blogger.com,1999:blog-3229665665713225060.post-58054110043843133842009-07-20T10:17:00.003-04:002009-07-20T12:28:43.662-04:00

Does anyone like coding? Does anyone care about coding? I used to assume the answer to both of these questions was an emphatic no. As it turns out, I was wrong.I'll admit right up front that I'm horrible when it comes to coding. I've been through phases where I've used every code I could find for every inspection, even those codes I knew were out of date. I've also been through streaks where

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com10tag:blogger.com,1999:blog-3229665665713225060.post-38004983075965354442009-07-15T11:11:00.002-04:002009-07-15T13:22:15.140-04:00

I just received this comment on an earlier post that I wanted to bring forward:Wayne Gray and John Scholz have published research indicating that OSHA inspections do make a difference. You can check out their paper "Do OSHA Inspections Reduce Injuries? A Panel Analysis." Also "Inside the Black Box," co-authored by Gray and John Mendeloff, which was published in the March 2005 issue of Law and

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com4tag:blogger.com,1999:blog-3229665665713225060.post-26445702517137533202009-07-13T14:05:00.002-04:002009-07-13T17:38:35.809-04:00

I was perusing the Whitehouse.gov list of nominations the other day, just to see where the department stood in terms of unfilled appointments, when I noticed that Thomasina Venese Rogers was named to Chair of the OSHRC. I don't follow the OSHRC closely, but Ms. Rogers has been been the Chair before and has been on the Commission since 1998, having been appointed by both President Clinton and

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com11tag:blogger.com,1999:blog-3229665665713225060.post-26374411211370453302009-07-11T16:59:00.003-04:002009-07-11T18:38:56.381-04:00

Couple more comments on evaluations to follow-up on. First:"We keep reading that the law doesn't allow CSHOs to be evaluated based on the number of inspections. Where is that in the law? When you quote it to me, read it closely. Doesn't it say RESULTS of inspections? How does that prohibit being evaluated based on productivity -- as opposed to the percent serious, or the size of penalties, etc.,

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com19tag:blogger.com,1999:blog-3229665665713225060.post-38372840473906092172009-07-08T15:52:00.002-04:002009-07-08T19:00:18.452-04:00

I got this comment on CSHO evaluations I want to follow-up:"I do not understood this bizzare obsession with 'lapse time.' I'm not sure exactly what lapse time indicates. It's been said that low lapse time indicates quick abatement. This assumes that most employers do not act in good faith to correct a violation as soon as the CSHO brings it to their attention. Typically this is the exception to

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-9296000371252939002009-07-06T10:54:00.002-04:002009-07-06T11:39:48.930-04:00

I received a comment/question from JT that I want to discuss.A very difficult question. I personally would prefer an objective "totality of job performance" standard, allowing evaluations to include all the tangibles and intangibles that don't necessarily show up in the numbers. Who's going out there and taking some initiative? Who's sitting around just collecting a check? Who does their homework

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-7487036033698823102009-07-02T13:14:00.003-04:002009-07-06T11:47:47.026-04:00

Here's the list of possible factors that have influenced the drop in Injury/Illness rates, in no particular order. If you have any ideas, leave a comment or send me an e-mail and I'll add it to the list, and thanks to the people who have sent me e-mails with additional ideas.The shift of jobs to other industries (note: when a manufacturer down sizes, it is usually the least experienced employees

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-50086403075240550892009-07-02T12:00:00.002-04:002009-07-02T13:13:21.256-04:00

The last post brought out a couple more comments, the first commenter asked:How should CSHOs be evaluated?To which a second commenter responded:On numbers and lapse time. At least partially. If we set goals for them to achieve (like we do for the ADs and AADs) at least they'll have a starting place. And that will eliminate the low performers/deadwood on staff.Let's put aside the fact that we

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com6tag:blogger.com,1999:blog-3229665665713225060.post-37884823082927544692009-07-01T16:08:00.003-04:002009-07-01T16:52:39.569-04:00

The last poll closed with a curious, although not totally surprising, result. I think most people in OSHA believe that we, as an agency, fair better under a Democratic administration than we do under a Republican administration (please, that's not a political statement, it's just an opinion of the perception of a difference). The top two vote getters were Scannell and Henshaw, both appointed

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com3tag:blogger.com,1999:blog-3229665665713225060.post-48012478380300025152009-06-30T14:15:00.002-04:002009-06-30T17:59:40.436-04:00

In the last week the Pump Handle has posted two interesting articles, one on how slow the administration has been to put forth nominations for DOL, and the other on a FOIA request at MSHA. The first post I'll let you read and draw your own conclusions about.The second post is the one that really made me sit up and laugh, it reminds me of our own Ergonomic Case Development Procedures. Does

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com3tag:blogger.com,1999:blog-3229665665713225060.post-6743756242070219222009-06-22T13:51:00.002-04:002009-06-22T14:10:03.680-04:00

Quick follow-up on a comment from the June 15, 2007 post. The commenter said:feasible abatement is NOT a requirement to support a citation where a standard is being used.It may however be an affirmitive defense from the employer. All the CSHO has to establish is hazard, exposure and knowledge.Feasible abatement is part of the 5a1 supportive documentation, but not when there is a standard.This

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com3tag:blogger.com,1999:blog-3229665665713225060.post-38113791320280772142009-06-18T15:49:00.003-04:002009-06-18T17:38:12.058-04:00

Here are a couple more comments from RT I want to share and respond to, but in reverse order.Additional thought - what keeps an OSHA inspector from going down the Scenario 2 route?E.g., citing an employer for 5 different 5(a)(1) citations/items if they didn't follow 5 different provisions of a consensus standard like the NFPA, and rack up $35k in penalties?We can't cite a company for violating

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com3tag:blogger.com,1999:blog-3229665665713225060.post-81124095945084133442009-06-17T09:46:00.002-04:002009-06-17T12:30:57.081-04:00

I received the following comment from RT that I want to bring out and respond to:"Good description of 5(a)(1), I agree. But I still see it all the time where OSHA uses consensus standards to prove up a 5(a)(1).For example, in the example you mention, at the hearing, when OSHA is asked to show that the hazard was recognized by the employer or the employer's industry, the SOL attorney will

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-73861326198892982692009-06-15T18:35:00.004-04:002009-06-16T15:45:03.732-04:00

I want to clarify for the non-OSHA people just how we use the General Duty Clause to issue a citation (we generally refer to these as 5(a)(1) citations in favor of the term General Duty Clause), and specifically the role that consensus standards play in those citations (this is for you John).Section 5 of the OSH ActBelow is Section 5(a)(1) of the OSH Act:(a) Each employer --(1) shall furnish to

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com8tag:blogger.com,1999:blog-3229665665713225060.post-86717255994829119602009-06-10T13:38:00.002-04:002009-06-10T15:30:46.987-04:00

If anyone wonders why I get so frustrated at the OSHA Underground, just read Mondays post and then follow along below."The Press release is posted on the OSHA site.Who ever is running the site is keeping up with the times."The press release came out the same day the citations were issued! We can't issue a press release before the citations, can we?"Why is it so hard to put these General Duty

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com16tag:blogger.com,1999:blog-3229665665713225060.post-17173396878599557392009-06-08T21:32:00.003-04:002009-06-08T21:57:30.773-04:00

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

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com37tag:blogger.com,1999:blog-3229665665713225060.post-89153456850687964742009-06-02T13:07:00.002-04:002009-06-02T14:15:27.846-04:00

Here are the two comments I received on how OSHA could measure success:"The use of the data collected for the Site Specific Targeting Program might be a starting point since the same sic codes are used most of the time A comparision of older establishment lists with newer lists could help establish repeats and provide an indicator of improvement.Just a thought...."This is a good thought. We

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-65743050098192216062009-05-26T10:23:00.002-04:002009-05-26T16:26:44.797-04:00

How does an agency like OSHA measure success? Maybe the better question is: How should an agency like OSHA measure success? This whole discussion is predicated on the idea that we must provide some measure of our efforts. Some people will make the argument that we should just do our jobs and not waste time measuring what we're doing, after all, the resources used to make those measurements

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com6tag:blogger.com,1999:blog-3229665665713225060.post-74685710506650129532009-05-22T11:49:00.003-04:002009-05-22T11:55:12.066-04:00

A friend of mine sent me this article from Slate, which discusses the safety and health problems commonly found in public university research laboratories. Even though Slate's conclusion is that the funding agencies need to require better S&H compliance, I think it also argues for OSHA jurisdiction over local government employees such as, oh I don't know, college researchers.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-27339915536422912552009-05-20T15:28:00.002-04:002009-05-20T16:02:20.101-04:00

Two weeks ago the Pump Handle posted a short excerpt from the confirmation hearing for the new Solicitor of Labor, below is part of that testimony (which I have copy/pasted from the Pump Handle):Senator Murray: “This committee has had a number of hearings about workplace accidents and the aftermath. One of the things that has become apparent is families of victims have very little say in OSHA

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-82381241819430833492009-05-20T14:24:00.005-04:002009-05-20T14:57:48.172-04:00

Just one I have to follow-up on:"Abel was responding at length to my anonymous question about OSHA's impact. I appreciate the thought Abel put into his response, and I'm mulling it over. I haven't commented again until now, so that weren't my incendiary bombs thrown above."I recognized the difference in writing styles. The "bomber" seems to be an anti-government type who's been dubbed "The

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-79389259109982697292009-05-18T09:52:00.003-04:002009-05-18T16:21:48.488-04:00

There are some comments I want to follow-up on. First:"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

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com10tag:blogger.com,1999:blog-3229665665713225060.post-5201394828073829992009-05-15T14:35:00.002-04:002009-05-15T15:30:01.939-04:00

Is OSHA a Paper Tiger? I received two different comments with two different perspectives on that very question:"Good safety is good business. That's the bottom line. Good companies realize that; bad ones don't or don't give a shit. It's critical to distinguish between the two groups.OSHA is a paper tiger. What really gets executives' attention is insurance costs, bad press, and downtime from

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com6tag:blogger.com,1999:blog-3229665665713225060.post-61121410434781775932009-04-29T10:44:00.004-04:002009-04-29T10:54:18.137-04:00

This was left as a comment for yesterday's post, it's very much worth reading:"In the early 1980s, I was a laid off Safety Professional and accepted a job at OSHA as a temporary position (until the recession cooled off.) My passion for the profession, however, only “heated up” after experiencing the "sense of job accomplishment" while working at OSHA -- i.e., through the authority vested to a law

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com5tag:blogger.com,1999:blog-3229665665713225060.post-61854648017867554442009-04-28T10:22:00.002-04:002009-04-28T14:18:21.898-04:00

Today is Workers Memorial Day, a day we all recognize as a time to lament the loss of workers throughout the world. There are plenty of rallies and demonstrations out there for you to participate in if you wish, but I use this day to reflect.Anyone out there who thinks we have one of those cushy government jobs should spend a couple of days with one of us as we do a fatality investigation. It's

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-16115380988239838862009-04-22T13:42:00.004-04:002009-04-22T13:45:08.190-04:00

I received an e-mail with a few more suggestions on why BLS numbers continue to drop, so check them out and if you have other suggestions let me know and I'll include it on the list.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-12104159540700180242009-04-20T13:45:00.003-04:002009-04-20T15:01:28.166-04:00

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

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-29560398154781977072009-04-16T15:06:00.003-04:002009-04-16T17:01:48.154-04:00

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

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com7tag:blogger.com,1999:blog-3229665665713225060.post-76442519506092127682009-04-10T15:16:00.002-04:002009-04-10T15:27:45.417-04:00

An OSHA friend recently forwarded me an e-mail conversation he had with one of his friends about what direction OSHA should head. Here's the part that really got me thinking:"If I'm safety czar, I end fatalities first, permanent disability second. We need a motor vehicle standard, and better tools to enforce fall protection - almost always top 3 in fats. Ergo to me is a huge can of worms

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com5tag:blogger.com,1999:blog-3229665665713225060.post-17084008857496760562009-04-10T14:45:00.001-04:002009-04-10T14:47:22.296-04:00

The Buffalo News is still hammering OSHA. How can they not understand that no one should die at work?

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-10145586985602377192009-04-09T17:40:00.002-04:002009-04-09T18:49:04.536-04:00

Several comments came in that I'm going to address. First:"Doesn't an appointed acting usually become the OSHA head? I know Snare did not, but he seemed the exception."No, my memory is that neither Henshaw nor Foulke were appointed as DAS before being nominated. The nominee for Assistant Secretary is expected to stay away until they are confirmed. Second:"What does a political deputy do? Make

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-16876773824452564702009-04-08T22:13:00.002-04:002009-04-08T23:16:53.554-04:00

By now most of us have seen the e-mail from Don Shalhoub announcing Jordan Barab as the Deputy Assistant Secretary (DAS), but here's the text of Don's e-mail:"We are pleased to announce that Secretary Solis has selected Jordan Barab to be Deputy Assistant Secretary for OSHA and Acting Assistant Secretary, effective Monday, April 13. Jordan comes to us from the House Education and Labor

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com5tag:blogger.com,1999:blog-3229665665713225060.post-52241963570474126122009-04-06T17:31:00.002-04:002009-04-06T18:30:36.358-04:00

Remember in one of my previous posts I complained about how OSHA can get slammed, but we can't defend ourselves? Well here's a great example. Today the Buffalo News posted an article about the citations they received for conditions that lead to the death of one of their reporters, Tom Borrelli. Here is the opening paragraph:"Sixty-two reporters died doing their jobs last year. As far as anyone

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com7tag:blogger.com,1999:blog-3229665665713225060.post-30292977071659806112009-04-03T10:58:00.003-04:002009-04-03T14:56:55.101-04:00

I really do love this stuff. The anonymous anarchist/conspiracy theorist commenter is at it again (but anyone else notice that he/she still hasn't provided any solutions, only criticisms?):"So it's settled! You favor a "Police State". Remember Big Brother is watching you! (ala the novel "1984")Police states are not interested in answers, they are only interested in POWER! You sound an awful lot

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-31700910154882216492009-04-02T10:49:00.003-04:002009-04-03T04:58:28.406-04:00

I received a few of comments on the interview which I would like to share and rebut."Kane and me."OK, I'm not an English major, so sue me."Great job except for one thing. Joe Dear? Please. What he did was a knee jerk reaction to a hostile congress. Roll-out or as its been called Roll-over was a joke and has left a bad taste in the mouths of many. A putrid taste we still experience daily.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com4tag:blogger.com,1999:blog-3229665665713225060.post-79368025077047545662009-04-01T18:15:00.002-04:002009-04-01T18:22:31.874-04:00

Today Occupational Health and Safety Online posted interview questions they asked both Kane and I. The questions covered a wide range of OSHA issues and you can find our responses here.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com6tag:blogger.com,1999:blog-3229665665713225060.post-4877132327427930092009-03-30T18:05:00.002-04:002009-03-30T18:08:26.924-04:00

I've extended the deadline for the poll question on the right, please encourage your friends and colleagues to vote, I'm especially hoping CSHOs will vote, maybe someone in DC will notice the results.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-16979258423253914462009-03-30T18:03:00.000-04:002009-03-30T18:04:13.553-04:00

I just can't let this go. On March 9th I posted my thoughts on injury and illness data. On March 10th I got this comment:"Did you drink the Kool Aid too? I suggest you check out a previous Pump Handle post on this subject and review the statistical analysis published in the technical literature:I suppose she (Chao)and those at OSHA who drank the Kool-Aid choose to ignore the empirical evidence

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-48903485419842042242009-03-25T17:25:00.004-04:002009-03-25T18:06:29.025-04:00

There was an anonymous comment on the last Ergonomics post that I want to bring out. The commenter said:"I disagree. I don’t see “substantially similar” meaning no ergonomic standard. What I do see is that OSHA can have ergonomic standards written for specific industry sectors. The national standard was a one size fits all standard and would have been cumbersome for everyone to have to comply

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-7025787737439600832009-03-23T18:26:00.002-04:002009-03-23T19:12:29.925-04:00

The OSHA Underground posted a short article on ergonomics today, I just want to comment on the article, I'm not going to get into the whole issue of ergonomics today (maybe later). Kane posted the California Ergonomic standard (it's very short) and asked if that was so hard to adopt into law, and the short answer is: Yes, it is.First, Congress rescinded our ergonomic standard under the

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-10020749455400519582009-03-20T16:33:00.002-04:002009-03-20T17:12:54.009-04:00

The Pump Handle today posted the nomination of M. Patricia Smith as Solicitor of Labor, along with a few observations on Ms. Smith's career. I'm intrigued, there is a chance here to see a significant change in the way we handle cases. For the first time in several years I feel that old spark of optimism, it's not a flame yet, but it is back.What the Pump Handle didn't mention was the nomination

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-67887066615056809132009-03-19T17:49:00.002-04:002009-03-19T18:06:47.857-04:00

I have a couple of comments I want to bring out to clarify something. An anonymous commenter wrote:"IL protected its public workers since 1987 under the IDOL. It is misleading to say they were not protected. I am sure many states are similar."That comment was responded to by another anonymous commenter who had previously commented:"Didn't say they weren't protected. Just said the program is not

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-86359675309695551752009-03-19T13:20:00.002-04:002009-03-19T13:35:08.137-04:00

CSHOs, why not get involved! John Astad at the Combustible Dust Institute is looking for a CSHO with some experience conducting combustible dust inspections to write a post on how we conduct those inspections. I could take a stab at it but I haven't done a dust inspection in a few years, which obviously means I haven't done one under the current NEP. You can do this anonymously if you like,

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-43750109565256685242009-03-18T18:06:00.003-04:002009-03-18T18:59:44.634-04:00

Wow, 11 comments, people are actually read this? If I'm not careful this may become like work, yikes. I want to first point out that my original post dealt with Federal OSHA inspecting state/county/municipal workers, not having the states do it, that's a slightly different argument.Having said that, please, read the comments, they are very good, thoughtful comments. Michael Wood (the

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-90021529520991517082009-03-18T17:54:00.004-04:002009-03-18T18:05:10.769-04:00

First, thanks Cindy for posting the regulatory text to the ANPR withdrawal, I didn't even think about doing that. For those who want to see the full reg text just click on the comments below the post on Diacetyl.Second, to the anonymous commenter who said "Popcorn makers have taken diacetyl out of popcorn which protects popcorn workers and (more important for popcorn makers) consumers. Diacetyl

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-34201500387576690802009-03-17T11:20:00.003-04:002009-03-17T12:06:50.734-04:00

The OSHA Underground posted a short article on a Chemical Safety Board (CSB) recommendation that OSHA cover all public employees, not just federal employees. While I agree with this in principle, I'm willing to bet dollars-to-donuts that it will never happen.The first obstacle to local government coverage by OSHA is the lack of political will to make it happen. No state, county, or municipal

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com13tag:blogger.com,1999:blog-3229665665713225060.post-22871784631851475872009-03-17T10:37:00.002-04:002009-03-17T11:19:36.903-04:00

Both The Pump Handle and OSHA Underground had short posts today on our withdrawal of the ANPR (Advanced Notice of Proposed Rulemaking) for diacetyl. Neither really came out and said if this was a good thing or a bad thing, but I think it's a good thing.First, NIOSH has been unable to state with absolutely conviction that bronchiolitis obliterans (popcorn lung) is caused by diacetyl. The

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-23607431885930184362009-03-16T21:31:00.002-04:002009-03-16T21:35:27.271-04:00

An anonymous commenter asked: "What is a FACE program?" FACE is Fatality Assessment and Control Evaluation program. Check the link to read about the program.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-42024323426734158562009-03-16T10:49:00.002-04:002009-03-16T11:05:02.652-04:00

This is another good comment posted anonymously that deserves some thought and discussion, and I need to thank the author for taking the time to write it. Even though I agree almost word-for-word with the commenter, in a later post I'll explain why, unfortunately, it can't work.[To answer commenter John's question, within OSHA, SOL means Solicitor of Labor (it never even occurred to me that it

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-43992154975933621462009-03-16T10:45:00.001-04:002009-03-16T10:48:31.970-04:00

J left a comment on illnesses that I wanted to make sure everyone sees:"A little insight from a state fortunate enough to get substantial funding from NIOSH to run a FACE program and from BLS to run CFOI: we essentially don't count illnesses. Acute exposures like carbon monoxide we count; toxic inhalations that lead to organ failure months later we try to count; but cancers we don’t touch for the

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-74255815945160829712009-03-13T15:50:00.002-04:002009-03-13T17:11:59.931-04:00

I want address the fourth anonymous commenter from yesterday, the person who asked about illness fatalities. The questions were: "Have you seen the 55,000 number, is it verifiable, and if it's true how come it's not news?"The answer to the first part of the question is yes, I have seen the statistic of 55,000 deaths from injuries/illnesses for last year. The break out is approximately 5,000

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-50498437483063047562009-03-13T12:02:00.002-04:002009-03-13T12:17:09.020-04:00

The OSHA Underground posted an entry on our new budget, and while I don't disagree with anything they said, I do want to throw out a cautionary note: those 100 new CSHOs aren't going to hit the ground running. Brand new CSHOs typically get attached to a senior CSHO's hip for about a year as they learn the job, then it takes anywhere from 2-4 more years for them to get good at their jobs (there's

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com4tag:blogger.com,1999:blog-3229665665713225060.post-30394459743440848012009-03-13T11:33:00.002-04:002009-03-13T11:59:39.047-04:00

To Tom the commenter: Read OSHA Underground's blog post on the John Prouty Construction significant case, then convince me that someone isn't getting paid by labor. This is exactly how paid bloggers work, they are master spinmeisters, they take fact and turn in on its head to support their position. Let me spell this out very simply SECRETARY SOLIS DIDN'T HAVE SHIT TO DO WITH THIS CASE!!! I'm

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-44656838135773450922009-03-12T15:54:00.002-04:002009-03-12T18:46:41.916-04:00

Yes, I really do love this stuff, one anonymous commenter says that injury rates aren't real and are contrivances of unions, the next one says I drank the Kool-Aid for trusting my own observations. This is fun.First, Dilligas, the examples of high dollar citations for recordkeeping were from 10 years ago, I haven't seen any in the last several years. Second, in the last 15 months (since 1/1/08)

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-30744070916857452702009-03-09T12:56:00.002-04:002009-03-09T15:04:16.866-04:00

Anyone who thinks the BLS injury and illness data are accurate, please let me know, so I can mock and ridicule you. Every one of us who have ever reviewed OSHA 300 logs (or OSHA 200 logs for us old farts) knows that there are all kinds of mistakes on the logs. Note that I said mistakes, not intentional omissions.We all know the big cases, Landis Plastics ($640k worth in 1997) and Saw Pipes (

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com5tag:blogger.com,1999:blog-3229665665713225060.post-70842949165384769562009-03-09T11:51:00.003-04:002009-03-09T15:10:46.269-04:00

I encourage everyone to read the comments that people are leaving, some of them are thought provoking (YES!! That's what I want). I want to address a couple of them now.To Blame the Victim: You obviously missed the point, I wasn't suggesting any course of action in regards to Whitmore, I even admitted up front I don't know much about the case. My point was that things are said that the agency

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-3118783915178260032009-03-02T13:20:00.002-05:002009-03-02T15:40:44.187-05:00

Recently a friend e-mailed me a news item in the Washington Post about a man named Bob Whitmore. The article was a discussion of how Whitmore, an OSHA employee, has been on administrative leave for over a year while OSHA does nothing about it. I'm not going to discuss the specifics of the case (because I'm not familiar with it), instead it raises an interesting and often frustrating conundrum

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-12505666952318784562009-02-27T11:48:00.002-05:002009-02-27T12:29:06.704-05:00

Today The Pump Handle (a great blog for public health issues that I highly recommend) had an interesting entry on the Bayer CropSciences plant explosion in Institute WV last year and Bayer's reticence in providing information to local emercency responders during the event. I mention the article because I believe this is the same site that was previously owned by Rhone Poulenc and in 1993 had a

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com2tag:blogger.com,1999:blog-3229665665713225060.post-9703351158598212332009-02-27T11:19:00.002-05:002009-02-27T11:34:16.319-05:00

Did you see the latest OSHA Underground post? In it Kane commented that the latest egregious case the agency issued was Secretary Solis coming out swinging. Wow, what a moronic thing to say. This case began last September, UNDER FOULKE! The new Secretary and her staff never even saw this case and, if they were briefed at all, it was after the citations were issued (the closing conference was

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com4tag:blogger.com,1999:blog-3229665665713225060.post-14181752968335012622009-02-16T15:56:00.002-05:002009-02-16T16:02:28.165-05:00

The Pump Handle is reporting that the Senate is scheduled to vote on Labor Secretary nominee Solis tomorrow, 2/16/09.

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0tag:blogger.com,1999:blog-3229665665713225060.post-19626519692970941322009-02-06T16:17:00.002-05:002009-02-06T16:53:36.593-05:00

My agency often gets criticized for how long it takes to publish a new standard, and there’s little doubt takes too long, but the criticism really is misdirected. I know how that sounds, like I’m defending the agency just because it’s my agency, but I’m not. There are many things to criticize within OSHA, and I’m a firm believer that constructive criticism can make a big difference in how the

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com4tag:blogger.com,1999:blog-3229665665713225060.post-16161538765652704532009-01-21T10:40:00.003-05:002009-02-06T17:15:56.040-05:00

The OSHA Underground blog had another interesting post today, in part by "CSHO Annie," who did an evaluation of IH inspections by IHs within the agency. The evaluation certainly wouldn't meet the rigors of a scientific study considering the factual errors, like the implication that there are 8 IHs in the Boise Area office (there are, I think, 3, the whole office only has 10 compliance officers)

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com1tag:blogger.com,1999:blog-3229665665713225060.post-34258003133686265992009-01-15T13:02:00.004-05:002009-01-21T15:51:13.286-05:00

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

Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.com0