Articles by Tom Lawrence CSP, P.E.

OSHA’s I2P2 idea – Not quite gone and not forgotten

By Tom Lawrence CSP, P.E.

When OSHA released its Spring Regulatory Agenda, the Injury/Illness Prevention Program had been moved to Long Term Action. In the immediately previous regulatory agenda, I2P2 had been on the proposed rule schedule for September 2014.


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When OSHA wins by losing – An alternative opinion

By Tom Lawrence CSP, P.E.

Aaron Trippler’s commentary on “When OSHA Wins By Losing” (ISHN OSHA Regulatory Alert—03-17-14) was interesting. However, I believe the winners when OSHA loses have not been appropriately identified. The real winners are:  1. S&H Excellence/Sustainability and 2. S&H Professionals.


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Puny ole OSHA? No for me…

By Tom Lawrence CSP, P.E.

OSHA may be “puny” relative to other government agencies but it is far from puny for its regulated community jurisdiction, particularly, for safety professionals and our employers, when the leadership of OSHA is all about radical left wing political agenda.


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Testimony of Tom Lawrence to OSHA’s Public Hearing on Improve Tracking of Workplace Injuries and Illnesses

By Tom Lawrence CSP, P.E.

I am Tom Lawrence from the St. Louis, MO area.  I have chemical engineering degrees and 43 years’ experience as a safety professional.  I am here today to vigorously oppose this proposed regulation.


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OSHA’s electronic injury/illness recordkeeping data regulation,

or OSHA adopts Saul Alinsky’s “Twelve Rules for Radicals”
By Tom Lawrence CSP, P.E.

The current administration looks to Saul Alinsky’s “Twelve Rules for Radicals” for their guidance. OSHA has now stepped in this direction and away from safety principles. Their first foray was the Shaming Press Releases.


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OSHA’s “Top Ten” citations: A case of failing to write doable regulations

By Tom Lawrence CSP, P.E.

This is the time of year when OSHA announces their top ten citations of the past fiscal year.  There are few changes in this top- ten list year after year.  Even though the list is of the complete standard’s name, it is usually only one or two sections of a standard that repeatedly makes this list. 


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I2P2 will be the scourge of the “best” safety programs

By Tom Lawrence CSP, P.E.

There was a statement in a commentary in the Wall Street Journal a couple of months ago: "A fundamental principle in medicine is that if you get the diagnosis wrong, you'll probably apply the wrong therapy. A corollary is that if the therapy isn't working, increasing the dose may make things worse."


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Keep risk assessment out of OSHA’s hands

By Tom Lawrence CSP, P.E.
No Comments
A commentary appeared in a recent edition of a national safety magazine.


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“Prevention” is not appropriate in I2P2 language

By Tom Lawrence CSP, P.E.

When Secretary of Labor Hilda Solis resigned her position, the talk became what might happen to OSHA’s planned Injury/Illness Prevention Standard (I2P2). Secretary Solis had announced this initiative in early 2010. The stated purpose was to require employers to establish a plan that would prevent violations of OSHA standards and that would protect workers from violations of their workplace rights.


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Stop the OSHA standards cheerleading

By Tom Lawrence CSP, P.E.

One objection of mine to adding more OSHA standards is that the standards cited frequently (top ten in frequency) remain generally the same year to year. Sometimes they shift position in frequency order. Sometimes the numbers of citations trend up or down, but generally it all remains in a controlled range.


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