Thought Leadership


Keep risk assessment out of OSHA’s hands

April 12, 2013
A commentary appeared in a recent edition of a national safety magazine.  Among a number of points designed to paint an optimistic picture of OSHA’s leadership was one that stated:  “For the first time, there are meaningful discussions about moving OSHA away from a prescriptive to a risk-based approach and getting this nation off the decade-long plateau of work-related fatalities and injuries that each of us, regardless of political perspective, should be disappointed to have allowed to happen on our watch”. 

I penned the following letter to the editor, in response, as follows:

“It states in this article that there are meaningful discussions with OSHA on moving OSHA away from prescriptive approaches to a risk-based approach to regulation. I have two questions: Why?  and  How?

Why? 

Risk assessment of any kind is a “value-add”of safety professionals in collaboration with our workplace colleagues and clients.  Why would we want to have the government regulate risk assessment or risk-based evaluations and in the process define our professional options about it?  That portrays us to the public and to our employers and clients as extensions of the government instead of as independent, value add professionals.

How? 

An essential for risk assessment or risk based evaluations is establishment of mutually acceptable and reasonable levels of residual risk. How could OSHA ever define reasonable risk in a practical dimension within the extreme political agenda environment that OSHA's leadership creates and within which OSHA functions?”

In other words, what that commentary says is that safety is all about big government solutions.

 Fatalities and injuries will just disappear if there can just be more government regulations and OSHA can be influenced to adopt risk-based regulations.  

ASSE has a podcast site on Apple’s iTunes Store and also at www.asse.org/education/virtual classroom.php. I just discovered this recently.  These podcasts are free. These are the audio portion of webinars and similar online sessions offered in the recent past by ASSE.  Most are about 1 ½ hours in length. If you need to listen in segments instead of the entire 1 ½ hours, you can stop mid-presentation, and resume later where you previously stopped.

One session currently available is entitled:  Ten Reasons Why Your Risk Assessments are Inadequate.  The two presenters discuss each reason in depth and then answer questions. 

In view of folks enamored with getting OSHA to take over the safety professionals’ risk assessment “value-add,” I suggest you listen to this podcast and then consider the following: 

Risk Assessments are a value add for our profession and we are developing our skills at it. Do we really want OSHA adding its complexities and its political agenda here?

 I certainly do not. 

The risk assessment inadequacies are issues that we must address ourselves, professionally.  And we can!

We need to separate our professional image from OSHA so that we can establish ourselves as an independent, “value-add” profession.  Our OSHA relationships as safety professionals should be a respectful handshake, not a hug.  Respectful also should include a willingness to push back when the political agenda is surging, in order to protect our professionals and our employers from that agenda.   Risk Assessment is our professional “value- add”—not OSHA’s. 

If OSHA cannot get injuries and illnesses down and citations down, how could it ever manage a risk assessment approach—not to forget that residual risk is not a concept that OSHA can handle? OSHA and OSHA compliance is Basic Safety, no more than that.

This column is solely the opinion of Tom Lawrence.  It does not necessarily represent the views of the St. Louis Chapter of ASSE, (where Tom is a member and heads up government affairs)  its officers or its members.

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