Dear Subscriber,

John Henshaw became the head of OSHA in August, 2001 after a career in environmental health and safety in the private sector. He's occupied the OSHA hot seat longer than any agency chief save for Dr. Eula Bingham, who ran OSHA during the Carter years.

Business and/or labor groups take shots at every OSHA chief, and the main criticism of Mr. Henshaw has been the lack of OSHA's standards-setting. But his critics knew what to expect from the outset. At his Senate confirmation hearing three and a half years ago, he said his priorities were to improve OSHA's credibility and effectiveness through: 1) strong enforcement provided by competent inspectors; 2) outreach and education efforts to OSHA’s customers; and 3) increased and improved voluntary programs.

If nothing else, Mr. Henshaw, an avid sailor, has not wavered from his course.

ISHN questioned Mr. Henshaw at his office in the Department of Labor this past October about progress and obstacles he's encountered along the way.

WHY PROS RESIST THE BUSINESS CASE

ISHN: Making the case that safety adds value to a business has been a major theme of yours for more than three years now. Yet according to ISHN reader research, only 25-30 percent of safety and health pros attempt to make that business case for safety. Why is your message not connecting with more professionals?

Henshaw: I think there are still some pros out there who may not agree that safety and health add value. Some people don't believe it. They may be coming from the old school of safety that says, "We've just got to force it down people's throats."

Or maybe the idea that you have to force safety adds more weight to some pros. You know, "No one else can do safety and health, I've got to be the champion because nothing else will sell it."

We need to get off that old paradigm.

I'd challenge these pros to think outside the normal box. If you think you've got to be able to calculate the business case in hard numbers, you may not be able to do it in all cases. Or it may take so much time you may not be able to do it. And some safety pros aren't able to figure out where the data is located to make the calculations.

Don't wait for the data to support everything that you do. Don't get caught up in the weeds.

I'd argue that the good managers, people who lead organizations, do not always lead on the basis of objective data. They lead on principles, they lead on values, on vision. Some of the values are based on data points; some are not.

If we're too analytical on this, safety and health people are not going to get where we want to be. I'd ask our enlightened professionals to lead, like the good CEOs, on values and principles.

ISHN: Why doesn't OSHA budget money and manpower to conduct a national study that would canvass industry to conclusively document the business case for safety?

Henshaw: I'm not sure in a nationwide study we would gather enough data points. Plus, there may be confounding factors that go into the end results.

I don't know if governmental studies have the kind of oomph you need, at least in safety, that you might get from a few leading academic institutions. I think they can create it more than we can. And it's more sustainable. We issue a report and it's a flash in the pan. Coming from academic institutions and professional societies the quality of the data will be good and it will be more relevant.

CAN INDUSTRY MOVE BEYOND COMPLIANCE?

ISHN: You have preached the need to move safety and health programs beyond mere compliance. But some safety experts say that most of U.S. industry is fixated on compliance, and that's where their safety programs stop. Why is it so difficult to get companies to view safety more broadly?

Henshaw: Many folks might be confused because they are so far away from compliance that's a milestone that's yet to be achieved.

That's OK. But I'd make the argument if you're just focusing on compliance, then you are not a true safety and health professional. All you are is a compliance specialist.

The end game is to reduce injuries, illnesses and fatalities. If that's your purpose, and that's what every safety and health professional's purpose ought to be, then you can't stop at compliance. You really have to go on.

ISHN: What do you say to readers who measure safety performance solely by OSHA recordkeeping numbers?

Henshaw: It may be that they do not want to disclose what they do every day. They only want to say, "Trust me, I'm going to get you there. As long as I produce that, why would you care about the process?"

But most supervisors want to know your plan to reduce injuries. Anybody who has a vision of how to get to the end game, they ought to be developing leading indicators, or intermediate measures, so they can maintain their course and reach the final outcomes.

If you don't do that, then at the end of the year, if results are up or down, it's just by luck. If you don't have plan or process, what have you done to impact results? Just your presence isn't good enough.

ISHN: You have spoken often of the need for safety cultures within organizations. Why don't OSHA inspectors go beyond citing violations and issue a report card, assessing the company's safety culture? After all, they are interviewing employees, reviewing paperwork, walking through the plant.

Henshaw: There is nothing in our standards that say you must have certain elements of a culture. We don't issue a report card per se, but we do this in some of our activities, certainly our consultation programs. They have a form to assess what systems are in place. To some extent they talk about culture. And we do this kind of assessment in VPP sites.

We're not psychologists who study organizational cultures. That's some pretty high level stuff. We can't be there. Others will lead that charge and I commend them. But that's leading edge and I don't think we can do that.

STANDARDS

ISHN: Speaking of standards, you have mentioned that the regulatory agenda doesn't provide the cover that it used to. Are you saying in past years the agenda has been there more for PR value than practical value?

Henshaw: That in essence is where I was coming from. In my mind the agenda wasn't a roadmap because we weren't living to those commitments. That's one reason we were told by the courts to deal with hexavalent chromium. It was on the agenda so long and nothing was being done.

ISHN: Why do some of those items just grow mold on the agenda?

Henshaw: Because the agency can work on only what it can work on. I think it is inappropriate for us to list things on the agenda that we are not actively working on. If you have so many things on the agenda, then we lose our focus. We can't hold our managers accountable to those dates because we keep moving them around. It's a waste of time and energy.

ISHN: Why have you taken heat for paring down the agenda to what you say is doable?

Henshaw: It's a perception issue. The perception is OSHA is working on something if it's on the agenda. There's also the thinking that everything on the agenda is at least a priority. Take it off and the perception might be, "You took my thing off the agenda. I had it on the agenda." But the reality was we weren't doing anything with it.

ISHN: What do you say to readers who felt that when you came to Washington, as a life-long industrial hygienist, one of your priorities would be to update the permissible exposure limits? Was it a priority? And why was nothing done?

Henshaw: It is something that's dear to my heart as an industrial hygienist, knowing that the PELs were out of date. How to get at that in the most effective way was the hard part. And we looked at many different ways. I was hopeful that a consortium of interest groups would come up with some good ideas. That didn't happen. Maybe there are just too many diverse viewpoints.

It's still something we've got to address. How to do it is the hard part. It's going to take us 50+ months to come up with a rule for hexavalent chromium. These things take years because of all the things you have to do, the reg analysis, the information gathering, the risk assessments, feasibility studies, economic analysis.

ALLIANCES

ISHN: How do you respond to the criticism that OSHA has all these alliances, but they're really not much more than paperwork exercises? That OSHA doesn't have the resources to follow up on them all?

Henshaw: If those people would choose to look on the web site they'd see a lot of good work being done.

ISHN: Is there documentation on what the alliances are actually producing?

Henshaw: On the web site there is a lot of information on the alliances, what they are intended to do, and as we generate the outcomes, there is a description of the outcomes.

ISHN: If you judge alliances by whether the audience represented by the alliance is buying the message that safety and health add value, how do you measure the outcome?

Henshaw: In the long term, the outcome is reducing injuries, illnesses and fatalities in that organization, or the membership it represents.

OSHA CULTURE CHANGE?

ISHN: Has the culture of OSHA changed to be more cooperative, truly? Many believe once an enforcement agency, always an enforcer.

Henshaw: I don't think our folks like to be the bad guys. If there is a bad actor out there, then yes, we do what it takes to get them to change. That includes heavy enforcement. And we're not going to stop that.

I think our folks are realizing that our job is to the change the workplace where change needs to happen. Just by racking up the penalties, it may look good on somebody's performance review, you can send it up to Congress and it will look good, but is it really producing an impact?

Our people want to make a difference. And that difference is not doing a hundred inspections, but creating a change in the workplace.

Does everybody in OSHA feel this way? Of course not. But there is nothing more frustrating to a compliance officer who is really dedicated to producing a change than to keep hitting that same violator and nothing happens, nothing changes. There is nothing more frustrating if that's the only tool they've got to use. Our people like to use an array of tools, which we've given them the freedom to use.

ISHN: So would you say a culture change has occurred here?

Henshaw: I don't know if it's a culture change. It's a broadening of our abilities and the tools we can use. I don't think our people were very happy with inspections as the only tool. Our people enjoy being safety and health professionals, not just inspectors. It's frustrating when you want to offer help and people are afraid to call you. Our people enjoy being asked to help; they like being connected to people.

On the outside they appear to just be digital, you know, doing the job, checking the boxes, following procedures, citing when necessary. Well, they are very engaging people. They are mission driven and they are driving safety and health in this country.

Dave Johnson is the ISHN E-News editor. He can be reached at djsafe@bellatlantic.net, (610) 666-0261; fax (610) 666-1906.

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WE NEED YOU!

Are you a safety and health pro or a manufacturer or provider of occupational safety and health products or services who enjoys writing?

Shakespeare need not apply, but ISHN is looking for authors to publish short articles (1,000 words) in our monthly issues.

Topics include: safety success stories, close calls and personal experiences, training tips, use of software, engineering controls (machine guards, lockout-tagout), gas detection and air monitoring, confined space safety, personal protective equipment, and OSHA compliance issues.

If any of these topics interest you — or if you have other ideas — e-mail editor Dave Johnson at djsafe@bellatlantic.net

We will also consider articles you’ve already written but not submitted to any safety magazine.

Thanks.