Safety and health program requirements

OSHA calls this the "centerpiece" of its current regulatory plan, one of the "most important" reg actions it has ever undertaken. A proposed standard is scheduled to be issued in June of this year.

Toward that end, OSHA has been convening stakeholders meetings to consider many, many questions. For example: should the rule cover all employers, or exempt small businesses, companies in less hazardous industries, and companies with good safety and health records? How does a one-size-fits-all standard give enough specifics on what constitutes compliance? What is "meaningful employee participation"?

The agency basically wants to build on its 1989 voluntary guidelines. Requirements would include periodic hazard assessments, accident investigations, hazard control/elimination, management leadership (employers must designate at least one employee to take the lead on safety and health), employee participation, training, and recordkeeping.

This is going to be one huge standard. OSHA is rolling into it exposure assessment requirements that were scheduled to be a separate rule, and is asking for input on whether to include medical surveillance provisions. The price tag (compliance costs) is estimated to exceed $1 billion annually, according to the agency. This guarantees opposition from the same Republicans and business groups who successfully derailed OSHA's ergonomics rule.

One industrial hygienist currently working on voluntary safety and health program requirements for the American Industrial Hygiene Association says there is "tremendous resistance" from business groups that fear even a voluntary standard will be used for litigation. Imagine, then, the fight OSHA is in for.


The political dust must settle before OSHA knows whether it will be allowed by Congress to continue work on a standard. At press time, there was still a chance that the agency's fiscal year 1996 budget might contain a one-year ban on developing an ergonomics rule.

Agency officials are playing it very safe right now- setting no timetable for future action. If permitted, the agency will push for a scaled-down standard likely to be limited to certain industries, facility sizes, or types of musculoskeletal disorders. It will probably emphasize broad programs to address hazards, rather than the step-by-step process of identification and control roundly criticized in a draft last year.

Indoor air quality

1996 will be spent "carefully reviewing the massive docket" resulting from months of public hearings and comments, according to OSHA. The next regulatory action won't come until fiscal year 1997- after the presidential election.


Throughout last fall sources inside and outside OSHA believed a proposal was close to being released. It could be out by the time you read this.

The proposed revisions should be a politically correct document: Instructions will run about 30 pages long, compared to the old rule's 85 pages. The OSHA Form 300, replacing Form 200, would be a standard 81/2 by 11 inches to be more computer friendly.

But OSHA wants to combine injury and illness sections of the recording form, a move sure to be controversial. Some safety and health professionals argue that this will make OSHA logs less useful. You can expect several years of hearings, comments, and debate before a final rule is issued.


A proposed standard is currently scheduled to be issued in June. Facilities where there is a risk of TB transmission would be required to have engineering controls, respiratory protection, medical surveillance, training, exposure control, recordkeeping, and work practice controls.

Permissible exposure limits

Work has started on drawing up new PELs for a small number of substances, perhaps 30 or 40, using a priority system for selecting contaminants based on severity of health effects and number of workers exposed. A proposed standard for these substances is scheduled for this July.

OSHA will proceed with caution. In 1992, a federal appeals court threw out new PELs for 428 substances, saying the agency didn't do its homework in determining significant risk and economic and technological compliance feasibility.

Respiratory protection

OSHA issued a proposed standard in 1994, and the final version is scheduled for this September.

Hazard communication

A special OSHA task force has a deadline of April for coming up with recommendations to simplify data sheets, reduce paperwork, improve training, and revise enforcement to target the most serious hazcom violations.