For nine hours on March 4, 2010, OSHA officials dutifully listened to 13 panels and 45 speakers present comments and suggestions on key issues facing the agency. In addition, OSHA accepted written comments until March 30.

So what will be the result of this exercise in “open government”? OSHA could be given EPA’s $10.5 billion budget and 17,384 employees (versus OSHA’s current budget of $559 million and 2,343 employees) and still short of satisfying “stakeholders” and all their wants, needs and ideas. It’s mission impossible. If it takes OSHA 94 years to inspect every U.S. worksite once, as the AFL-CIO claims, it will take the agency 100 years to get around to all these “inputs.” We’ve selected 50 comments to show you the challenge. Which ones do you think deserve top priority? Email me at

From earthquakes to window cleaning

1OSHA needs to do a better job ofcommunicatingwith the public. It takes forever to track down the correct office and person.

2OSHA must do a betterpublic relationsjob with workers. Half of workers do not like OSHA.

3OSHA needs to addressmental health. Many workers are stuck in boring, underpaying jobs in cubicles with no privacy and no prospects to advance. OSHA can recommend and talk about onsite therapy.

4OSHA should send awarning lettereach time an employee calls in a complaint.

5Small business is worse than big business when it comes to injuries. OSHA can’t fine small businesses like the millions it fined BP, but it should enforce small business compliance before accidents happen.

6Emphasize compliance andculture. Culture is a major safety determinant. OSHA does not help employers with their safety cultures.

7TheVoluntary Protection Programoffers the best management system in the U.S. for job safety and health. VPP needs more OSHA support, not less.

8Thewindow cleaningindustry still faces 12 to 15 serious injury incidents each year, with four or five fatalities. OSHA should incorporate by reference the American National Standards Institute (ANSI) I-14.1 Window Cleaning Safety Standard.

9 Hand-arm vibration syndromewas investigated by Dr. Alice Hamilton in 1918. NIOSH has reported that 1.2 to 1.5 million U.S. workers are exposed to hand-arm vibration. OSHA should recognize the current situation and prevent vibrationinduced disease.

10Sixty-nine percent of 9,442 9/11 recovery and response workers examined between July 2002 and April 2004 presented new or worsened respiratory symptoms and lung abnormalities. OSHA urgently needs to protectresponse, recovery and support personnelwho are asked to take action in any disaster.

11OSHA needs to initiate rulemaking to consider the benefits of requiring employers to have awritten safety and health program.

12 Medical surveillancemust be an essential element of these programs.

13OSHA should permit the use ofThreshold Limit Valuesif Permissible Exposure Limits do not exist.

14OSHA needs to seriously address theagingof the American workforce. More and more Americans are working much longer and into much older years.

15Market OSHAconsultationservices through letters, emails, and phone calls to small businesses.

16OSHA must more strenuously emphasize to employers the growing hazards associated with workplacestressand lean manufacturing.

17OSHA should initiateradio and TV spotsemphasizing workplace safety and health and consultation contact information.

18OSHA needs to take the lead in evaluatingnanotechnologyrisks.

19OSHA needs to supportsafe patient handlinglegislation in Congress and ergonomic hazards in nursing homes and other healthcare facilities.

20OSHA should go beyond its outreach to Spanish-speaking workers and specifically provide resources forHmong, Russian, Polish, and Haitian Creolespeakers.

21OSHA should consider daily or weeklypodcaststo update workers, regular phone/Web town hall meetings, and online chats.

22 Earthquakemitigation,medical marijuana’s risks to workplace safety, and use of prescription drugs on the job should all be addressed by OSHA.

23OSHA needs to do more to establish the worker’spersonal responsibilityfor safety and health on the job.

24OSHA needs to embracerisk assessment.

25OSHA should make mandatory aonetime, 30-hour training class, “An Overview of Occupational Safety and Health” for every worker in the country covered by OSHA.

26OSHA protections should be extended to every worker in the country, such aspublic employees.

27The“black hat” inspectorsof OSHA need to go. Help people, educate people, help businesses bring their safety programs into compliance.

28OSHA needs to accept the ever-increasing need for third-party inspections ofcranes. OSHA standards have not kept up.

29OSHA is woefully behind in settinghealth standards. The backlog of health standards is pathetic. OSHA chief Dr. David Michaels should eliminate optional peer reviews of standards for silica, beryllium, diacetyl and other standards. OSHA must make its health mission a top priority.

30OSHA should approach everywhistleblower complaint with a completely open frame of mind.

31OSHA needs to work more closely withother federal regulatory bodiesto avoid unnecessary confusion and redundancy.

32OSHA needs a closer working relationship withNIOSH. NIOSH should be part of all OSHA strategic planning.

33OSHA needs to work with the Federal Aviation Administration to improve protections for flight attendants. For aflight attendant, each day on the job brings potential exposures to turbulence, severe air pressure changes, unwieldy service carts, broken luggage bins, balky exit doors and door handles, exposures to toxic chemicals, unruly passengers, communicable diseases, and emergency evacuations.

34AfterElaine Chao, OSHA, you owe us.

35OSHA has letself-proclaimed “experts”on the outside run roughshod over its own career scientists for far too long,

36OSHA needs to be grounded insound science.

37To use the traffic safety analogy,OSHA should not be content to just be the sheriffenforcing use of stop lights and speed limits; OSHA can save many more lives by also promoting development of better highways (safety systems).

38OSHA shouldgo beyond VPPand offer to industry other recognition programs to improve safety in specific areas, similar to EPA’s model of performance recognition programs for pollution prevention, energy STAR, climate leaders.

39OSHA needs to incorporatecontrol bandingwhen revising hazcom to align with the UN’s Globally Harmonized System for identifying hazardous substances.

40OSHA needs to restorea column to the OSHA 300 Logthat employers would use to record work-related musculoskeletal disorders (MSDs). OSHA needs a much better handle on the scope of work-related MSDs.

41Who are you kidding, OSHA?Recording MSDsis only the first step toward setting an ergonomics standard. Don’t do it. We’re watching.

42OSHA needs to tighten the screws onstate OSHA programs. Too many have been too lax for too long.

43OSHA needs to tighten the screws on industryrecordkeepingpractices. Too many have been too lax for too long.

44OSHA needs to tighten the screws onVPPoversight. Too many sites have been too lax for too long.

45OSHA needs to crack down onincentive programsthat offer rewards for going without an injury, and so encourage the under-reporting of injuries.

46OSHA inspectors should not misuse the “general duty clause” and launch an inspection over a few cross words between employees in the lunchroom that one employee perceives as a threatening act ofworkplace violence.

47OSHA needs to refer more cases forcriminal prosecutionto the Justice Department.

48OSHA is in danger of broadeningoverly aggressive investigationsthat lead to the C-suite and the board room to find out “who knew what and when.”

49OSHA needs to step up protections for workers ingreen jobs.

50OSHA needs to step up protections for construction workers employed in federalstimulus fundingprojects.