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

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

2 OSHA must do a better public relations job with workers. Half of workers do not like OSHA.

3 OSHA needs to address mental 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.

4 OSHA should send a warning letter each time an employee calls in a complaint.

5 Small 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.

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

7 The Voluntary Protection Program offers the best management system in the U.S. for job safety and health. VPP needs more OSHA support, not less.

8 The window cleaning industry 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 syndrome was 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.

10 Sixty-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 protect response, recovery and support personnel who are asked to take action in any disaster.

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

12 Medical surveillance must be an essential element of these programs.

13 OSHA should permit the use of Threshold Limit Values if Permissible Exposure Limits do not exist.

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

15 Market OSHA consultation services through letters, emails, and phone calls to small businesses.

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

17 OSHA should initiate radio and TV spots emphasizing workplace safety and health and consultation contact information.

18 OSHA needs to take the lead in evaluating nanotechnology risks.

19 OSHA needs to support safe patient handling legislation in Congress and ergonomic hazards in nursing homes and other healthcare facilities.

20 OSHA should go beyond its outreach to Spanish-speaking workers and specifically provide resources for Hmong, Russian, Polish, and Haitian Creole speakers.

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

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

23 OSHA needs to do more to establish the worker’s personal responsibility for safety and health on the job.

24 OSHA needs to embrace risk assessment.

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

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

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

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

29 OSHA is woefully behind in setting health 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.

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

31 OSHA needs to work more closely with other federal regulatory bodies to avoid unnecessary confusion and redundancy.

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

33 OSHA needs to work with the Federal Aviation Administration to improve protections for flight attendants. For a flight 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.

34 After Elaine Chao, OSHA, you owe us.

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

36 OSHA needs to be grounded in sound science.

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

38 OSHA should go beyond VPP and 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.

39 OSHA needs to incorporate control banding when revising hazcom to align with the UN’s Globally Harmonized System for identifying hazardous substances.

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

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

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

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

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

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

46 OSHA 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 of workplace violence.

47 OSHA needs to refer more cases for criminal prosecution to the Justice Department.

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

49 OSHA needs to step up protections for workers in green jobs.

50 OSHA needs to step up protections for construction workers employed in federal stimulus funding projects.