Regarding the proposed I2P2 requirements; once it is a standard, that opens a number of potential problems. And once that door is open, it cannot be shut.

The 1989 Guidelines for Safety and Health Programs could probably use some updating. The talk is that the OSHA staff was within a few weeks of issuing revised guidelines when the political class at OSHA stopped the work, saying that they were going for a standard.

In deciding the potential problems with OSHA, I have to first remind myself that OSHA is first and foremost a political creation--a government agency always has some political dimension. OSHA's is particularly acute. "There is a new sheriff is town" is purely a political statement, not a safety and health statement. I have watched OSHA since its beginning. It is now the most politicized that it has been since Eula Bingham--perhaps more so. In Bingham's case, she was the driving force. My observation is that Dr. Michaels is only a figurehead. Barab/Berkowitz are running OSHA. My only question is, why Berkowitz has not been more visible.

OSHA uses our professional organizations--and we let OSHA get away with that--with no quid pro quo for our professionals.

The reason for the no impact is not lack of skill. Rather, it is that our organizations are not large enough or mean enough for OSHA to worry that we will sue them. If OSHA knows that an organization will not sue them, they will appear accommodating, invite us to come in and talk our heads off anytime---and then do nothing.

So if we open this I2P2 door as a standard, we absolutely cannot count on our organizations, based on their track records, to be able to influence OSHA on I2P2 development to protect us in any meaningful way, or that will they challenge OSHA about OSHA's interpretations once I2P2 is enacted.

Hopefully some of the large, mean management organizations will take OSHA on about I2P2. I am cheering them on.

By Tom Lawrence, longtime safety and health professional