I have been around since the beginning of OSHA and it is interesting to read thoughts from safety professionals on influencing OSHA, or the inability to influence OSHA.
Perhaps the best way to get the regulators’ ear is from the political side. Getting the elected representatives in Washington to more clearly understand the issues, the history, the unintended consequences, etc. might be the best tactic, wouldn’t you agree? Since, as you say, OSHA is highly political, it seems that by motivating those who might have an influence with OSHA is our best bet for creating a favorable outcome.
Some professionals have comments that the Injury and Illness Prevention Program (I2P2) should be dropped in favor of reissuing OSHA’s voluntary 1989 guidelines, which are sensible. I must add that in August of 1996 the Directorate of Compliance Programs issued OSHA Notice CPL 2, the Program Evaluation Profile (PEP) having the stated purpose: “Assessing employer safety and health programs in general industry workplaces.” This profile was particularly well done, especially the Appendix B, PEP Tables. I would support use of the PEP concept in a heartbeat. So, once again, maybe this concept should be brought back into the light of today.
Ted Ingalls, longtime safety and health professional