Full disclosure: I am a white, 59 year old, 30+ year safety guy. As you could guess from my age, my degree is not safety. I have worked in engineering, construction, a university-based state OSHA consultation program, and for a very large manufacturer. Politically, I am a conservative-leaning moderate. That said, I have some problems with David Michaels when I hear him or read what he says. He tends to paint all employers as spawn of the devil who cheat on recordkeeping and are ready to sacrifice their employees on the altar of the buck (hyperbole obviously). I get so tired of him making generalizations about employers. I have never known him to talk about the good employers and the bad actors. Hey, maybe I have missed it. He came close at NSC with his preaching to the choir comment, but that was as close as I thought he came.
Also, OSHA is hounding employers about recordkeeping. Many smaller-than-us employers do not really understand the recordkeeping requirements, and the requirements – especially bringing into the mix all the interpretive letters – are not well thought out. What does it tell us or OSHA if an employee is walking down a perfectly smooth hallway and his or her knee “gives out” and they fall and need knee surgery? What does it tell anybody if an employee is outside and is stung by a random bee or wasp and has an allergic reaction? What does it tell anybody if a manager sneezes in his or her chair in the office and pulls a back muscle and needs muscle relaxers? Granted, these are unusual, but they would all be recordable.
When I led the safety side of a state consultation program, most of the employers who requested assistance did so from the desire to improve their safety and health programs and to ensure the safety and health of their employees. Very few contacted us because they were referred by OSHA or wanted to just get by. I was heartened greatly by this. I have never run across an employer that treated its employees as expendable. I know that they exist, but Michaels needs to stop acting like the country is overrun with profiteering employers.
From a private email exchange with an ISHN reader