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I2P2 will not be the end of human civilization

By Garrett Brown MPH, CIH
March 29, 2011


I must say that I'm amazed at the near-hysteria of some of your readers about having an OSHA leadership that actually tries to do its job rather than just process VPP applications and praise corporate declarations of their "commitment to excellence."

Unless a company's business plan calls for killing their workers or regularly chewing them up and spitting them out, the company doesn't have anything to fear from an OSHA trying to keep workers safe and sound on the job. If the corporate OHS programs are already so much better than any OSHA regs, why all the rage and fulminations against efforts to fill in some of the gaps that almost everyone agrees still exist? If corporations are already "way ahead of OSHA," why so much opposition to OSHA going after the "low road" employers that exert a downward pressure on everybody else and prevent a "level playing field"?

All the predictions that the proposed "Injury and Illness Prevention Program" will be the end of human civilization as we know it seem just comical from California -- where we have had an IIPP regulation since 1991 and the state has not fallen into the sea. Businesses large and small have been implementing the approach and the requirements with varying degrees of effectiveness (hence the continuing citations) -- but no one thinks it is a bad idea or "simply cannot be done."

There is no human endeavor that does not have a political aspect or "political agenda" associated with it. Your (editorial commentary) critics have their own agenda as well, of course, which is that whatever it is the corporations and employers are doing is "good enough," and they should just be "left alone" to do whatever they think is in everyone's best interest.

The reality is that "good enough" still ends up killing a lot of workers -- BP-Texas, BP-Deepwater, Massey Coal, Kleen Energy, among many others -- and it really isn't "good enough."

Garrett is from Oakland, California

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Garrett Brown is a certified industrial hygienist who worked for Cal/OSHA for 20 years as a field Compliance Safety and Health Officer and then served as Special Assistant to the Chief of the Division before retiring in 2014. He has also been the volunteer Coordinator of the Maquiladora Health & Safety Support Network since 1993 and has coordinated projects in Bangladesh, Central America, China, Dominican Republic, Indonesia, Mexico and Vietnam. 

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