Why can't OSHA just reissue the Program Guidelines and Program Evaluation Profile? Makes sense from a safety and health standpoint but fails the political context.
The political class running OSHA now are the ones who carped at the last administration for not having a full plate of safety and health standards in development. Never mind that we already have 40 years and thousands of safety and health standards requirements in force. If there is not a full plate of standards in development, then safety and health are in decline, the current political class said.
This political class, once they took over OSHA, found out that the low hanging fruit hazards for standards has already been done. There are not a lot of opportunities that will meet the criteria of the OSHA and Administrative Procedures Acts. Combustible Dusts, for example, has turned out to be a very difficult issue for which to develop a one size fits all OSHA standard.
So the political class was searching to get something going in standards--otherwise they will look bad. Viola!!! Safety and Health Programs, which were cleverly renamed injury/illness prevention programs to make what OSHA wants to do sound more attractive. That sounds like an easy one to knock off in a standard, they thought. It is now up to us create very public objections to programs becoming a standard. Our argument should be that it will be government overreach. We should make the point that OSHA is a government, political agency and thus will make arbitrary and politically driven judgment of the effectiveness of our safety and health programs and issue massive citations and fines. This is not acceptable. Updated guidance documents are fine and are the alternative that we have to propose.