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Letters

September 18, 2013

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NSC executive responds to reader comments on I2P2


The National Safety Council has an official policy position in support of safety management systems and encourages all employers to invest in a process of continuous improvement. Moreover, the policy supports the proposed regulation that OSHA requires employers to have Injury and Illness Prevention Programs. This NSC policy was adopted by NSC delegates, divisions and directors, representing NSC members.

Considering the Council’s position and the numerous discussions we’ve had with our members about I2P2, I felt it necessary to respond to the letter from Tom Lawrence in the July issue. Mr. Lawrence was responding to an “In the News” item from April 2013 regarding comments from OSHA administrator David Michaels on I2P2 remaining OSHA’s number one priority. Mr. Lawrence correctly states the importance of the safety professional’s role, and the necessity of management leadership and engagement of all employees. He is also correct in noting that not all employers are able to staff safety professionals, and therefore are in need of direction and support.

However, Mr. Lawrence makes the case that the nation does not need an OSHA-required I2P2 because successful implementation is best accomplished with the support of safety professionals.

The issue not addressed by Mr. Lawrence is the needs of the many companies that do not have such expertise, which is one of the reasons why I2P2 rulemaking needs to progress.

It is important to recognize the looming shortage of qualified safety professionals, as noted in the NIOSH study from October 2011 titled “National Assessment of the Occupational Safety and Health Workforce,” which states, “The estimated number of OS&H professionals employers expect to hire in 2011 and over the next 5 years is substantially higher than the number estimated to be produced from OS&H training programs.” Add to this the graying of the current safety workforce and the impact of retirement, along with the potential for reduced or no funding for NIOSH Education and Research Centers, and it is clear that there needs to be a balance of performance and prescriptive direction provided to employers that are unable to hire or gain access to these professionals.

We believe regulatory requirements from OSHA are necessary to influence all companies, even those without safety professionals, to invest in making their companies safer. We also believe companies can make fundamental changes in their SMSs even without safety professionals, although that progress may be less than that experienced by companies with safety expertise.

That’s why NSC is investing in a campaign to engage as many companies as possible to help them understand the business case for safety and its relationship to employee retention, productivity, quality, and overall operational excellence and bottom-line results. And to support them on what we refer to as a “Journey to Safety Excellence.” It is also why we support the rulemaking process for I2P2.

Let’s progress with the debate and discussion on how this can be an effective means of helping companies with direction and resource, while creating no harm for companies that are already demonstrating effective systems.

Along with the Council, other organizations are supportive of I2P2, including the American Society of Safety Engineers and the American Industrial Hygiene Association. Finally, as a member of the National Advisory Committee on Occupational Safety and Health, I think it is compelling that NACOSH – which includes representatives from business, labor, government and health – continues to be unanimous in its support of this being the number one priority for OSHA.

Jim Johnson
Vice President, Workplace Safety Initiatives
National Safety Council
Itasca, IL

One reader’s opinion: What’s the safest color for a car?

In your August issue, the article titled “A look back at the NSC Library” has a question “What’s the safest color for a car?” The answer given is “There is no single color that is ‘safest’ in all situations.”

From my experience, I will never buy a blue vehicle. One lovely, clear, cloudless summer day I was driving on a two-lane highway with a large transport truck in front of me moving more slowly than I needed to go. I waited until a stretch of highway where I could see ahead for about ½ mile on a straight stretch with a slight uphill grade. I looked carefully for any oncoming vehicles, and it seemed obvious to me that the coast was clear. After I was about halfway past the long truck, out of the clear blue sky appeared a sky blue car. I had to make a split decision whether to break hard or floor the pedal. Fortunately, my car had the power to accelerate past the truck and cut in barely in time to avoid a catastrophic head-on collision! I will never, ever buy a blue vehicle for my own safety.

Feel free to use this information and experience for the sake of safety.

David Elberfeld
Safety & Wellness Committee
Northeast Delta Dental
Concord, NH

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