September Letters to the Editor

Fiscal impact of injuries can’t be ignored, reader says

I just read your ROI article in the June issue of Safety+Health. I thought it was outstanding! The data and stats are powerful – real eye-openers.

We provide Root Cause Analysis training, software and investigations. Safety has always been one of our key audiences, and RCA is very mature in this sector. While many organizations continue to be safety leaders, in recent years I have seen safety de-emphasized in more organizations – they are consciously taking greater risks, and it is troubling. I’m sure you have been seeing the same trend as us – increasing focus on quarterly/monthly profits and decreasing focus on safety. It’s not blatant, but it’s there. You see it play out when resources are being allocated. Your article did a great job of appealing to managers who may feel caught in the dilemma of having to prioritize profit over safety.

In our RCAs, some organizations historically avoided including the fiscal impact for injuries/fatalities for fear of overshadowing the human aspect. That’s understandable, but we have always encouraged them to include the costs in the problem statement, along with the specifics of the injury, because it helps make the business case for proactive safety focus and provides needed support for their program. You did a nice job balancing the issue.

I am asking my team to read your article and will be recommending it to my clients – well done!

Chris Eckert PE, CMRP
Midland, MI

Reader: I2P2 delay is ‘really good news’

In the August issue of Safety+Health (Washington Update), Kyle Morrison is discouraged about I2P2 being moved off the active regulatory agenda. While that I2P2 outcome is really good news, the fact that OSHA refuses to talk about it probably means that it will raise its head again. OSHA was likely told to move it so it would not be a target in the upcoming elections.

When I2P2 reappears, here are some of the reasons to oppose it:

  1. It cannot improve safety and health beyond what is being done already by the estimated 100,000 sites having OSH staff working collaboratively with management teams and employee colleagues. The 7,400,000 sites without OSH staff will never be able to sustainably implement I2P2.
  2. Safety and health management systems are the essence of who we are as OSH professionals. Our predecessors originated these systems and we continue to develop them. Making the essence of who we are into a government regulation diminishes our professional value add and could, in time, lead our employers to question the necessity or the value of having OSH professionals on staff.
  3. It will empower the government to perpetually harass VPP sites and other sites that have OSH staff and safety and health management systems. When these sites have injuries or illnesses or have any violations of OSHA standards identified, OSHA will declare these sites’ safety and health management systems as “not effective” and subject these sites repeatedly to “willful” citations and fines.
  4. I2P2 as a political agenda “process” regulation will empower OSHA to write multiple new regulations as interpretations of I2P2, bypassing the protections for OSH professionals and our employers to be able to comment on proposed regulations as specified in the Administrative Procedures Act and the OSH Act.

Tom Lawrence CSP, P.E.
Ballwin, MO

(NOTE: The views expressed above are solely the author’s and do not represent an official position of Cornell University.)