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Advisory group urges OSHA to beef up health management guidelines

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WASHINGTON — The National Advisory Committee for Occupational Safety and Health has urged the Occupational Safety and Health Administration to strengthen the health components of its proposed update to the agency's safety and health program management guidelines and make the document more accessible to small employers.

NACOSH members were generally complimentary about OSHA's draft proposal, but felt there was room for improvement, particularly on the health side.

“The document seems to do a very good job of addressing what I'll call the acute physical hazards … but is weak on the health side,” Joseph Van Houten, senior director of worldwide environment, health and safety at Johnson & Johnson in New Brunswick, New Jersey and an employer representative on NACOSH, said on Friday. “We need to enhance the health message.”

Stakeholders testifying at the meeting agreed that adjustments should be made to the health guidelines.

“Occupational diseases cause about 10 times more fatalities than safety hazards,” said Manuel Gomez, a retired public health scientist. “In light of that, I think there's a need to enhance the extent to which the document addresses occupational health hazards and occupational diseases more explicitly. As it reads now, it sounds like a safety document with some rare exceptions.”

A specific recommendation Mr. Van Houten made — adopted by NACOSH — was the addition of language in the worker participation section of the guidelines to involve workers in all aspects of the program by wearing all required personal protective equipment and fully participating in all monitoring and medical surveillance associated with health hazards.

“I think the document is a little weak on worker participation,” said James Thornton, director, family health centers and wellness initiatives for Huntington Ingalls Industries Inc. in Newport News, Virginia and a representative of the American Society of Safety Engineers. “In smaller businesses and medium businesses, it's sometimes difficult to get employees involved, but I think that's a very important concept. I believe the document can give some additional examples of how workers can be involved and participate in the process.”

Mr. Van Houten and others also expressed concern that small employers may be unable to fully understand the guidelines or may not have the resources to develop a safety and health program that meets the guidelines' objectives. For example, the guidelines advise employers to determine the severity and likelihood of incidents that could result from identified hazards and use this information to prioritize corrective actions.

“My question is 'how do I do that if I'm a small employer,'” Mr. Van Houten said. “There's no guidance.”

But others said that this was more of an implementation issue and that the current document was simply a framework to be built upon.

“I think OSHA first needs to get the framework right and then look at the tools for the implementation,” said Margaret Seminario, director of safety and health at the AFL-CIO in Washington and a NACOSH labor representative.

OSHA plans to release a final update to the guidelines in June, and the agency will likely publish smaller documents on implementation designed for small businesses such as step-by-step instructions on how to build an effective safety and health program, said Andy Levinson, deputy director, OSHA's Directorate of Standards & Guidance.

Implementation “is something we have a little more time to work on,” he said.

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