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To the editor: It was refreshing to read in the May 26 editorial opinion, "Don't Duck an Opportunity," that the Labor Department is encouraging employers to help educate government about business issues and needs, including the area of employee safety.

It is also good to see the Occupational Safety and Health Administration soliciting input from employers about ergonomics and other important issues.

In the late '60s and early '70s, several influential consultants, educators and authors were publishing books and articles and were beginning to be heard by employers regarding employee involvement and the recognition that safety on the job is best implemented upstream at the behavioral level. It was felt that safety was just another management function and should be managed accordingly.

Then in 1971, the Occupational Safety and Health Act went into effect. Those most knowledgeable in this field recommended going in a certain direction, but OSHA said to go in the opposite direction. For most employers, the direction they had to go was quite obvious.

Fortunately, some major corporations followed the advice of the experts, and their well-documented results have been dramatic. For the smaller employers, efforts were directed toward complying with OSHA criteria and various state requirements. Unfortunately, this does not ensure a safe workplace. According to statistics, we are almost 50% worse off from the standpoint of lost-time injuries than we were 25 years ago.

Hopefully the interest in Washington of listening to employers and others experienced in the positive impact of behavior-based safety will help remove those involved from the vacuum in which decisions were made and standards were produced that have tended to impede progress in this area.

Donald L. Dildy

Visalia, Calif.