Thanks to those of you who have responded so far to the draft paper, “Getting Home Safe and Sound? OSHA at Thirty Five,” which was posted here several days ago.  Many people have agreed with the need for this dialogue and indicated the intent to contribute to it.  Comments so far have supported the need for a generic safety and health program rule; raised cautions about what’s said in a public forum; urged stricter penalties when employers negligently violate OSHA rules; expressed the need to de-politicize OSHA; endorsed the idea of third party inspections and proposed examining the SEC audit system as a possible inspection model; offered suggestions for making the issue relevant to the broader public, activating workers’ families and journalists, and framing the issue differently for different groups; and questioned the differences between cultures in environmental health and occupational health.  Thanks for the excellent start to this discussion.  While I welcome comments and suggestions on all the themes and ideas in the paper I am especially interested in reactions to two sections. 

First, section 2 of the paper is the Roadmap for “Getting Home Safe and Sound.”  As described in the introductory letter this is “a short stand-alone set of principles, priorities and practical actions – a roadmap or framework for change.  The choice of a limited framework rather than a long shopping list is rooted in the belief that accomplishing change requires sharp focus by multiple parties on a common set of objectives so energies can be concentrated and coordinated instead of diffused.  Thus, while this list of principles, priorities and practical actions is a working draft and suggested changes are invited and needed, improvements should be along the lines of achieving a more compelling and better articulated short list rather than expanding into a more inclusive longer one.”  What do you think about the principles, priorities and practical actions that have been put forward in this draft?  What would you modify, eliminate or add?

Second, section 7 of the paper includes a description of a leveraged alternative to a system that regulates one hazard at a time and sends government inspectors to one workplace at a time: “OSHA would adopt a generic rule requiring employers to implement comprehensive safety and health programs that effectively reduce injuries and illnesses, in addition to compliance with other specific OSHA rules. Programs would include safety and health management systems, employee participation, exposure monitoring, medical surveillance, and ergonomic protections.  Employers would be required to obtain an annual written certification that their firm had been inspected and was in compliance with all OSHA requirements and the business owner or CEO would be required to sign an annual personal declaration that this had been done.  OSHA would license the inspectors and conduct on site audits of the inspections.  OSHA would also continue to do inspections in response to complaints, fatalities and catastrophes.  The business owners and private inspectors would be legally liable for acts of negligence, false statements, and conflicts of interest.”  Previous proposals along these lines have received moderate support from business and strong opposition from labor.  Can effective checks and balances be designed so that such a system could work to expand the reach and impact of the OSHAct without being corrupted and abused?

Comments on other aspects of the draft paper are also welcome.  Please respond below or in the previous post .  You can download the full paper at

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