By Chip Dawson
Rochester Business Alliance Safety Consultant

For the past sixteen years—through the Clinton and Bush Two administrations - we've seen a "kinder, gentler" OSHA. There have been few new regulations, alliances with stakeholders have numbered in the hundreds and cooperation has been the watchword.

No more! We're headed back to the Reagan and Bush One years with a tough enforcement focus. The Administration, it seems, has read the report from the DOL Inspector General that criticized OSHA's Enhanced Enforcement Program (EEP), heard about a new GAO study on the value of voluntary programs, and looked at multiple studies that suggest as few as one third of the workplace injuries actually make it onto an OSHA 300 log.

Labor Secretary Hilda Solis is quoted as saying "there's a new sheriff in town." Acting Assistant Secretary for OSHA Jordan Barab says that while the Voluntary Protection Programs (VPP) will continue, there will be no program growth goals, with resources to be shifted into enforcement. The Inspector General suggests that OSHA's resources should be focused on employers who are indifferent to their obligations under OSHA.

Here's what the future holds. The Agency expects to hire 160 new compliance officers and have a budget increase of 10 percent in 2010. Inspections will rise modestly to 40,000 per year. A safety and health program management standard is in the works, but not expected to pass until after 2012. Look for more citations, more penalties and more referrals to DOJ for criminal prosecution.

The EEP will become the Severe Violations Inspection Program (SVIP) and will be more comprehensive, more effective and focus more on larger employers. It will look at the employer's history as well as present practices, have mandatory follow-up inspections and inspections across all company units.

As severe as the new initiatives look, the vast majority of you reading this will not be impacted as long as you pay close attention to workplace safety and health. Consider these points to help you reach excellence:

• Have a strategic plan and a process for managing safety.
• Know the regulatory requirements for your business and be diligent about meeting them.
• Be familiar with the OSHA web site (www.osha.gov) and its wealth of resources.
• Involve all your people in the process - and listen to their advice.
• Put all recordable injuries and illnesses on your OSHA 300 log - and address their root causes.

Understand that, especially in smaller businesses, incidence rates are rarely statistically significant and that just a few random incidents could place you at the OSHA action level. So, to be safe, strive for zero incidents.

While OSHA may be growing sharper teeth, keep in mind that the Rochester Business Alliance is prepared to help you with all your safety and health management issues. For training and consultation on-site, there is a fee but we handle basic questions and concerns by phone or e-mail at no cost to you. If you'd like an advanced look at what the proposed OSHA safety and health program management requirements will look like, send me an e-mail requesting "Safety for the Leader/Manager."

If you have HSE questions or column suggestions, or would like to be added to the e-mail HSE Update list, contact Chip Dawson at (585) 461-1549.