February 23, 2007 The Pump Handle 0Comment

Dr. Tony Robbins recent response to my draft on OSHA at 35 makes the important point that economic developments are often more powerful than public health initiatives as determinants of environmental and occupational illness. I agree with his thought that predictive models of exposure might facilitate anticipatory public health strategies rather than our more typical efforts to catch up after the fact. It is with this in mind that we need to focus on forward looking ideas rather than dwelling on the frustration that comes from a close look at worker protection in the OSHA years. Here are three.

First, old problems with straightforward, feasible solutions such as fatal trench collapses have been remarkably resistant to the current OSHA paradigm – an embarrassingly small group of inspectors visiting a monstrously large group of workplaces with a monstrously large number of chemical and physical hazards one at a time. A different approach is needed, one that leverages greater impact out of scarce public resources. One such model would simply require that every worksite be periodically inspected and certified to be in compliance with OSHA requirements, with a final personal signoff by the CEO. OSHA would license and monitor the inspectors and would continue to do a limited number of workplace inspections in response to complaints or for audit purposes. Similar models of audited third party accreditation have been used for years to ensure compliance with a wide variety of laws and rules ranging from hospital licensing to pressure vessel inspections to animal inspections by accredited veterinarians. To be sure, there are lots of potential problems with such third party systems, some of which have been pointed out in previous posts to this site (see Jordan Barab comments)But these pitfalls, such as third party bias, can be addressed and overcome if interested parties are willing to sit down together to wrestle through them.

Second, while a deep understanding of hazards in the workplace of the future might require the type of complex input-output model suggested by Dr. Robbins, there is much about the next 20 years that is readily visible right now and can guide today’s decisions about resources, legislation, training and community action. Examples include genotoxins, nanoparticles, psychosocial stress and exceptional risks in growing sectors like health care and biotechnology.

Third, collaborative work among people and organizations with different skills, experience and perspective can often illuminate future needs more effectively than work done in isolation. A terrific example is the work being done by the New Jersey Work Environment Council, “a coalition of 70 labor, community and environmental organizations working together for safe, secure jobs, and a healthy, sustainable environment.”

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