File under “If you can’t get something through the legislative process, just create a new rule.”
In yet another instance of making an undated announcement on its website, DOL/OSHA (sometime, recently, yesterday, who knows?) announced its Safety and Health Practices Survey of private sector employers regarding their current safety and health practices.
According to OSHA “This survey will allow OSHA to better design future rules, compliance assistance, and outreach efforts.”
What the original Federal Register notice said was that this survey ” is to gain information… to support its rulemaking effort directed toward requiring employers to
establish injury and illness prevention programs to monitor and more effectively implement practices to mitigate workplace hazards…” (Emphasis ours.)
Link to Fed Reg 12 Aug 2010 Vol 75 no. 155, pps 48992-48994
The undated OSHA Announcement web page continues:
“The survey, which may contact as many as 19,000 employers nationwide, will ask questions about employers’ current practices with regard to safety and health management in their workplaces. For example, the survey will ask employers if they already have a safety management system, whether they perform annual inspections, who manages safety at their establishment, and what kinds of hazards they encounter at their facilities.”
No mention of whether or not the survey comes with a copy of Miranda Rights warning for employers.
But as we have shown in the original federal register posting, the intent is to justify their putsch for mandating Injury and Illness Prevention Plans. (I2P2)
I2P2 is the OSHA plan to backdoor implement the ergonomics standard into effect that was rejected under the Congressional Review act. It creates a means to hold employers accountable for hazards that even the authorities haven’t identified, and to the requirements of the rejected ergonomics standard. (Concerned? – read the coverage from The Hill on this issue.)
The survey will come via mail, and is being conducted by a contractor, ERG. The webpage mentions a website for the survey as well, but in the same fashion as not dating the OSHA web announcements, the address of the survey website seems to have been omitted. According to the OMB filing a sample of 400 establishments from “Group 6. Final Manufacturing” is anticipated. This group contains our industry’s 3 digit NAICS code 332.
If you are selected, they will follow up: “As noted above, reminder postcards will be sent to potential respondents two weeks after the mailing of the initial survey invitation letter. After four weeks, telephone contact with each nonrespondent will be attempted to encourage completion of the questionnaire either electronically or by mail. Callers will attempt up to six calls to reach the potential respondents. A final reminder postcard will be mailed after six weeks to the remaining nonrespondents. OSHA’s survey contractor will also implement a help line to answer both telephone and e-mail questions about the survey posed by respondents.”- Pdf OMB approval of survey
Tool You Can Use
The undated OSHA web announcement plainly states: “Participation in the survey is voluntary.”
Link to OSHA’s undated Safety and Health Practices Survey Announcement
You’ve Got Mail
Tag: Backdoor ergonomics enforcement means