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OSHA Gets OMB Approval to Conduct Extensive Survey

Last November, OSHA requested permission from OMB to conduct an extensive survey of employers. The purpose of the survey is to learn about their safety and health practices that may become elements of the agency’s injury and illness prevention program(I2P2) rulemaking.

This baseline survey is expected to yield almost 11,000 responses and will apparently seek feedback from private sector employers as well as State Plans (public sector). OSHA is not able to conduct such surveys without OMB prior approval. I presume that recipients are not REQUIRED to respond, but I do not know that for sure one way or the other. So, if your site is uncomfortable in providing proprietary information, you may want to get clarification before declining.

This effort is in support of the Agency’s rulemaking activities on the Safety & Health Program Rule (I2P2) – a top regulatory priority at the Agency as it would require all covered employers to implement a program to recognize and eliminate occupatioanl hazards. It’s my understanding that some 12-14 State Plan States already have some form of this rule in place now. It is certainly highly encouraged that all employers implement a safety and health program. This issue has been a controversial one over the years because of how it might be implemented as an actual standard – regulatory text/requirements as well as how it might be enforced.

Anyway, OSHA approval from OMB was recently received by the Agency and is presumably “in the works”. Employers and State Plan officials should expect to see the survey soon (if selected).

Mean time, the SBREFA Panel for I2P2 is scheduled to begin in June 2011. I don’t know -at this point- how the timing of the survey and the SBREFA Panel are being (or if) coordinated. The OMB letter suggests forms were included in the transmittal to/from the Department of Labor but are not provided in the docket. Since they are surveying employers and collecting as much “good” information as possible is their obvious aim, it would have been nice to provide the opportunity for any/all employers to submit comments via Federal Register Notice.

I commend OSHA for soliciting input from those who might be affected by the rule, if ultimately promulgated. Their intent is a good one. My only concern is how it will be received by those selected — as an opportunity to provide data, with enforcement skepticism, etc. I suppose that will ultimately be decided on how those surveys were constructed/structured. Time will tell.

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