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The group offered suggestions on a variety of issues ranging from rulemaking to strengthening support for state OSHA programs. To head federal safety and health agencies, ASSE officials urged the Obama administration to select individuals who have the leadership capabilities to build relationships across the spectrum of occupational safety and health stakeholders.

According to the group, the new administration should:

• Examine how OSHA standards are pursued. ASSE officials said OSHA should lead efforts to develop cooperative mechanisms to help counter the division that has limited the agency's ability to update standards and permissible exposure limits.
• Advance risk-based safety and health management approaches. According to the group, OSHA should encourage employers to take proactive responsibility for safety and health through risk-based regulatory approaches and compliance assistance resources. Europe, Japan, China and committed U.S. employers already use such approaches. ASSE officials said OSHA is falling behind the world in not incorporating risk-based safety and health management approaches.
• Understand that OSHA can help U.S. companies save jobs. Officials said rulemaking on global harmonization of hazard communications will help U.S. employers compete across the globe and should be completed. An engaged OSHA can help ensure occupational safety and health issues are addressed fully in U.S. trade agreements, the group said.
• Continue to support cooperative programs. The group said that initiatives, such as the Voluntary Protection Program and OSHA alliances, continue to advance employer understanding that safe workplaces save lives and positively impact an employer's bottom line.
• Allow third-party safety audits. The ASSE said it supports extending OSHA effectiveness by establishing a program to allow third-party safety audits of companies under strict requirements to ensure professionalism and maximize effect, thereby expanding the agency's reach beyond the limits of its current enforcement and cooperative programs.
• Keep an open mind regarding ergonomics regulation. If ergonomics emerges as a regulatory goal, officials said the ASSE will not be able to support a prescriptive approach. The group said its members' knowledge and experience indicate that ergonomic problems are addressed through specific job and workplace fixes. Any approach to ergonomics must be risk-based, encourage cooperation, and avoid prescriptive, one-size-fits-all solutions that cannot work, officials said.
• Harmonize with voluntary consensus standards. Officials said OSHA should increase its participation level in the voluntary consensus standard community and comply fully with the Technology Transfer Act's mandate to consider consensus standards when engaged in rulemaking. Use of such standards, the group said, will help expedite rulemaking and keep pace with current safety practices.
• Focus on transportation-related fatalities. Transportation-related deaths continue to be the leading cause of workplace fatalities in the United States. According to the ASSE, OSHA should examine its current efforts and engage employers, employees, and other federal agencies to create an emphasis on addressing this problem.
• Cooperate with NIOSH. The group said OSHA's relationship with the National Institute for Occupational Safety and Health envisioned by the 1970 Occupational Safety and Health Act should be increased so that NIOSH's work -- including key safety, health and environmental research -- can support and contribute to OSHA's standards and other activities.
• Improve support for state programs. The ASSE said OSHA's ability to support and encourage state program effectiveness must be strengthened.

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