Senators Olympia Snowe (R) and Joseph Lieberman (I) have sent a letter to Department of Labor Secretary Hilda Solis regarding OSHA regulation of noise in the workplace. Specifically, the agency is proposing an interpretation regarding exposure to noise in the workplace.
The Senators’ letter warns, “There is significant alarm, in the manufacturing community in particular, that this new proposal would force businesses to make drastic and costly changes, often at the expense of job creation.”
Originally posted at Shopfloor.org of the National Association of Manufacturers:
OSHA formally announced in the Federal Register this morning that that the agency will be extending the comment period for their proposal to change noise abatement requirements. However, many on Capitol Hill are asking OSHA if the agency understands the impact that this proposal will have on manufacturers of all sizes.
From OSHA’s notice in the Federal Register:
Two commenters, the National Association of Manufacturers and the Coalition for Workplace Safety (CWS), representing employers who would be affected by the proposed interpretation, have requested an extension of 90 days to assess the operating changes that their members would be required to make to comply with the interpretation.
While this announcement makes the extension official we appreciate that OSHA has recognized that it would take much longer than then initially proposed 60 day window to accurately assess the impact of the agency’s proposal.
We say “proposal” and not “proposed rule” because the agency is attempting to make these changes outside of the formal rulemaking process. While OSHA officials are accepting comments to the regulatory docket the agency is not compelled to take stakeholder feedback into account. Manufacturers, particularly smaller sized manufacturers, will be impacted by these changes, which come at staggeringly high costs without any evidence that the current process of protecting employees is deficient.
David Michaels, the Assistant Secretary of Labor for OSHA, told The Hill newspaper that the agency is “sensitive to possible costs associated with improving worker protection”. Further he said:
Our common objective is to ensure that workers don’t lose their hearing without overly burdening employers. OSHA will take all stakeholder comments seriously and will fully consider impacts on business and workers before determining what final action, if any, we will take.
We hope OSHA does take these comments seriously and realize that the costs of making these changes far outweigh potential benefits (if any) that may result.
Yesterday Senators Olympia Snowe (R-ME) and Joe Lieberman (I-CT), who co-chair the Senate’s Task Force on Manufacturing, sent a bipartisan letter to Labor Secretary Hilda Solis asking for more information on why the proposal has been put forth. The Senators point to important data that shows that the number of hearing loss incidents in the workplace is quite low and is improving significantly.
OSHA does not appear to support this change with data or any suggestion that employees require this new level of protection. Indeed the most recent Bureau of Labor Statistics (BLS) data on hearing loss injuries shows that from 2004-2009, incidences of hearing loss injuries have decreased from just under 29,000 per year to 19,500 per year and the rate of injuries has gone from 3.2 per 10,000 employees down to 2.2
More importantly the Senators posed several important questions to the Secretary of Labor that we very much look forward getting answers to as well:
-Did OSHA consider alternative interpretations prior to deciding to publish the proposed interpretation in the Federal Register? If so, what were these alternatives?
-Did OSHA consider any unintended consequences the proposed interpretations could have on small businesses? How did the agency address these concerns during formulation of the proposed interpretation?
-Does OSHA have any quantitative data affirming the necessity to change this policy, given that numerous organizations have noted that the current policy is effective?
Senators Olympia Snowe (ME), the top Republican on the Small Business Committee, and Mike Enzi (WY), the top Republican on Committee on Health, Education, Labor and Pension are concerned about the direction OSHA is taking.
In a recent letter, the Senators took issue with the fact OSHA “proposed several significant regulatory changes that could negatively affect small businesses by adding another layer of uncertainty to bottom-line business operating costs without the benefit of small business review panels or comprehensive outreach.”
The Senators specifically mention that they are troubled that OSHA’s proposed changes to the On-Site Consultation program will deter small businesses participation. They are concerned that by eliminating funding and staff for the Voluntary Protection Programs (VPP), OSHA is turning its back on a program that has been effective in creating a culture of safety in workplaces for nearly 30 years.
The Department of Labor’s Office of the Solicitor of Labor this morning announced its intention of extending the comment period for re-interpretation of the OSHA Noise abatement requirement by 90 days. The original comment deadline was scheduled for December 20th, but the Coalition for Workplace Safety sought additional time for public input. This 90-day extension will allow interested groups further opportunity to assess the impact of the interpretation.
As the NAM’s Keith Smith has blogged (here and here), the Occupational Safety and Health Administration announced in late October its intention to re-interpret the meaning of “feasible” regarding noise abatement programs. The new interpretation elevates the standard for administrative and engineering controls of noise, making them required unless an employer can demonstrate that making such changes will put them out of business. The Coalition for Workplace Safety sought the extension in light of the broad economic impact of such a requirement and the difficulty of gathering relevant data from which to base any decision.
A copy of the NAM request can be found here.
Joe Trauger is the NAM’s vice president for human resources policy.
NOTE: This was cross-posted with minor adjustments at Shopfloor.org
The Coalition for Workplace Safety has filed Comments to the OSHA docket regarding On-Site and SHARP programs.
First the good news: the Bureau of Labor Statistics (the DOL’s own keeper of stats) just announced that workplaces in 2009 were safer than they were in 2008: “nonfatal workplace injuries and illnesses among private industry employers declined in 2009 to a rate of 3.6 cases per 100 equivalent full-time workers, down from a total case rate of 3.9 in 2008. BLS also reported a decline in the total number of cases from 3.7 million in 2008 to 3.3 million in 2009.” This continues a virtual straight line trend towards fewer injuries in the workplace dating back to the creation of OSHA in 1971.
Of course, the best number and target is zero. Still, any movement in that direction should be recognized as progress and welcomed. But one would be hard pressed to find any sense of that in the reaction from Secretary of Labor Hilda Solis’s statement on these numbers. In addition to making the point that zero is the target, she also reiterated her belief that employers are coercing or otherwise discouraging employees from reporting injuries: “We are concerned about the widespread existence of programs that discourage workers from reporting injuries, and we will continue to issue citations and penalties to employers that intentionally under-report workplace injuries.”
Unfortunately, this Department of Labor and OSHA seem incapable of accepting that employers are actually doing a better job protecting their employees; that in fact the multi-faceted approach begun by the Clinton administration and continued during the Bush years of combining enforcement with outreach and compliance assistance for employers has been a successful strategy. Instead, this crowd is continuing to push the theme that employers are systematically underreporting and if we only knew the real story, we would understand the need for the aggressive enforcement-centric attitude this administration has championed.
Their first attempt to prove this through a National Emphasis Program did not produce their desired results when they targeted employers with better than average safety records in hazardous industries–in effect saying “we know you’re hiding something and we’re going to find it”–so they’ve retooled it now to go after employers with less sterling safety records–in effect saying “we know you must be hiding something because you’re actually reporting injuries.”
The crowning irony to all this is that at the end of this administration, what will this Secretary and her OSHA use to show they have been effective (I assume, they’ll want to show they were effective)? Why, the BLS Injury and Illness rates, of course. Those same statistics they can’t quite seem to accept right now. I can’t wait.
This timely reminder comes from Brad Hammock’s OSHA Law Blog:
It has been several months since OSHA unveiled its Severe Violator Enforcement Program (SVEP), which focuses OSHA’s enforcement resources on employers “who have demonstrated indifference to their OSH Act obligations by committing willful, repeated, or failure-to-abate violations.” This is the time for employers to ramp up their safety and health efforts to ensure that they do not become a “severe violator” in OSHA’s view. Here is a powerpoint presentation that recaps OSHA’s SVEP and provides some key advice to avoid being in the program. It also provides a breakdown of OSHA’s initiative to increase civil penalties administratively. With a particularly active OSHA enforcement program, employers must continually focus on their safety and health programs to ensure they are fully compliant with OSHA standards.
Just an FYI, OSHA published in the Aug. 31 Federal Register interim final rules that will help protect workers who voice safety, health, and security concerns. The regulations, which establish procedures for handling worker retaliation complaints, allow filing by phone as well as in writing and filing in languages other than English.
See the full release here.
Several major bills lately have included provisions to expand whistleblower protections for employees. The goal of such provisions is to allow employees to report actual employer wrongdoing, bringing regulatory violations and crimes to light in order to correct them. In the cases of the Protecting America’s Workers Act, the Robert C. Byrd Miner and Safety Act and now the Offshore Oil and Gas Worker Whistleblower Protection Act of 2010, these safeguards are meant to allow employees to report unsafe work practices by employers without retaliation.
These protections would be administered by the Department of Labor through the Occupational Safety and Health Administration (OSHA.) Would they accomplish their stated goal? Well, it’s valuable to look at how other similar whistleblower statutes have played out. OSHA currently has responsibility for processing allegations of whistleblower claims under the Sarbanes-Oxley (“Sarbox”) corporate governance laws. But in examining the caseload of these allegations of the 1,066 claims filed by employees only 25 whistleblower claims were actually upheld. This means that only about 2 percent of all of these whistleblower claims were legitimate.
This is a problem for employers, as they must use valuable resources to address all those other 98 percent of claims that have no merit and are not acted on by OSHA. These claims can be costly and further drive up the cost of doing business in the United States. As several of the aforementioned bills have expansive whistleblower enhancements included, we would hope that Congress would take the time to carefully review and debate the effectiveness of such measures.
The signs of such careful review are not encouraging. The Offshore Oil and Gas Worker Whistleblower Protection Act of 2010 was introduced by Rep. George Miller (D-CA) late Monday night and is slated to be voted on by the full House on Friday. The speedy action is far from the regular order that would allow the careful consideration of such a major bill that would divert resources away from job creation.
Cross-posted at the NAM’s Shopfloor blog here.
Today, the Coalition for Workplace Safety sent a letter to Members of the House of Representatives regarding the concerns of many in the employer community about H.R. 5663, the “Miner Safety and Health Act of 2010,” as it awaits floor action.
For printable PDF, click here.
The letter reads:
July 26, 2010
To the Members of the House of Representatives:
The Coalition for Workplace Safety (CWS) is a group of associations and employers who believe in improving workplace safety through cooperation, assistance, transparency, clarity, and accountability. CWS members are united in their desire to support policies that improve workplace safety. Unfortunately, H.R. 5663, the “Robert C. Byrd Miner Safety and Health Act of 2010” as approved by the Committee on Education and Labor, will not produce such results. While minor changes were made during the markup, none of them are sufficient to cure the problems this bill will create and the CWS, as represented by the signers below, continues to oppose this bill.
This legislation, while primarily addressing issues with mine safety, would result in the most sweeping changes to the Occupational Safety and Health Act since its inception. Unfortunately the provisions of this bill are not the right approach to assist both employers and employees in the shared goal of maintaining safe and healthful workplaces.
As we have made clear throughout the hearings and markup on this bill, H.R. 5663 is built around the theory that greater penalties and enforcement will yield safer workplaces. The CWS believes that instead of improving workplace safety, this bill will only increase the adversarial nature of the relationship between Occupational Safety and Health Administration (OSHA) and employers, and create more confusion leading to increased litigation and compliance costs.
According to the Bureau of Labor Statistics, from 1994 to 2008 the total recordable case rates for workplaces injuries and illnesses have been cut in half (improved by 53.6 percent), and workplace fatalities are now at their lowest level ever. To assist employers in continuing these efforts to maintain safe workplaces and prevent accidents, OSHA should engage cooperatively with employers and assist them in better understanding their obligations. This bill contains no support or assistance for employers to help them implement better safety programs or understand better their obligations. Such compliance assistance is particularly necessary to help small businesses, who often cannot afford to maintain safety personnel or hire consultants to guide them through complicated OSHA regulations.
In particular, the CWS is concerned with the following provisions of Title VII of H.R. 5663 that would amend the OSH Act:
Expansion of Whistleblower Rights (Section 701)—This provision would expand the ability of an employee to bring an action against their employer if they believe they have been inappropriately discharged or discriminated against because they reported an injury or unsafe condition, or participated in a proceeding related to safety and health before the Congress or any federal or state authority, or refused to violate any provision of the OSH Act. Current law (Section 11(c)) already provides employees with protections against such employer actions.
This provision is based on the belief that merely because the vast majority of current whistleblower complaints do not produce judgments in favor of the complainants, the system must be broken. In reality, the vast majority of complaints brought are not meritorious and no expansions of whistleblower rights are needed, nor will any expansions produce different results. The expansions will result, however, in excessive litigation and legal fees that will drain necessary resources from OSHA and employers. Section 701 simply promotes litigation and increases legal fees on employers, making OSHA’s whistleblower system punitive and a pathway to litigation rather than a tool for improving workplace safety.
Furthermore, Section 701 would provide the employee a right to a de novo review in federal court if either the Administrative Law Judge, or the administrative review board that hears appeals of such cases, do not issue decisions and orders within 90 days, regardless of whether the complaint has any merits. According to testimony delivered by attorney and whistleblower expert Lloyd Chinn at a hearing held in the Subcommittee on Workforce Protections on April 28, 2010, these deadlines will not be met, thereby giving employees the right to bring their case in a federal court which will result in lengthy, and resource intensive litigation.
Mandatory Abatement and Procedures for Obtaining a Stay (Section 703)—This section would force employers to begin any corrections (abatement) under a serious, willful or repeated citation immediately upon receipt of the citation. Current law allows employers to stay this requirement pending the completion of a challenge to the citation if they pursue one. While this section provides a process by which an employer could get a stay of this requirement, the criteria for that are unlikely to be satisfied, and while the employer is seeking this stay they will be required to be satisfying the abatement provisions set out by the OSHA inspector who may not have a good understanding of the workplace at issue.
Abatement is often a very costly, disruptive, and complicated process. It also represents part of the consequences of receiving a citation. While employers are prepared to correct hazards and make necessary improvements to their workplaces, whether they should have to spend the levels sometimes specified in a citation, and reconfigure their workplaces, or even cease certain operations or using certain machinery depends on whether OSHA has issued a valid citation. Just like any person accused of violating a law, employers have a right to due process before they can be forced to comply with costly and disruptive abatement measures specified by an OSHA inspector unfamiliar with the workplace, and this provision effectively strips employers of that right to due process. While the process provided in this section purports to protect an employer’s due process rights, it relies on the standard associated with seeking a preliminary injunction—a very difficult standard to meet. This represents an unreasonable burden for employers to overcome and is no substitute for current procedure that stays the abatement requirement while an employer exercises their due process rights. In effect, this bill seeks to make the OSHA inspector the judge, and jury.
Nor is this provision necessary. At a hearing in the Subcommittee on Workforce Protections of the House Education and Labor Committee on March 16, OSHA Director of Enforcement (now Deputy Assistant Secretary) Richard Fairfax made clear that OSHA can shut down a workplace “within an hour” if they find an imminent danger that requires such attention.
Increased Civil and Criminal Penalties (Sections 705, 706)—Perhaps the signature provisions of this bill are the increases in civil and criminal penalties, as well as other changes to how OSHA would impose these penalties. The CWS believes that increases in penalties do not yield improvements in workplace safety as penalties are never a proactive approach, they are merely reactive—they only apply after there has been a violation, accident, or fatality. The real impact of increasing civil and criminal penalties will be a significant surge in the number of citations employers choose to challenge as demonstrated by the increases in fines under MSHA, as a result of the MINER Act enacted after the Sago, WV mining tragedy. Since the MINER Act regulations took effect in 2007, the backlog at the Federal Mine Safety and Health Review Commission is 16,000 cases (worth $195 million), and expected to rise further as the current policy at MSHA is to not engage in settlements. This backlog has impacted safety in the mining industry by absorbing an unprecedented amount of MSHA resources which would otherwise be devoted to field and other activities.
Instead of forcing employers to accept the penalties and proceed to payment, these dramatic increases will shift the cost-benefit equation for challenging and getting legal representation so that there will be greater benefit in pursuing a challenge than there is currently. This is especially true with respect to the expanded criminal penalties that this bill would create.
Beyond the problems associated with the proposed increases, Section 706 (criminal penalties) also makes other objectionable changes. It specifies that the term “employer” also means “any officer or director” without any qualification or suggestion that such an officer or director had any role in the incident in question. This overly broad expansion of the definition for employer is unworkable, but more importantly would likely ensnare company officials that had no involvement in, or knowledge of, the incident giving rise to the citation and criminal penalty. Such a presumption raises serious substantive due process questions and contradicts well established legal principles of whether someone can be charged for something with which they had no connection. This provision would also create a very strong chilling effect on anyone taking a high level corporate job or seat on a board if they could find themselves facing criminal penalties because of the least responsible employee.
This section also introduces the new intent level for criminal penalties of “knowing” with no explanation or indication of how that new level is to be determined or limited. As used in environmental law, this term has come to be associated with a very low level of intent, a virtual “strict liability” standard where the party in question merely has to know that a given activity was taking place, not that there was a violation occurring or that environmental laws were being broken. To apply this in the OSHA context would not only seriously degrade the legitimate level of intent currently in place, but it would create tremendous confusion and guarantee that each time it was used, it would be challenged in court leading to massive new levels of litigation.
Pre-Final Order Interest Penalties (Section 707)–This section would impose interest penalties on employers, compounded daily, while they challenge a citation—in effect penalizing them for exercising their due process rights. This provision has no redeeming merit, nor can it be said to have any plausible connection to improving workplace safety.
The members of the Coalition for Workplace Safety are committed to seeking and advocating for new ways to continually improve safety in the workplace. Unfortunately we maintain our strong belief that H.R. 5663, as approved by the committee, will not improve safety but will instead create greater cost, litigation and hamper job creation. We urge you to vote against this bill.
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