Health and safety relationship with commerical industry
Interview With OSHA Chief John Henshaw
ISHN interviewed John Henshaw, assistant secretary of labor for OSHA, in his Washington office on October 18th. Henshaw, a certified industrial hygienist, worked for 26 years in industry. His career included stints as director of environment, safety and health for Solutia, Inc., a Monsanto spin-off; and various positions with Monsanto Company, including corporate director of quality and compliance assurance, corporate stewardship for environmental safety and health, and corporate industrial hygiene. He was president of the American Industrial Hygiene Association in 1990-1991.
Henshaw was named by President Bush to head OSHA on June 13, 2001. He was confirmed by the Senate on August 3, 2001. Here are excerpts of his remarks:
ISHN: In the first Bush administration, when Jerry Scannell was assistant secretary for OSHA, he talked of setting ambitious standards for motor vehicle safety, generic exposure monitoring and medical surveillance, and indoor air quality. You talk mostly about partnerships and the ways safety and health can add value. What happened? Why the change?
HENSHAW: In the past, OSHA came to be known for operating strictly on enforcement. Therefore you need standards. As we've learned over the years, it's more and more difficult to put out standards because we've got more hoops to jump through, more data to gather, more scrutiny on standards.
It seems to me this is an excellent time to deploy, as Congress intended us to deliver, a whole host of things to achieve the result we're looking for. You know, there are about 13 items in the (OSH) Act that say how OSHA can execute its responsibility, one of which is standards. All the other things deal with encouragement, using existing best practices, enforcement, and so on. We shouldn't think the only thing we can do is develop standards and enforce them.
We've assessed what works and what doesn't work. We studied last year all the positives around the Voluntary Protection Program, the partnerships, the alliances, the need for outreach and education. So what we've told ourselves is, there's a balanced approach here - not just enforcement and standards-setting.
As a sailor, I'm trying to adjust the winds to our boat. I can't change the direction of the wind. I'm trying to adjust it and make as much progress forward as we can.
Let me correct one thing. We are obviously vigorously pursuing our regulatory agenda. We'll do that. We have and we'll continue to generate standards. But it will be done in a manner where we know exactly what we're doing, and we'll accomplish it.
It won't be a wish list. It will be a do list. When we do something we're going to live up to it. We spent a lot of money with our wish list, doing things that we didn't carry to the next step. It was a waste of time and energy and money.
ISHN: What are your standards-setting priorities?
HENSHAW: The reg agenda spells it out. Crystalline silica is on there. It is ubiquitous; NIOSH has some new information on it. There are other specific compounds like glycol ethers and chromium.
We have a standards improvement process, which is trying to bring a host of standards up to date. I think our credibility is at stake when we have a standard so far out of date that people say, "Who cares?"
Then there are some new items on the agenda like cranes. The old standard on cranes was 30 years old. We need to update that. These are the kinds of things we have on the agenda.
ISHN: Some people are concerned that OSHA is rolling out partnerships and alliances too fast and furious now. That you won't have the time and resources to follow through. Your comment?
HENSHAW: The intent is to grow the things that have been successful, and over the last 30 years, the things that have worked. (At the time of this interview, federal OSHA had initiated 167 partnerships since the mid-1990s.)
Partnerships are usually a discreet project or with an organization. We have a qualification process, we have an inspection component, a monitoring piece. We establish an agreement up-front that we're going to work together, we're going to monitor each other, and each put a degree of resources in. The net result for us is using less resources than we normally would, especially on big projects, while we get better results.
One of the things we have to do with each one of our partnerships, and which we're doing, is measure those results at the end. We have to prove our worth and prove these partnerships are working every time we do one.
Now the alliances are something different. We've got maybe a dozen or so. Alliances are a loose form of a working relationship where we're capitalizing on each other's resources. It's another leveraging tool in my mind. Alliances are more geared toward associations and professional societies. We describe issues - ergonomics is going to be a key one for us - where we can collaborate.
We've got to figure out how can we get our job done with the amount of people that we have right now. Through our partnerships and our alliances we can multiply the number of people working with us, and in my mind get a bigger impact for our dollar.
WORKING WITH NAM
ISHN: Speaking of alliances, what can you tell our readers about how OSHA is going to be working with NAM (the National Association of Manufacturers)?
HENSHAW: The details haven't been worked out, but I would certainly welcome an alliance with NAM. It's going to be more in the education, outreach, assistance area. I'd very much welcome a signed agreement with them. We've been talking to them, and they're willing to talk about it. They know, members of NAM know, that safety and health add value. They want to get their members up to speed in respect to adding value to their organizations.
ISHN: There are concerns that OSHA is giving away too much with these partnerships, or will be co-opted and used by other groups. Your comments?
HENSHAW: In partnerships, we do actual on-site assessments. We're actually there. We're not giving anything away. We'll still do enforcement. We'll still conduct inspections at facilities. The only one where we give an exemption of programmed inspections is VPP.
With alliances, since we're talking about associations, we're certainly not giving anybody any kind of incentive, a safe harbor, or exemption.
The manufacturing sites in NAM, the members of NAM, they still have obligations, they're still part of our programmed inspections if they're under the SST (site-specific targeting). They're still going to be inspected as the result of formal complaints or accident investigations. So nobody is getting away with anything.
VOLUNTARY PROTECTION PROGRAM
ISHN: VPP has many benefits, but some people have said that one of the downsides of VPP is that it can do such a good job of operationalizing safety, spreading responsibilities among employees, that there is less need for full-time safety and health professionals. Your comments?
HENSHAW: I think most safety and health professionals would agree that the way to be effective in safety and health is to get safety and health operationalized. Get it down to the workplace, down to every employee and every management system and management practice. Safety is part of the job of every person on the site. Every safety and health professional would agree to that.
Now, if that means there's less need for some experts, well, our job is not to keep ourselves employed, our job is to make sure workplaces are safe. I would venture to say that there is enough work to go around forever in safety and health.
And by getting down into management, to operationalize it, we still need safety and health professionals to manage that, to keep the new ideas coming, keep the energy in it, keep the focus where it ought to be, identify additional hazards, and other solutions. That's a lot of work. I think it would require safety and health professionals to think a little broader than maybe the old traditional way of "I'm an expert, you come to my office and I'll tell you how to do it", as maybe the old safety professional did. We have to be more creative in how we deliver our services.
LOW JOB SATISFACTION
ISHN: In the most recent White Paper reader survey we conducted, only 38 percent of readers expressed satisfaction with their job. There are a lot of theories about this: all the major problems have been solved, injury rates are at an all time low, the profession is aging, not as idealistic and passionate. What are your thoughts about this low job satisfaction? You've been there, been a professional, led that life.
HENSHAW: Sure, it's not always an easy job. It's not easy to be green. That's partly because we've always been sort of an outside component. We've been a necessary evil. And I think one way to get around that, being an outsider, is to be an insider.
I don't think we've done an adequate job in articulating the value of safety and health, the business value, the economic value. We've always done our job on the human side, but I think we have a lot of opportunity here to turn this around and be an integral part of the business function, where we are a welcomed addition as opposed to an additional cost.
We haven't thought that way. I think the challenge for us is to get outside of the box we're in. We had to be there because of all the compliance issues we had in the past. You know, "OSHA said we have to do it so therefore I'm here to help you comply. I'm not here to add value; I'm here to help you comply. I'm here to avoid citations, not to add value."
I think now we've got to switch a little bit, and say, "I'm here to add value. I'm here to make people more productive".
ISHN: According to our White Paper research, our readers think the best jobs in EHS in the future are going to be in consulting. Are our readers giving up on the idea of being an insider? Do you see EHS becoming a profession of consultants and independent contractors?
HENSHAW: I think certainly as safety and health becomes an integral part of middle to small businesses, then safety and health consultants would have more activity, because they would get the small companies who can't afford the investment in hiring their own staff. So I hope we see more jobs in the consulting side because that means we're getting to more of those people who can't afford full time support. And they need a part-time person who they can bring in to help them solve the problems.
Now consultants also need to talk the language of the business, and that's where the skillful ones are going to be more successful because they can integrate and sell their value to whatever business they're dealing with. So I can see consulting increasing.
But the larger companies who have safety and health programs, the outsourcing and insourcing, that just keeps going back and forth, back and forth, and I don't know where that's going to end up. At any given time, it's guaranteed the pendulum is going to be on one side or the other.
ISHN: Will ergonomic guidelines work? Some people say guidelines will not be a strong enough incentive for smaller companies that are less committed to safety. Your comments?
HENSHAW: Unfortunately there are some employers out there for whom even standards aren't enough incentive to do the right thing. Just because you have a standard doesn't mean you have compliance.
I think, especially with ergonomics, guidelines are the only way to go. Ergonomics is so complex, so varied in respect to the conditions in plants, the solutions are different, even the evaluation tools are different.
Plus, this agency has been looking at how to address ergonomics for the last 10-15 years. And look where we're at today. We still haven't found a standard like other standards OSHA has done. So guidelines are the only way to get it done, at least at this juncture. Now what happens in the future, somewhere down the road, who knows?
One of the things I hated about some of the OSHA standards in the past was that they forced me to do things that didn't add value. I had to spend a lot of time fighting for the money I got, and I hated to waste it. So this is the time that business is going to have the ability to find its own solutions to its own problems, which is their obligation.
PERMISSIBLE EXPOSURE LIMITS
ISHN: Do you support the current work being done by AIHA (American Industrial Hygiene Association), ORC (Organization Resources Counselors), unions, and business groups to draft legislative language that would allow OSHA to update its hundreds of permissible exposure limits (PELs)?
HENSHAW: First of all, I recognize that the PELs need to be updated. Clearly, they need to be updated. The PEL project that was attempted 12, 13 years ago was something I encouraged because I liked that updating process, it needed to be done.
Whether this group will be successful or not, I don't know. We have had a briefing from them as to what the program looks like and what their proposal looks like. I know they've talked to several other people on the Hill as well as John Howard at NIOSH. I think that's moving in the right direction. Talk to the people who can take some action. I certainly welcome continued conversations with them and see what we can do.
SAFETY & HEALTH MANAGEMENT SYSTEMS
ISHN: Do you support the work of the ANSI Z10 committee that is drafting a voluntary occupational safety and health management system standard?
HENSHAW: I firmly believe that safety and health need to be a part of every management system. To what extent, and what kinds of issues need to be addressed, depends on the size of the organization.
I have been involved in management system work, 14000 (environmental management standard) and the ISO process. I haven't read the latest draft on what ANSI and AIHA are doing, so I can't tell you whether I like it or not versus something else. I can tell you in a general sense that management systems do work. But they need to be flexible enough to deal with the degrees, the diversity of workplaces that you have out there.
My biggest fear with any kind of voluntary standard is that it's written in such a way that it doesn't allow that flexibility, and it begins to isolate people. To those who already have the capital to invest in these kinds of very fancy management systems, they do it. The ones who don't are left out and they don't have any guidance.
ISO STANDARD COMING?
ISHN: Momentum seems to be gaining to build on the ISO quality and environmental standards. Do you think our readers will see in the next five years an ISO safety and health standard?
HENSHAW: I really don't know. Whether ISO would take that up or not, I have no way to judge. The only thing I can say is that your readers ought to focus on their own internal management practices and ensure safety and health is a part of that. Don't wait for ISO. Don't wait for some other process.
SAME STANDARDS CITED AGAIN AND AGAIN
ISHN: You make the point in your speeches that year after year, OSHA sees the same standards being violated most frequently - hazard communication, fall protection, lockout tagout, PPE. Why is this? Why doesn't industry seem to get some of the most basic aspects of safety and health after these rules have been on the books for years and years?
HENSHAW: Obviously each workplace has a different twist and a different reason for it. This gets into the whole concept of thinking we have the major problems solved. I'm not sure all of them have been solved, there's still a lot of big issues out there. But compared to 20 years ago, when we had the new carcinogen of the week, a lot of those have been addressed.
I view this as we're at another plateau now. In my mind it's more akin to a quality plateau. You know, we accepted a certain level of defects in quality, said we've done everything, we've manufactured the process, we have it automated, and here's the ten percent defect rate - hey that's just the way it is. We still have 5.7 million injuries in this country (annually). We've said all major hazards have been corrected, all the major issues. But we still have 5.7 million injuries. So I think the next step is, just like in the quality phase that was done several years ago, we've got to bring that down, down to zero defects. In this case zero injuries and illnesses.
That's going to take a little different mindset. The big issues aren't there. Now we're going to have to focus on the more minute issues, and the more system-oriented issues to get to that next plateau.
ZERO IS POSSIBLE
ISHN: Are you of the school that you can get to zero incidents, or do you think that if you set zero as the goal you're going to turn off employees, demotivate them, because they know something is going to happen, you can't control everything?
HENSHAW: It's a little bit of both. Maybe using the word "goal" is wrong. It's really a target, certainly it's what's possible. Zero is possible. I firmly believe zero is possible.
Now, can it be attained this year? Next year? The year after? Obviously, that's going to take some time. Again, it's similar to quality: is zero defects possible? Sure. We can achieve zero, but it shouldn't be a goal, it should be a target, a vision, an expectation. I don't know that it ought to be a discreet goal, only because we haven't solved all the issues and haven't built all the systems as we should. It is doable. Zero is possible and achievable.
WE ARE ALL IN THIS TOGETHER
ISHN: Are there any other messages you want to get out to our readers about what you're doing, or what you want to do?
HENSHAW: I would like to continue to request support from your readers to help us with enforcement, education and partnerships, because those three things are exactly what they've been doing in their workplaces. I think there are a lot of opportunities where we can collaborate. I'd like to see that.
We're all in this together, we're all trying to do the same thing, maximize our resources and collaborate to the extent we can. We also all need to take a leadership role. Which means being outspoken. Which means take a few risks. Which means, look at things differently. We have an obligation to look outside the box, let me look at it from a different angle. Every safety and health professional needs to do that.
Many professionals believe the truths are self-evident. They need to recast their message, not in a demanding way, but in a way that exercises leadership. Take some risks. Look at things different. Make sure safety and health is part of human capital. Take that message to different people, people you never thought of approaching before.
For more information, contact:
Alan L. Wozniak, CIAQP
(800) 422-7873 ext, 802
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Interview With OSHA Chief John Henshaw
Health and safety relationship with commerical industry
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