Occupational health and safety should not
solely be inspection, enforcement, and rulemaking. Regarding combustible dust
workplace fire and explosion hazards, outreach, education, training,
and research is essential. All these elements are included in the OSH
Act. The enlightening GAO report sheds light on the fact that the OSH
Act is not being adhered to. I encourage all EHS professionals to read
the OSH Act, Sections 20, 21, 22
Solely relying on a regulation in providing a warm and fuzzy feeling is not the complete solution. A prime example, would be the multitude of grain elevator explosions following the OSHA Grain Facility Standard So now we have reached a point where X fatalities is not acceptable but Y fatalities is acceptable. OSHA does not have the resources to be everywhere at once. The time has now come in the 21st century where the paradigm must change to shared responsibility engaging all stakeholders.
In contrast, "Clinical Professor of Environmental and Occupational Health Michael Silverstein claimed that OSHA and NIOSH have been working together for the past 40 years"
Then why hasn't NIOSH been a primary stakeholder in the OSHA Combustible Dust rulemaking?
Full Committee Hearing - Time Takes Its Toll: Delays in OSHA’s Standard-Setting Process and the Impact on Worker Safety.
Maybe this GAO report will open dialogue on establishing and coordinating local, state, and federal standardization, interoperability, compatibility, and responder health and safety to prepare for, train and respond to, mitigate, and recover from any incident by identifying requirements for an all-hazards incident response which includes OSHA, NIOSH, and US Fire Administration?
"The InterAgency Board (IAB) is a voluntary collaborative panel of emergency preparedness and response practitioners from a wide array of professional disciplines that represent all levels of government and the voluntary sector. The IAB provides a structured forum for the exchange of ideas among operational, technical, and support organizations to improve national preparedness and promote interoperability and compatibility among local, state, and federal response communities."Doesn't catastrophic ComDust related fires and explosions in the workplace warrant federal standardization, interoperability, and compatibility?
GAO Report: WORKPLACE SAFETY AND HEALTH, Multiple Challenges Lengthen OSHA’s Standard Setting.
"Improve coordination with other agencies: Experts and agency officials noted that OSHA has not fully leveraged available expertise at other federal agencies, especially NIOSH, in developing and issuing its standards. OSHA officials said the agency considers NIOSH’s input on an ad hoc basis but OSHA staff do not routinely work closely with NIOSH staff to analyze risks of occupational hazards. "
"However, OSHA can coordinate more routinely with NIOSH on risk assessments and other analyses required to support the need for standards, saving OSHA time and expense. In our report being released today, we recommend that OSHA and NIOSH more consistently collaborate on researching occupational hazards so that OSHA can more effectively leverage NIOSH expertise in its standard-setting process. Both agencies agreed with this recommendation."This is only the tip of the iceberg of agencies not working together regarding workplace ComDust fire and explosion hazards. For example, OSHA has ignored the US Fire Administration in the ComDust Rulemaking process. When a ComDust related fire goes beyond the incipient stage, who you going to call to extinguish the fire?
Multiple Challenges Lengthen OSHA's Standard Setting (GAO Report)