By Eric J. Conn and Dan C. Deacon of Conn Maciel Carey’s national OSHA Practice

OSHA announced in a November 30, 2015 Press Release, that it is seeking public comment on its updated voluntary Safety and Health Program Management Guidelines, described by OSHA as:

“providing employers and workers with a sound, flexible framework for addressing safety and health issues in the workplace.”

Comments about the draft Guidelines are due by February 15, 2016, and OSHA has stated its intention to hold a public meeting in March 2016 to receive further comment on the guidelines. OSHA’s projected final release date for the revised Guidelines is sometime in the Spring or Summer of 2016, before the end of President Obama’s second term.

Dr. David Michaels, the Assistant Secretary of Labor for OSHA, an epidemiologist by training, is a big believer in the value of data. From our experience, he loves to analyze quantitative data and set policy based on this analysis. A primary reason for the resurrection and revision of the H&S Management Guidelines, we suspect, is the strong correlation Dr. Michaels has found between the application of sound safety and health management practices and lower rates of incidents of occupational injuries and illnesses.

OSHA’s analysis shows that where effective safety and health management is practiced, injury and illness rates are significantly less than rates at comparable worksites where safety and health management is weak or non-existent. Hence, before he leaves office, it is no surprise that Dr. Michaels has Continue reading →