In Praise of Standing Pat

LET'S put this whole standards thing on hold, for now. Are you with me?

OSHA, the International Safety Equipment Association, the National Rifle Association, and roughly 2,000 shooting enthusiasts seemed eager to stop two standards initiatives in mid-July, giving me the odd feeling that what I saw as a lethargic but sensible approach to rulemaking was revolutionary to others. It's a matter of perspective.

I'm not a reenactor or a black powder hunter, but plenty of my fellow Americans are, and they answered the call to attack OSHA's April 2007 proposed changes in the explosives standard (29 CFR 1910.109). The agency extended the comment period but raised a white flag only eight days later, closing the comment period immediately and promising to clarify its intent and re-propose the new rule at some unspecified later date. The NRA and the Sporting Arms and Ammunition Manufacturers' Institute were jubilant. SAMMI, ironically, was one of two parties that asked OSHA in 2002 to update the standard--take ammunition completely out of it and clear up the confusion that stems from several agencies having jurisdiction over explosives, they advised. To its credit, SAMMI said this year's proposal was well-intentioned but misunderstood the nature of modern gunpowder and ammo. SAMMI's chief said he wants to work with OSHA on it.

Similarly, ISEA said OSHA stumbled in May 2007 by trying to recognize "good design standards" as a way to continually update its PPE regulations. ISEA President Dan Shipp sympathized with OSHA's difficulty in enacting needed changes but said the regs must cite specific ANSI standards. "To take those references out of the regulation and replace them with the requirement that PPE comply with some vaguely defined good design standard," Shipp said, "shows a lack of understanding of the role of performance standards and their use in regulation."

Summing up, here's where we stand now on OSHA's rulemaking: Slow, fast, and clever are not acceptable, and responsive may not be. Shouldn't we just stand pat until early 2009?

This article originally appeared in the September 2007 issue of Occupational Health & Safety.

About the Author

Jerry Laws is Editor of Occupational Health & Safety magazine, which is owned by 1105 Media Inc.

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