OMB and Risk-Risk Analysis
Sheriff, Robert E., Occupational Hazards
In my year as president of the American Industrial Hygiene Assn. (AIHA), I have dealt with a number of issues stemming from our federal government relations program.
I was dismayed to learn that out of the blue, with no public notice or comment, the Office of Management and Budget (OMB) is proposing that federal regulatory agencies be required to undertake risk-risk analysis of major regulations, in addition to the costs and benefits that must currently be determined. I decided that it was essential for AIHA to respond quickly to this proposed requirement.
As an industrial hygienist, I strongly believe that occupational illness and injury can and should be prevented. This belief is the basic foundation of my professional life; it is the reason that I do what I do for a living.
I was bothered by OMB's premise that regulations which prevent and control occupational illness cost lives because they cost money. This "health vs. wealth" approach can hinder the progress made in worker health and safety since OSHA was created 21 years ago. This attitude benefits only those workers who, out of sheer luck, do not contract an occupational illness or injury. The OMB proposal is like a reverse lottery. If by chance, through heredity, lifestyle, age or exposure, your name is drawn and you contract an occupational illness, become incapacitated, or possibly lose your life, too bad for you. Such an attitude flies in the face of basic human rights. It is also in direct conflict with OSHA's prime directive that employers are responsible for the health and safety of their employees. This is a responsibility which cannot be waived, signed-off, or deferred.
In my testimony to the Senate Labor and Human Resources Committee, I expressed my concern that the OMB concept runs counter to AIHA's belief that health and safety in the workplace pays. OMB's position seems to be "Just pay people more and their health will improve." Dollars are all OMB is concerned about. I believe that the economic theory behind OMB's position has been repudiated time and time again by Congress and by presidents of both political parties. If it were valid, there would be no reason for OSHA and other agencies, whose job it is to promote health and safety, to exist.
I also expressed concern to the committee about the interminable delay the new initiative will cause in the promulgation of safety and health regulations. Agencies with limited resources such as OSHA, the National Institute for Occupational Safety and Health, the Environmental Protection Agency, and others already have a difficult time in promulgating regulations and publishing guidelines in a timely manner. …