Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and no longer represents OSHA Policy. It is presented here as historical content, for research and review purposes only.

The OSHA Priority Planning Process Overview

OSHA's Mission and the Need For Priorities

The mission of the Occupational Safety and Health Administration (OSHA) remains as it has for nearly 25 years -- "to assure as far as possible every working man and woman in the nation safe and healthful working conditions." This challenge -- to save lives, prevent injuries and illnesses, and protect the health of America's workers -- is as vital today as when Congress enacted legislation to establish OSHA in 1970.

OSHA and its 25 State partners have had substantial success in fulfilling their mission. Workplace fatalities have decreased consistently since the OSH Act was established in 1970, at a rate of decline faster than that of the prior twenty five years. Injuries and illnesses on the job have been found to decline by 22% in the three years following an OSHA inspection of a manufacturing workplace when that inspection results in penalties. OSHA standards, such as those for lead, cotton dust, trenching, and grain dust have resulted in sharp decreases in injuries, illnesses, and deaths. Overall injury and illness rates have declined in the industries where OSHA has concentrated its attention, but have remained unchanged or have actually increased in the industries where OSHA has had less presence.

Despite OSHA's accomplishments, there were still more than 6,000 fatal work injuries in 1993. In addition, every year there are still an estimated 50,000 deaths from illnesses caused by workplace chemical exposures, and 6 million non-fatal workplace injuries. Injuries alone cost the economy more than $110 billion a year. These numbers are unacceptably high, particularly because illnesses, injuries, and deaths on the job are largely preventable.

OSHA continues to bear a major responsibility for promoting programs to prevent injury, illness, and death on the job. Yet, resources are scarce and are expected to remain so. As a result, OSHA must focus national attention and agency efforts where they are most needed and will be most useful. OSHA has already established standards for a number of the most important known hazards, and has developed enforcement strategies and consultation activities to deal with others, including falls, logging, confined spaces, asbestos, and more. Rulemaking for several other important problems--such as tuberculosis, methylene chloride, and scaffolds--is currently underway. However, important gaps remain. OSHA's Priority Planning Process expresses the Agency's intent to fill many of these gaps by identifying unfilled needs and establishing plans to deal with them through rulemaking and by leveraging the private sector to undertake voluntary interventions.

Meaningful priorities must be based on a sound assessment of the most serious threats to worker safety and health and those with the most potential for amelioration. They must also take account of national employment patterns as well as the concerns and interests of business, labor and the professional community. The affirmation of existing priorities and establishment of new ones must, for example, consider factors such as these:

Many injuries, illnesses, and deaths still occur as a result of hazards which are widely recognized and/or covered by existing rules but which are nonetheless inadequately controlled.

The Bureau of Labor Statistics, for example, reported that in 1993 more than half of the nation's most serious nonfatal injuries were caused by overexertion, being struck by objects, or falls to the same level. OSHA is working with employers to adopt the best practices for finding and fixing recognized hazards by offering them a choice between partnership or traditional enforcement based on their implementation of an effective safety and health program. OSHA is also working with business and labor to develop a comprehensive safety and health program rule which will establish minimum requirements and which will provide employers a clear starting place and a roadmap through the rest of the rules.

Substantial safety and health problems exist in industry sectors where OSHA has had minimal presence.

For example, the explosive growth of the service sector of America's economy has brought with it large numbers of relatively uncontrolled hazards. The Bureau of Labor Statistics reported that in 1993 six of the ten industries with the largest numbers of workplace injuries were in the service sector. Nursing home workers had a higher lost workday injury rate than those in paper mills, blast furnaces, steel mills, metal mining, or the manufacture of durable goods.

Work related musculoskeletal disorders such as tendinitis, carpal tunnel syndrome, and low back pain are leading causes of pain, suffering, and disability in the workplace today.

BLS estimated that more than 700,000 repetitive trauma or overexertion cases resulted in lost workdays in 1993. Back problems by themselves account for 16% of all workers compensation claims and 33% of the cost. Ergonomics, the science of designing jobs to fit people, provides tools to address these problems. OSHA is committed to working with business and labor on ergonomics initiatives, including the development of regulatory and non-regulatory approaches, special enforcement efforts, training, education and technical assistance.

OSHA's Priorities and OSHA's Regulatory Strategy

OSHA intends to address the issues emerging from its Priority Planning Process through a combination of rulemaking and other intervention tools. Only a small number of the new priorities listed below have been chosen for rulemaking at this time. Insofar as these new priorities enter OSHA's rulemaking calendar, they fit into a five point regulatory strategy intended to develop standards that make sense to reasonable people:

  • identify clear and sensible priorities
  • focus on key building block rules
  • eliminate or fix confusing and out-of-date standards
  • emphasize plain language
  • rely on cooperative partnerships
OSHA has, for example, initiated rulemaking on a fundamental Safety and Health Programs rule, which will establish a foundation for all future workplace safety and health efforts. In addition, at the request of the President, OSHA has conducted a page-by-page review of existing standards in order to define appropriate action on confusing and out-of-date rules. As a result OSHA will be working with business and labor to rewrite many old, industry consensus standards into plain language so they are more understandable and useable.

The Priority Planning Process

The OSHA Priority Planning Process has been aimed at identifying the top priority workplace safety and health hazards in need of either regulatory or non-regulatory action. The resulting set of priorities is intended to round out the agency's existing programs in order to ensure that the leading causes of occupational injuries, illnesses, and deaths are being effectively addressed. The Process was initiated in 1994 and proceeded through the following steps:

Priority Planning Committee: A Committee with subject matter and functional expertise in workplace safety and health issues was selected, with members from OSHA, the National Institute for Occupational Safety and Health (NIOSH), the Environmental Protection Agency (EPA), and the Labor Department's Office of the Solicitor, Office of the Assistant Secretary for Policy, and Mine Safety and Health Administration (MSHA). The Committee reviewed available information on occupational fatalities, injuries, and illnesses, and held an unprecedented dialogue with stakeholders and the public.

Dialogue With Stakeholders: The Priority Planning Committee actively solicited input from stakeholders and the public through three primary avenues: direct mailings beginning in August 1994, a Federal Register notice in October 1994 (59 FR 52557), and a series of four face-to-face "scoping" meetings in November 1994. More than 100 stakeholders submitted written comments to the Committee (Docket C-04), and nearly 200 representatives of labor, industry, professional and academic organizations, State plan designees, voluntary standards organizations, and the public met during the four scoping meetings. In addition, the Priority Planning Committee met with and received recommendations from two of OSHA's advisory committees: the National Advisory Committee on Occupational Safety and Health, and the Advisory Committee on Construction Safety and Health.

One key theme which emerged during this dialogue with stakeholders is the very broad support expressed by participants for OSHA's building blocks projects, particularly the safety and health programs rule. These comments have given added importance to OSHA's ongoing efforts to develop a proposal for such a rule, and although it is not included as one of the new priorities because it is already under active development, it will provide an important context for those action plans which will emerge to address the new priorities.

A second theme which emerged from the dialogue with stakeholders is the endorsement by most participants of the idea of considering non-regulatory actions as part of the planning process. This theme is clearly reflected in the final priority list, which includes substantial use of various non-regulatory approaches.

Review of Data: While the "most important" safety and health problems are not necessarily those which turn up at the top of any particular statistical listing of injuries and illnesses, it was necessary to review major statistical compilations as well as the relevant literature in order to make the most sound decisions. Three particularly useful sources were:

  • BLS' National Census of Fatal Occupational Injuries
  • BLS' Survey of Occupational Injuries and Illnesses
  • NIOSH's surveillance data bases
Decision Criteria: It was necessary to make decisions in a systematic and rational manner, yet the Committee believed that a rigid mathematical approach to ranking hazards could lead to conclusions that were not informed by all relevant considerations. Therefore a combined qualitative and quantitative approach was adopted. The Committee first applied four major criteria to the various hazards:

  • the seriousness of the hazard
  • the number of workers exposed or the magnitude of the risk
  • the quality of available risk information
  • the potential for risk reduction
These major criteria were then supplemented with three others so that the Committee could consider whether rulemaking was appropriate. The additional criteria are:

  • administrative efficiency or feasibility
  • legal feasibility
  • other public policy considerations (such as intensity of public concern and public perception of the hazard.)
Selection of National Priorities: The Committee applied its decision criteria to a list of more than 125 hazards that were nominated by individual stakeholders and agency staff. Eighteen of these hazards were selected because they best met the combination of criteria for designation as priorities. As a whole, these new priorities, which supplement rather than replace OSHA's on-going activities, affect millions of working men and women in a wide variety of workplaces. They involve preventable problems which are responsible for a large number of injuries and illnesses (or in some cases, responsible for posing a particularly high risk to a relatively small group), yet currently receive inadequate attention from government agencies or organizations in the private sector.

The 18 priorities were chosen on the basis of objective criteria; however, they are certainly not the only group of hazards that could have been selected. Other health or safety hazards that cause significant numbers of injuries or illnesses, or have generated a high level of public concern, were not chosen as priorities because they did not fit the Committee's criteria. These policy decisions are based on expert and professional judgment, and are not based on an arbitrary scoring system. They will be reviewed periodically as new information becomes available. The agency is committed to continuing this process on a systematic basis to evaluate progress and to identify emerging safety and health issues that may also need to be addressed.

Viewed by themselves, these new priorities would represent an incomplete safety and health agenda for the nation and for OSHA. However, when the new priorities are combined with the issues addressed by existing programs they cover many of the nation's leading occupational health and safety threats. The major exceptions involve issues for which the available evidence about health or safety hazards or effective preventive measures is inconclusive or controversial (such as exposures to electromagnetic fields or to workplace stress).

Action Approach: The agency has designated broad approaches (regulatory or non-regulatory action) for each of the priority hazards, with a significant emphasis on non-regulatory interventions. Five of the new priorities (Noise/Hearing Conservation in Construction and Other Noncovered Industries, Permissible Exposure Limits (continuation of activity), Electric Power Transmission and Distribution in Construction, Metalworking/Machining Fluids, and Crystalline Silica) have been designated for rulemaking and will be added to OSHA's regulatory calendar as other standards are completed and resources become available. For all the other priorities, OSHA will work with business, labor, the professional community, and state plan partners to encourage worker protection without developing new rules at this time. In some cases interventions may involve OSHA's use of its existing authority, including regular enforcement efforts, as well as program initiatives recently announced by the President that provide incentives to employers who effectively find and fix hazards. In most cases, the current approaches to the new priorities will be voluntary and informational.

Voluntary approaches seek to correct workplace hazards through cooperative actions. Examples are: partnerships with workers and management to identify actions to reduce or remove a hazard; encouragement of voluntary standard-setting organizations (such as the American National Standards Institute, and the American Council of Governmental Industrial Hygienists) to take action on priority hazards; the issuance of guidelines; the use of the existing Federal/State consultation program to encourage employers to identify and correct priority hazards; and dissemination of information about hazards and ways of preventing or controlling them.

Informational approaches involve the gathering, generation and distribution of additional information about priority hazards and issues. Examples are: research on health effects or control technology; technical information exchanges such as workshops and symposia; NIOSH Criteria Documents, Special Hazard Reviews, and Hazard Alerts; OSHA's "SafeWorks" and "Fatal Facts" fact sheets; and joint actions by employers and workers to publicize hazard information.

Action Plan Development and Implementation: OSHA will develop a comprehensive action plan for each priority issue with ample opportunities for public input. These action plans, which will be developed and implemented several at a time, will identify specific tasks and activities and lay out timeframes for completion.

NIOSH played a significant role in the Priority Planning Process by providing technical expertise and assisting in the selection of priorities. OSHA Assistant Secretary Joseph A. Dear and NIOSH Director Linda Rosenstock, M.D. jointly reviewed and approved the final list of priority hazards. Since many of the OSHA priorities will both affect and depend upon NIOSH research, OSHA will invite NIOSH to take a leadership role in developing action plans for these priorities. In addition, the results of the Priority Planning Process will help NIOSH develop the National Occupational Research Agenda (NORA). NORA is an on-going project designed to set priorities for workplace research over the next decade.

OSHA has stressed the involvement and input of individual stakeholders at every step of the Priority Planning Process. In this sense, the process is fully consistent with the President's March 4, 1995 directive concerning regulatory reform, and clearly demonstrates the importance of developing grass-roots partnerships with those who are affected by the agency's actions. We appreciate these efforts and strongly encourage interested individuals to continue to share ideas and comments with the agency throughout the implementation phase of the process.

Following this announcement, OSHA plans to convene a stakeholder meeting to informally discuss the 18 priority hazards and solicit input and assistance from interested individuals in developing and implementing the action plans. Specifically, OSHA seeks input as to which six priority issues the agency should address in the initial implementation phase, and which issues should be addressed in subsequent phases. In addition, we welcome comments on the format and content of the action plans (a draft action plan is included in the appendix as a sample format).

After these discussions, OSHA will draft action plans for the initial group of issues and convene a symposium with interested stakeholders to discuss the draft action plans in detail prior to final revisions and implementation. This process will be repeated in subsequent phases to address the remaining priority hazards. Again, we encourage the active participation of all interested individuals.

NOTICE: This is an OSHA Archive Document, and no longer represents OSHA Policy. It is presented here as historical content, for research and review purposes only.