Congressional Testimonies - (Archived) Table of Contents|
| Information Date:||10/17/1995|
| Presented To:||Subcommittee on Human Resources and Intergovernmental Relations Committee on Government Reform and Oversight.|
| Speaker:||Dear, Joseph A.|
Mr. Chairman and Members of the Subcommittee:
I am pleased to appear before the Subcommittee today to review the mission of the Occupational Safety and Health Administration (OSHA) and to discuss the many innovative programs the agency has developed to improve workplace protections for America's working men and women. Mr. Chairman, I applaud your longstanding concern for OSHA and for the American worker. The memorial in Bridgeport to those workers killed at L'Ambiance Plaza is a constant reminder to me and to OSHA's staff that we must improve our efforts to protect America's workers.
As you know, OSHA has received considerable criticism in the 104th Congress. Some have proposed to eliminate the agency. Others have proposed to slash OSHA's budget and trim our enforcement and regulatory powers to an extent that would greatly diminish our efforts to protect workers. In addition, there have been many misrepresentations of the agency's activities, from stories about OSHA banning the tooth fairy to the portrayal of OSHA as an agency bent on collecting fines for its own benefit. Mr. Chairman, I welcome this opportunity to set the record straight concerning our mission and to describe our efforts to reinvent OSHA.
Let me begin with the agency's mission and the continuing need for OSHA in today's workplace.
OSHA's mission, mandated by the Occupational Safety and Health Act of 1970, is "to assure so far as possible every working man and woman in the Nation safe and healthful working conditions..." This is a huge responsibility. There are over 6 million worksites in the United States under OSHA's jurisdiction, employing almost 100 million workers. Accomplishing this mission is extremely challenging in the context of the resources available to the agency. As you can see from the attached chart (#1), there is a growing gap between the resources available to OSHA and the size of the workforce it must protect. Counting State plan personnel, OSHA has a total of about 2,000 inspectors available to monitor workplaces and provide technical assistance to employers.
In spite of limited resources, OSHA has improved the lives of America's workers. Since its creation in 1970, the workplace fatality rate has declined 57 percent. Standards issued and enforced by the agency have made a real difference for millions of working people.
OSHA's cotton dust standard has virtually eliminated brown lung disease, which used to plague workers in the textile industry. The lead standard has reduced poisoning of workers in smelting plants and battery plants by two-thirds. In five years the grain dust standard reduced fatalities in grain elevators by 58 percent and reduced related injuries by more than 40 percent. OSHA's trenching standard has helped reduce trenching fatalities by 35 percent since 1990.
In areas where OSHA has concentrated its enforcement attention, such as manufacturing, construction, and oil and gas extraction, we have found that between 1975 and 1993 injury and illness rates have declined significantly (Chart #2). In industries that received less enforcement attention, such as wholesale trade, retail trade, and the service industry (including health care), the rates went up.
I am proud of OSHA's record. It is a story that needs to be told. At the same time, we still have along way to go. Every year work-related accidents and illnesses cost an estimated 56,000 lives. That is more than we lost in battle during the entire nine-year Vietnam War. On a average day 18 workers will be killed in safety accidents and an estimated 137 more will die from occupational disease. Both the human and economic toll are staggering. Accidents alone cost the economy over $112 billion a year.
In the face of the reality of limited resources, it was clear to me when I came to OSHA that the agency had to change its basic way of doing business if it were to continue making progress in the fight to improve worker safety and health. I would now like to discuss the key changes that have been made in the way OSHA operates.
The New OSHA
Many employers have complained that OSHA cares less about worker protection than about meeting perceived "quotas" for citations and penalties. While OSHA has never used quotas, it has in the past used inspections, citations and penalties as performance measures. The New OSHA's performance will now be measured by results--by the impact we are having on reduction of injuries, illnesses and fatalities in the workplace. We are beginning to measure such things as the percent of programmed inspections that find significant hazards as interim measures of success. Ultimately we are developing programs that will allow us to measure the success we've had at reducing injury, death and illness at both the sites we visit and the industry level in general.
On May 16 President Clinton announced three sets of regulatory reform initiatives for OSHA that the agency had been working on since 1993. These initiatives will fundamentally change the way we do business. First, OSHA will alter its basic operating method from one of command and control to one that offers employers a real choice between partnership and traditional enforcement. Second, OSHA will change its approach to regulations by identifying clear and sensible priorities, focusing on key building block rules, eliminating or fixing outdated and confusing standards and emphasizing interaction with business and labor in the development of rules. Finally, OSHA will alter the way it works on a day-to-day basis by focusing on the most serious hazards and the most dangerous workplaces instead of worrying about technical violations. We will insist on results instead of red tape. I will now describe some of the specific changes we have made to implement these initiatives.
Maine 200--A Partnership that Works
OSHA recognizes that most employers are interested in protecting their employees. Those who choose to work with their employees and with OSHA in reducing injuries and illnesses will find OSHA to be a willing partner. For example, in 1993 OSHA instituted a program in the state of Maine in which the 200 companies with the highest number of injuries were offered a choice: work in partnership to improve safety or face stepped-up enforcement. All but two firms chose partnership. Those firms opting to work with OSHA received assistance in developing strong safety and health programs, which include a self-inspection component to find and fix hazards. At the same time they were given the lowest priority for inspection, usually only being inspected if there were complaints from employees about serious hazards. In two years these employers have self-identified more than 14 times as many hazards as would have been expected to be cited by OSHA inspectors (Chart #3). Nearly six out of ten employers in the program have already reduced their injury and illness rates. Those employers that chose not to enter into a partnership with OSHA were given a traditional enforcement inspection.
The Maine 200 project demonstrates that OSHA can leverage limited resources to achieve worker protection by shifting responsibility back to the employers and employees at the worksite. OSHA has expanded the concept into New Hampshire and Wisconsin and will be instituting it in every state this fiscal year. The Maine 200 project has been recognized by the Ford Foundation. OSHA is a finalist for an "Innovations in American Government" award. This is the first time government organizations at the Federal level are being considered for this prestigious award.
Focused Inspections in Construction
Construction is one of the most hazardous industries in America. I know that this industry has been of particular concern to you, Mr. Chairman. OSHA believes that the key to a safe construction worksite is the establishment of an effective safety and health program by the controlling employer covering all worksite conditions. In order to encourage the establishment of such programs and to focus OSHA's limited resources effectively, OSHA launched in October 1994 its Focused Inspection Initiative in construction. Our compliance officers now conduct a review of the controlling contractor's safety and health program. If the employer has a program that meets OSHA's requirements, with an individual responsible for implementation, the inspection concentrates on the four leading construction dangers--falls, electrocution, crushing injuries such as trenching cave-ins, and being struck by material or equipment, and does not address the myriad of other OSHA regulations that a general inspection would encompass. These four hazards cause 90% of all deaths in the construction sector. If there is no satisfactory program, a comprehensive inspection is conducted. Focused inspections allow OSHA to concentrate on the real dangers in this industry while encouraging employers to establish comprehensive programs at their worksites. They allow OSHA to reach more construction worksites.
Revised Penalty Policy
OSHA's penalty system provides an incentive for employers to engage in proper safety and health activity. In recognition of the fact that the amount of penalty necessary to create such an incentive is smaller for smaller firms than for large ones, OSHA will increase the possible reduction in penalties which the OSH Act allows based on employer size. Soon penalty reductions of up to 80% may be given in certain circumstances to employers based upon the size of the establishment, with the smallest employers receiving the largest reductions.
Consistent with OSHA's belief that effective safety and health programs have a positive impact, penalty reductions for employers demonstrating "good faith," based upon the quality of their safety and health programs, will also be increased from the current 25% maximum. OSHA will be looking for programs that include management leadership, employee participation, workplace analysis, and hazard prevention.
OSHA's new focus on serious hazards rather than technical violations is illustrated by the dramatic reduction in minor paperwork violations in recent years, as shown in Chart #4. In FY 1991 OSHA issued more than 4300 citations to employers for failing to have an OSHA poster in the workplace. In the fourth quarter of FY 1995 OSHA issued two such citations. If an employer does not have the poster required by OSHA hanging in his shop the compliance officer will hand him the poster instead of handing out a fine. If there are no injuries or illnesses to record, OSHA no longer cites an employer for failing to complete recordkeeping. OSHA's compliance officers no longer cite for minor paperwork requirements; they advise and educate the employer instead.
On the other hand OSHA remains committed to strong enforcement measures for those employers who are not making an effort to protect their workers. In workplaces where OSHA still finds willful, serious, and repeat violations employers will continue to be penalized. Chart #5 shows that the number of inspections with initial penalties of $100,000 or more has increased by 79 percent from FY 1994 to FY 1995.
Reinventing Area Offices
In order to change the way OSHA operates it is essential that reform begin with OSHA's front-line workers who deal with the regulated community on a regular basis. OSHA has been in the forefront of the Clinton Administration's reinvention efforts. We began by developing a model office and pilot testing it in seven area offices. OSHA is using a Rollout Team, composed of internal union and management representatives, to bring to each office the improvements that have been piloted. Our goal is to redesign federal enforcement by FY 1997.
OSHA's Field Office Redesign Effort will change every aspect of our offices' operations. The basic philosophy underlying this effort is that OSHA's staff has the responsibility to reduce injuries, illness and deaths rather than simply enforce regulations. We will use Strategic Intervention Teams to identify the leading causes of workplace problems within a given area and then use a variety of techniques--enforcement inspections, investigations, education--to solve the problem. In Atlanta a Strategic Intervention Team formed a partnership with the Horizon Steel Company. In return for technical assistance at one site, Horizon Steel agreed to implement a fall protection program with front-line accountability throughout the company. Horizon Steel saw a reduction of 96 percent in its accident costs per man hour and three lives were saved as a result of using fall protection techniques at three different sites never visited by OSHA.
When OSHA's office in Parsippany, New Jersey, became aware of an increasing number of lead poisoning cases among bridge workers, the office formed a partnership with New Jersey's Department of Health and Transportation. Together they developed strategies for protecting these workers from increased blood lead levels, which are an indication of lead poisoning. OSHA's office used enforcement, implemented a comprehensive medical surveillance program, and developed a lead safety plan for each worksite where lead exposure occurred. OSHA and the New Jersey Health Department sponsored training sessions for employers and employees before they started working on a bridge or renovation project. OSHA described to the contractors the OSHA-funded on-site consultation program available in New Jersey which provides free advice on ways to identify and eliminate workplace hazards. If an employer, having been informed of his responsibilities and the assistance available, chose not to comply, OSHA initiated strong enforcement action.
As a result of this intensive effort, the mean blood level among affected bridge workers dropped 25 percent between 1991 and 1994. The percentage of employees who had blood levels higher than 50 ug/dl dropped from 24 percent in 1991 to 2 percent in 1994. OSHA and the State of New Jersey, working with employers and employees, made major advances in protecting bridge workers from the hazards of lead.
Another result of our efforts to reinvent the way OSHA's Area Offices do business is the reduction in the time it takes to get a hazard abated as a result of a complaint from a worker about safety and health. OSHA's offices in Cleveland and Peoria piloted a project to reduce the time period from when a complaint arrives in the office to when the hazard is corrected. They began responding to complaints over the telephone and by fax. Employers may respond by phone and fax in describing how the workplace danger was eliminated. It used to take almost fifty days for the Cleveland office to achieve hazard abatement. Now the time to abatement is 10 days. Peoria has cut its abatement time from 35 days to 8 (Chart #6). This more efficient approach to handling formal and nonformal complaints will be used by all OSHA Area offices.
OSHA is streamlining other procedures to serve the public better. In the past it sometimes took many weeks or months to receive a response to a request under the Freedom of Information Act (FOIA). Several offices are experimenting with new ways to answer FOIA requests and reduce the time required for a response. The Atlanta Area office has reduced the time for completing a FOIA request from 60 days to 4.5 days--a dramatic increase in service. Other offices are working to achieve the same kind of improvement.
OSHA's field offices are also becoming more efficient by changing procedures, making better use of computers and video cameras and forming partnerships with the private sector.
OSHA's history of setting standards priorities has been haphazard. Priorities constantly shifted, it took many years to issue a regulation, and much of the regulated public was frustrated with both the process and the outcome. A new approach was essential if OSHA was to address the many serious unregulated hazards in the workplace. We have instituted a new five-point regulatory strategy to identify priority issues, focus on key building block rules, eliminate or fix confusing and out-of-date regulations, emphasize plain language and use cooperative partnerships. Under our Priority Planning Process a committee composed of members from OSHA, DOL, NIOSH, EPA, and MSHA actively solicited input from stakeholders and the public beginning in August 1994. More than 100 stakeholders submitted written comments to the committee and nearly 200 representatives of labor, industry, professional and academic organizations, State plans, voluntary standards organizations and the public participated. NIOSH in particular played a key role providing technical assistance throughout the process and in the final selection of the priorities.
The Agency will soon announce the results of the Priority Planning Process, which will identify the most pressing workplace safety and health hazards in need of either regulatory or non-regulatory action. Identifying priorities will ensure that the leading causes of death, injury, and illness in the workplace are addressed first. To arrive at the priorities, the Committee applied a set of decision criteria to a list of 125 hazards nominated by stakeholders and agency staff. A group of approximately 20 issues, which affect millions of workingmen and women, were designated as priorities. Of these, a small number have been chosen for rulemaking and will be added to the regulatory calendar as other standards are completed. OSHA will work with industry, labor, the States and the safety and health community to find non-regulatory ways, such as information, education, and voluntary compliance, to address the remaining hazards. We now have a more rational process for addressing the most pressing safety and health needs of this nation than that used in the past.
In response to a directive from the President to review its rules and identify those in need of revision, OSHA has analyzed 3,200 pages of its Code of Federal Regulations. The Agency plans to "reinvent" 39 percent of these pages and eliminate 32 percent more. For instance, we will consolidate separate training, records maintenance, monitoring and medical surveillance provisions that were written at different times throughout the agency's history. OSHA will remedy the problem caused by regulations that were adopted in 1971 but have become outdated. Most of these regulations were originally written in technical or engineering text that was difficult for the layman to understand. By the end of 1996 OSHA will re-write more than 500 pages in an easier-to-read format.
One of the standards of most concern to employers, particularly those with small businesses, is the Hazard Communication rule. Yet this regulation is vital because workers must be aware of the dangers they face from toxic substances in the workplace. We have requested that the National Advisory Committee on Occupational Safety and Health, which is composed of representatives from industry, labor, the States, and academia, identify ways to improve the standard. Our goal is to focus on the most serious hazards, simplify the Material Safety Data Sheets which have been the source of numerous complaints about complexity, and reduce the amount of paperwork required by the Hazard Communication Standard. The work group will begin its meetings, which are open to the public, on October 19.
OSHA has implemented a number of projects to make information about the agency's regulations more easily available. In 1992 OSHA introduced the OSHA CD-ROM, which provides in one format all of OSHA's regulations and interpretations, its Field Inspection Reference Manual, decisions of the Occupational Safety and Health Review Commission and much more information. This is now the Government Printing Office's best selling CD-ROM. We are encouraging public participation in standards development by routinely disseminating the text of proposed and final standards through the OSHA CD-ROM and the Department of Labor's Electronic Bulletin Board. To provide special assistance for small businesses, OSHA is working with the National Performance Review to provide electronic access to regulatory information and services through the Internet.
Voluntary Protection Programs
One of the accomplishments of which I am most proud since I came to OSHA is the expansion of the Voluntary Protection Programs (VPP) (Chart #7). The prototype for VPP was a project developed by the Bechtel Corporation and the State of California in 1979-80 -- just the kind of innovative state effort that this Subcommittee has expressed interest in. Last month the Vice President characterized the VPP as:
fine examples of what Reinvented Government is all about. It is about working in partnership with common goals instead of as adversaries -- partnership between government and business -- between labor and management.
Companies participating in the VPP must undergo a rigorous, week-long evaluation by OSHA and periodic monitoring. They exceed OSHA's requirements and actively involve their employees in safety and health. In FY 1994 the number of lost workday injuries suffered by employees at the VPP sites was 49 percent lower than the average for their industry.
Currently there are 231 sites participating in the VPP, almost double the number of participating sites when I came to the Agency. Together these sites provide quality safety and health protection to approximately 167,000 workers. Other outreach activities, such as speeches by VPP participants at conferences and training events, have reached 100,000 more employees. Through the Voluntary Protection Programs Participants Association (VPPPA), a private organization, VPP participants actually mentor other companies, reaching another 71,000 workers by providing models and advice on safety and health. Thus, through VPP and the VPPPA 338,000 workers receive improved safety and health protection. This is an extremely effective way of leveraging our resources. The VPP has received the Vice-President's Hammer award, signifying that it is a leading example of government reinvention.
OSHA spends a sizable portion of its budget, almost $45 million in FY 1995, on compliance assistance programs for employers and employees. Some of these programs are especially designed to ensure that small business employers understand our rules and how to comply with them. For instance, OSHA's consultation program, administered by the States, is a free service available to employers to help them identify potential hazards at their worksite, improve their safety management systems, and qualify for one-year exemptions from routine OSHA inspections. The program is targeted toward small businesses in hazardous industries. It is completely separate from the enforcement program and participants cannot be cited during the consultation visit. In the last five years OSHA has helped over 100,000 small and medium-sized businesses identify and correct over 800,000 hazards.
OSHA's Training Institute, which instructs state and federal compliance officers, also provides instruction to the private sector. Sixty courses, dealing with subjects such as confined spaces, machine guarding, construction operations, and industrial hygiene, are open to employers and employees who wish to enroll. Some courses include simulated workplace environments with hands-on instruction in hazard recognition and control. Requests from the private sector for instruction have increased so rapidly that OSHA began offering its curriculum in community colleges and research centers throughout the country. There are now a dozen private educational institutions which conduct safety and health training.
State Plan Innovations
The Subcommittee has expressed interest in the relationship between OSHA and its state plans. The 25 States and territories which operate their own programs are an integral part of our effort to protect the American workforce. Approximately 40 percent of all employers are covered by the States rather than federal OSHA. We do not expect the States to be identical to federal OSHA, but we do expect them to be at least as effective in protecting the workers in their jurisdictions. As a former State plan administrator I know the particular strengths which the States bring to this program, such as knowledge of the industries and workforce in their jurisdictions and flexibility to innovate and do things in a way different from the Federal Government.
We have tried to encourage the states to experiment with new ways to prevent injuries and illnesses. Working closely with the Occupational Safety and Health State Plan Association, OSHA is developing performance agreements that would define goals and performance measures for state activities that differ from federal practices. Instead of monitoring the states by comparing federal and state activities, OSHA will assess results in each state. Since federal OSHA is redesigning its program, we should not stand in the way of States that want to do the same. We should also not expect the states to adopt every innovation developed in Washington. Many states will go beyond our reinvention efforts and others will find alternatives. Our only requirement is that the alternatives be in conformance with the State's basic statutory responsibility.
For instance, we would not allow a State to eliminate enforcement, but we would allow experiments such as that undertaken by the Washington State Department of Labor and Industries. Under an agreement between the Department and crane contractors in the State, a crane safety association will develop standards for the industry using penalties collected from inspections of their members. The association is open to crane companies, labor unions, and manufacturers.
Other examples of innovative efforts by the States include:
--The Virginia OSHA program initiated the "Blue Ridge Safety Network" in 1993. It links businesses in a geographical area to promote workplace safety through shared expertise and resources. There are 182 employers, insurers, health care providers, and educational institutions participating in the Network's Pilot Program. Larger employers share their safety expertise and experience with smaller employers. The Network has four subcommittees geared toward manufacturing, construction, agriculture, and health care.
--Approximately one-half of the States use establishment-
specific workers' compensation data for targeting their inspections to the most dangerous worksites. They provided the model for the Maine 200 program.
--Connecticut, Minnesota, New Mexico, and other States require employers to have safety and health programs. OSHA is now working on ways to encourage more employers to institute programs and is using programs as an incentive in some of the new enforcement policies that I have described. In fact, today a group of OSHA's "stakeholders" is meeting to discuss ways to make employers more aware of the value of safety and health programs.
--Washington State began a special construction program in 1989 in response to an increasing number of fatalities in that industry. The State formed a Construction Advisory Committee of more than two dozen representatives of labor, management and the Washington OSHA program. They produced a plan to focus the State's inspections on the five most hazardous construction operations, as indicated by workers' compensation data. In less than three years the construction industry in Washington experienced a 19 percent decline in compensable claims due to falls from elevation.
Threats to Further Progress
I believe that the changes we are instituting in OSHA will improve the agency's performance and help assure improvements in worker safety and health. All of OSHA's past and future success is threatened, however, by two pieces of legislation currently before the Congress.
The first is the FY 1996 appropriations bill for DOL, HHS, and Education, passed by the House in July. The measure would cut OSHA's budget by 15.5 percent and slash enforcement programs by 33 percent. By slashing OSHA's budget the House would risk higher fatality, injury, and illness rates, imposing millions of dollars of additional costs on employers in the form of higher workers compensation payments, related medical costs, and employee turnover.
In addition, the bill contains language that restricts OSHA from taking action on a standard for ergonomics and seeks to weaken the agency's rule on fall protection in construction.
A 33 percent cut in enforcement would decimate the Agency's enforcement effort. It would result in a 50 percent reduction in inspections and an estimated 50,000 more injuries a year to American workers. OSHA's diminished enforcement effort would consist of responses to accidents, complaints and referrals with virtually no resources available to do proactive inspections of high-hazard firms.
The second bill that would cause irreparable harm is H.R. 1834, which is being considered in the House Committee on Economic and Educational Opportunities. There is a fundamental difference between H.R. 1834 and the President's plans for a "New OSHA." Both approaches acknowledge that OSHA must find a new way of doing business. But the legislation would provide any employer--including those who choose to disregard worker safety--with exemptions and defenses against OSHA enforcement. In contrast, the "New OSHA" treats responsible employers differently from neglectful ones, offering incentives and cooperation to the former and applying traditional enforcement to the latter. The "New OSHA" offers employers a partnership with the agency that demonstrates a commitment to safety and health before being placed on a low priority inspection list. H.R. 1834 would represent a huge step backward from the principle of prevention through enforcement:
--It would prohibit the Agency from issuing first instance sanctions unless workers are killed or seriously injured or an imminent danger is present. Employers would receive only a warning even when they have ignored the most obvious hazards. There would be little incentive for employers to protect their workers before OSHA gets to their workplace. In contrast, The "New OSHA" will continue to issue first instance sanctions where workers' safety and health is threatened but will adjust penalties for those employers demonstrating a sincere effort to improve their workplaces.
--H.R. 1834 would force workers to notify their employers before filing a complaint about unsafe working conditions with OSHA, even when workers face an imminent danger on the job and possible retaliation from their employer. The bill would provide a disincentive for reporting hazards. The "New OSHA" is improving its response time to employee complaints while being more flexible with employers to ensure that hazards are abated.
--The bill would eliminate penalties for violations of the "General Duty Clause," thus removing a tool which OSHA has used for 25 years to require employers to keep workplaces free from hazards even when there is no specific standard. The General Duty Clause is a legal recognition of an employer's obligation to protect his workers from conditions the employer recognizes to be threats to the employees' safety and health. Making this provision unenforceable would effectively repeal it. If H.R. 1834 had been in effect in 1989, OSHA could have issued a penalty of only $10,800 after the explosion and fire which killed 23 workers at the Phillips 66 plant in Pasedena, Texas, that year. Under its "General Duty" authority OSHA proposed a penalty of $5.6 million to an employer that did not live up to its obligation to protect its workers from a serious explosion hazard.
--The bill would prevent OSHA from using its egregious penalty policy when it finds a significant number of serious violations in a single workplace. OSHA's ability to pressure "low road" employers, who shirk on workers' safety to gain competitive advantage, would be severely compromised. If this provision had been in effect in 1987 OSHA would have been allowed to issue a penalty of only $125,000 after the tragic construction collapse at L'Ambiance Plaza. Using the egregious penalty procedure OSHA issued a proposed penalty of $5.1 million. In addition to addressing the specific employer, these penalty levels allow OSHA to focus an entire industry on the safety and health problems of that industry.
--H.R. 1834 would exempt from programmed inspections all businesses of fewer than 50 employees in certain industries regardless of the conditions in the individual workplace. The "New OSHA" is improving its inspection targeting methods to assure that, where data are available, inspectors go to the most dangerous workplaces regardless of the overall industry safety and health record.
These are just a few of the troubling provisions of H.R. 1834.
Mr. Chairman, there is a right way and a wrong way to reform OSHA. Slashing the agency's budget and enacting legislation such as H.R. 1834 is the wrong way. These actions would reduce protections for American workers and result in increased death and injury. Surely this is not what the American public expects from its government. I believe that the "New OSHA" is the proper way and that the agency is making striking progress down this path.
Our experience in redesigning this Agency with the backing of the President
and Vice President has proven to me that federal agencies, which were once
considered impervious to change, can undergo a complete alteration of their
culture. In this case the beneficiaries of change will be the working men
and women of America who will receive increased protection from OSHA as well
as employers who will find that they can work constructively with OSHA.
|Congressional Testimonies - (Archived) Table of Contents|
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