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OSHA’s Rulemaking Process: Why Does it Take So Long?

A question I receive frequently is “Why does the OSHA setting of a standard take so long?” The reasons are many. Multiple requirements – statutory, legislative, judicial, and administrative – combine to slow the standards development process.

OSHA Inspections and Document Requests

Over the last several years ORC HSE has received enquiries from member companies in regard to excessive document requests at the beginning of an OSHA inspection. In some cases the requests by the Agency for documents and copies of programs will run two or more pages in length. These requests are provided to the employer during the opening conference. The concerns raised by ORC HSE member companies is that the requests seem open-ended, are very long, and contain requests for information that do not appear to be at all related to the reason and scope of the OSHA inspection as explained by the compliance officer. According to these companies the time involved to produce the items asked for would be excessive, especially for a limited scope inspection.

OSHA’s Treatment of Voluntary Employer Health and Safety Self-Audits

In 1996, ORC HSE (formerly ORC) visited the Occupational Safety and Health Administration (OSHA) on behalf of several member companies to request that the agency limit OSHA compliance safety and health officers’ practice of asking to see employer self-audits during the normal course of their inspections.

OSHA & Repeat Violations

In the March 8th, 2018 edition of the National Law Review, it was reported that on February 14th, 2018 the Second Circuit Court of Appeals issued a summary order upholding the characterization of a citation as “Repeat” even though the prior citations in a contested case were issued over four years prior.