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November-December 2016

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30 PalletCentral • November-December 2016 palletcentral.com that we will see a shift away from prioritizing enforcement and standards-setting and back toward the alliances, partnerships, and compliance assistance outreach activities that were favored in the George W. Bush administration. There could be some great opportunities for NWPCA if this comes to pass. Additionally, instead of discouraging employers from seeking Voluntary Protection Program (VPP) status (or finding ways to kick existing VPP sites out of the program), OSHA may restore funding to that program and encourage more small and medium- sized employers to get involved. While I do not expect to see the dozen or more National Emphasis Programs (including the one on combustible dust) dissolved immediately, there will no doubt be scrutiny of the longer-running initiatives to see if they have been effective, and these may be replaced with new initiatives aligned with the priorities of the new OSHA leader. Other things that could be affected include the scope of the "severe injury reporting" rule for that required reports to OSHA within 24 hours of in-patient hospitalization, amputation and eye loss. Many have been critical of OSHA's expansive definition of "amputation," which has triggered thousands of reports that OSHA must analyze and often deploy inspectors for investigation. These severe injury reports have consumed massive OSHA enforcement resources and a new administration could find better uses for its inspectorate using its prosecutorial discretion. The SVEP initiative (Severe Violator Enforcement Program), in place since 2010, which focuses on "employer shaming" through OSHA press releases and on follow-up inspections of additional worksites of companies that are categorized as safety scofflaws, could also grind to a halt, or be retooled in a significant way. Finally, any "OSHA Reform" legislation in 2017 will be quite different from the Democrat-sponsored "Protecting America's Workers Act." The PAW Act, technically still pending before SAFETY It is likely that we will see a shift away from prioritizing enforcement and standards-setting and back toward the alliances, par tnerships, and compliance assistance outreach activities that were favored in the George W. Bush administration.

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