Issue link: http://palletcentral.uberflip.com/i/819351
30 PalletCentral • March-April 2017 palletcentral.com funding, there will be fewer human resources to carry out inspections. This means that most enforcement actions for the foreseeable future will arise from either: • fatality incidents (which must be reported within 8 hours), • severe injury reports (in-patient hospitalizations, amputations, and eye losses, which must be reported to OSHA within 24 hours of occurrence), • professional referrals (such as where another government agency, such as a federal or state EPA office notifies OSHA that it observed something in violation), or • employee hazard complaints or whistleblower discrimination complaints. Basically, at least in the short term, if you run a safe operation without reportable injuries or illnesses, and you treat your employees fairly and investigate and respond to any safety concerns raised internally, you should be pretty safe from OSHA visits. The "programmed" inspections, relating to the old site- specific targeting data and OSHA's dozen National Emphasis Programs (NEP), may still be options but they will be rarely used, and the NEP list will likely be pared back once a new OSHA assistant secretary is appointed by the President and confirmed by the Senate. The new OSHA chief will also put his or her mark on other initiatives, such as whether proactive partnerships and alliances between business and the agency will be encouraged, and whether the Voluntary Protection Program (VPP) will once again flourish, after being discouraged during the last administration. Interestingly, there is bipartisan legislation (HR 1444) now pending before Congress that would codify the VPP, protecting it from resource starvation or elimination in future years. So the value of the VPP may be something that everyone recognizes. Whether this will be enacted as a stand-alone bill or rolled into a broader "OSHA Reform" measure remains to be seen. PC SAFETY Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also provides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. Adele can be reached at 301-595-3520 or www.safety-law.com.