OSHA: incorporating processes to increase efficiency, avoid duplication and enhance public participation in the regulatory process
For nearly a decade and a half, the Occupational Safety and Health Administration (OSHA) has been utilizing the Standards Improvement Process (SIP) as a means to revise, update and remove occupational health and safety standards that are outdated, obsolete, or unnecessarily burden employers. This process is one of the most effective tools in OSHA’s arsenal for reviewing and improving regulations. OSHA believes that improving these standards helps employers to better understand their obligations, ensure employee safety and health, and improve compliance while also reducing compliance costs.
Potential candidates for the Standards Improvement Project are identified through the Agency’s internal review of its standards by national office and field staff, suggestions and comments from the public and recommendations from the Office of Management and Budget. After standards are flagged by these interested parties, OSHA analyzes the information and develops its notice of proposed rulemaking to provide notification to the public at large regarding the key standards identified.
To date, the Agency has successfully completed three Standards Improve Projects rulemakings, all of which have been estimated to have significant annual savings and burden hour reductions. The first Standards Improvement Project (SIP-I) (RIN #1218–AB53) was published on July 22, 1996. SIP-I focused on miscellaneous changes to the general industry and construction standards, including the removal of obsolete medical tests and elimination of unnecessary cross-references. SIP-I was estimated to annually save $9.6 million in compliance costs and reduce the regulatory burden by 6600 hours. The second Standards Improvement Project II (SIP-II) (RIN #1218–AB81) was published on January 5, 2005, and revised health standards in order to reduce regulatory burden and facilitate compliance by eliminating unnecessary paperwork and revising employee notification requirements. SIP-II was estimated to annually save $6.8 million in compliance costs and reduce the regulatory burden by 210,000 hours. OSHA finalized its third installment of the Standards Improvement Project (SIP-III) (RIN #1218-AC19) in June 2011. SIP-III was the most ambitious and effective Standards Improvement Project to date, and is estimated to provide an annual cost savings exceeding $43 million and a reduction of over 1.8 million burden hours.
The standards improvement project has been a successful and popular mechanism for reviewing, updating and revising regulations. OSHA is continuing this initiative in Phase 4 of the SIP project, which will focus on identifying obsolete and unnecessary construction requirements.