Grain Trade Opposes OSHA Proposal

October 13, 1999

The National Grain and Feed Association opposes a proposal from the Occupational Safety and Health Administration that would expand a provision that now allows employees' involvement in evaluating workplace hazards.

Existing OSHA regulations allow employees, their representatives and members of join work place safety and health committees to accompany an OSHA consultant and the employer's representative during on-site consultation visits. The NGFA supports that approach.

However, OSHA wants to expand that provision to expressly authorize employee representatives to accompany the consultant during the physical inspection of the workplace, with or without the employer's permission.

"Since it is employers who voluntarily ask for the (OSHA) consultation service, they should retain the right to determine if employee participation would contribute positively to the intent and purpose of the consultation," NGFA said in its comments to OSHA. The agency's proposal is part of its consultation agreement program.

The NGFA also opposes changing OSHA's existing regulations that limit the participation in opening and closing conferences with the OSHA consultant to the employer unless the employer determines that employee participation would contribute constructively to the conference.

OSHA has proposed to allow employee representatives to participate in the opening and closing conferences with the consultant, either separately or jointly.

Another existing regulation NGFA supports requires employer permission before an OSHA consultant can contact employees as part of an on-site consultation. OSHA had proposed allowing the consultant to speak with a "reasonable number" of employees about safety and health issues at the work site.