Abstract
On 1 August 2018, on his Confined Space blog, Jordan Barab wrote that the U.S. Occupational Safety and Health Administration (OSHA) had proposed to rescind parts of the Electronic Recordkeeping regulation issued under the Obama administration in 2016. Those changes were established to provide OSHA and occupational health and safety researchers, advocates, and activists with improved access to data regarding how and why workers are harmed on the job, critical information for designing effective workplace injury and illness prevention programs. 1 The Trump administration has proposed to eliminate the requirement for employers to electronically submit to OSHA injury and illness records already collected in their facilities. OSHA claims that the information that employers are required to collect, keep, and report about the details of workplace injury/illness events, if maintained electronically by OSHA, would potentially place employee privacy at risk.
In its notice of proposed rulemaking, OSHA states that the proposal to rescind the extended provisions of the recordkeeping rule “. . . is expected to be an Executive Order 13771 deregulatory action . . . .” 2 That order requires that for every regulation issued, at least two prior regulations be considered for elimination. Further, “. . . the total incremental cost of all new regulations, including repealed regulations, to be finalized this year shall be no greater than zero . . . ” (with some exceptions). 3
Barab provides detailed explanation of the measures taken by OSHA in 2016 including its assurances to prevent public access to private employee information (see his website at http://jordanbarab.com/confinedspace/2018/08/01/oshas-rollback-real-story/).
Similarly, as we noted in the last issue of New Solutions, the U.S. Environmental Protection Agency (EPA) under the Trump administration has proposed to strengthen transparency in regulatory science by prohibiting review of research studies whose data are not publicly available in order to protect the privacy of research subjects. In fact, the EPA asserts the effectiveness of the same privacy protection measures that OSHA claims would be ineffective in protecting worker privacy.
Measures to eliminate the provision of information about occupational and environmental public health hazards, however, are not unique to the Trump administration or the United States. In New Solutions, Volume 28, Issue 1, Jhang presented analysis showing that during a period of economic crisis in the Republic of Korea, “. . . information regulation that provided a legal basis for government’s monitoring and inspection of occupational health and safety activities . . . ” was a major focus of deregulatory efforts. Further, he warns that “since changes in regulations without direct deregulatory impacts are not easily identifiable by workers, careful monitoring of deregulation is necessary to prevent policy impacts harmful to workers’ health and safety.” 4
The global effort to reduce production costs includes deregulation of public health and environmental protection. Of course, these measures take unique shape in each country and region. New Solutions welcomes more papers from across the globe that document successful efforts to advance the protection of occupational and environmental health and the ecosystems upon which our survival clearly depends. It is also important for the journal to continue to publish research like Jhang’s that show how efforts to strip human rights and protections take shape in different countries.
This issue of New Solutions includes the first part of a special issue that draws from a large-scale study of the human health and ecological impact of the Deep Water Horizon oil spill, an effort that included innovative community-based participatory research and citizen science approaches. The research project took the name, GC-HARMS (Gulf Coast Health Alliance: Health Risks Related to the Macondo Spill). We are especially grateful to John Sullivan, a longtime friend of New Solutions, for approaching us with the idea for the special issue, and for his dedicated efforts to organize this special issue and conduct six interviews with key community partners in the research project. The second part of this special issue will be presented in New Solutions, Volume 28, Issue 4.