No Test Know-How: Deficiencies of the Proposed OSHA Standard on the Accreditation of Training Programs for Hazardous Waste Operations

See Shepherd A. , “Diagnosis of plant failures from a control panel: A comparison of three training methods,” Ergonomics 20 (1977), 347–361; Morris Nancy and Rouse William , “The Effects of Type of Knowledge Upon Human Problem Solving in a Process Control Task,” IEEE Transactions on Systems, Man and Cybernetics 15 (1985), 698–707; Idem., “Review and Evaluation of Empirical Research in Troubleshooting,” Human Factors 25 (1985), 503–530; Rouse William and Morris Nancy , “On Looking into the Black Box: Prospect and Limits in the Search for Mental Models,” Psychological Bulletin 100 (1986), 349–363; and Baldwin Timothy and Ford Kevin J. , “Transfer of Training: A Review and Directions for Future Research,” Personnel Psychology 41 (1988), 63–105.

House Committee on Education and Labor . OSHA Oversight — Worker Protection at Superfund Sites. Hearing before the Subcommittee on Health and Safety. May 22, 1985. 99th Cong., 1st Sess., pp. 6 and 9.

Ibid.

House Report (Energy and Commerce Committee), No. 99-253(I), Aug. 1, 1985, [to accompany H.R. 2817], in U.S. Code/Congressional and Administrative News (1986), 2869. Office of Technology Assessment, Superfund Strategy (Washington, D.C., April, 1985); 237–242.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response . The Hazardous Waste System (1987), Exhibit 3, p. 1–4.

See the Specific Vocational Preparation requirements for the occupations listed in the Department of Labor's Specific Characteristics of Occupations Defined in the Dictionary of Occupational Titles (1981) under systems operations, processing (05.06.04); equipment operation, chemical processing (06.02.11); equipment operation, petroleum processing (06.02.12); and those included under “Sanitary Services” in the Dictionary of Occupational Titles (1977), p. 1327. For this last group of jobs, I looked up the specific vocational preparation requirements in Specific Characteristics.

The most influential statement of the standard industry position is Herbert W. Heinrich, Industrial Accident Prevention, which went through four editions between 1931 and 1959, and was translated into several languages. Heinrich's overt influence among academic industrial hygienists is minimal these days, but only because so many of his ideas have become second nature to the safety profession. For a recent treatment that acknowledges Heinrich's role, see DeReamer Russell , Modern Safety and Health Technology (New York, 1980). For more on Heinrich, see Gibson D. A. , “Herbert W. Heinrich: First safety engineer elected [to] International Insurance Hall of Fame,” Professional Safety 25 (April 1980), 20–24.

For example, in 1975–76 more than three-fourths of personnel executives surveyed by the Bureau of National Affairs reported that they attempted to identify “accident prone” employees, even though as one — but only one! — respondent correctly noted, “There is no such thing as an accident prone employee.” BNA , Safety Policies and the Impact of OSHA. Personnel Policies Forum Survey No. 117. (May 1977), 12–13, Table 9.

This view is widely shared, even among industry safety professionals. See, for example, Barnett Ralph and Brickman Dennis , “Safety Hierarchy,” Journal of Safety Research 17: 2 (1986), 49–55.

For general background, see Hirschhorn Larry , Beyond Mechanization (Cambridge, 1984). For examples of the alternative paradigm within the safety and health literature, see Perrow Charles , Normal Accidents (New York, 1984); and Wright Chris , “Routine Death: Fatal accidents in the oil industry,” Sociological Review 342 (May 1986), 265–289.

The classic studies of Komaci J. , clearly show the importance of changing the way work is organized and controlled in order to reduce the accident rate by any significant degree. Once past a certain threshold, more tinkering with the machinery and more training of the employees simply isn't good enough. See Komaci J. , “A Behavioral Approach to Occupational Safety. Pinpointing and Reinforcing Safe Performance in a Food Manufacturing Plant,” Journal of Applied Psychology 63 (1978), 434–445; idem., “Effect of Training and Feedback: Component analysis of a behavioral training program,” Journal of Applied Psychology 65 (1980), 261–270.

In general, see the legislative history of Public Law 99–519, the Asbestos Hazard Emergency Response Act of 1986, in the Congressional and Administrative News for 1986, 5004–5027, esp. 5005–5006.

Romano Jay , “Schools and Asbestos: Law Posing Problems,” The New York Times, New Jersey Section, (Sunday, June 18, 1989), 1, 8–9.

Miller Jerry W. , Organizational Structure of Nongovernmental Pastsecondary Accreditation: Relationship to Uses of Accreditation (Washington, D.C.: National Commission on Accrediting, 1973).

Ibid., 89, 95.

Carnegie Council on Policy Studies in Higher Education , Fair Practices in Higher Education (San Francisco: Jossey-Bass Publishers, 1979), 63.

Miller , Nongovernmental Postsecondary Accreditation, 122–138.

Ibid., 137.

Ibid., 125.

As the report made clear, the Superfund program had been marred by several major problems, the most important of which was the shortage of experienced, technically competent professionals in both the public and the private sectors. This shortage had two effects. In the private sector, the rapid expansion of the program “resulted in poor technical performance by contractors eager, but not necessarily qualified to enter this market.” And in the public sector, the shortage meant that there were not enough adequately trained people in the relevant agencies to ensure competent oversight and inspection. As a result, even the inadequate contractors were expected “to assure the quality of their own work.” See Superfund Strategy, 56, 235.

The Specific Vocational Preparation required for the jobs most likely to be found on a hazardous waste site is anywhere from six months to two years. An apprenticeable occupation requires a minimum of 2,000 hours of on-the-job training overall, and a minimum of 144 hours of additional, formal education annually. See 29 CFR 29.4 and 29.5.

For a list of apprenticeable occupations as of 1980, see 45 Federal Register 46 (March 11, 1980), 15571–15574. A more current list has not been published to my knowledge.

On apprenticeship generally, see Briggs Vernon and Foltman Felician , eds., Apprenticeship Research: Emerging Findings and Future Trends (Ithaca: New York State School of Industrial and Labor Relations, 1981); Glover Robert , Apprenticeship Lessons from Abroad (Columbus, Ohio: The National Center for Research in Vocational Education, 1986); and U.S. Department of Labor, Bureau of Apprenticeship and Training , Apprenticeship 2000 Issue Paper and Initiative, in 52 Federal Register 231 (December 2, 1987), 45904–45908; and Idem., Apprenticeship 2000: The Public Speaks (August 1988).