Policy Development: A Key Factor in Promoting PTD

In August 2011, NIOSH hosted “Prevention Through Design: A New Way of Doing Business,” a conference attended by 175 stakeholders that focused on applying prevention through design (PTD) principles within multiple industry sectors. Conference tracks focused on education, research, practice and policy. All presentations are available on ASSE’s website (www.asse.org/professionalaffairs_new/ptd.php). Although no presentations specifically addressed policy, this article provides an opportunity to identify policies that relate to PTD and influence its advancement and diffusion throughout multiple industries. The term policy is vague and has many meanings. A common thread across definitions is that policies dictate a proposed course of action and are typically set by organizations or institutions, rather than by individuals. Safety professionals can help their organizations establish and enforce safety-related policies, many of which may be borrowed from or reference policies established by national trade associations or consensus standards on this topic. Policies and standards together effect change in safety culture. This article summarizes PTD-related policies associated with federal agencies and national organizations. Many SH&E professionals and researchers regard this concept as a highly promising means for reducing occupational hazards by engineering out hazards faced by users, manufacturers, constructors and maintenance workers. SH&E professionals and design engineers have different roles in PTD. Typically, safety professionals develop, enforce and monitor safety-related policies, while design engineers address technical details of project design and execution, and comply with project specifications, building codes and regulations. Therefore, the owner may influence adoption of PTD policies by including an SH&E professional on project design teams, beginning with the kickoff team that meets at the conceptual design stage. PTD policy influences the development of consensus standards when such standards are adopted by many different organizations. This assumption is explicitly recognized in “Prevention Through Design: Plan for the National Initiative” (NIOSH, 2010a), which identifies goals relating to research, practice, education and policy. As reported in that document: 4) Policy: Business leaders, labor, academics, government entities, and standard-developing and -setting organizations endorse a culture that includes PTD principles in all designs affecting workers. Policy focuses on creating demand for safe designs for workers and incorporating these safety and health considerations into guidance, regulations, recommendations, operating procedures and standards. Most urgent to PTD implementation is the development of a broad, overarching policy that will guide the effort to establish processes and programs for enterprises of all sizes, across all industrial sectors. Outcome-based guidance for the implementation of industry- or activity-specific standards also is needed. As a fundamental element of developing such a policy, relevant recommendations from various authoritative and advisory organizations should reflect PTD principles. The ultimate goal is to include these principles in all design standards that affect workers. As NIOSH (2010a) notes, no singular policy related to PTD has yet been developed. Rather, various organizations and institutions across multiple industries have taken explicit or implicit positions with respect to designers’ role in occupational safety and health. These positions and related policies are reviewed, and recommendations for policy development are provided.