Recalcitrant. That is the word the Acting Assistant Secretary of OSHA used in her recent testimony before the Subcommittee on Workforce Protections to describe organizations being targeted by a new OSHA program that is under development.
Recalcitrant can mean obstinately defiant of authority or difficult to manage or operate.
Either way, OSHA is targeting recalcitrant organizations by revising their current Enhanced Enforcement Program (EEP) with a new program called Severe Violators Inspection Program (SVIP) to ensure recalcitrant organizations who are not implementing required safety and health programs are targeted for additional enforcement action. The additional enforcement could include daily penalties, other fines, incarceration of an individual officer who flouts the court’s order, as well as any other sanction that the court deems necessary to secure compliance and implementation of the required programs.
This story provides multiple lessons learned for Managers who need implementation tools to fully implement all types of required programs.
First, Managers within organizations need to implement multiple programs – OSHA, Information Security, Emergency Management, EEO and other Employment, Enterprise Risk, Environmental, Security, Ethics, etc. – and ensure compliance to avoid expensive fines, lawsuits and embarrassing enforcement headlines.
Second, Managers within enforcement organizations need implementation tools too. The Acting Assistant Secretary concluded her testimony by saying:
Madam Chairman, thank you once again for giving me the opportunity to appear today. OSHA will let the Subcommittee know when we have completed the design of the new enforcement program. No matter how well-intentioned or well-designed, if an enforcement policy is not implemented well it is a source of frustration-for workers, for Members of this Subcommittee, and for the American taxpayer. Not only are we committed to designing policies that protect workers, we are also committed to doing our utmost to implement those policies successfully.
Lessons learned regarding the lack of implementation continue to mount across all programs and all industries and all Managers…click here for more information.