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If specification codes are enforced, I believe that a craftsman with journeyman experience and at least 2 years of responsibility for the safety of others should be the minimum qualifications. On the other hand, performance codes would almost require that enforcement staff be graduate engineers or at least the equivalent.

Educational field staff who virtually are required to provide an industrial engineering service must therefore be composed completely of graduate engineers. What salary shall this staff receive? Recognizing that graduate engineering students are being recruited on campus for positions starting at $600 to $650 per month, government must therefore compete with private industry. Considering the prevailing rates of pay for a journeyman in private industry, I believe that enforcement staff should be paid at least $500 month. There should be a spread of at least $2,000 between the starting salary and the top of the grade over a period not to exceed 4 years. Whether civil service examinations are used in selection process or whether direct appointments are made by the department head is strictly a matter of State policy. The important factor is to secure competent personnel.

The actual number of persons required at the entrance level positions will of course be predicated upon the workload. However, I feel that as a rule of thumb where there is a separation of functions into enforcement and education, the education function should be staffed by about one-half the number necessary for enforcement.

The location of suboffices and staff throughout a State will depend upon the concentration of industries subject to jurisdiction and to some extent the size of the State. Insofar as span of control, I feel that for every eight persons engaged in field enforcement, there should be a supervisor. This span of control can be much larger in the educational area since the activity is one in which the field staff must and can by virtue of their qualifications exercise more judgment.

In each designated area where field offices are located, there should be a supervisor of field enforcement operations. This supervisor should be selected on the basis of promotion from field personnel. Similarly, the supervisor of educational field staff should likewise be selected from field personnel engaged in educational activities. However, as I have previously indicated, the number of supervisors necessary would be in the ratio of two enforcement supervisors to one educational supervisor.

Many safety divisions include assistant supervisor positions in their organizational structure. This organizational pattern is most effective since it relieves the supervisor of the responsibilities for becoming involved in technical field problems which may, in many instances, be of minor significance and yet be time consuming. An assistant supervisor can be utilized 100 percent of time in field supervision work, and only be at the area suboffice to relieve the supervisor when it becomes necessary for the supervisor to attend meetings, conferences, and other highly important discussions with management groups, labor groups, etc.

If assistant supervisory positions are utilized in the organizational structure, they should be allocated to a starting salary level of $670 per month for the enforcement section and $775 per month for the educational section. It is important in promoting field staff to supervisory positions that consideration be given to making the position sufficiently attractive from a financial standpoint, and there should be no overlap in the salary structure. By this I mean that the starting salary of the supervisory positions should be higher than the top grade of the field staff salary.

If the structure of the organization does not provide for assistant supervisors, some consideration should be given to slightly higher salaries for supervisors than those mentioned for assistant supervisors. The persons who will actually plan and direct the work of the supervisors could probably be best classified under the title of chief inspector. Chief inspectors both in the enforcement and educational activities area should be compensated at the rate of $14,000 per year as a starting salary, with a top of approximately $16,500.

Above the positions of chief inspectors should be the top administrative positions, such as assistant director and director. The salary grade of the director should be about $22,000 per year. The assistant director should be allocated, therefore, somewhere between the top salary of the chief inspectors and that of the director.

I recognize that many smaller States with small safety divisions could not under any circumstances consider these salary grades. However, in many of these States, the functions of the administrative staff-namely the directors, assistant directors, and in some instances the chief inspectors—are carried on by either commissioners or deputy commissioners.

The safety division, in order to function effectively, must have the support of a research and statistics bureau, or the services should be performed by a department bureau. In any event the gathering of statistics as an instrument for planning and control is most important to a safety division. Other areas where staff services are necessary are:

1. Occupational health, including radiological services, etc.
2. Administrative analysis which is a most valuable means of

achieving work simplification through the use of appropriate enforcement and procedures. A busy administrator can

devote little time to this area. 3. Expert engineering services, particularly in the field of elec

tronics and other complex engineering areas, is also a desir

able unit in a safety division. These staff functions must be staffed with professional personnel, whose salaries must be comparable to those paid by private industry. It is important to make a determination concerning what these salary schedules should be, since this will be predicated upon the ability to recruit in these specialized professions.

I know that allocation of salary grades for personnel in all branches of State Government presents many problems. I further recognize that most labor departments with safety divisions cannot arbitrarily determine salaries. Salaries in government are usually determined by boards, commissions, etc.

I would like to mention, however, very briefly the system used by the State of California in its salary administration : salaries of State employees are determined by a wage board whose decision, to the best of my knowledge, is seldom if ever revoked. This board consists basically of several impartial members who make their decisions based upon prevailing rates of pay for similar positions in private industry. I am of the opinion that this system is probably the reason why the State of California has the highest salaried safety personnel in the United States.

In closing, I would like to say that I recognize that other factors enter into the consideration for establishing the organizational structure, administration, staffing, salary schedules, functions, etc., for State safety divisions. However, I have discussed those in which my own years of experience appear to be the most significant in achieving an effective and efficient State safety service. In any case, the rapidly expanding industrial applications of science and technology spurred by pure research are creating larger facilities, larger concentrations of workers, and processes, machinery and devices with hazard potentials of greater scope and severity. The need for such effective State safety service is more important to our people at this time than ever before.

President CATHERWOOD. Thank you, Carl, for the additional coverage on areas of industrial safety. New York has some way to go with some of the levels you mentioned. I thought that it would be nice in New York to have the arrangement that Ray Anderson described in Canada, where the recommendations of the party in power were practically bound to be accepted and enacted by the legislative body. New York has one house of one political persuasion at the present time and the other house of the opposing political persuasion. This creates complications.

Our fourth panelist is F. A. Van Atta of the U.S. Department of Labor. I do not know the particular facet that Ernie has assigned to him. But because of his competence in this field and his widespread work over the years, we are delighted to have him here. It is my privilege to present him to you at this time.

F. A VAN ATTA, Deputy Director, Office of Occupational Safety, Bureau of

Labor Standards, U.S. Department of Labor I was asked to talk about the statutory requirements for setting up a model division of safety in a State labor department. I am not convinced that there is such a thing as a model department of occupational safety; but I will do my best. I do think there are certain fundamentals that you can agree upon, and you can set up some guidelines about what you should do and maybe even something in general about how you should do it. The simplest guideline that I can think of which is generally acceptable is for the States to take reasonable steps to promote the welfare of working people. If that is acceptable, then one primary requirement for their welfare is a reasonable safe, sanitary, and healthful working environment. The corollary of that is that you cannot expect a safe environment to be provided automatically by all employers for either humaritarian or economic reasons. The reason is that employers are human. The same reason why a craftsman or journeyman working in his own way and at his own speed will not provide himself with a safe environment and will not follow safe work practices. It is that simple. He does not believe it will happen to him. If it does, it was just bad luck; and it could not be helped. The thought does not usually occur to his foreman that a proper rail on the scaffold or a belt and tail line on the man would have at least prevented the injury, if they did not prevent the accident.

Starting from that as a basis, there are at least three essential functions of a division of occupational safety and health. First, it must get technical information as to what does, in fact, constitute a safe working environment. Second, it must see that this information gets into appropriate hands. Third, it must assure the use of the available information by everybody involved. I do not know if those are all of the functions but there are three and if they are acceptable as a minimum standard of performance, the necessary statutory authority follows immediately from the functions.

The first bit of statutory authority is that the law should state unequivocally the public policy—it is the responsibility and duty of an employer to provide a safe and healthful work environment for his employees. I do not think anyone is going to seriously question that as public policy, whether he is an employer, employee, or just people.

The problem begins when somebody asks the practical question, How do you define à safe and healthful environment? Many years' experience indicates that the detailed definition of what is a safe and healthful environment varies considerably from person to person. It may depend, among a good many other things, on who is paying the bill for controlling the environment. In view of the peculiarity of people, the law should contain a provision for providing a definition of what is reasonably safe and healthful which would be satisfactory to the people of the State. That means that you must have safety codes of some sort to define the safeguards and procedures which will be accepted as satisfactory. I will not specify how such codes should be formulated. But, as a matter of practical experience, we can observe that no State legislature has ever been willing or able to devote the time and effort necessary to keep an occupational safety code current and valid.

That would suggest that it is better to start with a provision and a procedure for the responsible body to obtain the best available technical advice, and on the basis of that advice, to promulgate regulations having the force of law. That obviously is a power which should be surrounded by safeguards against abuse. It should, at the same time, be recognized as a necessary power, especially necessary to be exercised in the light of expert advice, since the questions to be answered are never such that just anyone can handle them.

As a single and fairly simple example: it is not immediately obvious, at least to me, that a two-hand tripping device on a press may

be a completely satisfactory safety device, or that it may be no protection whatever against injury, or it may be anything in between, depending upon the mechanics of the particular situation. It should also be recognized that there are problems involved which can only be characterized as moral and ethical and involving questions of social policy upon which the technician is not in a position to offer advice. The procedure should certainly make provision for answers to such problems.

As a practical example of that: a proposal for hearing conservation written by a technician expresses its objective as the formulation and application of practical procedures to prevent impairment of hearing in sentence form. The technician can set up a standard to accomplish that end and will probably state it as:

Habitual exposure specified as permissible can be expected to cause permanent threshold shifts larger than 25 decibels average of the

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