رونوشت کامل Episode 197: Demystifying OSHA: A Conversation with David Keeling

I appreciate your approach. think demystify is a great way to way to frame it. And it's unfortunate, right, that that that not everyone gets to interact from ocean. I'll explain why why I believe it interact with OSHA. I'll explain kind of why I believe that. For too many years, OSHA has been a four letter word, right? Walk in the door and and it's because of a bad situation or it's something that we'd all prefer not to have occurred. And I think our opportunity is getting out there in front of that, right? When we get to a site or location after an event, it's already too late. So we need to find a way from a support and a collaboration perspective to get into doors earlier, to get information and get opportunities out there to employers earlier to engage, to really meet businesses, meet employers where they are. And I think, I think we can do a lot better job of that. And, you know, one of the things I'll tell you is I think I've been, people ask me sometimes what have you been surprised about? only four months in, but what have you been surprised so far when it comes to the job? I knew when I was, when I walked into this, this position, I would be walking in working with the best of the best and some really great career people who are really committed to the job and have a passion for the job. I underestimated even that. They really want to make things better. And the last thing you want to you'll hear them say is a lot of times where we in the meeting is, you know, I like this direction. I really don't want to be the policeman on the beat. That's not why I got into the job. Right. I really want to make a difference in people's lives. I really want to make employer safer and I really want to educate employers on how to do that. That's why I got in the job. ⁓ I didn't get in this job as a co-show or as a frontline inspector to in the office four days a week and then go out when a fatality happened. I got in this job to really engage with employers and employees on a daily basis and that's what I want to do to make them better. I knew that was there. I will tell you, I had underestimated that even after 40 years in the organization, how dedicated this group is to that concept. Blaine J. Hoffmann: That's good. That's good to hear. ⁓ What parts of your professional background maybe shaped or helped you with how you approach workplace safety or your outlook on the profession? Sort of like what you just said, they were shaped, I'm sure, along the way to get to this point as well. What about you? D. Keeling: Good night. at UPS for a of years. The health and safety, when there was some opportunity, would do some back and forth. There was a lot to do with those at the time. I was, to be frank with you, for the first couple of years, was a safety guard. That's what I did. I did inspections, did reviews, and we did it. We put policies in place, and that's all we did. And I didn't do a couple of other things that I think make us better in the long run, which I didn't do a very good job of convincing other people in the organization through building a business case that was the right thing to do for the business. So I would say traditionally we do. We do a really good job at teaching safety professionals what the rules are. But we don't do very good job. Unfortunately, sometimes I've explained to them how and how to tell the why there's a why for everything right? ⁓ The good example is ⁓ you may have seen there's a there's a new safety poster that went out recently. Promotia mandatory posting and it's a little different than what it's been in past and in the past it's been referred to its law. Well, of course it's the law, right? I don't think I'm telling you when anything they don't know it's a law, right? ⁓ But that's just, that's, if you approach it from that perspective, that's just as bad as you're allowed to be, right? If you approach it from that, that's a low bar to hit, to just be compliant with the law. And really the approach we want to take is a little different here. We want to tell people why, we want to explain to people why. The fact that you can build a business case and show that employees being safe, underscores the bottom line for the organization. It can be a competitive advantage. It can be something that an organization can take and raise up and hold up as a differentiator between them and competitors. And it's the right thing to do ⁓ from a personal perspective with our employees as well. So we want to approach it from really, we don't want to be a singular organization. We're certainly an enforcement agency. We'll remain an enforcement agency. But if all we do is enforce We're missing a tremendous opportunity. Blaine J. Hoffmann: Yeah. It reminds me of the old, I'm going to say the old days, the three pronged approach, right? That it was enforcement, it was outreach and education. And those other two prongs are important. I love that too. I definitely subscribe to that notion. My frustration within my profession has always been, it had been something similar, which is D. Keeling: I'm going to do it again. Blaine J. Hoffmann: You know, we can't just say, hey, here's a rule, here's a policy. You have to follow it, you know, no matter what. And this is all we're going to do when as a safety professional inside an organization, you know, one, we can meet a minimum standard many different ways. It's a lot of times they're performance driven or, you know, we get to determine how we're going to achieve that compliance, right? What means and methods. And so I think as a safety professional, we have an opportunity to do just what you said, make that business case, connect safety to how it supports the goal the business has at the end of the day. The business exists for a reason. I mean, we're not, we're not packaging safety and shipping it to a customer, right? It exists and we should celebrate that. That's okay that a business exists to produce something. Safety is a tool that

we can use to make sure it's done. efficiently, effectively, ⁓ with cost in mind, ⁓ productively repeated in a repeatable process. And it has this added benefit that some of the other areas of the business, like maybe quality doesn't have. it is now it's an employee benefit. It can be seen as an employee benefit. ⁓ just like our, ⁓ you know, health insurance benefits. You come here. D. Keeling: Mm-hmm. Blaine J. Hoffmann: We strive to take care of you so that you can keep coming here and doing this. And so I think you're right. We really can do. I know you were speaking on in terms of the administration, but I'm speaking in terms of our safety profession at large. We could all do a lot better with that. that I agree with you a hundred percent on that one. ⁓ What about ⁓ any leadership lessons that you learned along the way? I get asked us a lot from safety professionals about D. Keeling: Excellent. Yeah. Blaine J. Hoffmann: Hey, you know what helped shape you or usually they ask, you know, why I started a podcast ⁓ because it's kind of crazy, but it's usually something around ⁓ a moment in their career and maybe not a catastrophe, but just like a mentor they had or something that kind of kind of flipped that switch ⁓ for you. Was there any kind of leadership lesson you learned along the way that still influences you today? D. Keeling: Yeah, I was lucky and early in my career I had a few great mentors mentioned a couple names, you know, but Alexi Carly I worked for at UPS for a number of years learned a lot from Alexi. A few of the things is you don't necessarily have to be the smartest person in the room. In fact, if you are right, the old adage is if you're smart person in the room, find a new room. Luckily here at OSHA, that's not a problem for me, right? Rarely the smartest person in the room, which is fine, right? And that makes us better. Blaine J. Hoffmann: Yeah, you're in the wrong room. D. Keeling: So I think don't be afraid to ask more questions. A good leader asks more questions than they give answers a lot of times. ⁓ I think the other thing is the further we get away from the job, and I was talking to one of the things that I've done is make sure that I've connected early on with some of the co-shows in front of some of inspectors that are out, boots on ground to see how things are going and where we can improve, right? And where we have pinch points. Again, I hear them over and over again. I've got to find a way to get out and engage with employers and employees more. That's one of the things, but I think what it underscores is the further we get away from the job as it's being done, the less we know. Even if we used to do the job years ago, it's changed. were jobs rarely in the way you do a job. The process rarely stays stagnant. So engaging with frontline workers and don't assume you know right. Ask questions. And engage frontline workers. And then again, I think from a leadership perspective, understanding the business that you're

in, understanding what the goals of the business are. ⁓ Nails on a chalkboard to me is when we start talking about, and I used to do it, right? I'll throw myself under the bus. We just talk about a standalone safety culture. I'm not a believer in that. And I know I've followed your podcast. So I know I've had these conversations before on your podcast. Blaine J. Hoffmann: Yes. D. Keeling: So I'm a big believer that you can ingrain safety into the organizational culture, but in the the organizational culture is going to win, right? So you have to find your way to win within that culture. And every organization has their own. So I think that's for me, that's the thing, is how do I engage with the business in a way that the business understands? How do I engage the frontline workers in a way that is beneficial for them? ⁓ And don't be afraid to ask questions. I think that's... Blaine J. Hoffmann: Yes. D. Keeling: That's the biggest thing. And don't believe you have all the answers because we never did. Blaine J. Hoffmann: Yeah, absolutely. Well, no need to ask a question if you already think you have the answer, right? Awesome. So speaking of, you know, continuing down this path of, you know, the perspective of the administration, let's talk a little more technical then. And the one question I had written down here that I really want to get, and this was a question, by the way, I threw a... D. Keeling: Right, exactly, exactly. Blaine J. Hoffmann: call out to some of my colleagues and said, hey, if you could ask one thing, what would you ask? And I've got, ⁓ got, have you seen the aliens where the aliens are? But we won't, that's, I said, no, that's a different government official. We're not going to ask him that. So that was one question. No. So the, ⁓ what trends are you, and this is a great one. What trends are you watching most closely right now? Is it, is whether it's hazards, industries? ⁓ D. Keeling: The answer is no, but okay. Thank you. Blaine J. Hoffmann: workforce changes and technology and how we need to adapt. But what trends are you focusing on or seeing right now that need to be focused on? D. Keeling: Yeah, I think there's a number of things that we need to look at. ⁓ I think from an industry perspective, I think from a safety perspective, we're going, you're seeing that turned to serious injury and fatality, ⁓ the CIF conversation. You know, I think that's an opportunity for OSHA. We've looked at it again a little differently in the past when it comes to how we look at compliance, right? And again, missed opportunities, if that's the extent of what we engage in, is simply ⁓ Blaine J. Hoffmann: stiff. D. Keeling: rule breaking, right, or citations, right? I desperately care about the number of ⁓ inspections that we do because that's interactions with employers and employees. I'll be less concentrated on the number of citations and fines we give, right? That's not to say we're not gonna handle that employers or problem employers, we're

gonna do that and we're an enforcement agency. At the same time though, I think we have a responsibility to the country. and to the president and Secretary DeRemer to do the best we can in engaging employers and meeting them where they are. So not every employer, especially when you talk about another trend, can talk about side sifts is what's drive, where's that driven in, right? I think small and medium sized businesses, if you look at the numbers, right, I'm not telling you anything you don't know, and your audience doesn't know. But if you look at the numbers, an outsized, there's been an outside growth in small and medium sized business, serious injuries, and injuries in general. So we need to be more conscious of the fact that we have to meet businesses where they are in their journey. That's one thing that we're looking at doing. know, you know, we may have opportunity later on to talk about modernization of VPP or some of the things that we're doing right now is really intended to get further into small medium sized businesses, maybe those organizations who don't have the resources, quite frankly, to go a VPP route. I know you've been deeply involved in VPP in the past. It's a great program. But how can we make that more accessible for employers where it's appropriate and where it's not appropriate? What other avenues can we give employers and employees to engage? So that's one thing, a small and medium size of businesses. we need to it, know, along with, it's right in line with the president's ⁓ take from an economic perspective, right? With... ⁓ with how we want to do that and grow the economy. But it's the right thing to do ⁓ from an employee perspective as well because that's where the events are occurring. Blaine J. Hoffmann: Yeah, I mean, and I think a lot of us, you know, we get into hedgehog mode. We don't even see outside our four walls. ⁓ and, and I tell the story all the time. ⁓ my wife and I owned a couple of franchise frozen yogurt shops years ago, many years ago. And we always talked in terms of four walls, four blocks, four miles, you know, let's see how one you got to control. the business side, the back of house, the front of house, the experience of customer house when they come in, do you have inventory under control? Is it clean? Do you have a maintenance schedule? You your four walls, four blocks. Where are we located? What are our neighbors like? ⁓ Do we connect with them and make sure that we are aligned with what our neighbors are doing? And then four miles, how are we reaching into the communities and how do we impact the community at large? I think as safety professionals, I've always carried that lesson with me. Maybe it's not literally four miles or four blocks, but it's sort of this, ⁓ this, hot, you know, warm, cold zone type of approach. ⁓ we don't think that big in, in, as a safety professional, when we're talking about GDP and how as a country, we're competitive in the business landscape and D. Keeling: it. Blaine J. Hoffmann: safety in our small part, you know, that our small part, but is a big, can be a big lever to pull to be competitive and to increase jobs. Absolutely. I'm glad you brought that up. D. Keeling: Huge, huge. It's a competitive advantage if done correctly. Absolutely. Now, one of the other trends that I know you'd asked about trends, one of the other trends is AI. I'll tell you my, you know, kind of my spill on that real quick, right, is I'm not afraid of AI. I love the fact that we've got new tools coming into ⁓ the industry. ⁓ It helps make us better, right? It helps make us smarter and helps cut down time that we need to get to an answer. And if we use it correctly, you know, I used the analogy the other day with a group I was talking with it, you know, not quite as many people, we still make candles, but not quite as many people make candles for light, right? To light up a room. Not as many people who shoe horses as used to shoe horses. And we need to think about that that time frame, in that framework that we, you know, we have a tool here and we need to get ahead of it and we need to be out ahead of it. So I think it's a great opportunity for us to make our inspectors better, to make our inspections better. And it's a tremendous opportunity for us to leave something with employers when we go. One of the things I used to do and I think You know, it was kind of underscored with me. You mentioned some of my, some of the folks I had learned from over the years was always find the opportunity to get better. Even if you're doing well, find an opportunity to get better. Always be constructively dissatisfied. I use that term. And, and one of the things I used to, used to ask safety managers or supervisors that worked, worked with me or worked for me is, you know, we'd had, we didn't very well have OSHA come in the door, the EPA come in the door, FAA come in the door, the DOT, whoever it might be. for an inspection and or maybe don't been a local agency, but come in and left and how did you know? What did we learn was always my question and invariably what we heard back was no citations. No fines were doing great. That's really not what we asked, right? What we ask is what did we learn? What can we do better? So I think one of the things that we're going to look at doing from an OSHA perspective is leaving something with every interaction. And it's something really, I will tell you again, that I will tell these career folks, especially those in the regions and the area offices, and those on the front line, really embrace this early on. And they do it already, right? You've been involved with OSHA before and you know they come in and say, you know, it's not a legal ⁓ issue here, but here's some opportunities or here's some things that we might be able to do better to reduce the risk associated with this job. We've seen OSHA do that over the years. We want to formalize that a little more and leave something with businesses so that

they can improve, even if they're doing well. What's our opportunity for improvement? So I think AI can play a big part of that, ⁓ can help us determine beyond what our legal obligations are, what's a good risk analysis or risk assessment? And here it is, and here's how we can get better. Blaine J. Hoffmann: Yeah, I do. agree. The medium and small size businesses, I think the expertise and the technical expertise is where they lack with these tools can help, I mean, democratize or increase access, I should say, to some of that, those expert tools and how to do those things. What, what we need to fix is usually not the problem. How, how do we do it is, is usually where we kind of get stuck because there could be a number of different ways to do that. ⁓ D. Keeling: See you. Blaine J. Hoffmann: So, so I was going to ask you, and you kind of led right into it, some of the biggest challenges facing not just businesses, but what about OSHA? How do you see the administration tackling things like whether it's AI or emerging ⁓ industries we didn't have before? I remember we didn't have program software programmers. I'm old enough to remember we didn't have the internet. So those are new jobs. Those are whole new industries that. we didn't regulate before. D. Keeling: Right, yeah, one of the things that that again, some things you track when you're going to a new position, some things you maybe don't track as closely. OSHA had been under hiring freeze for about three years and one of the things I didn't track right as well as I probably should have is the effect that that had had. Obviously we had some with some cuts in addition to that, but the vast majority of boots on ground was actually lost in previous years and we lost a skill with that, but. Rather than look, and I think our region and area directors are doing a really nice job of this, looking at this, and we've talked lot about it, as an opportunity now to bring staff in that have that skill set, right? So we've actually, shameless plug here, we put out a job call, we've opened up about 108 positions, great response so far. ⁓ far more applicants than we have spots for, unfortunately, but ⁓ just in the first day or two. But we're looking for that skill set, right? It's maybe a little different than the traditional skill set. the ability to do risk assessments, not just understand what the legal obligations are, but how do you do a risk assessment? How do you leave something with an organization? Where are you with your understanding of AI and technology from that perspective? We're looking at industrial hygiene skill set. We're looking at safety engineer skill set. So we're looking at a little different than maybe we have in the past. ⁓ That's one challenge, but I think it's also an opportunity. I think whatever challenge comes, comes an opportunity. That's one of the things. ⁓ And I think the other and we've already touched on a little bit, but the other opportunity is to I don't I don't know that

I would sit here and say is somebody who's been in the industry for 40 years that OSHA has always been on the leading edge of safety. That's a shame, right? We ought to be providing leadership from from from an administration perspective, and I think the administration is doing that now. But from an OSHA perspective as part of the administration, we need to be doing that. ⁓ We've kind of been trailing a lot of times. So I think when we talk about things like ⁓ SIF and how we incorporate that in, proactive risk assessments using AI and using technology more effectively. ⁓ One of the things we're doing, I know you're longtime members of quite a few organizations out there, but VPPA, National Safety Council, ASSP, AAHA, I could go on and on with different groups that we're engaging with ⁓ that we want to be part, we want to be at the table with those groups. We want to be in the front of the conversation with them. We want to be a leader in the space, not a trailer. And we don't just want to be an enforcement arm. We don't want to be just in the enforcement business. We don't want to be in the abatement business. How do we get better? Blaine J. Hoffmann: Good. That's great. You mentioned VPP a couple of times. I just might probably, I mean, it's near and dear to me. Uh, I've worked so much with that program and with employers. Um, yeah, it's even, um, about, it was a handful, just shy of a dozen companies that initially said they had no intention of applying for VPP star status, but they wanted to use the VPP. D. Keeling: Thank you for that. Blaine J. Hoffmann: the CSP for ⁓ a benchmark. Like this is what some of the best performing when it comes to safety companies are doing. We want to sort of use that as a benchmark. And lo and behold, they ended up going, Hey, wait, we can do this. We can, we can apply. they've got their flag now. And I think it's a great program and it's probably in, I'm not just saying that. I've got episodes going back years where I talk about the whole series of ⁓ episodes on each of the four elements of EPP. I had to been five, six years ago. Look, that's probably one of the best things I think OSHA adopted and it came from industry. I believe electrical power generation company, maybe a utilities company out of California. But yeah, that's a great example of how OSHA is sort of saying, hey, this is something that the industry is doing that makes sense. How can we be a part of that? And so I would love to see more of the administration doing that partnering with, we're on it together. yeah. ⁓ D. Keeling: Mm-hmm. Right, absolutely. We're we're we didn't remember that we are. We might we might want to get we might find different roads to get there sometimes, but we all want to get to the same location right to the same destination. So yeah, one of the things that we're doing with VPP and I would agree with you. It's a phenomenal program. We do want to expand that both access to VPP, but also maybe companies we talked about earlier and you may find a company who says look, I want to aspire to that, but I'm just not there yet. I'm not there in resources. I'm not there in in time. You may have seen we rolled out recently safety champions. ⁓ That is intended. That's actually targeted for companies that either are not there. Maybe they do have the size, but they're not quite there yet in their journey. But small medium sized companies who quite frankly don't have the resources right? ⁓ And we're adding quite a few. I'll call them safety mentors, especially government employees, but we We've added. ⁓ I think we trained at the last batch was over 300 safety mentors, right? And that's just recently in the last couple of weeks. Blaine J. Hoffmann: ⁓ and these are SGEs then. Okay. D. Keeling: Their SGEs, they perform the same way that you did when you were in helping with the EPP, right? I'm gonna refer to them as safety mentors just because SGEs has a lot of different terminology in the government, right? So I'm gonna use the safety mentor word on that or reference on that. But we wanna use those folks, right? And we're looking right now at ways that we can incent people to join that safety mentor program as mentors. Blaine J. Hoffmann: Night. Right. Yeah. D. Keeling: And we want it. want that we've had great. We had our first. yesterday on Tuesday we had our first ⁓ phone call with people that were interested first WebEx with people that were interested in safety champions. We've got another one. Another shameless plug tomorrow afternoon at 2 o'clock Eastern Time safety champions. So yeah, we want to encourage people to people to engage in that. It is not everybody's not in the same place and we need to recognize it. Not everybody is in the same place. and a way to help them get to where they need to be. Blaine J. Hoffmann: That's great. I love it. ⁓ Yeah. And I had a whole section here on, on VPP, but I think that, I think that covered that whole section. just got there naturally. I see. This is why, ⁓ and you know, Dave, I don't use scripts. I don't have a, but for the, for this, I wanted to make sure I got the questions from some of my colleagues down and everything, but just having a conversation, just some that you give, you'll get there naturally. So, ⁓ which is great. So I did have a question that was, ⁓ D. Keeling: I can't stay on it when I do use them, so. Blaine J. Hoffmann: on here and it was right after a VPP question, but what does good faith look like from OSHA's perspective in 2026 and beyond? Good faith, I think that comes up a lot. Yeah. D. Keeling: Yeah, that's a great question. That's a great question and I'm answering that not as an attorney because I'm not an attorney. I'm going to answer it as a safety professional. ⁓ Good faith. ⁓ I truly believe and we can argue about the percentages whether it's and people will have different depending on what industry they're in and their experience in the background. They're going have different thoughts on this.

You can say it's a 90 10. You could say it's a 95 5. I will say it's even less than that. It's probably along the line of a 98 to, right? People that want to do the right thing for the right reason, simply don't know how or haven't had the opportunity, right? And we need to get engaged with those employers to get them where they need to be. Now, again, I will tell you that for those 2%, 5%, we can argue about the percentages, right? As safety professionals, but. ⁓ For those who simply won't do the right thing or have no intention to do the right thing, where we're finding incidents of willful or potentially criminal neglect, we're going to deal with that. And we're going to deal with that as we should, harshly. So no change on that, ⁓ no change in that approach. And I think you'll find, again, not an attorney, but think you'll find us in lockstep with the Solicitor's Office at the Labor Department and... and how we're going to approach those things. having said that, I'm a very bad golfer. I will tell you I'm a terrible golfer, right? It's one of the reasons I came back to work. My wife said you need to go back to work because I've seen your scores and you just need to go back to work. if you play, for those of you who play golf or have played golf, you got a lot of clubs in the bag, right? For me, compliance is like a sand wedge. We found ourselves in some place we don't want to be. We got to the ball out of there. And it may take one or two for me, it may take two or three whacks to get it out of the sand, right? But that's why the club's in the bag. But there are a lot of other clubs in the bag, right? And we at OSHA haven't necessarily been taking advantage of all the clubs in the bag in the past. So bad faith for me is people stuck in that sand wedge and we're to get them out one way the other, right? But it's a smaller percentage of the employers and we need to deal with... Unfortunately, it's that old 80-20 concept, right? Where you're to put a lot more of resources if you're part of the ⁓ employment group. So that's kind of where I'm at with that term. Blaine J. Hoffmann: Yeah, you're right. I think the other clubs, if we ⁓ use them right, should keep us out of the sand. ⁓ Yeah, let's not do that at all. Yeah, if we can. I am like you. I don't even bother with a bunch of clubs. I have like three that I'll take. I'm that bad. So it's terrible. ⁓ Mostly it's the time, I think. It's a great analogy. ⁓ D. Keeling: I don't want to hit the ball in the sand. No one does, right? So yeah, let's stay out of the sand. Blaine J. Hoffmann: So I like it. So what about, let's say we talked about VPP, but it could be, it could be any program. doesn't even have to be a program. It's just an organization that wants to get better. And maybe we, we call back to the safety champions program, something like that. But your advice to an organization that wants to strengthen their safety management system, they, they want to get better. whatever that means. Is that the direction the Safety Champions Program would go in into is to say, we can partner you up with a mentor site. They've been there, done that, they're succeeding, they can share some of that. D. Keeling: It is. I think for those folks, and I understand, and understand, I sat on the other side of the table for a few years for motion. So I understand that thought process that, you know, I'm a little, I'm a little tentative or a little bit afraid of engaging with OSHA. The trust factor just isn't quite there yet. Right. So, you know, this gives those groups an opportunity to engage and we're, you know, we're facilitating it, but we're not directly necessarily engaged. Now we do have on-site consultations. We want to change the perception of some of those as well. ⁓ We do have it walled off. I know people don't believe that between enforcement and I think you're going to see some more engagement from us on how we wall that off so that people are more comfortable and engaged on-site. yeah, safety champions and VPP is a great process, right? To follow. that you're not quite comfortable yet or you're a little embarrassed by where you stand because maybe a small medium-sized employer, I don't have a safety program right now. ⁓ Maybe I have a few best practices, but I don't have anything for them. And this is a way to build that out, right? We know there's a lot of companies in that situation out there. This is a great way to build that out in a way that's cost effective and you're taking advantage of best practices from around the industry. Blaine J. Hoffmann: Yeah, I call it safety R and D rip off and duplicate. Like there's no, it's no big secret. Yeah. It's a, it's not a big secret. We're all, ⁓ we're, we're, it's not like we have some sort of corner on approaching a hazard in a particular way. ⁓ if it works, then, ⁓ why not try it? And, ⁓ all right. So D. Keeling: There we go. Steel shamelessly. And I would say you know we talk about safety mentors again great relationship with one of my counterparts when I was in transportation Scott Mugno who was at FedEx for a number of years and I will tell you we talked on a regular basis about issues and problems we were having now this is FedEx and UPS at the time right and but we shared we shared same shamelessly best practices and I think it made us both better. Blaine J. Hoffmann: Yeah. I mean, we've got, we've got folks on the road. Man, there's a whole, you know, I've got it on my list of things to do, which is reach out to the department of transportation. mean, that is a huge, I mean, you think about like, we look at a company that makes and produces things inside, again, four walls. That stuff's coming, materials coming into the company product and materials are going out of the company. it's moving across the country. somehow. Those are all workers as well. we, it's weird we forget about that. D. Keeling: Right, yeah, I want to a number out at you. So we all know the BLS numbers came out

recently. And the number of fatalities that reported, you may remember, were about, I think it was 5,070 fatalities ⁓ in the BLS. Now, if I back up for a second, and we did this, went back in and looked at these numbers the next day. And if you look at the number of fatalities that were directly associated with compliance activities that OSHA would oversee, we were under 800. Blaine J. Hoffmann: What? Yeah. D. Keeling: So when you start looking at things like businesses that are under 20, right? Maybe don't have that OSHA interaction. When you start looking at things like transportation, certainly the DOT's oversight, right? From a transportation perspective. But the number one driver right now from a workplace loss perspective, from a Vitality perspective, is transportation. So I'm not comfortable. I can't live or play in a space where OSHA is going to go after 800 fatalities and not 5,070. Blaine J. Hoffmann: Yeah. Right. D. Keeling: Even though our regulatory oversight, right, understanding our regulatory oversight extends to those small, that smaller batch, a smaller number, our opportunity, right, the people we have to affect is over 5,000. And I think that's a different way of, we're trying to look at that a little differently. And that's really driving some of our conversations with getting ahead of prevention, safety prevention, ⁓ how we're engaging with employers, maybe non-traditionally. ⁓ We can't do it with just enforcement and traditional enforcement methods. Blaine J. Hoffmann: And is to that end, is there, I don't want to say a plan, but is it a strategic approach to also partner with these other agencies that sort of these, you're all on the same road, just different lanes to invoke a DOT reference. But for example, Department of Transportation, you have Mining, have MSHA, there is a lot of overlap. You'll have OSHA. in a building, in a facility looking at something and they're also in the transportation business. And so that company has to be both. Yeah. D. Keeling: can tell you we have we have weekly engagement with the mining team, weekly engaged with the mining team and we are having I don't I can't speak to what it's looked like historically as much but but I will tell you we're going to have regular interactions with the DOT and EPA some of those other groups. Yes, the answer the short answer that is absolutely we need to take advantage of each other's and we need to support one another and I think that's something that is something that Secretary to remember. ⁓ And the president, right, really pushed this administration to do. But we're in the same room on Mondays, every Monday, and there's conversations going on constantly. So yeah, we need to take advantage of each other, maybe more aggressively than we have in the past, and each other's strengths. Blaine J. Hoffmann: Yeah, definitely. agree. All right. So look, I want to thank you for the time we've spent today. I know you're super busy and, ⁓ it's not easy to sit down and do some of this stuff sometimes, but I, I definitely wanted to, ⁓ from, from very selfishly, by the way, from my profession, I want to try to break down that, that the myth of, you know, the mystique of OSHA or the fear of talking with OSHA or dealing with OSHA. ⁓ I've D. Keeling: Somebody asked me. Yeah, somebody asked me today what his success looks like at the end of the day and I'll I'll I'll I know I know the participants here may be muted by hear the laughter right down down Pennsylvania Ave. ⁓ If we get we could if we if we could walk up to the door. And they open the door and say OSHA finally it's about time you got here. Right, if we can ever get to that point, if we could. I know know I'm living in Shangri-La right there, right? But. We really want to move that direction. Blaine J. Hoffmann: I-I-I would-I Yeah, so what- Yeah. Yeah. D. Keeling: We want to be part of the solution. Blaine J. Hoffmann: Yeah, my first interaction with OSHA was official interaction with OSHA was after a fatality. And Scott, I won't name his full name, but he helped that organization through that process was, to say he was professional is almost an insult. He was a human being. He helped he he recognized what had happened to that company and the impact that it had emotionally on that company and I talked to him for and stayed connected with him for years I Went and did some speaking stuff invited him to speak at the company's safety conference that they had three years later He came and spoke like that That's what, that was my experience has always been with, with OSHA. It's never been adversarial. So I appreciate you helping me sort of demystify OSHA a little bit here. ⁓ and last question, ⁓ I wanted to ask you, what do you hope that that's my hope. What do you hope safety professionals take away from today's conversation? D. Keeling: and, and, all, and all candid, candid seriousness, we're here to help. We want to be part of the solution. We don't want to be part of the problem. ⁓ we don't ever want to be seen as the, part of the problem. So we want to engage early. We want to engage often. ⁓ we want to be seen as a partner in a process and we're here to help. And I mean that and as much sincerity as I can muster. ⁓ we want to hear success stories. We want to hear. And I think what you just said a minute ago is a great example. It's a great example of a success story that we can tell to convince other businesses, other organizations that we do want to change the narrative and we want to be, we want to be part of the solution. We want to be in the abatement and improvement business. Blaine J. Hoffmann: That's great. I love it. All right. Thanks again, David Keeling, Assistant Secretary of Labor for Occupational Safety and Health. I really appreciate your time and we should do this again soon. Anytime. It's an open invite. D. Keeling: She'll kill me later, but I'm gonna offer up Amanda Layhow is the next is your next your next person. So now go. I will leave the office before she finds me. Yeah. Blaine J. Hoffmann: ⁓ hey, I'll do it. ⁓ All right. Sounds good. Thank you so much. D. Keeling: Thanks.