Enforcement of Federal standards through Federal inspectors would result in the most intimate involvement of the Secretary of Labor in all operations affecting interstate commerce….easily result[ing] in blowing up the most minor grievances to very substantial proportions. A minor complaint can very well become a ‘federal case’. Provision of this kind of authority in the Federal government would tempt many an employee representative to boost his stock by calling on the federal government, since the very presence of a federal inspector could be used to demonstrate his importance and influence.
The really important progress in occupational safety and health would require far more consideration of the man rather than the environment.
It has been noted over and over again that in the vast majority of occupational accidents, human failure is wholly or partly responsible....
In many of the major industries the programs in occupational safety and health are successful, are well advanced, and have been developed to the point where the important remaining problem is human failure.
The prevention of job injuries requires an intimate knowledge of conditions and a close working relationship between management, labor and Government. The states, because of their familiarity with local programs, can plan safety programs for local areas more effectively than can be done through a national program administered from Washington D.C.
There is no evidence, in our opinion, which requires or justifies the imposition of a Federal police system for safety upon industry at this time...This program will be economically wasteful. There will be duplicate Federal and insurance programs. The program offered...is essentially a policing program, it is designed to force compliance with federally imposed standards.
[I]n striving to improve safety and healthful conditions in the workplace it is prudent—and it will be productive—to build upon the foundations of successful experiences of American industry working in partnership with State and private agencies. We seriously question whether certain of the measures embodied in the proposed legislation will not encumber rather than enhance progress in occupational safety and health.
We find that 80 to 90 percent of the injuries which are occurring in our company [Du Pont] are due to a human failure rather than a piece of equipment, a machine, or so on.
There is no evidence that [leaded gasoline] has introduced a danger in the field of public health…lead is an inevitable element in the surface of the earth, in its vegetation, in its animal life, and that there is no way in which man has ever been able to escape the absorption of lead while living in this planet.
Many of the temporary standards are unreasonable, arbitrary and technically unfeasible . . . If we can’t meet them when they are published we’ll have to close down.
