Here are some excerpts from Michaels’ 2007 testimony which clearly signal his views on recordkeeping, ergonomics, rulemaking and the General Duty Clause, among other topics: 

• “Preventable work related injuries and illnesses … are unacceptably high. Furthermore, the true incidence of these conditions is far higher than reported by the Bureau of Labor Statistics.”
• OSHA enforcement does not appear to be effective in further reducing injury rates. … Statistical analyses indicate that (any reported) decrease can be attributable to changes in OSHA recordkeeping rules.
• “For most hazardous chemicals, OSHA’s standards are either inadequate or totally absent. One could write a book about the hazards that OSHA has failed to regulate adequately.”
• “The primary blame (for OSHA’s failure to issue appropriate health standards) rests in a system that makes OSHA standard setting inordinately difficult and resource-intensive.”
• “OSHA has abandoned the general duty clause. It is time for the agency to start using it again.”
• “Ergonomic injuries cost employers $15-20 billion annually in workers’ compensation costs alone, yet this number one workplace safety and health problem is not even mentioned on OSHA’s most recent regulatory agenda.”
• “OSHA doesn’t have the staff to work on more than one or two standards at a time, and … each standard takes years to complete. Unless things change radically, only a handful of the thousands of chemicals in daily use in American workplaces will ever be the subject of an OSHA standard.”

Transcript of Michaels’ testimony before Congress in 2007:

http://www.defendingscience.org/newsroom/upload/Michaels_OSHA_Testimony.pdf

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