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Establishing an Effective Injury and Illness Program

An Injury and Illness Prevention Program (I2P2) provides systematic policies, procedures and practices that are adequate to recognize and protect workers from occupational safety and health hazards. Employers are encouraged to establish an effective I2P2 since it can significantly reduce occupational safety and health injuries and illnesses and lead to reduced workers’ compensation insurance costs.

Mike Tartal

Mike Tartal

Safety and Health Consultant

What does it mean to have an effective I2P2? At a minimum, four basic elements should be included: Management Commitment and Employee Participation, Safety and Health Training, Workplace Analysis, and Hazard Prevention and Control. Other sub-elements, such as Process Safety Management, can be added to a company’s I2P2 as necessary.

Here is an overview of the four basic elements and a general description of their characteristics to compare with your current company safety program.

1. Management Commitment and Employee Participation

Management commitment provides the motivating force and the resources for planning, organizing and controlling activities within an organization. In an effective I2P2, management regards workers safety and health as a fundamental and necessary ingredient to an organization’s success. Management applies its commitment to safety and health protection with as much vigor as it does to other organizational purposes (e.g. productivity and quality). Worker involvement provides the means through which workers develop or express their own commitment to safety and health protection, for themselves and their follow coworkers. Does your company’s safety plan:

  • State management’s support for effective safety and health practices and programs?
  • List specific safety and health goals, supporting objectives, and an action plan to achieve those goals?
  • Assign safety and health tasks and responsibilities plus clearly communicate those tasks and responsibilities to individuals who have the authority to take action and are accountable for their actions?
  • Provide the resources (money, personnel, and time) necessary to establish and maintain an effective I2P2?
  • Involve senior management in the planning and evaluation of safety and health performance?
  • Schedule an annual management and employee review of the organization’s overall I2P2?
  • Hold managers at all levels accountable to follow all safety and health rules and demonstrate effective safety and health leadership?
  • Involve employees in the organization’s I2P2 planning, decision making, resource allocation, training and evaluation?

2. Workplace Analysis

Workplace analysis examines not only existing hazards but the conditions and operations which might create new hazards. When top managers actively analyze the work and worksite, they can anticipate and prevent hazardous conditions. Through a self-inspection and review process of the procedures, equipment, tools and facilities, management can prevent minor situations from becoming major problems. Here are a few examples of good workplace hazard analysis:

Example One: A baseline hazard analysis / survey is conducted periodically (at least once every five years.)

Example Two: A worksite (job) hazard analysis has been performed and documented to determine what if any personal protective equipment (PPE) is required for employee safety. A certification of the hazard analysis has been completed.

Example Three: Workplace injuries / illnesses, near-miss accidents, and hazard incidence are documented, reviewed, analyzed, and tracked.

Example Four: Applicable OSHA mandated programs (Hazard Communication, Hearing Conservation, Respiratory Protection, etc.) are effectively in place and reviewed at least annually.

3. Hazard Prevention & Control

Hazard prevention and controls are triggered when managers or employees determine that a hazard or potential hazard exists. Where feasible, hazards are prevented by effective design of the job-site or job. Where it is not feasible to eliminate hazards, they are controlled to prevent unsafe and unhealthful exposure. Elimination or control is accomplished in a timely manner, once a hazard or potential hazard is recognized.

Hierarchy of Controls

When addressing hazard prevention and control, employers should use what is referred to as the “hierarchy of controls”. The hierarchy in appropriate order is:

  1. Administrative
  2. Engineering
  3. Personal protective equipment

Administrative controls, including work rules, are intended to eliminate the hazard. Substituting a very hazardous or toxic chemical used in a manufacturing process with a non-hazardous, non-toxic chemical that is equally or nearly equally effective is an example of an administrative control.

Engineering controls are intended to protect employees from a hazard when the hazard cannot be eliminated. The guard on a circular power saw is engineered to prevent an employee from inadvertently being cut by the saw blade when the saw is being used.

Where administrative controls and engineering controls are insufficient, personal protective equipment is used. An employee wearing safety glasses when operating a saw--to prevent saw dust or metal shavings from being thrown into the employee’s eyes—is an example. In all cases, a workplace (job) hazard assessment must be done first to identify the particular hazards present.

Here are some guidelines to put your hazard prevention and control into action:

  • Effective safety and health self inspections are performed regularly. The inspections are conducted by a supervisor or manager and include employees.
  • Hazards, when detected, are documented and tracked until they are effectively corrected.
  • Fair and effective work rules / work practices are established and enforced.
  • Engineering controls (machine guards, barriers, ventilation systems, fire protection systems, etc.) are implemented where ever feasible and established engineering controls are inspected or checked periodically.
  • Effective equipment / facility preventative and corrective maintenance is performed and good housekeeping is practiced.
  • Personal protective equipment (PPE) is provided to employees and effectively used by employees.
  • The organization is prepared for emergency situations and has an effective plan to provide competent emergency medical care when needed.

4. Safety and Health Training:

Your company’s safety and health training should address the safety and health responsibilities of all personnel. You can do this by incorporating safety and health training into other forms of company training (job training and job practices.) The depth and breadth of health and safety training your company needs depends on the nature of existing hazards and the potential for future hazards. Set up a schedule of training topics that will:

  • Ensure that all workers understand the hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards. Employees must accept and follow established safety and health protections.
  • Include health and safety training for supervisors and managers.
  • Provide new employees with basic health and safety training during initial orientation and advanced job specific training when assigned to particular work activities (operating a forklift, wearing a respirator or personal fall arrest system for example).
  • Produce job descriptions and performance reviews that require managers and supervisors to deliver appropriate and effective health and safety training (including hazard recognition).
  • Involve experienced employees in the health and safety training of co-workers.

Lastly, employers who participate in the USF SafetyFlorida consultation program are provided with an assessment of their organization’s existing I2P2. Employers could also use the safety and health management systems e-tool on OSHA’s website to develop and implement an effective I2P2.

To learn more about establishing an effective I2P2 for your business, contact us at www.usfsafetyflorida.com.