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Injury Illness Prevention Program

The Occupational Safety and Health Administration (OSHA) is currently reviewing options for enacting a standard that would mandate safety and health management systems for employers. This potential rule is called the Injury Illness Prevention Program (I2P2) and, as can be expected, is no easy nut to crack.

Pat Stark

Pat Stark, CHST, PCG

Safety & Health Consultant

In 1989 OSHA issued the Safety and Health Program Management Guidelines (54 FR 3908), which consisted of four major elements of an effective program: Management Commitment and Employee Involvement; Worksite Analysis; Hazard Prevention and Control; and Safety and Health Training.

When OSHA began stakeholder meetings fifteen years ago to discuss ideas for a Safety and Health Program rule, it interacted with hundreds of stakeholders from organizations, companies, small business owners, etc. These meetings led to the formation of the Small Business Regulatory Enforcement Fairness Act (SBREFA), and this proposed Safety and Health Program rule was never published. For more details, see http://63.234.227.130/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21464.

Ten years later, the American Industrial Hygiene Association published a voluntary consensus standard in conjunction with the American National Standards Institute (ANSI), named the ANSI/AIHA Z10-2005 “Occupational Safety and Health Management Systems.” This standard covers the Plan-Do-Check-Act principle, which emphasizes businesses’ continually improving and systematically eliminating the underlying root cause(s) of hazards. About this same time frame, the British Standards Institute, in joint efforts with private industries, consulting organizations and international government agencies, developed the Occupational Health and Safety Assessment Series (OHSAS) 18001-2007 “Occupational Health and Safety Management Systems.”

On August 3, 2010, OSHA held the last of its summer series of five stakeholder meetings on I2P2. On the agenda at these meetings have been topics such as possible regulatory approaches of a rule, covered employers, covered industries, relation to existing OSHA standards and the potential economic impact of a rule.

The six "core elements" of I2P2 include:

1. Management duties, which includes items such as policy, setting goals, planning and allocating resources, and assigning and communicating roles and responsibility.

2. Employee participation, such as involving employees in establishing, maintaining and evaluating the program, employee access to safety and health information, and employee role in incident investigations.

3. Hazard identification and assessment, including what hazards must be identified, information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards, hazard assessment and prioritization, and hazard identification tools.

4. Hazard prevention and control, such as such as what hazards must be controlled, hazard control priorities, and the effectiveness of the controls.

5. Education and training, which includes areas such as content of training, relationship to other OSHA training requirements, and periodic training.

6. Program evaluation and improvement, which includes monitoring performance, correcting program deficiencies, and improving program performance.

Comments from the August 3, 2010 I2P2 stakeholder meeting in Sacramento varied. There was general consensus that California has been a pioneer since California already has such a safety program rule in place. Other comments during this stakeholder meeting on various elements of I2P2 included:

  • “Stakeholders were concerned that, especially in the case of small employers, workplace plans can wind up sitting unused on a shelf following initial development.”
  • “Almost all of the stakeholders argued in favor of a rule that is simple and easy to understand. Many commented that if the rule is not kept as simple as possible, it will be overwhelming for small employers and they will ignore it entirely.”
  • “Stakeholders were nearly unanimous in their feeling that all employers, with no exceptions, should be covered. Opinions on how uniform the coverage should be, however, did vary. Some stakeholders believed that while all employers need a plan, small employers in low-risk environments should not be required to take much more action after establishing a plan. Another stakeholder emphasized that just because OSHA might rarely inspect small employers for compliance, it did not mean that they should be excluded from the rule.”

It will be interesting to see if I2P2 moves further along and formulates into an OSHA rule. One might wonder where occupational safety and health in the U.S. would be in 2010 if in 1970—when OSHA was established—if such a rule such as I2P2 had been part of the OSHA standards.

References: FR 75:35360-35362
I2P2 Stakeholder Meeting, Sacramento CA, August 3, 2010-Summary Report

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