Developments Archive

I2P2 — OSHA Discusses Proposed Standard With Stakeholders

The Occupational Safety & Health Administration (OSHA) held five meetings this summer to discuss their proposed final rule on mandatory Injury and Illness Prevention Programs.  Dubbed I2P2, these programs are a top priority for OSHA chief Dr. David Michaels.

The agenda for each meeting focused on four topics:

  • The possible regulatory approach for an I2P2 rule;
  • The scope and application of a rule;
  • The organization of a rule; and,
  • The potential economic impact of a rule.

While it’s reasonable to assume that nearly all employers are interested in the welfare of their employees, many stakeholders have deep reservations about how this proposed standard will affect their businesses.   The general consensus for business owners and operators, however, is that if OSHA indeed intends to move forward with a new standard that it should so do while being mindful of industry experience and input.

Concerns among the stakeholders include how I2P2 would relate to already existing standards, how implementation might affect small versus large businesses, how the new rule might be structured, the scope of the rule, how the rule might be organized, cost-benefit for employers, and how much assistance OSHA would provide to aid in the development and implementation of a safety management system.

The I2P2 initiative is a fundamental part of Dr. Michaels’ desire to foster a safety culture in the workplace.  Speaking in June at the American Society of Safety Engineers’ professional development conference, Dr. Michaels reaffirmed OSHA’s commitment to I2P2:

“Our goal must not be to punish or react, but to require employers to plan, prevent and protect. Plan, Prevent and Protect is the new enforcement strategy announced in the Labor Department’s spring regulatory agenda. This strategy is echoed in the proposed OSHA standard that would require employers to implement an Injury and Illness Prevention Program tailored to the actual hazards in their workplaces…under this rule, workers would have a greater voice in the workplace. Workers would participate in developing and implementing the safety and health plan, and have a role in evaluating the plan’s effectiveness in achieving compliance.”

Michaels also continued to emphasize keywords already common to industries in which safety management systems are the norm:

“Having a “safety plan” filed in a drawer or on corporate computers isn’t enough. An effective injury and illness prevention program requires management leadership and worker participation, hazard assessment and abatement, setting goals, and continual improvement.”

SMSLLC will continue to monitor OSHA’s efforts to develop and promulgate the I2P2 standard, as well as advise and assist clients curious to know more about workplace safety expectations.

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NTSB Cites Lack of Safety Culture in Accident Investigation

The National Transportation Safety Board (NTSB) determined that a June 2009 accident involving two trains of the Washington Metropolitan Area Transit Authority (WMATA) was caused in part by the lack of a safety culture.  Nine people were killed in the collision.

While the immediate cause of the accident was a track circuit module failure of the Automatic Train Control system, NTSB Chairman Deborah Hersman noted that, “The layers of safety deficiencies uncovered during the course of this investigation are troubling and reveal a systemic breakdown of safety management at all levels.”

Investigators reached numerous conclusions, including:

  • Before the accident, the position of Chief Safety Officer lacked the necessary resources and authority within the organizational structure of WMATA to adequately identify and address system safety issues, ensure the distribution of safety-critical information throughout the organization, or manage the system safety program plan as required by 49 CFR Part 659;
  • Shortcomings in WMATA’s internal communications, in its recognition of hazards, its assessment of risk from those hazards, and its implementation of corrective actions are all evidence of an ineffective safety culture within the organization;
  • Previous attempts at non-regulatory oversight failed to compel WMATA to maintain the organizational structure necessary to ensure effective identification and communication of safety-critical information throughout its Metrorail operations.

Recommendations included:

  • Elevate the safety oversight role of the WMATA Board of Directors by (1) developing a policy statement to explicitly and publicly assume the responsibility for continual oversight of system safety, (2) implementing processes to exercise oversight of system safety, including appropriate proactive performance metrics, and (3) evaluating actions taken in response to National Transportation Safety Board and Federal Transit Administration recommendations, as well as the status of open corrective action plans and the results of audits conducted by the Tri-State Oversight Committee;
  • Develop and implement a non-punitive safety reporting program to collect reports from employees in all divisions within your organization, and ensure that the safety department; representatives of the operations, maintenance, and engineering departments; and representatives of labor organizations regularly review these reports and share the results of those reviews across all divisions of your organization;
  • Develop a formal process by which the General Manager and managers responsible for WMATA operations, maintenance, and engineering will periodically review, in collaboration with the chief safety officer, all safety audits and open corrective action plans, and modify policy, identify and commit resources, and initiate any other action necessary to ensure that the plans are adequately addressed and closed within the required time frame.

For ship operators and other transportation professionals working within the framework of the ISM Code or similar safety management systems, much of the terminology noted above should be quite familiar.  Safety culture, risk assessment, policy statement, process implementation, corrective action plans, audits, resources and authority–these are all critical to the successful implementation of a safety management system.

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May 2010 – Regulatory Compliance Assessment

May 7, 2010 — SMSLLC recently completed a specialized assessment for Military Sealift Command (MSC) requested to benefit continued and future regulatory compliance arrangements for one of its vessels.

SMSLLC Principal Francis McGinty completed the assignment and believes that the approach may benefit other operators as well. “The assessment model focuses extensively on superstructure and hardware installations to validate conformance to national and international regulations and standards as appropriate. It is not a management system audit, though it could be performed in tandem with such an event.”

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