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.