On July 20, 2010, MSDSonline Product Manager Cassandra Minutillo attended the OSHA stakeholder meeting on Illness and Injury Prevention Programs (I2P2) in Washington D.C.
The gathering was the latest in a series of meetings OSHA has conducted to facilitate public discussion before it begins developing a rule that will require employers to reduce workplace injuries and illnesses through a systematic process that proactively addresses workplace safety and health hazards.
Minutillo, who oversees MSDSonline’s Incident Management applications, believes OSHA will move quickly after the last public stakeholder meeting, taking place August 3, 2010 in California, to create a proposed rule - with the intent of moving it through the legislative process a quickly as possible.
Following are a few of the questions OSHA posed to those in attendance at the July 20 meeting, about the scope and application of a new illness and injury prevention program rule as well as Minutillo’s observations from the discussion:
What elements are essential for an effective approach to an injury and illness prevention program? Most of the group agreed that a program should not focus on Injury and Illness rates as they are today. They feel this encourage under reporting. They also felt that the program should look at leading indicators versus lagging indicators. Two key items that they believe the program should focus on is Root Cause Analysis and Near Misses.
Should an OSHA injury and illness prevention program rule apply to every business or should it be limited in some way based on an employer's size, industry, incident rates, and/or hazard indices? There was general agreement that the size of the establishment should not exclude organizations from this standard. But the standard should be flexible enough not to force a burden on the small organization.
To what extent should OSHA rely on existing consensus standards in developing a rule? How can OSHA use state experience with injury and illness prevention in developing a rule? Cal/OSHAs I2P2 program has been discussed as sort of the gold standard. Their program covers all organizations and all workers. They have simple templates employers can use. ANSI/AIHA Z10 was also discussed as an example .
What mechanisms have been found to be effective for enabling employees to participate in safety and health in the workplace? Several people stressed the concept of all workers, including contractors, migrant workers, undocumented workers as well as the telecommuter. One point that I thought was well-made is that employee participation should carry equal weight with management participation.
Additionally, Minutillo reported that many of the employers in attendance believed Job Hazard Analysis was an effective tool for reducing costs by lowering accident rates.
MSDSonline will continue to follow OSHA’s progress in creating a new illness and injury prevention program rule and to bring you the latest news as it becomes available. In the mean time, Minutillo says, “Look to California for an idea of what’s to come, and look to MSDSonline for on-demand incident management solutions will help you stay compliant in this quickly changing environment.”