Update on I2P2, OSHA’s Injury & Illness Prevention Program

OSHA had a busy summer talking about its Injury and Illness Prevention Program with stakeholders around the country. During June, July and August, OSHA held meetings in NJ, TX, CA and Washington DC to solicit feedback that could be used to develop an I2P2 rule.

I2P2 is high on the agency’s priority list because it believes such a program could help prevent the dozen fatalities that occur each day and the over 3 million serious work related illnesses and injuries that occur annually.

The conversations at each meeting were centered on four key areas:

  1. Possible regulatory approach for an Injury and Illness Prevention Program rule
  2. The scope and application of a rule
  3. The organization of a rule
  4. The potential economic impact of a rule

Reading the minutes, there appeared to be a spirited discussion at each meeting with opinions ranging from those fully supportive of an OSHA standard to others that implore the agency to abandon its course and instead rely on regulations already in the books.

Other disagreements included whether a new law should cover all businesses or exempt smaller employers, the efficacy of mandating management/employee committees, the value and best implementation of a recordkeeping component, and finally what the economic impact of a rule would be.

There are already several states with injury and illness prevention programs, most notably California and considerable comparisons were made to the Cal/OSHA regulation which was implemented in 1991. You can see a guide to Cal/OSHA by following this link: http://www.dir.ca.gov/dosh/dosh_publications/iipp.html

What’s Next for I2P2?

According to the I2P2 FAQ Web page, the next step for OSHA on I2P2 is to “gather comments from small businesses during the small business review process…followed by the publication of a proposal, a notice and comment period and extensive public hearings.”

For those wondering how soon I2P2 could become law, at the last meeting in California, OSHA said that “while an Injury and Illness Prevention Program was a very high priority, the soonest the rule could be produced would be 18 months based upon the regulatory process.” If OSHA sticks to that timeline, the earliest a final rule would be published is mid to late 2013.

This means there is plenty of time for businesses and organizations to weigh in on the conversation with OSHA. To that end, OSHA realizes its stakeholder meetings are not the ideal forums for getting the diversity of input it seeks and encourages folks to “submit comments and resources along the way to assist OSHA in developing the best and most effective rule possible.”

No Time Like the Present

Even thought OSHA is still in the middle of its program, there is nothing stopping an interested organization from implementing an injury and illness prevention program of its own. In fact there are several systems in existence that provide substantial guidance on creating a safer, more proactive work environment, e.g. VPP, OHSAS 18001, and ANSI.