OSHA’s Injury and Illness Prevention Program (I2P2) Rising

OSHA Assistant Secretary Dr. David Michaels, was asked at Safety 2012, ASSE’s annual national safety conference, if OSHA would try to pass I2P2 before the November elections. According to Laura Swift, associate editor of Occupational Health and Safety (OH&S), Dr. Michaels said it was a possibility and then added “but I’m not allowed to say that.”

What does it mean? Depends on who you ask. There is a lot of doubt in the safety community that OSHA can get I2P2 done at all, let alone in the next few months. A day after Dr. Michaels made his announcement, C. Gary Lopez, safety consultant with Arthur J. Gallagher and Co. is quoted in an EHS Today article saying that I2P2 is “going nowhere fast.”

For those just joining the I2P2 conversation ( and those who didn’t catch MSDSonline’s presentation on I2P2 at Safety 2012 delivered by Chuck Haling)  I2P2 is OSHA’s initiative to create a standard that would compel employers to find and fix hazards. In January, OSHA issued a white paper that provides background on what an injury and illness prevention standard would look like, along with compelling facts and figures around I2P2 efficacy. According to the paper, OSHA’s approach would include six key components:

  1. Management Leadership
  2. Worker Participation
  3. Hazard identification and Assessment
  4. Hazard Prevention and Control
  5. Education and Training
  6. Program Evaluation and Improvement

In summary, employers would be responsible for ensuring there was top to bottom participation in the prevention of hazards, and a systemic approach to finding and fixing hazards, as well as planned assessment.

While Dr. Michaels has made it clear that I2P2 is a priority for OSHA, there has been considerable push back from various stakeholders. Those opposed to such a standard feel it’s tantamount to double jeopardy since hazard abatement is covered by the OSH General Duty Clause. Dr. Michaels counters that I2P2 is “about a process, not about abating hazards.” In other words, it’s really about can you figure out how to deal with this? How do you categorize your hazards? Did you follow up on injuries to determine what the causes were?

Take Away

Again, the question is: what’s the take away from Dr. Michael’s comments at ASSE? First, it would be safe to say I2P2 remains top of mind at OSHA. However, the level of covertness exhibited by Dr. Michaels and the fact that I2P2 was very much downplayed in OSHA’s 2013 budget request, would suggest that OSHA does not believe it has sufficient support at this time to conduct its activities in a more open and transparent way. If that is indeed the case, then given the current regulatory environment, where regulations of all kinds from agencies like the EPA and OSHA are under attack, it’s unlikely that a standard like I2P2 could get promulgated.

Still, it’s worth paying attention to those things that OSHA is paying attention to. The agency believes find and fix is something everyone should be doing. To that end, if you’re not already operating with the mindset of systemically rooting out hazards and tracking near misses (two important keys to maintaining a hazard free environment) then now is a good time to get started. Furthermore, there are sustainable, cloud-based electronic solutions (like MSDSonline’s Incident Management Account) that can help get you started and make the tracking of risks and reporting of injuries and illnesses easy.

Stay tuned to the Environmental Health and Safety Blog for updated on I2P2 and other compliance issues.

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