KPA Blog

This month OSHA published a whitepaper on Injury and Illness Prevention Programs (I2P2).  Leading up to this publication, there has been a lot of regulatory activity around I2P2. Shortly after proposing a federal standard for I2P2 in 2010, OSHA held a series of stakeholder meetings on the subject.  In this newly released whitepaper, OSHA makes clear that they see overwhelming value in moving forward.  The paper discusses the needs and benefits associated with a well-run program while downplaying the cost to business.

Questions raised by the whitepaper

What will the final regulation look like?  Who will it apply to?  And when will we see the first draft?  There are some preliminary indications in the white paper as to which industries the new regulation will affect, but the timeline for the new guideline is still up in the air. Additionally, there is a precedent for political pressures to get involved with crafting guidelines. In this case, it means that the federal standard will be based on a combination of state programs, the ANSI Z10 standard, and the OHSAS 18001 standard.  References in the whitepaper indicate that the regulation will require employers to abide by plans with some form of “management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.”  The tone of the whitepaper indicates that OSHA sees benefits for all sizes of businesses but may lean towards reduced regulation for business under a certain threshold of employees (less than 10 or 15).

Guidelines for an I2P2 Program

Based on the whitepaper and influencers in the legislative process, programs are likely to be evaluated on the following criteria:

1. Does management participate and encourage involvement in the safety systems and processes in your workplace?  This involvement is the key to letting your employees know that you care and that safety is an important part of everyone’s job.  There’s no better way to build a strong safety culture than to lead by example.
2. Do your workers participate in the safety program?  This includes participation in safety committee meetings, gathering and acting on employee suggestions, or as part of your hazard identification process.  Remember that employees are more likely to know about the hazards they face than management.
3. Do you have a system in place to identify hazards in your workplace?  Once identified, is there a process in place to ensure timely correction?  Identifying and correcting hazards not only eliminates risk of injury, but sends an important message to your employees that you value their safety.
4. Do you proactively evaluate your employees work practices and new processes to prevent and control new hazards?  This is where it’s good to look at industry experts and pool resources among many similar businesses to identify trends and new hazards before they occur.
5. Do you conduct regular health and safety training for your employees?  Training can be specific to a particular task or general in nature – either way taking time out for safety training sends the message that your business values safety over speediness.
6. Finally do you measure the effectiveness of your program and seek ways to improve it?  Can you measure your facility against your peers or departments against each other?  A good software tool will make these metrics easier to manage and simple accident investigations and evaluations will give you insight into where to improve the process.

The Point

If you’re a KPA Environment & Safety Pro client, then you already have the foundations to comply with the pending I2P2 requirements. Our programs include safety committees, incident tracking, and written programs based on industry best practices. Currently, these programs meet proposed I2P2 regulation requirements.  If things change in the legislative process, KPA will modify our programs to ensure compliance with any new regulations.

Additional information on OSHA’s I2P2 initiative and a copy of the whitepaper are available at:  http://www.osha.gov/dsg/topics/safetyhealth/

What do you think? Have you been watching these developments as OSHA crafts new regulations? Are you ready if it goes into place in 2012?