Posts Tagged ‘I2P2’

Are we required to fill-out the OSHA 300 Logs?

Friday, January 18th, 2013

Under the OSHA Injury and Illness Recordkeeping and Reporting Requirements, most employers are required to record work-related injuries and illnesses using the OSHA 300 Logs.  However, many businesses, including car dealerships, are currently exempt from most of the requirements, dependent on store’s primary Standard Industrial Classification (SIC) code.

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I2P2 status update

Wednesday, January 9th, 2013

For those of you wondering what is going on with OSHA’s I2P2 regulation: it’s still in the pre-rule stage. There are 3 stages to regulatory promulgation: Pre-Rule, Proposed Rule, and Final Rule. The rule is scheduled to have a “Small Business Regulatory Enforcement Fairness Act” study completed this month and a Notice of Proposed Rulemaking issued by December of 2013. That’s when we would likely switch to the Proposed Rule stage. With that schedule we might see a final regulation sometime in 2014, but more likely in 2015. A copy of the current information is shown below.

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Two of the nation’s largest safety associations are pushing OSHA to make the injury/illness prevention program (I2P2) rule a top priority in 2013

Friday, December 14th, 2012

I2P2 OSHAI2P2 was presented a few years as a top priority for OSHA and then we didn’t hear much about it for a while. Earlier this week we read an update again in this article that two of the nation’s largest worker safety associations — the American Society of Safety Engineers and the American Industrial Hygiene Assoc. — are pushing the Occupational Safety and Health Administration (OSHA) to make the injury/illness prevention program (I2P2) rule a top priority in 2013.

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OSHA Reminds Employers to Post Injury/Illness Summaries

Tuesday, April 17th, 2012

Employers who are required to keep the OSHA Form 300 Injury and Illness log must post OSHA’s Form 300A from Feb. 1 to April 30, 2012 in a common area wherever notices to workers are usually posted. The summary must list the total numbers of job-related injuries and illnesses that occurred in 2011. All establishment summaries must be certified by a company executive.

Copies of the OSHA Forms 300, 300A and 301 are available for download on the OSHA Recordkeeping Web page. See OSHA’s Recordkeeping Handbook for more information on posting requirements for OSHA’s Form 300A.

A Few Things You Should Know About OSHA’s Pending I2P2 Requirements

Friday, January 20th, 2012

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?

How Do You Know if Your Safety Program Is Working?

Friday, October 7th, 2011

How do you measure success? You look for things that you can track and measure. These key indicators are pretty standard, and should be documented and communicated as part of your safety program:

•Workplace inspections (KPA audits and your myKPAonline.com account are excellent resources)
•Exposure assessments
•Injury, illness, and incident tracking
•Employee input
•OSHA assessment

A note about injury rates: They’re a little misleading because they are lagging indicators- they do a great job at showing performance under past circumstances and are not reliable for predicting future performance (but you still have to track injury rates for reporting to regulatory agencies- so don’t ignore them).

 

Get a clear picture of where your program is headed: Culture predicts outcomes.

•Track work practices and sustained behaviors that increase or reduce hazards
•The level that culture supports safety objectives and activities
For example, how fast are issues addressed in your myKPAonline account?
•Workers’ interest in safety activities and behaviors
•The value placed on workplace safety by senior leadership compared to other objectives

I2P2 Part 2: Getting Started and Seven Parts of the Plan

Friday, September 30th, 2011

In the first post, we discussed what an effective I2P2 plan (Illness and Injury Prevention Planning, or sometimes IIPP) does, and the business case for implementing the I2P2 plan. This post gets a little more into how to set up the planning process for success. Begin at the top of your organization, with a committee of strategic leadership members.

In this planning phase, you’ll need to:

•Document the implementation process from the beginning; I2P2 is a company policy and needs to be documented as such.
–Demonstrate commitment to protection and continual improvement of employee health and safety
–Demonstrate that employees will be encouraged to effectively participate
–It helps to use existing workplace health and safety requirements as a framework ( such as 300 logs).
–Make sure it is in compliance with applicable laws and regulations.

Seven Parts

There are seven parts to a successful implementation of an I2P2 plan. It works based on “Plan-Do-Check-act” planning proceedure.

Using these seven steps, your business systemically eliminates underlying root causes of deficiencies, and moves toward long-term solution rather than one-time fix.

Example: inspection finds unguarded machine. Machine gets fixed and also process in place to discover underlying reason why machine is broken. Process might lead to replacing guards with more effective design, or replace the machines themselves so hazard is eliminated.

This illustration shows how the seven parts work together.

 

 

Injury and Illness Prevention Plan (I2P2) Part 1: Getting Started

Friday, September 23rd, 2011

What Does I2P2 Do?

Most fatalities and life altering events that happen at workplaces don’t result from unknown or unpredictable circumstances, or from weird occurrences. The vast majority of these incidents continue to include the basics:

  • Mobile equipment mishaps (distracted driving)
  • falls
  • contact with objects/ equipment

Most of these accidents are preventable, and that’s where your Injury and Illness Prevention Plan (abbreviated as IIPP or I2P2) fixes the problem.

 

 

 

 

 

The business case for an I2P2 plan:

1.Saves Money
  • Less worker time off work
  • Fewer injury claims
  • Less paperwork
  • Avoid liability in some situations
  • Cost shift from short term “putting out fires” safety strategy to long-term preventive planning.
2.Streamlines Processes
  • Shown to improve organizational productivity and financial performance
  • Improves employee job performance
Remember, Every system is perfectly designed to get the results it gets, so you want to get a system in place that starts eliminating injuries and illnesses from your workplace. That’s where an I2P2 plan comes into play. In the next two parts of this article, I’ll go over the parts of an I2P2 plan and how to get the ball rolling to put one in place at your dealership.

 

How to Implement a Successful I2P2 Program

Tuesday, May 24th, 2011

Like most Auto Dealers, you probably want to know how OSHA’s I2P2 (Injury and Illness Protection Program) will impact your business. Last week, EHSToday published an article “AIHce 2011: The Ins and Outs of I2P2 and Worker Involvement” about a roundtable discussion with William Perry, CIH, deputy director of OSHA’s Directorate of Standards and Guidance, and Bill Kojola, who works in the safety and health department at AFL-CIO.

My take-aways from this article came from the comments from Kojola. He said that for an injury and illness prevention program to be successful, it must accomplish the following goals:

  • It must encourage reporting – not just injuries, but ideas to control hazards.
  • It must shift from lagging to leading indicators.
  • It must get at root causes.
  • It must make use of documentation.
  • It must remove barriers to worker participation.

It’s no coincidence that our online safety system myKPAonline can be the make-it-or-break-it answer to implementing such a program. myKPAonline was partially driven by California’s IIPP program which can be considered as a precursor to I2P2. The picture shows a screenshot of myKPAonline for a dealership and provides reporting, documentation, root causes, and actionable information to implement a safety program.

Implementing I2P2 with myKPAonline

Implementing I2P2 with myKPAonline

OSHA video about the principles and benefits of the I2P2 program

Monday, January 10th, 2011

OSHA published a series of DOL Regulations Videos on their website. In one of these videos, Jim Thornton of Northrup-Grumman Discusses OSHA’s Injury and Illness Prevention Program (I2P2), explaining the principles and benefits of the I2P2 program. In summary, any effective I2P2 program embodies three principles:

1.    Management commitment. Senior management must buy in to the concept of employee safety.

2.    Employee engagement. An effective program must include employee engagement in order to obtain and sustain results.

3.    Hazard recognition program. Embodying the recognition of hazards, evaluation of hazards and control of those hazards

An effective i2p2 program benefits companies in the bottom line and in employee morale.

1.    Direct bottom line. Because injury and illness reductions that have been sustained have reduced direct cost in the form of workers comp tremendously because people have work more safely. They are more productive and their quality of work has increased

2.    Employee morale. Employees who are engaged are safer employees and their morale has increased which makes for a better work environment.