If you managed to take a look at our list of our Top 5 most popular blog posts from 2011, you might have noticed that I2P2 is kind of a big deal. If, on the other hand, that acronym means nothing to you, now is a good time to get better acquainted with OSHA’s propose Injury and Illness Prevention Program (get it? Two Is, two Ps…)

Anyway, OSHA has kicked off the New Year by reaffirming its commitment to I2P2 by releasing a white paper geared to convince businesses of the value of the program. For background, OSHA has been moving towards a requirement that would require most organizations in the U.S. to implement an injury and illness prevention program, which is essentially a safety management system (SMS) designed to proactively reduce injuries and illnesses.

In addition to outlining how I2P2 programs mitigate injuries and save lives, the paper breaks down the ROI of an SMS and the impact of lost time, compensation and other factors resulting from poor health and safety performance impact a business’ bottom line. It also addresses a particularly controversial concern surrounding I2P2 requirements – the financial impact of the program on small businesses.

As the paper notes, “The key elements common to all of these programs are management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.”

Check out the full text of the paper here, or head over to ISHN for a great summary of the document.

Between sweeping new regulations, ambitious new OHS programs, and environmental controversy in the U.S. and Canada, EHS issues were top of mind throughout 2011. To wrap up a year that had no shortage of headlines, we’ve analyzed last year’s Intelex blog stats to determine the most popular posts of 2011. Without further adieu, here are the Top 5:

1. I2P2, hazardous chemicals, high-risk construction among top OSHA priorities for 2011: OSHA Secretary of Labour Dr. David Michaels kicked off the year with an online chat outlining some of OSHA’s top priorities for 2011. While many of his priorities – including the ambitious I2P2 program and the addition of an MSD column to OSHA Form 300 reports – did not make it through the gates by the end of the year, this overview provided some guidance on where OSHA’s priorities lie in the very near future.
2. Start preparing for new OSHA fall protection requirements now: Fall safety, which for many years has landed in the top spot of OSHA’s list of most frequently cited violations, was a chief concern for residential builders across the U.S. as OSHA implemented new fall protection requirements.
3. The Top 5 upcoming OHS regulatory events you need to know about: Placing third on our Top 5 is, well, another Top 5! We combed through a variety of upcoming OHS legislation, regulations and literature to identify the five key OHS regulatory events that will have the most impact on businesses from coast to coast. Topping the list was OSHA’s monumental Injury and Illness Prevention Program (I2P2), which will have an equally monumental impact on U.S. businesses. It hasn’t been implemented yet, but could see the light of day in the very near future.
4. No more 'catch me if you can' – I2P2 and what it could mean for you: Well, if there is a emerging theme to this list, it might have something to do with I2P2. For most organizations, it is a distant thunder, buried in clouds gathering on the horizon. But for the proactive business, it ought to be so much more given its scope is absolutely vast and will essentially redefine how all companies manage safety.
5. Sustainability as a business opportunity: And finally, it wasn’t all about safety in 2011. As organizations continue to seek value in sustainability initiatives and as environmental advocates try to achieve buy-in from senior management on green programs in the face of a turbulent climate, we flipped the argument on its head. Instead of viewing sustainability programs as a financial burden, it should be thought of as an investment that carries great returns.

We are always on the hunt for fresh content ideas that are important to our readers. Write me or use the comments section below to share your ideas. Happy New Year!

It can be hard for businesses to determine which regulatory events will directly affect how they do business. That's why I’ve put together a list of the Top 5 OHS regulatory events on the immediate horizon business leaders as well as OHS managers and staff need to know about.

Yesterday we talked about the revised hazard communication standard. Here's the next issue in the Top 5:

1. The Injury and Illness Prevention Program:

OSHA chair Dr. David Michaels indicated in an online chat earlier this year that OSHA’s top priority for 2011 is publishing and enforcing a new, nationwide Injury and Illness Prevention Program (I2P2).

The scope of the planned regulation is sweeping: it will likely affect every employer in every industry, coast-to-coast. Michaels himself has called it the most significant change in workplace safety culture since OSHA’s inception 40 years ago.

OSHA is expected to model the program on California’s own successful, 20-year-old IIPP program.

So, the question is, when will it take effect? Well, the short answer is, we don’t know. Since OSHA has yet to even specify a date for a proposed rulemaking, it could be a ways off.

That said, OSHA has stated it wants to publish the rule by the year’s end. While few details are known on how the standard will take shape, one hint was provided in an OSHA web chat on Monday: OSHA has taken the fact many businesses across all industries have already implemented safety management systems (e.g. guided by frameworks like OHSAS 18001) into consideration and suggested I2P2 could be aligned with existing SMS conventions.

Thanks for reading. Feel free to write me or comment if you have any questions. Next week we'll be looking at what changes related to the Food Safety Modernization Act will mean to you.

Yesterday we talked about changes to injury and illness recordkeeping rules.

Here's the next issue in our Top 5:

2. Revised hazard communication standard:

OSHA will be reworking its hazard communication standard (HCS) to reflect the internationally used Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

This will significantly affect how businesses label hazardous products and maintain material safety data sheets (MSDS, soon to drop the “M” and become simply “SDS” to conform to the global standard). As in the pictured image, GHS will require all labels to have the red border, for example, around warning signals. Review this past Monday's web chat with OSHA for more info on this change.

Since almost all businesses are required to keep accurate MSDS, the impact of this change will be significant and far-reaching.

It is unclear exactly when the administration will issue a final rule on the issue, but OSHA indicated in a web chat on Monday that it intended to publish a final rule in September.

It can be hard for businesses to determine which regulatory events will directly affect how they do business. That's why I’ve put together a list of the Top 5 OHS regulatory events on the immediate horizon business leaders as well as OHS managers and staff need to know about.

Yesterday we talked about a proposed rule to add MSD to OSHA injury reporting forms. Here's the next issue in our Top 5:

3. Changes to injury and illness recordkeeping rules:

Businesses across the U.S. are already acquainted with OSHA Form 300 logs, reports generated on a monthly and annual basis that list all work-related injuries and illnesses.

Though thousands of businesses currently maintain these records, many industries have been exempt. But since OSHA is moving from the old Standard Industrial Classification (SIC) system to the more widely used North American Industry Classification System (NAICS), many previously exempt industries will be required to report workplace injuries and illnesses in accordance with Form 300 and 300A requirements.

Additionally, employers to report work-related fatalities and in-patient hospitalizations within eight hours of occurrence, and all work-related amputations (which don’t have to be reported currently) within 24 hours.

Stakeholders have been given until the end of September to comment, but a final rule will likely be issued before the end of the year.

It can be hard for businesses to determine which regulatory events will directly affect how they do business. That's why I’ve put together a list of the Top 5 OHS regulatory events on the immediate horizon business leaders as well as OHS managers and staff need to know about.

Yesterday we talked about a forthcoming crystalline silica rule. Here's the next issue in our Top 5:

4. Proposed rule to add MSD to OSHA injury reporting forms:

While OSHA has been back and forth on whether it will re-introduce a musculoskeletal disorder (MSD) column on Form 300 (and 300A) logs, which hundreds of thousands of organizations across the U.S. are required to complete, the issue is front and centre once again.

If this rule goes ahead, businesses will be required to record employee MSDs on monthly and yearly Form 300 logs.

After complaints from many stakeholders, OSHA had extended the deadline for public comments on the proposed rule, but that deadline passed on June 16. The administration has not provided a date on when a final rule will be issued, but expects a decision in the next couple of months.

Come back tomorrow for the third most important upcoming OHS regulatory event you need to know about. 

U.S. agencies and regulatory bodies are constantly proposing, reviewing, and finalizing new rules that often mean significant changes for businesses across the nation. Almost any company of any size needs to be aware of forthcoming changes that will impact how they manage their impacts and responsibilities related to occupational health and safety (OHS).

However, between proposed rules, final rules, pre-rules, long-tem actions and the dozens upon dozens of rules being reviewed at any given time, it can be hard for businesses to separate the wheat from the chaff and determine which events will directly affect how they do business.

In an attempt to ensure the most important issues are on your radar, I’ve put together a list of the Top 5 OHS regulatory events on the immediate horizon business leaders as well as OHS managers and staff need to know about.

We’ll start with number five and countdown to number one throughout the week.

5. The crystalline silica rule:

Earlier this year, OSHA started preparing a rule that would protect workers exposed to crystalline silica, a basic component of sand, granite, soil and other minerals that has been classified as a human lung carcinogen and can cause silicosis and tuberculosis.

More than 2 million U.S. workers, at least 100,000 of which operate in high-risk jobs like stonecutting, rock drilling, foundry work, blasting, quarry work and tunneling are exposed to crystalline silica on an ongoing basis. When the rule is implemented, thousands of employers in industries where crystalline silica is present will have to take an array of precautions to minimize exposure of workers to the dangerous compound.

The Office of Management and Budget (OMB) has already gone over the rule, and it has been returned to OSHA, which is well passed the typical deadline for review – it should have published a proposed rule by May 15. In a web chat this past Monday, an OSHA representative stated that the agency has made no final decision on the scope of a proposed rule and added “OSHA continues to work with OMB and is confident that a proposed rule will be published soon.” Since the agency has been working on the framework and scope of this rule since at least 2003, it is about time. 

Check back tomorrow for the fourth most important upcoming OHS regulatory event you need to know about.

The Occupational Health and Safety Administration (OSHA) is planning changes that would affect how businesses track and report on workplace injuries.

The proposed revisions to injury and illness recordkeeping rules would require employers to report work-related fatalities and in-patient hospitalizations within eight hours of occurrence, and all work-related amputations within 24 hours. Reporting amputations is not required under the existing regulation.

Also, the rule would update the section of OSHA’s recordkeeping rule that list industries exempt from injury and illness reporting requirements. Currently, some industries aren’t required to report due to their relatively low injury and illness rates. However, these industries are currently classified under the old Standard Industrial Classification (SIC) system, not the more widely used North American Industry Classification System (NAICS). The proposed rule would update the list to reflect NAICS classification, as well as more current Injury and Illness rates and, as a result, some industries formerly exempt from injury and illness reporting requirements might have to report when the rule is issued, including liquor stores, bakeries, auto parts stores, and more. In fact, OSHA estimates nearly 200,000 establishments will be affected by the changes.

However, these rules are by no means set in stone. The public has until September 20, 2011 to provide feedback. Head to regulations.gov to find the proposed rule and submit comments.

In the meantime, if you are not currently tracking and reporting on injury and illness data electronically, now is the time to start. A streamlined solution will significantly ease the burden of reporting in a timely, accurate and legally compliant manner, and make adjusting to these changes much easier.

Here one minute, gone the next. Now it’s back again. The controversial musculoskeletal disorder (MSDs) column is once again on the table as the Occupational Health and Safety Administration (OSHA) considers making it a mandatory component of OSHA 300 logs.

If the MSD column is restored, businesses would be required to record details on all work-related MSDs, injuries that tend to develop over time and affect joints, tendons, ligaments, nerves and muscles.

The MSD column used to be a mainstay of the OSHA 300 log, until it was removed in 2003 (though then-OSHA head John Henshaw maintained employers still needed to lump MSDs in with the "injury" or "all other illness" categories). The administration signaled earlier this year it would restore the column to the log, before withdrawing it and indicating it would reach out to small businesses first.

Well, that time is now. Beginning today, OSHA is reopening the public record on the matter and inviting the public – namely small employers – to provide feedback on this proposed revision to the Occupational Injury and Illness Reporting Requirements regulation. The notice has been posted in the Federal Register and the public is invited to submit comments until June 16, 2011.

"OSHA is eager to hear from the public on this, and every, proposed rule," David Michaels, OSHA’s Assistant Secretary of Labor noted in a release. "The more feedback the agency receives from small businesses on this topic, the better informed we will be in crafting a proposed regulation that protects workers without overburdening employers."

Opponents of the column complain that it unfairly burdens small business with intensive reporting requirements. Currently employers determine whether a case is “recordable” and meets the definition of “injury and illness” as defined by OSHA regulations. The proposed rule would define MSDs as “disorders of the muscles, nerves, tendons, ligaments, joints, cartilage or spinal discs that was not caused by a slip, trip, fall, motor vehicle accident or similar accident.”

According to OSHA, more than 1.5 million recordable MSDs occur annually among 1.5 million affected establishments, and that the costs of the new rule would total $1.7 million across all affected establishments.

Interested individuals are invited to comment on the small business teleconferences OSHA held April 11 and 12. A Summary of the comments are contained in the public docket here. Read the complete notice here.

In celebration of 40 years of making workplaces safer, the Occupational Safety and Health Administration (OSHA) has launched a new photo contest to boost awareness of workplace safety issues.

Anyone with a camera is invited to take a photo of a scenario or setting they believe represents an image of occupational health and safety (OHS) and submit it to OSHA. The administration is looking for outstanding portrayals of occupational health and safety in terms of artistic value, and capacity to inspire conversations on OHS issues. Other judging criteria include: the clarity and quality of the photo; the inclusion of worker, employer or workplace imagery; originality; and the suitability of the image for print in OSHA publications. The winners will be determined by a panel of expert judges with backgrounds in photography and labour issues.

In addition to being featured on OSHA's website, first, second and third-place photographs will be framed and displayed within OSHA's National Office in Washington, D.C., to serve “as a daily reminder of the real-life impacts of OSHA's mission for leading policymakers and prominent professionals,” according to the contest website.

Entrants have until August 12 to submit up to three photos, so take some time to capture an image that encapsulates an OHS matter in a unique way.

Check out the photo contest FAQ here.