OSHA releases I2P2 white paper to convince businesses of program’s benefit

Posted on January 10, 2012 by Paul Leavoy

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 proposed 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.

OHS injuries and illness in health care, safety in the wind industry and more on EHS This Week

Posted on December 23, 2011 by Paul Leavoy

Check out the most recent podcast of EHS This Week.

This week, Kristy Sadler and I discuss top stories from the world of environment, health and safety news, including

The relationship between days away from work and OHS injuries and illnesses in the health care sector.
The unexpected number one reason for on the job injuries at the Tucson fire department.
Safety issues in the wind power industry, and more.

Check back on a weekly basis for our rundown of the week’s top EHS Stories.

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The Top 5 upcoming OHS regulatory events you need to know about: #1

Posted on July 15, 2011 by Paul Leavoy

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.

The Top 5 upcoming OHS regulatory events you need to know about: #3

Posted on July 13, 2011 by Paul Leavoy

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.

Thousands of businesses to be affected by OSHA’s proposed recordkeeping rules

Posted on June 22, 2011 by Paul Leavoy

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.

OSHA reopens MSD column debate for public comment

Posted on May 17, 2011 by Paul Leavoy

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.