No more ‘catch me if you can’: I2P2 and what it could mean for you

As Occupational Safety and Health Administration (OSHA) chair Dr. David Michaels revealed in an online chat earlier this year, OSHA’s top priority for 2011 will be 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, and Michaels himself has called it the most significant change in workplace safety culture since OSHA’s inception 40 years ago.

While the organization continues to finalize the rule before its expected publication by the end of the year, it is worth evaluating what we do know about the proposed initiative. We know a few details about what OSHA will likely include in the final rule, plus thousands of American employers have already implemented injury and illness prevention programs based on elements of California’s own program (called IIPP and in existence since 1991). OSHA will reportedly be modeling the requirements of the forthcoming national program on California’s successful, 20-year-old program.

Here’s a rundown of a few elements that will likely be components of the OSHA program.

  • Define management duties: If they haven’t done so already, businesses may want to start documenting policies guiding management duties with respect to injury and illness prevention responsibilities, as well as defining goals and targets to improve health management performance.
  • Proactively manage hazards: Organizations will be expected to implement protocols to identify, assess, prevent and control hazards before they negatively impact employees. These include hazards that may relate to physical safety and health, as well chemical and biological hazards. As Michaels himself has ominously stated, “There will be no more waiting for a worker to get sick, hurt or killed to address a problem; no waiting for OSHA to show up to do an inspection; no playing a deadly game of ‘catch me if you can’ with the government while risking the lives of workers.”
  • Engage employees: In addition to crafting a system for assuring employee compliance with safe work practices, businesses will want to develop programs that ensure employee participation in all health and safety initiatives through education and training programs and streamlined employee access to health information.

Other elements intrinsic to California’s IIPP that may be included in OSHA’s I2P2 include:

  • Scheduled inspections/evaluation system.
  • Accident investigation.
  • Procedures for correcting unsafe/ unhealthy conditions.
  • Safety and health training and instruction.
  • Recordkeeping and documentation.

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