Think I2P2 ain’t happening? Think again.

So, there’s been some doubt OSHA’s ‘fabled’ I2P2 initiative – a massive Injury and Illness Protection Program – will be unveiled and enforced any time in the near future, there’s even been some speculation over whether it will be implemented at all. But I can assure you, these are just notions, and I2P2 will be implemented in the near future. In fact, probably this year, if not early 2014.

That said, it is understandable there’s been concern over the sheer amount of time it has taken for OSHA to finalize I2P2. Back in 2010, OSHA head Dr. David Michaels indicated it was ‘coming’. But then the U.S. midterm elections happened, and since regulation is a polarizing topic across the U.S., I2P2 talk was hushed. 

Then in January 2012 Michaels said it was OSHA’s “top priority” for the year. Then towards the end of the year health and safety leaders were assured it was a “top priority” once again. In fact, in June 2012 Michaels even hinted I2P2 could see the light of day even before the 2012 presidential election in November. Asked by reporters whether this was definitely going to happen, he coyly remarked ‘I’m not allowed to say.’

Well, it didn’t happen. It didn’t happen before the election, and it hasn’t happened since. However, I’d argue that all signs show it is coming, and it’s coming soon.

OSHA’s reputation at stake

For one, there’s the simple fact OSHA has a reputation to maintain. If it doesn’t deliver on its commitments – for example, repeatedly suggesting that I2P2 would be a reality in 2012/2013 – then it is not going to be taken seriously as an agency. So have no doubt that I2P2 is still on the front burner for this administration. 

We can’t say exactly when it will happen, but when it does happen organizations will have no excuses to make, for no one can allege that the agency didn’t warn the U.S. business community.

Additionally, the American Industrial Hygiene Association (AIHA), recently explained that OSHA’s Injury and Illness Prevention Program will happen and also acknowledged that safety programs are part of a minimal acceptable professional practice on any worksite in any industry. This aligns with OSHA’s recently released 2013 regulatory agenda where the agency once again noted that I2P2 would be a key priority in the months ahead.

‘Flurry of activity’ on regulatory front

Legal experts also widely agree that, since the 2012 Presidential Election has concluded, I2P2 will move back to the top of the regulatory map. Labour and employment law experts Ilyse Schuman and Michael Lotito opined in a JD Supra article that, in the aftermath of the election, the Obama administration would be likely “to continue to turn to federal agencies to achieve labour and employment goals, albeit at an even more dramatic place,” adding that U.S. businesses could see an acceleration of the administration’s efforts to dramatically alter workplace policy after Obama’s election win. They said employers should prepare for a “flurry of activity” by the Department of Labour with a continued focus on enforcement.

So don’t wait for what you’ve already been warned about. Implement a safety management system now and be prepared for everything I2P2 will require. 

Want to learn more? Download our White Paper, Safety Revolution: How I2P2 Will Reshape Your Business.

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