In 1989, the federal Occupational Health and Safety Administration (OSHA) assumed a fallback position when it issued prevention program guidelines rather than a mandatory standard. Two years later, California (Cal-OSHA) made Injury and Illness Prevention Plans (I2P2 or IIPP) mandatory for employers. Several OSHA state plans followed suit with their own program requirements.
Rand Corporation studies and OSHA whitepapers summarize results associated with properly implemented I2P2 programs. Encouraged by results, I2P2 has been an OSHA priority since the current administration took office in 2009.
In a June 25 plenary session at the American Society of Safety Engineers (ASSE) Safety 2013 conference, OSHA Administrator Dr. David Michaels called Injury and Illness Prevention Program rule making his highest priority while acknowledging that some consider the proposal controversial.
In sum, he said “I2P2 would require employers to have an ongoing, investigative, preventive process in place instead of being reactive and addressing problems after an accident occurs.”
What OSHA is recommending will have minimal impact on employers with progressive workplace health and safety programs. However, a mandatory program management standard would give OSHA deeper reach into program operations – similar to what they have currently through on-site consultation with Voluntary Protection Plan (VPP) and Safety and Health Achievement Recognition Program (SHARP) participants – without protections provided by voluntary consultative agreements.
Employers lacking well-established programs will have more work to do; namely, involve managers and workers in the development, implementation and continuous improvement of injury and illness prevention programs.
We know from experience that controversial rules can take years to promulgate. No one can be certain when (or even if) a federal rule will ever be adopted. In the meantime, we can reasonably expect additional states to issue program management requirements.
What to do now?
Become familiar with the proposed provisions and likely results. Benchmark your programs against the proposed provisions and consider voluntary adoption. Aside from prospective health, safety and productivity benefits, voluntary adoption of I2P2 provisions will aid in conformance with consensus standards such as ANSI Z10 and OHSAS 18001.
UL Workplace Health and Safety’s evolution of safety timeline gives us a unique perspective into how catastrophic events and work-related incidents can be prevented when we make the effort to glean lessons from the past.