In the summer of 2010, OSHA held the first in a series of stakeholder meetings on its ambitious proposal to adopt an Injury and Illness Prevention Program standard.
Now the proposal is back on the radar with the recent publication of a white paper in which the agency promotes injury and illness prevention programs as the foundation for “breakthrough changes in the way employers identify and control hazards, leading to significantly improved workplace health and safety environments.” The paper cites numerous studies validating benefits of the preventive approach including higher productivity and quality, lower turnover, reduced costs and greater employee satisfaction.
The white paper and the notes summarizing discussions at the stakeholder meetings are “must-reading” for occupational health and safety professionals who want to obtain a better understanding of the nature of the proposal, outcomes associated with the prevention strategy and concerns about what some perceive as an attempt to legislate culture change.
In some respects, the proposed prevention standard strikes me as a case of regulating common sense and best business practices. However, statistics suggest not all employers are willing to voluntarily embrace prevention programs and that some form of enforcement may be necessary.
The number of workers who die or are injured on the job every day remains unacceptably high. OSHA estimates implementation of prevention programs by employers who do not yet have them would reduce injury rates 15 to 35 percent, save lives and reduce costs by billions of dollars a year.
Of 34 states that have enacted some form of related legislation, 15 have mandated injury and illness prevention programs for all or some employers. The OSHA proposal follows their lead.
With respect to enforcement, as envisioned, application of the General Duty Clause (Section 5(a)(1)), which covers recognized hazards for which OSHA does not have standards, would not be affected. As stated by OSHA, “A citation for violating an existing OSHA standard or for violating the General Duty Clause would not mean that an employer could also be cited for violating the Injury and Illness Prevention Program standard.”
OSHA has identified six core program components, all of which are adaptable to any workplace:
- management leadership
- employee participation
- hazard identification and assessment
- hazard prevention and control
- education and training
- program evaluation and improvement
This list is by no means exhaustive. The proposal is in an early stage of development: The next step is to gather comments from small businesses, followed by the publication of a draft regulation, a comment period and extensive public hearings.
Experience shows injury and illness prevention programs need not be resource-intensive and can be designed to meet the needs of any size organization. Implementation guidance and information on model programs at successful companies are widely available. Given the laborious and politicized nature of the standard-setting process, why wait that long to be told?
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