OSHA May Be Planning to Regulate Injury and Illness Prevention Programs

The Occupational Safety and Health Administration (OSHA) has been holding stakeholders meetings around the country to gather information about Injury and Illness Prevention Programs, which OSHA refers to as I2P2, reports the National Utility Contractors Association (NUCA) vice president of safety George Kennedy. The meetings are informal and OSHA is collecting information to develop a rule that it claims will help employers reduce workplace injuries and illnesses through a systematic process that proactively addresses workplace safety and health hazards. 

For years, NUCA has promoted the use of OSHA’s 1989 Safety and Health Program Management Guidelines, which are voluntary guidelines. The elements included in the guidelines have been used by many companies to create successful safety programs. The elements include: Management commitment and employee involvement; worksite analysis; hazard prevention and control; safety training; emergency procedures; and recordkeeping.

OSHA intends to create a rule that will require all employers to develop and implement Injury and Illness Prevention Programs for their companies, according to Kennedy. The agency believes an OSHA rule would encourage employers to proactively address workplace safety and health hazards.

It appears that the I2P2 rule would include the following elements, which are similar to the 1989 guidelines but more detailed and specific:

–Management duties, including items such as establishing a policy, setting goals, planning and allocating resources and assigning and communicating roles and responsibilities.

–Employee participation, including items such as involving employees in establishing, maintaining and evaluating the program, employee access to safety and health information and employee role in incident investigations.

–Hazard identification and assessment, including items such as what hazards must be identified, information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards, hazard assessment and prioritization and hazard identification tools.

–Hazard prevention and control, including items such as what hazards must be controlled, hazard control priorities and the effectiveness of the controls.

–Education and training, including items such as content of training, relationship to other OSHA training requirements and periodic training.

–Program evaluation and improvement, including items such as monitoring performance, correcting program deficiencies and improving program performance.

“If your company does not have a safety program in place, now is a good time to start one. If your company has a program in place, audit it annually and keep it up to date,” says Kennedy. “Whether OSHA creates or drops the idea of rulemaking, your company can benefit from having a safety and health program in place. Implementing a safety program today that fits your company is a win-win situation so why not do it and show OSHA that employers do not need OSHA rules to show them how to do the right thing.”