OSHA Makes Case for Injury Illness Prevention Program

Date First Published on SafetySmart Compliance: May 9th, 2012
Topics: Illness Injury Prevention Program |

HardhatOSHA hasn’t had much to say about the Injury Illness Prevention Plan (I2P2) in recent months. But if you thought that I2P2 was going away, think again. Last week, OSHA issued a White Paper signalling that I2P2 remains very much at the top of its agenda.

White Paper Shows OSHA Still Believes in I2P2

As you may recall, OSHA first broached the idea of requiring employers to develop a written I2P2 program in April 2010. The idea, according to OSHA chief Dr. David Michaels, is to force employers to engage in a “proactive process to find and fix hazards before workers get hurt.”

Business protest and election politics seem to have relegated I2P2 to the back burner of the OSHA agenda. Or so it seemed. The Jan. 13, 2012, White Paper seems to put I2P2 back in play. The punch line is contained in the third paragraph of the first page:

“OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to a significantly improved health and safety environment. Adoption of [such programs] will result in workers suffering fewer injuries, illnesses and fatalities.”

The OSHA Case for I2P2

The White Paper then goes on to lay out OSHA’s case for I2P2:

  • 15 states already have regulations requiring such programs—10 more encourage them; [see attached chart]
  • The more than 2,400 facilities in VPP and 1,500 small business in SHAPR have adopted programs similar to I2P2;
  • I2P2 is required under ANSI/AIHA Z10-2005 and OHSAS 18001;
  • Implementation of I2P2 would reduce injuries by 15% to 35%;
  • I2P2 implementation will enable companies to reduce workers’ comp claims and achieve other significant savings.

Why I2P2 Is So Scary

I2P2 is a noble idea. And OSHA’s case that I2P2 programs prevent injuries and illnesses and cut claims is pretty accurate.

The problem, of course, is whether OSHA should have the authority to make companies adopt such programs. More precisely, should OSHA be able to dictate the kinds of safety programs companies should adopt?

Such authority seems to go against the grain of the basic OSHA system whereby OSHA identifies hazards and broad requirements and leaves employers discretion on the implementation details. Businesses fear that making OSHA the tsar of safety programs will force them to totally rewrite their safety programs; in addition to massive cost, this could result in making OSHA enforcement even more inconsistent and unpredictable than it is now.

Download the file version of your choice below for a summary of existing state injury and illness prevention programs