OSHA's I2P2

With the federal Injury and Illness Prevention Program (I2P2) legislation brewing since 2010, companies have been in a steady holding pattern for a few years, wondering if OSHA will ever push the legislation through, thereby drastically changing the safety requirements for American employers. With Obama’s second term secured and Dr. David Michaels, assistant secretary of labor for OSHA, articulating that passing I2P2 is his top priority in 2013,  it’s likely that this change will occur sooner rather than later.

See Also: Occupational Health & Safety (OHS) Training

Preparing for the implementation of I2P2, however, presents two main challenges. First, since the exact wording of the legislation is not yet available, safety managers must figure out how best to predict what will be required. Second, creating and managing a comprehensive injury and illness prevention program is an undertaking fraught with complications and challenges of its own. Many safety managers will opt for the path of least resistance by waiting until the legislation is passed to make any program changes. However, we consider this an exciting opportunity to rethink and improve the way safety is performed at your organization, with a newfound focus on proving a meaningful return on investment – an area with room for improvement for all of us in safety.

How will I2P2 impact safety professionals and organizations, and can technology help safety professionals overcome some of the greatest challenges of managing a comprehensive injury and illness prevention program, while adding value to your organization’s bottom line?

What to Expect from I2P2

OSHA has provided some indication, in plain English, about what to expect from the legislation – the FAQ page onDr. David Michaels assistant secretary of labor for OSHA the Federal OSHA I2P2 Web site states:  “The Injury and Illness Prevention Program standard will simply require employers to develop a program to help them find and fix hazards in their workplaces.” For many, this requirement simply may mean retooling their current program; for others it will mean creating an entirely new program from the ground up.

All U.S. employers will be required to have an operative safety program (not just a binder on a shelf or a policy statement in the employee handbook) that identifies and reduces workplace hazards on an ongoing basis. However, Federal OSHA sees this legislation as a performance-based requirement, and will allow the flexibility for each organization to create the program that meets its own specific needs.

While each company’s program will include unique processes and elements, OSHA recommends that safety directors include a handful of core components when designing an injury and illness prevention program. Here is a brief summary of these core components (for exact details, visit OSHA’s web site at http://www.osha.gov/dsg/topics/safetyhealth):

  • Management leadership – Ensure that safety leaders are identified with clearly defined responsibilities. 
  • Worker participation – When designing safety practices, involve the employees that work in the specific environment for which the practices are created.
  • Hazard assessment – Conduct periodic workplace inspections that identify and evaluate work-place hazards. 
  • Hazard prevention and control – Implement controls for all identified issues, and have a procedure in place to investigate incidents that occur. 
  • Education and training – Educate employees to understand the exposures for their job and how to avoid them. Re-training must occur anytime their roles or job tasks change. 
  •  Program evaluation and improvement – Clearly and consistently document all steps of the program (also is critical to prove compliance), conduct ongoing monitoring of program failures and successes, prove success through concrete metrics and continually improve the program and its processes. 

Overcoming I2P2 Challenges with Technology
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