When OSHA held its Regulatory Agenda Chat in July, many questions centered on OSHA’s planned Injury and Illness Prevention Program, dubbed I2P2, and called “OSHA’s highest regulatory priority.” But, there were few answers. Here is what we learned:
When: Shortly. OSHA had said that the Small Business Regulatory Enforcement Fairness Act process for I2P2 would begin in June, but that didn’t happen. In the Chat on July 11, OSHA said that it expected that process to begin “shortly,” and at that time a draft of the I2P2 would be available to the public.
What: Unknown. The Chat did not provide any clues on what we can expect I2P2 to look like. The most we learned was that I2P2 would be an “improved, more systematic approach to managing workplace health and safety.” In the past, we have been told that I2P2 would contain the following elements:
- Management duties
- Establish a policy
- Set goals
- Plan and allocate resources
- Assign and communicate roles and responsibilities
- Employee participation
- Involve employees in establishing, maintaining and evaluating the program
- Employee access to safety and health information
- Employee role in incident investigations
- Hazard identification and assessment
- Hazard prevention and control
- Education and training
- Program evaluation and improvement
The Bottom Line for Employers:
OSHA has engaged Eastern Research Group to prepare a Safety and Health Practices Survey to determine how safety is managed in various workplaces. In the meantime, we will need to pay close attention to this rulemaking and further developments, and will keep you posted.
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OSHA’s Planned Injury and Illness Prevention Program: Still Major Unknowns
When OSHA held its Regulatory Agenda Chat in July, many questions centered on OSHA’s planned Injury and Illness Prevention Program, dubbed I2P2, and called “OSHA’s highest regulatory priority.” But, there were few answers. Here is what we learned:
When: Shortly. OSHA had said that the Small Business Regulatory Enforcement Fairness Act process for I2P2 would begin in June, but that didn’t happen. In the Chat on July 11, OSHA said that it expected that process to begin “shortly,” and at that time a draft of the I2P2 would be available to the public.
What: Unknown. The Chat did not provide any clues on what we can expect I2P2 to look like. The most we learned was that I2P2 would be an “improved, more systematic approach to managing workplace health and safety.” In the past, we have been told that I2P2 would contain the following elements:
The Bottom Line for Employers:
OSHA has engaged Eastern Research Group to prepare a Safety and Health Practices Survey to determine how safety is managed in various workplaces. In the meantime, we will need to pay close attention to this rulemaking and further developments, and will keep you posted.