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St. Louis ASSE chapter opposes I2P2 (4/7)

April 7, 2011
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Concerned over what it sees as a significant potential for “compliance enforcement excesses,” the St. Louis, MO chapter of the American Society of Safety Engineers has notified OSHA about its opposition to the agency’s proposed I2P2 standard.

Among its reasons: the name change from Safety and Health Program Management Guidelines to Injury/Illness Prevention Program (I2P2).

“That is a very misleading title,” said Chapter President Harry Miller, in a letter to OSHA chief Dr. David Michaels. “The name I2P2 implies that following this standard will prevent injuries and illnesses. What is the potential outcome when injuries or illnesses occur at work sites with the I2P2 regulation in effect? Does that mean that the site personnel and safety/health professionals have failed in their responsibilities under the law and will be cited?

Miller also said that I2P2 would interfere with the goal of safety and health professionals of helping worksite leadership teams to achieve excellence. “We will be severely handicapped in doing that if who we are and everything we do is an OSHA requirement—and, by definition, only basic safety/health.”

Other objections to I2P2 by the chapter include:
  • Increased paperwork and other requirements that would burden safety/health professionals while offering few, if any, improvements
  • Difficulties coping with paperwork and other “soft” requirements of I2P3 on the part of sites that do not have safety/health staff
  • I2P2 will result in “de facto standards by compliance directive and interpretive letter”
  • OSHA’s inability – to date – to define what “effective” means in its description of an “effective site safety/health program.”
Summing up, Miller said his chapter vigorously opposes I2P2 because it adds “significant burdens and costs with few, if any, benefits to our members or their leadership team customers and employee stakeholders.” He did, however, express support for updating OSHA’s Safety and Health Program Management Guidelines, calling them “a more functional alternative.”

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