I2P2: Don't fear the debate

At this week’s ASSE annual conference in Chicago OSHA chief Dr. David Michaels and NIOSH head John Howard walked out and took seats on the stage of the Skyline Ballroom at McCormick Place for a rather casual one-hour sit-down with moderator Diane Steagal representing ASSE.

Right from the start, Dr. Michaels was hit with three questions about the Injury and Illness Prevention Program (I2P2) standard. How will it be enforced? Will it be a second “general duty clause”? Is it a back door way of regulating ergonomics? What will it do to the day-to-day job of pros?

I2P2 is not even out of the starting gate yet, says the OSHA boss. “We are just beginning. This is a slow and byzantine process that will take years. We hope to engage the whole country in finding answers to how best execute an I2P2 standard. Will it be a regulatory burden? Every time OSHA even thinks about doing something new people will say it’s going to be a burden. We believe I2P2 will be an important addition to every OSHA existing regulation.”

OSHA plans to take the unusual step of issuing a White Paper explaining how I2P2 would be enforced, even before rulemaking is completed. This is the reverse of OSHA’s customary approach, which is to issue a standard and then the follow-up enforcement directive.

In the less than two years Dr. Michaels has been in office, I2P2 has become almost synonymous with all things OSHA. Right now it is only an idea, years away from becoming even an official proposal let alone a final rule. It very well might never become a standard.

Yet I2P2 has quickly grown into an 800-pound gorilla that threatens to swat other OSHA issues, such as recent campaigns on distracted driving and heat stress, off the table.

Everyone take a deep breath, step back, and permit a healthy debate to air out over I2P2.