There was a statement in a commentary in the Wall Street Journal a couple of months ago:

"A fundamental principle in medicine is that if you get the diagnosis wrong, you'll probably apply the wrong therapy. A corollary is that if the therapy isn't working, increasing the dose may make things worse." 

This was from a former medical practitioner commenting on the government's regulatory solutions for health care. But it very accurately by analogy describes the government's approach to safety with I2P2, as illustrated by Dr. Michael's statement reported statement earlier this year to the assembled OSHA staff.

The government has correctly determined that the reason for the problem of persistent high injury rates is absence of safety management systems, structure and processes. The government has completely misdiagnosed the underlying (real) reason for that problem---which is: no safety professionals on staff in most work sites. The government's therapy (solution) resulting from this misdiagnosis is to enact I2P2, an extreme, one size fits all, written process (not hazard based) regulation that these sites will be unable to comply with.

Even worse will be the impact of the misdiagnosis on sites having safety professionals on staff. These sites, while having fewer injuries and violations of existing standards, still do experience these adverse consequence events. 

I2P2 will establish the terminology "injury and violation prevention" as a legal term in a regulation. It will legally empower the government to second guess and nitpick these existing safety programs and management systems and the site safety professionals who support them, using the government’s virtually unlimited interpretation powers for the term "injury and violation prevention".

Safety and health management was never conceived by safety professionals as a “prevention” program. It is, rather, a process organization program intended to have safety managed in similar manner to other site management systems. For it to function, however, it is essential to have a safety staff employed at the site.

Dr. Michaels defines sites with safety management systems as “the best” for purposes of the I2P2 regulation, implying that these sites really do not need this regulation—it is “the rest” that need it. “The best” already likely have a safety management system at their sites and are supporting and resourcing that system. But safety professionals and their employers should be ready for a sharp change in how the government views these sites if the government succeeds in getting I2P2 is enacted.

Even after generating thousands of citations, the government will become bored citing small work places having no safety management system and no safety professionals. To fulfill its political agenda objectives, the government will have to move to inspect and cite the larger workplaces, “the best,” according to Dr. Michaels, those with safety professionals, to generate sufficient PR interest for their burgeoning shaming press release program.