Thought Leadership

I2P2 will be the scourge of the “best” safety programs

June 25, 2013
/ Print / Reprints /
/ Text Size+

ISHN Guest BlogThere 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.



Image Galleries

Scenes from the World of Safety

Sights, signs & symbols from the National Safety Congress & Expo held in San Diego, CA, September 15-18

11/4/14 2:00 pm EST

Eye Injuries: You rarely see them coming. Practical Solutions for reducing injuries to the eye.

The 3M Eye Injury Reduction webinar will provide an examination of how to help solve eye injuries in the workplace. This issue continues to challenge virtually every industry, and the solution is often times multifaceted. 3M will share some new tools and approaches to help you in solving this issue.

ISHN Magazine


2014 October

This issue features articles about PPE safety and OSHA standards

Table Of Contents Subscribe


M:\General Shared\__AEC Store Katie Z\AEC Store\Images\ISHN\safetyfourth.jpg
Safety Engineering, 4th Edition

A practical, solutions-driven reference, Safety Engineering, 4th edition, has been completely revised and updated to reflect many of today’s issues in safety.

More Products

For Distributors Only - SEPTEMBER 2014

ISHN FDO SEPTEMBER 2014For Distributors Only is ISHN's niche brand standard-sized magazine supplement aimed at an audience of 2,000 U.S. distributors that sell safety products. Circulation only goes to distributors. CHECK OUT THE SEPTEMBER 2014 ISSUE OF FDO HERE


Facebook logo Twitter YouTubeLinkedIn Google + icon

ishn infographics

2012 US workplace deathsCheck out ISHN's new Infographic page! Learn more about worker safety through these interactive images. CLICK HERE to view the page.