Thought Leadership


OSHA’s I2P2 idea – Not quite gone and not forgotten

August 7, 2014

Thought LeadershipWhen OSHA released its Spring Regulatory Agenda, the Injury/Illness Prevention Program had been moved to Long Term Action. In the immediately previous regulatory agenda, I2P2 had been on the proposed rule schedule for September 2014.

I2P2 has supposedly been the OSHA administration’s number one priority for several years now. It was first introduced in the spring of 2010 with stakeholder meetings held that summer.

The interesting part is that, so far, there has been no communication from the OSHA administration on the reason for the shift to Long Term Action.

I have seen one commentary in the OSH news media and one brief notice in another along with an opinion survey as to what readers thought about the shift. The commentary proposed the reason as OSHA has run out of time to get the regulation enacted. I certainly do not agree with that. If they want to enact this regulation, they can just do it.

One possibility for a reason is that OSHA was told to shift I2P2 out of the active agenda, it was not their decision.

Why might that happen?

 It could be that the Obama administration did not want another big government regulation debated in the fall 2014 election season. Another reason:  labor leadership appears to be supporting the Keystone Pipeline. It could be that the Administration decided to pay them back---I2P2 being a political agenda priority of labor leadership.

None of these are necessarily the real reason. But they are consistent with someone else making the decision to shift I2P2 -- and no one talking about it.

There is yet another potential reason. The schedule has been released for ISO 45001, an OSH management standard. The proposal details are scheduled to be released in November, 2014 for a two-year discussion. If the I2P2 proposal were to be different from the ISO 45001 proposal, there could be complications for the OSHA standard--hence the decision to delay the I2P2 discussion.

None of these may actually be the reason but it is surely more than OSHA running out of time to get it enacted.

Meanwhile, I2P2 is on the back burner for now. Does that mean that we let down our guard about it? No. As long as this is on the regulatory calendar, there is potential for it to suddenly emerge to active status.

To summarize, once again, the reason that I oppose I2P2 and will continue to oppose it are:

  • It cannot improve safety and health beyond what is being done already by the estimated 100,000 sites having OSH staff working collaboratively with management teams and employee colleagues. The 7,400,000 sites without OSH staff will not be able to sustainably implement I2P2.
  • Safety and Health Management Systems are the essence of who we are as OSH professionals. Our predecessors originated these systems and we continue to develop them. Making the essence of who we are into a government regulation diminishes our professional value add and could, in time, lead our employers to questions the value of having OSH professionals on staff.
  • It will empower the government to perpetually harass VPP sites and other sites that have OSH staff and safety and health management systems. When these sites have injuries or illnesses or have any violations of OSHA standards identified, OSHA will declare these sites’ safety and health management systems as “not effective” and subject these sites repeatedly to Willful citations and fines.                                                                              

The opinions expressed in this article are solely those of the author. They do not necessarily represent the opinions of the leadership or membership of the St. Louis Chapter of ASSE.

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