Whatever happened to the I2P2 standard?
The rise and fall of OSHA’s most ambitious standard proposal
On June 14, 2010, Dr. David Michaels, the newly-appointed head of OSHA, gave a speech at the American Society of Safety Engineers’ annual conference in Baltimore. He emphasized implementing an Injury and Illness Prevention Program. “We will be asking employers to find the safety and health hazards present in their facilities… and then fix those hazards,” he explained. ”ASSE and other professional organizations asked for this rule, and I believe it has the potential to change the culture of workplaces… in a way we haven’t seen since OSHA was created 40 years ago.”
In the next several years Dr. Michaels repeatedly stressed the need for what became known as “I2P2.” It became the talk of the safety world, debated by vocal supporters and critics.
Fast forward to 2016. I2P2 is now listed on OSHA’s regulatory agenda in the “long term” category. “In reality, this means the issue is dead and not likely to be revised,” says an association government affairs director.
A combination of factors drove I2P2 off OSHA’s radar screen. First, politics: I2P2 was too controversial, with too much business opposition, to move forward with it before the mid-term 2012 elections, or the upcoming Presidential election. Second, Mike Seymour, a key OSHA staffer in writing the I2P2 standard effort, retired. Third, Dr. Michaels was forced to make a hard decision about three competing standards-setting priorities: silica, I2P2, and fall protection (also known as the walking and working surfaces standard). He came to realize time was running out, stepped back, and decided the first priority would be the silica rule. “Silica was his big one all along. He had every intent to get that one out,” says one source.
Another factor: Dr. Michaels while at the Department of Energy prior to OSHA, championed the Voluntary Protection Program (VPP), and believed the I2P2 proposal was similar to the popular VPP requirements. But the business lobby in Washington saw I2P2 as a Trojan Horse for an ergonomics standard. That perspective was reinforced early on when interim OSHA chief Jordan Barab spoke to the ASSE conference in 2009. “We need to confront the 60,000-pound elephant in the room: ergonomic,” Barab told the audience. “It’s a huge political football… we’re going to pick up that football… people are getting hurt by… backbreaking behavior that can be reduced or eliminated with proven remedies. We can fix this.”
“Stop looking for the magic bullet,” says one Washington source. “The bureaucratic, documentation-focused, paper-trail approach of I2P2, ergo, etc. have run their course.”
OSHA apparently has gotten the message. In a statement to ISHN issued February 11, 2016, the agency said, “We are focusing our efforts on updating the 1989 Safety and Health Program Management Guidelines.” OSHA calls updated guidelines “a sound, flexible framework for addressing safety and health issues in the workplace.”
The aim is to align the voluntary guidelines with safety and health management systems such as OHSAS 18001 and ANSI Z10. Management commitment, employee involvement, and a systems approach will be emphasized more than in the 1989 guidelines. The updated voluntary guidelines are not likely to be enforced using OSHA’s General Duty clause, as some fear, but could be used in penalty settlement cases, ISHN has learned. Fines could be reduced if cited companies agree to implement the guidelines.