The American Society of Safety Engineers supports the idea of I2P2 and wants legislators to listen to its experts if they decide to weight in on OSHA’s rulemaking, according to a letter sent by ASSE President Darryl C. Hill, Ph.D., to Representative Darrell Issa, Chairman of the House Committee on Oversight and Government.

“To be clear, ASSE, like everyone else, waits to see what OSHA proposes for its I2P2 standard,” wrote Hill. “If the Committee determines that its oversight of OSHA’s activities with regard to the I2P2 is needed, we encourage you to take the opportunity to listen to our member safety, health and environmental (SH&E) professionals’ view of such a standard.”

The I2P2 rule would require employers to implement a program tailored to the hazards in their workplaces and require employers to “find and fix” hazards without waiting for a workplace incident, an issue-specific OSHA standard, or an OSHA inspection.

If the House decides that oversight of OSHA’s I2P2 rulemaking is needed, the Committee on Oversight and Government Reform could hold hearings to provide it, and ASSE wants to have a say. “OSHA’s final I2P2 must encourage risk-based safety management that will help employers avoid proscriptive regulations, be highly flexible so that every industry can meet its requirements without unnecessary burdens, and be simple enough for the smallest employers to use without being burdened,” said Hill. “We firmly believe OSHA can write a standard that meets those requirements and will do all that we can do to help see a final standard that meets our principles.”

The ASSE has proposed a list of features that an effective I2P2 standard would have, including:
  • An emphasis on risk-based management of workplace hazards
  • While the employer is responsible for the program, both employer and employee must be involved.
  • A commitment to continual improvement and periodic reviews.