The Injury and Illness Prevention Program (I2P2) that OSHA calls its "highest regulatory priority" was on the minds of many who participated in the agency’s recent webchat on its 2011 regulatory agenda.

The chance to ask OSHA staffers direct questions drew many inquiries about whether companies with existing safety programs would be required to institute an I2P2, and whether small businesses needed – or would be negatively impacted by – I2P2s.

One online participant asked, “From my significant experience, large companies have effective I2P2. Is it OSHA's intent that I2P2 will be focused toward smaller companies?”

Another said, “An injury and illness prevention program for very small employers (less than 10) seems excessive and unnecessary. Have you considered a size application for this program?”

An OSHA staff member said the scope of the program was still under consideration, with the focus being on the most dangerous workplaces. The agency expects small and medium sized employers to benefit most from the I2P2 rule.

Factors cited as helping shape the agency’s proposal are California’s Injury and Illness prevention standard – which has been in place for two decades – and successful programs that have already been implemented by larger employers – programs OSHA says it is committed to not disrupting.

OSHA has not determined a specific date for publishing I2P2.

Combustible dust was also a popular topic during the webchat, with some expressing frustration at  OSHA’s failure to adopt a standard. Noted one participant, “It's been more than four years since the Chemical Safety Board urged OSHA to promulgate a standard on combustible dust. And just last month, three more workers died in what is believed to have been a combustible dust explosion at a metals recycling plant in New Cumberland, W.Va. Given that tragedies like this continue, how can OSHA justify still moving so slowly on a combustible dust standard?”

OSHA staff called combustible dust rulemaking a complex project that could affect a large number of industry sectors. “Consequently, the agency must conduct considerable research to ensure that the resulting standard effectively protects workers and meets legal requirements. While OSHA proceeds with its research and deliberations, we continue to actively enforce relevant standards and the general duty clause to address this serious hazard.”

OSHA’s 2011 agenda includes publishing final rules for Confined Spaces in Construction, General Working Conditions for Shipyards, Electric Power Transmission, Hazard Communication and Standards Improvement. Additionally, final rules for several whistle-blower regulations and a proposed rule for silica are expected to be published.

A complete transcript of the webchat is available at: