Federal OSHA is continuing its efforts to promulgate a generic safety and health management system rule called the Injury and Illness Prevention Program, formerly dubbed “IIPP,” and now, “I2P2”.
Unless it falls prey to the anti-regulatory fervor now building in Washington DC, OSHA could release the first draft of their proposed I2P2 program this year, and the policy wonk fireworks will begin.
Even long time safety pros seem split on being for or against I2P2. One side will emphasize that it will place new burdens on employers, especially small businesses who cannot do anything extra to improve workplace safety and health without it becoming a financial burden and costing the economy jobs.
The other side will insist that it will do more to improve worker safety and health in the US than any previous regulation while cutting losses and costs associated with injuries and illnesses.
Been there, done thatFor those who are in California, and several other state plan states, the I2P2 has been law for many years, which means that the results are in. The truth is somewhere in the middle.
Implementing I2P2 does require resources and effort. If implemented in good faith it does reduce injuries and illness. Since 1991 when California first finalized its I2P2 regulation, the state’s overall injury rate has dropped about 17%, but there is no way to attribute how much is specifically due to I2P2, just as there is no way to assess I2P2’s exact implementation cost.
Since 1991, I have implemented I2P2s for a global corporation of over 50,000 employees, for multiple companies as a consultant, and for a municipality of 150 employees. All these plans have had in common the standard sections as required by law. The federal version will likely contain these basic requirements as well.
It is important to remember that as a performance standard, the employer decides which specific methods and strategies to use and then includes them in their I2P2. This performance standard concept is crucial. The regulation lists only basic performance requirements, not the exact methods for accomplishing them. The sections below are based on the California law, because the federal version is not yet released.
Identify everyone with authority and responsibility for implementing the program.This ensures everyone in the organization from leadership to rank and file knows that there is an I2P2 and that everyone has some responsibilities in the process to make it work.
Include a system for ensuring employees comply with safe and healthy work practices.This can be a discipline system, but discipline should be considered a last resort if there are other ways to ensure compliance.
Include a system for communicating with employees.This is often the controversial section because it is often misinterpreted to mean it requires safety committees. The California version acknowledges safety committees ensure compliance with the law, but other means of communication, if effective and readily understandable, are compliant.
Also controversial in this section is that communication is considered a two way street, which means employer to employee and employee to employer, without fear of reprisal. Many employers who do not maintain good relationships with their employees do not want them to have the power to report hazards. This is controversial only with those for whom the issue of power over employees is critical; for others, it is a highly effective way to find and fix hazards.
Include procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and practices.Employers who take this section and turn it into a paper chase of inspection forms may be subject to unwanted program costs and inefficiencies. It is important to strike a balance on the inspection forms, while keeping it simple. For example if it takes 20 minutes of paperwork to report a hazard, and that time away from the job results in lost productivity metrics for that employee, they are not going to make a report. Go digital or go wireless, and get rid of the paper.
Include a procedure to investigate occupational injury or occupational illness.This seems intuitive that if accidents happen you want to look at the causes and use that knowledge to assess trends. There is no requirement as to logging near misses and other minor events, but these are valuable if you have an effective safety program and don’t have a lot of injuries for tracking accident trend data.
Include procedures for correcting unsafe or unhealthy conditions, work practices and work procedures in a timely manner based on the severity of the hazard.This is the heart of the program. This is simply “get the hazard before it gets you.” The naysayers will claim the rules force all hazards to be treated equally, but the requirements allow for setting priorities based on any factors including financial, as long as there is a good faith effort that cataloged the hazard, assessed the hazard, and the severity of the outcome are all looked at in the process. It is of critical importance however, that if you commit to fixing a hazard fast, it gets fixed fast.
Provide training and instruction.While this seems simple, it is really the part of the regulation that ultimately has the most impact. How well the I2P2 is implemented depends on how much an employer trusts and empowers the employees to become partners in hazard finding and fixing. The indicator of this trust is how much training the employer provides and how effective it is. When the employees are trained into an effective safety corps, the I2P2 will work great. If the program is put on the shelf, and the employees receive minimal halfhearted training, it will not work.
Document your good work.Training records must show who attended, what was the information presented, and the date and time. Hazard reports need to show closure, which means either it was fixed or if not, show a reasonable rationale why not.
In summary, the I2P2 will be as effective as the employer wants it to be. My experience is that it can work great in any size organization. My current situation with 150 employees means I can personally provide I2P2 training sessions. I emphasize that the employees are the eyes and ears of the organization, and that reporting hazards and incidents is simple and as easy as a 30 second email. They also know from experience that after reporting a hazard they see a response, copied to their supervisor, thanking them for reporting the hazard, and then either it gets fixed fast, or they get an explanation why not. I also make our IIPP text publicly available. Having our program posted on the Internet shows that it is important to our organization, that we are proud of our plan, and transparency is one of our values.