Small business have characteristics and challenges that must be taken into account if an OSHA I2P2 is to succeed with them. That’s the assessment of Gordon Miller, who outlined a strategy at AIHce 2011 for designing an I2P2 standard that addresses the needs of the nation’s 6.5 million small businesses.

Miller, the president of MM&A, LLC, a consulting company specializing in occupational, health, safety and environmental affairs, addressed the topic: “Making the Case for I2P2 in Small Workplaces and Implementation Best Practices.”

“One of the challenges that’s clearly out there is that small businesses have fewer resources,” said Miller. At many companies, environmental health and safety staff have been reduced. At small companies in particular, personnel tend to cover multiple roles, including some with which they may have little experience or expertise.

“There’s no question that the financial side is a burden right now,” said Miller. “Small companies can’t bury costs in some activities. They have to be looking at the bottom line.” Unlike their larger, better-capitalized counterparts, small business entities have to become profitably quickly if they are to survive. Statistics show an 80-90% failure rate for some types of businesses within the first year. Financial difficulties are the leading cause of that failure, making profitability a much higher priority than compliance with health and safety regulations.

Miller mentioned one manager who said his company had to make a profit first – then it could comply with regulations. “We have no intention of not complying,” the man told him.

An I2P2 standard will affect businesses of all sizes nationwide, but Miller identified stwo critical variables that will affect its impact on and success with small businesses:
  • It must be simple
  • It must be effective from the outset
The simplicity factor should extend to language used in written policies, training programs, reporting systems and evaluation systems – and the program should be adaptable to the many different types of small businesses it will cover. Compliance must be judged on a simple evaluation system. Implementation must be easy, consisting of as few steps as possible.

As for the need to see quick results, Miller said that small companies “don’t have long-term commitment dollars to spend.” He anticipates that the I2P2 process will require tremendous time and resources. “This is a huge, long-haul project. It’s a great idea – everybody will agree to it, but there are plenty of challenges. If not included (in the development process), those challenges are going to be potential stoppers.”