With all the fanfare OSHA’s administrator, Dr. David Michaels, has made over his “Injury and Illness Prevention Program” (I2P2) as being “OSHA’s highest rulemaking priority,” one has to wonder “Why?”
Few of us have had the pleasure of laying our eyes on the draft proposed regulation (whatever happened to the so-called “unprecedented levels of openness in Government” to create a “Transparent, Participatory, and Collaborative Government” pledge?)1, but with the recent OSHA White Paper, Fact Sheet, and sparse FAQs on its I2P2 website, one can begin to contemplate the reality of this regulation.