I2P2: The consultant’s full employment act

My focused concern with the current OSHA administration began with their absolute arrogance at the 2009 PDC of ASSE.

My continuing concern is over their proposal to make I2P2 an OSHA standard. I am absolutely opposed to this as a standard. My opposition is not to I2P2 itself. Safety professionals designed those concepts. When I took my first safety job in 1970, there was an I2P2 program already in place, designed by my predecessors.

My reasons for opposition to the standard:

It will further identify our professionals as an extension of OSHA without accomplishing safety benefits of any significance or sustainability. It will severely handicap our professionals’ value add proposition to our customers. For safety professionals, compliance is Basic. How can our professionals make a value add case for Excellence if everything we are identified with by our customers is compliance--Basic?

Sites with safety staff, of any kind, comprise no more than 1% of the work sites in this country. Without a safety staff, site personnel struggle to get the safety job done. They manage to do some things that are simply defined as “do this” and “do that” but beyond that level is hard. So the ultimate outcome will be just more and more citations which will satisfy the “new sheriff in town” political approach of the current OSHA administration but do little else.

With the OSHA administration empowered by the courts to issue any “reasonable” interpretation, and I2P2 standard will simply open the door for a political agenda filed day in compliance directives and letters of interpretation. Safety will indeed be controlled and dictated from 200 Constitution Avenue.

Recognizing that the forces for enacting this regulation are strong, I would then advocate the following conditions for the regulation as a fall-back position:

No compliance directives or letters of interpretation can be issued by OSHA for this standard. It has to be written to stand on its own. Now there is a novel concept. Safety professionals should work to stop the potential for political agenda mischief and standard making without the participation of the regulated community. This OSHA administration is fully capable of such mischief.

Any site that has one or more staff members who are: a member of ASSE, AIHA, CHMM or are a member of the Society of Human Resource Management with at least a 30 percent job description in safety and health --- and these safety staff members demonstrate continuing education through attendance educational professional meetings, on line webinars, professional development conferences, etc. will be exempt from enforcement of the I2 P2 standard.

I2P2 as a consultant’s full employment act

Yes, it could be. And I am a consultant who could be hired and benefit. Here is the problem: sites with safety staffs should not need to hire a consultant. Those sites that do not have a safety staff will hire the consultant to write them an I2P2 plan. But then, once the consultant departs, there will be no follow up and implementation.

Just talk to the loss prevention insurance company safety consultants who visit these sites with no safety professionals. What do they find on repeat visits? Little progress. It is easy for me to say this since I have prepared myself financially for retirement but I am really not interested in making that kind of money that writes programs that sit on the shelf. I have quit writing programs for clients because they often end up on the shelf. Some have gone on to other consultants who will do that for them.

I2P2 in California

If it really is a paperwork exercise, why are the number of citations high? And perhaps more fundamentally, what is it accomplishing for safety? If sites have safety professionals on staff, no problem. If not, they will not be able to keep up on a sustained basis. That is where the citations come from.

This reinforces my premise that I2P2 as regulation is merely a political agenda item for the current OSHA administration. We don’t need to depend on a court challenge. We need to stop it before it gets there.

How OSHA is regarded among safety professionals

There are some levels of concern about OSHA that intensify with particular issues — such as for me in I2P2 and arrogance at ASSE PDCs — but I don’t detect a general loathing of OSHA among my professional colleagues.

I don’t resent OSHA. It has a legitimate place. Safety is certainly more visible than it would be otherwise. The web site is an exemplary source for safety and health information. There are good things that OSHA does. I just have little patience for using OSHA for political agendas from those appointed to lead OSHA.