On the one hand, providing business (and government) leaders with a template (I2P2) on “what good looks like” in terms of leadership, participation, organizing, facilitating, and measuring organizational safety systems using contemporary strategies makes sense. Many organizations, with or without a staff safety person (especially if that person has safety as a collateral duty) will benefit from this form of guidance. I look for I2P2 to be a performance management standard, rather than a set of complex technical requirements – maybe I am incorrect here. I suppose we’ll need to see more detail before making up our minds about exactly what Michaels and company have in mind.
Here’s my concern (I readily admit that it has been about 7 years since I was intimately associated with the regulatory personnel from OSHA): to my knowledge, the CSHOs historically have had little working knowledge of and expertise in developing, organizing, managing, influencing and sustaining a contemporary safety management system. Consequently, how a CSHO would assess the status of a contemporary safety management system could be an interesting exercise and be replete with contentiousness and disagreement. Should an organization be cited and the case go before a commission, I’m not sure how they would see the issues. We need to help them take amorphous ideas and draft a standard that is flexible, reasonable, concise and clear – not one of OSHA’s strong points, especially with all the special interests they have to contend with.
Whether or not OSHA would view citations in this area as a “target area” so they could show how adept the administration is at catching the “laggards” who allegedly refuse to develop a sensible safety management system -- complete with adequate internal systems, structures and processes -- is anyone’s guess. One would hope that the administration would view the I2P2 area as being different from the body of technical safety standards currently in existence. I recall the Eula Bingham administration, where it appeared to be a war between organizations and the government. That could happen, but perhaps with a strong voice comprised of all the professional safety organizations and the NSC, maybe we can influence a more sensible approach.
You might agree that using ANSI Z10 and/or ISO 14000 as a model on which to build a contemporary set of guidelines would make sense. Yet, I haven’t heard a peep from Michaels and company about thoughts and direction. Makes one wonder how they intend to move this process forward. I guess we’ll have to “keep our ears to the rail.”