Since the start of the Obama Administration, the Occupational Safety and Health Administration (OSHA) has placed a high priority on establishing regulations for mandatory injury and illness prevention programs, also known as IIPP or I2P2. OSHA recently reaffirmed this intent in the Spring 2013 regulatory agenda. In the latest regulatory planning report, OSHA indicated its intent to publish a notice of proposed rulemaking on I2P2 regulations for the General Industry in January 2014.
It is believed that the OSHA I2P2 regulations will be modeled after California’s I2P2 program, in place since 1991. Since 1991, violations of the I2P2 program are among the most common cited causes of noncompliance in California. To protect their employees and avoid fines and penalties, employers must understand the requirements of I2P2 before OSHA finalizes a Federal standard.
Like California, a majority of U.S. states already require or encourage companies to have an injury and illness prevention program. As a result, many workplaces have already adopted I2P2 requirements. According to OSHA, facilities with these standards in place are among those with the fewest employee injuries. The Agency further claims that workplaces with I2P2 programs boast greater worker satisfaction rates and higher productivity.
What Is Required in an I2P2 Program?
There are six main elements to an I2P2 Program. Employers must:
- Management Leadership: Designate one or more individuals to implement the I2P2 Program. This will ensure that the program is being effectively implemented.
- Worker Participation: Work with employees to develop the program. Encourage workers to report concerns they have dealt with as part of their employment. In this way, the plan will cover important general safety standards, as well as safety standards for each unique location.
- Hazard Identification and Assessment: Investigate, assess, and document workplace hazards and any past injuries and illnesses. Once all existing hazards are identified, workers must be informed of these hazards.
- Hazard Prevention and Control: Create a control plan by prioritizing and controlling all hazards in the workplace. This includes fixing hazards that can be controlled immediately. The new control plan should then be shared with affected workers.
- Education and Training: Train employees on things like how to report injuries, how to recognize hazards, and ways to eliminate or reduce the hazards they encounter. This training must be provided in a language and vocabulary that every worker can understand.
- Program Evaluation and Improvement: Conduct a periodic review to evaluate the success of the I2P2. If necessary, modify the program to improve it.
Does My State Already Require This?
Twenty-seven states already operate their own approved occupational safety and health programs. View a full list of these states here
. Employers or employees should check their required state rules to ensure they meet all requirements.
If you would like more information about I2P2, OSHA published a Fact Sheet in June, which you can view here
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