OSHA's Proposed I2P2 Rule For Employers

March 3, 2012
Proposed by OSHA in 2010 the Injury and Illness Prevention Programs (I2P2) has not been implemented to date but it is still on the OSHA priority list. In January 2012 OSHA issued a white paper on I2P2 and announced that a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel would meet within two months.

David Michaels, assistant secretary of labor for OSHA, claims the program will benefit workers and business but employers are skeptical. The proposed I2P2 standard would require employers to implement programs to identify and correct health and safety hazards even where no injury has been reported and where no other standards exist. Due to its ambiguous nature the standard will be subject to a broad interpretation and offers OSHA another avenue of enforcement. OSHA is downplaying the employers cost of administering their individual program.

Michaels says that injury and illness programs are better than incentive programs. The data is skewed by employers who drive for low injury reporting and safe work is more important than reporting.

The Building and Construction Trades Department of the AFL-CIO will have a hand in developing an I2P2 rule specific to the construction industry.

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OSHA's White Paper: