AIHce 2011: The Ins and Outs of I2P2 and Worker Involvement

The Injury and Illness Prevention Program (I2P2) is still considered OSHA’s top rulemaking priority and safety stakeholders and businesses alike are curious what, exactly, would make up the rule’s content and scope. Several leaders discussed I2P2 in a roundtable discussion May 16 at AIHce in Portland, Oregon.

William Perry, CIH, deputy director of OSHA’s Directorate of Standards and Guidance, told AIHce attendees that the agency still is in the early stages of developing this rule and does not yet have a date for a proposal. The agency currently is conducting research and holding meetings with stakeholders.

On the basic level, an I2P2 standard would prompt employers to identify and control hazards and implement processes to protect the work force. In other words, such a program is designed to compel employers to “find and fix” hazards.

“This is a tool,” Perry said. “A tool that employers can set up and use to better and more systematically find and abate workplace safety and health hazards … I think there’s pretty widespread recognition that these programs can make a difference in the workplace in terms of reducing safety and health risks.”

While the agency has not yet made decisions on I2P2’s scope or content, Perry outlined some of the core elements OSHA likely would include in the proposal. These elements include:

  • Management duties;
  • Employee participation;
  • Hazard identification and assessment;
  • Hazard prevention and control;
  • Establishing priorities and track progress for controlling hazards;
  • Education and training;
  • Program evaluation; and more.

Worker Involvement

Bill Kojola, who works in the safety and health department at AFL-CIO, participated in the roundtable discussion and pointed out that “a worker safety and health program will have no legs unless management makes a commitment to making it happen.” That includes receiving input from employees themselves.

“Workers should be involved in developing the program,” he explained. “Workers are going to have views on good parts of the program and bad parts of the program. You want to make sure you tap into that knowledge and expertise while you’re revising.

“We shouldn’t let management develop exclusively the agenda for the meetings,” he added. “The agenda of workers is not necessarily going to be the same agenda as for management.”

For an injury and illness prevention program to be successful, Kojola said it must accomplish the following goals:

  • It must encourage reporting – not just injuries, but ideas to control hazards.
  • It must shift from lagging to leading indicators.
  • It must get at root causes.
  • It must make use of documentation.
  • It must remove barriers to worker participation.

Barriers to worker participation include certain types of incentive programs, including the type that reward employees for a specific amount of time worked without injury (thus discouraging reporting) or those that punish employees for becoming injured or ill. As long as these types of incentive programs are present, true and transparent worker involvement in safety programs will not happen.

“[I2P2] should ultimately find and then fix hazards,” Kojola said. “That’s the most important piece from a worker point of view … that’s the most important part of an injury and illness prevention program from all of our perspectives.”

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