Adequate Enforcement of Cal-OSHA’s I2P2 Can Reduce Injuries

Cal-OSHA’s Injury and Illness Prevention Program (I2P2) can lead to a reduction of injuries and illnesses, but only if inspectors do more than review employers’ written document. The findings, from a study by RAND Corp., could have significance for the implementation of a federal I2P2 program.

The California I2P2, which became effective in 1991, requires all employers to adopt certain procedures. These include communicating to employees about risks, carrying out regular workplace surveys and abating the hazards that are found, training employees about how to work safely and investigating the causes of the injuries that occur. A new study from the RAND Corp. found that the California occupational safety program can help prevent injuries to workers, but only if it is adequately enforced.

The first-ever evaluation of the California Injury and Illness Prevention Program found evidence that the program reduces workplace injuries, but only at businesses that had been cited for not addressing the regulation’s more-specific safety mandates.

“We found the safety effects to be real, but not very large,” said John Mendeloff, lead author of the study and a senior public policy researcher for RAND, a nonprofit research organization. “We think that the most important reason for the limited impact of this program is that inspectors often did not go beyond a review of the employer’s written document.”

When California Division of Occupational Safety and Health inspectors did investigate further and found failures to comply with provisions to train workers, identify and abate hazards and investigate injury causes, the average injury rates at targeted businesses declined more than 20 percent in the following 2 years, Mendeloff said.

However, these provisions were cited in only about 5 percent of Cal-OSHA inspections, RAND researchers found. In the other 20 percent of inspections where a violation of the rule was cited, it was only for the section requiring the employer have a written program. Such a violation carries an average penalty of $150.

The program has been the most frequently violated Cal-OSHA standard in every year since 1991, being cited in about 25 percent of all inspections. The California program also is one possible model for federal OSHA’s current rule-making effort to develop a safety and health program rule.

Enhancing Compliance

The RAND study notes that higher penalties for noncompliance with the program and more extensive activities to make employers aware of their obligations could enhance compliance. However, two other approaches could have a greater impact: having inspectors conduct more in-depth assessments of employer programs and having inspectors link the violations they find and the injuries that have occurred to the program by asking “Why weren’t these prevented by your Injury and Illness Prevention Program?”

The study found that employers who were cited for violations of the I2P2 in one inspection usually came into compliance in future inspections. However, the overall percentage of inspections finding program violations did not change over time.

Moreover, the percentage of first-time inspections finding violations was the same in 2007 as it was in 1993. These findings indicate that information about the program requirements failed to reach many employers, they failed to be convinced to comply by the threat of penalties, or both.

Cost Savings

The 20 percent reduction in injuries following citations for the specific requirements of the California I2P2 translates to about one injury per year at a workplace with 100 employees. Most estimates of the value of preventing a work injury are in the range of $15,000 to $50,000. The RAND study did not find evidence that the statewide workplace fatality rate had decreased after the introduction of the program standard.

The study of injury effects was carried out using several different injury data sets. In all cases, inspections were included in the data if “before and after” injury rates could be obtained for the inspected business. The study was limited to workplaces in the manufacturing, transportation, utilities, wholesale trade and health care sectors. It included inspections through 2006.

The study, “An Evaluation of the California Injury and Illness Prevention Program,” can be found at http://www.rand.org. Other authors of the study include Amelia Haviland and Regan Main of RAND, Wayne B. Gray of Clark University and the National Bureau of Economic Research and Jing Xia, formerly of RAND.

The study was sponsored by the California Commission for Health, Safety and Workers’ Compensation, a public body with management, labor and public representatives located in the state’s Department of Industrial Relations.

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