OSHA first proposed a possible Injury and Illness Prevention Program (I2P2) standard, which would compel employers to "find and fix hazards" in the workplace, in April 2010. Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels has since stressed that developing this standard is one of his top priorities.
California already maintains its own injury and illness prevention program. During a Nov. 2 NSC session, Peter Kuchinsky, senior risk management consultant and trainer, and John Haaf, senior risk management consultant, both from the Association of California Water Agencies Joint Powers Insurance Authority (CWA/JPIA), framed their I2P2 presentation as a "recipe for safety."
The recipe for I2P2 apparently serves up a solid foundation for occupational safety and health. As Haaf pointed out, while most regulations are reactive – created in response to workplace deaths or tragedies – I2P2 is proactive.
"I2P2 is not an additive" to a safety and health program, Haaf said. "It is the foundation. A foundation that you can build a safety program on."
Kuchinsky and Haaf shared the six elements federal OSHA considers necessary components for I2P2:
1. Management leadership;
2. Worker participation;
3. Hazard identification;
4. Hazard prevention;
5. Control education and training; and
6. Program evaluation and improvement.
Kuchinsky told attendees that if they currently have a safety plan, they likely already have I2P2 covered.
Following the Recipe
To demonstrate how I2P2's elements must be properly implemented, Kuchinsky and Haaf called some attendees onstage, outfitted them in I2P2 aprons and chef hats, and encouraged them to mix together various food ingredients that stood in for the I2P2 elements. When the participants were done, their containers overflowed.
"We followed recipe but they didn’t all fit – it didn’t quite work out," Kuchinsky said. Haaf added that this exercise shows that safety professionals can’t simply throw together all the elements of I2P2 and expect immediate success.
When implemented properly, I2P2 can enhance leadership, prevent financial loss, prevent injuries, offer liability avoidance and more, Haaf said. But to achieve these goals, an organization needs strong leadership, communication and recordkeeping and documentation.
"Management has responsibility to set the tone for safety and appoint people in charge who have the training, the equipment, and the authority to [prevent incidents from happening]," Haaf said. Furthermore, the company must encourage a two-way flow of information between workers and supervisors, and workers must feel comfortable reporting any hazards and problems they identify.
Kuchinsky stressed the importance of safety training; hazard assessment and correction; accident investigation and correction; and recordkeeping and documentation. "Did you document it?" he asked the audience. "It must be in writing."
In their second "cooking demonstration," Kuchinsky and Haaf carefully guided participants through the recipe of I2P2 elements. This time, the recipe worked.
"If you have the programs in place, make it part of your culture," Haaf advised. "Make your employees involved in all of it. And supervisors have to be aware of the program and participate in it, too."
To read OSHA's I2P2 reference, visit http://osha.gov/dsg/topics/safetyhealth/index.html.
