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AIHA Releases White Paper on OSHA’s Injury and Illness Prevention Program

At the request of OSHA, the American Industrial Hygiene Association (AIHA) released a white paper concerning OSHA’s Injury and Illness Prevention Program (I2P2), a potential new rule that would require employers to find and fix hazards in their workplaces.

AIHA recognizes that under the Occupational Safety and Health Act of 1970, employers are responsible to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” Aligning with this act, AIHA members are dedicated to providing occupational health and safety expertise and management program support to ensure that worker health and safety risks and hazards are identified and properly mitigated, if not eliminated.

The new white paper expresses AIHA’s support for an I2P2 standard: “AIHA believes that an I2P2 standard is consistent with the agency’s statutory mandate and mission.”

The paper also recognizes, however, “the complexities of a performance-based approach” and asserts that the rulemaking process must “first determine and specify management processes that employers will be required to use in an I2P2 standard.”

The AIHA paper stresses that an I2P2 standard should:

  • Be broad in scope and “have the widest industry and employer coverage that the rulemaking process can tolerate;”
  • Not exempt workplaces based on size or low injury rates;
  • Cover contract/leased labor and multi-employer worksites;
  • Be aware of potential documentation burdens on small employers;
  • Not make exemptions based on employer-generated data;
  • Consider exemptions for VPP Star workplaces.

According to the white paper, such a standard should support other OSHA standards and should be concise and easily understood. The paper also pointed out that an I2P2 standard is expected to be cost-effective for employers; AIHA is willing to host a working symposium on the issue of economic impact.

The full white paper can be downloaded as a PDF at

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