OSHA Web Chat Puts Focus on Injury and Illness Prevention Program

Jan. 6, 2011
In a Jan. 5 Web chat to discuss the 2010 fall semi-annual regulatory agenda, OSHA Administrator Dr. David Michaels and staff asserted that the potential Injury and Illness Prevention Program (I2P2) is the agency’s highest regulatory priority with “the greatest impact in terms of preventing workplace injuries, illnesses and fatalities.”

The I2P2 proposal, which would require employers to find and fix workplace hazards and is listed on the agenda in the pre-rule stage, garnered multiple questions during the Web chat. Michaels and other agency staff explained that I2P2 would cover all workplace hazards; companies with effective safety and health programs may already comply with future I2P2 requirements; and small- and medium-sized employers may stand to benefit the most from this rule.

When asked how the agency intends to address today’s many pressing occupational health and safety concerns, Michaels and staff acknowledged that OSHA cannot have a standard for every hazard. The agency therefore is seeking a solution by moving toward a possible I2P2 rule and increasing use of the general duty clause.

“This is a very important project and it is important that the agency get it right,” Michaels and staff said about I2P2. “While we have accomplished a lot since we announced this project in the Spring 2010 Regulatory Agenda, we have much more to do. We want to gather as much information as possible in advance of SBREFA to make the process as productive as possible.”


Safety stakeholders have had permissible exposure limits (PELs) updates in their sights for a long time. While OSHA did not address the complex problem of updating the long-outdated PELs in the regulatory agenda, staff said that PELs still are a key priority for the agency.

During the chat, agency staff pointed out that OSHA held a stakeholder meeting of labor, business and academic leaders in June 2010 to discuss PELs options. The agency also assembled a PELs task force and held a Web forum so stakeholders could pinpoint the chemicals they thought OSHA should focus on.

“OSHA is now analyzing all the information we have received to determine our next steps” to address PELs, Michaels and staff said during the chat.

Combustible Dust

A combustible dust regulation is in the proposed rule stage, with plans to initiate an SBREFA in April. This rule was proposed Oct. 21, 2009, and the comment period closed Jan. 19, 2010. OSHA has conducted research, site visits and stakeholder meetings on combustible dust. During the chat, OSHA staff acknowledged this is a “complex issue” and pledged to “work as expeditiously as possible” to develop a combustible dust final rule.

“Combustible dust rulemaking is a complex project that could affect a large number of industry sectors. Consequently, the agency must conduct considerable research to ensure that the resulting standard effectively protects workers and meets legal requirements,” Michaels and staff explained during the chat. “While OSHA proceeds with its research and deliberations, we continue to actively enforce relevant standards and the general duty clause to address this serious hazard.”

The 2010 fall semi-annual regulatory agenda outlined the anticipated final rules for Confined Spaces in Construction, General Working Conditions for Shipyards, Electric Power Transmission, Hazard Communication and Standards Improvement. The agency also plans to publish final rules for several whistleblower regulations; intends to propose a rule for silica; and included two new legislative initiatives for the construction industry: Backing Operations and Reinforcing and Post-Tensioned Steel Construction.

“This agenda continues to build upon the Secretary Hilda Solis’ regulatory strategy of plan, prevent, protect; and solidifies the Agency’s commitment to strengthening the worker’s voice in the workplace,” Michaels wrote in the live chat. “Improving access to information establishes a solid foundation for making workplaces safer.”

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