With the federal Injury and Illness Prevention Program (I2P2) legislation brewing since 2010, companies have been in a steady holding pattern for a few years, wondering if OSHA will ever push the legislation through, thereby drastically changing the safety requirements for American employers. With Obama's second term secured and Dr. David Michaels, assistant secretary of labor for OSHA, articulating that passing I2P2 is his top priority in 2013, it's likely that this change will occur sooner rather than later.
Preparing for the implementation of I2P2, however, presents two main challenges. First, since the exact wording of the legislation is not yet available, safety managers must figure out how best to predict what will be required. Second, creating and managing a comprehensive injury and illness prevention program is an undertaking fraught with complications and challenges of its own. Many safety managers will opt for the path of least resistance by waiting until the legislation is passed to make any program changes. However, we consider this an exciting opportunity to rethink and improve the way safety is performed at your organization, with a newfound focus on proving a meaningful return on investment – an area with room for improvement for all of us in safety.
How will I2P2 impact safety professionals and organizations, and can technology help safety professionals overcome some of the greatest challenges of managing a comprehensive injury and illness prevention program, while adding value to your organization's bottom line?
What to Expect from I2P2
OSHA has provided some indication, in plain English, about what to expect from the legislation – the FAQ page on the Federal OSHA I2P2 Web site states: "The Injury and Illness Prevention Program standard will simply require employers to develop a program to help them find and fix hazards in their workplaces.” For many, this requirement simply may mean retooling their current program; for others it will mean creating an entirely new program from the ground up.
All U.S. employers will be required to have an operative safety program (not just a binder on a shelf or a policy statement in the employee handbook) that identifies and reduces workplace hazards on an ongoing basis. However, Federal OSHA sees this legislation as a performance-based requirement, and will allow the flexibility for each organization to create the program that meets its own specific needs.
While each company's program will include unique processes and elements, OSHA recommends that safety directors include a handful of core components when designing an injury and illness prevention program. Here is a brief summary of these core components (for exact details, visit OSHA's web site at http://www.osha.gov/dsg/topics/safetyhealth):
- Management leadership – Ensure that safety leaders are identified with clearly defined responsibilities.
- Worker participation – When designing safety practices, involve the employees that work in the specific environment for which the practices are created.
- Hazard assessment – Conduct periodic workplace inspections that identify and evaluate work-place hazards.
- Hazard prevention and control – Implement controls for all identified issues, and have a procedure in place to investigate incidents that occur.
- Education and training – Educate employees to understand the exposures for their job and how to avoid them. Re-training must occur anytime their roles or job tasks change.
- Program evaluation and improvement – Clearly and consistently document all steps of the program (also is critical to prove compliance), conduct ongoing monitoring of program failures and successes, prove success through concrete metrics and continually improve the program and its processes.
Overcoming I2P2 Challenges
With this list of core components – not to mention the components unique to each program – that must be applied consistently across numerous tasks and often numerous locations, it is clear that the path from written policy to functional injury prevention initiatives is littered with challenges.
Even if an organization is able to implement efficient processes, directors often find themselves awash in data, with no easy way to identify the insights necessary for making program improvements. The data may have been compiled in disparate formats based on location, or it may be challenging to access all the relevant data, especially if there is no centrally available location to keep records. Safety managers and directors will be unable to identify injury trends, uncontrolled hazards or other key information in a way that will enable the implementation of preventative measures on a wide scale.
However, by leveraging the functional capabilities of well-designed enterprise-wide safety software, safety processes and all their accompanying moving parts can be implemented and managed in an organized and centralized fashion. Automation demands standardization of process, data collection and clean recordkeeping. Furthermore, analysis of program data becomes far more achievable with technology in place.
Consider the example of a retail company, which struggled for years with common hazards and injuries across its numerous locations throughout the United States. The company had a job hazard analysis (JHA) program in place; however, each location conducted JHAs on their own terms, with no centralized repository or standard language for collecting the data. Because each location conducted their JHAs from differing templates using disparate terms, the information gathered could not efficiently be compared and analyzed. As a result, the locations rarely shared data about hazards or the identification or efficacy of implemented controls, and the safety component of the organization ran at a high level of inefficiency.
With the recent implementation of JHA software, however, each site now contributes to the JHA program in a standardized format, and the technology allows all sites to compare and share information. Furthermore, the task of collecting and performing hazard assessments significantly is easier. The safety director now is better able to prioritize risks, more clearly share them with management and take action in a more strategic and cost-efficient way. Newly identified controls also now are compared and shared across the organization, making training, purchasing and prioritization more efficient and effective.
While the above example illustrates a single aspect of an I2P2-compliant safety program, the use of software can assist in the management of many of the core I2P2 requirements. Technology can help drive management leadership by making data more readily available, and therefore more usable for setting focus and gaining the necessary resources. The software system can enable efficient analysis of the entire organization's safety data to understand how best to prioritize resources moving forward, and ensures that the concept of continuous improvement – a crucial component of any successful safety program – becomes an integral part of the process.
John Gargiulo, MS, CIH, CSP, has over a decade of work experience with ergonomics and OSHA organizations. Nick Gargiulo, BS, is the health, safety and environmental specialist at FMC Technologies Schilling Robotics, where he focuses on safety, ergonomics and industrial hygiene. Joe Perry, MPT, has 15 years of experience in risk management and environmental health and safety for Fortune 500 companies and is the founder of Remedy Interactive.