OSHA’s I2P2 Standard Proposal



On January 13, OSHA released a white paper to support its case for the adoption of a federal Injury and Illness Prevention Program (I2P2) standard for all businesses – regardless of size or industry. First introduced in April 2010, the OSHA proposal of an I2P2 standard has since become a top focus for OSHA Administrator Dr. David Michaels.


The white paper begins by pointing out that I2P2 programs have proved effective in helping companies reduce injuries, illnesses, and fatalities, and that the adoption of such a program can also help develop “a transformed workplace culture that can lead to higher productivity and quality, reduced turnover, reduced costs, and greater employee satisfaction”. To make its case for the I2P2 standard, the paper points to the positive experiences of not only other nations, but the thirty-four American states, the U.S. Department of Defense, and various companies that already encourage or require the implementation of injury and illness prevention programs. The paper also details the costs of workplace injuries and fatalities, offers proof that I2P2 programs can improve the bottom line, and provides case studies on OSHA’s existing Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP).


The paper notes that while some 2,400 companies are currently enrolled in OSHA’s VPP and another 1,500 smaller-sized companies are enrolled in OSHA’s SHARP, workplace injury and illness rates are still extremely high. The paper states staggering annual statistics of an estimated 4,500 fatalities (12 per day), four million serious injuries, as well as tens of thousands of deaths or debilitations that have resulted from cases of occupational illness. In reality, the active participation of less than 5,000 companies in the voluntary but beneficial VPP and SHARP programs seems minor in light of the millions of other U.S. businesses that exist. OSHA argues that it will take the implementation of the I2P2 standard to yield significant decreases in current workplace injury and illness rates, encouraging more employers to take the measures needed to develop a workplace safety culture that emphasizes and reinforces the notion of safe work procedures at all times.


OSHA encourages the development of I2P2 programs “based on simple, sound, proven principles”, noting that no specific I2P2 model will be applicable all companies. Instead, I2P2 programs should be flexible, molded to the specific needs of the company, workforce and industry (among various other factors), and such programs should not be developed beyond the capabilities or scope of the company. Regardless of the company, OSHA notes that I2P2 programs have proven most successful when built on the following concepts: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement. While the specific focus of each concept may vary depending on the industry or the nature of a company’s work, the application of these concepts in some way will yield wide-ranging benefits, no matter how large or small the company.


The paper points to the positive impact of I2P2 programs, which encourage businesses to achieve and maintain improved compliance with existing regulations, and to create and uphold a workplace culture that revolves around safe practices and injury reduction. As the paper notes, the cost benefits of I2P2 are numerous and multi-faceted. For those companies who implement an I2P2 program where one did not exist before, OSHA estimates reduced injury rates of 15 to 35 percent. Other cost benefits include the reduction of workers’ compensation costs in recognition of the effort to improve the health and safety of the workplace, and indirect costs saved through lost time, productivity, turnover rates, insurance costs, etc, that may be incurred as a result of some workplace incident.


The OSHA white paper adeptly describes the proactive nature of I2P2 programs, which “provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to a significantly improved workplace health and safety environment”. The adoption of the I2P2 standard could yield countless benefits for workplaces of all industries and sizes, encouraging employers to strengthen the means in which they maintain the safety, security and healthfulness of their workforce, thereby decreasing injury, illness and fatality stats and fostering a greater sense of security amongst employees, employers, and even the general public as a whole.


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