OSHA Moving Ahead With Injury and Illness Prevention Program
OSHA’s number one standard priority is the so-called I2P2 injury and illness prevention program standard, aka the “find and fix” rule. This would involve identifying and controlling hazards as well as planning, implementing, evaluating and improving processes and activities that protect employee safety and health. The program calls on employers to “find and fix” workplace hazards proactively, which can make it easy for employers to be found noncompliant.
There is concern in the manufacturing community that no matter how often the employer trained employees, or however many safeguards were put in place; it would not be enough if an accident happened. Some are calling it a 20/20 hindsight standard. Injury and illness prevention programs already are required in California, which has a state OSHA Plan; other states have safety programs and safety committee requirements in connection with their workers compensation laws.
According to OSHA, the I2P2 regulation would build off already-issued voluntary guidelines, such as OSHA’s Safety and Health Program Management Guidelines, and other approaches, such as the agency’s Safety and Health Achievement Recognition Program. Consensus standards such as American National Standards Institute/American Industrial Hygiene Association Z10 and Occupational Health and Safety Association 18001 would also be used to assist in the rulemaking process.
The agency has engaged the Eastern Research Group to prepare a “Safety and Health Practices Survey.” The questionnaire attempts to determine how safety is managed in various workplaces and may hold clues to potential program elements that may be included in any I2P2 that is adopted. It will be sent to employer establishments selected at random from a publicly available database. The survey is currently being reviewed by the Office of Management & Budget.
Throughout the summer, the agency conducted a series of stakeholder meetings devoted exclusively to soliciting input to help OSHA formulate this rule. AFS and some member companies attended the stakeholder meetings. The draft proposed regulatory text for I2P2 should be ready for publication by year’s end. OSHA has stated publicly that it plans to convene a SBREFA Panel for its Injury and illness Prevention Program in the summer of 2011. AFS has requested a seat on the panel and has submitted the paperwork for a small foundry member company to participate given the huge impact this rule would have on the foundry industry. The AFS Washington office will be assisting the AFS member in the panel discussions. We will continue to update you on this important initiative.
For more information, contact Stephanie Salmon, Metalcasters Alliance for Government Affairs Washington Office, 202/842-4864 or ssalmon@afsinc.org.
