Working Safely
( Editor’s note; Many of you know Steve Sayer as a friend or neighbor here in Aliso Viejo. He was asked by meatingplace.com to write on safety issues for their online blog. Meatingplace.com is an on-line community for red meat and poultry processors
in North America. Membership is FREE. Meatingplace.com is published by the Marketing & Technology Group.)
I2P2. Kind of sounds and reminds one of that ergonomically rotund, short in stature, three-legged tin-can named R-2 D-2 of yesteryear. Movie audiences liked R-2 D-2 because it was small, cute and appeared cuddly; all from a distant galaxy – a long, long time ago.
Unfortunately most people not familiar with federal OSHA’s burgeoning I2P2 standard won’t find I2P2 small, cute or cuddly; and certainly not a work of any fiction.
I2P2 (also known as an injury and illness prevention program (IIPP)) is federal OSHA’s most recent ‘back to the future’ sequel to its original 1989 voluntary safety and health program management guidelines; including among other regulatory efforts, California’s injury and illness prevention program that went into regulatory law a long, long time ago; the last century in fact – on July 1,1991; in a state near you.
Under present California law (of which federal OSHA could base a measurable share of its proposed I2P2 final ruling upon) employers are required to establish, implement and maintain a written and effective IIPP. Although quantitative data on the effectiveness of state IIPP programs are not yet available, OSHA believes there is substantial evidence that such programs, including other similar processes, are effective. A rand corporation study is presently underway to evaluate the efficacy of California’s 1991 IIPP standard.
Contained within the May 4, 2010 federal register, OSHA had requested input to its development of a nation-wide IIPP ruling. The American Industrial Hygiene Association (AIHA) answered OSHA’s calling with a diversified task force of safety professionals to help promulgate an IIPP. On Dec.17, 2010 the AIHA published a white paper which proffered guidance and recommendations for OSHA’s rule making efforts for an I2P2 standard which can be viewed by tapping here.
In short, the proposed I2P2 standard would require all employers (with employee participation) to become more pro-active by developing and implementing a written and effective IIPP that minimizes worker exposure to safety and health hazards at the workplace. Working from a generic template, the standard would require, broadly, that each IIPP be custom tailored to the unique hazards that exist at each individual workplace nation-wide.
The AIHA task force had found that ‘the six core elements’ for an effective I2P2 program that were published in the May 4, 2010 federal register by OSHA were, ‘sound and correct.’ Those six core elements (as numbered below) are analogous to California’s eight core elements to its IIPP.
1. Management commitment and leadership
2. Employee participation
3. Hazard identification and assessment
4. Hazard prevention and control
5. Education, training, competence and awareness
6. Program evaluation and improvement
Contained within OSHA’s semi-annual agenda that was published in the federal register on Dec. 20, 2010, the I2P2 proposal was said to be at the tip-top of Dr. David Michael’s (current OSHA administrator) priority list.
“We are asking employers to ‘find and fix’ the hazards in their workplaces,’” said Dr. Michaels. “The program (I2P2) does represent a major paradigm shift for OSHA. This proposed standard could change workplace health and safety on a level we haven’t seen since OSH Act of 1970.”
What’s your take of I2P2?
Write to Steve at;
meatingplace.com
January 12, 2011
