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Written by:
Fred Rine, CEO of FDRsafety and former long-time Managing Director of Safety and Health at FedEx
Jim Stanley, President of FDRsafety and former U.S. Deputy Assistant Secretary of Labor for OSHA
Mike Taubitz, Senior Advisor to FDRsafety and former Global Safety Director for General Motors
Rose McMurray, Chief Transportation Advisor to FDRsafety and former Chief Safety Officer of the Federal Motor Carrier Administration

Here we go again – OSHA on wrong path with injury prevention proposal

May 6th, 2010 posted by Jim Stanley

Jim Stanley

OSHA has come out with more details about its proposed Injury and Illness Prevention Program and it’s now clear to me that what could have been a good idea is headed down the wrong path.

I agree that OSHA should require every company within its jurisdiction to have a safety and health program. But I think that the guidelines should be broad and that the programs should be judged based on the companies’ safety performance. These programs should require total management commitment and employee involvement, and should hold both workers and managers accountable for following safe work procedures.

What the federal government should not do is lay down detailed specifications for how safety and health programs should be constructed. And that is exactly what OSHA is proposing to do.

Businesses vary so much in their operations that it is unrealistic to think that federal specifications will serve the cause of health and safety. Companies need the flexibility to build programs that match their own circumstances.

Here is an excerpt from what OSHA says it has in mind for a proposed Injury and Illness Prevention Program, which it is calling I2P2 for short:

“Based on OSHA’s experience, the agency believes that an I2P2 rule would include the following elements:

“1. Management duties (including items such as establishing a policy, setting goals, planning and allocating resources, and assigning and communicating roles and responsibilities);

“2. Employee participation (including items such as involving employees in establishing, maintaining and evaluating the program, employee access to safety and health information, and employee role in incident investigations);

“3. Hazard identification and assessment (including items such as what hazards must be identified, information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards, hazard assessment and
prioritization, and hazard identification tools);

“4. Hazard prevention and control (including items such as what hazards must be controlled, hazard control priorities, and the effectiveness of the controls);

“5. Education and training (including items such as content of training, relationship to other OSHA training requirements, and periodic training); and

“6. Program evaluation and improvement (including items such as monitoring performance, correcting program deficiencies, and improving program performance).”

Your comments are most welcome.

8 Responses to “Here we go again – OSHA on wrong path with injury prevention proposal”

  1. [...] This post was mentioned on Twitter by The ALZASA Group, The ALZASA Group. The ALZASA Group said: FDRSafety Blog: Here we go again – OSHA on wrong path with injury prevention proposal (I agree with Fred on this one) [...]

  2. Will y’all be participating in the OSHA I2P2 workshops? I will be at the DC one in late June. Hope to see you there. Norman

  3. Success hinges on just how prescriptive OSHA gets in its rule making. Great article and thanks for the link!

  4. [...] OSHA’s proposed Injury and Illness Prevention Program, which has become known as [...]

  5. [...] there is another proposal not yet implemented that OSHA would be well-advised to rethink – the Injury and Illness Prevention Program. Under that plan, announced last spring, all employers under OSHA’s jurisdiction would be [...]

  6. [...] I have blogged previously, while it is an excellent idea to require every company to have a safety program, it is not a good [...]

  7. [...] proposal is the Injury and Illness Prevention Program, which has become known as [...]

  8. Lance says:

    This could cost employers up to $3k per employee!
    Now is not the time to give people more reasons NOT to hire.
    We are over taxed and over regulated already.

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