I’m a long-time proud member of the Accredited Standards Committee that developed and recently updated ANSI Z10, the U.S. National Standard for Occupational Health and Safety Management Systems. On the surface, that would likely make me a fan of I2P2, OSHA’s proposal to require every company in its jurisdiction to have a safety management program.
For those who read this blog, that in turn may prompt the question, “What gives? Jim Stanley has blogged here about the problems he sees with I2P2 – which stands for Injury and Illness Prevention Program. Is there a disconnect here?
The simple answer is, “No.” I don’t agree with I2P2 for all the reasons Jim has cited in the past, but also for another very fundamental reason. Those organizations that desire to have a health and safety management system will find excellent guidance in Z10. Z10’s guidance includes both mandatory language (“shall”) as well as recommending language (“should”). However, the decision about whether a company uses Z10 is voluntary. OSHA’s I2P2, on the other hand, would be another regulation that would likely be a major battleground between government, industry and unions.
The best alternative
What I’d really like for the U.S. to do is support the International Labor Organization’s Guidelines on occupational safety and health management systems (ILO-OSH 2001).
These guidelines were developed by government, industry and labor representatives and offer a collaborative approach for each nation – and for organizations. The free ILO document is what I call a performance guideline – it suggests the “what” without getting into the “how.” Each organization is free to choose the best method of implementing its custom tailored system.
ILO also has some important language that should be embraced by OSHA, industry and the labor leaders of this nation:
“2.2. National guidelines
“2.2.1. National guidelines on the voluntary application and systematic implementation of OSH management systems should be elaborated based on the model provided in Chapter 3 (Chapter 3 provides guidance for organizations), taking into consideration national conditions and practice….”
Is it too late to think that this nation might adopt a performance based approach already in use by other countries for more than a decade? By the way, you will find many similarities between Z10 and ILO. My fear is that I2P2 will erode two already excellent efforts that provide guidance for H&S management systems.
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