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

OSHA is headed in the wrong direction with its Injury and Illness Prevention Program (I2P2), according to Jim Stanley, a former No. 2 at OSHA headquarters. While he agrees that requiring companies to have a safety and health program is a good idea, he says OSHA is off-course in trying to be very specific about what should be in company plans.

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I agree many companies have unique circumstances that do not fit into cookie cutter solutions and OSHA should work with a broad cross spectrum of industry identifying hazards most commonly found in daily activities.

That stated, it is incumbent on each of us who are professional practitioners in Health and Safety to also understand that this is not cause for wide spread panic, the system will not undergo drastic and draconian changes, it will feature enhancements to existing programs creating more work for our profession. How can that be a bad thing?
The conversion from the old safety and health control outline, to the newer Illness Injury Prevention program, I2P2, is a really a gradual interception from 1989 to the current safety and Accident prevention methods of the I2P2 program. The early I2P2 safety programs may now seem dictatorial and one sided, that of the management and safety team, but now in October 20, 1998, OSHA convened a Business Regulatory Enforcement Fairness Act (SBREFA). A panel drafting the I2P2 Safety and Health Programming rules, consisting of the small entity representatives, SER, developed guidelines to improve the Accident and Illness Prevention Standards. Major guidelines:
1. Management duties goal setting, planning and allocating resources, and assigning and communicating roles.
2. Employee participation, involving employees to establish, maintain and evaluate their program by providing employee access to safety and health information, and providing employees a role in incident investigations
3. Hazard identification and assessment, incident investigation, safety changes within workplaces, emergency hazard assessment and prioritization,
4. Hazard prevention and control and control priorities, follow-up with effectiveness of safety and health controls;
5. Education and training, develop relationships to other OSHA training requirements and periodic training
6. Program evaluation monitoring and performance improvement; correcting program deficiencies,

The idea of better employee and employer collaboration is overdue to take off the ground! Utilizing employee participation to outline safety protocols certainly will not be a negative effort. It is the employee, the work-force themselves they will be protected. For myself, I have always questioned why employees are not consulted and asked questions about their work and what would make it safe and better, or about safety and health ideas to make their work place better. When the workforce is asked for a opinions about safety and health analysis and work protocols, only then will management see and understand the value in a Behavior Based Safety, the philosophy of the, Plan-Do-Check Cycle, to recognize, test, study and then implement procedures and protocols so to help to reinforce the I2P2 concept.
Stake holder concerns about the I2P2 having a huge gap between employee and employer dictation should be greatly narrowed. The usual, relying on a participatory and voluntary plan may make it easier for employers to design a safety and wellness program, but in the end there seems to be only one way for employers and employees to come together; that is to empower employees to assist in designing safety awareness for their own professions. The one glaring obstacle to this philosophy may be the need to increase budgets. This is an obstacle that will always cause concern to business owners. Unfortunately cost of business for safety is real and also in the long run can save lives. Saving live and preventing injuries lessens the insurance rates, but more importantly brings working men and women home at night. I see very little negativity in the I2P2 concept. Business can adjust if they care. I also believe congress should give incentives to increase the I2P2 concept through generous deductions and incentives. After all an incapacitated worker cannot pay taxes! Business must have the support to meet the needs for worker safety; on the other hand, there needs to be a way to insure compliance is made to insure this happens.


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