OSHA Announces Stakeholder Meetings for Injury and Illness Prevention Programs (I2P2)

OSHA invites interested parties to participate in informal stakeholder meetings on Injury and Illness Prevention Programs, referred to as ``I2P2.'' OSHA plans to use the information gathered at these meetings in developing an Injury and Illness Prevention Program proposed rule. The discussions will be informal and will provide the Agency with the necessary information to develop a rule that will help employers reduce workplace injuries and illnesses through a systematic process that proactively addresses workplace safety and health hazards.

DATES: Dates and locations for the stakeholder meetings are:

• June 3, 2010, 8:30 a.m. to 4:30 p.m., in East Brunswick, NJ.
• June 10, 2010, 8:30 a.m. to 4:30 p.m., in Dallas, TX.
• June 29, 2010, 8:30 a.m. to 4:30 p.m., in Washington, DC.

• Possible regulatory approaches. 
• Scope and application of a rule.
  • Covered industries.
  • Covered employers (size, high/low injury rates).
  • Covered hazards.
  • Relationship to existing OSHA requirements.
• Organization of a rule.
  • Regulatory text.
  • Mandatory or voluntary appendices.
  • Other standards incorporated by reference.
• The role of consensus standards. 
• Economic impacts.
• Any additional topics as time permits.

• In light of the ANSI Z10 standard, the OHSAS 18001 standard, and OSHA's 1989 guidelines, what are the advantages and disadvantages of addressing through rulemaking a systematic process that proactively addresses workplace safety and health hazards? 
• 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).

• Are these the appropriate elements? Which elements are essential for an effective approach? Should additional elements be included? 
• How can OSHA ensure that small business employers are able to implement and maintain an effective I2P2? 
• Should an OSHA I2P2 rule apply to every business or should it be limited in some way based on an employer's size, industry, incident rates, and/or hazard indices? 
• To what extent should OSHA rely on existing consensus standards in developing a rule? 
• How can OSHA use state experience with injury and illness prevention in developing a rule? 
• What mechanisms have been found to be effective for enabling employees to participate in safety and health in the workplace? 
• Given the variety of names used to describe processes to reduce injuries and illnesses in the workplace, what is the most appropriate name for OSHA to describe this topic?