By Stefan Schumacher
Working in the construction field, serious injuries are a real
possibility, and workplace safety has to be of the utmost concern.
The contractors, suppliers, manufacturers and steel producers we
talk to tend to take the issue very seriously. That being the case,
it may be worthwhile to know more about the Occupational Safety and
Health Administration's development of an injury and illness
prevention program (I2P2) standard.
The I2P2 rule would require employers to implement a program
tailored to the hazards in their workplaces and require employers
to "find and fix" hazards without waiting for a workplace incident,
an issue-specific OSHA standard, or an OSHA inspection.
The American Society of Safety Engineers recently came out in
support of the standard. More from ASSE:
The American Society of Safety Engineers sent a letter to the
House Committee on Oversight and Government Reform Chairman
Representative Darrell Issa reiterating the Society's support for
OSHA's development of an injury and illness prevention program
(I2P2) standard, and sharing the principles the Society will use in
responding to that rulemaking. If leadership in the House of
Representatives decides that oversight of OSHA's I2P2 rulemaking is
needed, the Committee on Oversight and Government Reform could hold
hearings to provide that oversight.
"To be clear, ASSE, like everyone else, waits to see what OSHA
proposes for its I2P2 standard," wrote ASSE President Darryl C.
Hill, Ph.D., CSP. "If the Committee determines that its oversight
of OSHA's activities with regard to the I2P2 is needed, we
encourage you to take the opportunity to listen to our member
safety, health and environmental (SH&E) professionals' view of
such a standard."
"OSHA's final I2P2 must encourage risk-based safety management
that will help employers avoid proscriptive regulations, be highly
flexible so that every industry can meet its requirements without
unnecessary burdens, and be simple enough for the smallest
employers to use without being burdened. We firmly believe OSHA can
write a standard that meets those requirements and will do all that
we can do to help see a final standard that meets our principles,"
Hill continued.
The suggested ASSE set of principles that an I2P2 standard must
contain if it is to succeed are:
1. An I2P2 standard must
encourage a movement in this nation towards risk-based management
of workplace hazards.
2. An I2P2 standard must
recognize the need for involvement of both the employer and
employee in establishing a safe workplace without diminishing or
replacing the overall responsibility for the program by the
employer.
3. An I2P2 standard should
instill in workplaces a commitment to continual improvement and
appropriate periodic review of the workplace I2P2.
4. An I2P2 standard will not
succeed if the end-result is simply a reiteration of the General
Duty Clause to cover hazards not specifically addressed in current
OSHA standards.
5. A standard must address
the qualifications of the individual charged by the employer with
creating a workplace's I2P2. The complex operations and
hazards that many large employers face will require a Certified
Safety Professional (CSP). Many employers will be able to
rely on a "competent person" if a more definitive understanding of
"competent person" can be adopted by OSHA, such as an appropriately
competent person who, through experience and training, is able to
identify actual and potential hazards, understand safe work
practices, design and implement control strategies, and have
demonstrated expertise in establishing and managing a safety and
health program.
6. While all employers
should be covered under an I2P2 standard, the standard must be
scalable, reasonably flexible and responsive to the realistic
capabilities and hazards of employers of all sizes and industry
groups. For some very small employers, or light hazard
operations, if a one or two-page checklist of hazards with
guidelines to control those hazards cannot meet the standard, the
standard will have difficulty succeeding.
7. Federal OSHA should take
into consideration the California I2P2 standard as a basis for a
federal standard. In any case, states like California with an
existing I2P2 standard should be exempt from a federal standard if
their standard is at least as effective as the federal
standard.
8. An I2P2 standard should
be harmonized with the most widely accepted voluntary consensus
standards governing safety and health program management in the
private sector, including ANSI Z10 Occupational Health &
Safety Management System and OSHAS 18000 Occupational
Health and Safety Management Systems Specification, and
efforts should be made to work with the standards development
organizations responsible for those standards.
9. Appropriate training for
OSHA inspection personnel that encourages cooperative as well as
enforcement-directed interaction with employers will be needed to
support the implementation and meaningful adherence to an I2P2
standard.
10. Withdrawing support for Voluntary Protection
Programs (VPP) is not consistent with the establishment of an I2P2
standard. Participation in VPP demonstrates that I2P2s are
effective in addressing workplace risks and developing a shared
employer and employee commitment to workplace safety and
health.