OSHA Sets Two More I2P2 Stakeholder Meetings

Registration is closed on the June 29 meeting in Washington, D.C., and with more people wanting to participate, there will be one more Washington meeting and one in Sacramento about OSHA's biggest priority at the moment.

Recent speeches by OSHA chief Dr. David Michaels, Ph.D., MPH, make it clear that promulgating a final rule to require employers to have Injury and Illness Prevention Programs (I2P2) is his current top priority. Michaels has said he hopes such a rule will transform the safety cultures of companies around the country.

OSHA held stakeholder meetings earlier this month in East Brunswick, N.J. and in Dallas. A third one -- already filled -- will take place June 29 in Washington, D.C., and the agency announced Tuesday it will host another one July 20 in Washington at the Capitol Hilton Hotel, 1001 16th St. NW, and a fifth Aug. 3 in Sacramento because people continue to ask to participate.

These are informal sessions to help the agency understand what the rule should contain, according to OSHA. Deadlines to confirm registration at the fourth and fifth meetings are July 6 and July 20, respectively. You can register at https://www2.ergweb.com/projects/conferences/osha/register-osha-I2P2.htm or fax your request to 781-674-2906, labeled "Attention: OSHA Injury and Illness Prevention Program Stakeholder Meeting Registration."

Tuesday's announcement of additional meetings included a history of OSHA rulemaking along the lines of I2P2. Starting in October 1995, OSHA worked on a safety and health program rule. It developed a draft by late 1998 and convened a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel for it, but the proposed rule was never published.

The announcement said OSHA wants these stakeholder meeting discussions to focus on major issues such as:

  • 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

These elements are likely to be included in a proposed I2P2 rule, according to the agency:

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)

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

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