I2P2 Still Far Off, GHS Near

OSHA's Dr. David Michaels joins NIOSH Director Dr. John Howard and Michael Silverstein, assistant director of Washington State's state plan agency, for an NSC panel discussing the value of safety management systems.

PHILADELPHIA -- The Nov. 1 session at the 2011 National Safety Congress & Expo featuring OSHA's Dr. David Michaels, NIOSH Director Dr. John Howard, and Michael Silverstein, assistant director of the Washington State state plan agency, was billed as a discussion among top safety authorities' leaders on safety management systems. It delivered and occasionally, went beyond that topic.
 
Michaels said the next step in OSHA's hoped-for Injury and Illness Prevention Programs (I2P2) rule will be issuing a new OSHA white paper. He also said the Department of Defense's I2P2 initiatives are working well and are cutting the services' incident rates. (Michaels also said he expects the GHS rule, which was submitted to OMB on Oct. 25, to be approved by OMB for publication soon.)
 
"We definitely don't want to use [I2P2] to double-ticket," he said. "I know that's been a concern."
 
Howard, citing California's 20-year-old I2P2 regulation, said its linchpin is the requirement that employers' programs be "effective." Cal/OSHA trained its compliance officers on how to assess programs' effectiveness, he said.
 
Silverstein said the same effectiveness requirement exists in Washington State's I2P2 regulation. He suggested requiring employers to fine and fix hazards and said their efforts should be monitored and certified on a regular basis, although not necessarily by OSHA.
 
A questioner in the audience said DoD's rules create a very simple and useful I2P2 scheme, and Michaels said OSHA has examined those rules. Any I2P2 standard that employers choose to follow will be acceptable in OSHA's eyes because its goal is continuous improvement by the regulated community, he said.
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