RAND Finds I2P2 Works in California, When It's Enforced

With federal OSHA planning its own injury and illness prevention program standard, the new report shows effective enforcement is vital to achieving injury and major hazard reductions.

If employers, safety managers, and workers want to know how OSHA's planned injury and illness prevention program (I2P2) standard would work in the real world, they now have a rigorous study answering the question. John Mendeloff, director of RAND Corporation's Center for Health and Safety in the Workplace, headed the five-member team that wrote it. The study was sponsored by the California Commission for Health, Safety and Workers' Compensation, an agency that is within California's Department of Industrial Relations, as is Cal/OSHA (formally named the Division of Occupational Safety and Health).

The report fills nearly 100 pages, not including appendices. Its key conclusion is that California's I2P2 program can help to prevent worker injuries, but only if it is adequately enforced. The authors also say compliance "improves substantially after the first inspection" with the requirements to have a written I2P2 document, to document hazard surveys, and to provide employee training, but compliance in first-time inspections hasn't improved over the years. Thus, either outreach programs haven't worked as hoped "or the deterrent posed by current inspections is not very strong, or both," they write. The median penalty for violating the requirement for a written program is just $140, and the annual probability of inspection has declined by almost half since the California rule took effect in 1991, they report.

They say in interviews, Cal/OSHA leaders indicated their inspectors usually didn't probe to discover whether or not employers had met the specific I2P2 elements. Essentially, inspectors normally looked at the employer's written document and went no further, if the employer had one.

The California program has been the most frequently cited Cal/OSHA standard each year since 1991 and is cited in about 25 percent of all Cal/OSHA inspections.

Dean Fryer, a DIR spokesman, said Jan. 27, "We are still reviewing the details of the study and can't make a comment at this time" about the study's findings.

Mendeloff and his co-authors say in a footnote that the fear employers have expressed about the potential OSHA rule –- that the standard would make it easier for OSHA compliance officers to cite willful violations –- isn't happening in California because Cal/OSHA very rarely cited willful violations. This happened only 31 times in more than 55,000 inspections during 17 years from the sectors examined by the authors. (They were inspections through 2006 of manufacturing, transportation, utilities, wholesale trade, and health care employers.)

"We found the safety effects to be real, but not very large," Mendeloff said in the RAND news release. "We think that the most important reason for the limited impact of this program is that inspectors often did not go beyond a review of the employer’s written document."

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