I2P2

December 7th will be the first meeting of the Injury and Illness Prevention Program workgroup. The idea of the socalled I2P2 is not new. In 1991, California developed its own Injury Prevention Program, and the State of Minnesota, for example, requires "A Workplace Accident and Injury Reduction Program (AWAIR)".

In August 2010, a stakeholder meeting discussed a possible I2P2 based on OSHA's Voluntary Protection Program, Safety and Health Achievement Recognition Program, ANSI Standards and OHSAS 18001 series (by the British Standards Institution), as well as state programs such as CAL OSHA's Injury Prevention Plan. OSHA hopes to be able to present the rulemaking on I2P2 within the next three years.

Consensus standards have been developed by the American National Standards Institute and the American Industrial Hygiene Association. The ANSI/AIHA Z10 standard is based on the Deming cycle (plan-do-check-act) and the concept of continual improvement which is also major part of the ISO 14000 process standard series focusing on Environmental Management Systems. The American Industrial Hygiene Association (AIHA) believes that the component of continual improvement is beyond the statutory limits and that the I2P2 program, although based on the PDCA model, should focus on OHS management.

Another consensus standard, OHSAS 18001, provides guidelines to establish occupational health and safety management systems that can help employers to reduce risks in the workplace. Similar to the ISO standards, the ANSI Z10 standard focuses on continual improvement and employer's efforts to constantly work on further development of environmental, health and safety goals.

An ISO series in regards to occupational safety and health was never developed. In contrast to consensus standards, OSHA regulations do not focus on continual improvement or on seeking new ways to improve workplace health and safety, but to provide standards that employers and employees must adhere to. OSHA standards are, however, only the minimum requirements and leave room for improvement. Using I2P2 as a regulation to force employers to put workers' safety and health into the center of attention, will hopefully over time turn compliance into a habit and bring on permanent change.

Meike Patten, MPSafetyTraining