Did you know that companies that invest in employee safety and health performance find a positive return on that investment (ASSE, June 2002)? Did you know that companies who did a poor job of managing workplace safety and health had inferior financial performance than those with successful management practices (Goldman Sachs JBWere, 2007)? Positive safety and employee health outcomes aren't the result of chance or half-hearted attempts. Rather they are rooted in dynamic safety and industrial hygiene programs.
OSHA has long recognized the importance of these programs. You could say its history goes back to the Occupational Safety and Health Act itself. Paragraph (j) in Section 17 of the OSH Act authorizes the Occupational Safety and Health Review Commission to assess civil penalties to employers who violate OSHA standards. It also specifies that the Commission give "due consideration" to the good faith of the employer. Most of us would agree that employers who successfully implement safety and health programs are demonstrating good faith.
OSHA's SHARP (Safety and Health Achievement Recognition Program) and VPP (Voluntary Protection Program) initiatives provide platforms that both support and recognize companies who are committed to developing or improving their safety and health programs. In addition, OSHA's Safety and Health Program Management Guidelines give guidance culled from companies with best safety practices and programs.
The emphasis on safety and health programs extends beyond OSHA. The American Industrial Hygiene Association's voluntary consensus standard Occupational Safety and Health Management Systems (ANSI/AIHA Z10-2005) uses the Plan-Do-Check-Act model to identify continuous improvement opportunities and the root cause of workplace hazards.
Similarly, the OHSAS (Occupational Health and Safety Assessment Series) 18001-2007 Occupational Health and Safety Management System consensus standard has a systematic approach to improved safety and health performance. This standard also requires a company's programs to be assessed and certified by a 3rd party. It is often referred to as ISO 18001.
Unfortunately, many companies have poor safety and health records despite evidence linking safety and health programs to improved performance and the wealth of resources on this topic. OSHA is increasing the ante on these companies by way of their proposed rule on Injury and Illness Prevention Programs, otherwise known as I2P2.
OSHA recognizes that the agency itself along with the consensus standards groups use other terms to describe these programs. Regardless of the words used, OSHA recognizes the common goal "to help employers reduce workplace injuries and illnesses through a systematic process that proactively addresses workplace safety and health hazards."
The proposed rule would address the following:
- Management duties
- Employee participation
- Hazard identification and assessment
- Hazard prevention and control
- Education and training
- Program evaluation and improvement
The rule would most likely acknowledge and/or incorporate the existing consensus standards. It may target certain employers based on their size, the nature of their operations and hazards, or incident rates. Regardless of the details, the overarching theme will be the implementation of a systematic process that proactively addresses workplace safety and health hazards.
Stakeholder meetings were held in 2010 and input from the small business community was obtained in 2012. The Notice of Proposed Rulemaking is scheduled for September 2014. Stay tuned for further developments on this rule.
Do you have injury and illness prevention programs? If you do, do they need to be reviewed and updated? Which hazards are likely to cause injury or illness in your workplace? How are you controlling these hazards? Click on the button below in order to learn how Cashins & Associates can help improve your company's safety and health programs.