Without any public announcement or fanfare, OSHA appears to have killed its injury and illness prevention program (I2P2), at least for the rest of the Obama’s Administration’s time in office. I2P2 has repeatedly been listed as a top priority for OSHA and was at one time scheduled to come out as a proposed rule this summer. It would have required companies to adopt an overall health and safety program, similar to a safety management approach, to identify and control hazards in the workplace.
However, as Roy Maurer reports on the Society for Human Resource Management website, OSHA has quietly removed I2P2 from its Regulatory Agenda. The agenda lists upcoming rules and their status and when a proposal is removed, it means it is largely dead.
That is not to say that OSHA doesn’t strongly believe that I2P2 is necessary or that identifying and addressing hazards is the best way to address safety in the workplace. As Maurer points out, the agency may have just run out of time. It has a full plate of other initiatives and the administration only has two-and-a-half years left in office, with much of that caught up in hard-fought congressional and then presidential races. That probably doesn’t leave enough time to jump through all of the hoops it takes to push through a major rulemaking initiative. Which doesn’t mean that I2P2 won’t be back if the next administration supports it.
Companies should also remember that the General Duty Clause pretty much requires employers to recognize and address all hazards, whether they are covered by regulations or not. I2P2 is a more formal, documented way to do that, but the responsibility to ID hazards will only become stronger no matter what rules come out in the future.