One of OSHA chief Dr. David Michaels’ top priorities appeared for the first time in the OSHA standards-setting agenda released April 26 by the Labor Department — the creation of standard requirements for an injury and illness prevention program.

This could be the consuming standard-setting effort of Dr. Michaels’ time at OSHA, overshadowing anything to do with ergonomics, the major standards push of the Clinton administration.

While it will take years for an injury and illness prevention program rule to move from the current prerule stage through all the various hearings, proposals, comment periods, and Labor Department and budget office clearances, likely requiring a second Obama term to complete, most OSHA watchers believe setting basic standards for workplace safety and health programs is less controversial than ergonomic standards.

“I think this is the real story of the new agenda,” says a seasoned OSHA watcher. “If it gets done it could change the whole paradigm by going from a compliance with hazard rules to a more proactive, employer-centered, risk-based approach.”

In a web chart, Dr. Michaels said: “Plan/Prevent/Protect is the department's new compliance strategy that describes cooperative efforts of our worker protection agencies (not just OSHA, but also the Mine Safety and Health Administration, Wage and Hour Division, and the Office of Federal Contract Compliance) to leverage agency resources. The goal of the Plan/Prevent/Protect strategy is to make workplaces safe, healthy, equitable, and secure. The approach of the new strategy is to change the culture of compliance from one in which some employers and other regulated entities wait for labor enforcement personnel to catch them violating the law to one in which employers and others proactively plan to reduce risk to workers by implementing the plan and protecting workers as a result.”

Here’s how OSHA describes the workplace safety and health rule in the regulatory agenda: “OSHA is developing a rule requiring employers to implement an Injury and Illness Prevention Program. It involves planning, implementing, evaluating, and improving processes and activities that protect employee safety and health. OSHA has substantial data on reductions in injuries and illnesses from employers who have implemented similar effective processes.

“The agency currently has voluntary Safety and Health Program Management Guidelines (54 FR 3904-3916), published in 1989. An injury and illness prevention rule would build on these guidelines as well as lessons learned from successful approaches and best practices under OSHA’s Voluntary Protection Program, Safety and Health Achievement Recognition Program and similar industry and international initiatives such as American National Standards Institute/American Industrial Hygiene Association Z10 and Occupation Health and Safety Association 18001.

“Twelve states have similar rules. (California’s being the most well-known.)

“As a first step, the agency plans to hold stakeholder meetings (June 2010) to obtain input for an injury and illness prevention rulemaking.”