OSHA’s Injury and Illness Prevention Program (I2P2) was vigorously debated yesterday (10/20/2014) at the American Industrial Hygiene Association’s (AIHA) annual Fall Conference, held in Arlington, VA.
The presidential-style debate featured I2P2 supporters James Thornton, CIH, CSP, director, health, safety and environment, Newport News Shipbuilding, div. of Huntington Ingalls Industries; and Charles Redinger, president of Redinger 306, Inc. I2P2 opponents were Tom Lawrence, Safety and Compliance Management; and David Sarvadi, Esq., Keller & Heckman, LLP, Washington, DC.
The debate was moderated by Industrial Safety & Hygiene News (ISHN) Chief Editor Dave Johnson.
The two sides, representing the broader national debate about the merits of I2P2 that has raged for the past four years, disagreed on 1) the value of I2P2 as a means of improving U.S. safety and health performance in the workplace; 2) the burden of I2P2 on small businesses; 3) the effectiveness of I2P2 based on conflicting research findings of I2P2-like programs in states; 3) the costs of I2P2; 4) the unintended consequence of I2P2 turning employer safety mindsets to a “compliance only” mode and interrupting momentum in industry toward building and sustaining “beyond compliance” safety cultures; 5) the ability of OSHA compliance officers to fairly and expertly evaluate I2P2 programs; 6) the potential devaluation of health and safety professionals as becoming I2P2 “compliance-only cops”; 7) the need for OSHA to wait on releasing I2P2 requirements until the voluntary international ISO 45001 occupational health and safety management system standard is issued in late 2016 to avoid potential conflicts in the two standards and confusion.
With regard to AIHA’s and the American Society of Safety Engineers’s (ASSE) formal endorsement of promulgating I2P2, opponents claimed the associations’ positions have been swayed by the large number of consultant members who could potentially benefit from the standard.
The two sides also disagreed on why I2P2 has been put on OSHA’s backburner; it is now listed as a “long-term action” item with no dates indicated for further movement forward in OSHA’s latest regulatory calendar. Opponents argued OSHA made the move to allow the ISO 45001 standard to come out first. Proponents of I2P2 said the move was made for pure political reasons, with the Obama administration not wanting the controversy over I2P2 to damage the candidacies of Democratic Senate and House campaigners in the upcoming mid-term November elections.
One source, speaking anonymously to protect relations with OSHA and the administration, told ISHN he believed the White House ordered OSHA to pull back I2P2, and in exchanged gave OSHA the greenlight to proceed with proposed standards on silica and beryllium. The source expects OSHA to issue a final standard on silica before the end of the Obama administration in 2016.
