The people who write huge swath OSHA standards are from the same philosophy (big government solves all ) that wrote: 2700 pages of healthcare law, begatting multiple thousands of a pages of regulations; 2300 pages of financial law, with more thousands of pages of regulations, etc. etc. Enough!!
I believe we have sufficient regulations to address basic safety already on the books. Basic safety is all the great majority of workplaces--those without safety staff--can even hope to handle.
There are still 40 years of OSHA regulations on the books. I can't see that being shut down. I think enforcement will continue and I support that. I can see standards being curtailed. Why continue to seek to add standards that have under Obama largely become purely political agenda excursions hidden under supposed safety improvements instead of real targeting of safety improvements? I2P2 is the prime example.
If OSHA can address combustible dust from an enforcement standpoint without a standard, then my point about sufficient standards already enacted is made. And OSHA has enforced combustible dust. The reason they can't get a standard enacted is the same reason the grain silos are not regulated. Any proposal that has been made is so broad as to be unworkable. My proposal was to add "combustible dust accumulations at 1/32 inch or greater on building surfaces" to the housekeeping standard and consider it regulated. Oh, but OSHA can't do that. We are the government and we have to be comprehensive.
Frankly, I think the OSHA standards department should be shut down and the money used to support compliance assistance in the Area offices. Standards have become nothing more than a political playground. Useless.
Will there be be a business backlash against I2P2. Probably and hopefully. But, from my perspective, there is a strong safety professional practice case to be made against I2P2. Should I2P2 ever reach the proposal stage, I plan to make that case in personal and public testimony. OSHA will probably try to propose something simple in appearance to camouflage their real intent--which is the radical left wing interpretation circus they can create from this standard. We as safety professionals will never know where we are--expect that our beloved profession has been totally sucked up by the OSHA political class.
I2P2 is already being done by sites that have safety staffs. Safety Staffs cannot function without something like that to provide them leverage. Without safety staff, the employers will not be able to keep up--just as now. Except with I2P2, there are no boundaries to constrain the political class and their interpretations. I2P2 was the invention of the safety profession. OSHA attempts to declare it a universal safety process. Not so! It just shows how naive the OSHA leadership is to the realities of the workplace.
