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Written by Bryan Haywood

Parent Category: Safety Info Posts

Category: OSHA Compliance Posts

Published: 04 April 2014

In the past several years OSHA has renewed their efforts in trying to get their "Injury and Illness Prevention Plan" (I2P2) on the table for discussion/rule making. To many safety professionals this may be a “new movement”, but in reality this effort dates all the way back to 1995. Recently, OSHA has said they are hoping to have a formal rule making effort going by September 2014 and this much needed "plan" is causing quite the stir in all industries and professions. It is my humble belief that in 1995 when OSHA first proposed this on the national level, that the atmosphere was just too burdened because we had just gotten PSM in 1992 and all the “higher risk” facilities were already working on a “management system” as they implemented PSM. However, most facilities in the USA do not deal with PSM so most of these businesses do not have a FUNCTIONING safety management system. If asked, most would say they DO HAVE a system in place, but as most seasoned safety professionals know this “system” is not really a living and breathing safety management system. Heck even some VPP sites struggle with an all encompassing and functioning safety management system. What OSHA is proposing is a MUST HAVE in my eyes! Whether we do it on our own using ANSI Z10 (which is OUTSTANDING by the way) or we wait for OSHA to require it, it is a MUCH need step to get us towards world-class safety. Ask yourself, or better yet ask your management team, what would happen tomorrow if the safety manager (or safety team) won the lottery and did NOT show up to work next week? What would happen to “safety”? Would anyone on the management team outside of the safety group have any idea what is “due to be done” over the next several weeks/months/quarters while they replace the safety team. If ONLY the safety team knows what is happening, what is scheduled to happen, and what has to be done to meet the “Lowest Safety Denominator” (i.e OSHA compliance) then we are just fooling ourselves into believing we have a functioning “safety management system”! I2P2 is meant to make safety a FUNCTION of “management” and not just the “safety manager” so it just makes me shake my head when I am at a safety conference and here safety professionals speak ill of the I2P2.  Here is the background of I2P2 and what we can expect…

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