Get to Know I2P2

In recent interviews, OSHA DIrector David Michaels has mentioned that several new OSHA regulations are progressing quickly. The one that may have significant impact on ginners is the Injury and Illness Prevention Program commonly referred to as I2P2. We’ve mentioned I2P2 in the past. In 2010 OSHA introduced the concept and began stakeholder meetings. Given the time since the initial introduction and Director Michael’s comments, we may see a proposed rule for I2P2 by the end of the year.

There are several things we know about the program and some important things we don’t. For instance the program essentially forces all businesses to evaluate jobs and have a plan to prevent injuries and illnesses. In other words it requires all businesses to have a comprehensive safety program. We don’t know if there will be a small business component or if the rule will apply to agriculture. This is significant as gins are considered agriculture.

Lets look at a few of the elements in the draft that was put out in 2010 and are part of a fact sheet recently released by OSHA on I2P2. 1.) Management Leadership – This requires management to set goals and measure progress.  2.) Worker Participation – requires employee representation when developing a safety program and have mechanisms for employee involvement in modifications and improvements. 3.) Hazard Identification and Assessment – this element is designed to have, as part of your program, a review of injuries, analysis of hazards and a plan to identify the ones that have hurt people and the ones that can hurt people. 4.) Hazard Prevention and Control – Once you identify (see 3.) the hazard, what are you going to do about it. 5.) Education and Training – This is what we’ve focused on for years and most are familiar with. Safety Meetings, training etc are part of this element. 5.) Program Evaluation and Improvement – This requires you to periodically review the program for completeness and effectiveness and requires employee involvement in the review.

Some State Plan states like California, have had I2P2 programs in place for years. My counterpart in CA has told me that these programs are not difficult and if you follow the programs outlined in the various ginner safety manuals, it should be fairly straight forward.

Our safety manual has all of these elements in some form. While our manual is due for an update, we’ve been hoping the OSHA I2P2 rule would be published so it would match the rule. Even if the new rule doesn’t bring agriculture in, our manual will reflect the rule when revised. The general duty clause still applies to gins and this would be a very opportune use of the clause.

Look for more information and details as the standard progresses. We expect to see a proposed rule by the end of the year.