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Hill,ASSE Applaud Fed Move to Develop Workplace Injury & Illness Prevention Standard

Posted in on Mon, Dec 20, 2010

Des Plaines, IL (December 20, 2010) — In a letter sent December 17 to U.S. Occupational Safety and Health Administration’s (OSHA) Assistant Secretary David Michaels, American Society of Safety Engineers (ASSE) President Darryl C. Hill, Ph.D., CSP, applauded him for beginning the task of promulgating an injury and illness prevention program (I2P2) standard, a standard ASSE has supported pursuing for a long while.

Hill included 10 principles from ASSE members to assist with the I2P2 rulemaking and urged OSHA to consider them as a basis for its standard. According to Hill, “An I2P2 standard must encourage a movement in this nation toward risk-based management of workplace hazards.”

Hill also addresses employee and employer involvement, continual improvement and periodic review, professional qualifications, flexibility for small employers, existing state I2P2 standards, harmonization with voluntary standards, OSHA personnel training, and utilizing the experience of Voluntary Protection Program (VPP) participants.

Hill noted an appropriate I2P2 standard that causes employers to make systematic risk-based assessments of occupational safety and health hazards workers face in workplaces and establish a meaningful plan to address those risks reflects the way the best employers already manage risks. Employers should and can approach safety and health management in the same way the best companies do, Hill noted. If they do, ASSE believes a significant and positive shift in the way safety and health is managed and enforced, as the principles ASSE outlines indicate, can be achieved.

ASSE asks that the final I2P2 standard improve safety and health management in every workplace. The suggested ASSE set of principles that an I2P2 standard must contain if it is to succeed are:

1. An I2P2 standard must encourage a movement in this nation towards risk-based management of workplace hazards.
2. An I2P2 standard must recognize the need for involvement of both the employer and employee in establishing a safe workplace without diminishing or replacing the overall responsibility for the program by the employer.
3. An I2P2 standard should instill in workplaces a commitment to continual improvement and appropriate periodic review of the workplace I2P2.
4. An I2P2 standard will not succeed if the end-result is simply a reiteration of the General Duty Clause to cover hazards not specifically addressed in current OSHA standards.
5. A standard must address the qualifications of the individual charged by the employer with creating a workplace’s I2P2. The complex operations and hazards that many large employers face will require a Certified Safety Professional (CSP). Many employers will be able to rely on a “competent person” if a more definitive understanding of “competent person” can be adopted by OSHA, such as an appropriately competent person who, through experience and training, is able to identify actual and potential hazards, understand safe work practices, design and implement control strategies, and have demonstrated expertise in establishing and managing a safety and health program.
6. While all employers should be covered under an I2P2 standard, the standard must be scalable, reasonably flexible and responsive to the realistic capabilities and hazards of employers of all sizes and industry groups. For some very small employers, or light hazard operations, if a one or two-page checklist of hazards with guidelines to control those hazards cannot meet the standard, the standard will have difficulty succeeding.
7. Federal OSHA should take into consideration the California I2P2 standard as a basis for a federal standard. In any case, states like California with an existing I2P2 standard should be exempt from a federal standard if their standard is at least as effective as the federal standard.
8. An I2P2 standard should be harmonized with the most widely accepted voluntary consensus standards governing safety and health program management in the private sector, including ANSI Z10 Occupational Health & Safety Management System and OSHAS 18000 Occupational Health and Safety Management Systems Specification, and efforts should be made to work with the standards development organizations responsible for those standards.
9. Appropriate training for OSHA inspection personnel that encourages cooperative as well as enforcement-directed interaction with employers will be needed to support the implementation and meaningful adherence to an I2P2 standard.
10. Withdrawing support for VPP is not consistent with the establishment of an I2P2 standard. Participation in VPP demonstrates that I2P2s are effective in addressing workplace risks and developing a shared employer and employee commitment to workplace safety and health.

Founded in 1911, the Des Plaines, IL-based ASSE is the oldest professional safety society and is committed to protecting people, property and the environment. Its more than 32,000 occupational safety, health and environmental professional members lead, manage, supervise, research and consult on safety, health, transportation and environmental issues in all industries, government, labor, health care and education. For more information and a copy of the letter please go to

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