Students, there’s a background to these resources. In 2010, OSHA began stakeholder meetings in order to begin the process to develop an Injury and Illness Prevention Program (I2P2) proposed rule. Based on OSHA’s experience, the agency believed that an I2P2 rule would include the following elements:
1. Management duties (including items such as establishing a policy, setting goals, planning and allocating resources, and assigning and communicating roles and responsibilities);
2. Employee participation (including items such as involving employees in establishing, maintaining and evaluating the program, employee access to safety and health information, and employee role in incident investigations);
3. Hazard identification and assessment (including items such as what hazards must be identified, information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards, hazard assessment and prioritization, and hazard identification tools);
4. Hazard prevention and control (including items such as what hazards must be controlled, hazard control priorities, and the effectiveness of the controls);
5. Education and training (including items such as content of training, relationship to other OSHA training requirements, and periodic training); and
6. Program evaluation and improvement (including items such as monitoring performance, correcting program deficiencies, and improving program performance).

An outline of the purpose and benefits of an overall I2P2 are detailed in OSHA’s document at https://www.osha.gov/dsg/topics/safetyhealth/OSHAwhite-paper-january2012sm.pdf (Links to an external site.) and https://www.osha.gov/dsg/InjuryIllnessPreventionProgramsWhitePaper.html (Links to an external site.)

This proposed OSHA regulation would then REQUIRE all employers to have an overall safety and health program. OSHA never finalized the proposed rule. However, California, Hawaii, and Washington all have state requirements for companies to have an I2P2, and other states provide for workers’ compensation incentives.

In its place, OSHA has developed these guidelines, including the Recommended Practices for Safety and Health Programs.

So, do we think that OSHA should require any of these components, like Cal/OSHA does?