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The Occupational Safety and Health Administration (OSHA) recently released a white paper on the value of injury and illness prevention programs (I2P2) in the workplace, noting that I2P2s lead to higher productivity and quality; reduced turnover; and greater employee satisfaction. 

The white paper was OSHA’s reaffirmation that it will continue to pursue its I2P2 rulemaking. Although no proposal has been made available to stakeholders, it is believed that employers will be required to implement internal safety programs that “find and fix” workplace hazards on a rolling basis. It is unclear whether OSHA’s proposal will be one-size-fits-all, or whether the agency envisions a more flexible approach. Also unclear is the extent to which the enforcement of such a rule would allow for “double-dip” citations when infractions are found—once under an existing standard, and once under the new I2P2 requirements. 

In the white paper, OSHA described the benefits of implementing injury and illness prevention programs in relation to cost and concluded that the adoption of such programs, “will help millions of U.S. businesses improve their compliance with existing laws and regulations, decrease the incidence of workplace injuries and illnesses, reduce costs (including significant reductions in workers’ compensation premiums) and enhance their overall business operations.” 

OSHA also addressed the cost concerns of small businesses arguing that low-cost approaches have been shown to be effective in small businesses 

In addition to issuing the white paper, on Jan. 6, OSHA notified the Small Business Administration that it intends to convene a Small Business Advocacy Review panel under the Small Business Regulatory Enforcement Fairness Act (SBREFA) in the next two months. The purpose of the SBREFA panel is to gather more information from small businesses on the impact the proposed rule could have. 

ABC fully supports safety and health management programs in the workplace and works with its members to develop and implement effective policies; however, ABC has voiced concerns about the proposed rulemaking. Among its concerns, ABC pointed out that the rule could negatively impact employers who already have effective I2P2 programs in place on their jobsites.