Federal OSHA is forging ahead with writing regulations requiring employers to develop injury and illness prevention programs that identify the hazards that are unique to their workplaces, and to develop processes for fixing those hazards. The process, known as risk-based injury and illness prevention (IIPP), which is in use at many of the country's largest employers, has proven successful at reducing injuries when implemented correctly, according to studies.
Fed-OSHA's risk-based plan differs from just having a general IIPP in place that follows the safety standards already laid out in OSHA's regulations, David Michaels, OSHA's assistant secretary, recently told the American Society of Safety Engineers at their annual conference.
"It's about a process, so we won't use that standard to say 'you didn't abate this,' but it's really about 'can you figure out how to deal with this?'" Michaels said during a seminar at the conference, according to a report in Business Insurance magazine. "How do you categorize your hazards? Did you follow up on injuries to determine what the causes were?"
While the risk-based approach to an IIPP is nothing new to larger employers, most small and mid-sized firms typically don't take this track in their own IIPPs.
That said, the risk-based approach is highly recommended by industrial safety professionals for implementation in all workplaces, as it focuses on ferreting out potential hazards and reducing the risk of injury based on the identified workplace hazards through policies and training.
The risk-based IIPP - dubbed "I2P2" by OSHA - will require employers to have a safety program that maps out a safety program that maps out a plan for indentifying and correcting hazards. That means having in place a flexible plan that focuses on hazards unique to their workplaces (as opposed to a boiler-plate program) and assessing how they can be minimized to a level that includes an acceptable amount of risk.
The IIPP would also include provisions for correcting hazards, as well as investigating near misses and putting in place procedures and policies to ensure that they don't occur again. The risk-based approach also includes regular monitoring and reassessment, and changing the plan when new work processes are included.
A risk-based IIPP would typically include:
- Management leadership
- Worker participation
- Education and training
- A definition of safety goals and risk acceptance criteria
- Hazard identification, prevention and control
- Accident/incident reporting and investigation of causes and contributing factors
- Implementing safety measures and evaluation of efforts
- Safety review of rules/regulations and work practice
Each of the above elements is important in ensuring the success of the overall program, and the elements are interrelated and interdependent.
You should note that every business is different, and a one-size IIPP does not fit all. Employers that implement injury and illness prevention programs must scale and adapt the various elements to meet the needs of their organizations, depending on size, industry sector or complexity of operations.
While the final regulations by Fed-OSHA are years away, you can still implement an IIPP in your organization if you have not already done so.
And if you do, you should strongly consider the risk-based approach, which is more involved but is more likely to pay off in terms of a reduced likelihood of injuries.
If you operate a small or mid-sized firm, you may consider the task of implementing an IIPP as a time-consuming and expensive endeavor. Structured programs can be difficult to establish in a small organization because of tight budgets. However, Fed-OSHA points out that even simple, low-cost approaches have been shown to be effective in small businesses.
IIPPs lend themselves to such low-cost approaches because they are highly flexible - the core elements can be implemented at a basic level suitable for the smallest business, as well as at a more advanced, structured level that may be needed in a larger, more complex organization.
Creating a culture of safety goes hand in hand with injury and illness prevention programs, Michaels added. "Embracing safety culture can increase profits and help create a better product. OSHA levels the playing field for responsible employers to allow them to compete with those employers who cut corners with safety," he said.
