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On Safety

Kyle Morrison's blog

A blog by Safety+Health Senior Associate Editor Kyle W. Morrison


kyle.morrison@nsc.org


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What happened to I2P2?

May 29, 2014

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From almost the moment he took the reins at OSHA, administrator David Michaels has called an Injury and Illness Prevention Program Standard his “No. 1 priority.” But the recently released Department of Labor regulatory agenda suggests that is no longer the case.

The spring 2014 regulatory agenda places the I2P2 rule into the “long-term action” category. In the previous agenda, OSHA was aiming to release a notice of proposed rulemaking this coming September; now, the NPRM has a release date of “to be determined.”

Simply changing the rulemaking to a long-term action does not mean OSHA has stopped working on I2P2.

But the move does send a signal that perhaps I2P2 is no longer the agency’s top priority. It is interesting to note that some of the language Michaels has used has subtly shifted. While a couple of years ago, an I2P2 rule was the No. 1 priority, it is now the I2P2 initiative in the top spot. A rule is a rule, but an initiative could mean a rule and/or guidelines.

An I2P2 rule isn’t without controversy, so I can see why OSHA wouldn’t rush into it. However, an I2P2 requirement has received a lot of industry support, and the majority of states already have such a requirement.

I reached out to OSHA to ask what prompted moving the rule to long-term action, and whether I2P2 still remains Michaels’ and OSHA’s No. 1 priority. I’ll let you know what the agency says when I hear back.

The opinions expressed in "On Safety" do not necessarily reflect those of the National Safety Council or affiliated local Chapters.

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