On Safety

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What happened to I2P2?

May 29, 2014

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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