Could the proposed I2P2 be stopped?

January 28th, 2011

With the start of a new year brought a new team of leader to the US House of Representatives, which will be working on unveiling proposals to reduce costs, as well as look at recent rules and current proposals from the EPA and OSHA.

US Rep. Darrell Issa, R-Calf. who is the new chairman of the Hose Oversight and Government Reform Committee, sent a letter recently to over 150 trade associations to identify specific ‘burdensome’ regulations.  The responses that are received will be compiled together and presented to the House Committee staff.

Under the guidelines of the proposed I2P2, the biggest concern is the effect to already struggling businesses and creating an added cost and burden to comply with such standards.  In the white paper that the AIHA submitted to OSHA, they outlined that there could be a struggle for small business owners to meet these standards, but would ask that there would be resources available to meet their needs to implement such standards.

Another concern is cost.  In today’s economy many businesses are still struggling to keep their doors opened and employees working.  By implementing the I2P2, there are some that feel that this would come with an added cost to train workers as well as keeping records which would result in the loss of jobs as businesses would have to reorganize their expenses and make cuts at the employee level to meet such standards.

In the coming weeks we will see how this plays out in Washington with the various groups involved for either recommending the I2P2 or wanting to stop the I2P2 from becoming a new rule.

Why the AIHA is recommending the I2P2

January 26th, 2011

The American Industrial Hygiene Association (AIHA) recently released a white paper concerning OSHA’s Injury and Illness Prevention Program (I2P2) and expressing their support for the I2P2 standard.  Outlined below is a brief overview of recommendations that the AIHA would like to see written into the policy.  To read the full AIHA report, click here

Scope and Application:
Such standard should not exempt small employers or workplace based on the number of employees, or based on the injury/illness incident rates.   The I2PS documentation should be clear and precise with only having needed and essential activities documented.

Covered Hazards:
The I2P2 should address all hazards covered by OSHA standards. This should also focus on proactive identification and control of workplace hazards and risks.  Along wit this, implementing a regular physical inspection of the workplace along with a review of relevant policies, procedures, and organizational practices.

Relationship to Existing OSHA Requirements:
The I2P2 standard should complement and support existing OSHA standards, requirements, and guidelines.

Organization and Regulatory Text:
The I2P2 standard should by written in clear and concise language that outlines basic requirements in a way that employers can understand, as there are many employers who do not employ EHS personal and therefor need to understand such information in a concise meaning.

Economical Impacts:

According to case study information, moving to such standard would be cost-effective move for all who would be involved.  By implementing such standards, this could help improve productivity and quality which would lower costs for businesses.

Injury and Illness Prevention Program (I2P2)

January 24th, 2011

OSHA’s proposed I2P2 has been discussed over the past few months, and this year OSHA would like to move forward on implementing this program as a standard for businesses.  Today we would like to give an overview of what the I2P2 is exactly and look at this week those who are for the implementation of this standard, and those who are not.

I2P2 Background

Would require employers to implement Injury and Illness Prevention Programs.

  • Employers identify and mediate risks to workers.
  • Methods to provide workers with opportunities to participate in the program
  • Such program would be made available to workers so that they can understand and help monitor its implementation
  • Require employers to implement the program so that the program actually protects workers
  • Provisions to prevent employers from not covering workers by mis-classifying them as independent contractors

Provide employers the tools necessary to find and fix their own workplace safety and health hazards.

Enhance worker’s voice and participation in the process as well as establish guidelines the would proactively address workplace safety and health hazards and ultimately reduce injuries and illness.

I2P2 Benefits

OSHA believes that an injury and illness prevention program is a universal intervention that can be used in a wide spectrum of workplaces to dramatically reduce the number and severity of workplace injuries.

Every year 5,000 workplace fatalities and about 3.5 million workplace injuries  caused by the exposure to common chemicals, physical, and biological agents.  By implementing such a program this could help reduce such fatalities and injuries on the job.

EHS Issue Concerns

January 19th, 2011

The American Industrial Hygiene Association (AIHA) has released a list of the top EHS Policy Issues for the new year.  Here is a sample of some of the most pressing issues that the organization is looking at this year and will be working with OSHA and Congress to try to address these issues and come to a better understanding on how to make such improvements.

Updating Permissible Exposure Limits (PELs): PELs indicate how long an individual can be exposed to a particular substance without experiencing harmful effects.  According to the AIHA, most PELs have not been updated since the 1960’s and 1970’s.

Injury and Illness Prevention Program (I2P2): Under the I2P2, this would require employers to establish and maintain a Injury and Illness Prevention Program.  This would involve planning, implementing, evaluating, and improving processes and activities that protect employee safety and health.

MSDS/Globally Harmonized System (GHS):
Improve the accuracy of MSDSs, as well as improve hazard communication for employers and employees.  With this would be to move forward to adopting the Globally Harmonized System (GHS) Standards.

National Conversation on Public Health and Chemical Exposure

January 17th, 2011

Earlier this month a web-dialogue took place that was organized by the Agency for Toxic Substances and Disease Registry (ATSDR) and the CDC, that discussed in an open forum about how to prevent and respond to harmful chemical exposures by individuals and communities.

The National Conversation is a non-profit organization working to see that chemicals are used and managed in safe and healthy ways for all people.  Their goal is to expose the various issues around chemicals, and look at recommendations that can be past along to government agencies to help strengthen efforts to keep the public safe from harmful chemical exposure.

For more information you can go to The National Conversation website.

Getting to Know Chemicals

January 13th, 2011

Under the Toxic Substances Control Act (TSCA) the EPA is requiring manufacturers of 19 high production volume chemicals to test their health and environmental effect and submit the data to the agency.

According to the EPA, HPV Chemicals are classified as those chemicals produced or imported in the United States in quantities of 1 million pounds or more per year.

Such chemicals have consumer and or industrial applications, from personal care products to metalworking fluids.  With the data reporting the EPA will be able to evaluate any potential risks from these chemicals being produced in large quantities.

The public also has access to research chemical specific health and safety studies through he Chemical Data Access Tool which is also apart of the Toxic Substances Control Act.

Through this website, you can find health and safety information, chemical testing results, and access to health and environmental effects.  The amount of search-able data will increase over times as additional information is either reported or is scanned from historically submitted documents.

New Year and New Regulations

January 11th, 2011

OSHA could be knocking on your door this year, as the agency will be conducting more than 3,000 additional inspections to various facilities.

Companies today are facing the stress from many levels, but overall it comes down to reducing costs of operations.  The question that this comes down to is how does a company reduce cost yet at the same time manage to keep their employers safe and avoid a visit from OSHA that could surprise them with an additional fine?

One area that often comes up to reduce costs is Personal Protective Equipment (PPE).  Those involved with making choices may say that the one PPE item is to expensive but at the same time provide better safety to the worker.  So do you go with a lower rated PPE item that does not preform as well to save money or invest in the later for the benefit of worker safety?

Here are a few areas to consider when you are looking at various PPE Equipment:

Functionality:  All PPE should help workers perform their jobs and provide adequate levels of protection.

Personal Factors: Make sure PPE items are comfortable for your workers which will help encourage workers to wear these products.

Quality Products: It may cost a little more, but higher quality products may help job performance and job safety.  Such products may also last longer so over the course of time saving the company money, which may be a deciding factor when selecting proper PPE products.

100 Years of ASSE

January 7th, 2011

The American Society of Safety Engineers have debuted a new short film ‘Century of Safety’ that chronicles the story of work safety and work tragedy over the decades.

ASSE is celebrating their 100th anniversary this year, and during the year the organization plans to celebrate with various events including their annual conference which will take place in Chicago June 12 to 14.

The short film is a documentary that chronicles how ASSE was organized after the Triangle Shirtwaist Factory fire in 1911 that killed 146 workers.  After this tragedy, employer safety was viewed in a different way and since then the film looks at what has been done to continue to keep workers safe in their respected professions.

To view the video you can go to Celebrating ASSE’s 100th Anniversary

Workplace Tragedies, How to Make 2011 a Safer Year

January 5th, 2011

2010 was an unfortunate year for workplace safety.  Who can forget the mine disaster at the beginning of the year that killed 29 coal miners in West Virginia as well as the off shore drilling rig in the Gulf of Mexico blast that killed 11 workers.  These events captured the attention of the general public as they were well portrayed by the media outlets but there were many other events that went unnoticed this past year.

The National Council for Occupational Safety and Health (COSH) has released their list of the Top 10 Workplace Tragedies for 2010.

Over the past year nearly 5,000 workers died while on the job.  Given the range of incidents that did happen, most of these could have been prevented.  Most of these incidents the workers involved did know that there were underlining issues that made their workplace unsafe.  As well, these companies that were involved knew the hazards they were placing their workers in but failed to make any changes to improve their conditions.

Now that we are in a new year, how can we look back and reflect upon these tragedies and improve workplace standards?  This year OSHA is planning on working on improving hazards in the workplace with their Injury and Illness Prevention Program (I2P2) which would look as such workplace incidents more closely and improve such safety conditions.

Keeping Employers Safe in the Summer Heat

August 25th, 2010

California is leading the way in making revisions to their OSHA Heat Illness Prevention Standards.

High heat procedures are now required for 5 industries when the temperatures reach 95 degrees or hotter.  These industries include: agriculture, construction, landscaping, oil & gas extraction, and transportation or delivery of agricultural products, construction material, or other heavy material.

Such procedures include, observing employees who are out in the elements, reminding to drink water, and providing access to shade within proximity to their working areas.

In 2005, California became the first state in the nation to develop a safety and health regulation to protect workers from heat illness.