IIPP – Ready or Not Here it Comes!

OSHA is poised to release to the public its initial regulatory approach to its Injury and Illness Prevention Program (IIPP) rule.OSHA has announced that it will begin the Small Business Regulatory Enforcement and Fairness Act (SBREFA) process for its IIPP rule, at which time the Agency will likely make public a draft regulatory text and some preliminary analyses of the costs and benefits of the rule.

The Agency’s oft-stated most significant regulatory priority has been under development in the Agency for over two years.Even so, most stakeholders have no idea what a federal IIPP rule will look like.Will it look like California’s IIPP rule?Or will it take some other approach to requiring employers to establish safety and health management systems in the workplace?

Most safety and health management systems have some form of the following elements, implemented to proactively address hazards in the workplace:

  • Management Leadership
  • Employee Participation
  • Hazard Identification and Prioritization
  • Hazard Control
  • Education and Training
  • Evaluation and Continuous Improvement

OSHA’s draft proposed rule will likely integrate some form of these elements.Of course, the real challenge for OSHA is to take these broad concepts and turn them into mandatory requirements, which can be broadly applied to employers in all industries and of all sizes.OSHA must also attempt to craft a rule that does not disrupt existing employer programs that may be working.However OSHA deals with these issues, it is important for stakeholders to watch OSHA’s rulemaking closely and actively engage OSHA on what will work and not work with respect to a proposed IIPP rule.