OSHA’s Pending IIPP Standard


In June, Michaels indicated the federal IIPP standard is currently OSHA’s “highest priority.” He continued by responding to naysayers—those who believe the standard is a case of over-regulating or has a financial agenda for OSHA—that the burden of IIPP implementation is negated by the incident reduction it is intended to address. The standard would create a preventative process regarding workplace safety as opposed to the more commonly used reactive process— where assessment and planning only comes up after an incident has occurred.

Nothing has been set in stone, and Michaels stated he was “hesitant to predict anything.” However, speculation suggests the federal standard may go into effect as early as mid-2014 and as late as 2015.

The Impact on Businesses

The primary hope is that not only will nationwide occupational injury and illness statistics see a significant decline, but employers also will see a greater monetary profit as a result. When the issues of workers’ compensation costs, employee loss and downtime (losses including training replacement employees), and litigations are less prominent, any resources allocated to the creation and implementation on an IIPP will be greatly insignificant in comparison.

For example, violations of the standard have been the No. 1 source of citations every year since it was implemented in California, accounting for 25 percent of all citations. The average injury rates for employers after a citation dropped by 20 percent during the next two years. The estimated average cost of a workplace injury is between $15,000 and $50,000, making a 20 percent decrease a significant benefit for a business.

If you have locations in California, the opportunity presented by the push for federal requirements is to take a good look at your current IIPP and strive to make it better. Save yourself the hassle and loss of a citation by taking the time to strengthen your program.

Employers located outside of California may benefit from taking preemptive measures. By implementing California’s IIPP guidelines now, you’ll be prepared for the federal changes coming with OSHA’s regulatory measures. (Check out California’s IIPP guidelines.)

Small businesses may expect certain exceptions in their IIPP requirements. OSHA has stated it intends to take into consideration small businesses with very few employees or those with preexisting IIPPs that would suffer drastically under the new requirements.

Whether or not you believe the impending standard is a burden, think about it this way: If your business is going to carry a burden, shouldn’t it be one for safety?

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About Michael Rich

Michael Rich is in charge of product development for Tempe, Ariz.-based Safety Services Co., a supplier of occupational health and safety training and compliance materials.

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