I2P2 is OSHA’s way of requiring an SMS

What is an Injury & Illness Prevention Program (I2P2)?  It is a very basic, 8-element, safety management system (SMS).  It is OSHA’s attempt to fundamentally change from the complaince model to an SMS model to manage workplace safety and health.  OSHA has been talking about I2P2 for nearly 20 years and has faced relentless pushback from the industries.  But it is time to move forward, as the old complaince model has run its course.  And the simple solution is OSHA’s I2P2.  So let’s look at CAL-OSHA’s I2P2 requirements for insight in what these 8-elements are and how they function as an SMS.

An I2P2 is a written plan that includes procedures and is put into practice. The eight (8) elements of an I2P2 are:

1. Management commitment/assignment of responsibilities;
2. Safety communications system with employees;
3. System for assuring employee compliance with safe work practices;
4. Scheduled inspections/evaluation system;
5. Accident investigation;
6. Procedures for correcting unsafe/ unhealthy conditions;
7. Safety and health training and instruction; and
8. Recordkeeping and documentation

Management Commitment/Assignment of Responsibilities

Your commitment to safety and health shows in every decision you make and every action you take. Your employees will respond to that commitment.

The person or persons with the authority and responsibility for your safety and health program must be identified and given management’s full support. You can demonstrate your commitment through your personal concern for employee safety and health and by the priority you place on these issues.

If you want maximum production and quality, you need to control potential workplace hazards and correct hazardous conditions or practices as they occur or are recognized.

You must commit yourself and your company by building an effective Injury and Illness Prevention Program (I2P2) and integrating it into your entire operation.

This commitment must be backed by strong organizational policies, procedures, incentives, and disciplinary actions as necessary to ensure employee compliance with safe and healthful work practices.

They should include:

• Establishment of workplace objectives for accident and illness prevention, like those you establish for other business functions such as sales or production for example: “Ten percent fewer injuries next year,” “Reduce downtime due to poorly maintained equipment.”
• Emphasis on your staff’s safety and health responsibilities and recognition by your supervisors and employees that they are accountable. Advise your management staff that they will be held accountable for the safety record of the employees working under them, and then back it up with firm action.
• A means for encouraging employees to report unsafe conditions with the assurance that management will take action.
• Allocation of company resources financial, material, and personnel for:
• Identifying and controlling hazards in new and existing operations and processes, and potential hazards.
• Installing engineering controls.
• Purchasing personal protective equipment.
• Promoting and training employees in safety and health.
• Setting a good example! If, for instance, you require hard hats to be worn in a specific area, then you and other management wear a hard hat in that area. If you and your management team do not support and participate in the program, you are doomed to failure from the start. It is especially important for plant supervisors and field superintendents to set a good example.

 

Safety Communications

Your I2P2 must include a system for communicating with employees – in a form readily understandable by all affected employees – on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal.

While this section does not require employers to establish labor-management safety and health committees, it is an option you should consider. If you choose to do so, remember that employers who elect to use a labor-management safety and health committee to comply with the communication requirements are presumed to be in substantial compliance if the committee:

• Meets regularly but not less than quarterly.
• Prepares and makes available to affected employees written records of the safety and health issues discussed at the committee meetings, and maintained for review by the Division upon request.
• Review results of the periodic scheduled worksite inspections.
• Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness or exposure to hazardous substances, and where appropriate, submits suggestions to management for the prevention of future incidents.
• Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, it may conduct its own inspection and investigation to assist in remedial solutions.
• Submits recommendations to assist in the evaluation of employee safety suggestions.
• Upon request of the OSHA, verifies abatement action taken by the employer to abate citations issued by OSHA.

If you elect not to use labor-management safety and health committees, be prepared to formalize and document your required system for communicating with employees.

Here are some helpful tips on complying with this difficult section:

• Your communication system must be in a form “readily understandable by all affected employees.” This means you should be prepared to communicate with employees in a language they can understand, and if an employee cannot read in any language, you must communicate with him/her orally in a language “readily understandable.” Your communication system must be “designed to encourage employees to inform the employer of hazards at the workplace without fear of reprisal” it must be a two-way system of communication.
• Schedule general employee meetings at which safety is freely and openly discussed by those present. Such, meetings should be regular, scheduled, and announced to all employees so that maximum employee attendance can be achieved. Remember to do this for all shifts. Many employers find it cost effective to hold such meetings at shift change time, with a brief overlap of schedules to accomplish the meetings. If properly planned, effective safety meetings can be held in a 15 to 20 minute time frame. Concentrate on:
  • Occupational accident and injury history at your own worksite, with possible comparisons to other locations in your company.
  • Feedback from the employee group.
  • Guest speakers from your worker’s compensation insurance carrier or other agencies concerned with safety.
  • Brief audio-visual materials that relate to your industry.
  • Control of the meetings.
  • Stress that the purpose of the meeting is safety. Members of management should attend this meeting.
  • Training programs are excellent vehicles for communicating with employees.
  • Posters and bulletins can be very effective ways of communicating with employees. Useful materials can be obtained from Cal/OSHA, your workers’ compensation insurance carrier, the National Safety Council or other commercial and public service agencies.
  • Newsletters or similar publications devoted to safety are also very effective communication devices. If you cannot devote resources to an entire publication, make safety a featured item in every issue of your company newsletter.
  • A safety suggestion box can be used by employees, anonymously if desired, to communicate their concerns to management.
  • Publish a brief company safety policy or statement informing all employees that safety is a priority issue with management, and urge employees to actively participate in the program for the common good of all concerned. (Model policy, statements are found in Appendix A.)
  • Communicate your concerns about safety to all levels of management.
  • Document all communication efforts, as you will be required to demonstrate that a system of effective communication is in place.

Hazard Assessment & Control

Periodic inspections and procedures for correction and control provide a method of identifying existing or potential hazards in the workplace, and eliminating or controlling them. Hazard control is the heart of an effective Injury and Illness Prevention Program.

If hazards occur or recur, this reflects a breakdown in the hazard control system. The hazard control system is also the basis for developing safe work procedures and injury/illness prevention training.

The required hazard assessment survey of your establishment, when first developing your Injury and Illness Prevention Program, must be made by a qualified person. This survey can provide the basis and guide for establishing your hazard assessment and control system. The survey produces knowledge of hazards that exist in the workplace, and conditions, equipment and procedures that could be potentially hazardous.

An effective hazard control system will:

• identify hazards that exist or develop in your workplace,
• how to correct those hazards and steps you can take to prevent their recurrence.

If you have an effective system for monitoring workplace conditions:

• You will be able to prevent many hazards from occurring through scheduled and documented self-inspections.
• Make sure established safe work practices are being followed and those unsafe conditions or procedures are identified and corrected properly.
• Scheduled inspections are in addition to the everyday safety and health checks that are part of the routine duties of managers and supervisors.

The frequency of these inspections depends on

• the operations involved,
• the magnitude of the hazards,
• the proficiency of employees,
• changes in equipment or work processes, and
• the history of workplace injuries and illnesses

Inspections should be conducted by personnel who, through experience or training, are able to identify actual and potential hazards and understand safe work practices.

Written inspection reports must be reviewed by management and/or the safety committee. The review should assist in prioritizing actions and verifying the completion of previous corrective actions. Overall inspection program results should be reviewed for trends.

Know which safety standards apply to your workplace and use them to identify potential hazards.

Your employees should be encouraged to tell you or their supervisors of possibly hazardous situations, knowing their reports will be given prompt and serious attention without fear of reprisal. When you let them know that the situation was corrected (or why it was not hazardous), you create a system by which your employees continue to report hazards promptly and effectively.

Workplace equipment and personal, protective equipment should be maintained in safe and good working conditions.

Hazards should be corrected as soon as they are identified. For any that can’t be immediately corrected, set a target date for correction based on such considerations as the probability and severity of an injury or illness resulting from the hazard; the availability of needed equipment, materials and/or personnel; time for delivery, installation, modification or construction; and training periods.

Provide interim protection to employees who need it while the correction of hazards is proceeding. A written tracking system such as a log helps you monitor the progress of hazard correction.

You should review and prioritize your program based on the severity of the hazard.

 

Accident Investigation

A primary tool you should be using in an effort to identify and recognize the areas responsible for accidents is a thorough and properly completed accident investigation. It should be in writing and adequately identify the cause(s) of the accident or near-miss occurrence.

Accident investigations should be conducted by trained individuals with the primary focus of understanding why the accident or near miss occurred and what actions can be taken to preclude recurrence. In large organizations, this responsibility may be assigned to the safety director. In smaller organizations, the responsibility may lie directly with the supervisor responsible for the affected area or employee.

Questions to ask in an accident investigation include:

• What happened?
  • The investigation should describe what took place that prompted the investigation: an injury to an employee, an incident that caused a production delay, damaged material or any other conditions recognized as having a potential for losses or delays.
• Why did the incident happen?
  • The investigation must obtain all the facts surrounding the occurrence: what caused the situation to occur; who was involved; was/were the employee(s) qualified to perform the functions involved in the accident or near miss; were they properly trained; were proper operating procedures established for the task involved; were procedures followed, and if not, why not; where else this or a similar situation might exist, and how it can be corrected.
• What should be done?
  • The person conducting the investigation must determine which aspects of the operation or processes require additional attention. It is important to note that the purpose here is not to establish blame, but to determine what type of constructive action can eliminate the cause(s) of the accident or near miss.
• What action has been taken?
  • Action already taken to reduce or eliminate the exposures being investigated should be noted, along with those remaining to be addressed. Any interim or temporary precautions should also be noted. Any pending corrective action and reason for delaying its implementation should be identified.

Corrective action should be identified in terms of not only how it will prevent a recurrence of the accident or near miss, but also how it will improve the overall operation. This will assist the investigation in selling his/her solutions to management. The solution should be a means of achieving not only accident control but also total operation control.

If you have a safety and health committee, its members should review investigations of all accidents and near-miss incidents to assist in recommending appropriate corrective actions to prevent a similar recurrence.

A thorough investigation of all accidents and near misses will help you identify causes and needed corrections and can help you determine why accidents occur, where they happen, and any accident trends. Such information is critical to preventing and controlling hazards and potential accidents.

 

Safety Planning, Rules & Work Procedures

Planning for safety and health is an important part of every business decision, including purchasing, engineering, changes in work processes, and planning for emergencies. Your safety and health planning are effective when your workplace has:

Rules are written to apply to everyone and address areas such as personal protective equipment, appropriate clothing, expected behavior, and emergency procedures. You and your employees should periodically review and update all rules and procedures to make sure they reflect present conditions.

Rules and procedures should be written for new exposures when they are introduced into the workplace.

Safe and healthful work practices are developed for each specific job.

Discipline or reward procedures to help assure that safety rules and work procedures are put into practice and enforced. Reward or positive reinforcement procedures such as bonuses, incentives, or employee recognition programs should provide positive motivation for compliance with safety rules and procedures.

A written plan for emergency situations. Your plan must include a list of emergencies that could arise and a set of procedures in response to each situation. Some emergency procedures, such as those covering medical emergencies or fire evacuation, are mandated by Cal/OSHA regulations.

If you have operations involving hazardous substances, procedures or processes, you must designate emergency response teams to be specifically trained and equipped to handle possible imminent hazards.

 

Safety & Health Training

Training is one of the most important elements of any Injury and Illness Prevention Program. It allows employees to learn their job properly, brings new ideas into the workplace, reinforces existing ideas and practices, and puts your program into action.

Your employees benefit from safety and health training through fewer work-related injuries and illnesses and reduced stress and worry caused by exposure to hazards.

You benefit from reduced workplace injuries and illnesses, increased productivity, lower costs, higher profits, and a more cohesive and dependable workforce.

An effective Injury and Illness Prevention Program includes training for both supervisors and employees. Training for both is required by Cal/OSHA safety orders.

You may need outside professionals to help you develop and conduct your required training program.  Outside trainers should be considered temporary. Eventually, you will need your own in-house training capabilities so you can provide training that is timely and specific to the needs of your workplace and your employees.

To be effective your training program needs to:

• Let your supervisors know:
  • They are key figures responsible for the establishment and success of the I2P2.
  • The importance of establishing and maintaining safe and healthful working conditions.
  • They are responsible for being familiar with safety and health hazards to which their employees are exposed, how to recognize them, the potential effects these hazards have on the employees and rules, procedures, and work practices for controlling exposure to those hazards.
  • How to convey this information to employees by setting good examples, instructing them, making sure they fully understand and follow safe procedures.
  • How to investigate accidents and take corrective and preventive action.

Let your employees know:

• The success of the company’s Injury and Illness Prevention Program depends on their actions as well as yours.
• The safe work procedures required for their jobs and how these procedures protect them against exposure.
• When personal protective equipment is required or needed, how to use it and maintain it in good condition.
• What to do if emergencies occur in the workplace.

An effective Injury and Illness Prevention Program requires proper job performance by everyone in the workplace. Sr management must ensure that all employees are knowledgeable about the materials and equipment they are working with, what known hazards are present, and how they are controlled.

Each employee needs to understand that:

• No employee is expected to undertake a job until he/she has received instructions on how to do it properly and safely, and is authorized to perform the job.
• No employees should undertake a job that appears to be unsafe.
• No employee should use chemicals without fully understanding their toxic properties and without the knowledge required to work with them safely.
• Mechanical safeguards must always be in place and kept in place.
• Employees are to report to a superior or designated individual all unsafe conditions encountered during work.
• Any work-related injury or illness suffered, however slight, must be reported to management at once.
• Personal protective equipment must be used when and where required, and properly maintained.

Your supervisors must recognize that they are the primary safety trainers in your organization. Encourage and help them by providing supervisory training. Many community colleges offer management training courses at little or no cost.

You as the employer are required under Cal/ OSHA standards to establish and carry out a formal training program. A professional training person, an outside consultant or your supervisors may provide injury and illness prevention training to your employees.

This program must, at a minimum, provide training and instruction:

• To all employees when your program is first established.
• To all new employees.
• To all employees given new job assignments for which training has not been previously received.
• Whenever new substances, processes, procedures or equipment are introduced to the workplace and present a new hazard.
• Whenever you or your supervisors are made aware of a new or previously unrecognized hazard.
• For all supervisors to assure they are familiar with the safety and health hazards to which employees under their immediate direction and control may be exposed.

 

Source: https://www.dir.ca.gov/dosh/dosh_publications/IIPP.html#5