Will OSHA’s Injury Illness Prevention Program give you a headache?

March 6, 2013
A formal hazard analysis part of the design process becomes more important because of an OSHA white paper published about a year ago.

OSHA White Paper
Draft Proposed Rule

Equipment designers are often advised to make a formal hazard analysis part of the design process. There is some additional urgency to instituting this practice because of an OSHA white paper published about a year ago.

The OSHA white paper describes the Injury and Illness Prevention Program (IIPP). It is anyone’s guess whether or not the IIPP will become a formal regulation but it’s much more likely if the same leadership stays in place at OSHA after the presidential election.

The part of the proposed IIPP that most interests designers is a section on hazard identification and assessment. It requires that all new equipment be inspected for hazards before being installed in the workplace. It also requires this inspection at other times after the equipment is in place. You’ll have to rank the hazards discovered by severity and correct those that are correctable.

One problem is that this requirement gives no objective method to determine hazard severity. So companies will have to develop their own method.

It is up to those purchasing the equipment to identify and correct hazards. It’s also their responsibility to figure out a way to rank uncorrectable issues by severity. As purchasers identify hazards, they will look for ways to correct them. At a minimum, that will most likely mean more conversations between purchasers and equipment suppliers about what is safe and unsafe on equipment being designed and introduced into facilities. These conversations will almost certainly extend back to equipment designers.

The most immediate way IIPP will affect engineering firms is that it requires them to develop a formal IIPP program that includes common components such as demonstrating management leadership and employee participation; showing they identify and assess hazards; have formal ways of preventing and controlling hazards; undertake training; and have ways of evaluating how effective they are at doing all this. Note: The Proposed IIPP rule will be required for all employers excluding those in construction and agriculture or those that meet a grandfather exemption clause.

Finally, it should be said that IIPP programs are not a new concept. In fact, many states have had them or currently require some employers to have a program in place. The most well known is in California, where these types of programs began in 1991. The Golden State saw a 19% drop in injuries and illnesses after the first five years of implementation. Fatalities dropped by as much as 31% below the national average in 2009, though it is unknown whether this was solely because of the mandatory IIPP program.

Joe Tavenner

Joe Tavenner CSP, CFPS, is a long-time Certified Safety Professional who works in occupational safety and design for safety. Got a question about safety? You can reach Joe at [email protected].

Edited by Leland Teschler

© 2013 Penton Media, Inc.

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