Injuries and Illness

I2P2: It’s on OSHA’s Mind, Is It on Yours?

Injury and illness prevention is always a big issue for safety professionals especially when incidents result in days away from work. Many companies are responding with injury and illness prevention plans.

According to BLS, the total number of injury and illness cases requiring days away from work to recuperate was in 2011(the most recent year for which such statistics are available) was 1,181,290. The median days away from work was 8 days.

Some other interesting stats:

  • The severity of injury to men was greater than that to women; men required a median of 10 days to recuperate compared with a median of 7 days for women.
  • Among private industry workers, injuries and illnesses to workers with 1-5 years of service with an employer accounted for 35 percent of the cases. However, the number of cases involving days away from work increased for workers with fewer than 3 months of service (up 3 percent from the previous year) and 3-11 months of service (up 7 percent).
  • Musculoskeletal disorder (MSD) cases (387,820) accounted for 33 percent of all injury and illness cases in 2011. The median days away from work to recuperate from MSDs was 11 days.

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One of the items on OSHA’s regulatory agenda for 2013 and beyond is the development of a federal Injury and Illness Prevention Program (I2P2) standard.

OSHA Chief Dr. David Michaels has said of the I2P2 plan:

  • "We know we do not have, nor will we ever have, enough inspectors in every workplace to ensure all health and safety rules and best practices are followed all the time."
  • "Instead of waiting for an OSHA inspection or a workplace tragedy to address workplace hazards, employers would be required to create a plan for identifying and remediating hazards, and then implement this plan."
  • "I believe it has the potential to change the culture of workplaces across America…"

Of course, I2P2s or written safety plans are not new. California adopted "SB 198" over 20 years ago, and at least 8 states have written safety plan requirements including California, Hawaii, Michigan, Nebraska, Nevada, North Carolina, Oregon, and Washington.

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Planning Your Plan

According to Don Dressler, a consultant who focuses on safety, employment and human resources issues, accident investigations, OSHA compliance, and workers’ compensation (, I2P2 plans typically:

  • Assign responsibilities for safety
  • Specify how you communicate with employees about safety
  • Describe how employee compliance with safety is assured
  • Define how hazards are inspected
  • Specify accident investigation procedures
  • Call for a hazard correction process
  • Plan safety training
  • Detail recordkeeping requirements

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