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July 21, 2012

OSHA Initiatives Every Employer Should Track

In a recent article in Workplace HR & Safety magazine, a workplace safety expert from MSDSonline offers his views and advice on a number of OSHA initiatives related to incident reporting and recordkeeping. P.J. Schoeny identifies five items that "could have profound repercussions for employers in the near future." Here are some key points from the article:

OSHA safety signs1. I2P2
I2P2 is the Injury and Illness Prevention Program and is described by OSHA as "a proactive process to help employers find and fix workplace hazards before workers are hurt." OSHA Director Dr. David Michaels has repeatedly said in recent years that implementing an I2P2 standard is one of the agencies top priorities.

2. Modernization of OSHA's Injury and Illness Data Collection Process
OSHA is working on an important update to its method of collecting data. This initiative could easily lead to a requirement that every employer provide injury and illness information directly to OSHA on an annual, semi-annual, or even quarterly basis.

3. Recordkeeping Update
OSHA issued a proposed rule in June of 2011 and is currently working on the final rule. Specifically, OSHA is working to move from the Standard Industrial Classification (SIC) system to the North American Industry Classification System (NAICS).

4. Crackdown on IncentivesOSHA Safety First sign

In March, OSHA issued a memo to keep their offices on the lookout for incentive programs that reward employees for not getting injured. Given OSHA's crackdown on employer incentive programs, employers should review their own safety programs to ensure they are in alignment with OSHA's view on the practice.

5. Whistleblower Programs
OSHA has turned up the heat on whistleblowing in recent years. One of the key changes at OSHA in 2012 is the placing of the Whistleblower Protection Program under direct control of OSHA Director Dr. Michaels. In recent months, OSHA has revised guidelines for investigating whistleblowing cases and has made a concerted effort to build awareness and promote its resources for whistleblowers - including a dedicated website at

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