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June 09, 2014
OSHA’s I2P2 (Injury and Illness Prevention Program) Idea: Many States Have Been There, Done That
By David Galt, Senior Legal Editor - EHS Training

There’s been a lot of discussion about OSHA’s now-tabled proposal to require businesses to create a formal injury and illness prevention program, or “I2P2.” It is not widely known that many states already require certain businesses to have an I2P2, and others offer strong incentives for businesses to implement such programs. Whether OSHA’s proposed rule moves forward or not, I2P2 should not be anything new for employers in the states that require the written programs…unless you are an employer unaware of your state’s requirements.

Many States Require an I2P2, Others Offer Strong Incentives

There are 22 states that require a written injury and illness prevention program for certain industries, mostly as a requirement for worker’s compensation insurance coverage. Many of those states also offer discounts on workers' compensation premium rates of up to 5 percent for qualifying organizations that adopt and implement written safety and health programs.

Some states, like California and Washington, require most workplaces to have a written plan regardless of workers’ compensation coverage, and other states only require them for “high hazard” industries like those conducting a lot of electrical or hazardous chemical handling work. Each state calls them something different; common names are Injury and Illness Prevention Program, Accident Prevention Program, and Loss Control Program.

Some states only require the written plan for employers with worker’s comp experience modification rates, or EMRs, above a threshold that indicates a high-hazard workplace. For example, many states set an EMR threshold of 1.2—at or over that limit will trigger the written plan requirement.

List of States

The states that require some form of I2P2 for certain employers are AK, AZ, CA, HI, KY, LA, ME, MN, MO, MT, NC, NE, NH, NM, NV, NY (government only), OK, OR, PA, TX, UT, VA, WA, and WV. Some of these states also provide I2P2 incentives to certain employers that don’t meet the regulatory threshold for a required plan.

The states that offer incentives for I2P2 plans but don’t require them are CO, FL, MA, ND, OH, and WY.

OSHA-Required Safety Plans

Depending on your type of operation, federal OSHA requires as many as 18 formal written safety plans, and there may be additional requirements from state agencies including workers compensation providers.

For more information and expert insight about OSHA’s written safety plan requirements:

OSHA Requires 18 Safety Plans--Do You Have Yours?
What Is an OSHA Safety Plan?

Compliance Assistance

In the states with regulatory requirements for formal safety plans, their rules direct the regulatory agency or workers’ compensation insurer to provide considerable compliance assistance to each employer to help them create and implement the plan.

There are excellent tips and considerations for developing an I2P2:
I2P2 for High Hazard Workplaces - Tips and Considerations
BLR’s Safety Plans topic page

OSHA’s latest regulatory agenda contains a big surprise 6 key elements of an effective I2P2
Infographic: Job hazard analysis
Final BLS data: Overall fatal injury rate down, but contractor, construction fatalities up
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