OSHA “I2P2″ Delayed Until September, 2014

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RIN Data
DOL/OSHA RIN: 1218-AC48 Publication ID: Fall 2013
Title: Injury and Illness Prevention Program
Abstract: OSHA is developing a rule requiring employers to implement an Injury and Illness Prevention Program. It involves planning, implementing, evaluating, and improving processes and activities that protect employee safety and health. OSHA has substantial data on reductions in injuries and illnesses from employers who have implemented similar effective processes. The Agency currently has voluntary Safety and Health Program Management Guidelines (54 FR 3904 to 3916), published in 1989. An injury and illness prevention program rule would build on these guidelines as well as lessons learned from successful approaches and best practices under OSHA’s Voluntary Protection Program Safety and Health Achievement Recognition Program, and similar industry and international initiatives such as American National Standards Institute/American Industrial Hygiene Association Z10 and Occupational Health and Safety Assessment Series 18001.
Agency: Department of Labor(DOL) Priority: Economically Significant
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage
Major: Undetermined Unfunded Mandates: Undetermined
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.)
Legal Authority: 29 USC 653; 29 USC 655(b); 29 USC 657
Legal Deadline:  None
Timetable:

Action Date FR Cite
Stakeholder Meetings 06/03/2010 75 FR 35360 and 75 FR 23637
Initiate SBREFA 01/06/2012
NPRM 09/00/2014
Regulatory Flexibility Analysis Required: Yes Government Levels Affected: Undetermined
Small Entities Affected: Businesses Federalism: Undetermined
Included in the Regulatory Plan: No
RIN Data Printed in the FR: Yes
Agency Contact:
William Perry
Acting Director, Directorate of Standards and Guidance
Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue NW., Room N-3718,
Washington, DC 20210
Phone:202 693-1950
Fax:202 693-1678
Email: perry.bill@dol.gov

Introduction/Executive Summary

Image of workers An injury and illness prevention program,1 is a proactive process to help employers find and fix workplace hazards before workers are hurt. We know these programs can be effective at reducing injuries, illnesses, and fatalities. Many workplaces have already adopted such approaches, for example as part of OSHA‘s cooperative programs. Not only do these employers experience dramatic decreases in workplace injuries, but they often report a transformed workplace culture that can lead to higher productivity and quality, reduced turnover, reduced costs, and greater employee satisfaction.

Thirty-four states and many nations around the world already require or encourage employers to implement such programs. The key elements common to all of these programs are management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.

Based on the positive experience of employers with existing programs, OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to a significantly improved workplace health and safety environment. Adoption of an injury and illness prevention program will result in workers suffering fewer injuries, illnesses and fatalities. In addition, employers will improve their compliance with existing regulations, and will experience many of the financial benefits of a safer and healthier workplace cited in published studies and reports by individual companies, including significant reductions in workers’ compensation premiums.

Background

In the four decades since the Occupational Safety and Health Act (OSH Act) was signed into law, workplace deaths and reported occupational injuries have dropped by more than 60 percent. Yet the nation’s workers continue to face an unacceptable number of work-related deaths, injuries and illnesses, most of them preventable:

  • Every day, more than 12 workers die on the job – over 4,500 a year.
  • Every year, more than 4.1 million workers suffer a serious job-related injury or illness.

An enhanced focus on prevention is needed to bring these numbers down. To accomplish this, an effective, flexible, commonsense tool is available that can dramatically reduce the number and severity of workplace injuries and illnesses: the injury and illness prevention program. This tool helps employers find hazards and fix them before injuries, illnesses or deaths occur. It helps employers meet their obligation under the OSH Act to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” It also helps employers avoid the significant costs associated with injuries and illnesses in the workplace.

Injury and illness prevention programs are not new, nor are they untested. Most large companies whose safety and health achievements have been recognized through government or industry awards cite their use of injury and illness prevention programs as their key to success. Convinced of the value, effectiveness, and feasibility of these programs, many countries around the world now require employers to implement and maintain them. These countries include Canada, Australia, all 27 European Union member states, Norway, Hong Kong, Japan and Korea. This initiative also follows the lead of 15 U.S. states that have already implemented regulations requiring such programs.

How Does an Injury and Illness Prevention Program Work?

Most successful injury and illness prevention programs include a similar set of commonsense elements that focus on finding all hazards in the workplace and developing a plan for preventing and controlling those hazards. Management leadership and active worker participation are essential to ensuring that all hazards are identified and addressed. Finally, workers need to be trained about how the program works and the program needs to be periodically evaluated to determine whether improvements need to be made.

These basic elements – management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement – are common to almost all existing health and safety management programs. Each element is important in ensuring the success of the overall program, and the elements are interrelated and interdependent.

When it comes to injury and illness prevention programs, every business is different, and one size certainly does not fit all. Employers who implement injury and illness prevention programs scale and adapt these elements to meet the needs of their organizations, depending on size, industry sector or complexity of operations.

What Are the Costs of Workplace Injuries, Illnesses and Deaths to Employers, Workers and the Nation?

The main goal of injury and illness prevention programs is to prevent workplace injuries, illnesses and deaths, the suffering these events cause workers, and the financial hardship they cause both workers and employers.

Workplace incidents cause an enormous amount of physical, financial and emotional hardship for individual workers and their families. Combined with insufficient workers’ compensation benefits and inadequate medical insurance, workplace injuries and illnesses can not only cause physical pain and suffering but also loss of employment and wages, burdensome debt, inability to maintain a previous standard of living, loss of home ownership and even bankruptcy. When implemented effectively, injury and illness prevention programs can help workers and their families avoid these disruptive and sometimes calamitous impacts on their lives.

Image - Cost of the Most Disabling Injuries 1998-2008 Chart At the same time, these programs will help employers avoid the substantial cost impacts and business disruptions that accompany occupational injuries, illnesses and deaths. One widely-cited source regarding estimates of the magnitude of these costs is the Liberty Mutual Research Institute, which reports the direct cost of the most disabling workplace injuries in 2008 to be $53 billion (Liberty Mutual Research Institute, 2010).2 Another source, the National Academy of Social Insurance (NASI), estimates the annual workers’ compensation benefits paid for all compensable injuries and illnesses in 2009 at $58 billion (National Academy of Social Insurance, 2011). NASI further reports the total costs paid by employers for workers’ compensation increased from $60 billion in 2000 to $74 billion in 2009.

In addition to these direct costs, employers incur a variety of other costs that may be hidden or less obvious when an employee is injured or ill, but in most cases involve real expenditures of budget or time. These expenditures are commonly referred to as indirect costs and can include:

  • Any wages paid to injured workers for absences not covered by workers’ compensation;
  • The wage costs related to time lost through work stoppage;
  • Administrative time spent by supervisors following injuries;
  • Employee training and replacement costs;
  • Lost productivity related to new employee learning curves and accommodation of injured employees; and
  • Replacement costs of damaged material, machinery and property.

OSHA has historically used the results of one study (Stanford University, 1981) that found the indirect costs can range from 1.1 (for the most severe injuries) to 4.5 (for the least severe injuries) times the direct costs.3

“Establishing safety as a value rather than a priority tells our employees and our customers that safety is built into our culture, not something we do to merely comply with regulations.

Our excellent safety performance over the past seven years has been a key factor in reducing our insurance cost. Our low EMR [Experience Modification Rate], incidents rates, and SHARP Management System have impressed our customers and, in many cases, was a key factor in selecting Parsons to perform their project.”

Charles L. Harrington, Chairman & CEO, Parsons Corp.

Source: National Safety Council.

When workers are killed, are injured or become ill, there are substantial costs beyond those borne by employers. A variety of approaches can be used to estimate these costs. For example, Viscusi and Aldy (2003) provided estimates of the monetary value of each life lost. OSHA updated these estimates (to account for inflation) to 2010 dollars, yielding a value of $8.7 million for each life lost. Multiplying this value by the 4,547 workplace deaths reported by the Bureau of Labor Statistics for 2010, OSHA estimates the annual cost of known workplace fatalities to be nearly $40 billion.

This estimate does not include the cost of non-fatal injuries, or of occupational illnesses like cancer and lung disease. These illnesses generally may occur many years or even decades after workers are exposed and are therefore seldom recorded in government statistics or employer surveillance activities.

The human and economic costs of these conditions are indisputably enormous. Leigh et al. (1997) estimated that more than 60,000 workers die each year from occupational illnesses, and more than 850,000 develop new illnesses annually. Similarly, Steenland et al. (2003) estimated that between 10,000 and 20,000 workers die each year from cancer due to occupational exposures, and between 5,000 and 24,000 die from work-related Chronic Obstructive Pulmonary Disease.

In summary, the number and costs of workplace injuries, illnesses and fatalities are unacceptably high. Injury and illness prevention programs have been proven to help employers and society reduce the personal, financial and societal costs that injuries, illnesses and fatalities impose. As described below, the thousands of workplaces that have implemented these programs in some form have already witnessed the resulting benefits, in the form of higher efficiency, greater worker productivity and lower costs.

What Is the Evidence that Injury and Illness Prevention Programs Protect Workers and Improve the “Bottom Line”?

Image - Top Benetits of Effective Workplace Safety Programs ChartNumerous studies have examined the effectiveness of injury and illness prevention programs at both the establishment and corporate levels (e.g., Alsop and LeCouteur, 1999; Bunn et al., 2001; Conference Board, 2003; Huang et al., 2009; Lewchuk, Robb, and Walters, 1996; Smitha et al., 2001; Torp et al., 2000; Yassi, 1998). This research demonstrates that such programs are effective in transforming workplace culture; leading to reductions in injuries, illnesses and fatalities; lowering workers’ compensation and other costs; improving morale and communication; enhancing image and reputation; and improving processes, products and services. The studies also highlight important characteristics of effective programs, including management commitment and leadership, effective employee participation, integration of health and safety with business planning and continuous program evaluation. They suggest that programs without these features are not as effective (Shannon et al., 1996, 1997; Gallagher, 2001; Gallagher et al., 2003; Liu et al., 2008).

One study (Smitha et al., 2001) focused on manufacturing facilities in 13 states with mandatory injury and illness prevention programs and/or mandatory health and safety committee requirements. The authors found that both types of regulations were effective in reducing injury and illness incidence rates. Three of the four states with only safety and health program requirements experienced the greatest reductions in injury and illness rates following promulgation of these mandatory program regulations.

OSHA examined the injury and illness prevention programs in eight states where the state had either required a program or provided incentives or requirements through its workers’ compensation programs. The successes of these state programs, which lowered injury and illness incidences by 9 percent to more than 60 percent, are discussed below: Source: Huang et al., 2009. Data based on responses from 231 U.S. companies with 100 or more employees.

  • Alaska had an injury and illness plan requirement for over 20 years (1973 to 1995). Five years after the program was implemented, the net decrease in injuries and illnesses (i.e., the statewide reduction in injuries and illnesses over and above the national decrease during the same time period) for Alaska was 17.4 percent.
  • California began to require an injury and illness prevention program in 1991. Five years after this requirement began, California had a net decrease in injuries and illnesses of 19 percent.
  • Colorado has a program that allows firms to adopt basic injury and illness prevention program components in return for a workers’ compensation premium reduction. The cumulative annual reduction in accidents was 23 percent and the cumulative reduction in accident costs was between 58 and 62 percent.
  • Hawaii began to require employers to have injury and illness prevention programs in 1985. The net reduction in injuries and illnesses was 20.7 percent.
  • Massachusetts Workers’ Compensation program firms receive a premium credit for enrolling in a loss management program. In the first year of this program, firms participating in the program had a 20.8 percent improvement in their loss ratios.
  • North Dakota has a program under its workers’ compensation program for employers who have a risk management program. The incentive is a 5 percent discount on annual workers’ compensation premiums. These risk management programs contain many of the elements of an injury and illness prevention program. They resulted in a cumulative decline for serious injuries of 38 percent over a four-year period.
  • Texas had a program under its workers’ compensation commission from 1991 to 2005 which identified the most hazardous workplaces. Those employers were required to develop and implement injury and illness prevention programs. The reduction in injuries, over a four-year period (1992-1995), averaged 63 percent each year.
  • Washington began requiring establishments to have injury and illness prevention programs in 1973. Five years later the net decrease in injuries and illnesses was 9.4 percent.

OSHA also examined fatality rates and found that California, Hawaii and Washington, with their mandatory injury and illness prevention program requirements, had workplace fatality rates as much as 31 percent below the national average in 2009.

Liu et al. (2008) examined the effectiveness of Pennsylvania’s voluntary program that provides workers’ compensation premium discounts to employers that establish joint labor-management safety committees. These committees are responsible for implementing several injury and illness prevention program elements: hazard identification, workplace inspection and safety management. The authors found that among program participants there was a strong association between improved injury and illness experience and the level of compliance with the program requirements. This is further evidence that programs with strong management commitment and active worker participation are effective in reducing injury risk, while “paper” programs are, not surprisingly, ineffective.

There are many benefits from developing a safety culture at your company – none of which is more valuable than employee loyalty. When employees know you care about their personal well-being and you prove that to them in their workplace, it increases morale, engagement, awareness, motivation and productivity.”

Daniel R. Nobbe, Plant Leader, Fiberteq LLC, Danville, IL.

Source: National Safety Council.

The literature on injury and illness prevention programs also includes numerous studies that attempt to identify the critical success features associated with superior health and safety performance. Gallagher (2001) concludes that management commitment and employee involvement are the keys to program success: “[R]ecurring findings across these studies were the critical role played by senior managers in successful health and safety management systems, and the importance of effective communication, employee involvement and consultation.”

Worker participation, a fundamental element of injury and illness prevention programs, makes an important contribution to an employer’s bottom line. When workers are encouraged to offer their ideas and they see their contributions being taken seriously, they tend to be more satisfied and more productive (Huang et al., 2006). Engaging employees in dialogue with management and each other about safety and health can lead to improved relationships and better overall communication, along with reduced injury rates. Improved employee morale and satisfaction translates to greater loyalty, lower absenteeism and higher productivity.

This body of research, combined with studies of individual companies (see boxes, below, with Case Studies of Programs Implemented under OSHA’s Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP)) demonstrate clearly that injury and illness prevention programs are effective at the establishment level in dramatically reducing risk of workplace injury. This effect has also been detected in state-wide comparisons.

Based on its review of the literature on the effectiveness of these programs and on the experience of the states that have implemented injury and illness prevention program requirements, OSHA estimates that implementation of injury and illness prevention programs will reduce injuries by 15 percent to 35 percent for employers who do not now have safety and health programs. At the 15 percent program effectiveness level, this saves $9 billion per year in workers’ compensation costs; at the 35 percent effectiveness level the savings are $23 billion per year.4 In addition to these workers’ compensation savings, employers could also save indirect costs incurred when an employee is injured or ill. Beyond the monetized benefits of injuries and illnesses averted, and lives saved, nonmonetized costs of workplace injuries and deaths include uncompensated lost wages, the loss of human capital assets, the loss of productivity, the cost of other government benefits required by injured workers or their survivors, the loss of government tax revenues, other business expenses, and other losses not compensated by workers’ compensation or other insurance.

How Widespread are Injury and Illness Prevention Programs?

Photo: Elena Finizio, Braintree, MA Area Office
Photo: Elena Finizio, Braintree, MA Area Office

Employers across the United States have implemented injury and illness prevention programs, and many jurisdictions, in the United States and abroad, currently require or encourage implementation of these programs. Currently, 34 U.S. states have established laws or regulations designed to require or encourage injury and illness prevention programs, including 15 states with mandatory regulations for all or some employers.5 Other states, while not requiring programs, have created financial incentives for employers to implement injury and illness prevention programs. In some instances this involves providing – or facilitating – workers’ compensation insurance premium reductions for employers who establish programs meeting specified requirements. And 16 states, in all three of these groups, provide an array of voluntary guidance, consultation and training programs, and other assistance aimed at helping and encouraging employers to implement injury and illness prevention programs. Depending on the state, these programs apply to all employers, employers above or below a certain size threshold, employers with injury and illness rates above industry average, employers in “high-hazard” industries or employers with above-average workers’ compensation experience modification rates.

The more than 2,400 establishments that belong to OSHA’s Voluntary Protection Program have programs that are based on the same core elements found in the injury and illness prevention program that OSHA will be proposing. The same is true for OSHA’s Safety and Health Achievement Recognition Program, in which more than 1,500 smaller employers are enrolled. Each year, dozens of organizations seeking international recognition for their safety and health program proudly submit applications to the National Safety Council for the Robert W. Campbell award (see text box). Case studies of past winners are available on the Campbell Award website.

Recognizing Business Excellence in Safety and Health

The Robert W. Campbell Award recognizes organizations that achieve business excellence by integrating environmental, health and safety (EHS) management into their business operating systems. The Award aims to:

  • Recognize businesses that uphold EHS as a key business value and link measurable achievement in EHS performance to productivity and profitability.
  • Establish a validated process by which industries can measure the performance of their EHS operations system against well-tested and internationally accepted key performance indicators.
  • Use a rigorous systematic review process to capture and evaluate the successes and lessons learned.
  • Share leading edge EHS management systems and best practices for educational purposes worldwide.

The Award program is supported by a network of 22 Global Partners across five continents committed to promoting EHS as an integral component of business management worldwide.

Source: www.campbellaward.org.

There are at least two industry consensus standards for injury and illness prevention programs. The American National Standards Institute (ANSI) and American Industrial Hygiene Association (AIHA) have published a voluntary consensus standard, ANSI/AIHA Z10 – 2005 Occupational Safety and Health Management Systems (ANSI/AIHA, 2005). The Occupational Health and Safety Assessment Series (OHSAS) Project Group, a consortium of selected Registrars, national standards bodies, professional associations and research institutes, has produced a similar document, OHSAS 18001 – 2007 Occupational Health and Safety Management Systems (OHSAS Project Group, 2007). These consensus-based standards have been widely accepted in the world of commerce and adopted by many businesses on a voluntary basis.

Canada, Australia and all members of the European Union operate programs that either require employers to adopt injury and illness prevention programs, or provide incentives or recognition to those who do so. For example, under the 1989 EU Framework Directive (89/391), EU member countries must have national legislation in place requiring employers to maintain risk identification and prevention programs that are very similar to OSHA’s injury and illness prevention program concept (European Union, 1989). U.S. companies operating internationally are familiar with these requirements and have already put in place their own programs to meet these requirements. Finally, many private workers’ compensation carriers offer incentives to employers who have injury and illness prevention programs and provide technical assistance to help them implement their programs.

Photo: Frank Wenzel, Washington DOSH

Photo: Frank Wenzel, Washington DOSH

The United States Departments of Defense (DOD) and Energy (DOE) have both adopted this approach for protecting workers employed or stationed at the nation’s military installations and nuclear weapons factories, including DOE’s high hazard establishments. The success of DOD’s program is described in the box below. DOE’s program, entitled Integrated Safety Management, includes an expectation that the facilities will “embrace a strong safety culture where safe performance of work and involvement of workers in all aspects of work performance are core values that are deeply, strongly, and consistently held by managers and workers.” According to DOE, the aspects of this safety culture that impact safety performance are Leadership, Employee/Worker Involvement and Organizational Learning (DOE, 2011).

Despite the value to employers and workers in terms of injuries prevented and dollars saved, many U.S. workplaces have not yet adopted injury and illness prevention programs. Based on the positive experience of employers with existing programs, OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to significantly improved workplace health and safety environments. Adoption of injury and illness prevention program will result in workers suffering fewer injuries, illnesses and fatalities. In addition, employers will improve their compliance with existing regulations, and will experience many of the financial benefits of a safer and healthier workplace described in the literature and in reports by individual companies.

Are Injury and Illness Prevention Programs Too Complicated and Expensive for Small Businesses?

For many small businesses, establishing an injury and illness prevention program may seem daunting. Any program based on formal structures can be difficult to establish in a small organization because of tight budgets. Yet simple, low-cost approaches have been shown to be effective in small businesses (Hasle and Limborg, 2006). Injury and illness prevention programs lend themselves to such low-cost approaches because they are highly flexible – the core elements can be implemented at a basic level suitable for the smallest business, as well as at a more advanced, structured level that may be needed in a larger, more complex organization.

OSHA’s Safety and Health Achievement Recognition Program (SHARP), which recognizes small employers that operate exemplary injury and illness prevention programs, provides compelling evidence that such programs can and do work for small businesses. For example, the Ohio Bureau of Workers’ Compensation (2011) analyzed the policies of 16 SHARP employers over a 12-year period from 1999 to 2010. The study compared the employers’ experience prior to and after achieving entry into the SHARP program. The preliminary results of the study show that the average number of claims for these employers decreased by 52 percent, the average claim cost decreased by 80 percent, the average lost time per claim decreased by 87 percent, and claims (per million dollars of payroll) decreased by 88 percent.

An internal OSHA study of nine SHARP firms, ranging in size from 15 to 160 employees, found that the firms achieved the following as a result of their programs:

  • A reduction in the number of injuries and illnesses.
  • Improved compliance with regulatory requirements.
  • Improved business and cost savings including reduced workers’ compensation premiums, reduced administrative and human resources burden associated with filing injury and illness reports, managing workers’ compensation cases and training new employees. The companies also experienced improved efficiency in operations and material use, and improved productivity. They were able to leverage their limited health and safety resources.
  • An improved workplace environment with greater collective responsibility for workplace health and safety.
  • Improved reputation and image in the community including relationships and cooperation between employers and OSHA, between employers and employees, and among employers in the business community.

Conclusions

  • Despite the combined efforts of employers, workers, unions, safety professionals and regulators, more than 4,500 workers lose their lives and more than four million are seriously injured each year. Tens of thousands more die or are incapacitated because of occupational illnesses including many types of cancer and lung disease. The human toll from this loss is incalculable and the economic toll is enormous.
  • Many employers in the U.S. have been slow to adopt a workplace “safety culture” that emphasizes planning and carrying out work in the safest way possible.
  • Injury and illness prevention programs are based on proven managerial concepts that have been widely used in industry to bring about improvements in quality, environment and safety, and health performance. Effective injury and illness prevention programs emphasize top-level ownership of the program, participation by employees, and a “find and fix” approach to workplace hazards.
  • Injury and illness prevention programs need not be resource-intensive and can be adapted to meet the needs of any size organization.
Photo: Roberto Rodriguez, Mesquite, Texas

Photo: Roberto Rodriguez, Mesquite, Texas

OSHA believes that adoption of injury and illness prevention programs based on simple, sound, proven principles will help millions of U.S. businesses improve their compliance with existing laws and regulations, decrease the incidence of workplace injuries and illnesses, reduce costs (including significant reductions in workers’ compensation premiums) and enhance their overall business operations.

References

Alsop, P. & LeCouteur, M. (1999). Measurable success from implementing an integrated OHS management system at Manningham City Council. Journal of Occupational Health & Safety – Australia & New Zealand, 15, 565–572.

Angello, J. (2010). A journey to improved safety performance. The Leader, 19(3), 27-29.

ANSI/AIHA (2005). American National Standard – Occupational Health and Safety Management Systems. ANSI/AIHA Z10–2005.

Bunn, W. B. et al. (2001). Health, safety, and productivity in a manufacturing environment. Journal of Occupational and Environmental Medicine 43(1), 47-55.

Bureau of Labor Statistics. (2010). Table A-1. Fatal occupational injuries by industry and event or exposure, All United States, 2010. Available at: http://www.bls.gov/iif/oshwc/cfoi/cftb0241.pdf*

Conference Board. (2003). Driving toward “0″: Best practices in corporate safety and health.

DOE, (2011). U.S. Department of Energy, Office of Health, Safety and Security. A basic overview of Integrated Safety Management.

European Union, (1989). Council Directive of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work. (89/391/EEC).

Gallagher, C. (2001). New directions: Innovative management plus safe place. In W. Pearse, C. Gallagher, & L. Bluff, (eds.) Occupational health & safety management systems: Proceedings of the first national conference (pp. 65-82).

Gallagher, C. et al. (2003). Occupational safety and health management systems in Australia: Barriers to success. Policy and Practice in Health and Safety 1(2), 67-81.

Hasle, P. & Limborg, H. (2006). A review of the literature on preventive occupational health and safety activities in small enterprises. Industrial Health 44(1), 6-12.

Huang, Y. H. et al. (2006). Safety climate and self-reported injury: Assessing the mediating role of employee safety control. Accident Analysis and Prevention 38(3), 425-33.

Huang, Y. H. et al. (2009). Financial decision-makers’ views on safety: What SH&E professionals should know. Professional Safety (April), 36-42.

Leigh, J. P. et al. (1997). Occupational injury and illness in the United States: Estimates of costs, morbidity, and mortality. Annals of Industrial Medicine 157(14), 1557-1568.

Lewchuk, W., Robb, A., & Walters, V. (1996). The Effectiveness of Bill 70 and Joint Health and Safety Committees in Reducing Injuries in the Workplace: The Case of Ontario. Canadian Public Policy, 22, 225-243.

Liberty Mutual Research Institute. (2010). 2010 Liberty Mutual Workplace Safety Index.

Liu, H. et al. (2008). The Pennsylvania Certified Safety Committee Program: An Evaluation of Participation and Effects on Work Injury Rates. RAND Working Paper WR-594-PA.

National Academy of Social Insurance. (2011). Workers’ Compensation: Benefits, Coverage, and Costs, 2009.

Ohio Bureau of Workers’ Compensation. (2011). Ohio 21(d) SHARP Program Performance Assessment.

OHSAS Project Group. (2007). Occupational health and safety management systems – Requirements. OHSAS 18001:2007. Published as a British Standards Institute standard.

Shannon, H. et al. (1996). Workplace organizational correlates of lost-time accident rates in manufacturing. American Journal of Industrial Medicine, 29(3), 258-268.

Shannon, H. et al. (1997). Overview of the relationship between organizational and workplace factors and injury rates. Safety Science, 26, 201-217.

Smitha, M.W. et al. (2001). Effect of state workplace safety laws on occupational injury rates. Journal of Occupational and Environmental Medicine, 43(12), 1001-1010.

Stanford University. (1981). Improving construction safety performance: The user’s role (Technical report No. 260). Department of Civil Engineering.

Steenland, K. et al. (2003). Dying for Work: The Magnitude of US Mortality from Selected Causes of Death Associated with Occupation. American Journal of Industrial Medicine, 43, 461-482.

Torp, S. et al. (2000). Systematic health, environment, and safety activities: Do they influence occupational environment, behavior and health? Occupational Medicine, 50(5), 326-333.

U.S. Department of Energy, Office of Corporate Safety Analysis. (2009a). Occupational Medicine Newsletter. Corporate safety: Health & safety is working!

U.S. Department of Energy, Office of Health, Safety and Security (HSS). (2009b). A basic overview of the worker safety and health program (10 CFR 851). Outreach & Awareness Series to Advance DOE Mission.

Viscusi, W. & Aldy, J. (2003). The value of a statistical life: A critical review of market estimates throughout the world. Journal of Risk and Uncertainty, 27, 5-76.

Yassi, A. (1998). Utilizing Data Systems to Develop and Monitor Occupational Health Programs in a Large Canadian Hospital. Methods of Information and Medicine, 37, 125-129.


Footnotes:

Footnote 1: The occupational safety and health community uses various names to describe systematic approaches to reducing injuries and illnesses in the workplace. Consensus and international standards use the term Occupational Health and Safety Management Systems; OSHA currently uses the term Injury and Illness Prevention Programs and others use Safety and Health Programs to describe these types of systems. Regardless of the title, they all systematically address workplace safety and health hazards on an ongoing basis to reduce the extent and severity of work-related injuries and illnesses.

Footnote 2: The “most disabling” injuries are defined by Liberty Mutual as those causing the injured employee to miss six or more days from work.

Footnote 3: For more details see OSHA’s Safety and Health Management Systems eTool, available at http://www.osha.gov/SLTC/etools/safetyhealth/mod1_costs.html.

Footnote 4: If injury and illness prevention programs achieve a 15 percent reduction in injuries and illnesses for employers who do not currently have safety and health programs, the overall reduction in injuries and illnesses for all employers including those that already have programs is estimated at 12.4 percent. Applying this 12.4 percent to NASI’s estimate of the $74 billion in direct workers’ compensation costs in 2009, workers’ compensation savings could be as high as $9 billion per year. With a 35 percent program effectiveness, the overall reduction in injuries and illnesses for all employers is estimated at 30.8 percent and workers’ compensation savings could reach $23 billion per year.

Footnote 5: The 15 states are: Arkansas, California, Hawaii, Louisiana, Michigan, Minnesota, Mississippi, Montana, North Carolina, New Hampshire, Nevada, New York, Oregon, Utah, and Washington.

Additional Information Can Be Found Here: http://www.osha.gov/dsg/topics/safetyhealth/

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OSHA “I2P2″ Delayed Until September, 2014

osha40-400x122

I2P2 Powerpoint <—- Download Here!

OSHA I2P2 White Paper  <—– Download PDF File Here

Update:

RIN Data
DOL/OSHA RIN: 1218-AC48 Publication ID: Fall 2013
Title: Injury and Illness Prevention Program
Abstract: OSHA is developing a rule requiring employers to implement an Injury and Illness Prevention Program. It involves planning, implementing, evaluating, and improving processes and activities that protect employee safety and health. OSHA has substantial data on reductions in injuries and illnesses from employers who have implemented similar effective processes. The Agency currently has voluntary Safety and Health Program Management Guidelines (54 FR 3904 to 3916), published in 1989. An injury and illness prevention program rule would build on these guidelines as well as lessons learned from successful approaches and best practices under OSHA’s Voluntary Protection Program Safety and Health Achievement Recognition Program, and similar industry and international initiatives such as American National Standards Institute/American Industrial Hygiene Association Z10 and Occupational Health and Safety Assessment Series 18001.
Agency: Department of Labor(DOL) Priority: Economically Significant
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage
Major: Undetermined Unfunded Mandates: Undetermined
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.)
Legal Authority: 29 USC 653; 29 USC 655(b); 29 USC 657
Legal Deadline:  None
Timetable:

Action Date FR Cite
Stakeholder Meetings 06/03/2010 75 FR 35360 and 75 FR 23637
Initiate SBREFA 01/06/2012
NPRM 09/00/2014
Regulatory Flexibility Analysis Required: Yes Government Levels Affected: Undetermined
Small Entities Affected: Businesses Federalism: Undetermined
Included in the Regulatory Plan: No
RIN Data Printed in the FR: Yes
Agency Contact:
William Perry
Acting Director, Directorate of Standards and Guidance
Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue NW., Room N-3718,
Washington, DC 20210
Phone:202 693-1950
Fax:202 693-1678
Email: perry.bill@dol.gov

Introduction/Executive Summary

Image of workers An injury and illness prevention program,1 is a proactive process to help employers find and fix workplace hazards before workers are hurt. We know these programs can be effective at reducing injuries, illnesses, and fatalities. Many workplaces have already adopted such approaches, for example as part of OSHA‘s cooperative programs. Not only do these employers experience dramatic decreases in workplace injuries, but they often report a transformed workplace culture that can lead to higher productivity and quality, reduced turnover, reduced costs, and greater employee satisfaction.

Thirty-four states and many nations around the world already require or encourage employers to implement such programs. The key elements common to all of these programs are management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.

Based on the positive experience of employers with existing programs, OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to a significantly improved workplace health and safety environment. Adoption of an injury and illness prevention program will result in workers suffering fewer injuries, illnesses and fatalities. In addition, employers will improve their compliance with existing regulations, and will experience many of the financial benefits of a safer and healthier workplace cited in published studies and reports by individual companies, including significant reductions in workers’ compensation premiums.

Background

In the four decades since the Occupational Safety and Health Act (OSH Act) was signed into law, workplace deaths and reported occupational injuries have dropped by more than 60 percent. Yet the nation’s workers continue to face an unacceptable number of work-related deaths, injuries and illnesses, most of them preventable:

  • Every day, more than 12 workers die on the job – over 4,500 a year.
  • Every year, more than 4.1 million workers suffer a serious job-related injury or illness.

An enhanced focus on prevention is needed to bring these numbers down. To accomplish this, an effective, flexible, commonsense tool is available that can dramatically reduce the number and severity of workplace injuries and illnesses: the injury and illness prevention program. This tool helps employers find hazards and fix them before injuries, illnesses or deaths occur. It helps employers meet their obligation under the OSH Act to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” It also helps employers avoid the significant costs associated with injuries and illnesses in the workplace.

Injury and illness prevention programs are not new, nor are they untested. Most large companies whose safety and health achievements have been recognized through government or industry awards cite their use of injury and illness prevention programs as their key to success. Convinced of the value, effectiveness, and feasibility of these programs, many countries around the world now require employers to implement and maintain them. These countries include Canada, Australia, all 27 European Union member states, Norway, Hong Kong, Japan and Korea. This initiative also follows the lead of 15 U.S. states that have already implemented regulations requiring such programs.

How Does an Injury and Illness Prevention Program Work?

Most successful injury and illness prevention programs include a similar set of commonsense elements that focus on finding all hazards in the workplace and developing a plan for preventing and controlling those hazards. Management leadership and active worker participation are essential to ensuring that all hazards are identified and addressed. Finally, workers need to be trained about how the program works and the program needs to be periodically evaluated to determine whether improvements need to be made.

These basic elements – management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement – are common to almost all existing health and safety management programs. Each element is important in ensuring the success of the overall program, and the elements are interrelated and interdependent.

When it comes to injury and illness prevention programs, every business is different, and one size certainly does not fit all. Employers who implement injury and illness prevention programs scale and adapt these elements to meet the needs of their organizations, depending on size, industry sector or complexity of operations.

What Are the Costs of Workplace Injuries, Illnesses and Deaths to Employers, Workers and the Nation?

The main goal of injury and illness prevention programs is to prevent workplace injuries, illnesses and deaths, the suffering these events cause workers, and the financial hardship they cause both workers and employers.

Workplace incidents cause an enormous amount of physical, financial and emotional hardship for individual workers and their families. Combined with insufficient workers’ compensation benefits and inadequate medical insurance, workplace injuries and illnesses can not only cause physical pain and suffering but also loss of employment and wages, burdensome debt, inability to maintain a previous standard of living, loss of home ownership and even bankruptcy. When implemented effectively, injury and illness prevention programs can help workers and their families avoid these disruptive and sometimes calamitous impacts on their lives.

Image - Cost of the Most Disabling Injuries 1998-2008 Chart At the same time, these programs will help employers avoid the substantial cost impacts and business disruptions that accompany occupational injuries, illnesses and deaths. One widely-cited source regarding estimates of the magnitude of these costs is the Liberty Mutual Research Institute, which reports the direct cost of the most disabling workplace injuries in 2008 to be $53 billion (Liberty Mutual Research Institute, 2010).2 Another source, the National Academy of Social Insurance (NASI), estimates the annual workers’ compensation benefits paid for all compensable injuries and illnesses in 2009 at $58 billion (National Academy of Social Insurance, 2011). NASI further reports the total costs paid by employers for workers’ compensation increased from $60 billion in 2000 to $74 billion in 2009.

In addition to these direct costs, employers incur a variety of other costs that may be hidden or less obvious when an employee is injured or ill, but in most cases involve real expenditures of budget or time. These expenditures are commonly referred to as indirect costs and can include:

  • Any wages paid to injured workers for absences not covered by workers’ compensation;
  • The wage costs related to time lost through work stoppage;
  • Administrative time spent by supervisors following injuries;
  • Employee training and replacement costs;
  • Lost productivity related to new employee learning curves and accommodation of injured employees; and
  • Replacement costs of damaged material, machinery and property.

OSHA has historically used the results of one study (Stanford University, 1981) that found the indirect costs can range from 1.1 (for the most severe injuries) to 4.5 (for the least severe injuries) times the direct costs.3

“Establishing safety as a value rather than a priority tells our employees and our customers that safety is built into our culture, not something we do to merely comply with regulations.

Our excellent safety performance over the past seven years has been a key factor in reducing our insurance cost. Our low EMR [Experience Modification Rate], incidents rates, and SHARP Management System have impressed our customers and, in many cases, was a key factor in selecting Parsons to perform their project.”

Charles L. Harrington, Chairman & CEO, Parsons Corp.

Source: National Safety Council.

When workers are killed, are injured or become ill, there are substantial costs beyond those borne by employers. A variety of approaches can be used to estimate these costs. For example, Viscusi and Aldy (2003) provided estimates of the monetary value of each life lost. OSHA updated these estimates (to account for inflation) to 2010 dollars, yielding a value of $8.7 million for each life lost. Multiplying this value by the 4,547 workplace deaths reported by the Bureau of Labor Statistics for 2010, OSHA estimates the annual cost of known workplace fatalities to be nearly $40 billion.

This estimate does not include the cost of non-fatal injuries, or of occupational illnesses like cancer and lung disease. These illnesses generally may occur many years or even decades after workers are exposed and are therefore seldom recorded in government statistics or employer surveillance activities.

The human and economic costs of these conditions are indisputably enormous. Leigh et al. (1997) estimated that more than 60,000 workers die each year from occupational illnesses, and more than 850,000 develop new illnesses annually. Similarly, Steenland et al. (2003) estimated that between 10,000 and 20,000 workers die each year from cancer due to occupational exposures, and between 5,000 and 24,000 die from work-related Chronic Obstructive Pulmonary Disease.

In summary, the number and costs of workplace injuries, illnesses and fatalities are unacceptably high. Injury and illness prevention programs have been proven to help employers and society reduce the personal, financial and societal costs that injuries, illnesses and fatalities impose. As described below, the thousands of workplaces that have implemented these programs in some form have already witnessed the resulting benefits, in the form of higher efficiency, greater worker productivity and lower costs.

What Is the Evidence that Injury and Illness Prevention Programs Protect Workers and Improve the “Bottom Line”?

Image - Top Benetits of Effective Workplace Safety Programs ChartNumerous studies have examined the effectiveness of injury and illness prevention programs at both the establishment and corporate levels (e.g., Alsop and LeCouteur, 1999; Bunn et al., 2001; Conference Board, 2003; Huang et al., 2009; Lewchuk, Robb, and Walters, 1996; Smitha et al., 2001; Torp et al., 2000; Yassi, 1998). This research demonstrates that such programs are effective in transforming workplace culture; leading to reductions in injuries, illnesses and fatalities; lowering workers’ compensation and other costs; improving morale and communication; enhancing image and reputation; and improving processes, products and services. The studies also highlight important characteristics of effective programs, including management commitment and leadership, effective employee participation, integration of health and safety with business planning and continuous program evaluation. They suggest that programs without these features are not as effective (Shannon et al., 1996, 1997; Gallagher, 2001; Gallagher et al., 2003; Liu et al., 2008).

One study (Smitha et al., 2001) focused on manufacturing facilities in 13 states with mandatory injury and illness prevention programs and/or mandatory health and safety committee requirements. The authors found that both types of regulations were effective in reducing injury and illness incidence rates. Three of the four states with only safety and health program requirements experienced the greatest reductions in injury and illness rates following promulgation of these mandatory program regulations.

OSHA examined the injury and illness prevention programs in eight states where the state had either required a program or provided incentives or requirements through its workers’ compensation programs. The successes of these state programs, which lowered injury and illness incidences by 9 percent to more than 60 percent, are discussed below: Source: Huang et al., 2009. Data based on responses from 231 U.S. companies with 100 or more employees.

  • Alaska had an injury and illness plan requirement for over 20 years (1973 to 1995). Five years after the program was implemented, the net decrease in injuries and illnesses (i.e., the statewide reduction in injuries and illnesses over and above the national decrease during the same time period) for Alaska was 17.4 percent.
  • California began to require an injury and illness prevention program in 1991. Five years after this requirement began, California had a net decrease in injuries and illnesses of 19 percent.
  • Colorado has a program that allows firms to adopt basic injury and illness prevention program components in return for a workers’ compensation premium reduction. The cumulative annual reduction in accidents was 23 percent and the cumulative reduction in accident costs was between 58 and 62 percent.
  • Hawaii began to require employers to have injury and illness prevention programs in 1985. The net reduction in injuries and illnesses was 20.7 percent.
  • Massachusetts Workers’ Compensation program firms receive a premium credit for enrolling in a loss management program. In the first year of this program, firms participating in the program had a 20.8 percent improvement in their loss ratios.
  • North Dakota has a program under its workers’ compensation program for employers who have a risk management program. The incentive is a 5 percent discount on annual workers’ compensation premiums. These risk management programs contain many of the elements of an injury and illness prevention program. They resulted in a cumulative decline for serious injuries of 38 percent over a four-year period.
  • Texas had a program under its workers’ compensation commission from 1991 to 2005 which identified the most hazardous workplaces. Those employers were required to develop and implement injury and illness prevention programs. The reduction in injuries, over a four-year period (1992-1995), averaged 63 percent each year.
  • Washington began requiring establishments to have injury and illness prevention programs in 1973. Five years later the net decrease in injuries and illnesses was 9.4 percent.

OSHA also examined fatality rates and found that California, Hawaii and Washington, with their mandatory injury and illness prevention program requirements, had workplace fatality rates as much as 31 percent below the national average in 2009.

Liu et al. (2008) examined the effectiveness of Pennsylvania’s voluntary program that provides workers’ compensation premium discounts to employers that establish joint labor-management safety committees. These committees are responsible for implementing several injury and illness prevention program elements: hazard identification, workplace inspection and safety management. The authors found that among program participants there was a strong association between improved injury and illness experience and the level of compliance with the program requirements. This is further evidence that programs with strong management commitment and active worker participation are effective in reducing injury risk, while “paper” programs are, not surprisingly, ineffective.

There are many benefits from developing a safety culture at your company – none of which is more valuable than employee loyalty. When employees know you care about their personal well-being and you prove that to them in their workplace, it increases morale, engagement, awareness, motivation and productivity.”

Daniel R. Nobbe, Plant Leader, Fiberteq LLC, Danville, IL.

Source: National Safety Council.

The literature on injury and illness prevention programs also includes numerous studies that attempt to identify the critical success features associated with superior health and safety performance. Gallagher (2001) concludes that management commitment and employee involvement are the keys to program success: “[R]ecurring findings across these studies were the critical role played by senior managers in successful health and safety management systems, and the importance of effective communication, employee involvement and consultation.”

Worker participation, a fundamental element of injury and illness prevention programs, makes an important contribution to an employer’s bottom line. When workers are encouraged to offer their ideas and they see their contributions being taken seriously, they tend to be more satisfied and more productive (Huang et al., 2006). Engaging employees in dialogue with management and each other about safety and health can lead to improved relationships and better overall communication, along with reduced injury rates. Improved employee morale and satisfaction translates to greater loyalty, lower absenteeism and higher productivity.

This body of research, combined with studies of individual companies (see boxes, below, with Case Studies of Programs Implemented under OSHA’s Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP)) demonstrate clearly that injury and illness prevention programs are effective at the establishment level in dramatically reducing risk of workplace injury. This effect has also been detected in state-wide comparisons.

Based on its review of the literature on the effectiveness of these programs and on the experience of the states that have implemented injury and illness prevention program requirements, OSHA estimates that implementation of injury and illness prevention programs will reduce injuries by 15 percent to 35 percent for employers who do not now have safety and health programs. At the 15 percent program effectiveness level, this saves $9 billion per year in workers’ compensation costs; at the 35 percent effectiveness level the savings are $23 billion per year.4 In addition to these workers’ compensation savings, employers could also save indirect costs incurred when an employee is injured or ill. Beyond the monetized benefits of injuries and illnesses averted, and lives saved, nonmonetized costs of workplace injuries and deaths include uncompensated lost wages, the loss of human capital assets, the loss of productivity, the cost of other government benefits required by injured workers or their survivors, the loss of government tax revenues, other business expenses, and other losses not compensated by workers’ compensation or other insurance.

How Widespread are Injury and Illness Prevention Programs?

Photo: Elena Finizio, Braintree, MA Area Office
Photo: Elena Finizio, Braintree, MA Area Office

Employers across the United States have implemented injury and illness prevention programs, and many jurisdictions, in the United States and abroad, currently require or encourage implementation of these programs. Currently, 34 U.S. states have established laws or regulations designed to require or encourage injury and illness prevention programs, including 15 states with mandatory regulations for all or some employers.5 Other states, while not requiring programs, have created financial incentives for employers to implement injury and illness prevention programs. In some instances this involves providing – or facilitating – workers’ compensation insurance premium reductions for employers who establish programs meeting specified requirements. And 16 states, in all three of these groups, provide an array of voluntary guidance, consultation and training programs, and other assistance aimed at helping and encouraging employers to implement injury and illness prevention programs. Depending on the state, these programs apply to all employers, employers above or below a certain size threshold, employers with injury and illness rates above industry average, employers in “high-hazard” industries or employers with above-average workers’ compensation experience modification rates.

The more than 2,400 establishments that belong to OSHA’s Voluntary Protection Program have programs that are based on the same core elements found in the injury and illness prevention program that OSHA will be proposing. The same is true for OSHA’s Safety and Health Achievement Recognition Program, in which more than 1,500 smaller employers are enrolled. Each year, dozens of organizations seeking international recognition for their safety and health program proudly submit applications to the National Safety Council for the Robert W. Campbell award (see text box). Case studies of past winners are available on the Campbell Award website.

Recognizing Business Excellence in Safety and Health

The Robert W. Campbell Award recognizes organizations that achieve business excellence by integrating environmental, health and safety (EHS) management into their business operating systems. The Award aims to:

  • Recognize businesses that uphold EHS as a key business value and link measurable achievement in EHS performance to productivity and profitability.
  • Establish a validated process by which industries can measure the performance of their EHS operations system against well-tested and internationally accepted key performance indicators.
  • Use a rigorous systematic review process to capture and evaluate the successes and lessons learned.
  • Share leading edge EHS management systems and best practices for educational purposes worldwide.

The Award program is supported by a network of 22 Global Partners across five continents committed to promoting EHS as an integral component of business management worldwide.

Source: www.campbellaward.org.

There are at least two industry consensus standards for injury and illness prevention programs. The American National Standards Institute (ANSI) and American Industrial Hygiene Association (AIHA) have published a voluntary consensus standard, ANSI/AIHA Z10 – 2005 Occupational Safety and Health Management Systems (ANSI/AIHA, 2005). The Occupational Health and Safety Assessment Series (OHSAS) Project Group, a consortium of selected Registrars, national standards bodies, professional associations and research institutes, has produced a similar document, OHSAS 18001 – 2007 Occupational Health and Safety Management Systems (OHSAS Project Group, 2007). These consensus-based standards have been widely accepted in the world of commerce and adopted by many businesses on a voluntary basis.

Canada, Australia and all members of the European Union operate programs that either require employers to adopt injury and illness prevention programs, or provide incentives or recognition to those who do so. For example, under the 1989 EU Framework Directive (89/391), EU member countries must have national legislation in place requiring employers to maintain risk identification and prevention programs that are very similar to OSHA’s injury and illness prevention program concept (European Union, 1989). U.S. companies operating internationally are familiar with these requirements and have already put in place their own programs to meet these requirements. Finally, many private workers’ compensation carriers offer incentives to employers who have injury and illness prevention programs and provide technical assistance to help them implement their programs.

Photo: Frank Wenzel, Washington DOSH

Photo: Frank Wenzel, Washington DOSH

The United States Departments of Defense (DOD) and Energy (DOE) have both adopted this approach for protecting workers employed or stationed at the nation’s military installations and nuclear weapons factories, including DOE’s high hazard establishments. The success of DOD’s program is described in the box below. DOE’s program, entitled Integrated Safety Management, includes an expectation that the facilities will “embrace a strong safety culture where safe performance of work and involvement of workers in all aspects of work performance are core values that are deeply, strongly, and consistently held by managers and workers.” According to DOE, the aspects of this safety culture that impact safety performance are Leadership, Employee/Worker Involvement and Organizational Learning (DOE, 2011).

Despite the value to employers and workers in terms of injuries prevented and dollars saved, many U.S. workplaces have not yet adopted injury and illness prevention programs. Based on the positive experience of employers with existing programs, OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to significantly improved workplace health and safety environments. Adoption of injury and illness prevention program will result in workers suffering fewer injuries, illnesses and fatalities. In addition, employers will improve their compliance with existing regulations, and will experience many of the financial benefits of a safer and healthier workplace described in the literature and in reports by individual companies.

Are Injury and Illness Prevention Programs Too Complicated and Expensive for Small Businesses?

For many small businesses, establishing an injury and illness prevention program may seem daunting. Any program based on formal structures can be difficult to establish in a small organization because of tight budgets. Yet simple, low-cost approaches have been shown to be effective in small businesses (Hasle and Limborg, 2006). Injury and illness prevention programs lend themselves to such low-cost approaches because they are highly flexible – the core elements can be implemented at a basic level suitable for the smallest business, as well as at a more advanced, structured level that may be needed in a larger, more complex organization.

OSHA’s Safety and Health Achievement Recognition Program (SHARP), which recognizes small employers that operate exemplary injury and illness prevention programs, provides compelling evidence that such programs can and do work for small businesses. For example, the Ohio Bureau of Workers’ Compensation (2011) analyzed the policies of 16 SHARP employers over a 12-year period from 1999 to 2010. The study compared the employers’ experience prior to and after achieving entry into the SHARP program. The preliminary results of the study show that the average number of claims for these employers decreased by 52 percent, the average claim cost decreased by 80 percent, the average lost time per claim decreased by 87 percent, and claims (per million dollars of payroll) decreased by 88 percent.

An internal OSHA study of nine SHARP firms, ranging in size from 15 to 160 employees, found that the firms achieved the following as a result of their programs:

  • A reduction in the number of injuries and illnesses.
  • Improved compliance with regulatory requirements.
  • Improved business and cost savings including reduced workers’ compensation premiums, reduced administrative and human resources burden associated with filing injury and illness reports, managing workers’ compensation cases and training new employees. The companies also experienced improved efficiency in operations and material use, and improved productivity. They were able to leverage their limited health and safety resources.
  • An improved workplace environment with greater collective responsibility for workplace health and safety.
  • Improved reputation and image in the community including relationships and cooperation between employers and OSHA, between employers and employees, and among employers in the business community.

Conclusions

  • Despite the combined efforts of employers, workers, unions, safety professionals and regulators, more than 4,500 workers lose their lives and more than four million are seriously injured each year. Tens of thousands more die or are incapacitated because of occupational illnesses including many types of cancer and lung disease. The human toll from this loss is incalculable and the economic toll is enormous.
  • Many employers in the U.S. have been slow to adopt a workplace “safety culture” that emphasizes planning and carrying out work in the safest way possible.
  • Injury and illness prevention programs are based on proven managerial concepts that have been widely used in industry to bring about improvements in quality, environment and safety, and health performance. Effective injury and illness prevention programs emphasize top-level ownership of the program, participation by employees, and a “find and fix” approach to workplace hazards.
  • Injury and illness prevention programs need not be resource-intensive and can be adapted to meet the needs of any size organization.
Photo: Roberto Rodriguez, Mesquite, Texas

Photo: Roberto Rodriguez, Mesquite, Texas

OSHA believes that adoption of injury and illness prevention programs based on simple, sound, proven principles will help millions of U.S. businesses improve their compliance with existing laws and regulations, decrease the incidence of workplace injuries and illnesses, reduce costs (including significant reductions in workers’ compensation premiums) and enhance their overall business operations.

References

Alsop, P. & LeCouteur, M. (1999). Measurable success from implementing an integrated OHS management system at Manningham City Council. Journal of Occupational Health & Safety – Australia & New Zealand, 15, 565–572.

Angello, J. (2010). A journey to improved safety performance. The Leader, 19(3), 27-29.

ANSI/AIHA (2005). American National Standard – Occupational Health and Safety Management Systems. ANSI/AIHA Z10–2005.

Bunn, W. B. et al. (2001). Health, safety, and productivity in a manufacturing environment. Journal of Occupational and Environmental Medicine 43(1), 47-55.

Bureau of Labor Statistics. (2010). Table A-1. Fatal occupational injuries by industry and event or exposure, All United States, 2010. Available at: http://www.bls.gov/iif/oshwc/cfoi/cftb0241.pdf*

Conference Board. (2003). Driving toward “0″: Best practices in corporate safety and health.

DOE, (2011). U.S. Department of Energy, Office of Health, Safety and Security. A basic overview of Integrated Safety Management.

European Union, (1989). Council Directive of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work. (89/391/EEC).

Gallagher, C. (2001). New directions: Innovative management plus safe place. In W. Pearse, C. Gallagher, & L. Bluff, (eds.) Occupational health & safety management systems: Proceedings of the first national conference (pp. 65-82).

Gallagher, C. et al. (2003). Occupational safety and health management systems in Australia: Barriers to success. Policy and Practice in Health and Safety 1(2), 67-81.

Hasle, P. & Limborg, H. (2006). A review of the literature on preventive occupational health and safety activities in small enterprises. Industrial Health 44(1), 6-12.

Huang, Y. H. et al. (2006). Safety climate and self-reported injury: Assessing the mediating role of employee safety control. Accident Analysis and Prevention 38(3), 425-33.

Huang, Y. H. et al. (2009). Financial decision-makers’ views on safety: What SH&E professionals should know. Professional Safety (April), 36-42.

Leigh, J. P. et al. (1997). Occupational injury and illness in the United States: Estimates of costs, morbidity, and mortality. Annals of Industrial Medicine 157(14), 1557-1568.

Lewchuk, W., Robb, A., & Walters, V. (1996). The Effectiveness of Bill 70 and Joint Health and Safety Committees in Reducing Injuries in the Workplace: The Case of Ontario. Canadian Public Policy, 22, 225-243.

Liberty Mutual Research Institute. (2010). 2010 Liberty Mutual Workplace Safety Index.

Liu, H. et al. (2008). The Pennsylvania Certified Safety Committee Program: An Evaluation of Participation and Effects on Work Injury Rates. RAND Working Paper WR-594-PA.

National Academy of Social Insurance. (2011). Workers’ Compensation: Benefits, Coverage, and Costs, 2009.

Ohio Bureau of Workers’ Compensation. (2011). Ohio 21(d) SHARP Program Performance Assessment.

OHSAS Project Group. (2007). Occupational health and safety management systems – Requirements. OHSAS 18001:2007. Published as a British Standards Institute standard.

Shannon, H. et al. (1996). Workplace organizational correlates of lost-time accident rates in manufacturing. American Journal of Industrial Medicine, 29(3), 258-268.

Shannon, H. et al. (1997). Overview of the relationship between organizational and workplace factors and injury rates. Safety Science, 26, 201-217.

Smitha, M.W. et al. (2001). Effect of state workplace safety laws on occupational injury rates. Journal of Occupational and Environmental Medicine, 43(12), 1001-1010.

Stanford University. (1981). Improving construction safety performance: The user’s role (Technical report No. 260). Department of Civil Engineering.

Steenland, K. et al. (2003). Dying for Work: The Magnitude of US Mortality from Selected Causes of Death Associated with Occupation. American Journal of Industrial Medicine, 43, 461-482.

Torp, S. et al. (2000). Systematic health, environment, and safety activities: Do they influence occupational environment, behavior and health? Occupational Medicine, 50(5), 326-333.

U.S. Department of Energy, Office of Corporate Safety Analysis. (2009a). Occupational Medicine Newsletter. Corporate safety: Health & safety is working!

U.S. Department of Energy, Office of Health, Safety and Security (HSS). (2009b). A basic overview of the worker safety and health program (10 CFR 851). Outreach & Awareness Series to Advance DOE Mission.

Viscusi, W. & Aldy, J. (2003). The value of a statistical life: A critical review of market estimates throughout the world. Journal of Risk and Uncertainty, 27, 5-76.

Yassi, A. (1998). Utilizing Data Systems to Develop and Monitor Occupational Health Programs in a Large Canadian Hospital. Methods of Information and Medicine, 37, 125-129.


Footnotes:

Footnote 1: The occupational safety and health community uses various names to describe systematic approaches to reducing injuries and illnesses in the workplace. Consensus and international standards use the term Occupational Health and Safety Management Systems; OSHA currently uses the term Injury and Illness Prevention Programs and others use Safety and Health Programs to describe these types of systems. Regardless of the title, they all systematically address workplace safety and health hazards on an ongoing basis to reduce the extent and severity of work-related injuries and illnesses.

Footnote 2: The “most disabling” injuries are defined by Liberty Mutual as those causing the injured employee to miss six or more days from work.

Footnote 3: For more details see OSHA’s Safety and Health Management Systems eTool, available at http://www.osha.gov/SLTC/etools/safetyhealth/mod1_costs.html.

Footnote 4: If injury and illness prevention programs achieve a 15 percent reduction in injuries and illnesses for employers who do not currently have safety and health programs, the overall reduction in injuries and illnesses for all employers including those that already have programs is estimated at 12.4 percent. Applying this 12.4 percent to NASI’s estimate of the $74 billion in direct workers’ compensation costs in 2009, workers’ compensation savings could be as high as $9 billion per year. With a 35 percent program effectiveness, the overall reduction in injuries and illnesses for all employers is estimated at 30.8 percent and workers’ compensation savings could reach $23 billion per year.

Footnote 5: The 15 states are: Arkansas, California, Hawaii, Louisiana, Michigan, Minnesota, Mississippi, Montana, North Carolina, New Hampshire, Nevada, New York, Oregon, Utah, and Washington.

Additional Information Can Be Found Here: http://www.osha.gov/dsg/topics/safetyhealth/

Fire Prevention Weekly Update – May 22, 2013

u-s-fire-administration

  1. Campaigns / Other Fire Prevention Efforts
  2. Campus fire safety
  3. Inspections/Code enforcement
  4. Smoke Alarms
  5. Sprinklers
  6. Wildland Fire Safety
  7. Fire safety tips and reminders
  8. Other Safety News
  9. International News

Links to Fire Prevention-related news articles – Updated 05/20/2013

Campaigns/ Other Fire Safety Activities

  1. Fond du Lac Firefighters Bring Safety Initiative Door-to-Door – story and video – (Wisconsin)
  2. Savoring sweets to save lives – Ice cream social raises money to install smoke alarms (Iowa)
  3. Fire safety program includes home inspections (Alberta, Canada)
  4. Residents at East Cobb Condo to Get Lesson in Fire Safety
  5. Smoke Alarms Provided to Elderly/Disabled in Texas
  6. Volunteers go door-to-door for fire safety (Iowa)
  7. Chico school kids get the low-down on fire safety (California)
  8. Windsor firefighters knocking on doors to check for smoke alarms (Canada)

Campus fire safety

  1. Dormitory fire halted by fire sprinklers (San Luis Obispo, CA)

Inspections / Code enforcement

  1. Investigation finds SA apartments flunking fire inspections (Texas)
  2. Inspections Important Part of Fire Prevention (Idaho)

Smoke Alarms

  1. New Maryland Law Dictates Need for Smoke Alarms
  2. Smoke detectors could have saved Perryville man (Missouri)
  3. City called for smoke detectors before fatal fire
  4. No smoke detectors found after Pottsville fire kills 6
  5. Sleeping Teens Saved By Smoke Alarm (New York)
  6. Smoke alarms save grandmother’s life during house fire in Elizabeth (Colorado)

Sprinklers

  1. Fire sprinklers save apartment and surrounding businesses (Harrisonburg, VA)
  2. Task force: New apartments must have fire sprinklers (South Dakota)
  3. Fire sprinklers credited with saving three story apartment (Melbourne, FL)
  4. Shenandoah closes loophole in fire sprinkler ordinance
  5. Dormitory fire halted by fire sprinklers (San Luis Obispo, CA)

Wildland Fire Safety

  1. Creating ‘defensible space’ can be key to homes surviving wildfires (Minnesota)
  2. Which mulch is the right mulch? Research on mulch and fire helps you decide!
  3. Upper Midwest wildfires raise concern for community safety (NFPA)
  4. Tinderbox-Dry Western U.S. at High Risk of Major Wildfires
  5. Australian Council launches app for fire inspections

Safety tips and reminders

  1. Summer Vacation Fire Safety (Georgia)
  2. Fire Chief Gives Out Some Fire Prevention Tips (Indiana)
  3. Establishing a fire escape plan (Alabama)
  4. Extension Cords: Leading cause for electrical fires

Other Safety News

  1. Galesburg fire sparks a lesson in prevention
  2. Fire investigators burning to learn
  3. 1 critical after Motel 6 fire in Phoenix; smoke detectors possibly not working

Fire Prevention News: International

  1. Complacency causes fires: NSW Commissioner (Australia)
  2. Australian Council launches app for fire inspections
  3. Fire department helps found education group (Canada)
  4. Windsor firefighters knocking on doors to check for smoke alarms (Canada)
  5. Firies warn residents to do safety check (Australia)

Fire Prevention Weekly Update – May 7, 2013

u-s-fire-administration

  1. Campaigns / Other Fire Prevention Efforts
  2. Campus fire safety
  3. Inspections/Code enforcement
  4. Smoke Alarms
  5. Sprinklers
  6. Wildland Fire Safety
  7. Fire safety tips and reminders
  8. Other Safety News
  9. International News

Links to Fire Prevention-related news articles – Updated 05/06/2013

Campaigns/ Other Fire Safety Activities

  1. MFRD: students ride fire boat; learn about fire safety on Mobile River (Alabama)
  2. Donated iPads will be used for fire safety education (Connecticutt)
  3. GFD helps hotels improve fire safety (Guam)
  4. Young pupil’s homework used in fire safety drive (United Kingdom)
  5. Importance of fire prevention and smoke alarms presented to seniors (Louisianna)
  6. There’s no place like Home Safe Home (Canada)
  7. Fire District 1 offering free smoke alarms and home safety checks (Washington)

Campus fire safety

  1. GW Extends Fire Safety to Study Abroad
  2. Fire Knocked Down At USC’s Viterbi School Of Engineering (California)

Inspections / Code enforcement

  1. Fatal Carmel fire unable to alter building codes (New York)
  2. Focus on fire safety as May arrives: know codes to avoid costly problems (Wisconsin)
  3. New fire code rules in effect this week after Naples raises concerns (Florida)

Smoke Alarms

  1. Girl alerts household to fire OFD: Too many families without working smoke alarms
  2. Mother and two young children safe after escaping fire
  3. Clarington fire chief frustrated by number of homes without smoke alarms (Canada)

Sprinklers

  1. Buffalo Grove Officials Debate Home Fire Sprinklers (Illinois)
  2. Sprinklers credited with keeping Mount Prospect shopping center fire under control
  3. St. Paul fire chief to honor workers who installed sprinklers in public housing
  4. Fire Knocked Down At USC’s Viterbi School Of Engineering (California)
  5. Home fire sprinklers requirements in California yield no negative impact on construction (NFPA)
  6. Proposals to exempt fire sprinklers in the IRC withdrawn (NFPA)
  7. Senior living facility fire contained by fire sprinklers (Tinley Park, IL)
  8. Fire Marshal Leaves Home Sprinklers On Table (West Virginia)
  9. Mesa uses federal dollars to help fund home sprinkler efforts (NFPA)
  10. Fire sprinklers save two Redmond area buildings on Saturday (Washington)

Wildland Fire Safety

  1. Communities take action to enhance fire safety (California)
  2. Wildfire preparedness efforts pay off (Colorado)
  3. Fire Marshal Warns of Dangerous Conditions (New Hampshire)
  4. Red Flag Warning up, UC Berkeley identifies risk (California)
  5. Springs Fire May Be Fully Contained Monday

Safety tips and reminders

  1. Keep older adults in mind this National Electrical Safety Month (NFPA)
  2. Deaths illustrate fire safety is not just slogan (South Carolina)

Other Safety News

  1. Communities can combat arson; state fire marshal says work together (Illinois)
  2. Carbon Monoxide Detectors Not Required In Oklahoma Schools
  3. Nearly 50,000 home fires involved electrical failures or malfunctions (NFPA)
  4. Fall safety and high jinks make the point on TV show (NFPA)
  5. 5 women die in limousine fire on Calif. bridge


Fire Prevention News: International

  1. Alarm hailed as life saver (New Zealand)
  2. Tokyo tackles fire risks in old houses (Japan)
  3. Greater Manchester firefighters remind the public to be careful when cooking
  4. Young pupil’s homework used in fire safety drive (United Kingdom)
  5. There’s no place like Home Safe Home (Canada)
  6. Sprinklers to be law in retirement homes (Ontario, Canada)

OSHA Injury and Illness Prevention Programs (I2P2) White Paper

osha40-400x122

I2P2 Powerpoint <—- Download Here!

OSHA I2P2 White Paper  <—– Download PDF File Here

Introduction/Executive Summary

Image of workers An injury and illness prevention program,1 is a proactive process to help employers find and fix workplace hazards before workers are hurt. We know these programs can be effective at reducing injuries, illnesses, and fatalities. Many workplaces have already adopted such approaches, for example as part of OSHA‘s cooperative programs. Not only do these employers experience dramatic decreases in workplace injuries, but they often report a transformed workplace culture that can lead to higher productivity and quality, reduced turnover, reduced costs, and greater employee satisfaction.

Thirty-four states and many nations around the world already require or encourage employers to implement such programs. The key elements common to all of these programs are management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.

Based on the positive experience of employers with existing programs, OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to a significantly improved workplace health and safety environment. Adoption of an injury and illness prevention program will result in workers suffering fewer injuries, illnesses and fatalities. In addition, employers will improve their compliance with existing regulations, and will experience many of the financial benefits of a safer and healthier workplace cited in published studies and reports by individual companies, including significant reductions in workers’ compensation premiums.

Background

In the four decades since the Occupational Safety and Health Act (OSH Act) was signed into law, workplace deaths and reported occupational injuries have dropped by more than 60 percent. Yet the nation’s workers continue to face an unacceptable number of work-related deaths, injuries and illnesses, most of them preventable:

  • Every day, more than 12 workers die on the job – over 4,500 a year.
  • Every year, more than 4.1 million workers suffer a serious job-related injury or illness.

An enhanced focus on prevention is needed to bring these numbers down. To accomplish this, an effective, flexible, commonsense tool is available that can dramatically reduce the number and severity of workplace injuries and illnesses: the injury and illness prevention program. This tool helps employers find hazards and fix them before injuries, illnesses or deaths occur. It helps employers meet their obligation under the OSH Act to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” It also helps employers avoid the significant costs associated with injuries and illnesses in the workplace.

Injury and illness prevention programs are not new, nor are they untested. Most large companies whose safety and health achievements have been recognized through government or industry awards cite their use of injury and illness prevention programs as their key to success. Convinced of the value, effectiveness, and feasibility of these programs, many countries around the world now require employers to implement and maintain them. These countries include Canada, Australia, all 27 European Union member states, Norway, Hong Kong, Japan and Korea. This initiative also follows the lead of 15 U.S. states that have already implemented regulations requiring such programs.

How Does an Injury and Illness Prevention Program Work?

Most successful injury and illness prevention programs include a similar set of commonsense elements that focus on finding all hazards in the workplace and developing a plan for preventing and controlling those hazards. Management leadership and active worker participation are essential to ensuring that all hazards are identified and addressed. Finally, workers need to be trained about how the program works and the program needs to be periodically evaluated to determine whether improvements need to be made.

These basic elements – management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement – are common to almost all existing health and safety management programs. Each element is important in ensuring the success of the overall program, and the elements are interrelated and interdependent.

When it comes to injury and illness prevention programs, every business is different, and one size certainly does not fit all. Employers who implement injury and illness prevention programs scale and adapt these elements to meet the needs of their organizations, depending on size, industry sector or complexity of operations.

What Are the Costs of Workplace Injuries, Illnesses and Deaths to Employers, Workers and the Nation?

The main goal of injury and illness prevention programs is to prevent workplace injuries, illnesses and deaths, the suffering these events cause workers, and the financial hardship they cause both workers and employers.

Workplace incidents cause an enormous amount of physical, financial and emotional hardship for individual workers and their families. Combined with insufficient workers’ compensation benefits and inadequate medical insurance, workplace injuries and illnesses can not only cause physical pain and suffering but also loss of employment and wages, burdensome debt, inability to maintain a previous standard of living, loss of home ownership and even bankruptcy. When implemented effectively, injury and illness prevention programs can help workers and their families avoid these disruptive and sometimes calamitous impacts on their lives.

Image - Cost of the Most Disabling Injuries 1998-2008 Chart At the same time, these programs will help employers avoid the substantial cost impacts and business disruptions that accompany occupational injuries, illnesses and deaths. One widely-cited source regarding estimates of the magnitude of these costs is the Liberty Mutual Research Institute, which reports the direct cost of the most disabling workplace injuries in 2008 to be $53 billion (Liberty Mutual Research Institute, 2010).2 Another source, the National Academy of Social Insurance (NASI), estimates the annual workers’ compensation benefits paid for all compensable injuries and illnesses in 2009 at $58 billion (National Academy of Social Insurance, 2011). NASI further reports the total costs paid by employers for workers’ compensation increased from $60 billion in 2000 to $74 billion in 2009.

In addition to these direct costs, employers incur a variety of other costs that may be hidden or less obvious when an employee is injured or ill, but in most cases involve real expenditures of budget or time. These expenditures are commonly referred to as indirect costs and can include:

  • Any wages paid to injured workers for absences not covered by workers’ compensation;
  • The wage costs related to time lost through work stoppage;
  • Administrative time spent by supervisors following injuries;
  • Employee training and replacement costs;
  • Lost productivity related to new employee learning curves and accommodation of injured employees; and
  • Replacement costs of damaged material, machinery and property.

OSHA has historically used the results of one study (Stanford University, 1981) that found the indirect costs can range from 1.1 (for the most severe injuries) to 4.5 (for the least severe injuries) times the direct costs.3

“Establishing safety as a value rather than a priority tells our employees and our customers that safety is built into our culture, not something we do to merely comply with regulations.

Our excellent safety performance over the past seven years has been a key factor in reducing our insurance cost. Our low EMR [Experience Modification Rate], incidents rates, and SHARP Management System have impressed our customers and, in many cases, was a key factor in selecting Parsons to perform their project.”

Charles L. Harrington, Chairman & CEO, Parsons Corp.

Source: National Safety Council.

When workers are killed, are injured or become ill, there are substantial costs beyond those borne by employers. A variety of approaches can be used to estimate these costs. For example, Viscusi and Aldy (2003) provided estimates of the monetary value of each life lost. OSHA updated these estimates (to account for inflation) to 2010 dollars, yielding a value of $8.7 million for each life lost. Multiplying this value by the 4,547 workplace deaths reported by the Bureau of Labor Statistics for 2010, OSHA estimates the annual cost of known workplace fatalities to be nearly $40 billion.

This estimate does not include the cost of non-fatal injuries, or of occupational illnesses like cancer and lung disease. These illnesses generally may occur many years or even decades after workers are exposed and are therefore seldom recorded in government statistics or employer surveillance activities.

The human and economic costs of these conditions are indisputably enormous. Leigh et al. (1997) estimated that more than 60,000 workers die each year from occupational illnesses, and more than 850,000 develop new illnesses annually. Similarly, Steenland et al. (2003) estimated that between 10,000 and 20,000 workers die each year from cancer due to occupational exposures, and between 5,000 and 24,000 die from work-related Chronic Obstructive Pulmonary Disease.

In summary, the number and costs of workplace injuries, illnesses and fatalities are unacceptably high. Injury and illness prevention programs have been proven to help employers and society reduce the personal, financial and societal costs that injuries, illnesses and fatalities impose. As described below, the thousands of workplaces that have implemented these programs in some form have already witnessed the resulting benefits, in the form of higher efficiency, greater worker productivity and lower costs.

What Is the Evidence that Injury and Illness Prevention Programs Protect Workers and Improve the “Bottom Line”?

Image - Top Benetits of Effective Workplace Safety Programs ChartNumerous studies have examined the effectiveness of injury and illness prevention programs at both the establishment and corporate levels (e.g., Alsop and LeCouteur, 1999; Bunn et al., 2001; Conference Board, 2003; Huang et al., 2009; Lewchuk, Robb, and Walters, 1996; Smitha et al., 2001; Torp et al., 2000; Yassi, 1998). This research demonstrates that such programs are effective in transforming workplace culture; leading to reductions in injuries, illnesses and fatalities; lowering workers’ compensation and other costs; improving morale and communication; enhancing image and reputation; and improving processes, products and services. The studies also highlight important characteristics of effective programs, including management commitment and leadership, effective employee participation, integration of health and safety with business planning and continuous program evaluation. They suggest that programs without these features are not as effective (Shannon et al., 1996, 1997; Gallagher, 2001; Gallagher et al., 2003; Liu et al., 2008).

One study (Smitha et al., 2001) focused on manufacturing facilities in 13 states with mandatory injury and illness prevention programs and/or mandatory health and safety committee requirements. The authors found that both types of regulations were effective in reducing injury and illness incidence rates. Three of the four states with only safety and health program requirements experienced the greatest reductions in injury and illness rates following promulgation of these mandatory program regulations.

OSHA examined the injury and illness prevention programs in eight states where the state had either required a program or provided incentives or requirements through its workers’ compensation programs. The successes of these state programs, which lowered injury and illness incidences by 9 percent to more than 60 percent, are discussed below: Source: Huang et al., 2009. Data based on responses from 231 U.S. companies with 100 or more employees.

  • Alaska had an injury and illness plan requirement for over 20 years (1973 to 1995). Five years after the program was implemented, the net decrease in injuries and illnesses (i.e., the statewide reduction in injuries and illnesses over and above the national decrease during the same time period) for Alaska was 17.4 percent.
  • California began to require an injury and illness prevention program in 1991. Five years after this requirement began, California had a net decrease in injuries and illnesses of 19 percent.
  • Colorado has a program that allows firms to adopt basic injury and illness prevention program components in return for a workers’ compensation premium reduction. The cumulative annual reduction in accidents was 23 percent and the cumulative reduction in accident costs was between 58 and 62 percent.
  • Hawaii began to require employers to have injury and illness prevention programs in 1985. The net reduction in injuries and illnesses was 20.7 percent.
  • Massachusetts Workers’ Compensation program firms receive a premium credit for enrolling in a loss management program. In the first year of this program, firms participating in the program had a 20.8 percent improvement in their loss ratios.
  • North Dakota has a program under its workers’ compensation program for employers who have a risk management program. The incentive is a 5 percent discount on annual workers’ compensation premiums. These risk management programs contain many of the elements of an injury and illness prevention program. They resulted in a cumulative decline for serious injuries of 38 percent over a four-year period.
  • Texas had a program under its workers’ compensation commission from 1991 to 2005 which identified the most hazardous workplaces. Those employers were required to develop and implement injury and illness prevention programs. The reduction in injuries, over a four-year period (1992-1995), averaged 63 percent each year.
  • Washington began requiring establishments to have injury and illness prevention programs in 1973. Five years later the net decrease in injuries and illnesses was 9.4 percent.

OSHA also examined fatality rates and found that California, Hawaii and Washington, with their mandatory injury and illness prevention program requirements, had workplace fatality rates as much as 31 percent below the national average in 2009.

Liu et al. (2008) examined the effectiveness of Pennsylvania’s voluntary program that provides workers’ compensation premium discounts to employers that establish joint labor-management safety committees. These committees are responsible for implementing several injury and illness prevention program elements: hazard identification, workplace inspection and safety management. The authors found that among program participants there was a strong association between improved injury and illness experience and the level of compliance with the program requirements. This is further evidence that programs with strong management commitment and active worker participation are effective in reducing injury risk, while “paper” programs are, not surprisingly, ineffective.

There are many benefits from developing a safety culture at your company – none of which is more valuable than employee loyalty. When employees know you care about their personal well-being and you prove that to them in their workplace, it increases morale, engagement, awareness, motivation and productivity.”

Daniel R. Nobbe, Plant Leader, Fiberteq LLC, Danville, IL.

Source: National Safety Council.

The literature on injury and illness prevention programs also includes numerous studies that attempt to identify the critical success features associated with superior health and safety performance. Gallagher (2001) concludes that management commitment and employee involvement are the keys to program success: “[R]ecurring findings across these studies were the critical role played by senior managers in successful health and safety management systems, and the importance of effective communication, employee involvement and consultation.”

Worker participation, a fundamental element of injury and illness prevention programs, makes an important contribution to an employer’s bottom line. When workers are encouraged to offer their ideas and they see their contributions being taken seriously, they tend to be more satisfied and more productive (Huang et al., 2006). Engaging employees in dialogue with management and each other about safety and health can lead to improved relationships and better overall communication, along with reduced injury rates. Improved employee morale and satisfaction translates to greater loyalty, lower absenteeism and higher productivity.

This body of research, combined with studies of individual companies (see boxes, below, with Case Studies of Programs Implemented under OSHA’s Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP)) demonstrate clearly that injury and illness prevention programs are effective at the establishment level in dramatically reducing risk of workplace injury. This effect has also been detected in state-wide comparisons.

Based on its review of the literature on the effectiveness of these programs and on the experience of the states that have implemented injury and illness prevention program requirements, OSHA estimates that implementation of injury and illness prevention programs will reduce injuries by 15 percent to 35 percent for employers who do not now have safety and health programs. At the 15 percent program effectiveness level, this saves $9 billion per year in workers’ compensation costs; at the 35 percent effectiveness level the savings are $23 billion per year.4 In addition to these workers’ compensation savings, employers could also save indirect costs incurred when an employee is injured or ill. Beyond the monetized benefits of injuries and illnesses averted, and lives saved, nonmonetized costs of workplace injuries and deaths include uncompensated lost wages, the loss of human capital assets, the loss of productivity, the cost of other government benefits required by injured workers or their survivors, the loss of government tax revenues, other business expenses, and other losses not compensated by workers’ compensation or other insurance.

How Widespread are Injury and Illness Prevention Programs?

Photo: Elena Finizio, Braintree, MA Area Office
Photo: Elena Finizio, Braintree, MA Area Office

Employers across the United States have implemented injury and illness prevention programs, and many jurisdictions, in the United States and abroad, currently require or encourage implementation of these programs. Currently, 34 U.S. states have established laws or regulations designed to require or encourage injury and illness prevention programs, including 15 states with mandatory regulations for all or some employers.5 Other states, while not requiring programs, have created financial incentives for employers to implement injury and illness prevention programs. In some instances this involves providing – or facilitating – workers’ compensation insurance premium reductions for employers who establish programs meeting specified requirements. And 16 states, in all three of these groups, provide an array of voluntary guidance, consultation and training programs, and other assistance aimed at helping and encouraging employers to implement injury and illness prevention programs. Depending on the state, these programs apply to all employers, employers above or below a certain size threshold, employers with injury and illness rates above industry average, employers in “high-hazard” industries or employers with above-average workers’ compensation experience modification rates.

The more than 2,400 establishments that belong to OSHA’s Voluntary Protection Program have programs that are based on the same core elements found in the injury and illness prevention program that OSHA will be proposing. The same is true for OSHA’s Safety and Health Achievement Recognition Program, in which more than 1,500 smaller employers are enrolled. Each year, dozens of organizations seeking international recognition for their safety and health program proudly submit applications to the National Safety Council for the Robert W. Campbell award (see text box). Case studies of past winners are available on the Campbell Award website.

Recognizing Business Excellence in Safety and Health

The Robert W. Campbell Award recognizes organizations that achieve business excellence by integrating environmental, health and safety (EHS) management into their business operating systems. The Award aims to:

  • Recognize businesses that uphold EHS as a key business value and link measurable achievement in EHS performance to productivity and profitability.
  • Establish a validated process by which industries can measure the performance of their EHS operations system against well-tested and internationally accepted key performance indicators.
  • Use a rigorous systematic review process to capture and evaluate the successes and lessons learned.
  • Share leading edge EHS management systems and best practices for educational purposes worldwide.

The Award program is supported by a network of 22 Global Partners across five continents committed to promoting EHS as an integral component of business management worldwide.

Source: www.campbellaward.org.

There are at least two industry consensus standards for injury and illness prevention programs. The American National Standards Institute (ANSI) and American Industrial Hygiene Association (AIHA) have published a voluntary consensus standard, ANSI/AIHA Z10 – 2005 Occupational Safety and Health Management Systems (ANSI/AIHA, 2005). The Occupational Health and Safety Assessment Series (OHSAS) Project Group, a consortium of selected Registrars, national standards bodies, professional associations and research institutes, has produced a similar document, OHSAS 18001 – 2007 Occupational Health and Safety Management Systems (OHSAS Project Group, 2007). These consensus-based standards have been widely accepted in the world of commerce and adopted by many businesses on a voluntary basis.

Canada, Australia and all members of the European Union operate programs that either require employers to adopt injury and illness prevention programs, or provide incentives or recognition to those who do so. For example, under the 1989 EU Framework Directive (89/391), EU member countries must have national legislation in place requiring employers to maintain risk identification and prevention programs that are very similar to OSHA’s injury and illness prevention program concept (European Union, 1989). U.S. companies operating internationally are familiar with these requirements and have already put in place their own programs to meet these requirements. Finally, many private workers’ compensation carriers offer incentives to employers who have injury and illness prevention programs and provide technical assistance to help them implement their programs.

Photo: Frank Wenzel, Washington DOSH

Photo: Frank Wenzel, Washington DOSH

The United States Departments of Defense (DOD) and Energy (DOE) have both adopted this approach for protecting workers employed or stationed at the nation’s military installations and nuclear weapons factories, including DOE’s high hazard establishments. The success of DOD’s program is described in the box below. DOE’s program, entitled Integrated Safety Management, includes an expectation that the facilities will “embrace a strong safety culture where safe performance of work and involvement of workers in all aspects of work performance are core values that are deeply, strongly, and consistently held by managers and workers.” According to DOE, the aspects of this safety culture that impact safety performance are Leadership, Employee/Worker Involvement and Organizational Learning (DOE, 2011).

Despite the value to employers and workers in terms of injuries prevented and dollars saved, many U.S. workplaces have not yet adopted injury and illness prevention programs. Based on the positive experience of employers with existing programs, OSHA believes that injury and illness prevention programs provide the foundation for breakthrough changes in the way employers identify and control hazards, leading to significantly improved workplace health and safety environments. Adoption of injury and illness prevention program will result in workers suffering fewer injuries, illnesses and fatalities. In addition, employers will improve their compliance with existing regulations, and will experience many of the financial benefits of a safer and healthier workplace described in the literature and in reports by individual companies.

Are Injury and Illness Prevention Programs Too Complicated and Expensive for Small Businesses?

For many small businesses, establishing an injury and illness prevention program may seem daunting. Any program based on formal structures can be difficult to establish in a small organization because of tight budgets. Yet simple, low-cost approaches have been shown to be effective in small businesses (Hasle and Limborg, 2006). Injury and illness prevention programs lend themselves to such low-cost approaches because they are highly flexible – the core elements can be implemented at a basic level suitable for the smallest business, as well as at a more advanced, structured level that may be needed in a larger, more complex organization.

OSHA’s Safety and Health Achievement Recognition Program (SHARP), which recognizes small employers that operate exemplary injury and illness prevention programs, provides compelling evidence that such programs can and do work for small businesses. For example, the Ohio Bureau of Workers’ Compensation (2011) analyzed the policies of 16 SHARP employers over a 12-year period from 1999 to 2010. The study compared the employers’ experience prior to and after achieving entry into the SHARP program. The preliminary results of the study show that the average number of claims for these employers decreased by 52 percent, the average claim cost decreased by 80 percent, the average lost time per claim decreased by 87 percent, and claims (per million dollars of payroll) decreased by 88 percent.

An internal OSHA study of nine SHARP firms, ranging in size from 15 to 160 employees, found that the firms achieved the following as a result of their programs:

  • A reduction in the number of injuries and illnesses.
  • Improved compliance with regulatory requirements.
  • Improved business and cost savings including reduced workers’ compensation premiums, reduced administrative and human resources burden associated with filing injury and illness reports, managing workers’ compensation cases and training new employees. The companies also experienced improved efficiency in operations and material use, and improved productivity. They were able to leverage their limited health and safety resources.
  • An improved workplace environment with greater collective responsibility for workplace health and safety.
  • Improved reputation and image in the community including relationships and cooperation between employers and OSHA, between employers and employees, and among employers in the business community.

Conclusions

  • Despite the combined efforts of employers, workers, unions, safety professionals and regulators, more than 4,500 workers lose their lives and more than four million are seriously injured each year. Tens of thousands more die or are incapacitated because of occupational illnesses including many types of cancer and lung disease. The human toll from this loss is incalculable and the economic toll is enormous.
  • Many employers in the U.S. have been slow to adopt a workplace “safety culture” that emphasizes planning and carrying out work in the safest way possible.
  • Injury and illness prevention programs are based on proven managerial concepts that have been widely used in industry to bring about improvements in quality, environment and safety, and health performance. Effective injury and illness prevention programs emphasize top-level ownership of the program, participation by employees, and a “find and fix” approach to workplace hazards.
  • Injury and illness prevention programs need not be resource-intensive and can be adapted to meet the needs of any size organization.
Photo: Roberto Rodriguez, Mesquite, Texas

Photo: Roberto Rodriguez, Mesquite, Texas

OSHA believes that adoption of injury and illness prevention programs based on simple, sound, proven principles will help millions of U.S. businesses improve their compliance with existing laws and regulations, decrease the incidence of workplace injuries and illnesses, reduce costs (including significant reductions in workers’ compensation premiums) and enhance their overall business operations.

References

Alsop, P. & LeCouteur, M. (1999). Measurable success from implementing an integrated OHS management system at Manningham City Council. Journal of Occupational Health & Safety – Australia & New Zealand, 15, 565–572.

Angello, J. (2010). A journey to improved safety performance. The Leader, 19(3), 27-29.

ANSI/AIHA (2005). American National Standard – Occupational Health and Safety Management Systems. ANSI/AIHA Z10–2005.

Bunn, W. B. et al. (2001). Health, safety, and productivity in a manufacturing environment. Journal of Occupational and Environmental Medicine 43(1), 47-55.

Bureau of Labor Statistics. (2010). Table A-1. Fatal occupational injuries by industry and event or exposure, All United States, 2010. Available at: http://www.bls.gov/iif/oshwc/cfoi/cftb0241.pdf*

Conference Board. (2003). Driving toward “0″: Best practices in corporate safety and health.

DOE, (2011). U.S. Department of Energy, Office of Health, Safety and Security. A basic overview of Integrated Safety Management.

European Union, (1989). Council Directive of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work. (89/391/EEC).

Gallagher, C. (2001). New directions: Innovative management plus safe place. In W. Pearse, C. Gallagher, & L. Bluff, (eds.) Occupational health & safety management systems: Proceedings of the first national conference (pp. 65-82).

Gallagher, C. et al. (2003). Occupational safety and health management systems in Australia: Barriers to success. Policy and Practice in Health and Safety 1(2), 67-81.

Hasle, P. & Limborg, H. (2006). A review of the literature on preventive occupational health and safety activities in small enterprises. Industrial Health 44(1), 6-12.

Huang, Y. H. et al. (2006). Safety climate and self-reported injury: Assessing the mediating role of employee safety control. Accident Analysis and Prevention 38(3), 425-33.

Huang, Y. H. et al. (2009). Financial decision-makers’ views on safety: What SH&E professionals should know. Professional Safety (April), 36-42.

Leigh, J. P. et al. (1997). Occupational injury and illness in the United States: Estimates of costs, morbidity, and mortality. Annals of Industrial Medicine 157(14), 1557-1568.

Lewchuk, W., Robb, A., & Walters, V. (1996). The Effectiveness of Bill 70 and Joint Health and Safety Committees in Reducing Injuries in the Workplace: The Case of Ontario. Canadian Public Policy, 22, 225-243.

Liberty Mutual Research Institute. (2010). 2010 Liberty Mutual Workplace Safety Index.

Liu, H. et al. (2008). The Pennsylvania Certified Safety Committee Program: An Evaluation of Participation and Effects on Work Injury Rates. RAND Working Paper WR-594-PA.

National Academy of Social Insurance. (2011). Workers’ Compensation: Benefits, Coverage, and Costs, 2009.

Ohio Bureau of Workers’ Compensation. (2011). Ohio 21(d) SHARP Program Performance Assessment.

OHSAS Project Group. (2007). Occupational health and safety management systems – Requirements. OHSAS 18001:2007. Published as a British Standards Institute standard.

Shannon, H. et al. (1996). Workplace organizational correlates of lost-time accident rates in manufacturing. American Journal of Industrial Medicine, 29(3), 258-268.

Shannon, H. et al. (1997). Overview of the relationship between organizational and workplace factors and injury rates. Safety Science, 26, 201-217.

Smitha, M.W. et al. (2001). Effect of state workplace safety laws on occupational injury rates. Journal of Occupational and Environmental Medicine, 43(12), 1001-1010.

Stanford University. (1981). Improving construction safety performance: The user’s role (Technical report No. 260). Department of Civil Engineering.

Steenland, K. et al. (2003). Dying for Work: The Magnitude of US Mortality from Selected Causes of Death Associated with Occupation. American Journal of Industrial Medicine, 43, 461-482.

Torp, S. et al. (2000). Systematic health, environment, and safety activities: Do they influence occupational environment, behavior and health? Occupational Medicine, 50(5), 326-333.

U.S. Department of Energy, Office of Corporate Safety Analysis. (2009a). Occupational Medicine Newsletter. Corporate safety: Health & safety is working!

U.S. Department of Energy, Office of Health, Safety and Security (HSS). (2009b). A basic overview of the worker safety and health program (10 CFR 851). Outreach & Awareness Series to Advance DOE Mission.

Viscusi, W. & Aldy, J. (2003). The value of a statistical life: A critical review of market estimates throughout the world. Journal of Risk and Uncertainty, 27, 5-76.

Yassi, A. (1998). Utilizing Data Systems to Develop and Monitor Occupational Health Programs in a Large Canadian Hospital. Methods of Information and Medicine, 37, 125-129.


Footnotes:

Footnote 1: The occupational safety and health community uses various names to describe systematic approaches to reducing injuries and illnesses in the workplace. Consensus and international standards use the term Occupational Health and Safety Management Systems; OSHA currently uses the term Injury and Illness Prevention Programs and others use Safety and Health Programs to describe these types of systems. Regardless of the title, they all systematically address workplace safety and health hazards on an ongoing basis to reduce the extent and severity of work-related injuries and illnesses.

Footnote 2: The “most disabling” injuries are defined by Liberty Mutual as those causing the injured employee to miss six or more days from work.

Footnote 3: For more details see OSHA’s Safety and Health Management Systems eTool, available at http://www.osha.gov/SLTC/etools/safetyhealth/mod1_costs.html.

Footnote 4: If injury and illness prevention programs achieve a 15 percent reduction in injuries and illnesses for employers who do not currently have safety and health programs, the overall reduction in injuries and illnesses for all employers including those that already have programs is estimated at 12.4 percent. Applying this 12.4 percent to NASI’s estimate of the $74 billion in direct workers’ compensation costs in 2009, workers’ compensation savings could be as high as $9 billion per year. With a 35 percent program effectiveness, the overall reduction in injuries and illnesses for all employers is estimated at 30.8 percent and workers’ compensation savings could reach $23 billion per year.

Footnote 5: The 15 states are: Arkansas, California, Hawaii, Louisiana, Michigan, Minnesota, Mississippi, Montana, North Carolina, New Hampshire, Nevada, New York, Oregon, Utah, and Washington.

Additional Information Can Be Found Here: http://www.osha.gov/dsg/topics/safetyhealth/

 

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