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Seven Parts of an Effective Injury and Illness Prevention Plan
1. – KPA CONFIDENTIAL –
Seven Parts of an Effective Injury and Illness Prevention Plan
September 22, 2011
2. Questions
• If you have questions
during the presentation,
please submit them using
the “Questions” feature
• Questions will be
answered at the end of the
webinar or an emailed
response will be provided
3. The Business Case for an I2P2 Plan
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1. Saves Money
2. Streamlines Processes
1. Every system is perfectly designed to get the results
it gets.
5. I2P2 Goals
• Encourage communication and documentation
– not just injuries, but ideas to control hazards.
• Shift measurements from lagging to leading
indicators.
• Get at root causes.
• Use of documentation to improve the plan.
• Remove barriers to worker participation.
• Conform to what OSHA is most likely to
require if it becomes a standard
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7. How to Do It
Start at the top
• I2P2 is a policy, and needs to be documented
as one.
– Demonstrate commitment to protection and
continual improvement of employee health and
safety
– Demonstrate that employees are effectively
participating
– It helps to use existing workplace health and
safety requirements as a framework (300 logs).
– Make sure it is in compliance with applicable laws
and regulations.
– Date, sign and officially endorse policy.
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8. How to Do It
Establish responsibility and authority
• How will it be
implemented, managed, checked, and acted
upon?
• What resources are dedicated to the plan?
– Provide appropriate
financial, human, organizational resources to keep
plan active
– Define roles, assign responsibilities, establish
accountability, delegate authority to maintain and
continue to improve the plan.
– Integrate the plan with other business processes.
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9. How to Do It
Communicate with various shareholders
• Employees (employee representatives)
– Ask them about their workplace health and safety
concerns, along with suggestions for mitigation
– Ownership: They are responsible for adhering to
company health and safety rules and
requirements.
• Suppliers, contractors, customers
– Some parts of the plan affect all visitors.
– Especially contractors who come in contact with
hazards.
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10. How to Do It
Employee Participation
• All levels of the organization: integrated
involvement from all levels from CEO to each
worker
– Target workers who come in contact with hazards
most often for ownership roles (even contractors).
– Provide employees and employee representatives
with mechanisms, time, resources and timely
access to information to encourage participation
– Identify and remove barriers to participation
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11. How to Do It
“Creating an organization that eliminates fatalities and
life-altering injuries cannot be delegated. It requires
the integrated involvement of the entire
organization, from the CEO to each worker.”
~ Thomas Krause
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12. How to Do It
Plan for Action
Get a plan in place that provides
reporting, documentation, root causes, and
actionable information once hazards are
identified.
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13. How to Identify Hazards
• Employees should have a role in
– Incident investigations
– Procedure development
– Job safety analysis
– Injury and incident prevention planning
– Initial and ongoing reviews
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14. How to Identify Hazards
• Where to look for hazards
– Level that culture supports safety objectives and
activities
– Work practices and sustained behavior that
increase or reduce hazards
– Value placed on safety compared to other
objectives
– myKPAonline report, if available
– Observations in all areas of the facility
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16. Decide How to Handle Hazards
Don’t start the to do list quite yet…
• Take a good hard look at the identified hazards.
• Why did they become hazards? Are there patterns that
could point to a root cause? Are there controls in place
to address the root cause?
• Prioritize issues based on risk of injury or
illness, severity of issue, and applicable regulations.
– Hierarchy of controls
• Set smart goals and systematically accomplish
prioritized objectives.
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17. Do it! (yes)
Implement the plan, and document progress.
Also note lessons learned from success and setbacks from
implementation and operation. Use this information to
improve processes next time.
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18. Training and Education
Document Administrative controls including
• Training
• Job planning
• Rotating and scheduling
• Changes to work procedures
• Implementation of work area protection
• Emergency preparedness
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20. How to measure
All or some of these key indicators should be documented and
communicated as part of your plan
• Workplace inspection and testing (audits)
• Exposure assessments
• Injury, illness, and incident tracking
• Employee input
• OSHA assessment
21– KPA CONFIDENTIAL –
21. Best Practices
How do you measure success?
Old school:
Injury rate performance (but you still have to track it)
• Small staff size and relative infrequency of preventable incidents
• Tends to lead to decision making and behavioral biases
• Latent indicator
Much better: Culture predicts outcomes.
• Track work practices and sustained behaviors that increase or
reduce hazards
• The level that culture supports safety objectives and activities
• Workers’ interest in safety activities and behaviors
• The value placed on workplace safety by senior leadership
compared to other objectives
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23. Which Part of the Plan to Improve?
• Identify any newly created hazards resulting
from corrective and preventive actions and
evaluate overall risk reduction
• Considerations of hazards associated with
behaviors
• Consideration of hierarchy of controls
• Review of scope and sequence of plan
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24. When to Make Improvements?
• New processes or operations
• Changes to existing
operations, services, products or supplies
• Scheduled planning reviews
• Changes in applicable regulations
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26. Resources
OSHA’s New Injury and Illness Prevention Programs (I2P2) Webpage
ANSI Occupational Health and Safety Management System
International Labor Organization (ILO) Guidelines on Occupational
Safety and health Management Systems According to Internationally
Agreed Principles by ILO’s Tripartite Constituents
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27. Contact Information
28– KPA CONFIDENTIAL –
The recorded webinar and presentation slides will be emailed to
you today including your local representative’s contact information.
www.kpaonline.com
mjohnson@kpaonline.com
303-219-7802
Editor's Notes
Saves money: Less time off work, few injury claims, less paperwork, avoid liability in some situations. Cost shift from short term to long-term planning.Streamlines Processes: Shown to improve organizational productivity, financial performance, and employee satisfactionQuote attribution: Dr. Paul Batalden. Did a lot to improve medical care at hospitals.Treat the illness, not the symptoms.Gets prevention and safety into daily standard operating procedures, like foundation for safety culture
Most fatalities and life altering events are not result from unknown or unpredictable circumstances, or from weird occurrences. Vast majority continue to include the basics: Mobile equipment mishaps (distracted driving)falls contact with objects/ equipmentThe vast majority of these accidents are preventable, and that’s where an I2P2 plan comes into play.Actually, OSHA knows this.I2P2 rule requires employers to identify their workplaces’ health and safety hazards on their own and take action to resolve them. Fifteen states already require common sense injury & illness prevention programs.OSHA head, Dr. David Michaels commented that implementing the rule is highest priority for 2011Looks like
Lagging indicators: injury rate performance
Based on “Plan-Do-Check-act”Systemically eliminates underlying root causes of deficiencies. Example: inspection finds unguarded machine. Machine gets fixed and also process in place to discover underlying reason why machine is broken. Process might lead to replacing guards with more effective design, or replace the machines themselves so hazard is eliminated. Seeks long-term solution rather than one-time fix.------Distribute handout for next part of webinar
Who’s going to champion the plan?
Communication takes many forms: Employees: suggestion boxes, signs, bulletins in breakroomsCustomers: signs, bulletins in customer areas
Emphasize getting workers who use hazardous materials involved in I2P2Integration Quote on next slide.
Regulatory agencies get it that organizations are not in total compliance at any particular point in time. Under such circumstances, an organization should not be considered out of conformance with this standard so long as its plan, as implemented, results in prompt detection and correction of the system deficiencies that contributed to the instance of noncompliance.
My personal story: long journey why I am kinda an expertMorning meetingsrisk assessments at onset of new projects- or safety committee meetingsmake it like a game to identify all hazards involved in a processSigning-off on forms that they attended risk assessment meeting Create a “safety mantra”
Look for controls in place to reduce hazards:Choices made in selecting hazardous chemicals: is there a safer alternative?Example: Methylene Chloride in solvents & strippersGeneral duty clause: If it looks bad, it probably is.
Great! Everyone is onboard for working together to prevent illnesses and accidents at work. You’ve worked together to identify the workplace hazards.Now you officially know about these hazards. Now what?___Might not address every single identified hazard, but set sufficient goals to reduce risk and improve workplace in a measurable manner.Specific Measurable Attainable Realistic Timely
Methelene chloride example
Focusing effect – the tendency to place too much importance on one aspect of an event; causes error in accurately predicting the utility of a future outcome.[10]Normalcy bias – the refusal to plan for, or react to, a disaster which has never happened before.Forward Bias - the tendency to create models based on past data which are validated only against that past data.Recency effect – the tendency to weigh recent events more than earlier events (see also peak-end rule).
New or modified technology including software and equipmentNew or revised procedures for work practices, designspecifications or standardsModifications of EHS devices and equipmentSignificant changes in organization structure- including use of contractors