A preliminary report has failed to find any clear impact of California’s required Injury and Illness Prevention Programs (I2P2) on the total fatality rate in the state. The exact effect on the number of worker injuries is unclear.
The report was performed by the RAND Center for Health and Safety in the Workplace for the California Commission for Health, Safety and Workers’ Compensation (CHSWC). The CHSWC is charged with examining the health and safety and workers’ compensation systems in California and recommending administrative or legislative changes.
California adopted its I2P2 plan in 1991. It’s the most frequently cited standard in California with violations in about 25% of inspections.
Have those citations dropped over time? After a decline in the first two years following the start of I2P2, the number of I2P2 violations per inspection remained fairly constant. The report concludes that newly inspected facilities are no more likely to have written programs now than 20 years ago.
On the other hand, once a facility has been cited for an I2P2 violation, the likelihood of finding another one there declines substantially.
That sounds like a piece of good news, but you also have to consider this: Cal-OSHA inspects about 8,000 to 10,000 facilities per year out of more than 700,000 in the state. That means only about 1.25% are inspected. Even in manufacturing, only 5% of facilities receive a Cal-OSHA visit.
To determine the impact on injuries, the study used two measures:
- A Lookback test based on the assumption that if compliance with the I2P2 helped to prevent injuries, then facilities with violations of the regulation should, on average, be those with poorer safety performance, and
- A Change test based on the assumption that, if the I2P2 were effective, facilities that were cited for non-compliance and then came into compliance would have improved injury records.
For the Lookback test, two samples showed employers that were cited for the basic requirement to have a written I2P2 document actually had fewer injuries than facilities that had no I2P2 violations — the opposite of what proponents of the programs would expect.
The study says this may be because small businesses tend to under-report injuries.
However, employers that were cited for more specific violations of the I2P2, particularly the requirements to train employees, did have worse performance than companies that weren’t cited.
For the Change test, the study found companies that were cited for non-compliance with specific sections of the I2P2 improved their injury rates afterward. For inspections that weren’t triggered by injuries, the companies improved their injury rates by 22% the following year.
The study also notes that the reduction in injuries would be less in industries with low injury rates.
What’s it mean?
The CHSWC says the study was conducted “to inform policy in both California and in the federal OSHA program, which has made the adoption of a similar national requirement a top priority.”
So, what are the policy implications? The study makes a significant suggestion: Look toward Great Britain where employers are required to conduct risk assessments.
Under this approach, OSHA would still inspect facilities to identify hazard-specific violations. The inspector would ask managers how the company’s I2P2 allowed a hazard to occur.
In other words, the hazard would be related to the I2P2 that the employer is required to implement.
This would make inspections more time consuming, and fewer would be conducted.
But the study predicts such an approach might provide more long-lasting benefits. That’s because the efforts to improve the company’s safety and health program would become part of its standard operating procedures. Typically, the effects from an inspection last only one to two years.
This preliminary report, which hasn’t yet been adopted by CHSWC, was made public just days after federal OSHA produced its white paper on the benefits of I2P2s.
You can download the preliminary CHSWC report (PDF) here.
What do you think about the results from this study, especially in comparison to what federal OSHA says in its white paper on I2P2s? Let us know in the comments below.
