ARLINGTON, Va. — The U.S. Occupational Safety and Health Administration (OSHA) has proposed that employers need to implement a new program into their businesses called the Injury and Illness Prevention Program, or I2P2 for short. The program will mean more active planning, implementing, evaluating and improving activities that will keep employees safe and protect their health.

At the American Industrial Hygiene Association's 2014 Fall Conference, independent moderator Dave Johnson, editor of Industrial Hygiene & Safety News, conducted a debate between supporters for I2P2 (Charles Redinger of Redinger 360, Inc., and James Thornton, director of health, safety and environment at Northrop Grumann Newport News) and opponents (Thomas Lawrence of Safety and Compliance Management and David Sarvadi, an attorney for Keller & Heckman).

Participants addressed critical questions, such as:

• Are safety and health programs or management systems cost-effective for reducing injuries and illnesses in large, medium and small enterprises?
• Do these programs have value?
• Can OSHA develop a rule mandating I2P2 requirements that is equally valuable and cost-effective across large, medium and small enterprises?
• Have state OSHA plan I2P2-type standards proven valuable?

The immediate issue with I2P2 was clear from the small business perspective: The opponents did not want more government regulations among small businesses, and they didn't like the definition of "prevention" by OSHA standards.

Lawrence made it clear from the beginning that if OSHA was to implement this rule, it would have a negative reaction among small businesses because they would be responsible for complete prevention. The gist was that larger companies could afford fines for such thing while small businesses could not.

Meanwhile, Thornton and Redinger rebutted that idea with the fact that health and safety management have both been the same for a long time, and clearly we are in need of a change. There were more than 4,000 fatalities on the job last year and 4 million serious injuries. Small business employers are the ones who need this the most because they need the protection. They also made it clear that this plan isn't regarded as a one-size-fits-all measure.

Johnson asked why there was so much controversy. After all, he said, it seems like both sides agree on the idea that workers need to be protected and injuries need to be prevented.

Sarvadi responded that businesses had seen this kind of management before, and it never seemed to work well. He also cited that the number of deaths and injuries has been declining for years, so this much regulation was unnecessary and Lawrence agreed and stated that I2P2 couldn't be sustained.

Yet, Thornton disagreed, saying that it's the employers and employees like the ones at this debate who are hungry for change — and they are the ones who need it. I2P2 is a great thing for companies and businesses who want something different, he said.

One of the largest sticking points of the debate was during the third question: Would OSHA will be flexible with businesses that already have an I2P2-type model in place, and why are there new concerns about new burdens when it comes to I2P2?

Thornton immediately answered that it comes down to trust. He said that the idea of regulated communities vs. OSHA get politicized, that OSHA needs to change, but people need to have faith in OSHA and the system. Redinger also added that burdening issues are here, such as the idea of enforcement of compliance, which could be a double jeopardy. It could open doors to nonconformants.

Meanwhile, Sarvadi was quick to point out that few people are willing to accept something like this simply based off faith. Businesses need proof that this works — they need evidence. Voluntarily accepted programs are more widely accepted, so is this standard necessary? Is there a true risk-preventative? These are the kinds of questions that need to be asked.

The last few questions were perfect for wrapping up the session and touched base with some of the legitimate concerns that employees have when it comes to I2P2. One of the questions asked if I2P2 would create a more negative environment for employees, and would it be detrimental to health and safety culture?

Redinger and Thornton both agreed that it would not. In fact, they said it would be beneficial for large businesses and stimulating for small businesses. They said this program will give employees more leverage with their employers.

Sarvadi, however, wasn't so convinced. He thought that rather than help, it would harm small business employees. If someone gets injured and the company gets a fine, then it becomes the employee's fault and could put his or her job at risk.

Lawrence immediately followed up by quoting an OSHA member from years ago, saying, "We're not here to help people, we're here to find them and fine them," implying that small businesses will bear some of the brunt of OSHA's new fines that will accompany I2P2.

The main theme of the session was OSHA vs. small business. While OSHA is trying to implement a better program, small businesses are rejecting any more government intervention. OSHA wants to protect workers, and small businesses want to protect their business and their workers in their own way.

When looking at studies as to whether programs like this work, there are many, but there are obvious contradictions. Some studies condone I2P2-type programs, while others show there is no benefit and no difference made.

The government and business in general have had a rather tumultuous relationship since the recession, so it is understandable why small businesses do not want more regulation. However, OSHA is looking to expand its priorities and has always wanted worker protection, and it makes sense that it would be constantly looking for new programs to aid in worker safety and health protection.

It is a difficult time, and hopefully the OSHA can work with small businesses to make the program more suitable to their needs, and in turn gain the trust of businesses and restore some faith that seems to have been lost.