Representatives from NAHB were on hand to provide a small business perspective at a June 29 meeting at the Occupational Safety and Health Administration in Washington, D.C. on the agency’s efforts to develop a proposed rule (I2P2) on an Injury and Illness Prevention Program.

A top priority of the Administration, the new regulation would require every business to develop a written worker safety and health program.

“Instead of waiting for an OSHA inspection or a workplace injury to address a hazard, employers would be required to create a plan for identifying and reducing or preventing hazards, and then implementing this I2P2 plan to protect workers,” said Jordan Barab, deputy assistant secretary of labor for OSHA.

OSHA has indicated that the I2P2 will help employers reduce workplace injuries and illnesses through a systematic process that proactively addresses workplace safety and health hazards.

At the June meeting — which included representatives from small and large employers, organized labor and academia and consultants — NAHB voiced concern that OSHA was too vague when defining the scope of this proposed rule and that a continual improvement management system may prove unduly onerous for small businesses while not necessarily improving the safety and health of workers in the residential construction industry.

Rob Matuga, NAHB’s assistant vice president for labor, safety and health policy, shared with OSHA a copy of NAHB’s “Home Builders’ Safety Program” and recommended that the agency take into account existing safety programs when developing the I2P2 rule, arguing that safety programs must be tailored for each job site, industry and employer.

To ensure that small business employers implement and maintain an effective I2P2 plan, NAHB added, the rule should be simple, practical and flexible and one that brings value to the residential construction industry by improving worker safety.

NAHB also said that OSHA should consider allowing smaller employers to implement an abbreviated I2P2 plan so that it does not exceed their management capabilities.

OSHA held an additional meeting of stakeholders on July 20 in Washington, D.C. and one is scheduled for Aug. 3 in Sacramento, Calif.

For more information on the rulemaking, or to register for the Aug. 3 meeting, click here.

For further information, e-mail Rob Matuga, or call him at 800-368-5242 x8507.