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July-August-2014

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palletcentral.com PalletCentral July-August 2014 19 developing such a program even in the absence of OSHA requirements? The answer is yes and yes. While many may debate the issues involved with OSHA enforcement of an I2P2 program – and the debate has ranged from whether OSHA will turn this into a super-charged "General Duty Clause" to whether small establishments can possibly create, implement and maintain complex programs that may be better suited to larger workplaces – the devil will be in the details, in terms of OSHA oversight. For now, however, employers have the luxury of crafting an I2P2 program that is appropriate for their worksites without federal dictates … and they are likely to find that injuries and illnesses will be reduced as a result (along with the corresponding worker's compensation and lost productivity costs that ensue following an industrial accident). Also bear in mind that some businesses are already dealing with I2P2 (or similar) requirements as a result of being located in states such as California or Washington, which run their own OSHA programs and already have I2P2 program mandates that are enforceable. In fact, 34 states and many nations around the world already either require or encourage employers to implement these programs. In states where a regulatory mandate is absent, often the state worker's compensation rules will dictate discounts for employers who voluntarily take these actions. The Cal-OSHA I2P2 Make no mistake, though … OSHA does plan on seeing I2P2 through to fruition, although the announced delay raises the specter that this could be a "midnight rule" along the lines of the ill-fated ergonomics rule.

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