Federal law may differ from state standards

The American College of Occupational and Environmental Medicine (ACOEM) has taken a strong position in favor of the Occupational Safety & Health Administration's proposed federal Illness and Injury Prevention Programs (I2P2) standard, including strengthening the requirements in certain ways beyond what California OSHA already requires, says Paul Papanek, MD, MPH, chairman of the board for the San Francisco, CA-based Western Occupational Environmental Medical Association.

"In particular, they ought to be updated periodically," says Papanek. "Also, when the I2P2 contains provisions for mandated medical surveillance, they should be countersigned by a physician knowledgeable in occupational medicine."

In addition, says Papanek, ACOEM has explored with OSHA the possibility of offering extra incentives to employers, perhaps through its Voluntary Protection Programs (VPPs), if the employer includes health and wellness provisions in the I2P2.

"Overall, we believe that it's time to export this terrific and successful idea to the entire nation," Papanek says.

California businesses are "no strangers to I2P2 programs," says Mary Hale, MSN, COHN-S, NP, an occupational health nurse practitioner at the Occupational Health Facility at University of California—Los Angeles (UCLA) Medical Center. The state's Department of Industrial Relations' Division of Occupational Safety and Health has an excellent web presentation for developing, implementing and evaluating an I2P2 safety program, she notes.

Businesses with more than 20 employees already have a program, explains Hale, unless they have a Workers' Compensation Experience Modification Rate of less than 1.1% or are on a designated list of low hazard industries.

While California's local government agencies are not currently required to keep records of the I2P2 programs, this could change under a federal OSHA rule, says Hale. "The process and flavor of a nationally developed program to proactively address workplace safety and health hazards will undoubtedly make some changes in California," says Hale.

Large companies who have participated in OSHA's VPP have already gone beyond the minimum standards, notes Hale. "They have proven programs which increase workplace safety and prevent injuries and illnesses," she says. "These standards could be implemented as a baseline."