What if I already have a manageable, common sense injury and illness prevention program in place?
We are aware that many small and large businesses already have effective injury and illness prevention programs. Our primary goal in our proposal is to reach those employers that do not have an effective program. Fifteen states already have requirements for such programs—and OSHA has learned much from the variety of approaches taken by these 15 states. It is not the agency’s intention to require that employers who have previously implemented effective programs that share the basic elements of OSHA’s rule to make unnecessary changes. We plan to issue a proposal that is sufficiently flexible to allow those programs to continue uninterrupted. OSHA has not written this proposal yet, and we are still engaging with stakeholders and listening to their concerns. I understand that OSHA originally planned to have its first Small Business Regulatory Enforcement Fairness Act (SBREFA) panel on this initiative late last year, from October to December 2010 at some point, but the first SBREFA panel is
