One of the stated goals of OSHA under the Obama administration was to implement a required written injury and illness prevention program for every workplace. It was also a goal of the Clinton administration. Under Clinton, OSHA was pushed aside as other items took precedence. Time ran out even though there was no major opposition.

  The Bush administration did not push an I2P2 rule, and it lay dormant until Obama promised to strengthen OSHA. I2P2 became one of a number of safety priorities. And, just as it was under Clinton, there has been no real opposition. It is also true that there has been no support for it. OSHA and safety is not a winner with Congress.

  The safety bills tend to sit in committees until time runs out on the administration. This may be the case again.

  California became the first state to have an I2P2 in 1991.

  In 2010 OSHA begins holding stakeholder meetings to discuss draft proposal for I2P2

  In July, 2111, OSHA gathered for a web chat and gathered facts that would make up the bulk of the new I2P2. They incorporated a name, The Small Business Regulatory Enforcement and Fairness Act (SBREFA)

  In January, 2012, OSHA releases white paper describing the benefits of I2P2s and touted results of state programs that were already using it.

  In February, OSHA postpones the March 2012 SBREFA panel.

  In March 2012 SBREFA panel was postponed until at least late 2012.

  Today, 12 states have adopted I2P2 plans. I think many of these were enacted because the states considered it a done deal that federal OSHA would adopt them. It hasn’t happened.

  Federal OSHA has not produced a plan and until they do, most state plans will lag in enforcement.

  On May 23, 2014, OSHA announced that I2P2 had been demoted to a long-term action.

  The talk among OSHA executives is that I2P2 is a victim of too much resource drain. Others are starting to question if it is worth it and if it will indeed happen?

  The I2P2 was one item on an aggressive OSHA agenda by the Obama administration. While I am not privy to OSHA politics, not one of the original Obama agenda plans seems likely to be enacted.

  There are changes that are in the works at OSHA, but none of them involve Congress. Instead, it is the UN enacting Global Harmonization on a Hazard Communication program for the world.

  The initial plans offered by the Obama administration came at a time when Democrats controlled every branch of government. With a Republican majority, it is virtually impossible to pass anything new. This leaves OSHA doing what it can with existing laws, but without much help from Congress. Nicholson would say this is as good as it gets. Enjoy it.