Although its fate is uncertain, the debate continues over the passage of a federal-level Injury Illness and Prevention Program ("I2P2") regulation. Federal OSHA continues to emphasize its commitment to I2P2. Entering the first quarter of 2012, OSHA:

  • had issued a white paper on the purported benefits of injury illness and prevention programs; and

  • indicated that the long-awaited initiation of the small business regulatory review process—where the initial draft proposal of the rule will be vetted for further regulatory analysis—should begin in 2012.

It remains to be seen when OSHA will publish the initial draft rule as the March 2012 target date has come and gone. At this present juncture, the impact of the sequester budget cuts will likely impact the timeline of the passage of I2P2. Against this backdrop, California – one of the model state programs for reviewing the I2P2 experience – made headlines when a study commissioned by the California Commission for Health, Safety and Workers Compensation (and conducted by the RAND Group) indicated that its Injury Illness and Prevention Program ("IIPP") regulation, which has been in effect since 1991, was generally ineffective in reducing injuries and illnesses in California.

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