Institute for Policy Integrity

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Comments to OSHA on its Injury and Illness Prevention Program

September 4, 2013

The Obama Administration is poised to improve worker safety by establishing a nationwide Injury and Illness Prevention Program. But unless it is well designed, the program will leave too many vulnerable to unsafe work conditions.

Today, Policy Integrity sent recommendations to OSHA that, if followed, will maximize the program’s effectiveness and prevent more workplace harms before they occur. The recommendations take aim at economic and behavioral inefficiencies in injury prevention processes, offering best practices for closing those gaps.

Among the suggestions is one that would mandate robust optimal safety provisions in place of workers’ compensation insurance. Doing so would attack a distortion in the labor market that leads employers to under-invest in worker safety—through the shared risk of an insurance system, they do not bear the full responsibility for hazards in the workplace.

As OSHA prepares a draft of its I2P2 regulations, it should consider this and the many other safety-maximizing recommendations.

Filed under Public Comments, Safety and Consumer Protection