work incident injuri formLast week, OSHA published its new “Recommended Practices for Safety and Health Programs,” which advises employers in the healthcare industry and other private sector industries to establish comprehensive internal safety and health programs. The OSHA bulletin also provides extensive guidelines and resources for creating such programs.

In releasing the updated recommendations, OSHA argues that employers adopting such programs could reduce injuries and illnesses and promote sustainability. To the extent that this new guidance creates new compliance burdens and risks (see below), healthcare is likely to be one industry in which OSHA focuses its efforts. After all, OSHA believes that “[m]ore workers are injured in the healthcare and social assistance industry sector than any other.”

The non-binding recommendations come more than two years after OSHA shelved plans to issue a regulation requiring employers to maintain “Injury and Illness Prevention Programs” (sometimes referred to as “I2P2”). However, a number of states already require some or all employers to have such programs. OSHA first published voluntary Safety and Health Program Management Guidelines in 1989.

OSHA published both in the form of a 40-page online guide and a web tool. The guidelines appear to recognize that developing a robust safety and health program can be a long-term process, so they begin with a quick-start guide, followed by detailed action items for employers to follow.