What is the Department of Labor’s “P3 Initiative”?
The purpose of the Department of Labor’s (DOL) P3 Initiative, introduced in 2011, was to require employers to “take full ownership” over their adherence to DOL requirements and promote openness and transparency when it comes to the health and safety of employees. The goal of the program is to have employers “find and fix” violations, ensuring compliance with safety, wage and anti-discrimination laws, before an investigator comes into the workplace. In other words, the burden is on employers to obey the law, not on the DOL to “catch” employers in a violation.
P3 refers to Plan / Prevent / Protect and applies to those employers who are covered under the Wage and Hour Division (WHD), Occupational Safety and Health Administration (OSHA), Mine Safety and Health Administration (MSHA), Office of Federal Contract Compliance Programs (OFCCP) and/or the Employee Benefits Security Administration (EBSA). P3 requires obligated employers to:
- Plan – develop written plans for identifying and fixing violations
- Prevent – implement the plans and create processes to implement the overall strategy
- Protect – test the processes regularly with designated compliance employees to ensure they are working
It is expected that the finer details of the P3 Initiative will be announced sometime in 2013. Stay tuned.
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