Before we jump into what an Injury and Illness Prevention Program (IIPP) is and why it is required by law, we want to let you know that we are here to help if you do not have these programs in place yet. We can provide you with IIPP templates that you can use to get jump-started on creating your own program and these templates will save you time and money in hiring someone to create these programs and forms for your business. For more information, contact Kevin at: [email protected] or call: 530.320.3617.

What is an IIPP?

An Injury and Illness Prevention Program, (IIPP) is a basic safety program tailored to business operations. California employers with at least one employee are required to have a written IIPP that is understandable to all employees. You must inform your employees of their right to receive a copy of your written IIPP.   IMPORTANT UPDATE  – You must also have a written COVID-19 Prevention Program (CPP).

Keeping employees safe on the job keeps them working and your business more productive. An effective IIPP shows that safety is important at your company and guides your employees to work safely.  It can help you improve the safety and health in your workplace and reduce costs with good management and employee involvement.

Who needs an IIPP?

You do! More important than needing an IIPP, you want one. There’s no question that injuries can have a big impact on your business. You would much rather have employees avoid injury and illness in the first place. Your IIPP can help your employees stay safe on the job and remain productive, and help you avoid expensive costs—both direct and indirect—that come with a workplace injury.

One more important reason to have an effective IIPP: you can avoid the citation that comes from not having one. Each year, Cal/OSHA issues more fines to businesses in violation of the IIPP regulation than it does for any other standard.

How to create your IIPP?

Start by first identifying the hazards and how you can eliminate or reduce them.  Next, you will need to put together your written IIPP document in accordance with Cal/OSHA’s requirements.

1. Responsibility – Who manages your IIPP?

An essential first step to developing your IIPP is identifying who’s in charge of your safety plan and establishing their roles and responsibilities. The person or persons in charge of your IIPP must:

1. Be identified in your written IIPP and have management’s full support.
2. Be knowledgeable about your workplace’s health and safety issues and hazard control measures.
3. In addition to having authority and responsibility for your workplace’s safety and health program, they must also have the authority and responsibility for making necessary corrections and implementing the program.

Ensure employees are aware of who the person is with the authority and responsibility for their IIPP.

2. Compliance – How do employees follow the rules?

The IIPP standard requires that employers establish a system for ensuring that employees follow the organization’s safety rules. This system must include informing employees about the requirements of your IIPP and the safety procedures to be followed.

In order to achieve substantial compliance, this section should include a method for providing positive recognition of employees who perform and follow safe and healthful work practices. It should also address disciplinary action for employees who fail to follow safety rules. Training is involved in achieving compliance and it is also important to retrain employees whose safety performance is lacking.

Make sure your system does not discourage employees from reporting their injuries or symptoms.

If safety rules aren’t followed, it’s helpful to review procedures to see if they are practical and achievable and to consider if revisions are needed. Having employees involved in creating rules and procedures can help ensure that they are.

Establishing health and safety rules and work procedures is an important step in developing your IIPP. It is a good idea to periodically review and update all rules and procedures to make sure they reflect present conditions at the workplace. Make sure your employees understand the steps they need to take to be in compliance.

3. Communication – How to inform employees about your IIPP

You need a system for communicating with employees. This means communicating in a way that is easily understandable by all affected employees on matters that relate to workplace safety and health. This means you should be prepared to communicate with employees in a language they understand. Communication can take place through trainings, meetings, announcements, email notices, memos, newsletters, and/or through the activities of a health and safety committee.

• All employees must be informed about your IIPP and how it is being implemented as well as their responsibility to comply with its procedures.
• Your communication system should include provisions for encouraging employees to report potential hazards in the work environment without fear of reprisal. (One way to do this is to have a notification system where employees report hazards anonymously. This helps eliminate the fear of reprisal. Employees need to be aware of the methods to communicate with their employer about health and safety matters).

When conducting meetings with employees, schedule general employee meetings where safety is freely and openly discussed. Schedule these meetings on a regular basis (weekly, monthly, or quarterly) and announce the schedule to all employees to achieve maximum attendance. Remember to do this for all shifts and if you have multiple shifts, consider holding meetings at shift change to capture more employees at one meeting.

Other considerations for meeting topics include:

• Occupational accident and injury history at your worksite.
• Feedback from your employees.
• Guest speakers.
• Safety material via PowerPoint, video, and/or handouts.

Management needs to be present at these meetings. Document all communication efforts, as you will be required to demonstrate that a system of effective communication is in place.

While Cal/OSHA’s IIPP standard does not require employers to establish health and safety committees, it’s a good way to involve employees in safety and to implement an effective health and safety program. Establishing a health and safety committee can also help you meet the communication requirements of the IIPP standard. If you establish a health and safety committee to meet the communication requirements of the IIPP standard, your committee should include both labor and management representatives. The committee must also:

• Meet regularly, but no less than quarterly.
• Prepare written records of the safety and health issues discussed.
• Review periodic inspection results.
• Review accidents.
• Review investigations of alleged hazardous conditions brought to the attention of a committee member.
• Submit recommendations to assist in the evaluation of the employee safety suggestions.

Exception: Employers having fewer than 10 employees shall be permitted to communicate to and instruct employees orally in general safe work practices with specific instructions with respect to hazards unique to the employees’ job assignments as compliance with communication subsection. (Remember, you still must have a written IIPP with fewer than ten employees).

4. Hazard assessment – What hazards exist at your workplace

Workplaces must have procedures in place to identify and evaluate all areas of the work environment for health and safety hazards, unsafe conditions and work practices. These procedures include periodic inspections. The inspections are made when the safety program is first established, whenever new substances, processes, procedures, or equipment are introduced that represent a new occupational safety and health hazard, and whenever the employer is made aware of a new or previously unrecognized hazard.

Assessing hazards can be accomplished by conducting regular inspections of each work area and by obtaining information from employees through interviews or other methods. These inspections will tell you what hazardous conditions, equipment, and procedures exist in the workplace that could be potentially hazardous. The scheduled hazard inspections are part of the daily safety and health checks that managers and supervisors are doing as part of their job duties, not in lieu of them. The frequency of these inspections depends on the operations involved, the magnitude of the hazards, the proficiency of employees, changes in equipment or work processes, and the history of workplace injuries and illnesses.

Inspections should be conducted by personnel who, through experience or training, are able to identify actual and potential hazards and understand safe work practices. They should be knowledgeable in the Cal/OSHA safety orders that apply to your workplace to better help you identify potential hazards. When hazards are identified, an action plan needs to be developed to correct them if they cannot be corrected immediately.

Your hazard assessment system should also include input from employees about potential hazards and any suggestions they have for correcting safety and health issues. The procedures chosen need to result in a comprehensive evaluation of the hazards present at the workplace and the inspections should be documented, which will allow review by management and if applicable, the safety committee.

5. Accident/exposure investigation – What caused an accident/near miss?

Employers need a procedure in place to investigate occupational injuries and illnesses. Accident investigations should be conducted by trained supervisory or managerial personnel, with the primary focus of identifying why the incident or near miss occurred and what actions can be taken to prevent it from happening again.

The investigation report should be in writing. It can include photos, sketches, measurements, sampling, and other pertinent information. It should also include a description of the underlying factors that may have contributed to the incident and what can be done to prevent it from happening in the future.

This information is critical for accident prevention and controlling losses at the workplace.

6. Hazard correction – Making changes to improve safety.

Once hazards are observed or discovered, they should be addressed in a timely manner, based on the severity of the hazard. Hazard control is the heart of an effective IIPP and the basis for developing your safe work procedures and accident prevention training. Employers need to have methods and/or procedures for correcting unsafe or unhealthy conditions. If a hazard exists or is imminent and cannot be abated right away without endangering employees and/or property, remove all exposed personnel from the area except those necessary to correct the existing condition. Having a tracking log in place will help your organization monitor the progress of the hazards being corrected at the worksite.

Employees necessary to correct the hazardous condition shall be provided the necessary safeguards. This includes training and equipment. There are various methods that can be used to correct hazards. The most effective solutions are those that actually remove the hazard (for example, using non-toxic cleaning chemicals instead of toxic chemicals, having a machine do a hazardous job instead of an employee, and using a ventilation system). If the hazard can’t be removed completely, establish policies and procedures to limit exposure to help reduce the risk (for example, using two people to lift a heavy object). Personal protective equipment (such as goggles, respirators, gloves, non-slip shoes) can be worn to protect the worker from direct exposure to the hazard and in some cases, may be necessary.

7. Training and instruction – Performing job duties safely.

Training is one of the most important elements of any IIPP. It allows employees to learn their job properly, brings new ideas into the workplace, reinforces existing ideas and practices, and puts your program into action. An effective IIPP includes training for both supervisors and employees, in a language and manner they understand. Make sure your training program reaches all affected employees and that it covers all relevant topics. Employees assigned non-routine tasks must be provided additional training about any health and safety issues related to these tasks. Your company and employees will benefit from an effective training program through fewer work-related injuries and illnesses.

The IIPP standard requires that training be provided to all workers on the hazards in their workplace when they start working for their employer, whenever they are given a new job assignment, and whenever new procedures and equipment are introduced. If you are unable to conduct your own required trainings you should reach out to an outside consultant, Cal/OSHA consultation, vendors, your insurance carrier, and/or broker for assistance. Outside trainers may be considered a temporary resource and eventually, you might want to have your own in-house training capabilities. You can encourage your supervisors to be your primary safety trainers. Provide them with the necessary training through outside sources so that they can conduct the required safety and health trainings to your employees in a timely and effective manner.

8. Recordkeeping – Document corrections, changes, and successes with your IIPP.

Workplaces must maintain a written IIPP and documentation of how the elements of their IIPP are carried out. Maintaining such records can help you be more efficient and effective in implementing your IIPP as well as demonstrate the effectiveness of your overall program. Recordkeeping can enable you to learn from past experience, identify patterns of injury and illness, and help target prevention efforts. Records can also help you document your successes, such as lower rates of injuries and incidents and correction of health and safety problems. Cal/OSHA will review your records during inspections to ensure they are complete and accurate. It is recommended that the following records be kept to document the elements of your program:

Scheduled and periodic inspections to identify unsafe conditions and work practices. These records must include:

• The name of the person(s) conducting the inspection.
• The hazards identified.
• The action taken to correct the unsafe hazards and/or work practices.
• Records shall be maintained for at least one year, however, employers with fewer than 10 employees may elect to maintain the inspection records only until the hazard is corrected.

Documentation of safety and health training provided to employees, which must include:

• Employee names or other means of identifying employees.
• Training dates.
• Type(s) of training and the name of the training provider.
• Training records of employees who have worked for less than one year for the employer need not be retained beyond the term of employment if they are provided to the employee upon termination.

Having adequate recordkeeping processes in place will enable you as an organization to learn from your experiences and better enable you to make the necessary corrective actions moving forward.

Communicating the plan to your employees

Once you complete your IIPP, communicate the plan with your employees. Their safety and your bottom line depend on your injury and illness prevention efforts.

Sources:   Safe at Work California – https://www.safeatworkca.com/ and  The Department of Industrial Relations –  https://www.dir.ca.gov/title8/3203.html