An Injury and Illness Prevention Program, (IIPP) is an important safety program that is personalized to your business operations. All California employers with at least one employee are required to have an effective written IIPP and it needs to be understood by all employees. And, an IIPP can help reduce your cost(s) by having management and employee involvement.
Many workplaces have a hard time understanding the importance and benefits associated with investing in a workplace safety program, especially if they’ve never had high injury rates or a Cal/OSHA inspection.
Having and maintaining an effective IIPP will demonstrate your efforts in providing a safe and healthful workplace for your employees. Whether you currently have an IIPP or are building one for the first time, be sure to review and update it each year for effectiveness.
Some of the benefits to having an IIPP are reduced accidents and injuries, claims costs, increased job satisfaction, and increased productivity.
Who needs an IIPP?
If you’re a business owner with one or more employees, 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, production and company morale.
Another reason to have an effective IIPP is to avoid a 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 do I create an IIPP?
Glad you asked! To assist you in building a complete IIPP specific to your workplace operations, we have developed an easy-to-use online IIPP Builder℠. It will guide you through the nine parts of an IIPP and ask questions about your current safety practices along the way:
Our IIPP Builder℠ includes these nine sections:
1. Responsibility – Who manages your IIPP?
2. Compliance – How do employees follow the rules?
3. Communication – How to inform employees about your IIPP
4. Hazard assessment – What hazards exist at your workplace?
5. Accident/exposure investigation – What caused an accident/near miss?
6. Hazard correction – Making changes to improve safety
7. Training and instruction – Performing job duties safely
8. Access - Your IIPP is available to your employees
9. Recordkeeping – Document corrections, changes, and successes with your IIPP
Your answers help build your safety program and tailor it to your business. When you’re finished building your program, you can save a copy to your computer or, if you’re a policyholder, you can save it and come back to finish it later, access it any time to edit or update it, and you can create additional plans for different locations.
1. Responsibility – Who manages your IIPP?
An important 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:
- Be identified in your written IIPP and have management’s full support.
- Know about your workplace’s safety and health issues and hazard control measures.
- Have the authority and responsibility for making necessary corrections and implementing the program.
Communicate to your employees who is in charge of and responsible for your IIPP.
2. Compliance – How do employees follow the rules?
The IIPP standard requires that employers establish a system/protocol for ensuring that employees follow the organization’s safety rules. In other words, you need substantial compliance. To achieve this you should include a method for providing positive recognition of employees who perform and follow safe and healthful work practices. This should also address disciplinary action for employees who fail to follow your safety rules.
3. Communication – How to inform employees about your IIPP
You need to communicate with your employees in the language understood by your employees. Communication can take place through trainings, meetings, announcements, email notices, memos, newsletters, and/or through the activities of your safety leader.
A few points to remember:
- Know your audience and the best ways to communicate with them.
- Your safety communications are most impactful when they involve employee interaction.
- All of your employees should be familiar with your IIPP and their responsibilities in following procedures.
- Management should be present at regular safety meetings and the meetings should be open where safety is discussed freely. All staff or unit members must attend as often as possible.
- Document all safety meetings, including attendee sign-in sheets and retain records for at least one year.
Your employees should have a way to anonymously report hazards without fear of retaliation.
4. Hazard assessment – What hazards exist at your workplace
The fourth element of your IIPP is the hazard assessment. The goal of conducting a hazard assessment is to identify a hazard before an injury occurs. Workplaces with the strongest safety cultures make risk assessments and mitigating the hazards found a priority by regularly and actively managing the risk.
Here are a few things you can do to improve your safety culture in this area:
- Conduct risk assessments, also called inspections, of your workplace as necessary (daily, weekly, etc.). To clarify, it will depend on the exposure or risk for the job, project, or task as hand. For example, it might be best to conduct them daily or weekly at a construction site and in some instances, multiple times a day when you have multiple shifts or rotating personnel. Remember that the more you identify and mitigate hazards, the safer your employees will be.
- Involve your employees. Don't rely on management alone to conduct your inspections. Train all your employees on how to identify hazards in their work environment. This will help increase awareness of danger in their day-to-day activities. Do the same with hazard mitigation.
- Perform a Job Hazard Analysis (JHA). The JHA allows you identify all the basic steps of the job or task at hand and identify where potential hazards may exist. This is very useful when employees are performing job duties in a way that is not in line with your policies and procedures. If so, find out why. There may be a hazard they are having difficulty with that prevents them from doing it properly or they may have come up with a more efficient and safer way to do the job.
5. Accident/exposure investigation – What caused an accident/near miss?
Accident investigations should be conducted by a trained supervisor or manager, and whenever possible, include your employee(s). They’re frontline workers and can bring a unique perspective to why something happened. Whichever method you use to determine the root cause of the accident or near miss, it needs to answer these fundamental questions:
- What happened?
- How did it happen?
- Why did it happen?
- What needs to be corrected?
- When will the correction be completed?
Finding the underlying factors that may have contributed to the incident will help you prevent it from happening in the future.
6. Hazard correction – Making changes to improve safety.
Once hazards are observed or discovered through an accident investigation or risk assessment, they should be addressed in a timely manner, based on the severity of the hazard. However, if an imminent hazard exists and cannot be fixed right away without endangering employees and/or property, remove all exposed personnel from the area except those necessary to correct the hazardous condition.
Employees that correct the hazardous condition shall be provided effective training, the necessary equipment, and Personal Protective Equipment (PPE). You can start by training your managers and supervisors on the Hierarchy of Controls. The Hierarchy of Controls describes five ways to eliminate or reduce risk and if possible, you can apply one or more of these methods.
- Start with the one that is most effective, eliminate material or process whenever possible.
- Substitute the material or process with one that is less hazardous
- Implement engineering controls. A physical change such as installing barriers or distance will help protect your employees from the hazardous condition.
- Administrative controls - This method includes changes to procedures, training, warning signs, and labels. ADMINISTRATIVE CONTROLS DO NOT ELIMINATE HAZARDS, they only limit them or prevent your employees' exposure to them.
Finally, Personal Protective Equipment, or PPE such as gloves, respirators, hard hats, safety glasses, or the like are the least effective means of controlling hazards.
7. Training and instruction – Performing job duties safely.
Training and instruction are an important part of any IIPP. Effective training helps workers learn their jobs well, reinforces good ideas and practices, brings new ideas, and jump-starts your company's safety program. Regular training reminds your employees that hazards exist and that no one is immune from accidents.
Your safety training should cover all relevant topics and reach all affected employees. Focus your training on the identified hazards and conduct training when:
- A new employee joins
- A new assignment is given
- When new procedures or equipment are introduced
Remember to keep the training interactive and include hands-on demonstrations whenever possible. 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.
8. Access - Your IIPP is available to your employeees
Cal/OSHA requires that all employees have access to a copy of the IIPP written by their employer by one of these two methods:
- Through a company server or website which allows employees to review, print, or email a copy of the IIPP
- If requested, provide employees with access to a paper or electronic copy of the IIPP from their supervisor or human resources can provide a copy of the IIPP within five (5) business days of receipt of the request
9. Recordkeeping – Document corrections, changes, and successes with your IIPP.
During a Cal/OSHA inspection, they will review your records to verify if you have conducted safety meetings, risk assessments, and training. They will want to see changes you made to prevent the same or similar hazard or accident/incident from happening again.
This is why workplaces must maintain a written IIPP and documentation of how the elements of their IIPP are carried out. These records will demonstrate the effectiveness of your overall program.
Other common record keeping items are:
- Employee disciplinary actions (as appropriate)
- Safety meeting records to include date, topics discussed, and names of those who attended
- Safety inspection records to include date, hazard, corrective action, and when it was completed
- Accident investigations to include date, what happened, how will it be prevent, and when it was completed
- Employee safety training records to include date, training topic, and when it was completed
- Applicable operating permits when working with asbestos, lead, etc.
- Registries of hazardous substances such as safety data sheets (SDS)
