Like an umbrella that protects you from the rain, your Injury and Illness Prevention Program (IIPP) protects your employees against potential injury. This broad workplace safety plan has been required in California since 1991. So why do many California employers not have one? Or, if they do, why aren’t they using it properly? Business pressures and lack of experience may make it seem difficult to write an IIPP. Some employers might not be aware of the law. Others may just think having the written document is good enough. But in reality, these are dangerous assumptions that could come with a big price tag.
Each year, Cal/OSHA issues more than 2,000 IIPP-related citations. That’s more than any other violation. And with each citation comes a fine. Fines range from $500 to more than $12,000, depending on the frequency and severity of the infraction.
The good news is you can prevent a citation by putting a safety plan for your workplace into action.
No written IIPP?
Cal/OSHA’s regulation calls for a written safety plan that you must have on file and available to employees. To get started on your plan, access State Fund’s IIPP Builder. Once you answer questions about your business, you’re on your way to a new or updated IIPP.
When you develop your IIPP, choose procedures that address your specific work hazards. An IIPP not customized to your operations won’t address the hazards your employees face each day. This creates gaps in your safety program that can lead to injuries as well as a citation. For example, if you manage an office, you’ll want to include information on ergonomics. If you manage a loading dock, you want to include information on forklift use and lifting techniques. And of course, you also must commit to follow your procedures.
How do I use my IIPP?
Once you have a written plan, maintain a copy at all your jobsites and tell your employees about it. Get creative about how you make it available to all staff and at all work locations. Send the IIPP out by email, host it on a shared computer drive, save it on portable drives, or place it in the cloud. This provides access from any remote or field location.
The goal is to make the IIPP accessible to employees, wherever they are. Not only do they have access to the safety plan, but also the inspection forms, hazard analysis, reporting forms, etc. And, you have your IIPP available if Cal/OSHA drops by for an inspection.
After employees know where to find the IIPP, train them on how to use it. A good IIPP identifies safe practices, safety responsibilities, and safety hazards at your workplace. They also clearly state how to report hazards and safety concerns. If a Cal/OSHA inspector interviews an employee about your IIPP, could the worker recite your safety resources and expectations? More importantly, if a hazard is present, do your employees know what to do in order to stay safe?
Training frequency increases given the variety of tasks, environments, and hazards specific to your industry. In construction, for example, employers must conduct toolbox or tailgate trainings at least every 10 working days.
Do I need to update my IIPP?
So now you have the written IIPP, made it available to employees, and have trained them, so you’re done, right? Not yet.
An IIPP is a fluid document, it’s required and designed to flex and change as the workplace changes. As new employees are hired, processes introduced, or hazards discovered, update and change the IIPP with the work environment. It’s a good idea to review your IIPP annually. Each new version of your IIPP should trigger another round of training with employees.
Completing a written IIPP, implementing it, and educating your employees on it help make your workplace safer. It also helps you achieve Cal/OSHA compliance with one of the most frequently cited regulations.
And, it keeps you off Cal/OSHA’s citation list.