In this blog we are starting a periodic series which will answer frequently asked questions about Cal/OSHA and workplace safety.
It seems appropriate to start with the most basic requirement found in Title 8: California’s Illness and Injury Prevention Plan (IIPP). We are starting with the IIPP because from time to time we still run into employers – usually new companies – who do not know they need to have an IIPP. So, here we go…
Under California law, Title 8 California Code of Regulations, section 3203 requires every employer regardless of size to develop and implement an IIPP.
Specifically, section 3203 requires that the employer’s plan must address eight elements: Responsibility, Compliance, Communication, Hazard Assessment, Accident/Exposure Investigation, Hazard Correction, Training and Instruction, and Recordkeeping.
This written plan is worthless however if it is not used as the framework for your safety program. At the very least, using the plan in your safety program will save you from a quick ticket when Cal/OSHA inspects your workplace. When reviewed periodically, your IIPP serves as a reminder to conduct inspections for workplace hazards and to provide regular safety training to your employees. But the best safety programs go beyond the bare bones of an IIPP by encouraging active participation from all employees, supervisors and management.
An effective IIPP, then, provides benefits for both you and your employees. Most fundamentally, it can assist you in your efforts to prevent injuries and illnesses, which are costly to both you and – obviously – y0ur employers.
All of that said, we recommend that you stick to Cal/OSHA’s minimum requirements when writing your plan. Think of it this way: Your plan is a promise to your employees, a contract if you will, so you should only promise what you know you must and can deliver. If your plan has promises in it which are not required by section 3203 you may be setting yourself up for disaster. For example, one of our clients added a section to its IIPP about how it would deal with imminent hazards. When this section of their IIPP was not followed to the letter and an employee died, the employer found itself defending both a willful serious citation AND a criminal charge.
Cal/OSHA has online tools available to assist you in writing your IIPP here. They are a good place to start. The benefit to using this e-tool is that if your plan mirrors Cal/OSHA’s recommendations, you can’t be faulted for not having included all of the elements required by section 3203 in your plan.
If you have questions about creating or updating an IIPP for your workplace, give us a call at 707-431-7900.