The absence of an Injury and Illness Prevention Program (IIPP) ranks among the most frequent Cal/OSHA (California Occupational Safety and Health Administration) citations against businesses. Fines for the failure to have an IIPP are upwards to $7,000. Many California employers are not aware that it is mandated by law to have a written IIPP. The law (Senate Bill 198) enacted in 1989, and effective on July 1, 1991, requires California employers to develop and implement an IIPP.Below is a list of the eight required sections of the IIPP, along with suggestions that will help you get started in creating an effective safety program:
- Management commitment/assignment of responsibilities- A demonstration of safety and health begins with top-level management. Management’s commitment to safety will set the tone for the rest of the organization. Appointing a safety captain to be in charge of the program is a great start to demonstrating company-wide commitment. While the safety captain’s primary role is to ensure that safety work-habits are adopted throughout the organization, they may, also, lead a safety committee comprised of employees representing each department/area of the organization. Members of the committee can assist the safety captain by executing the organization’s safety goals.
- Safety Communication system- There are many creative ways that you can communicate the importance of safety to your staff. They may include: introducing your safety program during new hire orientations, include examples of safe behaviors in a company newsletter/company-wide communication, post safety posters throughout your facility or communicate a safety tidbit on a regular basis at a start-up/staff meeting. Remember, empowering your team to develop creative ideas on how to effectively communicate your safety program will go a long way in motivating them to stay committed.
- Compliance to the safety program- Make sure that all employees practice safe work habits throughout the day. A great way to ensure compliance is to create a Safety Recognition Program that rewards employees for working safely. The Recognition Program does not have to be costly. It may include: a designated parking space for a quarter, lunch for the top five safe employees, or verbal recognition in a company-wide event.
Remember: The best way to seek compliance by your employees is to first gain their commitment. Employees are not motivated when they feel like an initiative is “shoved down their throats.” However, if they feel like they are a part of the solution, their commitment will translate into compliance by being a safety role model. For example, demonstrating initiative by communicating safety hazards to the management team. On the flip side, there should also be consequences established for those employees that are exhibiting unsafe behaviors in the workplace. - Hazard Assessment- An internal assessment of anything that is potentially dangerous must be included in a written inspection report and reviewed by management and/or the safety committee. Hazards that are identified in your assessment must be corrected. However, if they can not be corrected immediately, then establishing a date will demonstrate your commitment and show that there is a plan in place to make identified corrections.Please Note: imminent hazards cannot be postponed for corrections.
- Investigations- The investigation process must be documented in your IIPP. This allows for the identification of root causes of the incident, while making corrective actions. The investigation needs to occur after the accident happened, while the facts are fresh. If possible, interview the injured worker at the scene of the accident. Remember, every investigation should include an action plan that addresses the prevention of future accidents.
- Hazard Correction- Include methods/procedures for correcting unsafe or unhealthy conditions in a timely manner.
- Training- Training is important to not only educate, but to reinforce the requirements listed above (1-6). Training should be done at minimum- when new guidelines are established, to all new hires, and for all supervisors. Additionally, training must be done when new hazards are introduced into the workplace and when employees are assigned new job duties that will expose them to new hazards.
- Record Keeping- Is one of the most important elements of your IIPP. It shows Cal OSHA that you not only have written documentation of your safety program, but that your program is being implemented. Records should be maintained for at least a year. They should include records of scheduled and periodic self inspections as well as safety training. Inspection records should include the name of the person that conducted the inspection, the unsafe conditions or practices identified and the corrective action taken. Safety training records should include the employee name or other identifier, training dates, type(s) of training and the name of the training provider. In addition, while recordkeeping is very important, requirements are less stringent for employers with less than 10 employees.
The IIPP is not only a way to save money, but it also reinforces the importance of workplace safety. While all eight requirements are listed, each requirement is extensive. If you have additional questions about the eight requirements, please call your Risk Management Representative to assist you with creating an effective Injury and Illness Prevention Program.