Injury & Illness Prevention Program

Rev 3-7-2017

Cal/OSHA Consultation Services Branch

Welcome!

• Introduction • Location of Restrooms• Emergency Procedures • Cell Phones (silent mode)• Training Impact Form

Workshop Summary

• Designed to help you develop or improve your Injury and Illness Prevention Program (IIPP)

• The target audience

–Supervisors

–Managers

–Owners of small-businesses

Learning Objectives

• By the end of the workshop, participants will be able to:–Describe the 8 elements of an IIPP–Perform an IIPP assessment–Develop or improve your IPP

Why Do We Need An IIPP?

• Because we live in California• Required by T8CCR 3203(a) and 1509(a)• It makes good business sense• Save $$$• Other reasons such as employee morale,

productivity, etc.

Injury and Illness Prevention Program

• Title 8, California Code of Regulations, Section 3203 (T8CCR 3203)–Went into effect July, 1991–The most cited Cal/OSHA regulation–Required of all employers in California

IIPP Key Elements (3203)

• Authority / Responsibility

• Ensuring Compliance

• Communication

• Hazard Assessments

• Incident Investigations

• Correction

• Training

• Documentation

• Every employer shall establish, implementand maintain an effective Injury and Illness Prevention Program (IIPP)

The Program shall be in writing and, shall, at a minimum address:

IIPP ELEMENTS - 3203(a)(1)

• Responsibility– A person assigned as administrator with the

authority and responsibility for implementing the provisions of the program• When replacing responsible person ensure the

written IIPP is updated– Name vs. Position

• Ensure the responsible person does have responsibility

– Large vs. small employer

IIPP - 3203(a)(2)

• Compliance– Inform workers of IIPP

provisions– Evaluate worker’s safety

performance– Retraining for safety

deficiencies– Discipline workers for

failure to comply

• Compliance– Recognize workers who follow safe and

healthful work practices• Discourage programs that intentionally or

unintentionally provide employees an incentive to not report injuries/illnesses or safety/health hazards they may observe.

– Examples may include programs that have “zero” injury/illness goals

• Recognition programs should use leading indicators

IIPP - 3203(a)(3)• Communication

– Two-way communication without fear of reprisal• Meetings • Training programs• Posting• Written communications• A system of anonymous notification by employees about

hazards• Labor/management safety and health committees• Any other means that ensures communication with

employees– Exception: 10 or fewer employees

– it may be verbal

IIPP - 3203(a)(4)

• Hazard Assessment– Periodically

• You define the frequency and who performs these assessments

– When IIPP is initially established or changes made

– New substances, processes, procedures

– New hazards are identified– After injury or illness

• Assessments should Include:– Physical hazards– Hazardous materials (chemical)– Biological hazards– Employee work habits / behaviors– Cal/OSHA Regulations

• Guidance for Hazard Inspections– Who should do the inspections– When should you do the inspections – Using checklist(s) and facility diagrams

The 10 Most Frequently Cited Violations

• IIPP • Heat Illness • Lockout/Blockout• Reporting Serious Injuries• Hazard Communication • Respiratory Protection • Portable Fire Extinguishers • Air Compressor Permits• Emergency Medical Services (Construction) • Portable Ladders

IIPP - 3203(a)(5)

• Accident Investigation– Determine the root cause, not find blame

• Visiting the accident scene ASAP• Interview injured workers and witnesses• Examining the workplace or causal factors• Taking corrective action to prevent recurrence

– Can use the OSHA Form 301

IIPP - 3203(a)(6)

• Hazard Correction– When observed or discovered– Include methods and/or procedures for

correcting unsafe or unhealthy conditions, work practices and work procedures in a timely manner based on the severity of the hazard• If imminent hazard, remove workers immediately

– All action taken shall be documented

• Hazard Correction – Imminent Hazard

– When an imminent hazard exists which cannot be immediately abated without endangering employee(s) and/or property, remove all exposed personnel from the area except those necessary to correct the existing condition

– Employees necessary to correct the hazardous condition shall be provided the necessary safeguards

IIPP - 3203(a)(7)

• Training–When the IIPP is first established–To reassigned workers–Whenever new substances, processes,

procedures or equipment are introduced

–New hazards–Job specific training

IIPP - 3203(b)

• Recordkeeping– Required documents:

• Training records• Hazard assessment records• Safety Committee records

• Hazard Assessment Records–Maintain for at least one (1) year

• Exception: Employers with fewer than 10 employees may elect to maintain the inspection records only until the hazard is corrected

• Training Records– Maintain for at least one (1) year

• Include employee name or other identifier, training dates, type(s) of training, and training provider(s)

• Exception 1 – Less than 10 employees keep a log of training

• Exception 2 – Employee leaves within a year keep need not keep records if they are given to employee

For Employers With Fewer Than 20 Employees

• In industries not on a designated list of high-hazard industries established by the Department of Industrial Relations, and have a Workers' Compensation Experience Modification Rate of 1.1 or less

-- or --• In industries on a designated list of low-hazard

industries established by the Department

• What’s Needed:

1. Written documentation of the identity of the person or persons with authority and responsibility for implementing the program as required by subsection (a)(1)

2. Written documentation of scheduled periodic inspections to identify unsafe conditions and work practices as required by subsection (a)(4)

3. Written documentation of training and instruction as required by subsection (a)(7)

IIPP - 3203(c)

• Employers who elect to use a labor/management safety and health committee to comply with the communication requirements:– (1) Meets regularly, but not less than quarterly;– (2) Prepares and makes available to the affected

employees, written records of the safety and health issues discussed at the committee meetings and, maintained for review by the Division upon request. The committee meeting records shall be maintained for at least one (1) year;

IIPP - 3203(c)

– (3) Reviews results of the periodic, scheduled worksite inspections;

– (4) Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness, or exposure to hazardous substances and, where appropriate, submits suggestions to management for the prevention of future incidents;

IIPP - 3203(c)

– (5) Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, the committee may conduct its own inspection and investigation to assist in remedial solutions;

IIPP - 3203(c)

– (6) Submits recommendations to assist in the evaluation of employee safety suggestions; and

– (7) Upon request from the Division, verifies abatement action taken by the employer to abate citations issued by the Division

IIPP for Construction (1509)

• Same 3203 elements plus:– Code of Safe Practices -

develop and post• Posted at a conspicuous

location at each job site office or be provided to each supervisory employee who shall have it readily available

– Tailgate safety meetings every 10 work days

Reviewing your IIPP

• Does it have the following:1. Identifies person(s) with authority/responsibility?2. System to ensure employee compliance with safe work

practices?3. System for employees report hazards?4. Procedures for identifying & evaluating workplace

hazards?5. Procedures for investigating accidents?6. Methods for correcting hazards?7. Training program?8. Documentation & records maintenance?

Other Programs to Consider

The IIPP may be considered an umbrella program• Heat Illness• Lockout/Tagout• Hazard Communication• Emergency Action Plan• Respiratory Protection• Bloodborne Pathogens• Airborne Transmission

Diseases (ATD)

• Workplace Violence for Health Care

• Lab Safety• Forklift• Hearing Conservation• PPE• And more….

• San Fernando Valley 6150 Van Nuys Boulevard, Suite 307 Van Nuys, CA 91401 (818) 901-5754

• Los Angeles, Orange 1 Centerpointe DriveSuite 150La Palma, CA 90623(714) 562-5525

• San Bernardino464 W. 4th Street, Suite 339 San Bernardino, CA 92401 (909) 383-4567

• San Diego 7575 Metropolitan Drive, Suite 204San Diego, CA 92108 (619) 767-2060

• Northern California 2424 Arden Way, Suite 410 Sacramento, CA 95825(916) 263-0704

• San Francisco Bay Area 1515 Clay Street, Suite 1103 Oakland, CA 94612 (510) 622-2891

• Central Valley 1901 North Gateway BoulevardSuite 102 Fresno, CA 93727 (559) 454-1295

Cal/OSHA Consultation Service Toll-Free Number 1-800-963-9424

Helpful Information

• Cal/OSHA’s web page• www.dir.ca.gov/dosh

– Publications– Title 8 regulations – Policy and Procedure

• Fed/OSHA’s web page• www.osha.gov

– Educational materials– Title 29 of the Code of

Federal Regulations– Federal Registers

Cal/OSHA IIPP Publicationshttp://www.dir.ca.gov/dosh/PubOrder.asp

• Guide to Developing Your Workplace Injury & Illness Prevention

• Injury and Illness Prevention Model Programs– for High Hazard Employers– for Employers With Intermittent Workers

in Agriculture – for Employers with Intermittent

Employees – for Non-High Hazard Employers

IIPP eTool

• The etool will produce a written IIPP for you by answering a set of questions

• Each of your answers will automatically appear underlined in a written IIPP which is specific to your workplace

• The written IIPP you produce will not be sent to Cal/OSHA

www.dir.ca.gov/dosh/etools/09-031/index.htm

Enforcement’s IIPP P&P

• www.dir.ca.gov/samples/search/querypnp.htm• P&P C-45 A & B

– A: General Industry (3203)– B: the additional elements required for Construction

(1509)• Evaluate the effectiveness of an employer's IIPP• Evaluated on every inspection

Any Questions?