he Injury and Illness Prevention Program (§3202)
Employers operating with employees in California are required to have an “effective” written Injury and Illness Prevention Program (I.I.P.P.). The requirements of the I.I.P.P. are found in California Code of Regulations §3202. The Construction Industry must also adhere to items within §1509.
History
In 1989 the California Legislature passed and the Governor signed SB 198, what many believe is the most significant piece of Occupational Safety and Health legislation since the enactment of the OSHA Act.
SB 198 shifts the focus of state policy in workplace safety and health to prevention. The changes weave the prevention approach into every aspect of Cal/OSHA enforcement sanctions.
On July 1, 1991, regulations became effective implementing the part of this bill requiring employers to establish, implement and maintain worksite injury prevention programs. Shortly after §3202 was approved, §1509 was developed and implemented.
IIPP Intended Purpose
The §3203 standard was developed and implemented as a result of SB 198. The intent was to have a basic, simply standard requiring all California employers to have a formal written safety program.
Senate Bill (SB198) was support by both Labor and the majority of large employers operating in California.
The following is a list of common questions that §3203 was intended to address:
- Who is the person with the overall safety responsibility?
- How do employees communicate with management on safety issues?
- How does your organization identify Hazards?
- What method / process does the company take to correct hazards?
- Does your company conduct “safety” related training?
- Are employees given additional training or re-training to ensure compliance with safe and healthful work practices?
- Does your company conduct investigations to determination the cause (s) of accidents, hazardous substance exposures, and near misses?
- Are employees disciplined for performing unsafe or unhealthful work practices?
- Does the company correct hazards (including damaged tools and equipment) in a timely manner?
- Is there an employee recognition program for performing safe and healthful work practices?
Eight (8) Elements
There are eight elements detailed within the I.I.P.P. standard, T8 CCR §3203.
- Responsibility
- Compliance
- Communication
- Hazard Assessment
- Accident/Exposure Investigation
- Hazard Correction
- Training and Instruction
- Recordkeeping
I.I.P.P. common citations
- 3203(a) – Employer failed have an effective IIPP
- 3203(a)(1) – Employer failed to identify a designate a person for the IIPP
- 3203(a)(4) – Employer failed to conduct periodic inspections
- 3203(a)(7) – Employer failed to have a written safe operating procedure
- 3203(b)(1) – Employer failed to maintain inspection records
- 3203(b)(2) – Employer failed to maintain training records
- 1509(a) – Employer failed to have an effective I.I.P.P. – construction
- 1509(b) Every employer shall adopt a written Code of Safe Practices which relates to the employer’s operations
- 1509 (d) Periodic meetings of supervisory employees shall be held under the direction of management for the discussion of safety problems and accidents that have occurred.
- 1509 (e) Supervisory employees shall conduct “toolbox” or “tailgate” safety meetings, or equivalent, with their crews at least every 10 working days to emphasize safety.
Keeping in mind that a requirement of the IIPP standard [§3203(a)(7)(A)] infers that company employees receive training on the elements of the company IIPP.
I.I.P.P. (where and when)
Employers in California are required to “train” [§3203(a)(7)(A)] their employees on the requirements and provisions of the I.I.P.P.
Employers are required to have available a copy of their I.I.P.P. for review. This includes off-site workplaces such as construction job-sites. Recently (2022) a change was made requiring the employer to “make available” a copy of the IIPP to the employee or their designee!
Employer I.I.P.P. do not have to be submit a copy of their I.I.P.P. to Cal/OSHA unless employer is requesting a permit, variance or as part of the OSHA inspection process an “inspection” has been opened.
“Kitchen sink” IIPP’s
Editorial comments
Your I.I.P. Program should be a simple document addressing the eight requirements identified in §3203. A “clean-simple” I.I.P.P. should not exceed more than a dozen pages, and can be as few as just three of four pages.
We recommend that your “other” safety-compliance programs (Lock-Out Tag-Out, Confined Space, etc) be maintained as separate documents. For presentation (hard copies) all programs can be assembled in one binder (or booklet) divided by tabs.
Cal/OSHA is now recognizing digital versions of the employer’s written programs (eg. I.I.P.P., H.I.I.P. and other “mandatory” programs) stored on electronic devices, “the cloud”, in lieu of hard copies. With that said, it is still recommended to had a printed copy available in the home office as well as hard copies in satellite office including “foreman pick-up trucks”.
Safety and compliance of your workplace is not only a legal requirement it is a sound business practical. Successful safety-compliance programs assist in reducing workplace incidents that result in employee injuries, equipment and property damage and OSHA citations.
If you need assistance creating an effective program or simply wish to have a professional review it, contact us. to schedule a professional comprehensive review of your current written program and an analysis of your workplace, to ensure you have all safety-compliance programs required.
Contact us at:
email: OSHAPro4u@gmail.com
Office: (888) OSHA-PRO
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Area Manager: Paul Andersen
email: paulandersenCHST@aol.com
OSHA Compliance Services (OCS) specializes in safety compliance services. We are a certified Disable Veteran Business Enterprise (DVBE). We provide on-site services such as safety and compliance audits, site safety advisors and various compliance
