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June 29, 2017
Cal/OSHA 2017: Is your IIPP effective enough to save you from a citation?
By Ana Ellington, Legal Editor

The injury and illness prevention program (IIPP) requirement has been the most frequently cited standard in California workplace health and safety inspections almost every year since it became effective. At the Cal/OSHA Summit 2017, learn about how to avoid common mistakes that lead to citations at Lisa Prince, Esq.’s presentation on IIPPs in California.

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Inspectors from the California Division of Occupational Safety and Health, better known as Cal/OSHA, are required to assess compliance with the IIPP in almost every inspection. Some judgments about noncompliance are clear-cut. For example, the lack of a written IIPP document leads to a citation. But even if the paper trail is adequate, the question of assessing the effectiveness of the program is a somewhat subjective one and can be difficult. Prince will address strategies for demonstrating a commitment to your IIPP.

Most safety professionals believe the elements of the California IIPP are obvious ingredients of a good safety program. But how do you know if an inspector will find your program to be effective?  

Cal/OSHA’s policy and procedure manual provides guidance to inspectors about how to examine whether the IIPP program is effective. Its suggested measures include the following:

  • Do workers know the name of the person in charge of the IIPP?
  • Are workers aware of methods to communicate with the employer about health and safety, and have they used them?
  • Have workers been recognized for good safety behavior or disciplined for bad safety behavior?
  • Have the procedures for identifying hazards been carried out when the IIPP was first established, when there are changes in workplace, and when the employer is made aware of a hazard?
  • Does implementation of injury investigations result in a determination of the cause?
  • Have identified hazards been abated in a timely manner?
  • Does training result in increased understanding of hazards and safer work practices?

After reading these inspection points, how would you fare if an inspector knocked on the door? Let’s rewrite the questions in a way that could better help you develop an effective IIPP.

  • Do you fully involve your workers (supervisors and management, too!)?
  • Do your workers know how to communicate to you concerns about health and safety?
  • What steps does your company take when workers demonstrate good safety behavior? How about when they exhibit bad safety behaviors?
  • How frequently do you review and revise your procedures for identifying safety and health hazards?
  • When conducting incident investigations, do you get to the root cause of the incident?
  • Are you correcting any identified hazards in a timely manner?
  • Are you training workers to recognize, report, and minimize safety and health hazards at the worksite?

If you still have concerns, do not fear. Come October 10 and 11, 2017, to the Cal/OSHA Summit—a leading state-specific event for California employers. In addition to presenting on how to avoid the most common IIPP mistakes, Lisa Prince will help your organization develop a comprehensive, written, and effective IIPP that complies with the Cal/OSHA rule.

Remember, how well you actually put into practice your IIPP in your workplace is what will determine how effective it is. And don’t forget to regularly review and update your IIPP in order for it to remain effective.

Attend BLR’s CAL/OSHA Summit 2017 at the Westin South Coast Plaza in Costa Mesa, California on October 10-11, 2017!

Click here to register!

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