by: Rebecca Gomez

In California, organizations with at least one employee are required to have a written Injury and Illness Prevention Program (IIPP) that is easily accessible for employees to read. An IIPP is a safety program that requires employers to develop and implement an effective program that improves safety in the workplace. In order for the IIPP to be effective, all employees, supervisors, and management need to be actively involved.  Cal/OSHA requires eight elements to be written in the IIPP and implemented in the workplace (with a few exceptions).

1. Responsibility (The position/person who is in charge of implementing the IIPP)
2. Compliance
3. Communication
4. Hazard Assessment
5. Accident/Exposure Investigation
6. Hazard Correction
7. Training and Instruction
8. Recordkeeping

Above are the minimum components required for an IIPP to be acceptable to Cal/OSHA standards. Everything in the IIPP must be implemented and documented to avoid a fine from the Cal/OSHA inspector. If your organization adds additional safety procedures to the IIPP, make sure those procedures are properly implemented with proper documentation.

There are a few exceptions to the IIPP requirements. One exception is as follows:

If your organization has 20 employees or less in a calendar year, whose industry is not on a high hazard list, and has an experience modification rating of 1.1% or less, your organization qualifies for the limited requirements of the IIPP:

1. Identity of those whose authority and responsibility to implement the IIPP
2. The schedule of periodic inspections to identify unsafe conditions and work practices
3. Training provided to employees.

Cal/OSHA provides a sample IIPP program (see attached). Anything that is written in the IIPP must be implemented and have supporting documentation. Administrators need to make sure that employees know who the IIPP administrator (the authority) and who has the responsibility for implementing the procedures in the IIPP (This is usually one of the first questions a Cal/Osha inspector will ask an employee during an inspection). If your organization identifies a specific individual’s name, instead of a position title, make sure to update the IIPP if another individual replaces that position.  It is important to update your IIPP at least once a year.

The IIPP, while statutory, can support an organization’s safety culture. The IIPP enforces the importance of safety in the workplace. A safe work environment can help prevent workplace injury claims and lower your organization’s workers’ compensation premium. Please let us know if you have any questions or concerns regarding workers’ compensation or the IIPP. We are here to help.