For the past 33 years California companies with 10 or more employees have been required to establish, implement and maintain a written Injury, Illness and Prevention Program (IIPP), for compliance to CCR Title 8, §3203. We find that many clients have both implemented, and established their programs, but too many of them fail to properly maintain their written plans to stay current with evolving business practices.
What is program maintenance?
Maintenance is exactly what one would expect.
In our modern world, it’s easy to forget regular maintenance. This is why the ‘change oil’ light comes on in our cars at a set interval, even when the car seems to be running perfectly. And because our company documents do not have idiot lights, we need to be intentional with our maintenance calendar.
Businesses change. Risks change. Employees turnover. Employee titles change. That emergency health clinic that you’ve been using since 1991 has probably changed names a half dozen times since the company’s IIPP was initially drafted during the first Bush administration.
Why now is a good time to review your IIPP?
Over the past two months, Cal/OSHA implemented two new programs. The Workplace Violence Prevention Plan (WVPP) and the Heat Illness and Prevention Plan for Indoor Workplaces (HIIP) became effective on July 1, and July 25, respectively. In each of those instances, Cal/OSHA has stated that these new plans could be standalone documents, or incorporated into an existing Injury, Illness and Prevention Program. For those that wish to combine plans, or supplement the IIPP, now is the time to do so as the enforcement period has already started.
Does your combined IIPP make sense?
Now that you have compiled all the documents that will make up the 2024 revised IIPP, does the language merge OK? Are the responsible employees correctly identified? Does your IIPP state to report injuries to “Janet Smith”, but your HIIP states to report to “Human Resources”? Are there contradictory evacuation plans, phone extensions, emergency contact numbers?
Are there any programs that can be purged from the IIPP, perhaps for activities that the business no longer conducts? CDMS recently reviewed a client’s IIPP that had chapters, CHAPTERS(!), dedicated to welding, hot work and the safety requirements of acetylene cylinders, but they started contracting these services out to a third-party vendor a decade ago. Again, maintenance is the key for IIPP success.
Finally, for our clients with IIPPs.
Those that added the temporary Covid-19 Prevention Temporary Standards to your existing Injury, Illness and Prevention Plans in November 2020 are reminded that they must remain in effect until February 3, 2025. For those who added a section for Heat Illness and Prevention for Outdoor Workspaces (§3395), those can remain, but like above, make sure it makes sense within the revised IIPP.
Also, make sure to date, record and sign any revisions. Take the obsolete versions out of circulation, but make sure you keep a copy of each version for your records.
CDMS’s Role:
CDMS provides training and plan development to our California clients. Please reach out to service@cdms.com to schedule an evaluation if you think your facility may be subject to the IIPP, Workplace Violence Prevention or Indoor Heat Illness Prevention requirements. We can also review existing Plans and make recommendations.
