Guide To Developing Your Workplace Illness Program

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Department of Industrial RelationsDivision of Occupational Safety and HealthPublications UnitGuide toDevelopingYourWorkplaceInjury &IllnessPreventionProgramAugust 20201

About This GuideIn California every employer has a legal obligation to provide and maintain a safe and healthfulworkplace for employees, according to the California Occupational Safety and Health Act of 1973. Asof 1991, a written, effective Injury and Illness Prevention (IIP) Program is required for every Californiaemployer.This guide describes the employers’ responsibilities in establishing, implementing, and maintaining anIIP Program, as well as making the written IIP Program available to their employees. It also outlinessteps that can be taken to develop an effective Program that helps assure the safety and health ofemployees while on the job.The term “employer” as used in the Cal/OSHA Act includes any person or corporation, the State andevery State agency, every county or city or district and public agency therein, which has any personengaged in or permitted to work for hire, except for household services.This guide is designed to help employers provide better workplace protection for their employees,and to reduce losses resulting from accidents and injuries. The material in this publication is basedon principles and techniques developed by occupational safety and health professionals nationwide.It is intended to provide guidance, rather than prescribe requirements, and is not intended as a legalinterpretation of any state standard.

Table of ContentsWhy Have a Workplace Injury and Illness Prevention Program?. . . . . 1Accidents Cost Money. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Controlling Losses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Cal/OSHA Injury & Illness Prevention Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1What is an Injury & Illness Prevention Program? . . . . . . . . . . . . . . . . . 2Management Commitment, Assignment of Responsibilities, and Assuring EmployeeCompliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Safety Communications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Hazard Assessment & Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Accident Investigation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Safety Planning, Rules & Work Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Safety & Health Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Employee Access to the Injury and Illness Prevention Program. . . . . . . . . . . . . . . . . . .2345678Getting Started on Your Injury & Illness Prevention Program . . . . . . 10Assign Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Look at What You Have. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Safety & Health Survey. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Workplace Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Review & Compare. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Develop an Action Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Take Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Maintain Your Program and Ensure Employee Access to It . . . . . . . . . . . . . . . . . . . . .1010101111121212Safety & Health Recordkeeping. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Injury & Illness Records. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Exposure Records. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Documentation of Your Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Model Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Sources of Information & Help. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Cal/OSHA Consultation Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Other Sources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Appendix A: Model Policy Statements . . . . . . . . . . . . . . . . . . . . . . . . . 17Appendix B: Non-Mandatory Checklist Evaluation Injury & IllnessPrevention Programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19Appendix C: Code of Safe Practices. . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Why Have a WorkplaceInjury and Illness Prevention Program?Controlling LossesTaking risks is a part of running a business,particularly for small business owners. You takerisks in product development, marketing, andadvertising in order to stay competitive. Somerisks are just not worth the gamble. One of theseis risking the safety and health of those whowork for you.If you would like to reduce the costs and risksassociated with workplace injuries and illnesses,you need to address safety and health rightalong with production.Setting up an Injury and Illness PreventionProgram helps you do this. In developing theProgram, you identify what has to be done topromote the safety and health of your employeesand worksite, and you outline policies andprocedures to achieve your safety and healthgoals.Accidents Cost MoneySafety organizations, states, small businessowners and major corporations alike now realizethat the actual cost of a lost workday injury issubstantial. For every dollar you spend on thedirect costs of a worker’s injury or illness, youwill spend much more to cover the indirect andhidden costs. Consider what one lost workdayinjury would cost you in terms of: Productive time lost by an injured employee. Productive time lost by employees andsupervisors attending the accident victim. Clean up and startup of operationsinterrupted by the accident. Time to hire or to retrain other individuals toreplace the injured worker until his/her return. Time and cost for repair or replacement ofany damaged equipment or materials. Cost of continuing all or part of theemployee’s wages, in addition tocompensation. Reduced morale among your employees, andperhaps lower efficiency. Increased workers’ compensation insurancerates. Cal/OSHA Injury & IllnessPrevention ProgramIn California every employer is required by law(Labor Code Section) to provide a safe andhealthful workplace for his/her employees. Title8 (T8), of the California Code of Regulations(CCR), requires every California employer tohave an effective Injury and Illness PreventionProgram in writing that must be in accord with T8CCR Section 3203 (www.dir.ca.gov/Title8/3203.html) of the General Industry Safety Orders.Additional requirements in the following T8CCR Safety Order Sections address specificindustries:Construction—Section 1509 ons 6507, 6508, 6509 (www.dir.ca.gov/Title8/sb14a3.html),6760, 6761, 6762 (www.dir.ca.gov/Title8/sb15a3.html)Ship Building, Ship Repairing, Ship Breaking—Section 8350 (www.dir.ca.gov/Title8/8350.html)Cost of completing paperwork generated bythe incident.Tunnels—Section 8406 (www.dir.ca.gov/Title8/sb20a3.html)1

What is an Injury & Illness Prevention Program?Your Injury and Illness Prevention Program mustbe a written plan that includes procedures and isput into practice. These elements are required:correct hazardous conditions or practices as theyoccur or are recognized.You must commit yourself and your company bybuilding an effective Injury and Illness PreventionProgram and integrating it into your entireoperation.1. A person (or persons) with authority andresponsibility for implementing the Program isidentified2. A system for ensuring employees comply withsafe and health work practices.This commitment must be backed by strongorganizational policies, procedures, incentives,and disciplinary actions as necessary to ensureemployee compliance with safe and healthfulwork practices.3. A system for communicating with employeesin a form readily understandable by allaffected.They should include:4. Procedures for identifying and evaluatingwork place hazards.1. Establishment of workplace objectivesfor accident and illness prevention, likethose you establish for other businessfunctions such as sales or production. Bevery careful that the objectives you set donot unintentionally discourage reporting ofaccidents, injuries or illnesses5. Procedures to investigate occupational injuryor illness.6. Procedures for correcting unsafe or unhealthyconditions, work practices and procedures.7. Provide employee training and instruction.2. Emphasis on your staff’s safety and healthresponsibilities and recognition by yoursupervisors and employees that they areaccountable. Advise your management staffthat they will be held accountable for theunsafe actions of the employees workingunder them, and then back it up with firmaction. At the same time, recognize thosewho routinely abide by workplace policy andprocedures, and consistently engage in safebehavior.8. Procedures to allow employee access to theProgram.9. Recordkeeping and documentation.Management Commitment,Assignment of Responsibilities,and Assuring EmployeeComplianceYour commitment to safety and health showsin every decision you make and every actionyou take. Your employees will respond to thatcommitment.3. A means for encouraging employees toreport unsafe conditions with assurance thatmanagement will take action.4. Allocation of company resources - financial,material and personnel - for:The person or persons with the authority andresponsibility for your safety and health programmust be identified and given management’s fullsupport. You can demonstrate your commitmentthrough your personal concern for employeesafety and health and by the priority you placeon these issues.a. Identifying and controlling hazards in newand existing operations and processes,and potential hazards.b. Installing engineering controls.If you want maximum production and quality, youneed to control potential work-place hazards andc. Purchasing personal protectiveequipment.2

d. Promoting and training employees insafety and health.5. Reviews investigations of alleged hazardousconditions brought to the attention of anycommittee member. When determinednecessary by the committee, it may conductits own inspection and investigation to assistin remedial solutions.5. Setting a good example! If, for instance, yourequire personal protective equipment (PPE)to be worn in a specific area, then you andother management wear that PPE in thatarea.6. Submits recommendations to assist in theevaluation of employee safety suggestions.If you and your management team do notsupport and participate in the program, you aredoomed to failure from the start. It is especiallyimportant for plant supervisors and fieldsuperintendents to set a good example.7. Upon request of the Division, verifiesabatement action taken by the employer toabate citations issued by the Division.If your employees are not represented by anagreement with an organized labor union, andpart of your employee population is unionized,the establishment of labor- managementcommittees is considerably more complicated.Safety CommunicationsYour program must include a system forcommunicating with employees - in a formreadily understandable by all affected employees- on matters relating to occupational safetyand health, including provisions designed toencourage employees to inform the employer ofhazards at the worksite without fear of reprisal.If you elect not to use labor-managementsafety and health committees, be prepared toformalize and document your required system forcommunicating with employees.Here are some helpful safety communicationtips:While this section does not require employersto establish labor-management safety andhealth committees, it is an option you shouldconsider. If you choose to do so, remember thatemployers who elect to use a labor-managementsafety and health committee to comply with thecommunication requirements are presumed tobe in substantial compliance if the committee:1. Your communication system must be in aform readily understandable by all affectedemployees. This means you should beprepared to communicate with employeesin a language they can understand, and ifan employee cannot read in any language,you must communicate with him/her orallyin a language readily understandable. Yourcommunication system must be designed toencourage employees to inform the employerof hazards at the workplace without fear ofreprisal. It must be a two-way system ofcommunication.1. Meets regularly but not less than quarterly.2. Prepares and makes available to affectedemployees written records of the safety andhealth issues discussed at the committeemeetings, and maintained for review by theDivision upon request.3. Review results of the periodic scheduledworksite inspections.2. Schedule general employee meetings atwhich safety is freely and openly discussedby those present. Such, meetings shouldbe regular, scheduled, and announced toall employees so that maximum employeeattendance can be achieved. Rememberto do this for all shifts. Many employersfind it cost effective to hold such meetingsat shift change time, with a brief overlap ofschedules to accomplish the meetings. If4. Reviews investigations of occupationalaccidents and causes of incidents resultingin occupational injury, occupational illnessor exposure to hazardous substances, andwhere appropriate, submits suggestions tomanagement for the prevention of futureincidents.3

properly planned, effective safety meetingscan be held in a 15 to 20-minute time frame.Concentrate on:8. Communicate your concerns about safety toall levels of management.9. Document all communication efforts, as youwill be required to demonstrate that a systemof effective communication is in place.a. Occupational accident and injury historyat your own worksite, with possiblecomparisons to other locations in yourcompany.Hazard Assessment & Controlb. Feedback from the employee group.Periodic inspections and procedures forcorrection and control provide a method ofidentifying existing or potential hazards in theworkplace, and eliminating or controlling them.Hazard control is the heart of an effective Injuryand Illness Prevention Program.c. Guest speakers from your worker’scompensation insurance carrier or otheragencies concerned with safety.d. Brief audio-visual materials that relate toyour industry.If hazards occur or recur, this reflects abreakdown in the hazard control system. Thehazard control system is also the basis fordeveloping safe work procedures and injury/illness prevention training.e. Control of the meetings.f. Stress that the purpose of the meeting issafety. Members of management shouldattend this meeting.The required hazard assessment survey of yourestablishment, when first developing your Injuryand Illness Prevention Program, must be madeby a qualified person. This survey can providethe basis and guide for establishing your hazardassessment and control system. The surveyproduces knowledge of hazards that exist inthe workplace, and conditions, equipment andprocedures that could be potentially hazardous.3. Training programs are excellent vehicles forcommunicating with employees.4. Posters and bulletins can be very effectiveways of communicating with employees.Useful materials can be obtained fromCal/OSHA, your workers’ compensationinsurance carrier, the National Safety Councilor other commercial and public serviceagencies.An effective hazard control system will identify:hazards that exist or develop in your workplace;how to correct those hazards; and steps youcan take to prevent their recurrence. If you havean effective system for monitoring workplaceconditions:5. Newsletters or similar publications devoted tosafety are also very effective communicationdevices. If you cannot devote resourcesto an entire publication, make safety afeatured item in every issue of your companynewsletter.1. You will be able to prevent many hazardsfrom occurring through scheduled anddocumented self-inspections. Make sureestablished safe work practices are beingfollowed and those unsafe conditions orprocedures are identified and correctedproperly. Scheduled inspections are inaddition to the everyday safety and healthchecks that are part of the routine duties ofmanagers and supervisors.6. A safety suggestion box can be used byemployees, anonymously if desired, tocommunicate their concerns to management.7. Publish a brief company safety policy orstatement informing all employees thatsafety is a priority issue with management,and urge employees to actively participatein the program for the common good of allconcerned. (Model policy, statements arefound in Appendix A.)The frequency of these inspections dependson the operations involved, the magnitude of4

the hazards, the proficiency of employees,changes in equipment or work processes,and the history of work-place injuries andillnesses. Inspections should be conductedby personnel who, through experienceor training, are able to identify actual andpotential hazards and understand safe workpractices.to identifying hazards and correspondingpersonal protective equipment that may berequired.4. Hazards should be corrected as soon asthey are identified. For any that can’t beimmediately corrected, set a target data forcorrection based on such considerationsas: the probability and severity of an injuryor illness resulting from the hazard; theavailability of needed equipment, materialsand/or personnel; time for delivery,installation, modification or construction; andtraining periods.Written inspection reports must be reviewedby management and/or the safety committee.The review should assist in prioritizing actionsand verify completion of previous correctiveactions. Overall inspection program resultsshould be reviewed for trends.Provide interim protection to employeeswho need it while correction of hazards isproceeding. A written tracking system suchas a log helps you monitor the progress ofhazard correction.Know which Cal/OSHA safety orderscontained in Title 8 of the California Codeof Regulations apply to your workplace anduse them to identify potential hazards. ACal/OSHA Consultation Service consultantor outside consultant can assist you inidentifying safety orders applicable to yourwork.5. You should review and prioritize yourprogram based on the severity of the hazard.Accident Investigation2. Your employees should be encouragedto tell you or their supervisors of possiblyhazardous situations, knowing their reportswill be given prompt and serious attentionwithout fear of reprisal. When you let themknow that the situation was corrected (or whyit was not hazardous), you create a systemby which your employees continue to reporthazards promptly and effectively.A primary tool you should be using in an effort toidentify and recognize the areas responsible foraccidents is a thorough and properly completedaccident investigation. It should be in writing andadequately identify the cau

What is an Injury & Illness Prevention Program? 2. Management Commitment, Assignment of Responsibilities, and Assuring Employee Compliance 2. Management Commitment, Assignment of Responsibilities, and Assuring Employee Compliance 2. Safety Communications 3. Hazard Assessment & Control 4. Accident Investigation 5. Safety Planning, Rules & Work .

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