The Illness and Injury Prevention Program is a requirement from Cal-OSHA that every employer in the state of California must comply with.
There are eight standards that every program must comply with. We will not be addressing the eight specific requirements in this article since we have written about them in this article.
What we will talk about in this article is what are some of the things that go into the making of a Bulletproof Illness Injury Prevention Program. This article even has more value now that the fines have already gone up by 80% effective last November. Not only that but OSHA is forcing the California Osha, to now comply with the tougher federal requirements.
There is one last thing that I would like to say before we get into the guts of a bulletproof Illness Injury Prevention Program, I would encourage every employer in California to get a labor law consultant, along with a good Cal-OSHA consultant. The good news is Ces Today does both, so if after you have read this article should you have questions please give us a call, we would love to hear from you.
This should be a brief statement that explains that your company understands that every employer must have an illness injury prevention program and that this is ours.
Introduction to Our Program
This is where you talk about the importance of safety in the workplace. This section should also include the fact that it is both the responsibility of the employer and the employee. This and other sections is where you make sure that you expect your employees to report any hazards that they may find in the workplace so that management can get them repaired. This is also a great place to let your employees know that the company has no desire to put their employees in harm’s way.
Safety First Priority
The objective of your safety program should be to reduce the potential for workplace injuries. In fact, it is the goal of our program to reduce injuries to zero.
Safety Policy Statement
In this section, you will outline each step that you will take as an employer to make sure that the workplace is safe.
- Explain how you will be conducting your companies safety training
- Discuss how you will conduct On-Site Inspections
- Talk about how you will either discipline or reward your employee for their actions.
- Encourage employees to report any unsafe work conditions, as well as situations where the employee is not comfortable in performing a task because they don’t feel that they have been trained, well enough.
Responsible Safety Officer
This section will include the following
- The name of your safety officer. Just a side note here please be aware that in the even a lawsuit the safety officer will be named in that lawsuit. You should make your companies designated safety officer aware of that.
Now we will discuss the duties of the safety officer.
- Develop and enforce the codes of safe practices that the company will use, and expect employees to comply with.
- Develop and implement a way for employees to report unsafe work conditions immediately.
- Should an accident happen it will be the job of the responsible safety officer to conduct a through investigation of each accident. This would be true even if the accident does not cause or involve an injury.
- Instruct other supervisors as to their duties in providing an injury free environment.
- It is also the job of the safety officer to maintain all company records that have to do with training, accident investigation, and worksite inspections.
Agreement to Participate
This is another place that you want your employees to be aware that they too have a duty to perform. Their duty is to participate and follow the companies rules and guidelines that have been established for the purpose of having a safe working environment.
Individual Cooperation Necessary
While the agreement to participate is a company-wide reminder the individual cooperation will guarantee that the work environment is safe. Now while some of this may sound as if it is redundant please keep this in mind the more you spell it out the more that your employees will get the message. In a bulletproof illness injury prevention program, there will be a subtle difference that will by the end of the program demonstrate to both Cal-OSHA and your employees that you are taking the business of safety seriously.
Potential Daily Duties Required
- New employee. Whenever you hire a new employee there are two things that must be done. Number one conduct an overall safety training. Number two pass out the companies codes of safe practice and have the employee sign that he or she received it.
- Accident. In the event of an accident make sure to fill out your analysis of injury or illness form. This form is only used when time is lost from work. Don’t forget to fill out the Cal-OSHA 300 LOG as well.
- Safety Violation Form. This is a form that would be filled out in the event that an employee violates a company established safety rule.
- Conduct a special safety training when either new equipment is brought into the workplace or new job functions ae added to the operation.
- Employee Report of Unsafe Condition or Practice. Every employer needs to have a form that an employee can use and then turn in immediately in the event of any unsafe work practice or condition that the employee may see.
- The conducting of safety training topics, if you are a construction company your should be training your employees every ten days. Most other companies can train once a month. If you work strictly in an office setting then every three months is fine.
- Random Hazard Inspections must be conducted periodically. The question becomes what is periodically? Some enforcement officers will say once a year is fine, others will say that twice a year is good, and still others will say that monthly is ideal. So the answer is going to depend on two things, number one what does your illness and injury prevention program say, and can you document in writing that you are acting in accordance with what your safety program does say.
In conclusion please remember that it is not enough that your written safety program addresses all of the above issues. If you are not doing what your safety program says or you cannot document what you are doing in writing then you will have issues when Cal-OSHA comes to pay you a visit.
Because of what is going on with enforcement in the field CES Today has implemented what we call the Platinum Services. With this service, we come twice a year and make sure that our members are doing everything that they are required to do. The first thing we do is an onsite inspection of the workplace. We take notes on all hazards that are found. From the master list of the hazards that we find some that the employer will choose that he or she can fix immediately. We will write up all of the reports that are necessary and then put the reports in the compliance kit that we provide with the Platinum Service.
I then check to make sure they are doing their safety training properly, and if they are not we bring that to their attention and help them to get them done. After the meeting, the client will receive an email recapping the visit and what we found along with a reminder to encourage them to make sure that everything does get done.