New Rules Require Employers to Provide IIPP upon Request

New Cal/OSHA regulations require employers to provide access to their injury and illness prevention programs upon request.

Under the new rule, effective July 1st, employers are required to provide a copy of their IIPP within five days upon an employee’s or an employee’s representative’s (a lawyer’s) request. The employer can provide it in electronic or printed form.

That said, the new rule excludes requests for records of the steps the employer has taken to implement and maintain the IIPP.

Despite the previous absence of this requirement, many employers already provide employees access to the IIPP through the availability of printed and/or electronic copies.

“For employers that do not currently provide such access, they will need to ensure that employees can access a free copy of the IIPP directly or through a designated representative upon request,” Cal/OSHA’s board staff wrote in the “Final Statement of Reasons” for the rulemaking package. “As such, providing access need not be a complex procedure requiring costly development.”

The rule was needed because the current IIPP standard does not explicitly state that employees should have access to their company’s IIPP.

IIPP Required Elements

Every employer in California is required to have an effective IIPP. This basic safety program for your workplace addresses the hazards your employees face at work each day, and it must be in writing. Required elements of the program are:

• Responsibility
• Compliance
• Communication
• Hazard Assessment
• Accident/Exposure Investigation
• Hazard Correction
• Training and Instruction
• Employee Access to the IIPP
• Recordkeeping

Armstrong & Associates Insurance Services has an updated IIPP template that contains the New Employee Access to IIPP procedure. Log into your Client Portal to download the template. Go to Armstrong 24/7 – CSR24 Access Portal www.armstrongprofessional.com to access the 2020 IIPP template in our “Forms and Flyers” section.

Cal/OSHA has a guide for creating an IIPP.
https://www.dir.ca.gov/dosh/etools/09-031/how.htm

Contact your agent or Armstrong Safety Consultant safety@armstrongprofessional.com for more information related to developing your IIPP.

But, you should not just create an IIPP because you have to. Going through the process of creating an IIPP ― as well as updating it periodically ― can also help your organization by:

• Preventing workplace injuries.
• Reducing your workers’ compensation insurance rates.
• Helping you to find ways to boost your workflow.
• Improving the bottom line of your business.

How to develop an effective IIPP

• The plan is in writing and reflects what you actually do.
• A point-person, who is in charge of managing the IIPP process. (Responsibility)
• Input from department heads as well as rank and file employees when updating or creating your IIPP.
• Requiring that everyone follows the rules of the program. (Compliance)
• A system for reliable, prompt communication between supervisors and line employees on safety. (Communication)
• Conducting regular inspections to identify hazards. (Hazard Assessment)
• A framework for investigating accidents and illnesses, to discover the cause and to prevent recurrence. (Accident Investigation)
• Requiring that hazards are corrected promptly when found. (Hazard Correction)
• A regimen for training employees on the hazards they may encounter at work. (Training)
• Providing employees access to the IIPP when requested. (Employee Access to IIPP)
• Documentation of training and workplace inspections. (Recordkeeping)