Do You Have An IIPP?

Authored by Steve Holden. Published in the Sacramento Business Journal December 2014. Too often employers say; “What’s an IIPP?” Risk and safety managers in California know, but sadly too many smaller businesses without a dedicated risk or safety manager do not. IIPP stands for Illness and Injury Prevention Program, and every employer is required to have one. Moreover, the program is required to be written and effective. An IIPP is a basic workplace safety program. For small employers in very low hazard industries, the IIPP may constitute the entire safety program. For most employers, however, the IIPP is only the starting point of a more comprehensive program. The IIPP must include eight key elements. Responsibility. The program must designate an individual with the overall responsibility for ensuring that the IIPP is effective. Compliance. The program must identify the processes and practices in place for ensuring compliance with health and safety rules. This is where the company’s process for discipline should be included. Communication. The program must set for a plan for regular and effective communication with employees and provide employees with clear instructions on where and how to raise concerns about health and safety issues. Hazard Assessment. The program must outline a process and schedule for regular inspections and other forms of hazard assessment. Accident/Exposure Investigation. The program must include details on how the company will conduct and document investigations into accidents and exposure incidents. Hazard Correction. The program must set forth the responsibility and process for correcting hazards that are identified via regular assessments or employee complaints. Training. The program must include an outline of how employees will be trained on good health and safety practices. Recordkeeping. The program must identify the relevant records that will be kept under the program, provide instructions on completing such records and identify procedures for maintaining the records. Employers with fewer than 20 employees who are not in an industry designated as high hazard may in certain cases be permitted to have an IIPP that is less comprehensive. Given the value of a comprehensive IIPP, however, taking advantage of the small employer exception is generally not recommended. Employers should remember that the law requires an effective IIPP. While that standard is somewhat subjective, there are several important aspects of IIPP development and implementation that will increase the likelihood of meeting the standard. Employees from top to bottom must be engaged, energized and responsible. Additionally, the unique and specific hazards in a workplace must be identified. Boilerplate hazard statements will not suffice. Finally, the IIPP must be regularly reviewed and updated. An effective IIPP can be extremely beneficial. First, it is likely to significantly improve the safety and health of the workforce. Second, employee morale is generally higher when employees feel safe and feel that their employer cares about their safety. Third, happy employees are productive employees. Fourth, reduced workplace injuries and illness can significantly reduce the cost of doing business. The cost reduction comes in several different forms, including reduced workers’ compensation premiums, reduced lost employee time and reduced exposure to litigation. Even if these benefits did not exist, employers should be motivated to develop an effective IIPP. The first step in any Cal-OSHA investigation is a review of the employer’s IIPP. The absence of a written program or a poorly constructed program will result in a citation every time. Employers have multiple options for creating an IIPP. Insurance brokers committed to a high level of customer service often have employees who assist customers at little or no cost. While this little or no cost option may be attractive, not all brokers are equal. Some provide the service via genuine safety experts, others do not. Employers can also create an IIPP through self-help. The California Department of Industrial Relations provides model IIPP programs, instructions for their development and sample forms that can be incorporated. While the model programs and instructions provided are good, employers should be cautioned that the success of any self-help option depends upon the commitment and competency of the person charged with developing the program. For employers less concerned about finding a low-cost option, professional safety consultants are also available.