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Occupational Health & Safety Alert – Injury and Illness Prevention Programs

  • April 1, 2017
  • Robin Hendrickson
  • Property & Casualty
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Source: State of CA Department of Industrial Relations

Over the last 40 years, employers have had the responsibility to provide a safe and healthy work environment for their employees under the Occupational Safety and Health Act of 1970 (OSHA). Today, several states have mandated requirements to enforce the implementation of a workplace safety program.

Cal OSHA: Basic Elements of an Injury and Illness Prevention Program

Title 8 of the California Code of Regulations (T8CCR) Section 3203, requires every employer to develop, implement and maintain a written IIPP.

The 8 required Injury and Illness Prevention Program elements are:

1. Responsibility: Management commitment and assignment of responsibility

2. Compliance: System for ensuring employee compliance with safe work practices

3. Communications: Safety communications system with employees

4. Hazard Assessment: Scheduled inspections/evaluation system

5. Accident/Exposure Investigation: Investigation of accidents, injuries and illnesses

6. Hazard Correction: Procedures for correcting unsafe/unhealthy conditions

7. Training and Instruction: Safety and health training and instruction

8. Recordkeeping: Maintain IIPP documentation and records of injuries/illnesses

To be effective, an IIPP must fully engage all employees, identify specific workplace hazards, correct identified hazards, and provide effective training.

Cal OSHA’s Exceptions to the Written IIPP and Documentation

Employers with less than 10 employees:

Must comply with all 8 required IIPP key elements, with the following exceptions:

Communication: Employers can communicate and instruct employees orally in general safe work practices with specific instructions with respect to hazards unique to the employees’ job assignments.

Recordkeeping: Employers may elect to maintain inspection records only until the hazard is corrected and can comply with the training documentation provision by maintaining a log of instructions provided to the employee with respect to the hazards unique to the employees’ job assignment when first hired or assigned new duties.

Employers with less than 20 employees:

Employers with less than 20 employees who are in industries that are not on a designated list of high-hazard industries established by the department of industrial relations and who have a workers’ compensation experience modification rate of 1.1 or less, and for employers with less than 20 employees who are in industries on a designated list of low-hazard industries established by the department, written documentation of the program may be limited to the following requirements:

  • The identity of the person(s) with authority and responsibility for the program
  • Scheduled periodic inspections to identify unsafe conditions and work practices
  • Employee training and instruction

*High and Low Hazard industries can be found here:

State of CA OSHA Policy & Procedures Manual

Reference, additional resources, sample injury and illness prevention program, sample forms and checklists can be found by visiting:

State of CA Department of Industrial Relations

Content Disclaimer: The information provided herein is for informational, educational and discussion purposes only and shall serve solely as a resource to be used together with your ABD professional insurance advisors in making risk management decisions. While ABD endeavors to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability, or availability with respect to the information contained in this document. The information provided herein does not constitute professional advice, nor does ABD provide professional advice beyond our current or prospective brokerclient relationship. If you have legal, tax or financial planning questions, we advise you to contact a licensed professional. If any actions or decisions are made based solely on the information provided herein without consultation with a licensed professional, you do so at your own risk and ABD shall have no liability resulting from such action or decisions.

Revision 2017

Robin Hendrickson

Robin Hendrickson

As ABD’s Occupational Health & Safety practice leader, Robin leads a team of experienced workers’ compensation claims management, wellness initiative, and loss mitigation and strategy consultants. Robin, and her team, work with employers to reduce occupational risk exposures, implementing best practices to control claim costs, and keeping employees safe, healthy, and productive.
The information provided is of a general nature and an educational resource. It is not intended to provide advice or address the situation of any particular individual or entity. Any recipient shall be responsible for the use to which it puts this document. ABD shall have no liability for the information provided. While care has been taken to produce this document, ABD does not warrant, represent or guarantee the completeness, accuracy, adequacy, or fitness with respect to the information contained in this document. The information provided does not reflect new circumstances, or additional regulatory and legal changes. The issues addressed may have legal, financial, and health implications, and we recommend you speak to your legal, financial, and health advisors before acting on any of the information provided.
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