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Why Employers Need Injury and Illness Prevention Programs
Safety and health professionals call them by different names – some say Site Safety and Health Program, while others say Injury and Illness Prevention Program (IIPP). Regardless of the name, the goal is the same: to have a written document that spells out the proper safety procedures for a given worksite or company. For years, safety and health advocates have argued that one of the most important steps to maintain a safe worksite is having a written safety program. While federal OSHA doesn’t require employers to have an IIPP, many state-run OSHA programs do.
“One of the primary reasons to have an IIPP is so both employers and workers can understand the safety expectations on the job and ensure these expectations are being met,” says LHSFNA Management Co-Chairman Noel C. Borck. “This is why worker access to the written program is so critical. A written program doesn’t do much good if it sits on a shelf without being understood and implemented by everyone on site.”
LHSFNA Comments on Stronger IIPP Requirements
The LHSFNA formally submitted comments to Cal/OSHA in support of a proposed standard to require all employers in California to make IIPP documents available to workers within five days upon request. While IIPPs have been required in California since 1991, the existing law only required employers to “establish, implement and maintain” a written program, without specifying how that information is distributed to workers.
The Cal/OSHA standards board approved the proposed standard, which is set to go into effect in 2021. The new rules mandate access for employees, their union representatives and their attorneys. Employers in California will also have to communicate this right to access and the procedure to access the IIPP to all employees. The LHSFNA applauds this step forward for workers’ rights in California, especially in industries such as construction, where safety procedures have a direct impact on safety and health. Access to the procedures and policies in an IIPP helps set the expectation on site that safety is a collaborative and ongoing effort between workers and management.
What’s in an IIPP?
While many states don’t mandate IIPPs, the LHSFNA recommends all employers implement these programs and the Fund can help LIUNA signatory employers create them. All policies stated in the IIPP must be implemented and documents should be maintained to show how those policies are followed.
The basic elements of an IIPP are:
- Responsibility – management’s commitment to a safe workplace and who is responsible for safety on the jobsite
- Compliance – how the employer will comply with required OSHA rules and regulations
- Communication – how information will be relayed to employees, such as the results of a worksite inspection or hazards that have been corrected
- Hazard Assessment – the approach the employer will take to identify hazards on the jobsite (e.g., regular walkthroughs, notification from employees, safety committees)
- Accident/Exposure Investigation – how incidents, including both injuries and close calls, will be investigated.
- Hazard Correction – who is responsible for correcting hazards that have been identified, how hazard correction is prioritized and what steps will be taken to correct hazards
- Training and Instruction – how workers will be trained (e.g., regular toolbox talks, job safety analyses before each task) and what training will be required for workers and for supervisors
- Recordkeeping – what records will be kept, how long they will be kept and who has access to them
Note: The Fund recommends evaluating and updating your IIPP at least once a year. When additional safety procedures are added, those procedures should be communicated to workers and documented.
The Fund’s Online Site Safety & Health Program can help LIUNA signatory contractors create a program that’s specific to the hazards faced on their sites. The staff of the LHSFNA’s OSH Division are also available to review and create these programs for LIUNA signatory contractors. For assistance, contact the OSH Division at 202-628-5465.
When employers view written safety and health programs as an action plan to protect workers – and not as another paperwork requirement – they can become a blueprint for safety on the jobsite.