As 2016 draws to a close, employers are advised to check two key elements of their safety programs to ensure they are current and consistent with applicable regulations as we begin a new year.
INJURY AND ILLNESS PREVENTION PROGRAM (IIPP)
For over twenty years, Cal/OSHA has required all employers to establish, implement and maintain a written Injury and Illness Prevention Program (IIPP) that is specific to their operations. For the construction industry, the applicable regulation is California Code of Regulations, Title 8, Section 1509.
This section requires the program to be consistent with General Industry Safety Orders at Title 8, Section 3203. Section 1509 further requires:
- Every employer to adopt a Code of Safe Practices which relates to the employer’s operations
- The Code to be posted at a conspicuous location at each job site office or be provided to each supervisory employee who shall have it readily available
- Periodic meetings of supervisory employees shall be held under the direction of management for the discussion of safety problems and accidents that may have occurred
- Supervisory employees shall conduct “toolbox” or “tailgate” safety meetings with their crews at least every 10 working days to emphasize safety.
The following eight elements should be addressed in the IIPP:
- Responsibility
- Compliance
- Communication
- Hazard assessment
- Accident/exposure investigation
- Hazard correction
- Training and instruction
- Recordkeeping
As in other program areas, Cal/OSHA has prepared numerous tools to assist employers in complying with regulatory requirements. Following is a link to Section 1509: https://www.dir.ca.gov/title8/1509.html
This section contains the following useful tools:
- Pocket Guide for the Construction Industry
- Prevention Model for High Hazard Employers
- Workplace postings
- Tailgate/Toolbox Topics: Setting up a Tailgate/Toolbox Safety Meeting
Members interested in checking their IIPPs for consistency with Cal/OSHA regulations can access the above link and click on Model Injury and Illness Prevention Program for High Hazard Employers. This model program was prepared for a wide spectrum of employers and may not match the exact needs of your workplace. It does provide the essential framework required for an IIPP.
This model program requires the IIPP administrator to carefully review the requirements of each of the eight subject areas, fill in the appropriate blank spaces and check those items applicable to your business. Sample forms for hazard assessment and correction, accident/exposure investigation, and worker training and instruction are provided.
HEAT ILLNESS PREVENTION PROGRAM(HIP)
In 2005, California became the first state to adopt an emergency regulation to address the hazards of working in hot, outdoor environments. California Code of Regulations, Title 8, Section 3395 applies to all outdoor places of employment with special high heat procedures applying to the construction industry, as well as agriculture, landscaping, oil and gas extraction and selected transportation activities delivering agricultural products, and construction materials.
The critical elements of an effective Heat Illness Prevention Program are:
- Procedures for providing sufficient water
- Procedures for providing access to shade
- High-heat procedures
- Emergency response procedures
- Acclimatization methods and procedures
As the regulation was amended effective May 2015, employers may want to ensure their program is consistent with those changes. Following is a link to an electronic tool prepared by Cal/OSHA: www.dir.ca.gov/dosh/etools/08-006/index.htm
This tool contains the current version of Title 8, Section 3395 as well as Employer Sample Procedures for Heat Illness Prevention.
CAL/OSHA ENFORCEMENT PROCEDURES
It is important to remember that should you be subjected to a Cal/OSHA enforcement inspection, the compliance officer will undoubtedly give you a “Document Request” that requests, among other documents, the IIPP, Safety Inspection Records, Employee Training Records, Safety Committee Meeting Minutes, and the Heat Illness Prevention program.
Should you be presented with this request, please be sure to provide the requested documents by the “postmark date” noted on the top, right hand section of the request. If the copies are not provided by that date, Cal/OSHA will interpret non-production as an admission that the documents do not exist, and possible citations and penalties could result.