New Rules Require Employers to Provide IIPP upon Request

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

Under the new rule, which is expected to take effect in April, employers will be 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. This was excluded at the behest of employers who raised concerns that allowing such requests would give attorneys a green light to file requests in hopes of discovering errors or “improprieties.”

Despite the current absence of a rule, 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.”

Employer groups had lobbied for a 10-day window for providing the IIPP, while labor groups wanted a faster timeline of just 48 hours. The board compromised with the five-day rule.

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

Current IIPP standard

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.

Cal/OSHA has a guide for creating an 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.

Elements of 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.
  • 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.
  • A system for reliable, prompt communication between supervisors and line employees on safety.
  • Conducting regular inspections to identify hazards.
  • A framework for investigating accidents and illnesses, to discover the cause and to prevent recurrence.
  • Requiring that hazards are corrected promptly when found.
  • A regimen for training employees on the hazards they may encounter at work.
  • Documentation of training and workplace inspections.

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