The Final Chapter: Addressing Training, Access and Recordkeeping in the IIPP

Author, Jack Marrs, Associate Account Executive, Rancho Mesa Insurance Services, Inc.

In this third installment of exploring an Injury and Illness Prevention Program (IIPP), we will be taking a closer look at: Providing employee training and instruction, procedures to allow employee access to the program, and recordkeeping and documentation.

Providing Employee Training and Instruction

Providing clear and effective training for both employees and supervisors is essential for the success of an IIPP. All employees are required to be fully aware of the workplace hazards they may face. Comprehensive and well-conducted trainings can help reduce the likelihood of work-related injuries and illnesses. An article from The State Fund suggests “If you are unable to conduct your own required trainings, you should reach out to an outside consultant, Cal/OSHA consultation, vendors, your insurance carrier, and/or broker for assistance.” The more knowledgeable and prepared employees are, the safer the work environment becomes.

Take a look at the training resources that are available to your organization. Rancho Mesa clients can access the online safety training courses in the SafetyOne™ platform.

Procedures to Access the IIPP

All employees are required to have access to the written IIPP. This will ensure that all employees are fully aware of the safety protocols and hazard prevention strategies used to minimize workplace accidents and illnesses and thus, maintain a safe workplace.

According to Cal/OSHA, employers can meet this requirement by:

1. Unobstructed access through a company server or website, which allows employees to review, print, or email a copy of the IIPP

2. When requested, provide a printed copy of the IIPP (unless the employee agrees to receive an electronic copy)

The IIPP can be made accessible to users of the SafetyOne mobile app. It allows organizations to upload digital files into a file cabinet that is available only to their users.  For employees who aren’t SafetyOne app users, they could scan a QR code or complete a webform to request the IIPP from their administrator.  However your organization decides to distribute the IIPP, it should be easy for employees to access or request.  

Recordkeeping and Documentation

Recordkeeping and proper documentation are crucial components of the IIPP. By maintaining accurate records, employers can learn from past incidents and identify injury and illness trends. This knowledge allows for necessary corrections and improvements in future operations, which will improve overall workplace safety. There are 5 steps required by the OSHA for a compliant recordkeeping system:

1. Each employer (unless exempt by size or industry) must record each fatality, injury, or illness that is work-related, is a new case, or meets one or more of the general recording criteria specified in Title 8, Section 14300.

2. Record each injury or illness on the Cal/OSHA Log of Occupational Work Related Injuries and Illnesses (Form 300) according to its instructions.

3. Prepare an Injury and Illness Incident Report (Form 301), or equivalent.

4. Annually review and certify the Cal/OSHA Form 300 and post the Summary of Work-Related Injuries and Illnesses (Form 300A) no later than February 1 and keep it posted where employees can see it until April 30.

5. Maintain the last five years of these records in your files.

A simple way to collect the incident information required for the OSHA logs (Form 300, 300A and 301) can be obtained by utilizing SafetyOne’s mobile forms. Either through the mobile app or via a QR Code or web link, employees can complete accident investigation forms and witness statements digitally.  Then, the person responsible for documenting and maintaining the OSHA logs, can review the reports that came in through the mobile app and document the OSHA logs in the RM365 HRAdvantage Portal.

Rancho Mesa will host several webinars in the coming months to assist clients with understanding the best practices for completing their OSHA logs using SafetyOne™ and the RM365 HRAdvantage Portal.

Cal/OSHA has a Guide to Developing Your Workplace Injury and Illness Prevention Program that is helpful for organizations that need some assistance with getting started.

Rancho Mesa also has a 6-page Sample Injury and Illness Prevention Overview for California Employers available through our RM365 HRAdvantage Portal.

Following these steps is a proactive approach to building a safer working environment for all employees. The bottom line, it’s all about mitigating accidents before they happen and building a safe work environment.

Please contact me with any questions regarding the IIPP at (619)-486-6569 or via email at jmarrs@ranchomesa.com.

Identifying Proper Procedures for the Injury and Illness Prevention Program

Author, Jack Marrs, Associate Account Executive, Rancho Mesa Insurance Services, Inc.

In this second installment of exploring an Injury and Illness Prevention Program (IIPP) we will be taking a closer look at the procedures for identifying and evaluating workplace hazards, investigating occupational injury or illnesses, and correcting unsafe or unhealthy conditions, work practices and procedures.

Identifying and Evaluating Workplace Hazards

Employers need to have proper measures in place to identify potential health and safety risks like unsafe conditions and practices within the workplace. These measures involve conducting regular inspections to identify any areas of the workplace that may be hazardous. Also, conducting interviews with employees is a great way to identify any potential workplace hazards. During this process it is important to document any identified hazards and create a plan of action to fix them.

According to California’s State Fund “Inspections should be conducted by personnel who, through experience or training, are able to identify actual and potential hazards and understand safe work practices. They should be knowledgeable in the Cal/OSHA safety orders that apply to your workplace to better help you identify potential hazards.”

Investigating Occupational Injuries or Illnesses

Referring now to the investigation that should take place after an accident or near miss has occurred. The investigation should be done by a trained employee who is able to identify the cause of the accident and understands what solutions need to be put in place to prevent a similar incident from happening in the future. When doing an investigation, it is crucial to fill out an investigation report containing the details about what happened. This information is used to not only identify root causes but much of the data that is collected will need to be documented on the OSHA logs.  CAL/OSHA lists five important steps for proper recordkeeping:

1. Each employer (unless exempt by size or industry) must record each fatality, injury, or illness that is work-related, is a new case, or meets one or more of the general recording criteria specified by OSHA.

2. Record each injury or illness on the OSHA Form 300, according to its instructions.

3. Prepare an Injury and Illness Incident Report known as Form 301, or its equivalent.

4. Annually review and certify the OSHA Form 300 and post the Summary of Work-Related Injuries and Illnesses known as the Form 300A no later than February 1 and keep it posted where employees can see it until April 30.

5. Maintain the last five years of these records in your files.

Lastly, building an inventory of investigation reports can lead to a stronger ability to identify developing trends and root causes that could lead to additional incidents, if not corrected.

Correcting Unsafe or Unhealthy Conditions, Work Practices and Procedures

Once your safety team becomes aware of a hazard, it is imperative to take immediate action. If the hazard is not easily fixable, employees should vacate the work area until a solution is implemented. Once the solution is in place, only trained staff members should enter the hazardous area to address the issue. This approach ensures effective hazard management while minimizing the risks associated with its correction.

By implementing an effective Injury and Illness Prevention Program, workplaces will begin to fulfill their regulatory obligation of maintaining a safe workplace, but also create a culture of safety and accountability.

Our next installment will cover the last 3 critical components of the IIPP: providing employee training and instruction, procedures to allow employee access to the program, and recordkeeping and documentation.

Please contact me with any questions about managing your risk at (619) 486-6569 or via email at jmarrs@ranchomesa.com.

Breaking Down the First Few Components of the IIPP

Author, Jack Marrs, Associate Account Executive, Rancho Mesa Insurance Services, Inc.

Building upon Sam Brown’s article “Guidance for Developing an Effective Injury and Illness Prevention Program” (IIPP), I would like to delve further into some of the key components of an IIPP. In this first installment, I will explore assigning the right person to create the IIPP, compliance with safety regulations, and effective communication.

Person Responsible for Creating the IIPP

This person must understand the ins and outs of the organization. They must be familiar with the workplace hazards and understand what safety measures need to be put in place. They are also in charge of updating the program and improving it as the organization changes and grows. This individual must also be formally mentioned in the IIPP, clarifying the assigned responsibility for overseeing this aspect of safety by including their name in the document.

Compliance with Safety Regulations

The IIPP outlines the system for ensuring employees comply with safe and healthy work practices.

This entails effectively training and informing employees about their responsibilities and expectations. Employees need to understand the system that is put in place as well as the safety procedures and the requirements of the IIPP. Providing positive recognition and rewarding employees who are following the IIPP guidelines is crucial, while disciplinary measures should be put in place for those who fail to comply. This is how you begin to create a culture of safety and accountability. Also, to ensure your IIPP stays up to date, it is considered best practices to regularly review and update all rules and procedures as needed.

Effective Communication

The IIPP must include a system for communicating with employees in a form readily understandable by all affected.

It remains critical to effectively communicate with your employees on matters that relate to the IIPP. Clear communications can be learned through trainings. And, it is important that employees use language that can be easily interpreted. According to the State Fund, “your communication system should include provisions for encouraging employees to report potential hazards in the work environment without fear of reprisal. One way to do this is to have a notification system where employees report hazards anonymously.” This helps eliminate fear in the employee and allows them to feel comfortable holding their co-workers to the IIPP standard. Effective communication can help prevent injuries from happening in the first place.

By embracing these components, organizations can create a culture of safety and accountability.

The next IIPP article will cover the three critical components of the IIPP: identifying work place hazards, investigating occupational injury or illness, and work practices/procedures.

If you have any inquiries, feel free to reach out to me at (619) 486-6569 or via email at jmarrs@ranchomesa.com.

4 Essential Tools For Managing Your Company's Risk

Author, Alyssa Burley, Client Services Coordinator, Rancho Mesa Insurance Services, Inc.

Risk Management is the identification, analysis, assessment, control, and avoidance, minimization, or elimination of unacceptable risks. Companies manage their risk through what is known as an Injury and Illness Prevention Program (IIPP). As a business owner, supervisor or manager, there are tools available to assist in risk management endeavors.

“Injury and illness prevention programs are systems that can substantially reduce the number and severity of workplace injuries and illnesses while reducing costs to employers,” according to OSHA.

Below are four tools your company can use to proactively manage the IIPP.

Training

Access to a robust bilingual database of both online and offline trainings is essential to ensuring employees are up to date on required and supplemental training. Weekly training shorts (e.g., tailgate topics, safety shorts) that are industry specific and relevant keeps employees focused on safety and reinforces a safety culture within the company.

“Training in the safe way for workers to do their jobs well is an investment that will pay back over and over again in fewer injuries and illnesses, better morale, lower insurance premiums and more,” according to OSHA’s training requirements document.

Tracking of Employee Training

Maintaining employee training documentation is vital for ensuring employees are trained on required topics and in regular intervals. Having an electronic tracking system can streamline the process and allow management to generate reports and search records from any device with internet access.

According to OSHA’s documentation, “it is a good idea to keep a record of all safety and health training. Documentation can also supply an answer to one of the first questions an incident investigator will ask: ‘Did the employee receive adequate training to do the job?’”

To learn more about OSHA training requirements, review Training Requirements in OSHA Standards.

Incident Tracking and OSHA Reporting

Documenting near-misses, injuries, and accidents can keep your company OSHA compliant while helping to prevent incidents in the future. Making sure supervisors complete a thorough investigation and collect witness statements at the time of the incident can also ensure hazards are addressed immediately. Electronic documentation of a near-miss or incident creates a standardization of data that is collected, allows for trend reporting, and electronic submission of OSHA 300A Summary data.

Written Job Hazard Analysis

A job hazard analysis (JHA) identifies the dangers of specific tasks in order to reduce the risk of injury to workers. JHAs are important for managing risk because they help to identify hazards which can be reduced or eliminated before an employee is hurt. Once a JHA is established, management should observe and document their findings and any remedies that are made.

Risk Management starts with a written IIPP, but it is up to management to implement and utilize the available tools to make it effective. Contact Rancho Mesa’s Client Services Department at (619) 438-6869 to learn more about the Risk Management Center platform.

Developing an Effective Injury and Illness Prevention Program (IIPP)

Author, Daniel Frazee, Executive Vice President, Rancho Mesa Insurance Services, Inc.

If you have operated a business in the state of California for any period of time, you have very likely heard about or run across the acronym IIPP. Wherever you stand with your knowledge within the world of safety, injury, and illness, it is important for every organization to understand the mandatory parts of an IIPP. What is often overlooked is how developing an effective safety program can create positive change and truly impact your bottom line.

What is an IIPP?

An Injury and Illness Prevention Program (IIPP) is a required written workplace safety document that must be maintained by California employers (Title 8 of the CA code of regulations, section 3203). These regulations require eight (8) specific elements that are summarized below. In many cases, this process requires direct questions about how the company currently views and manages safety. Answering these questions will begin to highlight the positive aspects of what already is currently in place and shed light on areas that need improvement.

Responsibility

Clarifying the name, title and contact information for the person(s) with overall responsibility for the IIPP is a critical first step to this process. Making the IIPP available and accessible at all business locations becomes the first task of the “responsible person.”

Compliance

What is the content of the company’s safety meetings? Who runs those meetings? How do you discipline employees if they do not follow safety guidelines? How might the company recognize or reward their employees for safe practices or behavior?

Communication

Safety meetings are held on what type of schedule within your organization? How can employees anonymously notify management of safety and health concerns without fear of reprisal? Is there a safety committee in place that provides communication to all employees? If not, who would be considered as important members of that committee?

Hazard Assessment

Who within the company is responsible for periodic inspections to identify and evaluate workplace hazards? Provide detail on this schedule along with accompanying documentation that these visits occurred. Continuously communicating with employees for feedback and constantly reviewing hazards on a jobsite or within the workplace are crucial. Lastly, does the company use a standard or tailored JHA (Job Hazard Analysis) checklist to accomplish this? Re-visiting these checklists regularly as exposures change is critical to reducing claim frequency.

Accident/Exposure Investigation

Post-accident, who is the name of the person within the organization responsible for conducting those investigations? What type of form or checklist are you using to establish “root causes” of the accident or injury? And, back to the compliance section, what type of discipline could be handed down in the event of employee error that causes an accident or injury?

Hazard Correction

After the company has identified the hazard and determined exactly how and why an incident occurred, the IIPP must provide detail on how the company will correct the problem from happening again. One solid first step can include a review of Personal Protective Equipment (PPE) use. That is, did the equipment being used cause the accident or injury and, if yes, why? Answering the\is question may show that the piece of equipment was not appropriate for the task, or the item was defective or too old, which caused failure.

Training and Instruction

Ongoing and job specific training and instruction are really the lifeblood of any truly effective IIPP. Presenting the information in a clear, concise format that is easily understood is often the most difficult task in this process. Yet, it remains perhaps the most important as it is vital that employees are continually educated and RETAIN their instruction. Peeling back this process with managers, foreman, superintendents, etc. and learning specifically how the training is being disseminated, allows for a true baseline to be established.

Recordkeeping

Document, document, document! While establishing a written version of the IIPP might be the first step, and revising/editing on an annual basis is recommended, having the proper documentation that accompanies each section is just as important. This provides the responsible person(s) an important tool to continually compare the company’s actions, trainings, assessments and prevention techniques with the available documentation.

Can An Effective IIPP Impact my Bottom Line?

Building an effective IIPP means that the document represents a part of the company’s culture. For it to be meaningful and have a real impact on reducing workplace injuries and illnesses, it must reflect what your company is actually doing on a day to day basis. As the company’s ownership ties this into the overall business, building the IIPP from the ground up into a living, breathing document has measurable impact on controllable costs like workers’ compensation. Reducing frequency of injury can help lower the experience modification, improve the loss ratio, and establish a solid risk profile in the insurance marketplace. Having the supporting documentation along with specific examples of forms, checklists and assessments can arm an insurance broker with the tools they need in the marketplace. More specifically, this information provides a broker important leverage points when negotiating the most competitive terms possible for the employer with the insurance carrier’s underwriter. Those points can lead directly to premium savings, which leads to healthier margins and stronger profitability. Build the IIPP because it is a CA state requirement and it is the right thing to do. But, believe that building a first class safety program will absolutely lower your long-term insurance costs.

For a sample IIPP, visit the Risk Management Center or contact Alyssa Burley at (619) 438-6869.