Property & Casualty

Occupational Health & Safety Alert - Injury and Illness Prevention Programs

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

Robin Hendrickson
The Author
Robin Hendrickson

As Newfront’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.

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