Injury and Illness Prevention Program (IIPP) Requirements Apply to All California Employers

By Chris Malicki, OHST, CHST, COSS

chris-malicki-resized As the owner or manager of an engineering or architectural firm, you may not be aware that you are required to have an Injury and Illness Prevention Program (IIPP).  Every employer, however, is required to have one.  Cal OSHA regulations clearly state:  “every employer shall establish, implement and maintain an effective Injury and Illness Prevention Program”.

Granted, there are a few exceptions to the regulations, but they mostly pertain to the content of the program or how its implementation is documented.  There is no sweeping exemption for design professionals or workers in similar administrative roles or environments.  Even public agencies such as city, county, and utility providers are not exempt from the regulations (although in the past, they were exempt from the monetary penalties).

The bottom line is, Cal OSHA expects all employers to inspect all workplaces prior to the commencement of work, and establish and implement written policies and procedures to prevent worker injury.

That said, if you are, for example, a landscape design company, who occasionally has workers in the field surveying, conducting site walks, directing the placement of trees, etc., your workers are subject to the IIPP requirements.

An IIPP in its simplest form, is the “safety umbrella” that hovers over your company.  The basic required sections include:

  • Responsibility
  • Compliance
  • Communication
  • Hazard Assessment
  • Accident/Exposure Investigation
  • Hazard Correction
  • Training and Instruction
  • Recordkeeping

You may note that in the items above, there is no mention of fall protection or electrical safety, the two leading killers of construction workers.  That is because, those hazard specific topics are addressed in separate, but related, written safety programs.

How do you solve this problem if you are not compliant?

  • Develop and implement your own program internally by utilizing the tools at: https://www.dir.ca.gov/title8/3203.html.
  • Contact your commercial insurance professional for advice.
  • Roll the dice and ignore the requirement (not recommended).