Is Your IIPP “Effective”?
The Injury and Illness Prevention Program (IIPP) requirement is Cal/OSHA’s most cited regulation since its adoption on July 1, 1991. The regulation states that “every employer shall establish, implement and maintain an effective Injury and Illness Prevention Program.” However, “effective” is not defined and it is this subsection of the regulation that is cited most often.
The California Industrial Hygiene Council (CIHC), of which I’m a board member, has recently petitioned the Standards Board to clarify this point so that employers have a better understanding of what constitutes an “effective” IIPP. The basis for CIHC’s proposed changes results from language of various citations itself, such as an employer was cited for an ineffective accident investigation, or failure to implement an effective IIPP, etc. Based on these citations, CIHC has proposed four changes; only one will be discussed below.
The first change proposed by CIHC is, of course, to define “effective” by amending subsection (a)(1). Effective is defined as producing a decided, decisive or desired effect. CIHC recommends requiring that the employer appoint a competent person to be the IIPP administrator. “Competent person” is used in numerous other Cal/OSHA regulations. In this case, CIHC recommends defining the individual as someone with the skills, knowledge and experience to manage health and safety for the employer, recognize hazards and risks in the activities and assure the availability of the corrective action to manage the hazards and risks. I believe this is an excellent idea and long overdue and should help produce the desired effect of a safe workplace, and of course make the IIPP effective by identifying a competent person to manage the program. Establishing a standard for who should administer the IIPP for an employer is something that should not be taken lightly and identifying someone who has the experience, training and background to identify and control unsafe and unhealthful conditions and work practices makes sense. After all, that was the overarching purpose of the IIPP. We’ll keep you posted how this petition makes its way through the standards process.