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IIPP Series Part I: It’s Not a Porta Potty Request!

- November 19, 2018 by Rhyanne Skinner, CSP (View all posts by Rhyanne)

What is an “IIPP?’’ First and foremost, it does NOT involve the little blue room on your jobsite! It’s a written safety program required by the State of California, Title 8 Safety Orders and enforced by Cal/OSHA. IIPP stands for Injury and Illness Prevention Program.  If you’re not located in California, please don’t stop reading! Having an IIPP is a good idea for everyone.  Other state run OSHA programs have similar expectations and Federal OSHA may not require an IIPP but I’m sure that any compliance officer would appreciate your effort in creating one. In this blog series, I’ll cover what it is and why it’s important to have one.

Let’s start with the financial aspects. It’s citeable by Cal/OSHA should you ever have the great (mis)fortune of having an inspection. As a former Enforcement officer, I can tell you a few things about the financial relevance of this as it pertains to citations. The average starting penalty for not having an IIPP is $1,000 but can be as high as $1,500. Lack of an IIPP also affects your penalty reductions, particularly as it relates to serious citations (starting at $18,000!). Without one you loose up to 15% reduction in penalty, for a serious citation that equals $2,700!  Some day in the federal OSHA

Now here’s the clincher, the law says not only do you have to have an IIPP but it must also be “implemented, maintained, and effective.” What this means for those of you who thought “Hmmm… I think we have one of those, it’s in a binder somewhere on my secretary’s desk,” is that isn’t enough!  You need to take that thing down, blow the dust off of it and figure out what you’ve committed yourself to!  Part of the reason lack of an IIPP is consistently the #1 most frequently cited citation in California is because employers frequently don’t meet the measure of the standard; their program is just like a lot of yours, it sits on a shelf or on the floor of a truck and it’s not implemented, maintained, or effective. Another way employers get bit on this one is that Cal/OSHA will focus on individual required elements and cite you under the same clause that that element doesn’t meet muster.

What the citation and workers compensation statistics show is that employers without an IIPP, an – effective IIPP – are far more likely to have accidents. The problem with accidents from an economic stand point is multi-fold: they cost you money, production time, labor time, increase your workers’ comp rates and they’re likely to cause Cal/OSHA to show up and now you’re looking at citations and penalties.  Let’s not forget the potential for legal costs here, also!

Stay tuned for my next blog where I’ll discuss the “emotional” aspects of IIPPs!

 

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