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By: Enriqueta Castro, CSP, SDRMA Risk Control Manager

Just like in sports, special districts rely on a healthy, high-performing team to achieve their goals. An effective injury and illness prevention program is your defensive line—it’s the playbook that protects your employees.

The power of the IIPP starts with identifying and evaluating workplace hazards. This process provides a road map to determine potential hazards, identify Cal/OSHA regulations, and develop a game plan on how to protect your employees.  Let’s take a look at all of the elements of the IIPP. Please note, the information provided is general in nature, we recommend a thorough review of the CCR 3203 when developing or revising your IIPP.

Hazard Assessment

The hazard assessment is the heart of an effective IIPP. Gathering this information sets you up for success. This process is critical when first developing your IIPP.  It’s also required:

• New substances or processes that present potential new hazards are introduced into the workplace.
• Previously unidentified hazards were recognized.
• Occupational injuries and illnesses occur.
• Workplace conditions warrant an inspection.

To continue to identify unsafe conditions, periodic inspections are also required to evaluate physical hazards, use of hazardous materials, and safe work practices. 

Responsibility

Employers typically agree that everyone has a responsibility to be safe; but to be successful responsibilities and accountability go together. The IIPP Administrator must be given the authority to oversee and manage the IIPP; however, the true success happens when managers and supervisors understand how important their roles are and how their leadership is critical to an effective program.

Compliance

Here’s where all your hazard assessment work comes into play.  Cal/OSHA requires employers to have a system to ensure employees comply with safe and healthy work practices.  Through your hazard assessment you have the information needed to determine other Cal/OSHA requirements, develop written programs, develop policies and procedures, and establish responsibilities and accountability.

Communication

Now that you’ve established the required policies and procedures it’s time to think about how you communicate your district’s commitment to safety and your expectations for employees. This is the time to think about the critical role of managers and supervisors and how they influence employees.

The regulation provides specific requirements to include in your program.  You must communicate safety in a readily understandable manner. You must encourage employees to inform you of identified hazards without fear of reprisal. Other recommended procedures include safety meetings, training programs, posting, written communications, anonymous hazard reporting options, and safety committees.

Hazard Correction

Your IIPP must include your commitment to correct unsafe or unhealthy conditions, work practices and work procedures in a timely manner based on the severity of the hazard.  This requirement falls hand-in-hand with the hazard assessment requirements.  An unsafe condition can be identified through a variety of avenues, such as reported by an employee, through a hazard inspection, through an accident investigation, to name a few. The critical component is that the district has a system in place to document the hazard correction process.

Accident Investigation

Employers are required to include their procedures on investigating occupational injury and illnesses.  This section can be used to educate employees on what to do in the event they are injured as well as the investigative process.  The goal of the investigation is to identify contributing factors and develop prevention measures to reduce reoccurrence.

Training

The hazard assessment is the greatest tool to help identify your employee’s job-specific hazards. This will help identify the training topics required. Supervisors must also be trained on the safety hazards to which employees under their immediate direction and control are exposed. In addition, training must be provided:

• When the IIPP is first established.
• When new employees are hired.
• When employees are reassigned to a new area or task with no prior training.
• Whenever new substances, operations, or equipment are introduced.

Recordkeeping

Documenting and recordkeeping is essential for an effective IIPP. Cal/OSHA requires documentation on training, inspections, accident investigations, and program revisions.

Congratulations!  Taking a fresh look at your IIPP is no easy feat; it takes strategy, focus, and commitment. It reflects a strong commitment to employee safety while helping reduce risk, injury-related costs, and downtime.

This article originally appeared in California Special Districts magazine,