In many states including California, employers have been required to develop and implement an effective IIPP for nearly 30 years. Unfortunately, the IIPP is one of the most misunderstood components of an employer’s overall Safety and Health Program.
What is an IIPP?
The IIPP is the basic safety prevention framework that exists within the organization. It is not meant to be the end all, be all solution and address every possible workplace hazard. Unfortunately, many employers overlook the basic required elements which include:
- Hazard Assessment
- Hazard Correction
- Accident Investigation
- Record Keeping
Think of the IIPP as the basic injury prevention umbrella that exists within the organization.
Like an umbrella, it is not meant to be taken out into a hurricane, but meant to just keep the hazard raindrops from reaching employees. It is just one of many elements of the organization’s overall Safety and Health Program. Other elements of the Program should include:
- Incident Response Procedures
- Emergency Action Plan
- Fire Prevention Plan
- Pandemic Safety Plan
Then, we have hazard specific elements that apply to the organization’s business operations or scope of work that may include:
- Code of Safe Practices
- Heat Illness Prevention Plan
- Wildfire Smoke Program
- Fall Hazards
- Electrical Safety Program
- Confined Space Entry
- Trench and Excavation
The primary error made by many employers is failure to separate the aforementioned topics into individual “silos” and combine everything, including the kitchen sink, into one comprehensive document entitled “IIPP”.
The downside of this strategy is that if OSHA, the legal system, regulators, etc., ask for the IIPP, they then get EVERYTHING, including the kitchen sink. Why provide something for which is not asked?
The Benefits of Silos
For those of us that have been deposed or otherwise involved in legal action, one basic strategy exists: Only answer the question that is asked of you, and nothing more.
That said, why would an organization want to reveal its entire hand to OSHA or others, only to have it used against them?
Avoid Cal OSHA’s Infamous “1BY” Form
After Cal OSHA conducts an inspection (investigation), and feels that it has enough material to issue a citation, they typically issue a 1BY form, or “Notice of Intent to Classify as Serious”. This letter is nothing but a bold faced, fishing expedition, intended to compel employers to provide information for which was not asked. Ignore it!
There are many, proven advantages to keeping your organization’s Safety and Health Program as simple and divided as possible, but unfortunately many employers have fallen prey to OSHA and the legal system.
What is the solution to developing effective policies and procedures? Keep them simple, in their own silos, and never provide information for which there has been no specific request.