The Department Injury and Illness Prevention Program (IIPP) is designed to provide a written plan for the protection of employees and to reduce the losses resulting from work-related injuries and illnesses. All departments must establish, implement and maintain an Injury and Illness Prevention Program (IIPP). The requirements for an effective written injury and illness prevention program are contained in Title 8 of the California Code of Regulations, Section 3203. Written programs have eight required elements:
A. Responsibility/Management Commitment
Each Department Head must designate a responsible person or persons to implement the departmental Injury and Illness Prevention Program. The Department Head has the overall responsibility and authority for the implementation of the IIPP. Senior management provides overall direction and designates program implementation through Department Safety Coordinators, Site Safety Coordinators, Training Coordinators, etc. Senior management is responsible for monitoring program implementation and effectiveness.
Department Heads, directors, managers and supervisors must demonstrate ongoing commitment and leadership for their IIPP and the County Safety Management Program. Activities that demonstrate program effectiveness include participation in safety activities with direct interaction with employees such as through department staff meetings with safety on the agenda. Allocation of appropriate resources for program implementation, including support of the Department Safety Coordinators role is critical to program effectiveness. The development of effective management systems to monitor program implementation demonstrates ongoing management commitment and support of the overall program.
Departments must inform employees of the Injury and Illness Program requirements and the safety program requirements must be enforced. A system to require employees to comply with safe work practices and procedures should be described in the written IIPP document. Compliance methods may include employee recognition programs, counseling, re-training, performance evaluations with a safety element, and disciplinary procedures consistent with County policies and Memorandum of Understanding.
Departments must develop effective, two-way communication on safety and health issues, including a method for employees to report hazards anonymously. Specific communication methods at all levels of the organization must be outlined in the department IIPP. Safety communication methods may include staff meetings, general safety meetings, training programs, written communications, newsletters, safety bulletin boards, and department safety committees.
Smaller departments can satisfy the communication requirement during regularly scheduled staff meetings. Larger departments are strongly encouraged to establish a department occupational health and safety committee. Departments with multiple locations are encouraged to maintain a safety committee for each division, program or site, as appropriate. Each established department safety committee shall invite at least one member from each employee organization.
D. Hazard Assessment
Departments must identify and evaluate the hazards found in their workplace in order to implement effective controls.
- Job-specific Hazard Assessments
Departmental IIPPs include job-specific hazard assessments. These are the baseline hazard assessments that are the foundation for developing effective safe work practices.
Hazard assessment is an ongoing process and evaluations are conducted whenever new or previously unrecognized hazards are identified, new substance, equipment or operation are introduced, and the occurrence of an occupational illness or injury.
- Periodic inspections
Periodic inspections are conducted to identify work area hazards and to evaluate the effectiveness of controls. Work practice observation can be incorporated into the periodic inspection. Each Department identifies inspection criteria, develops periodic inspection schedules and designates the responsibility for conducting inspections by work area or facility.
Supervisors develop methods for the evaluation of safety procedures for operations conducted off-site.
- Reporting of Hazards
All managers and supervisors will encourage employees to report workplace hazards without fear of retaliation and will provide prompt reports on the status of hazard correction. Each Department is responsible to make sure the Sonoma County Employee Hazard Report form (PDF: 205 kB) is readily available to employees in all work locations to facilitate the formal reporting of safety hazards. The written department IIPPs must clearly describe the locations of report forms and the methods for employees to submit a Hazard Report directly to their supervisor, or to another individual if anonymity is desired. The IIPP must also describe the method of elevating safety concerns through the department, up to and including the Department Head.
E. Hazard Correction
The Supervisor, Manager or Department Head, as warranted by the specific condition, will assess hazard severity and identify the method and time it will take to conduct hazard correction. Upon request of the Department Head, Risk Management will provide assistance to the department on hazard corrections.
Each Department will implement a hazard correction tracking system to identify hazards through periodic inspections, Employee Hazard Reports, accident investigations or other methods are corrected and the correction documented.
F. Injury procedures
- Injury/Illness/Exposure Procedures
The department IIPP will reference the County of Sonoma Injury/Illness/Exposure Procedures. Department specific procedures will also be described or referenced.
- Accident/Incident Investigations
All departments must conduct effective accident/incident investigations to identify the root cause of the accident and to implement adequate control measures. Accident /incident investigations must be reviewed periodically by department management to determine that thorough investigations are conducted by supervisors and deficiencies in the safety management system are identified. Opportunities for improvement from investigations can be used for planning and corrective action.
The department IIPP defines the level of investigation that will be performed for accidents and “near miss” incidents. The IIPP also describes the time frames for investigations, investigation responsibilities for individuals, teams or committees, and follow up procedures described.
G. Department Safety and Health Training
Department Heads are responsible to provide all employees with designated department occupational safety and health training on general and job-specific hazards, and safe work practices. Each department will develop an occupational health and safety-training matrix for employees with similar job hazards that include IIPP training, job-specific training (based on the department IIPP hazard assessment) and regulatory program training requirements. Departments may choose to include optional topics to reach department best practice goals.
Supervisors and Managers require a higher level of training to include all health and safety hazards to which employees under their immediate direction and control are exposed.
Each department is responsible for the delivery of job-specific health and safety training to extra-help, temporary, volunteers and contract employees. This requirement will apply for County employees from other departments assigned to work in their operation or facility. Departments are not responsible for health and safety training for the employees of other County departments contracted to perform specific facility or infrastructure tasks that are independent of the mission of the department.
Each department provides safety training and instruction when:
- Safety policies and programs are first established or revised
- New employees are hired (orientation safety training)
- Employees are assigned to a new area or task where specialized training is needed.
- New substances, operations, procedures or equipment are introduced
Each department shall establish a system to monitor the completion of employee safety training for each individual to effectively manage the delivery of mandatory training requirements. An assessment of safety training effectiveness is included in periodic evaluations.
H. Record keeping
IIPP records are maintained consistent with the records retention requirements identified in Common Accounting and Administrative Records (CAAR) retention schedule.
Specific IIPP record keeping requirements include:
- Periodic inspection records will include the date of the inspection, location, name of the person conducting the inspection, unsafe work practices or conditions identified, and the corrective action taken.
- Occupational health and safety training records will include the employee names and signature (sign-in sheets), instructor, training date and training curriculum or agenda. Staff meetings where required safety training is delivered will follow the same record keeping format.
I. Program Evaluations
The Department Safety Coordinator, Department Safety Committee or other designated staff is responsible to evaluate the effectiveness of the departmental IIPP on an annual basis. A report summarizing department IIPP implementation and program status shall be submitted to the Department Head for review. Corrective actions to improve program implementation and management system deficiencies will be recommended and the status of corrective actions will be documented.
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