IIPP Recordkeeping

On October 14, 2017, Governor Brown vetoed AB-978: Employment safety – Injury and Illness Prevention Program.  This bill would have required an employer to provide upon request a complete copy of the company’s written Injury and Illness Prevention Program (IIPP) and all required attachments to a current employee or a representative of the employee within 10 business days.  Unquestionably, if this bill passed, it would have significantly expanded the scope and detail to whom IIPPs and attachments would have been provided.

Even though this bill was vetoed, there are still existing recordkeeping requirements under IIPP with which employers must comply.  Title 8, CCR §3203 of the General Industry Safety Orders, requires that following documents be maintained by all employers as part of the IIPP:

• Records of scheduled and periodic inspections to identify unsafe safety conditions and work practices. The inspection records must include 1) who conducted the inspection; 2) unsafe conditions and work practices that have been identified; and 3) actions taken to correct the unsafe conditions and work practices.  Corrective action must include what steps were taken to correct the hazard and the date the corrections took place.
• Training records including 1) new employees; 2) employees given new job assignments for which training has not been previously provided; 3) for new substances, processes, procedures that are introduced into to the workplace and represent a new hazard; 4) for awareness of a new or previously unrecognized hazard; and 5) supervisor awareness. These records must in employee names, training dates, types of training and training providers.
• Labor/management safety and health committee meeting records, if the employer elects to use such a committee.

The records must be provided to Cal/OSHA as requested during a site inspection. These records must be maintained for at least one year. There are exceptions for maintenance of records for employer size or local government entities. Employers engaged in construction activities (regarding 8 CCR §1509 – IIPP) must also maintain a code of safe practices, periodic meetings of supervisors and “tailgate” or “toolbox safety meetings which must occur at least every 10 working days.

If you haven’t reviewed your IIPP or your records for some time, now may be a good time.  Let us know if you’d like to verify that your IIPP meets the Cal/OSHA requirements.