Did You Know...You Don't have to Keep all your Safety Programs as One Document?

Have you considered keeping all your policies separate instead of appendices or attachments to your Injury Illness Prevention Program (IIPP)?

Some legal minds believe it puts the agency in an improved position to keep each program separate. This way the agency can provide only the specific programs that Cal/OSHA has requested in conjunction with an inspection.

Remember that everything that you put into your IIPP is a process, and Cal/OSHA will hold you to that process. In other words, it is a list of promises and should Cal/OSHA find that you are not making good on those promises, it will most likely result in a citation and/or fine.

If you should receive the Cal/OSHA Document Request form, stick to it. For example, if your IIPP and Heat Illness Prevention Program are requested and all the safety related programs are attached to the IIPP. The agency could end up providing something like 200 pages of safety programs for review, most of which was not even requested, but then could potentially expose the agency to citations. If the programs are separate, you can provide Cal/OSHA with a succinct yet effective IIPP—that simply addresses the 7 elements as required by Title 8 CCR GISO 3203 and Heat Illness Prevention Program.

Those with concerns regarding employees being able to easily find safety documents, you might consider keeping the program documents together in a binder or electronic folder for distribution, just different tabs.