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Safety First. Model Injury and Illness Prevention Program

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Safety First Model Injury and Illness Prevention Program 1 Injury and Illness Prevention Program Introduction 3 Recordkeeping Exceptions 4 Safety Policy Statement and Responsibility 5 Manager & Supervisor
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Safety First Model Injury and Illness Prevention Program 1 Injury and Illness Prevention Program Introduction 3 Recordkeeping Exceptions 4 Safety Policy Statement and Responsibility 5 Manager & Supervisor Safety Responsibilities 6 Compliance 7 Communication 8 Hazard Identification and Assessment 9 Accident Investigation / Hazardous Substance Exposure 10 Training and Instruction 11 Recordkeeping 12 Employee Acknowledgement 13 Use these forms to maintain and document activities: Accident Investigation Report form 14 Inspection Worksheet 15 Employee Training Log 16 Supervisor Responsibilities (Orientation) 18 General Safety Rules 19 2 INTRODUCTION The purpose of this manual is to assist with the development of an Injury and Illness Prevention Program. Cal/OSHA Title 8, CCR Section 3203 requires every California employer to provide and maintain an effective Injury and Illness Prevention Program (IIPP). The IIPP must include these elements: 1. Safety Policy and Responsibility - A written safety policy statement that governs the company s decision making on matters concerning employee safety and health. Within the statement identify the person responsible for coordinating the Injury and Illness Prevention Program. 2. Compliance Procedure Explain how employees will be disciplined when they fail to follow safety and health rules and procedures. 3. Communication This section describes how safety issues will be communicated to employees and how often. 4. Hazard Assessment Describe the process used to identify and eliminate or control hazardous conditions or unsafe work practices. 5. Accident Investigations Explain the procedures for investigating an accident and how corrective actions will be administered to ensure they are implemented to prevent recurrence. 6. Training and Instruction This section describes how new or transferred employees will be trained to the safety and health aspects of a given job, as well as whenever new substances, processes, procedures or equipment are introduced into the workplace. 7. Recordkeeping Provide a description of the administrative procedures for the maintenance of records, as evidence of safety activities. See Recordkeeping Exceptions on Page Employee Acknowledgement - A statement the employee signs acknowledging understanding of their responsibility to comply with safety rules and that they received job specific training. As you develop your Injury and Illness Prevention Program, keep this in mind: Keep it simple, concise and easy to read. Make certain that all required elements are included in the program. Ensure the program safety rules and training materials are specific to your company s operations, processes and equipment. Remember to review your program annually and make changes, if necessary. Update the program if you have any changes in your processes or operations. To be judged effective, the policies, procedures and activities outlined in the program must be fulfilled as written, and documentation maintained as evidence for at least 5 years. If you want assistance creating your IIP Program, call or our Safety and Health Department at DISCLAIMER This manual should not be construed as representing or warranting that the use of any or all of the information contained will result in compliance with the laws presented in Senate Bill 198 or related Cal/OSHA regulations. You MUST tailor your Injury and Illness Prevention Program to meet your business' specific safety needs. At a minimum, your completed program must be used as outlined for this program to be considered effective. Failure to do so could result in penalties should your business be inspected by Cal/OSHA. Additional information related to having an effective Injury and Illness Prevention Program is available at: 3 Small Employer Recordkeeping Exceptions If you employ fewer than 10 employees there are less stringent recordkeeping and training requirements. Specifically the exceptions are: Training You can give oral instruction to an employee on the general and specific safety rules that apply to the employee's job assignment(s). Document the instruction given on a training log, showing the specific jobs an employee is trained to perform. Show the employee's name, date of training, type of training, and trainer's name. Training records of employees who work for less than one year can be given to the employee when employment terminates, or you must retain the records for 1 year after termination. Inspections Records of inspections may be discarded after identified hazards are corrected. If you employ Fewer than 20 employees and are not on the list of high hazard industries established by the Department of Industrial Relations (see list below), and have a workers compensation experience modification rate of 1.10 or less, then written documentation of your Injury and Illness Prevention Program may be limited to: Written documentation identifying the person responsible for implementing the program Written documents of inspections that identify unsafe conditions and work practices Written documentation of training and instruction given to employee HIGHEST HAZARD INDUSTRY LIST NAICS* Industry Group / Activity Healthcare 623 Nursing and residential care facilities Manufacturing 3114 Fruit and vegetable preserving and specialty food manufacturing 3115 Dairy product manufacturing 312 Beverage and tobacco product manufacturing 3211 Sawmills and wood preservation 3259 Other chemical product and preparation manufacturing 3262 Rubber product manufacturing 3273 Cement and concrete product manufacturing 3312 Steel product manufacturing from purchased steel Ornamental and architectural metal work manufacturing 3363 Motor vehicle parts manufacturing 3366 Ship and boat building 3372 Office furniture (including fixtures) manufacturing NAICS* Industry Group / Activity Construction Framing contractors Masonry contractors Other foundation, structure, and building exterior contractors Transportation and Warehousing 481 Air Transportation 492 Couriers and messengers 493 Warehousing and storage Wholesale Trade 4244 Grocery and related product merchant wholesalers Retail Trade 452 General merchandise stores Utilities 5622 Waste treatment and disposal *North American Industry Classification System go to to find your industry classification 4 Preceding pages can be omitted from the final version of your Injury and Illness Prevention Program. The italicized instructions at the top of each section should be deleted. How to use this Policy Statement in your program: When the policy statement is finalized, provide each employee with a copy and give new employees a copy during the orientation process. If this is a new program for the company then introduce the Injury and Illness Prevention Program at a brief safety meeting. Also, review the responsibilities of the safety coordinator and employees safety responsibilities. Safety Policy Statement and Responsibility It is the policy of to consider injury and illness prevention (Your company name here) equally important as operations, customer service and administration. The Injury and Illness Prevention Program outlines the company s policies and procedures to maintain a safe and healthy work environment for all employees. Responsibility for implementing the injury prevention program is assigned to, (Insert safety coordinator name here.) who will coordinate safety efforts and oversee the enforcement of all company safety policies, procedures and rules. The prevention of injuries and property damage is an objective for all employees in the organization. Each manager/supervisor shall make the safety of employees an integral part of his or her regular management function. It is equally the duty of each employee to accept and follow established safety regulations and procedures. Each employee is responsible for following general safety rules and safe work practices at all times. Any employee injury or illness that occurs on the job must be reported to management immediately. (Insert signature of company Owner/Officer here.) 5 Manager and Supervisor Safety Responsibilities: Set the proper example for safe behavior and never act unsafely or violate a safety rule or an established safe work practice. Provide complete job safety training to new and transferred employees. Be continuously vigilant of unsafe conditions that could contribute to an injury and take corrective action to eliminate or control unsafe conditions or work practices immediately. Make certain all injuries, no matter how minor, are treated immediately. Report all employee injuries to the workers compensation claims administrator for reporting to the company s workers compensation insurance company. Make certain employees are furnished with the appropriate computer workstation equipment to prevent musculoskeletal injuries. Enforce corrective actions when employees fail to follow safety rules. Documentation of the employee s failure to comply with safe rules is essential to the safety program. 6 How to use this Compliance Policy: Share this element of the IIPP with all employees to ensure everyone understands that it is each individual s responsibility to follow safety rules and work practices, and that there are consequences for not adhering to safety rules. Check the Compliance Practices that will be used by your company. Compliance All employees will be trained in safe work practices when hired and when new substances, processes or equipment are introduced into the workplace. If an employee is observed using unsafe work practices they will be retrained. Employees are expected to follow safe work practices at all times. Our system of ensuring that all workers comply with these practices includes one or more of the following checked practices: Informing workers of the provisions of our IIP Program. Evaluating the safety performance of all workers. Recognizing employees who perform safe and healthful work practices. Providing training to workers whose safety performance is deficient. Disciplining workers for failure to comply with safe and healthful work practices. Management and the employee will agree on an appropriate length of time to correct unsafe behavior. Management reserves the right to terminate any employee for a serious and willful violation of a safety practice such as using drugs or alcohol on the job, rendering a machine guard or safety switch inoperable, fighting, etc. 7 Instructions for safety communications: This responsibility is normally shared within a business. The safety coordinator may provide topics on a regular basis to the owner, general manager or supervisors that can then be used at a brief safety meeting, handed out or posted in a conspicuous location.. Communication can occur in a variety of ways: safety meetings, posters, handouts, paycheck stuffer or safety committee. Check the methods of communication your company will use. Communication Safety communication with employees will occur at the following times: New worker orientation including a discussion of safety and health policies and procedures. Review of our IIP Program. Training programs. Regularly scheduled safety meetings. Posted or distributed safety information. A system for workers to anonymously inform management about workplace hazards. Our establishment has less than ten employees and communicates with and instructs employees orally about general safe work practices and hazards unique to each employee's job assignment.* Employees will be encouraged to report any unsafe conditions to the manager without fear of reprisal. Management review all safety and health suggestions and determine if an inspection, additional training, or other action is necessary. If action is needed to correct an unsafe condition or process, management will determine the appropriate corrective action, assign responsibility for correcting the condition or process and establish a target date for completion. The safety coordinators will follow-up to ensure the corrective action is completed by the target date. *The ten employee rule takes into consideration the total number of employees your company employed during the year. For example, if you have ten employees on the payroll, but you had two employees leave and they were replaced, then your business had 12 employees during the year. 8 How to implement Hazard Identification and Assessment: Inform current and new employees to whom they are to report an unsafe condition, process or procedure. Ensure you have a method in place for employees to anonymously report an unsafe condition. Recordkeeping requirements vary depending on the number of workers employed by the business. These are described in the Small Employee IIP Program section found at the front of this document. Hazard Identification & Assessment Unsafe or unhealthy work conditions, practices or procedures shall be corrected in a timely manner based on the severity of the hazards. Periodic inspections are performed according to the following schedule: 1. When we initially established our IIP Program; 2. When new substances, processes, procedures or equipment which present potential new hazards are introduced into our workplace; 3. When new, previously unidentified hazards are recognized; 4. When occupational injuries and illnesses occur; and 5. Whenever workplace conditions warrant an inspection. 6. When an imminent hazard exists which cannot be immediately abated without endangering employee(s) and/or property, we will remove all exposed workers from the area except those necessary to correct the existing condition. Workers who are required to correct the hazardous condition shall be provided with the necessary protection. Unsafe or unhealthy work conditions, practices or procedures will be corrected in a timely manner based on the potential of the hazard to cause injury; hazards that are more serious will be given higher priority to correct. When hazards cannot be immediately controlled or eliminated, then the action necessary for correction should be documented with a date established for completion. A copy of the inspection report is to be sent to the Safety Coordinator who will maintain a log of incomplete items, which will be reviewed monthly. Any item that has not been corrected will be identified in the review and follow up will occur each month with the person responsible for correcting the hazard. Imminent Hazards Report all imminent hazards to your manager, supervisor or safety coordinator. Employees will be removed from the area where an imminent hazard exists, or protected from imminent hazards until they are corrected. When employees are exposed to a life threatening or serious hazard, which cannot be immediately eliminated or controlled without endangering them, all exposed employees will be removed from the area. Those needed to correct the situation will be provided with the necessary protection. 9 Implementing an Accident Investigation procedure: Accident investigation is a management responsibility. Ensure this is communicated during the introduction of the IIPP and when hiring a new manager or supervisor. Recordkeeping requirements vary depending on the number of workers employed by the business. These are described in the Small Employee IIP Program section found at the front of this document. Accident Investigation/Hazardous Substance Exposure The employee s immediate supervisor or other management member will investigate any incident resulting in bodily injury or illness, exposure to hazardous substance, or property damage. Facts gathered from the investigation will be documented on the Accident Investigation Report form. A completed copy of the Accident Investigation form, along with suggested corrective actions, will be sent to the Safety Coordinator. Procedures for investigating workplace accidents and hazardous substance exposures include: 1. Interviewing injured workers and witnesses; 2. Examining the workplace for factors associated with the accident/exposure; 3. Determining the cause of the accident/exposure; 4. Taking corrective action to prevent the accident/exposure from recurring; and 5. Recording the findings and actions taken. Each manager will be responsible for ensuring unsafe conditions are corrected, and if necessary, employees are retrained to prevent recurrence of the accident. 10 Training Employees: Employee training must occur at time of hire, and when an employee is transferred to a new job or when new equipment or processes are introduced into the work environment. Documentation of training given to employees is a critical element of the IIP Program. This portion of the IIPP requires the most attention when creating the IIPP because training must be tailored to reflect the company s operations, equipment, processes and procedures. Training and Instruction All workers, including managers and supervisors, shall have training and instruction on general and job-specific safety and health practices. Training and instruction is provided: 1. When the IIP Program is first established; 2. To all new workers, except for construction workers who are provided training through a construction industry occupational safety and health training program approved by Cal/OSHA; 3. To all workers given new job assignments for which training has not previously provided; 4. Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard; 5. Whenever the employer is made aware of a new or previously unrecognized hazard; 6. To supervisors to familiarize them with the safety and health hazards to which workers under their immediate direction and control may be exposed; and 7. To all workers with respect to hazards specific to each employee's job assignment. General workplace safety and health practices include, but are not limited to, the following: 1. Implementation and maintenance of the IIP Program. 2. Emergency action and fire prevention plan. 3. Provisions for medical services and first aid including emergency procedures. 4. Prevention of musculoskeletal disorders, including proper lifting techniques. 5. Proper housekeeping, such as keeping stairways and aisles clear, work areas neat and orderly, and promptly cleaning up spills. 6. Prohibiting horseplay, scuffling, or other acts that tend to adversely influence safety. 7. Proper storage to prevent stacking goods in an unstable manner and storing goods against doors, exits, fire extinguishing equipment and electrical panels. 8. Proper reporting of hazards and accidents to supervisors. 9. Hazard communication, including worker awareness of potential chemical hazards, and proper labeling of containers. 10. Proper storage and handling of toxic and hazardous substances including prohibiting eating or storing food and beverages in areas where they can become contaminated. 11 RECORDKEEPING How to comply with the Recordkeeping requirement: Recordkeeping requirements vary depending on the number of workers employed by your business. These are described in the sections below. Select the Category that fits your business and delete the others. Category 1: Since we have less than ten workers, including managers and supervisors, we maintain inspection records only until the hazard is corrected and only maintain a log of instructions to workers with respect to worker job assignments when they are first hired or assigned new duties. Category 2: Our company has twenty or more workers or has a workers' compensation experience modification rate of greater than 1.1 and is not on a designated low hazard industry list. We have taken the following steps to implement and maintain our IIP Program: 1. Records of hazard assessment inspections, including the person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and the action taken to correct the identified unsafe conditions and work practices, are recorded on a hazard assessm
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