New change to the IIPP Safety Orders (Section 3203 of the California Code of Regulations) is intended to ensure employee access to the IIPP by specifying who can request such access, what information is to be provided, and a timeframe for requests to be fulfilled.
Prior to this amendment, Section 3203 Injury and Illness Prevention Program did not explicitly state that employees are entitled to receive, review, or copy their employer’s IIPP.
While this doesn’t sound like a big deal, it is. Did you know that Cal-OSHA issues citations and fines to companies for not implementing their IIPP? Employees may now review your IIPP and may notice discrepancies. As long as everything is current in your IIPP and you are doing everything you say you are doing, you should be okay. If you need help, see last paragraph.
ACCESS
Access is defined as the right and opportunity to examine and receive a copy of the Company’s IIPP. Access must be provided in a reasonable time, place and manner, but not later than 5 business days after request.
If an employee as part of their regular work duties, routinely uses the electronic means to communicate with management and co-workers, then unobstructed access to IIPP may be provided through a company server or website. Employee must be able to review, print or email IIPP.
DESIGNATED REPRESENTATIVE
A designated representative is any individual or organization to whom an employee gives written authorization to exercise a right of access.
A recognized or certified collective bargaining agent shall be treated automatically as a designated representative.
WHAT TO PROVIDE
The employer shall provide the requested a printed copy of the program, unless the employee or designated representative agrees to receive and electronic copy.
One printed copy shall be provided free of charge. Additional copies requested within one year of previous request and the program has not been updated, then the employer may charge reasonable reproduction costs.
COMMUNICATION
The employer must communicate these employee rights and request procedures to all employees.
WHAT NOT TO PROVIDE
Employers are not required to provide any of the records or steps taken to implement and maintain the written program.
If an employer has distinctly different and separate operations with distinctly separate and different programs, the employer may limit access to the program (or programs) applicable to the requester.
IMPORTANT STEPS
Review your IIPP. Do you know what’s in your IIPP? Can you answer these questions? Is your IIPP current? Are you doing what your IIPP says you are doing?
An IIPP should only be about 8 pages long. Sometimes we see companies imbed their IIPP in a myriad of other policies and procedures. Your IIPP should be one chapter in your safety program. Each policy should be an additional chapter in your Safety Program, with the IIPP acting as the framework.
If you would like a “No Charge” review of your IIPP, please email [email protected] or call Teddi at (951) 674-1333.
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