A farmer trains workers in the field
Photo credit: Hector Amezcua, College of Agricultural and Environmental Sciences, UC Davis

Injury and Illness Prevention Program (IIPP): Requirements and Exceptions for Employers With Less Than 10 Employees

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Every employer in California is required to establish, implement, and maintain an effective Injury and Illness Prevention Program (IIPP), per Title 8 of the California Code of Regulations (T8CCR), section 3203 from Cal/OSHA. 

The IIPP was the most frequently cited Cal/OSHA regulation violation in 2019 (source). While the last year has forced employers to prioritize COVID-19 prevention and the subsequent emergency temporary standard, it is important to revisit the other workplace hazards covered in the IIPP as this year’s season ramps up.

The IIPP is a proactive process to help employers find and fix workplace hazards before workers are hurt. Not only do these employers experience dramatic decreases in workplace injuries, but they often report a transformed workplace culture that can lead to higher productivity and quality, reduced turnover, reduced costs, and greater employee satisfaction. (source)

What does the IIPP include?

There are nine elements that must be included in your IIPP. Some of the elements below link to articles with more details about each component, but be sure to review the standard in its entirety to understand what is required. 

  1. Assignment of the responsibility for safety
  2. Systems for ensuring employee compliance with safety procedures 
  3. Communication with employees and methods for involving them in safety-related activities 
  4. Hazard assessment/inspection 
  5. Investigations of occupational injuries, occupational illnesses, and accidents 
  6. Correction of hazards 
  7. Training employees and supervisors on workplace hazards 
  8. Recordkeeping and documentation of program
  9. Employee access to the program: adopted on January 16, 2020, which requires employers to provide employees with access to their written IIPP within five days of an employee's request.

Exceptions for employers with less than 10 employees

Although every California workplace needs to have an IIPP, there are a few differences on how employers with less than 10 employees can comply with this regulation. For instance:

  • Generally, the standard requires both written and oral communication with employees about safe work practices and hazards unique to their job assignment. If you are an employer with less than 10 employees, you may communicate with employees orally only.
  • You only need to maintain hazard inspection records until the hazard is corrected instead of maintaining the records for at least one year.
  • You can maintain a log of instructions provided to newly hired workers with respect to the hazards that are unique to their job assignments, rather than maintaining training records with specific details for at least one year.

A Word of Caution

This is a highly simplified summary of these exceptions, so please review the standard in detail to completely understand how these exceptions apply. While these exceptions exist in the standard, it may be a good idea for employers with less than 10 employees to maintain records for training and hazard identification per the full standard. In the case of an employee injury or OSHA inspection, it may be easier to supply the records rather than try to prove that you met the exception.

Resources

  • WCAHS provides FREE trainings to help you develop your IIPP:
    • Wednesday June 2, 2021 from 9:30am-11:30am (in English) - Register here by May 28
    • Wednesday June 9, 2021 from 9:30am-11:30am (in Spanish) - Register here by June 4  
  • Print resources that supplement our trainings:

This article is based on the Worker Occupational Safety and Health Training and Education Program (WOSHTEP) administered by the Commission on Health and Safety and Workers' Compensation in the California Department of Industrial Relations through interagency agreements with the Labor Occupational Health Program at the University of California, Berkeley; the Western Center for Agricultural Health and Safety at the University of California, Davis; and the Labor Occupational Safety and Health Program at the University of California, Los Angeles.

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