Understanding the Essential Prevention Plans Required by CalOSHA
Most of the time when I take on a new client and I ask to see their Injury and Illness Prevention Program (IIPP) document they look at me like I’m nuts. (This actually happens many times during the onboarding process.)
They are usually surprised to find out that CalOSHA requires all employers in all industries to have one and to train employees on it. Moreover, there are seven programs/plans that CalOSHA might require and most employers are subject to three of them.
(If you’ve been to one of my talks and are looking for the “Thank Me Later Links” scroll to the end 😀)
The Injury and Illness Prevention Program (IIPP)
The Injury and Illness Prevention Program (IIPP) is the cornerstone of workplace safety in California. All employers are required to develop, implement, and maintain an effective IIPP, which must be tailored to the specific needs and conditions of the workplace.
Training is required on the plan at least once and as needed when the plan is updated or as often as you feel is necessary to maintain a safe workplace (don’t forget to train new hires!!). And of course all employee training needs to be documented!!
COVID-19 Prevention Plan (CPP)
As I’m writing this the COVID-19 Prevention non-emergency regulations (often called the NETS or Non-Emergency Transmission Standards) are still in effect (until February 3, 2025). This means all employers are required to have and train on a COVID-19 Prevention Plan (CPP).
The CPP focuses on minimizing exposure to the virus in the workplace and keeping employees informed about safety measures. This plan also requires one-time training at a minimum.
Workplace Violence Prevention Plan (WVPP)
Starting this year, nearly all employers are required to have a Workplace Violence Prevention Plan (WVPP). This plan is designed to identify and mitigate the risks of violence in the workplace. Training on the WVPP is required annually.
There are two exemptions that might be relevant to some readers of this post (from SB 553):
(E) Employees teleworking from a location of the employee’s choice, which is not under the control of the employer (this means everyone).
(F) Places of employment where there are less than 10 employees working at the place at any given time and that are not accessible to the public, if the places are in compliance with Section 3203 of Title 8 of the California Code of Regulations (this means you have an IIPP).
Other Plans That May Be Required Depending on the Workplace
Heat Illness Prevention Plan (HIPP): Required for employers with outdoor workers or in high-temperature environments.
Hazard Communication Program (HazCom): Required for employers handling hazardous chemicals.
Emergency Action Plan (EAP): Required for employers who have more than 10 employees, outlining procedures during emergencies like fires or earthquakes.
Fire Prevention Plan: For workplaces where fire hazards are present.
Why These Plans Matter
It won't surprise you to learn that there are statutory legal and cash penalties for non-compliance with these programs. If you ask me, though, these are ways that you signal to your team that you care about their health and safety. At the end of the day it’s up to you as a leader to decide whether this becomes a homework assignment that everyone ignores, or you make it an opportunity to improve your workplace and your culture.
What do I do now?
Here’s the good news: for many employers, these can be DIY projects. CalOSHA provides model programs you can adapt to your situation. But please, don’t ignore the training and documentation requirements!!
Here are the famous "Thank me later links"
IIPP: https://trainingacademy.dir.ca.gov/page/iipp-model
CPP: https://www.dir.ca.gov/dosh/dosh_publications/CPP.doc
WVPP: https://www.calhr.ca.gov/Documents/model-workplace-violence-and-bullying-prevention-program.pdf
Bonus! Unlawful Harassment Training Materials: https://calcivilrights.ca.gov/shpt/