INJURY AND ILLNESS PREVENTION PROGRAM (California Senate Bill 198 Compliance)

INJURY AND ILLNESS PREVENTION PROGRAM (California Senate Bill 198 Compliance) The Injury and Illness Prevention Program has been adopted and implemented in compliance with California Labor Code Section 6401.7 (SB 198) and General Industry Safety Order Section 3203

THE LAW AND REGULATION DIGEST OF SENATE BILL 198 (SB 198)

On October 2, 1989, Senate Bill 198 became effective and made several changes to the California Labor Code dealing with worker safety. The most significant was the requirement for ALL employers to implement a written injury and illness prevention program The bill required the Cal/OSHA Standards Board to adopt specific standards regarding criteria to be included in these written programs.

SUMMARY

Every employer in California must have an injury and illness prevention program in compliance with SB - 198 or be subject to Cal/OSHA fines for regulatory violations of up to $25,000. In summary, the program MUST BE IN WRITING and identify the person responsible for its implementation. In addition, it must contain the following elements: (1) A system to ensure that employees comply with safe practices.

(2) A system for fear of reprisal.

communicating with employees about safety matters and their right to report unsafe work practices or conditions without (3) A system for identifying and evaluating workplace hazards , including a record keeping system of periodic inspections, unsafe conditions noted, and corrective actions taken.

(4) A system for investigating occupational injuries and illness .

(5) A system for correcting unsafe conditions in timely manne r based on the severity of the hazard.

(6) Training and instruction to employees and supervisors including detailed documentation of such training.

OUR IIPP HAS BEEN COMPLETED THE COMPONENTS…….

1. Injury and illness prevention plan summary 2. Safety and risk management policies 3. Cal OSHA serious accident reporting policy 4. Modified work letter and schedule 5. Accident investigation training 6. Emergency action plan 7. Facility inspection worksheet 8. Fire prevention plan

OUR IIPP HAS BEEN COMPLETED THE COMPONENTS…….

9. Hazard communication plan (right to know) 10. Heat illness prevention plan 11. Lock out tag out (hazardous energy control) plan 12. Maintenance job hazard analysis 13. Maintenance safety directives 14. Personal protective equipment plan 15. Radio safety communication guide 16. Return to work policy 17. Workplace security plan 18. Work safety rules (with acknowledgement)

About the Plan Documents……

The “heavy lifting” has been done for all the plans. Corporate has provided compliant outlines containing the required format and information. Examine the documents line by line. “Customize” the plan by inserting information specific to your location, personnel, facilities and procedures. You will see where this is needed in the document. Train your employees, managers and supervisors on their responsibilities and expectations of the plan. Document the training.

Conduct “drills” where appropriate to ensure that the plan works and all are familiar with their duties. Update the plan regularly or when new information is added. File in a tabbed IIPP binder.

About the Plan Documents……

These are general industry OSHA approved formats. They may have language which is not needed or applicable to your location and scope of business. Not a problem to change a word to more accurately portray your business. For example, templates may use the word “plant” or “construction site”. Change those words to “location”, “site” or terminal to more accurately address your location. In some cases, entire words, sentences or paragraphs may be removed as not applicable.

Example of Plan Template

A list of refuges/safe zones is given in this table (a refuge zone is a meeting area designated in a location deemed safe for each group of employees within evacuating an area or building. (enter your answer) The (enter your answer) ) to remain behind to care for essential plant Your Company Each department reports to their respective representative as follows: : (enter your answer) See the appendix for a copy of the building plans with means of egress procedures for each group are designated employees to remain behind during evacuation to care for critical plant operations. The procedures to be taken by those employees who have been selected operations until their evacuation becomes absolutely necessary include: 1. The monitoring of plant 2. Manufacturing manufacturing processes: power supplies and water supplies, essential services which cannot be shut down for every emergency alarm, and processes which must be shut down in stages or steps where certain employees must be present to assure that safe shut down procedures are completed, including the following (enter your answer) 3. (enter your answer) Trained evacuation personnel conduct head counts once evacuation has been completed. There is at least one trained evacuation person for each twenty employees in the workplace to provide adequate guidance and instruction at the time of an emergency. The employees selected are trained in the complete workplace layout and the various alternative escape routes from the workplace. All trained personnel are made aware of employees with disabilities who may need extra assistance, such as using the buddy system, and of hazardous areas to be avoided during emergencies. Before leaving, these employees check rooms and other enclosed spaces in the workplace for employees who may be trapped or otherwise unable to evacuate the area. A copy of the list of trained personnel appears below: (enter your answer)

#1 IIPP Plan Summary

IIPP Plan Summary – Lengthy language required legally to be stated and acknowledged by the corporation. Includes explanations of requirements and expectations of the employer and the state. WHAT YOU NEED TO DO…..

Nothing for you to do here. Read through though, as it provides guidance, reasoning and procedural information.

#2 Safety and Risk Management Policies

You already have this information in your Keolis Policies and Procedures Manual. It was added to the IIPP because it provides corporate direction for employees and management on safety related matters. WHAT YOU NEED TO DO…….

Read and understand the information. Any variance between what is written in the policies and what you do at your location needs authorization from corporate.

#3 CALOSHA Serious Accident Reporting Policy

If a serious injury or illness occurs it must be reported as soon as practically possible but no longer than 8 hours after knowledge of accident, to the nearest District Office of the Division of Occupational Safety and Health. Definition of “serious”, direct guidance reporting requirements, district office locations and jurisdictions, phone numbers, etc. are found in this document.

WHAT YOU NEED TO DO…… Read and understand this guidance. Train management staff on the requirement.

#4 Modified Duty Work Letter

From the policies and procedures manual. Admitted to IIPP because it concerns rehabilitation of injuries. WHAT YOU NEED TO DO….

Train your staff on what it is and how to use it. Make certain your employee medical treatment center is aware that you have a vigorous back to work policy and that you have modified duty available.

#5 Accident Investigation Training

Corporate presentation concerning requirements and expectations of accident and injury investigations. Included because thorough investigations are critical to prevent future accidents (identifying cause, hazards and leading to eliminating hazards).

WHAT YOU NEED TO DO…..

Train the investigators, document the training. Hold them accountable for completing thorough investigations in all cases of accident and injury.

#6 Emergency Action Plan

The EAP communicates to employees policies and procedures to follow in emergencies. This written plan is available upon request to employees, their designated representatives, and any OSHA officials who ask to see it.

WHAT YOU NEED TO DO…….

Format the plan outline, train employees. Conduct drills, update as necessary. Communicate the plan to your client or emergency response agencies as necessary.

#7 Facility Inspection Worksheet

Included because proactive inspection, hazard identification and abatement is the cornerstone of the IIPP. WHAT YOU NEED TO DO….

Conduct regular facility inspections, at least monthly. Suggest Safety Committee involvement. Abate EVERY hazard recognized with a sense of urgency. Document the abatement and file the inspection along with the abatement information.

#8 Fire Prevention Plan

This FPP is in place to control and reduce the possibility of fire and to specify the type of equipment to use in case of fire. WHAT YOU NEED TO DO…….

Format the plan outline, train employees. Conduct drills, update as necessary. Communicate the plan to your client or emergency response agencies as necessary.

#9 Hazard Communication Plan

Complies with the requirements of OSHA's Hazard Communication Standard for general industry by compiling a list of hazardous chemicals, using MSDSs, ensuring that containers are labeled, and training our workers. WHAT YOU NEED TO DO…..

Format the plan. Ensure that you specify how your RTK station is organized. Hold new hire and refresher training on the RTK/MSDS station. Very important that you “drill” employees on finding random MSDSs in the binder. Let’s look at why…….

Sections of a Material Safety Data Sheet

               

Chemical and Product Identification: Composition, Information on Ingredients: Hazards Identification:

effects.

Acute effects on skin, eyes, respiratory system and internal harm if swallowed. This section provides detailed information on the physical properties of the material. Also, may list carcinogenic effects, chronic First Aid Measures: Manufacturer recommendation for immediate treatment in case of eye, skin contact. Also, remedies for inhalation and ingestion.

Fire Fighting Measures: Section gives flammable limits, flash point, flammability, fire hazard and extinguishing procedures. This section explains how to extinguish fires involving the product, and lists the specific type of fire extinguisher necessary. It also gives the flash point for the product. This is the temperature at which the product will give off sufficient vapors to ignite in the presence of an ignition source (such as a spark or flame). Other information such as upper and lower explosive limits are given.

Accidental Release Measures: the vapor will rise or sink in the air.

Spill clean up processes, as well as ventilation recommendations. For example, vapor pressure indicates how rapidly the material evaporates, and vapor density is an indication of whether Handling and Storage: Information on exposure controls, such as breathing vapors and heat avoidance. Puncture warnings, incineration dangers, etc. Pressure warnings and storage temperature requirements.

Exposure Controls, Personal Protection:

body and respiratory protection.

PPE recommended for eyes, Physical and Chemical Properties:

This section will list the physical state, pH, boiling point, specific gravity, solubility.

Stability and Reactivity Data:

This section provides information on appropriate precautions regarding materials which decompose dangerously, or which are hazardous if allowed to mix with other chemicals. It may give conditions to be avoided, incompatibility with other chemicals or compounds.

Toxicological Information: Toxicity to animals, other organisms.

Ecological Information: Toxicity to the environment, whether the chemical is biodegradable.

Disposal Considerations: Discarding directions, regulated or non, state and local environmental control regulations.

Transport Information: Gives proper shipping names, DOT classifications of product.

Regulatory Information: Federal Regulatory information, such as clean water act restrictions, release reporting requirements, etc.

Other Information

#10 Heat Illness Prevention Plan

California Employers with any outdoor places of employment must comply with the Heat Illness Prevention Standard T8 CCR 3395. These procedures have been created to assist the employer in crafting their heat illness prevention procedures, and to reduce the risk of work related heat illnesses among their employees.

WHAT YOU NEED TO DO…..

Read this guidance, follow it where applicable in all cases. Key here is to advise employees of heat related hazards, preventive measures and provide reminders. Document your procedures, training sessions and reminder schedules.

#11 Lock Out/Tag Out (Hazardous Energy Control)

This plan establishes the minimum requirements for controlling hazardous energy whenever maintenance or repair is done on vehicles and equipment. It is used to ensure that the machine or equipment is stopped, isolated from all potentially hazardous energy sources and locked out before employees perform any servicing or maintenance where the unexpected energization or start up of the machine or equipment or release of stored energy could cause injury.

#11 Lock Out/Tag Out (Hazardous Energy Control)

WHAT YOU NEED TO DO…..

Format the plan, involving maintenance and operations personnel. Eliminate those sections which do not apply to your location. Determine what training content communicates the process of LOTO to each segment of employees. Each has a different specific responsibility to safety facilitate the process. Document your training. Make certain that your location uses distinguishable materials for LOTO on vehicles and equipment.

#12 Maintenance Job Hazard Analysis

Job Hazard Analysis (JHA), Activity Hazard Analysis (AHA) or Risk Assessment (RA), is a safety management tool in which the risks or hazards of a specific job in the workplace are identified, and then measures to eliminate or control those hazards are determined and implemented. WHAT YOU NEED TO DO….

Insist that the job hazard analysis is used in maintenance safety meetings to remind personnel of common task risks. Also, utilize the maintenance technical manuals to teach safety concerning specific tasks (reference “Caution”, “Warning”, “Danger ”).

Job Hazard Analysis Example

#13 Maintenance Safety Directives

These directives are to be installed and maintained as standard operating procedure at all Keolis locations. These processes will assist us in protecting our most valuable asset (our employees), as well as complying with regulatory safety mandates. WHAT YOU NEED TO DO…..

Read and understand the directives. Have your maintenance manager, supervisors and employees sign off. Only those items which the location cannot (because of hardship) accommodate will receive authority for variance. Apply to Corporate Safety Director for documented variance.

#14 Personal Protective Equipment Plan

This program addresses eye, ear, respiratory, hand, and foot protection. A hazard assessment is included in this plan. Based on this assessment, specific items of personal protective equipment are deemed necessary during performance of certain activities. WHAT YOU NEED TO DO… Format the plan, eliminate those sections which do not apply to your need for PPE. Train your employees, document the training. Inventory your PPE stock, monitor compliance daily.

#15 Radio Safety Communication Guide

Recommended formats of safety messages to assign for radio broadcast or other types of distribution. Safety messages are a reminder of safe operating techniques the employee needs to hear WHILE performing tasks. WHAT YOU NEED TO DO…..

Assign the messages to halt trends, keep employees sharp or warn of known hazards. Document the distribution time and type. Hold managers, supervisors and dispatchers accountable to regularly distribute the messages. You can make up your own messages, even have drivers broadcast their own messages (pre approved, of course). They usually really like doing this!

#16 Return to Work Policy

Documents this corporation’s policy to provide temporary transitional work to employees who are unable to perform regular duties due to occupational illness or injury as soon as the treating physician deems it medically feasible.

WHAT YOU NEED TO DO…..

Read the document. Providing modified duty to all employees who have been assigned medical restrictions related to a work injury is not optional.

#17 Workplace Security Plan

Keolis is interested in preventing internal or external theft of information or materials, as well as preventing violence of any sort from occurring either between co-workers or from a non-employee to an employee. WHAT YOU NEED TO DO…… Format the plan considering your location, processes and needs for security. Bring your management team to the table and brainstorm scenarios of security breaches and preventive measures. Bring to mind past scenarios where security plans would have been useful.

#18 Workplace Safety Rules

Generic workplace safety rules and best practices to be posted for the employees to view. Reminders of safety expectations of management in the workplace of all employees.

WHAT YOU NEED TO DO…….

Go through each rule and keep, delete or adjust the rule for your local use. Format your rules for specific safety needs. Introduce the rules at a safety meeting, and post the rules in a place where employees are expected to observe postings from management. Document the training for employees. Hold employees accountable for observing the rules. Get HR involved!

Questions?

Thank you!