An Injury and Illness Prevention Program (IIPP), also referred to as a written safety program, provides a written description of the programs and policies an employer has put into place to provide a safe work environment for its employees. Successful implementation of a safety program requires commitment from all levels within an organization to place a primary emphasis on safety – a commitment that, when adhered to and reinforced by all employees, ensures that workers can return safely to their families at the end of every shift.

One key aspect to review in your California IIPP is the inclusion of specific language related to employee access to the IIPP. In July 2020, the California Occupational Health & Standards Board approved an amendment to General Safety Order section 3203 to include very specific language regarding language to be included in IIPPs addressing employee access to the program. With much focus during 2020 and 2021 being placed on compliance with and application of COVID-19 protocols, the need to update this section of the IIPP may have been overlooked by employers.

Cal/OSHA provides an IIPP template that includes sample accessibility language. State Compensation Insurance Fund also provides an IIPP program resource, which includes an addendum that can be used to address employee access to the IIPP.

Some additional general tips regarding an IIPP are:

• Review and update your IIPP when any major changes occur or at least annually.
• When IIPPs are updated or revised, include a revision date on the document.  Maintain archived copies of prior versions of the IIPP in the event they are requested by an OSHA inspector.
• For supervisors who oversee field crews, consider carrying a hard copy of the current IIPP in a binder in company vehicles for easy access if the program is requested in the field.
• For field or remote operations, consider posting a laminated copy of the current IIPP in areas where required state and federal posters are posted. 

Western Growers Insurance Services is a full-service insurance brokerage offering a suite of insurance and tailored risk management solutions to agricultural and related industry members. For more information or assistance, please contact Ken Cooper, Director of Risk Strategy for WGIS, at [email protected].