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I2P2 has been mentioned in workplace safety organizations since its introduction in 2010. According to the articles around that time, the federal program would completely change OSHA enforcement capabilities and significantly enhance workplace safety. Instead of bringing about widespread change in the workplace, I2P2 has lurked in the background, leaving many business owners wondering what they should do. Here’s what you need to know in 2016.
If you haven’t heard the term before, I2P2 is the acronym for the Injury and Illness Prevention Program (IIPP). During President Obama’s first administration, program momentum was strong, and OSHA held several meetings to create a plan for the new program. However, its energy significantly slowed during the 2012 election season. In 2013, OSHA rebranded the program as a number one priority. Now, three years later, there’s still no clear time frame for program enactment.
Although there isn’t a federal standard currently in place, OSHA still has I2P2 implementation on its agenda. Developing strong workplace health and safety policies promotes state and federal compliance and reduces the overall risk associated with workplace incidents. In other words, policy development at the company level makes a lot of sense for every business. The state of California requires all businesses, regardless of size, to have an effective program in place. Maintaining compliance at the state level will improve your company’s ability to protect itself from future federal changes.
The state Department of Industrial Relations offers a free eTool for businesses needing to develop or update their IIPP. Effective policies include outlined procedures for all standard IIPP requirements.
Your IIPP should include eight required policies regarding the chain of responsibility, compliance, hazards, communication protocols, accident and exposure incident investigations, hazard mitigation, training, and record keeping. Policies should include information for all levels of employees, specifically relate to your workplace environment, and offer a demonstrable process for effective training.
To remain in compliance with state regulations, a business must have a written policy, put it into practice, and update it on a regular basis. While the state doesn’t have a standard for the creation of an IIPP, it does reserve the right to assess a civil penalty on businesses that don’t maintain an effective program.
Businesses can develop an IIPP on their own, but you should consider having an attorney help you write or review your program. Once a policy is put in place, it becomes a kind of contract similar to an employee handbook. If you include rules and procedures you can’t maintain in practice, you could face a costly citation and investigation from Cal/OSHA.
An attorney can improve your ability to craft an IIPP that keeps your business in compliance with state standards while reducing the risk of breaking your own policy. If you do have additional policies regarding workplace health and safety, your attorney may instruct you to create an internal separate from your state mandated IIPP.
Yes. HIPP (Heat Illness Prevention Program) is a program specifically designed for businesses involved in outdoor activities. If your enterprise falls into this category, you may need to develop an HIPP and an IIPP.
If you need to develop an IIPP, update an old program, or appeal a Cal/OSHA citation, the team at DiMarco Arujo Montevideo can help. The laws regarding IIPP compliance at the state and federal level can be confusing, and fines for noncompliance can range from hundreds to thousands of dollars.