IIPP (Injury and Illness Prevention Programs)
BY GRAPHIC PRODUCTS STAFF
An injury and illness prevention program (IIPP), has been established to help employers identify and fix workplace hazards resulting in a significant reduction in the number and severity of workplace injuries.
OSHA is in the early stages of establishing a federal requirement for employers to have an injury and illness prevention program. However, many state OSHA's already require IIPP and many employers have created an injury and illness prevention program on their own. The result has been a dramatic decrease in workplace injuries. In addition, OSHA reports that employers using IIPP often see a transformed work culture that can lead to higher productivity and quality, reduced turnover, reduced costs, and improved employee job satisfaction.
According to OSHA’s online page on IIPP, thirty-four states already require or encourage employers to implement an injury and illness prevention program. The key characteristics common to all of these IIPP programs are:
- Management leadership
- Worker participation
- Hazard identification and assessment
- Hazard prevention and control
- Education and training; and
- Program evaluation and improvement
These elements are interrelated and interdependent, and each is important for ensuring the success of the overall program
Based on the experience of employers who have already implemented an injury and illness prevention program, OSHA believes that IIPP provides the foundation for major improvements in the way employers identify and control hazards, OSHA states that they expect widespread implementation of IIPP will significantly improve workplace health and safety, and reduce workplace injuries, illnesses and fatalities. Another benefit OSHA predicts is that IIPP will result in better compliance with existing regulations and this will result in reduced costs, including significant reductions in workers' compensation premiums.
What Is An Injury and Illness Prevention Program?
California has required all employers to have an injury and illness prevention program since 1991. They require that the IIPP be written and include the following:
- Management commitment and assignment of responsibilities
- Describe the safety communications system with employees
- A system for assuring employee compliance with safe work practices
- Scheduled inspections and system evaluation
- Accident investigation
- Procedures for correcting unsafe and unhealthy conditions
- Safety and health training and instruction; and
- Recordkeeping and documentation
Most successful injury and illness prevention programs include a similar set of elements. The goal is to:
- Find all hazards in the workplace
- Develop a plan for preventing and controlling hazards
- Have management involvement and leadership
- Have active worker participation
- Have workers trained so they know how IIPP works; and
- Have a periodic evaluation of the IIPP to identify areas that can be improved
It is important to recognize that every business is different. IIPP is not a one size fits all type of program. The elements of each injury and illness prevention program should be tailored to be appropriate for the location. Employers who implement injury and illness prevention programs scale and adapt these elements to meet the needs of their organizations, depending on size, industry sector or complexity of operations.
Is IIPP A New OSHA Hazard Regulation?
No. The coming IIPP standard is not a new hazard regulation. What the OSHA Injury and Illness Prevention Program standard will do is require that employers have a written program that establishes how they will find and fix hazards in their workplaces.
There has been a concern that a new federal IIPP standard will open the door for OSHA to cite employers for not addressing hazards that are not covered by OSHA standards but are identified by the employer in their IIPP. OSHA points out that they already can cite employers under the General Duty Clause for recognized hazards, that could have been abated, and for which OSHA does not have standards. In addition, OSHA says that they probably will also cite employers for not complying with the IIPP they have established.
What is the most cited violation in regard to IIPP? In California, the most cited IIPP violation is also the #1 general reason for a citation being issued. The official citation is titled: “No IIPP developed in writing and implemented.” It is a citation for not having an IIPP. In addition to requiring that every workplace have an IIPP, California also requires some types of employers to meet specific requirements for what is to be included in an IIPP. Employers may be cited for not having an IIPP that meets the California requirements.
Will the OSHA IIPP Requirements Be Similar to California's?
Many people are advocating that OSHA adopt an injury and illness prevention program that is similar to the one used by California. A RAND study of IIPP in California found that when it was properly implemented, it was effective in reducing injury rates. However, at the time of this writing, the details of what OSHA is planning are not known, although it appears the OSHA standard will include significantly higher fines than those established in California. OSHA has expressed their concern that the fines be sufficiently high such that they cannot be considered a cost of doing business, should an employer choose to not comply with the IIPP requirements.
What If I Already Have An Injury and Illness Prevention Program In Place?
Many businesses have already seen the benefits of IIPP and have effective injury and illness prevention programs in place. OSHA has said that it is not their intention to force employers to make unnecessary changes if they already have IIPP programs that meet the OSHA requirements. The plan for IIPP is to make the new requirements flexible enough so that existing IIPP programs can continue uninterrupted.
Are Injury And Illness Prevention Programs Too Expensive for Small Businesses?
After implementing IIPP in California it was noticed that many employers, especially small businesses, did not have the expertise needed to develop an effective IIPP. They had to spend thousands of dollars to hire a consultant who would develop an IIPP plan for them. In addition, employers in low-hazard industries such as real estate offices, and businesses that only operated seasonally saw little justification for the cost of developing an IIPP.
The Council on California Competitiveness determined that IIPP in California was:
…imposing unnecessary and unproductive costs on many businesses for which application of the program makes little sense. Literally millions of dollars in needless hard costs and lost productivity will result from the current application of this program to businesses whose work environments pose virtually no risk to the safety of their employees.
…the Ohio Bureau of Workers' Compensation (2011) analyzed the policies of 16 SHARP employers over a 12-year period from 1999 to 2010. The study compared the employers' experience prior to and after achieving entry into the SHARP program. The preliminary results of the study show that the average number of claims for these employers decreased by 52 percent, the average claim cost decreased by 80 percent, the average lost time per claim decreased by 87 percent, and claims (per million dollars of payroll) decreased by 88 percent.
Injury and Illness Prevention Programs - SHARP
OSHA's has an existing voluntary program for small business that incorporates IIPP called the Safety and Health Achievement Recognition Program (SHARP). The results from SHARP show that IIPP in small businesses has been effective. For example, OSHA reports that:
Injury and Illness Prevention Programs - Visual Communication
Signs and labels visually communicate needed information in any environment and under all types of conditions. They warn employees about hazards and inform them about required protective measures. They remind employees to immediately report any new hazards they spot. They guide employees to ensure proper maintenance and operation of equipment, helping to ensure the safe operation of machinery and equipment. Some signs deliver their messages when the lights go out and no source of illumination is available. Some labels and signs need to survive daily wash-downs and cleaning. All of these require tough, durable labels and signs, such as those made by DuraLabel printers.
Whatever your label and sign requirements, DuraLabel has the answer. They've been in the industrial labeling business since 1971, and have developed unique printers and tough-tested supplies that get the job done right, so you don't need to worry about having durable visual communication.
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