PART 1:
IIPP, Haz Com, and Emergency Plan compliance basics

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Bureau of Labor & Statistics 2005:
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5,702 workplace deaths in US
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16 workers avg. fatally injured/day
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More than 4.2 million injuries & illnesses reported in private sector
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453 workers fatally injured in
California

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Employee:
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Pain & Suffering
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Loss of Wage
Company:
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Medical/workers’ comp insurance rates
Loss of productivity
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Product/equipment damage
National Safety Council: $27,000 per incident; work-related death $780,000

Gives the agency wide powers in its enforcement activities.
“
Each employer:
1.
shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees
2.
shall comply with occupational safety and health standards promulgated under this act.
(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.”

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Identify, eliminate or minimize hazards.
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Ensure employees obtain required training before beginning work.
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Investigate accidents to determine causal factors, and implement corrective actions.
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Provide supervision to ensure employee compliance with safety rules and procedures.
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Implement disciplinary actions when necessary to correct unsafe work behaviors.

“ Be a Manager, Go to Jail”
California Penal Code, Section 387
Enacted in 1990 by the California legislature. This law is designed to protect workers as well as the public.
Makes organizations and their managers criminally liable when they fail to warn their employees and report to Cal-OSHA the existence of “serious concealed dangers of which the corporation and its managers have actual knowledge…”
Investigations can be long and involved.
Convictions can involve fines and/or imprisonment.

Corporate Criminal Liability Act cont.
Definition of a manager…
A person having both:
1.
Management authority and
2.
Significant responsibility for any aspect of a business including safety of a product/business practice (Employers, directors, management officials, supervisory personnel)
Note: you do not have to have the words
“manager” or “supervisor” in your title for you to be considered as a manager.

Corporate Criminal Liability Act cont.
Definition of a Serious Concealed Danger…
A danger related to a product or business practice, that creates a substantial probability of death, great bodily harm, or serious exposure to an individual.

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State agencies, such as Universities and Colleges become subject to OSHA fines starting January
2000.
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Proposed penalties increased from less than $1 million in 1999 to over $29 million in 2006.
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Employers criminally prosecuted for workplace accidents (recent: 9-year prison term; probation + high six-figure penalty).
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Calif. Supreme Court ruling:
Cal/OSHA standards are admissible in any civil proceedings to define standard of care in negligence lawsuits.

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Death or serious injury
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Employee complaint (can be anonymous)
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Another agency referral
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Recognized high hazard industry
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Random inspection
Important note: If you are visited by an OSHA enforcement officer, do not turn them away. Ask them to wait and contact EH&S immediately for assistance.

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The IIPP is the “umbrella” safety program that details how the organization will protect employees from hazards in the workplace.
The University has a campus-wide
IIPP, and most departments have their own departmental IIPP.

Check with your department safety coordinator to see if a departmental
IIPP has already been established.

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Responsibility
Compliance
Communication
Hazard Assessment
Accident/Exposure Investigation
Hazard Correction
Training and Instruction
Recordkeeping
The next few slides will provide information regarding
each component.

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Who is the
Program
Administrator?

Usually the individual at the highest level.
Who is charged with the responsibility for maintaining the
IIPP?
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How will compliance be assured?
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Providing info and training to employees
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Evaluating safety performance

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How will your department handle communication with employees about safety?
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Handouts
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Posters
Emails
Face-to-face discussions/training
Meetings
On-line training

Methods for discovering and correcting hazards in the workplace…
For task/job hazards:
Job Safety Analysis (JSA)
Usually completed by the Supervisor, unless assigned to subordinate.
For work environment hazards:
Job site inspections:
Find hazards and eliminate or minimize them before the job is performed!
Misc. hazards:
Accident Investigations
Employee reports:
Employees should be encouraged to report hazards to the supervisor or EH&S as soon as possible. Form is available for employees to do this anonymously.

Which jobs/tasks to pick first?
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Set priorities based on:
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Review job description/duties
Jobs or tasks that have caused accidents.
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Jobs or tasks involving near-misses.
New jobs.
Jobs that have undergone changes in procedures, processes, or equipment.

Other considerations when prioritizing:
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Industry information
OSHA High Hazard listing
OSHA regulations specific to the work

How do you complete a JSA?
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Involve the employees who complete the work and their supervisors
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Break tasks into sequence of steps or movements
Identify the potential hazards associated with each step
Recommend Action or Procedure to eliminate or minimize each identified hazard

What’s next?
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Share completed JSAs w/ supervisor and employee
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Implement recommendations to minimize/eliminate identified hazards
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Engineering controls
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Administrative controls
Personal protective equipment
Develop procedures and train employees
Keep a file of all JSAs
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Periodically review for new tasks/hazards

Keep this in mind when choosing control solutions for identified hazards .
Your ability to control hazards decreases as you go down the following list of solutions…
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Substitution/Elimination
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Engineering
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Administration
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Personal Protective Equipment

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Substitution/Elimination

Can the work be completed in a way that the hazard can be completely eliminated?
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Can you replace the hazard with something less hazardous, and still get the job done?
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Example: replace a organic solvent cleaner with an non-toxic citrus-based cleaner.

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Administration
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Can you limit employee exposure through scheduling of work?
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Example: Can you limit the amount of time employee is exposed using the employee’s work schedule?
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Watch out for the need for administration pitfalls!
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Workload requiring extra work time
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Peer absences

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Engineering
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Can the hazard be eliminated or mitigated through remodeling/revamping equipment?
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Example: Surround a process that creates loud noise with a sounddampening enclosure.

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Personal Protective Equipment
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Unpopular with employees, often uncomfortable.
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Requires increased level of supervision to ensure proper use and maintenance.

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Complete regular job site inspections.
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Frequency will depend on level of safety hazards.
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Most administrative office spaces need only an annual inspection.
Labs: monthly/quarterly
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Construction/mfg: daily/weekly

(Note: EH&S will be assisting with this process)
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Procedures for investigating incidents include:
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Interview injured employees and witnesses.
Examine the workplace for causal factors.
Take corrective action to prevent reoccurrance.
Record the findings and actions taken.

…
Must be done in a timely manner…
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When observed or discovered; and
If the hazard can’t be fixed in a timely manner, determine if:
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 the piece of equipment should be tagged out “unsafe – do not use” employees need to be removed from the area until it is safe to return.

Common threads leading to injuries:
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Lack of knowledge
Unfamiliarity with equipment
Incorrect performance of task
Training and proper supervision to ensure tasks are completed properly can reduce the risk of injury.

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Step 1: Determine which training is necessary .
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Complete a Job Safety Analysis.
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Ask employees to describe job procedures.
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Observe employees as they work. Ask questions.
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Review accident reports/records
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Consult with EH&S Workers’ Compensation Coordinator regarding previous injury statistics in your department
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Review industry information
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Are there practices or operations that have not led to accidents in your organization, but have led to accidents elsewhere (other departments, other Universities)?

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Step 2: Determine scope of training.
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All employees
Employees in a particular workspace
Employees who work with or near hazardous chemicals or substances
Employees who work with or near a hazardous piece of equipment
Supervisors

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Step 3: Identify goals and objectives
Step 4: Conduct the training and collect/maintain documentation.
Step 5: Provide refreshers as needed

.
1.
2.
3.
Every employee must receive training regarding:
4.
5.
The existence of the campus IIPP
The departmental IIPP
The department Emergency Plan and campus emergency and evacuation procedures.
Hazard Communication (Chemicals)
Job Specific hazard training
This training should be completed before beginning work .

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1. Existence of campus IIPP
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Provide a link to the campus plan so that they may download it.
http://www.csufresno.edu/ehs/policies.htm
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Questions about the campus plan should be directed to EH&S

2. Departmental IIPP
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Review all components of the departmental IIPP with the employee.
Provide employee with a copy.

cont.
3.
Department Emergency Plan
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Review & provide a copy of your department emergency plan.
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Emergency escape procedures/routes
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Preferred means for reporting fires/other emergencies
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Names/job titles of ees/departments to contact for further info
If applicable: procedures to be followed by ees remaining to operate critical operations before evacuating
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If applicable: rescue/medical duties for key ees

cont.
3.
Emergency and Evacuation Procedures
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Provide link to campus emergency procedures handbook.
http://www.csufresno.edu/police/emergenc y.htm
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Have the employee complete the
Campus Emergency Evacuation
PowerPoint training.

4. Hazard Communication
Every employee has a “Right to Know” about chemicals.
The Hazard Communication Standard
(HazCom) was created by Cal-OSHA to provide individuals with information about the chemical hazards on the job, and how to protect themselves against those hazards.

Chemicals are hazardous if they:
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Cause acute health problems
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(such as corrosives that can burn eyes or skin)
Cause chronic health problems
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(such as toxic chemicals that can cause long-term illnesses, such as cancer)
Suddenly release pressure
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(these explosive chemicals includes gases that could expand violently
Are flammable/combustible
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(chemicals that catch fire easily)
Are reactive
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(these chemicals are not stable, and thus can burn, explode, or release dangerous vapors if exposed to heat, air, water, or particular other chemicals.

The HazCom Standard details threepronged compliance:
1) Chemical manufacturers are required to:
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 determine the physical and health hazards of each product they make. provide detailed container labels and supply Material Safety Data Sheets (MSDS)

2) Employers are required to:
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Make MSDS’s available to employees
Provide employees with training about the
Hazard Communication Standard
Explain how it’s being put into effect in their workplace, including:
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How to recognize, understand and use labels and MSDSs
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Using safe procedures when working with hazardous substances

3) Employees are required to:
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Read labels and MSDS’s
Follow label and MSDS instructions and warnings.

How do I find MSDS’s?
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Look up your chemical at www.msdsonline.com
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Username: csuf
Password: bulldog
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Call the chemical/product manufacturer or distributor.
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“Google” your chemical/product or distributor
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Call EH&S for assistance.

Next steps…
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Complete a chemical inventory.
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Obtain Material Safety Data Sheets
(MSDS) for each chemical used or stored in your department. MSDS’s must be available to the employee.
Ensure that employees receive appropriate training.

Determine the level of training needed
Level 1: High chemical use/exposure potential
(Research/laboratory, Ag or Grounds Maintenance)
Consult with EH&S for training.
Level 2: Medium chemical use/exposure potential
(Plant Operations/Maintenance)
Consult with EH&S to training.
Level 3: Minimal chemical use/exposure potential
(Administrative/Office work/Non-lab teaching)
See outline of necessary training on next slide.

Level 3
Provide training on:
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Location of your MSDS files (must be available to the employee at will)
Right to know law*
Precautions to follow*
How to read labels*
How to read MSDSs*
*
Training handouts available from EH&S

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Document everything. If you don’t have a record of it – it didn’t happen.
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“Training” can be as detailed as a 40-hour class or simply a 5-minute safety talk at the end of a department meeting
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 have everyone sign in for every meeting
If info is distributed via email – keep a copy w/the distribution list
Must attach an outline of the information covered and/or handouts
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Utilize documentation forms already developed

The following documentation forms have been developed for your use:
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Employee safety/emergency procedures training record
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For documenting initial training on IIPP, Emergency procedures, HazCom and Job-specific training
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Safety Training Attendance Record
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For documenting subsequent training
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Safety Committee Meeting (if applicable)
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Report of Unsafe Condition or Hazard
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Provides employees with an anonymous method for reporting hazards.
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Hazard Correction Report
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For documenting corrections to identified/reported hazards.

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Keep up to date with training new employees.
Provide trained employees with refreshers regarding IIPP;
Emergency Plan; Hazard
Communication; job-specific hazards
Review job tasks to determine the need for JSA’s