Do you have a Safety Plan (IIPP)? Is it Covid-19 Compliant?
Tip: Make sure your UPDATED IIPP is in compliance with the new Covid-19 Regulations.
- Requirement: An Employer is required to have a written safety plan – an IIPP- Injury & Illness Prevention Plan (Cal. Code of Regulations Section 3203).
- Safety Plan: The safety plan must be a written document. It must also be is available to all employees to review, especially Managers in charge of implementing the safety regulations. An employer need not provide a written copy to all its employees. But, the safety plan should be readily available at the job site or on-line, or preferably both.
- Safety Meetings: The contents of your Company IIPP should be communicated to all employees, either in writing or orally, during safety meetings. Safety Meetings with your employees should be conducted regularly. The frequency of Safety Meetings depends on your particular Industry.
- Preparing/Revising a Safety Plan: An attorney can prepare an IIPP for you. However, you may be able to obtain a generic copy from your workers’ compensation Insurance Company at no cost. Then, you must customize it to your Company.
- Then, if you need assistance, you can ask an employment attorney to review it and provide you with advice on the best way to implement the policy. If you need help, please let us know.
- In addition to our Employment law Attorney, we work with a safety regulation Company. This Company can perform a Safety inspection and/or Audit for you at a reasonable rate. This will help you determine if you are in compliance before you have a Cal-OSHA inspection.
- Inspection: During every inspection conducted by Cal/OSHA the inspector will ask to review a copy of the employer’s IIPP – Safety Plan. Failing to have an IIPP is the most common citation issued by Cal/OSHA. The citation for this violation can be $500 or greater.
GOV’T RESOURCES:
- Cal/OSHA and OSHA guidance (dictates how to implement safety from COVID-19 exposure at work). https://dir.ca.gov/dosh/coronavirus/Health-Care-General-Industry.html
and Federal DOL – OSHA: https://www.osha.gov/SLTC/covid-19/ - Disinfecting: https://www.cdc.gov/coronavirus/2019-ncov/community/pdf/ReOpening_America_Cleaning_Disinfection_Decision_Tool.pdf and
https://www.cdc.gov/coronavirus/2019-ncov/community/pdf/Reopening_America_Guidance.pdf
NOTE: Each Month we will provide a Legal related “Tip” on various subjects. While these tips cannot take the place of legal advice from an attorney, as they are general in nature, they will provide you with some information to review and help you consider whether you may need to seek legal advice, based on your particular situation.