Printing Operations in California Must Now Share Their Injury and Illness Plans with Employees

California is one of the states that has a state specific Occupational Safety and Health agency authorized by the Federal Occupational Safety and Health Administration to develop and enforce their own safety regulations. The agency is known as Cal/OSHA is required to adopt all federal safety regulations but can be more stringent and set their own requirements if one does not exist at the federal level.

One such regulation is the state's Injury and Illness Prevention Program (IIPP). The IIPP regulation requires all businesses in California, regardless of size or industry, to develop a formal written plan. Essentially, an IIPP program is a written workplace safety program that must include the following essential elements:

•Identify the person or persons with authority and responsibility for implementing the safety program.
•Include a system for ensuring that employees comply with safe and healthy work practices.
•Include a system for communicating with employees on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the work site without fear of reprisal.
•Include procedures for identifying and evaluating workplace hazards, including scheduled periodic inspections to identify unsafe conditions and work practices.
•Include a procedure to investigate occupational injury or occupational illness.
•Include methods and/or procedures for correcting unsafe or unhealthy conditions, work practices and work procedures in a timely manner.
•Provide training and instruction to all new employees, to all employees given new job assignments for which training has not previously been received, whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard, and whenever the employer is made aware of a new or previously unrecognized hazard.
•Train supervisors to familiarize themselves with the safety and health hazards to which employees under their immediate direction and control may be exposed.

Cal/OSHA has a web page with a model plan that can be used to develop or enhance an existing one.

Effective July 1, 2020, California employers will need to provide access to their IIPPs upon request of an employee, the employee’s authorized representative (e.g. an attorney), or the employee’s union representative. Previously there was no requirement under Cal/OSHA to provide access to IIPPs. Companies need to comply with the request within 5 business days.

Employers have two options to comply with the standard. First, they can provide requesting employees with a printed or electronic copy of the program. Second, in lieu of providing a copy of the program, employers can also allow employees “unobstructed access through a company server or website, which allows an employee to review, print, and email the current version of the Program.”


For more information on this issue, or if you have additional questions, please contact PRINTING United Alliance’s Government and Regulatory Affairs department at govtaffairs@sgia.org.