Safety Communications and Your Injury and Illness Prevention Program

In California every employer has a legal obligation to provide and maintain a safe and healthful workplace for employees, according to the California Occupational Safety and Health Act of 1973. As of 1991, a written, effective Injury and Illness Prevention (IIP) Program is required for every California employer.  Safety Communications plays a big role in this requirement.

Your GDI Insurance Agency, Inc Broker can help you create and keep your IIP Program free of charge. We then will coordinate this plan with your OSHA compliant safety program, which your GDI Insurance Agency Broker will also help you create, manage and implement free of charge.

These programs, besides being required, if used correctly with the help of your GDI broker will help you keep the cost of your workers compensation insurance and modification factor down.

Safety Communications

Your Injury and Illness Prevention Program must include a system for safety communications with employees – in a form readily understandable by all affected employees – on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal.

1. While this section does not require employers to establish labor-management safety and health committees, it is an option you should consider. If you choose to do so, remember that employers who elect to use a labor-management safety and health committee to comply with the safety communications requirements are presumed to be in substantial compliance if the committee: Meets regularly but not less than quarterly.
2. Prepares and makes available to affected employees written records of the safety and health issues discussed at the committee meetings, and maintained for review by the Division upon request.
3. Review results of the periodic scheduled worksite inspections.
4. Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness or exposure to hazardous substances, and where appropriate, submits suggestions to management for the prevention of future incidents.
5. Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, it may conduct its own inspection and investigation to assist in remedial solutions.
6. Submits recommendations to assist in the evaluation of employee safety suggestions.
7. Upon request of the Division, verifies abatement action taken by the employer to abate citations issued by the Division.

If your employees are not represented by an agreement with an organized labor union, and part of your employee population is unionized, the establishment of labor management committees is considerably more complicated. You should request clarification from the Cal/OSHA Consultation Service.

If you elect not to use labor management safety and health committees, be prepared to formalize and document your required system for communicating with employees.

Here are some helpful tips on complying with this difficult section:

• Your communication system must be in a form that is “readily understandable by all affected employees.” This means you should be prepared to communicate with employees in a language they can understand, and if an employee cannot read in any language, you must communicate with him/her orally in a language that is “readily understandable.” Your communication system must be “designed to encourage employees to inform the employer of hazards at the workplace without fear of reprisal.” It must be a two-way system of communication.
• Schedule general employee meetings at which safety is freely and openly discussed by those present. Such, meetings should be regular, scheduled and announced to all employees so that maximum employee attendance can be achieved. Remember to do this for all shifts. Many employers find it cost effective to hold such meetings at shift-change time, with a brief overlap of schedules to accomplish the meetings. If properly planned, effective safety meetings can be held in a 15- to 20-minute time frame. Concentrate on:Occupational accident and injury history at your own worksite, with possible comparisons to other locations in your company.Feedback from the employee group.Guest speakers from your worker’s compensation insurance carrier or other agencies concerned with safety.- Brief audio-visual materials that relate to your industry.
  – Control of the meetings.
  – Stress that the purpose of the meeting is safety.
  – Members of management should attend this meeting.
• Training programs are excellent vehicles for communicating with employees.
• Posters and bulletins can be very effective ways of communicating with employees. Useful materials can be obtained from Cal/OSHA, your workers’ compensation insurance carrier, the National Safety Council or other commercial and public service agencies.
• Newsletters or similar publications devoted to safety are also very effective communication devices. If you cannot devote resources to an entire publication, make safety a featured item in every issue of your company newsletter.
• A safety suggestion box can be used by employees, anonymously if desired, to communicate their concerns to management.
• Publish a brief company safety policy or statement informing all employees that safety is a priority issue with management, and urge employees to actively participate in the program for the common good of all concerned. (Model policy, statements are found in Appendix A.)
• Communicate your concerns about safety to all levels of management.
• Document all communication efforts, as you will be required to demonstrate that a system of effective communication is in place.

Safety Planning, Rules & Work Procedures 

Planning for safety and health is an important part of every business decision, including purchasing, engineering, changes in work processes, and planning for emergencies. Your safety and health planning are effective when your workplace has:

1. Rules written to apply to everyone and addressing areas such as personal protective equipment, appropriate clothing, expected behavior, and emergency procedures. You and your employees should periodically review and update all rules and procedures to make sure they reflect present conditions. Rules and procedures should be written for new exposures when they are introduced into the workplace.
2. Safe and healthful work practices developed for each specific job.
3. Discipline or reward procedures to help assure that safety rules and work procedures are put into practice and enforced. Reward or positive reinforcement procedures such as bonus, incentive or employee recognition programs should provide positive motivation for compliance with safety rules and procedures.
4. A written plan for emergency situations. Your plan must include a list of emergencies that could arise and a
   set of procedures in response to each situation. Some emergency procedures, such as those covering medical emergencies or fire evacuation, are mandated by Cal/OSHA regulations.
5. If you have operations involving hazardous substances, procedures or processes, you must designate emergency response teams to be specifically trained and equipped to handle possible imminent hazards.

Safety & Health Training

Training is one of the most important elements of any IIP Program. It allows employees to learn their jobs properly, brings new ideas into the workplace, reinforces existing ideas and practices and puts your program into action.

Your employees benefit from safety and health training, including safety communications, through fewer work-related injuries and illnesses and reduced stress and worry caused by exposure to hazards.

You benefit from reduced workplace injuries and illnesses, increased productivity, lower costs, higher profits and a more cohesive and dependable work force.

An effective IIP Program includes training for both supervisors and employees. Training for both is required by Cal/OSHA safety orders.

You may need outside professionals to help you develop and conduct your required training program. Help is available from the Cal/ OSHA Consultation Service, your workers’ compensation insurance carrier, private consultants and vendor representatives.

Outside trainers should be considered temporary. Eventually you will need your own in-house training capabilities so you can provide training that is timely and specific to the needs of your workplace and your employees.

To be effective and also meet Cal/OSHA requirements, your training program needs to:

1. Let your supervisors know:
   o They are key figures responsible for establishment and success of your Injury and Illness Prevention Program.
   o The importance of establishing and maintaining safe and healthful working conditions.
   o They are responsible for being familiar with safety and health hazards to which their employees are exposed, how to recognize them, the potential effects these hazards have on the employees, and rules, procedures and work practices for controlling exposure to those hazards.
   o How to convey this information to employees by setting good examples, instructing them, making sure they fully understand and follow safe procedures.
   o How to investigate accidents and take corrective and preventive action.
2. Let your employees know:
   o The success of the company’s Injury and Illness Prevention Program depends on their actions as well as yours.
   o The safe work procedures required for their jobs and how these procedures protect them against exposure.
   o When personal protective equipment is required or needed, how to use it and maintain it in good condition.
   o What to do if emergencies occur in the workplace.

Keeping Your Employees Informed

An effective IIP Program requires proper job performance by everyone in the workplace. As the employer, you must ensure that all employees are knowledgeable about the materials and equipment they are working with, what known hazards are present and how they are controlled.

Each employee needs to understand that:

• No employee is expected to undertake a job until he/she has received instructions on how to do it properly and safely, and is authorized to perform the job.
• No employees should undertake a job that appears to be unsafe.
• No employee should use chemicals without fully understanding their toxic properties and without the knowledge required to work with them safely.
• Mechanical safeguards must always be in place and kept in place.
• Employees are to report to a superior or designated individual all unsafe conditions encountered during work.
• Any work-related injury or illness suffered, however slight, must be reported to management at once.
• Personal protective equipment must be used when and where required, and properly maintained.

Your supervisors must recognize that they are the primary safety trainers in your organization. Encourage and help them by providing supervisory training. Many community colleges offer management training courses at little or no cost.

You as the employer are required under Cal/ OSHA standards to establish and carry out a formal training program. A professional training person, an outside consultant or your supervisors may provide injury and illness prevention training to your employees.

This program must, at a minimum, provide training and instruction:

• To all employees when your program is first established.
• To all new employees.
• To all employees given new job assignments for which training has not been previously received.
• Whenever new substances, processes, procedures or equipment are introduced to the workplace and present a new hazard.
• Whenever you or your supervisors are made aware of a new or previously unrecognized hazard.
• For all supervisors to assure they are familiar with the safety and health hazards to which employees under their immediate direction and control may be exposed.

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