Ever since I dipped my pinky toe into the waters of safety there has been an ongoing battle among safety professionals and risk managers alike as to whether the IIPP should be part of a larger safety manual or if it should remain a standalone document. For the past 20 years, I have advocated that IIPP’s should be standalone documents for a variety of reasons. Reasons that can result in thousands upon thousands of dollars in savings. And today OSHA proved my argument once again. So, why would you want your IIPP to be separate and distinct from your Safety Manual? Let’s take a look.
Nail # 1 – You can never write a compliant program.
There is one thing for certain, I have rarely seen a written safety program that an OSHA inspector cannot find something wrong with. And IIPP’s are no exception. In California, the IIPP is a requirement under Title 8, Section 3203. It’s a simple requirement. One that should be very easy to comply with. In fact, there are technically only eight elements to the plan; however, most safety professionals will tell you that there are only seven elements. Makes for a great interview question. The eight element is Records of the Steps Taken to implement and maintain the Program.
And therein lies the problem with injury illness prevention plans. Nobody, not even the professionals, seem to know what is going on or how to make a compliant plan. If you can’t get this program correct, then why would you want to include 20 additional plans for OSHA stew over?
Nail # 2 – You only spent a few days writing the program.
The fact of the matter is that our to-do lists are overflowing and there just isn’t enough time in the day to write a thorough safety program. I know, but you are paid to. Most of us will browse the Internet for sample plans which were also written by overwhelmed staff members who are charged with safety. If were lucky, we might find a plan that was written by a true safety professional.
In most cases, we gloss over the regulations to find the most important elements and then write our plan to comply with those elements. We assign individuals to be administrators of the programs and fail to obtain their signature on the finalized program – and easy citation. We never run our finalized written programs by other safety professionals, risk managers, or even Cal OSHA consultation. As the old adage goes-we rushed to errors.
Nail # 3 – You are a team of one.
As I referred to in number two, you are a single safety professional and don’t have a team to help you write policies are review policies. Once you hand over your written IIPP document to OSHA they have six months to review the program. They also have a team of OSHA inspectors and specialist that focus on the details of IIPP’s and other safety programs. They’ve looked over hundreds, if not thousands, of IIPP’s and know what the common errors are and how to find holes in your program. You don’t have the luxury of time, strength in numbers, or financial resources to spend ensuring that your IIPP is compliant.
Nail # 4 – Your program is never effective.
Once an injury occurs, your program has ceased to be effective. I hear this all the time from OSHA inspectors. “Your training is not effective.” How on earth do you dispel that statement? Can you? Is the fact that 99 other people took the training and did not get injured proof that your training is effective. Not in the eyes of OSHA. One injury is one too many. And that means ineffective. Read how to beat this logic.
The final nail
You are simply going to be wrong and will be cited for something. So if you are going to be wrong in the eyes of OSHA, do you want to be wrong once or 27 times. Each of the four nails above relate to every written safety program that you hand over to OSHA. They have 6 months to review your programs and will find holes, gaps, training that wasn’t provided, inspections that were never done, updates that never happened and the like. Do like a good risk manager and use segregation and separation to your advantage. If OSHA wants to see your heat illness plan, give them that alone. Not heat illness, bloodborne pathogens and the other 25 policies you have.