A Safety Management Approach

Bob Lapidus, CSP, CSMS

My colleagues and I do 100 to 200 safety surveys annually for a variety of organizations. Currently, we are targeting those entities with an Experience Modification of 1.19 and above, and over the last five years have sustained three or more serious injuries (incurred losses of over $10,000 per injury), and a frequency of more than ten occupational injuries or illnesses during that same time period.

We are finding that these high-loss establishments either do not have an Injury & Illness Prevention Program (IIPP) or the program in place has not been fully implemented.

These high-loss organizations do not have a foundational safety program in place comprising the following functions of the required IIPP:

  • Establishing responsibilities
  • Including activities that provide compliance or accountability systems
  • Communicating safety-related information
  • Inspecting workplace facilities and operations
  • Investigating accidents and injuries
  • Correcting identified safety problems
  • Training employees on how to do their tasks in a safe manner
  • Recording all safety activities as well as occupational injuries and illnesses

Surprising, some managers in these organizations do not know what an IIPP is or from whence it came. Adopted and implemented by Cal/OSHA in 1991 (25 years ago), California was the first state to require its employers to have a foundational safety program in place. The eight functions required establish a comprehensive basic safety program. See Title 8, Section 3203 for the IIPP requirements.

Of the eight required IIPP functions, the one that stands out from the rest in our safety visits is the lack of occupational injury and illness investigations. Most of these entities file the appropriate workers’ compensation forms, but beyond that, no thought goes into what caused the specific event to occur. Consequently, no action is being taken to prevent the same kind of incident to occur again. They are not learning anything from their negative events.

Interesting about the IIPP is the fact that not having one is normally considered by Cal/OSHA to be a general violation, a relatively low-cost penalty citation. On the other hand, if Cal/OSHA comes into an organization due to a severe injury or illness, and the Cal/OSHA inspector finds that the entity does not have an IIPP in place, the lack of the program can generate a serious violation, starting at about $18,000 and going up from there. Cal/OSHA considers the lack of an IIPP where a serious injury has been sustained, as a critical fault on the part of the employer.

For More Information
To become part of discussion on topics like the one above, go to www.safetycenter.org to obtain information about Safety Center’s Safety Management Specialist Certificate.

After completing this nine-day program, graduates may take the exam to achieve the Certified Safety Management Specialist (CSMS) designation.  Recipients of the CSMS receive a beautiful plaque and become part of an elite group of safety specialists who have achieved this recognition.  Once this certification is attained, successful candidates keep it for the rest of their lives without any additional requirements or fees.

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