Businesses getting ready to re-open need to consider yet another item on the re-opening checklist: an Injury, Illness and Prevention Plan (IIPP) to address COVID-19. Title 8 of the California Code of Regulations section 3203 requires every employer to develop a written IIPP that protects employees from workplace hazards. Most California workplaces now must consider COVID-19 to be a workplace hazard that employees are exposed to.

Fortunately, the California Department of Industrial Relations Division of Occupational Safety & Health (DOSH), or Cal/OSHA, provides guidance and easy to modify forms and checklists that can help employers create and develop an IIPP that addresses COVID-19:

Step-By-Step Guidance On How To Create Your Own Written IIPP Customized To Your Workplace:

Sample IIPP Forms and Checklists:

Cal/OSHA’s Consultation eTools with Action Kits:

Cal/OSHA’s Guide to Developing Your Workplace Injury and Illness Prevention Program With Checklists For Self-Inspection, describes the employers’ responsibilities in establishing, implementing, maintaining, an IIP Program:

An IIPP has 8 required elements:

  1. Responsibility
  2. Compliance
  3. Communication
  4. Hazard Assessment
  5. Accident/Exposure Investigation
  6. Hazard Correction
  7. Training and Instruction
  8. Recordkeeping

An effective IIPP is not just a paper program. For your IIPP to be effective, Cal/OSHA identifies four items to put into practice in your workplace:

  • Fully involve all employees, supervisors, and management
  • Identify the specific workplace hazards employees are exposed to
  • Correct identified hazards in an appropriate and timely manner
  • Provide effective training

Your workplace assessment needs to identify the workplace hazards posed by COVID-19 and measures to prevent or reduce the spread of the virus based on your operations. Basic measures that all employers should asses and implement are: cleaning and disinfecting; good hand hygiene; when and what PPE is needed or appropriate; physical distancing; and training employees on COVID-19 infection prevention methods. Implementing your prevention measures could incorporate CDC, OSHA, state and local guidelines and orders. Good sources to incorporate into the written IIP Plan include:

Cal/OSHA Guidance on Requirements to Protect Workers from Coronavirus:

Federal OSHA Guidance on Preparing Workplaces for COVID-19 publication

Identifies different Coronavirus-related risk categories for workers, including higher-risk industries, and provides specific guidance for workplace safety for those industries.

Los Angeles County Social Distancing Protocol:

As with everything related to this pandemic, be vigilant in keeping up-to-date on evolving rules and guidance, and modify your IIPP, as needed. We will continue to provide updates on COVID-19 issues impacting the workplace.