Ensure IIPP is Available to Employees
California's law requiring employers to maintain a written Injury and Illness Prevention Plan ("IIPP") was adopted over thirty years ago. Under this requirement, employers must proactively identify and develop plans to mitigate workplace dangers, regularly updating the IIPP if conditions change.
Effective January 1, 2021, employers must now make their IIPP available to employees or their labor representatives (i.e., union) within five days of a request. This must be satisfied by providing a written copy unless the requestor agrees to accept an electronic version. Initial copies must be free. Alternatively, the program can be maintained on an employer's electronic resources so long as employees regularly use the system to communicate with management. Employees must be advised of their right and the procedure to request review of IIPP materials (which is best distributed in the employee handbook).
The chief benefit of this change is to remind employers that IIPPs are not "set and forget" programs. Management should review and revise their programs regularly and keep copies readily available for employee (and Cal-OSHA) review.