OSHA IIPP: What to Expect from an Audit

By law, the Occupational Health and Safety Administration (OSHA) is required to make unannounced Injury and Illness Prevention Program (IIPP) audits of companies, including commercial construction contractor businesses.

The audit is performed to ensure that employers provide and maintain safe working environments for employees. Errors reported in the audit result in fines.

In accordance with both state and federal law, every employer is responsible for workplace safety by means of maintaining an IIPP.

“The IIPP is a program that clearly states the responsibilities employers and employees must undertake to prevent accidents and losses in writing. Because safety is everyone’s responsibility, the IIPP should be easily accessible regardless of your role in the company,” said Jerry Bach, vice president and an instructor at the Safety Center Incorporated.

In evaluating the IIPP, auditors should ask employers and employees the following:

• Who manages the IIPP program and who is the most involved and responsible?
• To whom are you supposed to report a safety complaint if you have one?
• Are safety meetings held? How often are they held?
• When was the last time there was an accident or near-miss incident here?
• Did management investigate the accident themselves?
• What did they do with the information?
• What changes resulted from the accident?

“Even if an employer believes  his or her workplace is safe from hazards, the slightest error in IIPP recordkeeping may incur major fines,” Bach warns.

 According to OSHA construction industry guidelines, fines for serious violations can be as high as $25,000, with an initial base penalty of $18,000. Failure to correct an OSHA violation can result in fines as high as $15,000 for each day the violating condition goes uncorrected.

“Maintaining an effective IIPP program will save money because accidents cost money. For every dollar you spend on the direct costs of a worker’s injury or illness, you will spend much more to cover the indirect and hidden cost,” Bach said.

The key to avoiding costs and ensuring that employees return home safely every evening lies in the following eight core elements of an IIPP:

• Responsibility
• Compliance
• Communication
• Hazard assessment
• Hazard correction
• Accident investigation
• Training
• Recordkeeping

Responsibility

Ideally, everyone within the contractor organization is responsible for safety. An effective IIPP is one in which safety responsibility is delegated throughout a contractor organization from top to bottom. During an audit, contractors and their employees should expect to be asked who is responsible for safety.

“OSHA auditors will want to know how foremen and superintendents train employees to recognize and respond to hazards, identify causes of accidents and identify how accidents are being preventing,” Bach said.

Supervisors represent the management team or agency, and their actions are viewed as representative of management at all times. They must be role models for safety.

Compliance

The element of compliance focuses heavily on how a safety discipline and reward system is outlined in an IIPP.

“OSHA auditors will ask for a discipline plan in an IIPP to see how a contractor company handles employees who either violate or comply with safety regulations,” Bach said.

A sound safety discipline and reward system directly reveals how much an employer values his/her employees and safety compliance.

“Compliance to safety regulations boosts morale, and thus enables more productivity in the workplace,” Bach said.

Communication

Communication, regardless of work environment, is always crucial to preventing injury or illness. In the construction work environment, an effective IIPP must include formal training, worksite demonstrations and effective tailgate/safety meeting sessions, one-on-one communication and safety committees. Signage, flyers, a suggestion box and safety bulletins are all acceptable means of communication.

Hazard Assessment

Construction workers are exposed to toxic agents, have higher death rates from cancer and have a high risk of hearing loss, so it is important to remain aware of hazards at the worksite. Hazard assessment skills should be fully employed while working with paints, cleaners, acids, glue, urethanes, wood, fiberglass, cement, silica, welding, noise, heat stress, confined spaces and lasers.

Hazard Correction

A hazard should be corrected at first observation. When an imminent hazard cannot be immediately abated without endangering employees or property, an employer should remove all exposed personnel and provide all necessary personal protective equipment to guard the face and eyes, feet, hands, body, hearing, head and respiratory function of necessary personnel.

Accident Investigation

Accidents are most likely to happen when unsafe acts occur and when unsafe conditions are present. An unsafe act is defined as failure to comply with an IIPP, operating equipment unsafely, using unsafe tools, unsafe industry work practice and a lack of hazard recognition skills. Physical working conditions include the general environment, equipment, work facilities and ergonomic interaction between the employee and the job.

“Unsafe conditions can be damaged equipment, environmental conditions, poor housekeeping, equipment failure or a lack of equipment maintenance,” Bach said.

A company’s IIPP should have an established procedure to investigate injury and illness. This procedure should investigate the cause, prevent a reoccurrence, develop a best work practices to reduce losses and create effective training opportunities. After the accident investigation, it is important to provide additional training to employees, set goals for reducing accidents, hold management and supervision accountable, increase frequency of inspections to find and fix hazards as well as recognize employees who work safely.

Training

Training should occur when the IIPP is first established, when new substances and equipment represent a new hazard, when there are new job assignments and for all new hires. There are several ways to hold trainings, including supervisory meetings, a formal training program, hands-on demonstrations, effective tailgates, as well as one-on-one and equipment and job-specific training. Refresher training should be performed as a form of prevention, not just after an accident or safety infraction.

Recordkeeping

Records of scheduled and periodic inspections identifying unsafe conditions and work practices should be kept along with documentation of accident investigations and safety and health training. Reports to Cal/OSHA must be made following serious injury or death, blasting or unusual occurrences, construction activities annual permit, asbestos-related work, use of carcinogens or construction involving lead work.

“If you incorporate the eight elements you can successfully avoid fines and maintain a safe working environment for your employees,” Bach said.

Construction Business Owner, December 2008