Putting together an injury and illness prevention plan (IIPP) can be a daunting task, especially if you’ve never done it before. An IIPP can also be a great learning tool. It also exposes risk areas at your place of business that you may not have considered before. An IIPP not only keeps you in compliance with OSHA standards, but it’s also a great way to assess risk areas at your business and correct them before they are a problem. Being proactive and correcting potential hazards before they are full blown incidents keeps your workers’ compensation claims down and keeps your mod rates low. Lower industry mod rates can mean substantial savings on workers compensation insurance rates.
Not sure where to start with the creation of an IIPP? You’re not alone. Kamm Insurance Group has assembled a few tips to get you started.
First of all, why do you need a written IIPP? Because it’s required.
OSHA requires an IIPP for any business with 11 or more employees. OSHA also requires training on many of the areas included in an IIPP. Besides the legal requirement, an IIPP gets you closer to a safety and risk management program that is meaningful to your workplace, and its specific operations.
Consider near-miss data as a starting place for obvious hazards.
Go through your past OSHA-300 logs to get a sense of the risk management gaps.
- Investigate a near-miss, the same as you would an incident.
- Have an open discussion and investigation into what happened. Don’t blame.
- Gather facts. Look for the root cause of the near-miss. The root cause might be something simple. Correct it.
Scenario: An area rug in the lounge often curls up at the edge. Employees have tripped several times, but no one has actually fallen or injured themselves.
Solution: Don’t ignore the near-miss and wait for it to become a full-blown incident. Tape down the edges of the rug or replace the rug altogether. This simple fix can save thousands of dollars in a slip, trip or fall claim.
About Recordkeeping: Many businesses are required to maintain OSHA 300 logs or OSHA-equivalent records. Workers’ compensation records are not equivalent to the OSHA 300 logs, and contain private information that must be redacted for OSHA recordkeeping purposes. The two systems are separate. OSHA uses the North American Industry Classification System (NAICS) to determine industries required to maintain OSHA logs. Find your industry NAISC here.
Do not try to complete an IIPP alone.
Enlist others such as direct-line staff, supervisors and upper management. Form a safety committee with these key employees and make the IIPP your first project. Ask your team a few simple questions:
- What are we doing now?
- What works? What doesn’t work?
- What are our safety goals?
Review incident reports on file or request your organization’s insurance claims/loss runs.
These will help you gain a sense of what’s happening at your business. Claims, incident reports and near-misses can reveal a lot of information about safety issues and potential incidents. Avoiding one serious injury will deliver an immediate return on investment in training and employee time, not to mention the benefits of avoiding lost work, medical bills, potential OSHA penalties and increased insurance rates. Workplaces that put a premium on safety have a happier workforce and less turnover. It truly pays to face mistakes and learn from them. (Click to view the estimated costs of workplace injuries.)
A walk-through is a great place to start your safety & risk evaluation.
You probably walk around your business every day. This time, do a walk-around with your team and approach the walk from a safety hazard perspective.
- Don’t judge! Look at every aspect with a new eye for safety and do not place blame on others. This is a team effort to make your workplace safer. Everyone’s intent is to learn and improve.
- Bring a checklist as a guideline. Make the checklist your own and be honest about what you see on the walk.
- Look for hazards present in each job area as well as hazards present within each job process.
- Even office jobs have hazards, such as ergonomics, chemical/cleaning supply exposures, ladders, first aid, fire extinguisher use and safety exits. More is discussed below.
- Do you have a chemical inventory list for all hazardous chemicals onsite?
- Do you have each chemical’s safety data sheet (SDS) on file? Does your staff know where to find them and how to read them?
- Have you reviewed the importance of machine guarding, golf car governors, PPE and fall protection systems?
- What about training on hand tools, grinders, chain saws, chippers, tree trimming, gutter cleaning and any work involving ladders?
- Consider needle stick hazards or using universal precaution when handling laundry, trash and clean-ups.
Offices have hazards and risk areas.
Don’t ignore your office areas and office workers. Look at your workplace as a whole entity, not just as “safe” or “unsafe areas.”
- Consider ergonomics, computer security, slips/trips/falls, ladder safety, chemical safety, first aid, evacuation plans, bloodborne pathogens and workplace violence.
- Does your office staff know what a lockout/tagout device looks like? If not, there is a chance someone might remove the lock/tag and power up a device accidentally which could lead to electrocution or loss of an appendage.
- Behavior-based training gets people thinking about safety. Ladders or standing on chairs as ladders pose a fall risk. Loose cords and open file cabinets cause trips/falls and struck-by incidents. Improper use of cleansers and chemicals can cause toxic fumes.
- Office workers are a part the same team. By training everyone on the importance of safety and hazard recognition, you instill vigilance across all departments.
Potential hazards are everywhere? Yes.
Understanding the job roles and tasks associated with a job are part of a hazard assessment. From office workers to maintenance crews, hazards are everywhere.
A written IIPP can also help you with your Emergency Action Plan (EAP).
An EAP is also required by OSHA. For example:
Does your workplace have a fire safety plan?
Have you staged fire drills and trained workers on how to use a fire extinguisher?
Call your local fire department. Schedule a proactive inspection. They may even assist you with a mock drill and a debriefing on areas for improvement.
Do you know what the alarms sound like at your workplace? Do you know what specific emergency each alarm sound signals? (A fire alarm may sound different than a tornado alarm. You would not exit the building in a tornado, but you would a fire.)
What about weather emergencies?
How will you communicate during these emergencies?
Have you made exit plans for disabled persons in your employ?
Do you or your staff know what to do to sustain life-saving efforts while EMS is on the way? Training on CPR, First Aid. Heat Illness and rescue planning for Confined Space Permit Entry are important for these.
These are only a few things to consider when assembling a comprehensive safety and risk management plan.
Train – and retrain – your staff on the IIPP you’ve developed.
An IIPP is useless without training, communication, rehearsing and retraining.
Use your IIPP as a blueprint to train your staff. Kamm Insurance Group has online safety and compliance training to cover most areas of your IIPP. There’s a lot to sort out. We can help you on your way to risk mitigation and a safer workplace.
Kamm Insurance Group is your partner in risk.
Contact Rebecca Little, MLIS, OSHA-Authorized Trainer for more information on training and risk programs.