California Workplace Safety & the IIPP (Cal/OSHA)

Cal/OSHA requires every California employer to establish, implement, and maintain an effective Injury and Illness Prevention Program. No exception relieves any employer of having the program. The relief from maintaining a fully written program is at fewer than 20 employees, and only for an employer in an industry not on the Department's designated high-hazard list and with a workers' compensation experience modification rate of 1.1 or less, or for an employer under 20 in a designated low-hazard industry. That employer still documents three things in writing — who is responsible for the program, a record of periodic inspections, and a record of employee training (Lab. Code §6401.7(e)(2); 8 CCR §3203(b)(2) Exception No. 3). Local governmental entities — counties, cities, cities and counties, districts, and public or quasi-public corporations or agencies (including joint-powers entities), but not state agencies — need not keep any of these records at all, regardless of size (8 CCR §3203(b)(2) Exception No. 4).

• 1. Responsibility — who has authority for the program;
• 2. Compliance — how you ensure safe work practices;
• 3. Communication — a two-way system employees can use without fear of reprisal;
• 4. Hazard assessment — scheduled inspections and identification;
• 5. Accident/exposure investigation;
• 6. Hazard correction — timely abatement;
• 7. Training — on general and job-specific hazards;
• 8. Employee access — you must allow employees to examine and receive a copy of the Program, on request, and an employee may authorise a designated representative in writing to do so (a recognised bargaining agent counts automatically).

Recordkeeping is a real duty but it is not element 8 — it sits separately at 8 CCR §3203(b), which requires records of inspections and of training.

• Heat-illness prevention — outdoor (8 CCR §3395): water, shade, preventative cool-down rest, and acclimatization. §3395 applies to outdoor places of employment only. Its high-heat procedures (subsection (e)) are narrower still — they reach only agriculture, construction, landscaping, oil and gas extraction, and certain transportation or delivery work.
• Heat-illness prevention — indoor (8 CCR §3396): indoor workplaces are covered by a separate regulation, not by §3395. If you have indoor work areas that get hot, check §3396 on its own terms.
• Workplace Violence Prevention Plan (SB 553, Labor Code §6401.9): most employers must maintain a written plan, a violent-incident log, and training.

Maintain the OSHA 300/300A injury logs and post the 300A summary from February 1 to April 30. A serious injury, illness, or death must be reported to Cal/OSHA immediately (Labor Code §6409.1(b)). The 8-hour outer limit is regulatory, not statutory: 8 CCR §342(a) defines “immediately” as no longer than 8 hours after you know, or with diligent inquiry would have known, of it, extendable to 24 hours only on a showing of exigent circumstances.