Given recent changes in California’s COVID requirements and pending workplace violence prevention requirements, we thought it might be a good time to revisit employee safety programs.

As you know, every employer in California must have a written and effective safety program. This is usually known as an Injury and Illness Prevention Program (IIPP), but goes by other names, such as Section 3203 Plan, and Business Safety and Recovery Plan. In this article, we’ll refer to the safety program as the IIPP. The California requirement for a written IIPP went into effect in 1991 and it requires more than a document that sits in a binder on the shelf. In order to avoid Cal/OSHA fines, the IIPP has to be alive and well in your workplace. This means employers must hold regular and current trainings and inspections. Penalties for not having a compliant IIPP can reach into the thousands of dollars; these penalties are fairly easy to avoid, since safety is important, and the program document is not overly complicated.

Our team is available to assist in developing your IIPP, should you require our expertise. The Personnel Perspective stands out as a longstanding HR firm in Napa County, offering expert guidance and essential support to navigate your HR challenges effectively.

As of 2023, the COVID prevention plan (CPP) can be part of the IIPP. Effective on July 1, 2024, workplace violence prevention (WVP) must be part of the IIPP as well. We’ll cover each of these requirements below.

The Cal/OSHA Non-Emergency Regulations for COVID-19 remain in place for employers until February 3, 2025. COVID-19 prevention procedures must be addressed either in the written IIPP or maintained in a separate document. We recommend including COVID prevention as a chapter or section in the IIPP, along with fire prevention, emergency evacuation, earthquake preparedness, and other more industry-specific measures such as high heat abatement and wildfire smoke. The COVID plan needs to address precautionary measures, proactive response, and training.

As of January 2024, the California Department of Health altered some definitions for COVID related issues and reduced some of the requirements. For example, “infectious period” is now a minimum of 24 hours from the day of symptom onset. There is no infectious period for COVID cases with no symptoms. If an employee tests positive for COVID and has symptoms, they must be excluded from work for at least 24 hours from when symptoms started. They can return to work after 24 hours with no fever (without the use of fever-reducing meds) and any other symptoms are mild and improving. If an employee tests positive and has no symptoms, they do not need to be excluded from the workplace. Positive cases must wear a mask at work for ten days from the positive test or symptom onset. Employees no longer need to be excluded from work because they had a close contact.

In 2023, the California legislature passed, and Governor Newsom signed, SB 553, which requires most California employers to include a written workplace violence prevention plan in their IIPP by July 1, 2024. The WVP plan must incorporate:

1. documentation of employee involvement, compliance, and communication
2. a record of certain workplace incidents in a separate violent incident log
3. annual workplace violence prevention training to all employees
4. hazard identification and response
5. maintenance of certain records for specified periods of time

There are exemptions for employers in some industries such as health care, for remote employee sites, and for small employers with fewer than 10 employees working together in one place. We can help you develop your IIPP and add the COVID and workplace violence prevention sections to your IIPP, if you would like assistance.

When in need of professional advice on HR-related matters, consider contacting The Personnel Perspective, which stands out among HR firms Napa County, for expert and practical guidance and vital support. Contact us at (707) 576-7653.