A proposal to eliminate the independent evaluation of California employers’ Injury and Illness Prevention Programs (IIPPs) was recently included as part of a package of recommendations made by the state’s Office of Self-Insurance Plans.
The revision would eliminate the requirement for an independent evaluation of a self-insurance applicant’s IIPPs by a qualified professional, either a Certified Safety Professional (CSP) or a Certified Industrial Hygienist (CIH). In lieu of professional review of an applicant’s IIPP, the proposed revision allows for self-certification by the employer.
The proposed change, which would affect the California Code of Regulations, Title 8, Section 15353, Injury & Illness Prevention Program (IIPP), is a change BCSP urges the Office of Self-Insurance Plans to reconsider.
“While the objectives of the Amendment are well-intentioned — to simplify the application process, reduce costs for employers, and eliminate unnecessary redundancy — the effect of such a change would be at the cost of public and worker safety,” wrote BCSP CEO Dr. Treasa Turnbeaugh, CSP, ASP, CET. “It is not sufficient that an employer simply have an IIPP in place; an IIPP, like any safety management system, must be effective in reducing the hazards related to workplace injury and illness.”
Without third-party review, the only way to determine the value of any given IIPP would be to wait and see the results. It is not disputed that safety has value, but it must be understood that it is an investment as well. Given the cost of work done without safety, with both fatal and non-fatal work injuries estimated by the National Safety Council to have cost $198 billion in 2012, it is important that investments made in safety programs like IIPPs be of real value. The best way to ensure this value is through impartial, independent evaluation.
“Maintaining the existing high evaluation standards of employer IIPPs by CSPs and CIHs not only shows that the State of California takes workplace injury prevention seriously, but is a simple and reasonable way to reduce the potential financial burdens of workplace injuries and illnesses on California taxpayers,” explains Dr. Turnbeaugh.
BCSP urges the Office of Self-Insurance Plans reject the proposal.