ɫ�� Injury & Illness Prevention Plan

All employees are responsible for reading, understanding, and complying with this Injury & Illness Prevention Plan.

I. PLAN STATEMENT.

It is the policy of ɫ�� (“College”) to provide a safe and healthful workplace for all employees. This Injury and Illness Prevention Plan (“IIPP”) provides information and guidance to help employees and Supervisors maintain a safe working environment and report workplace injuries and unsafe conditions or work practices. For information on how the College protects against and resolves safety issues related to workplace violence, please see the Workplace Violence Prevention Plan.

II. APPLICABILITY.

The IIPP is applicable to all employees of the College (including faculty, staff, casual employees, and administrators) in the performance of their work duties.

III. DEFINITIONS.

Incident – Any accident, injury, illness, or hazardous substances exposure affecting a College employee.

Environmental Health & Safety (EH&S) – The Environmental Health & Safety department of the College.

Personal Protective Equipment (PPE) – equipment worn to minimize exposure to hazards that cause serious workplace injuries and illnesses.

Supervisor – An employee who supervises other College employees in the performance of their duties.

Workplace Hazards – Workplace hazards are any unsafe work practices, unhealthful or unsafe physical conditions, or anything else that presents a potential for a workplace injury. This includes, but is not limited to: slip/trip/fall hazards; blocked emergency equipment or exits; damaged equipment, tools, or PPE; inadequate or improper use of tools and PPE; improper storage of chemicals, reactants, or toxic substances; repetitive operations; adverse work environments; work processes and procedures; use of tools, machinery, or equipment; stacking goods in a unstable manner; and storing goods, tools, or equipment against doors, exits, fire extinguishing equipment, and electrical panels.

IV. PLAN.

A. Plan Responsibilities

Depending on their role at the College, employees may have different responsibilities under this plan to ensure a safe and healthful workplace.

1. Safety Program Administration

All members of the College’s administration are responsible for safety and health in the workplace and are expected to do everything within their control to assure a safe environment that is compliant with federal, state, and local safety regulations.

The COO/VPFO is directly responsible for overseeing the College’s safety program. These responsibilities include:

Setting safety policy;
Assigning safety responsibility and accountability to individual employees and Supervisors;
Reviewing and evaluating the results of the safety program; and
Providing active leadership through example, participation, and active interest in the program.

2. Environmental Health and Safety Manager

The Environmental Health and Safety Manager (“EH&SM”) is directly responsible for implementing the College’s safety program. These responsibilities include:

Writing, updating, and implementing the IIPP;
Keeping up-to-date on changes to local, state, and federal health and safety regulations;
Attending departmental safety meetings as needed;
Working with Supervisors to plan, organize, and coordinate health and safety training;
Setting up health and safety inspection procedures, conducting inspections, and ensuring corrective actions are completed;
Assisting in maintaining accident reporting and investigation procedures in conjunction with Human Resources and Campus Safety;
Conducting workstation and workplace evaluations, including Ergonomic assessments and corrections;
Working with Human Resources, Campus Safety and health professionals in Emmons Health Center to provide first aid treatment and transport of injured employees;
Maintaining communication with Human Resources professionals responsible for administering the College’s Worker’s Compensation program; and
Maintaining communication with local, federal, and state safety agencies.

3. Senior Risk and Insurance Manager

The Senior Risk and Insurance Manager is responsible for supporting the College’s safety program. These responsibilities include:

Co-chairing the Campus Safety Committee with a representative from Human Resources; and
Communicating with College insurance carriers.

4. Vice Presidents and Department Leadership

All Supervisors are responsible for supporting the College’s safety program. Specific responsibilities include:

Being familiar with this IIPP and implementing the program at the departmental level; and
Elevating concerns to the COO/VPFO or Environmental Health and Safety Officer, as appropriate.

5. Supervisors

All Supervisors are responsible for supporting the College’s safety program. Specific responsibilities include:

Being familiar with this IIPP;
Reviewing the Basic Safety Rules with subordinate employees;
Supplementing the Basic Safety Rules with department-specific rules that reflect the safe equipment operation and job procedures specific to each work area;
Ensuring that each subordinate understands and is trained on how to complete their job duties in a safe manner;
Documenting the safety training provided to subordinates by the Supervisor;
Creating standard operating procedures (SOPs) for activities that present a risk of injury when conducted/performed, and training subordinate employees on these SOPs;
Ensuring employees follow safe work practices, including using required PPE;
Ensuring machines and equipment are maintained in safe operating condition;
Arranging for the repair or replacement any equipment, PPE, or machinery found to be defective, damaged, outdated, or identified as a source of potential injury;
Following the guidelines of the Hazard Communication Guide, , and/or Safety Data Sheets (as appropriate) regarding the location and use of hazardous materials;
Investigating and reporting to Human Resources all Incidents, including completing the Supervisor’s Report of Accident form and having the employee(s) complete an Employee Report of Work Related Injury or Illness (English or Spanish);
When an Incident occurs: (1) ensuring the employee receives medical treatment, if needed, or ensuring the employee completes a refusal of medical treatment form; (2) identifying and expediting any corrective action(s) necessary to prevent similar accidents; and (3) retraining employees on the safe performance of their duties when necessary; and
Reporting to the EH&SM, without delay, any unsafe or unhealthful conditions that cannot be corrected at the Supervisor level.

6. All Employees

All employees are responsible for supporting the College’s safety program. Specific responsibilities include:

Complying with all safety rules (including the Basic Safety Rules in Section D) and established safe work practices;
Exercising caution and common sense in performing their job duties;
Performing their job duties in a safe manner;
Immediately reporting any unsafe conditions or work practices to their Supervisor, the EH&SM, or other appropriate employee for prompt corrective action; and
Where they are qualified to do so, correcting any observed unsafe conditions (such as putting out a wet floor sign where a wet floor is observed).

7. Campus Safety Committee

The Campus Safety Committee is co-chaired by the Sr. Risk and Insurance Manager and a representative from Human Resources. The Campus Safety Committee shall be composed of representatives from the following:

Administration;
Faculty;
Staff (specifically staff from Hospitality Services and Facilities Management); and
Other invitees (which may include representatives from Workers Compensation and insurance carriers).

The Campus Safety Committee is responsible for improving employee safety by reducing employee injuries and suggesting safety improvements to senior staff. Specific responsibilities may include:

Conducting regular meetings to update members on campus safety and health issues;
Investigating allegations of hazardous conditions brought to the Committee’s attention, and communicating with employees and the College administration regarding such hazards;
Participating in investigation and analysis of accidents involving injuries or illnesses;
Assisting in setting up job hazard analyses and SOPs;
Remaining informed about the contents of this IIPP, offering suggestions for its improvement, and assisting with implementation of other Environmental Health and Safety programs;
Discussing facility, equipment, and procedural safety hazards and helping resolve problems; and
Working with Worker’s Compensation insurance representatives to reduce losses through analysis of injury and illness data and implementing their suggestions for loss reduction.

Employees may request to participate in Campus Safety Committee meetings by contacting the Sr. Risk and Insurance Manager.

B. Record Keeping

The Occupational Safety and Health Act of 1970 requires employers to record work-related injuries and illnesses. The Supervisor’s Report of Accident form, which is filled out by Supervisors following an Incident, is used by the College to record all workplace Incidents. The Employee Report of Work Related Injury or Illness (English or Spanish) is completed by an employee following an Incident, and is used by the College to record the employee’s perspective of the Incident.

The Human Resources Department is responsible for maintaining records of work-related injuries and illnesses and determining if an injury or illness meets the reporting guidelines.

C. Obtaining Medical Treatment and Transport

When an employee is injured on the job, the Supervisor must offer the employee medical treatment. Medical treatment may be obtained as follows:

For minor injuries requiring only minor first aid and which can be fully treated in one visit (such as scrapes, minor cuts, minor burns, or insect stings or bites) the employee should report to the Emmons Health Center for first aid.
For any injury requiring more than minor first aid or which will require more than one visit to treat (such as strains, sprains, broken bones, cuts requiring stitches, or infections) the Supervisor should immediately contact Human Resources to obtain authorization for the employee to be treated at Agile Occupational Medicine in Glendale.
For any life-threatening injuries (such as compound fractures, broken neck or spine, heart attack, serious bleeding) the Supervisor or other employee bystander should immediately call 911 to obtain emergency medical treatment. After communicating with 911, or simultaneously where more than one uninjured bystander is present, the Supervisor or bystander should contact Campus Safety at (323) 259-2599 for assistance.
For non-life-threatening injuries after hours, call Campus Safety at (323) 259-2599.

If an employee refuses medical treatment, the Supervisor must ensure the employee completes a refusal of medical treatment form.

For life threatening emergencies, transport to medical facilities will be undertaken via ambulance. In other cases:

An injured employee who can safely transport themselves to Agile Occupational Medicine may do so.
An injured employee may also arrange to have a friend or relative transport them to Agile Occupational Medicine where appropriate.
Where the injured employee cannot transport themselves or arrange for other transportation, the Supervisor may request taxi vouchers from Human Resources or Campus Safety to ensure the employee is safely transported to Agile Occupational Medicine.

A Supervisor or fellow employee may NEVER use their personal vehicle to transport an injured employee.

D. Basic Safety Rules

Safety begins with a commitment from every individual: knowledge and observance of safe work practices at all times is key to preventing workplace injuries and illnesses. Everyone is responsible for being alert to the safety of themselves and others and for taking all necessary actions to protect themselves and others from harm. The following basic safety rules are designed to help reduce the occurrence of workplace Incidents and apply to all work areas of campus, including the office environment:

If an Incident or “near-miss” should occur, report it to your Supervisor immediately.
Take an active interest in your own safety by developing good work habits and bringing unsafe working conditions to the attention of your Supervisor and the EH&SM.
Good housekeeping is essential for preventing accidents: Keep your work area clean and free of trip/slip/fall and laceration hazards.
Use handrails on steps. Avoid using stairways that do not have handrails.
Open hallway and building doors slowly to avoid hitting someone who might be on the other side. From the other side, approach doors cautiously to avoid being hit.
PPE (such as chemical splash goggles, gloves, steel-toed shoes, earplugs, fall protection, respirator, etc.) must be worn or used in any area where it is required.
Do not alter or disable existing safety features of equipment (i.e., converting 3-prong to 2-prong plugs, removing equipment guards, disabling warning alarms, etc.)
Be aware of the location of first aid kits and fire extinguishers and ensure you know how to use them.
Never operate a tool or machine that you have not been trained to use: Always ask your Supervisor if you are in doubt about how to safely operate a tool or perform a task.
Follow established job procedures. Changes to regular job procedures require the approval of your immediate Supervisor.
Follow the guidelines of the Hazard Communication Guide, , and/or Safety Data Sheets (as appropriate) regarding the location and use of hazardous materials.
Only use the proper tool for the job: If the proper tool is not available, get help from your Supervisor.
Never use defective or damaged (other than cosmetic damage) tools or equipment.
Use proper lifting techniques to avoid strain injuries. Do not jerk to lift. Avoid lifting and twisting. Keep your feet in line with the load. Get assistance in lifting any bulky, awkward, or heavy item which you feel you cannot safely lift alone. Consider alternatives: It may be possible to split up a load or use a cart. Always push rather than pull a heavy load. Do not store heavy objects up high.
If a repetitive task causes you discomfort, or if you feel like the ergonomics of your workplace need adjusting or that a task is unsafe or unhealthful, report it to your Supervisor immediately. Contact the EH&SM at (323) 259-2933 for a workplace or workstation evaluation.
Never use drugs or alcohol in the workplace or while performing job duties, as this can jeopardize your safety and the safety of others. Pursuant to the Campus-Wide Drug and Alcohol Policy, the use of drugs and alcohol in the workplace or while performing job duties is prohibited. If you or someone you know has a drug or alcohol problem, notify Human Resources.
If you have any questions, call the EH&SM at ext. 2933.

Department managers and Supervisors are responsible for supplementing these Basic Safety Rules with department-specific rules that reflect the safe equipment operation and job procedures specific to each work area.

E. Identifying and Evaluating Workplace Hazards

To maintain a safe and healthful workplace, Workplace Hazards must be identified. The College has procedures to correct Workplace Hazards.

Workplace inspections are the primary tool the College uses to identify unsafe conditions and practices. Secondary tools include employee and Supervisor reports, governmental inspections and audits, and post-accident evaluations.

During a workplace inspection, the following will be evaluated:

Evidence of violations of safety rules;
Machinery, hand tools, and other equipment to assess condition, the presence of necessary guards and safety features, and proper usage;
The use or storage of chemicals, including flammables, corrosives, toxics, and reactives;
Housekeeping practices including the presence of trip/slip/fall hazards or blocked access to emergency equipment and/or exits;
The availability and proper use of PPE;
Fire safety equipment; and
Evidence of other unsafe conditions and/or deviations from accepted safe work practices.

California law requires the College to conduct “regular and frequent” inspections of the workplace. Frequency of inspection shall be determined by EH&SM based on the risks associated with each work area. For example, office areas can be inspected annually, whereas laboratories and workshops should be inspected more frequently. In addition, some equipment requires scheduled inspections.

Inspections shall be conducted:

Per the inspection schedule developed for the specific work area or equipment;
When new substances, processes, procedures or equipment which present potential new Workplace Hazards are introduced;
When new, previously unidentified hazards are recognized or reported;
When occupational injuries and illnesses occur; and
Whenever workplace conditions warrant.

Inspections are most reliable when performed by a person outside of the office or department being inspected. This is referred to as “cross inspections.” Blank safety inspection forms are available from EH&S. A copy of all inspection results should be sent to the EH&SM.

Goals of safety inspections:

Detection and elimination of physical hazards.
Detection and elimination of unsafe work practices.
Control of housekeeping.
Increased awareness of safety.
Education of College personnel.
Compliance with Federal and State safety and health laws.
Increased knowledge of operations.
Improved utilization of space.

1. Responsibilities of All Employees to Identify Workplace Hazards

All employees are responsible for inspecting their own workplace on a daily basis and for promptly reporting Workplace Hazards to their immediate Supervisor. All employees are responsible for reporting any unsafe work practices they observe. Employees may be recognized for their compliance with this IIPP.

2. Responsibilities of All Supervisors to Identify Workplace Hazards

All Supervisors are responsible for routinely inspecting the workplaces within their area of responsibility and correcting or reporting Workplace Hazards. Supervisors must focus on specific hazards that may cause or contribute to an Incident.

a. Procedure: Supervisor Investigation of Incidents

If an Incident occurs in a Supervisor’s area of responsibility, the Supervisor’s Report of Accident must be completed within 48 hours or the next working day. All factors that caused or contributed to the Incident are to be noted in the appropriate sections of this report. The report is filed with Human Resources and a copy is sent to our worker’s compensation insurance carrier.

After an Incident the Supervisor is responsible for conducting an investigation that includes:

Interviewing the injured worker(s) and all witnesses;
Examining the workplace for factors that contributed to the Incident;
Determining the cause of the Incident;
Taking corrective action to prevent the Incident from reoccurring; and
Recording the findings and corrective actions taken.

3. Responsibilities of Safety Committee to Identify Workplace Hazards

The Safety Committee will conduct inspections of selected workplaces as part of its scheduled meetings. The purpose of these inspections is to instill a team approach to identifying and correcting Workplace Hazards. The inspection findings will be documented and a copy of this report will be filed with the EH&SM.

4. Responsibilities of the EH&SM to Identify Workplace Hazards

Together with the Sr. Risk and Insurance Manager, the EH&SM will regularly review Incident records and the Claim Profile Analysis Report provided by the College’s insurance carrier. The goal of this review is to help identify duties, positions, departments, or work areas that result in repeat or serious Incidents so corrective actions and training can be prioritized to help reduce Incidents.

F. Correcting Workplace Hazards

To maintain a safe and healthful workplace, Workplace Hazards must be corrected to the extent feasible. When discovered or observed, Workplace Hazards will be corrected in a timely manner based on the severity of the Workplace Hazard.

When an imminent hazard exists, which cannot be immediately abated without endangering employees and/or property, the College will remove all exposed employees from the area, except those necessary to correct the hazard. Employees who are required to correct the hazardous condition will be provided with the necessary PPE and other reasonable forms of protection.

Where corrective actions require more time and/or larger expenditures of capital, the College will evaluate the seriousness of the hazard, prioritize corrective actions, and use interim corrective measures until the hazard can be abated.

1. Responsibilities of All Employees to Correct Workplace Hazards

All employees who know about an actual or potential Workplace Hazard must act (within the scope of their role) to correct them. Hazards that cannot be corrected by an employee must be elevated to their Supervisor or to EH&S.

2. Responsibilities of All Supervisors to Correct Workplace Hazards

All Supervisors who know about an actual or potential Workplace Hazard must act (within the scope of their role) to correct them. This may include changing operations and work practices in the area they oversee. Hazards that cannot be corrected by a Supervisor must be elevated to their Supervisor or to EH&S.

3. Responsibilities of the Administration to Correct Workplace Hazards

College administrators have overall responsibility to assure efficient and safe operations within their area of responsibility, and to make decisions that encourage safety. All administrators who know about an actual or potential Workplace Hazard must act (within the scope of their role) to correct them. This may include changing operations and work practices in the area they oversee. Hazards that cannot be corrected by an administrator must be elevated to their Supervisor or to EH&S.

4. Corrective Actions & Procedures

Corrective actions generally fall into four categories:

Engineering Controls, Mechanical Controls, or Job Redesign – This is the preferred method of corrective action because it is a permanent solution that usually eliminates or reduces the Workplace Hazard. Cal/OSHA requires use of this solution whenever possible.
Training – Training on safe performance of work duties, in accord with an established standard operating procedure can help reduce the occurrence of Incidents.
Administrative Procedures – These are interim controls used to minimize exposure to a Workplace Hazard. These can also take the form of a standard operating procedure implemented to minimize Workplace Hazards while engineering controls are being investigated, funded, and installed.
Use of PPE – Where a Workplace Hazard cannot be mitigated, or while mitigation is in process, the use of PPE can function as a corrective measure by reducing exposure to the Workplace Hazard.

a. Procedure: Job Hazard Analysis

When the corrective action for a Workplace Hazard is not obvious, a Job Hazard Analysis (“JHA”) will be completed using the available from EH&S. The form helps identify the steps necessary to perform a job duty, the hazards associated with those steps, and the means by which they can be completed safely. Supervisors are responsible for contacting EH&S about any Workplace Hazard for which the corrective action is not obvious. EH&S will then work collaboratively with the Supervisor to conduct a JHA and determine a corrective action.

b. Procedure: Post-Incident Corrective Actions Under Supervisor Control

Supervisors must complete a Supervisor’s Report of Accident form whenever an Incident occurs. When the corrective action can be completed by the Supervisor, the Supervisor must indicate what corrective action they are taking/will take to prevent recurrence of the Incident. The Supervisor should also note the approximate date that the corrective action will be implemented. When the corrective action cannot be completed by the Supervisor, the Supervisor must contact EH&S.

c. Procedure: Post-Inspection Corrective Action

When a safety inspection discloses an unsafe condition or work practice, the EH&SM will record the recommended corrective action in the Safety Inspection Report. The EH&SM will work with the relevant department(s) to implement the corrective action.

H. Safety Training

The College provides the following safety trainings:

A general safety orientation for all new employees;
Training on the Workplace Hazards specific to an employee’s position and how to perform their job duties safely;
Special training for employees who work with hazardous materials or certain machinery or equipment;
Training on how to use the PPE provided;
Additional training whenever an employee is given new job duties that present Workplace Hazards for which they were not previously trained;
Additional training whenever new potential Workplace Hazards are introduced to the workplace or a previously unrecognized Workplace Hazard is identified; and
Supervisor training to familiarize them with the Workplace Hazards their subordinate employees may be exposed to.

1. Procedure: Safety Orientation for New Employees

The Human Resources Department is responsible for providing all new employees with a safety orientation. The safety orientation should be given at the start of employment.

The safety orientation for new employees must include the following:

An explanation of the College’s IIPP;
Providing a copy of the summary description of this IIPP, including the Basic Safety Rules;
Reviewing the summary description of this IIPP, including the Basic Safety Rules;
Notice of the requirement to, and procedures for, immediately reporting all workplace injuries;
Information on availability of medical treatment for workplace injuries;
The mandated by Labor Code 2810.5;
Notice of the requirement to report all unsafe conditions to their Supervisor and/or EH&S;
Notice that they will receive safety orientation and training from their Supervisor(s);
A clear statement that no employee should attempt to perform a job duty that appears to be unsafe; and
Any other safety program information made available by EH&S.

This safety orientation/training must be documented, including an acknowledgment by the employee that they understand the information provided. A copy of this documentation must be sent to EH&S.

2. Procedure: Safety Orientation by Supervisors

Once an employee begins working, the responsibility for safety education and training passes to the employee’s immediate Supervisor. Before an employee begins performing an assigned task their Supervisor should ensure they are familiar with any applicable safety policies or procedures. At the start of employment, the Supervisor must discuss the safety rules and safe work practices of the department in which the employee works. This must be followed by instruction about the Workplace Hazards associated with the specific job and any required or recommended PPE.

Subjects Supervisors should discuss with new employees include, but are not limited to, the following:

Implementation of the IIPP and the employee’s responsibilities under the IIPP;
What to do in the event of an emergency or fire;
How to obtain medical services and first aid, including during life-threatening emergencies;
Prevention of musculoskeletal disorders, including proper lifting techniques;
Proper housekeeping, such as keeping stairways and aisles clear, keeping work areas neat and orderly, and promptly cleaning up spills;
The College’s prohibitions of horseplay, scuffling, or other actions that adversely impact safety;
Proper storage of goods, tools, and equipment, such as stacking goods in a stable manner and not storing goods tools, or equipment against doors, exits, fire extinguishing equipment, and electrical panels;
Proper reporting of Workplace Hazards and Incidents to Supervisor(s);
Notice of residual Workplace Hazards; and
Proper storage and handling of chemicals and toxic/hazardous substances, including the proper labeling of containers and the prohibition against eating or storing food and beverages in areas where they could become contaminated.

After initial training and education, the Supervisor must also complete periodic reviews with the employee. Annual reviews are recommended. With assistance from EH&S, Supervisors must provide periodic reviews of general safety information and job specific information as necessary to meet the training needs of current employees. All training must be documented: Documentation must be signed by the employee and sent to EH&S.

I. Communication

Employees are allowed and encouraged to communicate freely with their Supervisor and other members of management about safety and health matters and Workplace Hazards, without fear of reprisal. Employees are always encouraged to make recommendations about changes in the workplace or work practices which will improve job safety and performance. Through open communication and collaboration, all College employees can help maintain a safe and healthful workplace from which all will benefit.

Communication is best when it is a mutual exchange. The College administration is responsible for keeping employees informed regarding matters important to their health and safety. Supervisors are responsible for communicating with their subordinate employees about health and safety in a way that is readily understandable by all. College-provided training is also an important and ongoing part of the College communication system.

The College’s communication system is depicted pictorially below:

Visual representation of safety communications between college and employees

1. Communication Through the Safety Committee

Members of the Safety Committee should encourage employees to communicate safety-related problems through the available channels. Employees may also communicate safety-related problems to the Committee.

2. Communication Through EH&S

All employees are encouraged to communicate safety-related problems directly to the EH&SM.

3. Communication Through Safety Suggestion Email Address

The College has established an email address (risk@oxy.edu) to make it easy for any employee to report a Workplace Hazard or safety concern or to make a suggestion to improve safety and health conditions in the workplace without fear of reprisal. These emails will be reviewed frequently and, where necessary, appropriate corrective action will be taken.

J. Disciplinary Action

Employees who do not comply with this IIPP or the College’s health and safety policies and practices may be subject to discipline, up to and including termination. Discipline may consist of, but is not limited to, verbal and written warnings, letters placed in an employee’s file, suspension without pay, demotion, being placed on probationary status, and/or termination. Generally, but not always, the severity of the disciplinary action will reflect the nature of the policy violation.

Employees may be subject to discipline for the following:

Violations of this IIPP;
Violations of safety rules;
Engaging in unsafe work practices;
Failure to wear proper PPE;
Failure to use required safety equipment;
Failure to maintain their workspace in a tidy and safe manner; and
Removing guards or safety devices from equipment or machinery.

This list is non-exhaustive: employees may be disciplined for other violations of the College’s health and safety policies and practices not listed above.

V. PLAN HISTORY.

Responsible Officer(s): COO/VPFO; EH&S Manager

Last Revised Date: September 25, 2024

VI. RELATED POLICIES AND RESOURCES.

Campus-Wide Drug and Alcohol Policy

Employee Report of Work Related Injury or Illness (English or Spanish)

Refusal of Medical Treatment Form

Safety Suggestion Email Address

Supervisor’s Report of Accident

Workplace Violence Prevention Plan