This publication is compiled from various reference sources and is designed to provide current and authoritative information regarding the subject matter covered. It is provided with the understanding that the publishers and Prestige Personnel Services are not engaged in rendering medical, legal, accounting or other professional service. The publication also explains, in general terms, the requirements of California law concerning occupational safety and health, and the California Occupational Safety and Health program (CAL/OSHA). It is not intended as a legal interpretation of any Federal or State standard. It is intended to provide guidance rather than prescribe requirements. Any reader who has questions about the laws which relate to CAL/OSHA should refer directly to the appropriate legislation or obtain the advice of a legal professional.

Farm Employers Labor Service and Prestige Personnel Services believe the information provided to be correct but assumes no liability for consequential or other damages attendant to the use of this publication. In no event shall Farm Employers Labor Service's or Prestige Personnel Services's liability for any claim, however designated, exceed the purchase price for this publication. No claim may be maintained against Farm Employers Labor Service or Prestige Personnel Services in any tribunal unless written notice of the claim is delivered to Farm Employers Labor Service or Prestige Personnel Services within thirty (30) days after the discovery.

FARM EMPLOYERS LABOR SERVICE

2300 River Plaza Drive

Sacramento, California 95833-3293

This workbook is licensed to the purchaser and may be reproduced

for the purchasers own use. The workbook may not be reproduced in whole or part

for any commercial use without the express written permission of the copyright owner.

Injury and Illness Prevention

Program (Sb 198)

General requirements

In 1989 the state legislature passed and the Governor signed into law SB 198. One of the major requirements of SB 198 is for employers to implement and maintain an effective written injury prevention program. The Cal-OSHA Standards Board (Board) was given the responsibility to write a standard to implement this requirement.

The Board amended General Industry Safety Order (GISO) §3203 (Accident Prevention Program) with a more comprehensive standard. The new regulation requires, starting July 1, 1991, every employer to establish, implement and maintain an effective written injury prevention program (Program) which shall at a minimum contain the following:

1. Identify the person or persons with authority and responsiblilty for implementing the Program. GISO §3203 (a) (1).

2. Include a system for ensuring that employees comply with safe and healthy work practices. GISO §3203 (a) (2).

3. Include a system for communicating with employees in a form readily understandable by all affected employees on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal. GISO §3203 (a) (3).

EXCEPTION: Employers having fewer than 10 employees shall be permitted to communicate to and instruct employees orally in general safe work practices with specific instructions with respect to hazards unique to the employees' job assignments as compliance with subsection (a)(3).

4. Include procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and work practices. GISO §3203 (a) (4).

5. Include a procedure to investigate occupational injury or occupational illness. GISO §3203 (a) (5).

6. Include methods and/or procedures for correcting unsafe or unhealthy conditions, work practices and work procedures in a timely manner based on the severity of the hazard. GISO §3203 (a) (6).

7. Provide training and instruction: (A) When the program is first established; (B) To all new employees; (C) To all employees given new job assignments for which training has not previously been received; (D) Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard; (E) Whenever the employer is made aware of a new or previously unrecognized hazard; and (F) For supervisors to familiarize them with the safety and health hazards to which employees under their immediate direction and control may be exposed. GISO §3203 (a) (7).

Record Keeping Requirements:

Section 3203 also requires employers to maintain records that document compliance with the regulation. In a few instances employers having fewer than 10 employees are provided minor exceptions in the record requirements. The following are excerpts from §3203 (b) which pertain to record keeping:

Records of the steps taken to implement and maintain the Program shall include:

(1)Records of scheduled and periodic inspections required by subsection (a) (4) to identify unsafe conditions and work practices, including person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and action taken to correct the identified unsafe conditions and work practices. These records shall be maintained for three (3) years; and

Exception: Employers with fewer than 10 employees may elect to maintain the inspection records only until the hazard is corrected.

(2)Documentation of safety and health training required by subsection (a) (7) for each employee, including employee name or other identifier, training dates, type(s) of training, and training providers. This documentation shall be maintained for three (3) years.

EXCEPTION NO. 1: Employers with fewer than 10 employees can substantially comply with the documentation provision by maintaining a log of instructions provided to the employee with respect to the hazards unique to the employees' job assignment when first hired or assigned new duties.

EXCEPTION NO. 2: Training records of employees who have worked for less than one (1) year for the employer need not be retained beyond the term of employment if they are provided to the employee upon termination of employment.

Exception No. 3: For Employers with fewer than 20 employees who are in industries that are not on a designated list of high-hazard industries established by the Department of Industrial Relations (Department) and who have a Workers' Compensation Experience Modification Rate of 1.1 or less, and for any employers with fewer than 20 employees who are in industries on a designated list of low-hazard industries established by the Department, written documentation of the Program may be limited to the following requirements:

A. Written documentation of the identity of the person or persons with authority and responsibility for implementing the program as required by subsection (a)(1).

B. Written documentation of scheduled periodic inspections to identify unsafe conditions and work practices as required by subsection (a)(4).

C. Written documentation of training and instruction as required by subsection (a)(7).

Exception No. 4: Local governmental entities (any county, city, city and county, or district, or any public or quasi-public corporation or public agency therein, including any public entity, other than a state agency, that is a member of, or created by, a joint powers agreement) are not required to keep records concerning the steps taken to implement and maintain the Program.

Note 1: Employers determined by the Division to have historically utilized seasonal or intermittent employees shall be deemed in compliance with respect to the requirements for a written Program if the employer adopts the Model Program prepared by the Division and complies with the requirements set forth therein.

Note 2: Employers in the construction industry who are required to be licensed under Chapter 9 (commencing with Section 7000) of Division 3 of the Business and Professions Code may use records relating to employee training provided to the employer in connection with an occupational safety and health training program approved by the Division, and shall only be required to keep records of those steps taken to implement and maintain the program with respect to hazards specific to the employee's job duties.

Safety and Health Committees:

Safety and health committees are optional. However, if committees are used to satisfy the "communication" requirement, GISO §3203 (a) (2), they need to meet minimum standards as outlined in §3203 (c) as follows:

(c) Employers who elect to use a labor/management safety and health committee to comply with the communication requirements of subsection (a) (3) of this section shall be presumed to be in substantial compliance with subsection (a) (3) if the committee:

(1)Meets regularly, but not less than quarterly;

(2)Prepares and makes available to the affected employees, written records of the safety and health issues discussed at the committee meetings and, maintained for review by the Division upon request;

(3)Reviews results of the periodic, scheduled worksite inspections;

(4)Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness, or exposure to hazardous substances and, where appropriate, submits suggestions to management for the prevention of future incidents;

(5)Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, the committee may conduct its own inspection and investigation to assist in the remedial solutions;

(6)Submits recommendations to assist in the evaluation of employee safety suggestions; and

(7)Upon request from the Division, verifies abatement action taken by the employer to abate citations issued by the Division.

Cal/OSHA Inspections & Citations:

The legislation (SB 198) which required the implementation of the new regulation, requires Cal-OSHA inspections to include an evaluation of the employer's injury prevention program using the substantial compliance criteria included in GISO §3203. The evaluation must include interviews with employees and members of any employer-employee safety and health committee.

If an employer cited for any violation does not have an injury prevention program which meets the substantial compliance criteria, the civil penalty would not be adjusted for good faith or history, adjustments which would otherwise reduce the amount of the penalty.

Compliance Checklist:

The following checklist was prepared by the Cal/OSHA Standards Board staff. It can be useful to evaluate an injury and illness prevention program.

1. Does the written Injury and Illness Prevention Program contain the elements required by Section 3203 (a)?

2. Is the person or persons with authority and responsibility for implementing the Program identified?

3. Is there a system for ensuring that employees comply with safe and healthy work practices (i.e., employee incentives, training and retraining programs, and/or disciplinary measures)?

4. Is there a system that provides communication with affected employees on occupational safety and health matters (i.e., meetings, training programs, posting, written communications, a system of anonymous notification concerning hazards, and/or health and safety committees)?

5. Does the communication system include provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal?

6. Is there a system for identifying and evaluating work place hazards whenever new substances, processes, procedures, or equipment are introduced to the workplace and whenever the employer receives notification of a new or previously unrecognized hazard?

7. Were workplace hazards identified when the Program was first established?

8. Are periodic inspections for safety and health hazards scheduled?

9. Are records kept of inspections made to identify unsafe conditions and work practices?

10. Is there an accident and near-miss investigation procedure?

11. Are unsafe or unhealthy conditions and work practices corrected?

12. Are employees protected from serious or imminent hazards until they are corrected?

13. Have employees received training in general safe and healthy work practices?

14. Do employees know the safety and health hazards specific to their job assignment?

15. Is training provided for all employees when the training program is first established?

16. Is training provided to all new employees and to all employees given a new job assignment?

17. Are training needs of employees evaluated whenever new substances, processes, procedures or equipment are introduced to the workplace and whenever the employer receives notification of a new or previously unrecognized hazard?

18. Are supervisors knowledgeable of the safety and health hazards to which employees under their immediate direction and control may be exposed?

19. Are records kept documenting safety and health training for each employee, including employee name or other identifier, training dates, type(s) of training, and training providers?

20. Does the employer have a labor/management safety and health committee?

21. Does the committee meet at least quarterly?

22. Is a written record of Safety Committee meetings distributed to affected employees and maintained for review by the Division?

23. Does the committee review results of the periodic, scheduled worksite inspections?

24. Does the committee review accident and near-miss investigations and, where necessary, submit suggestions for the prevention of future incidents?

25. Does the committee review investigations of alleged hazardous conditions brought to the attention of any committee member?

26. When determined necessary by the committee, does the committee conduct its own inspections and investigations to assist in remedial solutions?

27. Does the committee evaluate employee safety suggestions and submit recommendations?

28. Does the committee verify abatement action taken by the employer as specified in Division citations upon request of the Division?

Writing a Injury and Illness Prevention Program:

The following sections of the workbook contain sample policies which relate to the required subjects of an Injury Prevention Program. Each section of the workbook begins with a summary description of the §3203 section which the sample policies cover, if appropriate. The sections of the workbook which contain sample policies not required in a written Program state that fact at the beginning of the section. The samples covering subjects not required in a Program are included so that employers can expand their safety programs beyond the scope of GISO §3203.

Employers can develop a safety program by using the sample policies to construct their own Injury Prevention Program. When selecting the policies make sure that you include each of the required subjects of a written injury prevention program as discussed at the beginning of this section.

If you wish to have FELS type your customized program in English and Spanish you can request this service by completing the Injury and Illness Prevention Program order form. A blank order form is located in the back of this workbook. Extra order forms can be obtained through FELS. On the order form, indicate the policies you desire to have in your Injury and Illness Prevention Program together with any changes. Mail the order form to FELS with your payment. Within a month you will receive your completed program. The completed program will include the policies you select from the samples found in this manual together with any changes you request, a table of contents for the overall safety manual and the selected forms as an appendix.

If requested, the customized program will be typed by FELS in accordance with the policies selected by you together with any changes indicated by you on the order form. It will not be substantively reviewed by FELS. Your customized program should be reviewed by you or your legal adviser upon receipt thereof for completeness. When notified by you, FELS will correct any errors or omissions with respect to your program as specified on the Injury and Illness Prevention Program order from.

Section I

Management Statement

The sample policies in this section are general management statements regarding the overall safety program of the company. They are intended as an introduction to the Injury and Illness Prevention Program. They do not necessarily satisfy any of the required subjects of a Injury and Illness Prevention Program.

Sample Policies

SAFETY POLICY (28052)

It shall be our policy to conduct all operations safely by instituting the appropriate safety measures that will prevent injuries to persons and damage to property. When an employee begins to work here, that employee has a right to expect a safe place in which to work and to be provided with the proper machines, tools and equipment to do the job safely.

The company has a management commitment to promote safety, to operate in a safe manner and to always strive to improve the company's safety record.

In order to carry out these objectives the following procedures have been established:

1. The establishment of a safety committee comprised of employees and management personnel.

2. Scheduled periodic inspections will be conducted of all work areas to identify unsafe conditions and work practices.

3. Review all on-the-job accidents and occupational illnesses to determine their cause.

4. Unsafe conditions and work practices will be corrected as uncovered by periodic inspections and review of accidents and illnesses.

5. Scheduled instructional training will be conducted on the hazards unique to each employee's work assignment.

6. Employees will be trained in general safe work practices at the time of hire and trained specifically for his or her job before being assigned to the job or before being assigned to any new work assignment.

7. Safety awareness programs will be conducted to highlight the importance of safe work practices among all employees. The program may include a safety award program or contest.

SAFETY (28001)

Safety is a vital consideration to us. Safety and good housekeeping are necessary parts of everyone's daily activity. For the protection of employees, safety guards and safety equipment are provided. You must use this protective equipment and follow the directions of your supervisor regarding safety.

SAFETY (28002)

Accidents don't just happen, they are caused. Your safety is a matter of major concern to the company. Every reasonable precaution is taken to provide you with a safe place to work. However, without the sincere and faithful cooperation of all employees, safety programs alone are of little value in preventing accidents. Accident prevention is largely a responsibility of each individual.

The company feels that a clean, safe and healthy environment should be provided for all employees. Employees are expected to do their part to work safely, wear required safety equipment, observe all safety rules and regulations, and to keep their work area neat and clean. The company strives to abide by all regulations and request that you report all injuries and any unsafe situations to your supervisor so that the situation can be corrected.

SAFETY (28014)

A clean, safe and healthy environment will be provided for all employees. Employees are expected to do their part to work safely, wear required safety equipment, observe all safety rules and regulations, and to keep their work area neat and clean.

ACCIDENT PREVENTION AND REPORT OF INJURIES (28015)

We have a strong accident prevention program and consider it an important company objective to prevent employee accidents wherever possible. All jobs can be performed efficiently and safely, and we urge you to make accident prevention a part of your job.

Should you have an accident, including minor cuts, bruises and strains, you must report the injury to your foreman as soon as possible to assure prompt medical attention and to protect your rights under the law.

SAFETY/WORK CONDITIONS (28017)

This company has a strong accident prevention program and considers it an important company objective to prevent employee accidents whenever possible. Our safety program is outlined on the "SAFETY PROGRAM" boards posted at appropriate locations on the ranch.

ACCIDENTS, SAFETY AND HEALTH (28021)

It is the policy of the Company to do everything possible to protect you on the job and to comply with all the requirements of State and Federal law. Also, there is a certain amount of precaution which you must take.

SAFETY AND INJURY PREVENTION POLICY (28040)

The company is committed to providing safe working conditions for all it's employees and to protect customers, visitors or persons residing on or near company property from any unusual health or safety risk.

To accomplish this the company will

1. Comply with all applicable current and future occupational health, safety and environmental regulations of the County, State and Federal authorities.

2. Provide the necessary funding to maintain an effective and comprehensive safety and health program at all levels of the organization under the direction of a Safety and Environmental Coordinator.

3. Promulgate policies and practices that will reduce employee exposure to known and suspected occupations health and safety risks and take prompt advantage of new technology that enhances employee safety as quickly as is economically feasible.

4. Encourage all employees to participate in the company safety programs and hold each employee personally responsible for the safety use of all company property and for working in a safe manner, particularly in the use of required protective equipment.

The recognition and control of hazards and unsafe acts is the key to a safe work environment. There is no job so urgent that we can not take the time to perform it safely.

INTRODUCTION (28041)

The California Labor Code (Section 6401.7) requires the establishment of a written injury prevention program. The company is committed to protecting employees, customers and visitors from injury while on company property, as well as protecting the environment. Our safety and injury prevention program goes beyond mere compliance with the law and reflects the company's position as a leader in the industry and a concerned member of the community where we live and work.

This program is not optional. Good business practice, the law, and a concern for the well being of ourselves and our fellow human beings require we implement and maintain it.

ONGOING PROGRAMS (28118)

The following ongoing program are a part of the company's Safety Training program:

1. Hazard Communication Program.

2. Hearing Conservation Program.

3. Forklift Training Program.

4. Employee Performance Analysis Program.

5. Job Safety Analysis Program.

6. Pesticide Training Program.

SAFETY (28121)

Safety is the recognition and control or removal of the risks inherent in our business. Since it is not practical to remove all of these risks, recognition and control take on increased importance. This safety program has the elements needed to provide the safe workplace that every employee deserves. With the cooperation of all employees we can do it.

DRUG-FREE WORKPLACE POLICIES (28185)

In order to maintain a drug-free workplace, our company does not allow the manufacture, sale, distribution, possession or use of any controlled substances or illegal drugs.

Our company realizes the dangers of drug abuse. We support the Drug-Free Workplace Act of 1990. Any employee found to be using a controlled substance or illegal drug will be subject to immediate dismissal.

Our company does not provide or make available any counseling or rehabilitation programs to employees.

All employees, upon being hired, must sign an acknowledgment that states they agree to abide by the company's drug-free workplace policies and rules as a condition of my employment.

Section II

Designated Responsible Person

The sample policies in this section respond to the subject matter, in whole or part, in §3203 (a) (1):

(1)Identify the person or persons with authority and responsibility for implementing the Program."

At a minimum an injury prevention program must identify the responsible person's name(s). The individual with this responsibility must be in a position that has the authority to authorize changes in company policies and procedures. The person should also have the skill to formulate written safety policies and procedures.

Sample Policies

PERSON RESPONSIBLE FOR INJURY PREVENTION PROGRAM (28126)

(Insert name of person who has authority to implement safety program) has the authority and responsibility to develop and implement the company's injury prevention program.

INJURY PREVENTION ADMINISTRATION (28057)

The overall administration of the Injury Prevention Program is the responsibility of (Insert name of person who has authority to implement safety program). The following are the areas of responsibility and the people assigned to these responsibilities.

1. Processing reports and investigations pertaining to accidents and injuries. These reports are: Accident and Safety Analysis Report, Employer's Injury Reports and Doctor's Medical Reports.

Responsible Person: (Title)

2. Inspect Company operations each calendar quarter and to report findings to the appropriate supervisor and his or her superior for corrections. It is, however, the responsibility of each supervisor to perform an inspection of his or her area and equipment at least once a month, and to document the inspections findings.

Person responsible: (Title)

3. Develop and implement employee safety training program.

Assigned person: (Title)

4. Follow-up on all safety suggestions.

Assigned person: (Title)

5. Purchase the necessary personnel protective safety equipment.

Assigned person: (Title)

6. Develop and implement the company's Employee Safety Communication program.

Assigned person: (Title)

ASSIGNMENT OF INJURY PREVENTION RESPONSIBILITIES (28058)

The company has assigned the overall responsibilities to develop, implement and review the company's Injury Prevention program to (Insert name of person who has authority to implement safety program). This person is responsible to insure that:

1. Safety Inspection reports, Employer's Reports of Occupational Injury or Illness Reports, Employee's Claim for Workers' Compensation Benefits forms and Employee's Medical Documents are processed, analyzed and/or stored properly.

2. Inspect company facilities each (Insert inspection period, i.e.: month, quarter, six months, year) and prepare an inspection report.

3. Analyze each injury or illness report to determine cause of the injury or illness.

4. Direct appropriate personnel to correct safety hazards found during inspections or following review of an employee injury or illness report.

5. Develop and implement employee safety training.

6. Communicate with employees the company's safety policies and procedures.

SUPERVISOR'S RESPONSIBILITIES TO THE SAFETY PROGRAM (28059)

The effectiveness of any safety program rests ultimately, in the hands and actions of the supervisors. Management expects each superintendent to support the Safety Program by:

1. Enforcing the company Safety Policy and all Safety Procedures in the work areas for which he or she is responsible.

2. Cooperating with management and other supervisors in maintaining an active safety program.

3. Practicing safety personally, thus setting a good example for personnel under his or her supervision and delegating safety responsibilities to subordinate supervisors.

4. Remaining alert for unsafe conditions or practices and acting immediately to correct any hazards.

5. Investigating all on-the-job injuries under his or her supervision and completing the Injury and Illness Analysis Reports. Immediate action should be take to eliminate the cause of the injury.

6. Encouraging two-way communication with employees to make them aware of the company's interest in safety practices. Every effort should be made to promote employee interest and participation in the Safety Program. Safety meetings, Safety committees, tailgate safety meetings and committee safety inspections are types of communication which should be utilized. Reports of meetings and safety activities should be forwarded to the manager for review.

7. Forwarding copies of the monthly departmental safety meeting to the manager.

8. Informing the manager of safety problems.

RESPONSIBILITIES (28042)

The responsibility for the establishment and funding of the company's Safety and Injury Prevention Program rests with the Chief Executive Officer.

The responsibility for implementing of this program and maintaining the necessary tracking and record keeping to ensure it's effectiveness is delegated to the Safety and Environmental Coordinator.

The Individual managers and supervisors of the company are responsible for carrying out the various elements of the program.

Each employee is responsible for learning safe work procedures and for working without injury to themselves, others or damage to company property.

EMPLOYER'S COMMITMENT TO SAFETY (28159)

It is the policy of our company to provide safe work conditions for all employees. Our safety program's success depends on everyone's help. (Insert the person's name with authority to implement safety program) will have authority and responsibility for maintaining the Injury and Illness Prevention Program and will be accountable for safety practices, safety education and training, communicating safety information and fire protection.

Section III

Employee Compliance

The sample policies in this section respond to the subject matter, in whole or part, in GISO §3203 (a) (2):

(2)Include a system for ensuring that employees comply with safe and healthy work practices. Substantial compliance with this provision includes recognition of employees who follow safe and healthful work practices, training and retraining programs, disciplinary actions, or any other such means that ensures employee compliance with safe and healthful work practices.

Sample Policies

SAFETY RESPONSIBILITIES OF EMPLOYEES (28055)

Accidents are caused by a combination of three factors. They are: environment, failure of equipment, and people.

The company is responsible to insure that the work environment and the equipment are free of safety hazards. However, employees are responsible to work in a safe manner.

The company will not tolerate employees who do not observe safe work procedures or who violate company safety rules. The company will discipline employees on the same basis for safety violations as it disciplines employee under the conduct standards of the company.

COMPLIANCE WITH COMPANY'S INJURY PREVENTION PROGRAM (28127)

To insure that everyone in the company is encouraged to comply with the company's injury prevention program, the company will:

1. Recognize the contributions of employees to the company's safety program when they make useful safety suggestions, show a concern for working safely and maintain an accident free record.

2. Conduct monthly safety awareness meetings. The meetings will cover safety subjects which relate to the type of hazards employees may experience on the job.

3. The company will not tolerate any employee's unsafe act or unsafe attitude. Employees who violate this principle will be disciplined in the same manner as the company disciplines employees who violate other company performance standards. There is no exact procedure for disciplining employees. Depending on the offense and the employee's work history, the company may give an employee a verbal warning, a written warning, or a suspension from work. When appropriate the employee will be discharged. In any event, the company maintains the right to discharge employees at any time, for any reason, with or without prior notice, and with or without good cause.

EMPLOYEE COMPLIANCE WITH SAFETY RULES (28049)

Employees must understand that failure to follow safety rules and perform their work safely can result in serious disciplinary action, including removal. Supervisors will regularly observe employee's work practices. Repeat violations will result in the issuance of a reprimand of SAFETY RULES.

SAFETY (28025)

There is a right way and a wrong way of doing everything. The right way is invariably the safe way and the best way. Our superiors are constantly searching out hazards and every effort has been made to install any safety device or procedure that is needed. Protective equipment is furnished by the Company on many jobs. However, each employee must assume the responsibility for following safety advice and established safety procedures. Your foreman will instruct you in the proper, safe practices to be followed on your specific assignment. If you have any questions about the safe way of doing your job, ask your foreman and...

THINK.....

1. A major portion of the accidents that occur are caused by the "careless act." Don't take chances. It isn't worth it!

2. Observe all warning signs, safety bulletins and posters.

3. Avoid all horseplay and never distract another worker.

4. Use protective clothing and equipment. Goggles, safety glasses, guards and other protective equipment are furnished by the Company. It is mandatory that they be used.

5. CAREFULLY READ THE LABELS IN USING CHEMICALS, PESTICIDES, INSECTICIDES, AND HERBICIDES AND FOLLOW DIRECTIONS EXACTLY. Return all empty cans and bottles to the pesticide disposal facility to be destroyed. Don't ever re-use!!!

6. It is the responsibility of each employee to immediately report to a super visor any safety hazard which he sees.

SAFETY AWARENESS (28128)

Without the cooperation of employees the company's safety program would be meaningless. Employees must observe all company safety procedures and, most of all, use good common sense while performing their jobs. Employees who can not perform their job in a safe manner will not be allowed to work at our company. All managers and supervisors have the authority to discipline, including suspension of an employee or discharge of of an employee for not observing this policy. The company maintains the right to end the employment relationship on an at-will basis.

The company will provide each employee with injury prevention training when they are first hired, when they are assigned a different task in which they have no previous training or when a new procedure/substance is introduced into the work place. Periodic retraining will also be provided to insure that employees are up-to-date on safe work procedures. Retraining may also be initiated when employees are observed using unsafe procedures.

Employees who demonstrate good safety habits will be recognized by the company in the following manner:

1. Employees will receive safety awards for their identification of hazards, observing safety procedures or other actions which contribute to a safe work place.

2. Employees who make safety suggestions which are put into practice by the company or are deemed useful will be awarded a cash bonus in relation to the usefulness of the suggestions.

SAFETY OBJECTIVES (28138)

Safety is required, encouraged, and enforced at our company. We will not tolerate a lax attitude about our safety program. The key to an excellent safety program is teamwork. We must set an example for others to follow. Safety is a job requirement. Our goal is to encourage, train and maintain the involvement of all personnel. A persons's employment with this organization depends on his or her willingness to cooperate with our safety program. We believe in safety and insist on it from all employees.

EMPLOYEE'S RESPONSIBILITIES (28164)

Each employee is required to learn and to obey safety practices, to use all safety devices and protective gear. Disciplinary actions will be taken to assure that employees comply with safe and healthy work practices.

Employees must inform their supervisor of all safety, health, and fire hazards on discovery. Employees will not be dismissed or discriminated against for informing supervisors or owners about work site hazards. If in doubt about a health or safety matter, employees have a duty to talk it over promptly with their direct supervisor.

Employees must report immediately any accidents to their supervisor.

Section IV

Communications

The policies in this section respond to the subject matter, in whole or part, in GISO §3203 (a) (3):

(3)Include a system for communicating with employees in a form readily understandable by all affected employees on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal. Substantial compliance with this provision includes meetings, training programs, posting, written communications, a system of anonymous notification by employees about hazards, labor/management safety and health committees, or any other means that ensures communication with employees.

Exception: Employers having fewer than 10 employees shall be permitted to communicate to and instruct employees orally in general safe work practices with specific instructions with respect to hazards unique to the employees' job assignment as compliance with Subsection (a) (3).

Sample Policies

SMALL COMPANY COMMUNICATIONS (28129)

Because the company has fewer than 10 employees the company will communicate on-the-job safety issues to employees orally. The subjects to be covered with employees will be:

1. General safe work practices.

2. Specific instructions with respect to hazards unique to an employee's job assignment.

3. The company's safety and general work rules.

COMPANY/EMPLOYEE COMMUNICATIONS (28130)

The company wants all employees to report unsafe conditions. The company's policy prohibits any management person from retaliating against an employee who exercises this policy. In order to encourage better safety communications between the employees and the company management:

1. The company will conduct monthly meetings with employees to discuss safety issues. The company will be represented by at less one top management person.

2. The company will provide employees with an opportunity to meet once a month without any management personnel present to discuss safety concerns. The employees may report their concerns to the company orally or in an anonymous report. The sole purpose of the meeting will be to provide employees a way to inform the company of their safety concerns without fear of reprisal.

3. The company will post safety suggestions on the company's bulletin board.

4. The company will maintain a suggestion box where employees can make comments on any issue that concern them, including safety hazards. The general manager will review the suggestions and report his or her findings to employees at the monthly employee safety meetings.

5. The company will maintain a labor/management safety committee. The committee will meet quarterly and will be represented by two management personnel and three non-management personnel. The committee will do the following:

A. Prepare minutes of the meetings. The minutes will be posted on the company's bulletin board for inspection by employees.

B. Review employee suggestions received through the company's suggestion box or by any other means.

C. Review periodic, scheduled work site inspection reports.

D. Review accidents for their causes.

E. Report recommendations to management for the correction of unsafe procedures or hazards.

F. Upon request of Cal/OHSA, verify abatement action taken by the company to abate citations issued by Cal/OSHA.

6. The company will prepare and distribute paycheck stuffers when appropriate or at least once a calendar quarter. The stuffers will remind employees of safe work practices or alert them to new recognized hazards in the work place.

EMPLOYEE SAFETY COMMUNICATIONS (28065)

The company encourages all employees to discuss their safety suggestions or concerns with anyone in management, especially their immediate supervisor. If an employee feels intimated in discussing his or her safety concerns with a management person, the employee should write down the concern and deposit it in the employee suggestion box.

As suggestions are received, the manager will notify all employees by means of a general employee meeting or a memorandum posted on the company bulletin board regarding the company's position on the suggestions or concerns expressed by employees.

SAFETY COMMITTEE (28053)

A safety committee has been established to ensure that there is adequate employee involvement, participation and understanding of the company/employee Injury Prevention Program. The safety committee is appointed by the company and is comprised of 2 production employees, 2 supervisors and one management person. Employees wishing to be appointed to the safety committee should submit a written request to the office or discuss it with any management person.

The term of each committee member is one year.

The committee is empowered to:

1. Meet on the 1st Wednesday of each month. The time during which the committee members meet will be considered as time worked.

2. Establish a schedule to inspect all places of employment for safety hazards.

3. Make safety inspections of all places of employment for safety hazards according to the safety inspection schedule and report findings to the company.

4. Review all logs 101 (i.e., accident reports) submitted by employees.

5. Recommend to the company changes in procedures or facilities to correct safety hazards found during periodic inspections or review of accident reports.

6. In conjunction with the company's Workers' Compensation Insurance carrier recommend a periodic safety training program for employees.

7. Periodically review the effectiveness of the company's safety awareness program and to suggest changes or improvements to the program.

SAFETY SUGGESTIONS (28056)

Employees are encouraged to make suggestions which will decrease safety hazards. The safety committee will review all suggestions and make appropriate recommendations to the company. When appropriate and upon the recommendation of the safety committee an employee making a suggestion which has outstanding merit will be awarded a cash reward.

EMPLOYEE COMMUNICATION (28045)

Occupational safety and health matters will be promptly communicated with employees. This will be done by:

BULLETIN BOARDS: A safety bulletin board will be located in each work area. The Cal/OSHA Poster and the company's Safety Policy will be permanently posted on all bulletin boards. In addition the minutes of the last Safety and Health Committee meeting will be posted on all bulletin boards. Other safety related items shall be posted on the bulletin boards as they become available.

TAILGATE TALKS: Supervisors will give Tailgate talks at least once each month to all employees. Provisions must be made to ensure that employees who were not present are given the information presented during the talk. This may be done by presenting the talk at a later time for the missing employees or by posting an outline of the talk on the safety bulletin board. Tailgate talks must be documented on the SAFETY MEETING REPORT.

EMPLOYEE SAFETY HANDBOOK: An Employee Safety Handbook will be issued to each employee. This handbook covers basic safety rules, guidelines for safe work performance, company policy, etc. (Note, Supervisors will be provided a SUPERVISOR'S SAFETY HANDBOOK, which will include all the Employee's Safety handbook with appropriate additional information for supervisors.

SAFETY POSTERS: Safety Posters, either purchased from a vendor or produced by the Safety and Environmental Coordinator will be posted on the bulletin board and at other appropriate locations.

SAFETY PERFORMANCE ANALYSIS: At least once each quarter, the Safety and Environmental Coordinator will prepare an analysis of the effectiveness of the safety program. This analysis will include accident statistics for the company. The analysis will be posted on safety bulletin boards.

SAFETY AND HEALTH COMMITTEE (28046)

A Safety and Health Committee will be established to address safety and health in the company. The committee will meet at least once per quarter. Minutes will be kept of the meetings and the minutes will be posted on all bulletin boards. The duties of the committee will include:

1. Review the periodic worksite inspection.

2. Investigation of causes of injury, illness, or exposure to hazardous substances.

3. Investigation of any alleged hazardous condition brought to the attention of any committee member. When determined necessary, the committee may conduct its own inspection and investigation.

4. Upon request from the California Occupational Safety and Health (Cal/OSHA), verify the abatement action taken by the company as specified in citations.

MEMBERSHIP OF THE COMMITTEE: Membership on the Safety and Health Committee will be limited to five persons and will have both management and non-management employees. The Safety and Environmental Coordinator will serve as the technical advisor to the committee and will attend all meetings.

SPECIAL EMPHASIS PROGRAMS (28120)

Based on the needs of the organization, the Safety and environmental Coordinator will recommend special emphasis programs. Such programs might include special Safety Awards or Safety Promotions.

SAFETY LITERATURE (28140)

There are safety booklets, posters and pamphlets available in the office. The following is a partial list:

How to Prevent Slips, Trips and Falls

Respiratory Protection

Lifting Properly

How to Read an MSDS

Forklift Safety

We encourage all employees to take copies home and study them.

SAFETY AWARENESS (28160)

Communication and training of new processes, new procedures, new equipment, safety activities, hazards, and safe work practices will be done by one or a combination of the following: (1) one on one conference between the supervisor and the employee, (2) training sessions, (3) posting on the company bulletin board, or enclosures with the employee's pay check.

SAFETY AWARENESS (28163)

Supervisors will be knowledgeable of the safety and health hazards to which employees under their immediate direction and control may be exposed.

Supervisors, under management's direction, will meet at least quarterly to talk over results of work site inspections, employee safety suggestions, safety problems and accidents that have happened. Supervisory employees will conduct safety meetings with their crews at least every 10 working days to stress safety.

Section V

Facility Inspections for Hazards

The policies in this section respond to the subject matter, in whole or part, in §3203 (4):

(4)Include procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and work practices. Inspections shall be made to identify and evaluate hazards:

(A)When the Program is first established;