Injury and Illness Prevention Program

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Introduction and Policy Objective

California State University, Dominguez Hills (CSUDH) is committed to protecting the health, safety, and wellbeing of students, employees, visitors, and the surrounding community. The program policy provides the procedures that must be followed by all University employees in maintaining a safe and healthy campus environment.

The University shall:

  • Comply with all applicable laws and regulations related to the environment, health and safety;
  • Maintain high standards of safety and responsible concern for the environment in  campus activities;
  • Maintain an environmental health and safety (EHS) program that addresses safety concerns;

    The program policy enforces compliance with the regulations below:

California Code of Regulations (CCR) Title 8 Section 3203
CSU Executive Order 1031
CSU Executive Order 1039

Responsibilities

Deans, Directors & Vice Presidents

Deans, Directors & Vice Presidents, need to ensure that there is an active IIPP under the areas they oversee. They are responsible for the following;

  • Ensure that areas in which they have oversight are following all campus health and safety policy and guidelines
    Communicating leaderships commitment to supporting a campus that promotes health & safety in the workplace
  • Designating a Department Safety Coordinator
  • Ensure the correct and/or adequate equipment is used in instruction activities.
  • Ensure their departments/areas are compliant with the program policy, other safety related policies including CSU Executive Order 1039.

Supervisors/Managers/PI’s

All CSUDH supervisors/managers and PI’s are responsible for the well-being of their employees during the performance of their work duties, including compliance with Federal and State health and safety regulations, the program policy and other safety related policies.  

To meet this responsibility, supervisors shall:

  • Provide job-specific training to their employees.
  • Ensure their employees receive any required health and safety training; understand the hazards of their work and ways to protect themselves.
  • Conduct preliminary incident investigations of all reported injuries and illnesses.
  • Maintain Safety Data Sheets (SDS) for all hazardous materials and ensure the materials are properly labeled, stored, inventoried, and, as appropriate, identified for proper disposal.
  • Correct any unsafe conditions and/or work practices as soon as they are identified.
  • Ensure that all employees are provided with personal protective equipment (PPE), where required, and are trained in its proper use and maintenance.
  • Ensure that all employees receive initial and periodic medical examinations, where required, as identified by federal and state regulations.
  • Maintain records of all health and safety assessments, inspections, investigations, and trainings.
  • Recognize employees who follow safe and healthful work practices.
  • Ensure that employees who utilize unsafe work practices are retrained and/or disciplined.
  • Undertake disciplinary action on employees who willfully and/or repeatedly violate safety protocols.
  • Foster an environment in which employees can report hazardous conditions or unsafe work practices without fear of reprisal or inaction.
  • Provide access to a copy of this program policy to all employees and answer employee questions about it.
  • Develop department specific safety policies and Job Safety Analysis (JSA’s) as needed for specific tasks or hazardous equipment
  • Stop work if there is reason to believe it poses a hazard to the worker and/or is immediately dangerous to like and health

Employees

All employees shall adhere to the campus as well as department-specific health and safety procedures as informed by their supervisor/manager. Compliance with the safety policies of CSUDH is a condition of employment for all University employees. To meet these criteria employees shall:

  • Do not perform any hazardous task if you have not received prior training.
  • Use PPE where required
  • Report any unsafe condition or work practice immediately.
  • Comply with Health & safety signage, posters and directives
  • Cooperate with incident, injury investigations to help determine a root cause
  • Report any work place injury to their supervisor, regardless of severity.

Department Safety Coordinators

Department Safety Coordinators (DSC) will act as a liaison between the department and EH&S. This person will monitor activities within the department to ensure workplace safety is maintained. For departments that do not identify, EHS will work directly with the Supervisors/Managers/PI’s of the department.

  • Maintain any department safety records as it relates to training, inspections or safety meetings
  • Coordinate any tailgate or safety meetings (if the department elects to have these meeting types)
  • Work with EH&S to obtain any relevant Health & Safety information as it relates to regulations
  • Report to EH&S any unsafe behaviors or conditions that can’t be corrected on their own

EHS Department

Members of the EHS staff shall provide oversight and support to all University Management & Department Safety Coordinators to ensure proper implementation of the IIPP. To meet this responsibility, EHS staff shall:

  • Perform hazard assessments and periodic inspections in campus work spaces.
  • Ensure corrective actions are implemented in a timely manner.
  • Provide training to employees and advise administrative units within the University on required training and appropriate training procedures including content.
  • Conduct preliminary and/or follow up incident investigations.
  • Communicate safety and health information including any regulatory requirements that require such communication, to the campus community.
  • Provide material to departments to assist with content for trainings and/or safety meetings
  • Review the campus IIPP annually and make revisions as necessary

EHS Program Administrator

The EH&S Manager has the authority and responsibility for oversight and implementation of the IIPP, including:

  • Interpreting Regulations so as to properly develop compliance strategies with regards to safe work practices, mitigating workplace hazards, injury/illness investigation & training programs
  • Communicating with employees on matters concerning safety and health.
  • Establishing procedures to correct unsafe working conditions or work practices in a timely manner, based on seriousness of hazard.
  • Establish a recordkeeping system that maintains inspection, training, and other standard-specific documentation.
  • Monitor the effectiveness of the IIPP and make revisions as necessary
Safety Communication of Workplace Hazards

Effective communication and reporting of health and safety information is critical to a successful IIPP program. 

Supervisors

Supervisors shall:

  • Communicate any changes work conditions, processes, procedures, and/or materials that impact the health and safety of an employee(s).
  • Communicate any safety and health hazards/updates passed down by EHS, to affected employees.
  • Contact EHS for support if corrective measures are outside the technical ability or expertise of the supervisor/department.
  • Foster a work environment that welcomes notifications by employees regarding hazardous conditions, unsafe work practices, and/or injuries.

Employees

Employees shall:

  • Report any injury or illness to their supervisor, regardless of severity.
  • Report any unsafe work practice or condition to their supervisor.
  • Contact EHS to report any unsafe work practice or condition (employee can remain anonymous).
  • Contact EHS if a previously reported hazardous condition has not been corrected or has re-occurred.

Resources

While supervisors have primary responsibility for providing employees with hazard information pertinent to their work assignments, information concerning safety hazards is available from a number of other sources. Safety information is communicated to employees by e-mail, voice mail, distribution of written memoranda, or by articles in internal newsletters (if applicable). Other resources include, but are not limited to the following examples:

  • Accessing the EH&S website- The EH&S website has many resources, forms and checklists that can be accessible and are downloadable. You can also contact EH&S staff to inquire on any Health & Safety questions you may have.
  • EH&S specific programs – In addition to this IIPP there are specific programs that have been created to manage exposures. These include, but are not limited to, Chemical Hygiene Plan(laboratories), Hazard Communication Plan (non-labs), Heat Illness, Exposure Control Plan, Lockout/Tagout, Powered industrial trucks, Respiratory Protection.EH&S Guidelines – Guidelines are typically written where state and federal regulators do not require a written program. Guidelines can assist and will provide general regulatory information around these activities. A few examples of guidelines include Mobile Elevated Work platforms (MEWP’s) and Window Washing activities.
  • Safety Data Sheets (SDS’s)- SDS’s are provided for any hazardous material that is purchased and used on campus. You can also visit the manufacturer’s website to find an SDS or go to MSDS online and search for the chemicals SDS.
  • Machine & Equipment manufacturer manuals- All machinery and equipment should be operated as per manufacturer’s instructions. Employees who use equipment and/or machinery should review and understand the safety requirements to operate.

Job Hazard Analysis

EHS shall perform a Job Hazard Analysis (JHA) to assess workplace hazards and establish safe work procedures if any of the following conditions arise:

  • When the IIPP is first established, or prior to assigning of any job/task that has not been previously assessed for hazards.
  • Whenever new substances, processes, or equipment are introduced to the workplace that represent a new occupational safety and health hazard.
  • Whenever the University is made aware of a new or previously unrecognized hazard.

JHA’s are conducted as follows:

  • For common tasks within departments across campus
  • Identify the job hazard
  • Identify the hazard control
  • Recommend overall training for the Job class
  • Recommend overall PPE for the job class
  • Completed JHA’s are available on the EHS website.

Job Safety Analysis (JSA)


JSA’s are typically developed by department or job function that performs the task as they the most familiar with the hazards associated with that piece of equipment or task. Components of a JSA should include:

  • Picture of the task
  • What Job, shop or department would perform the task
  • Any specific Job title
  • When the JSA was created
  • What PPE is required
  • What trainings are required or recommended
  • What hazards are associated within the steps of performing the task
  • Methods to control the hazards, using Hierarchy of controls (eliminate, substitute, Engineering controls, Administrative Controls and lastly PPE)

JSA’s should be reviewed by EH&S to ensure proper controls are in place. JSA’s should then be kept within the department that uses them at or near the equipment that it is written for. And also used to train staff prior to using that equipment or performing that task. For reference there is a link on the EH&S web page for JHA’s for various job classes. Departments can use these JHA’s as a resource when creating a JSA. The JSA should be more detailed than the JHA as it covers each step of the task or equipment use.


EMERGENCY ACTION PLAN

The campus Emergency Action Plan addresses campus response to disaster, emergency, catastrophic event or crisis (e.g., earthquake, fire, flood, loss of critical infrastructure, terrorist attack, civil unrest, etc.). The Emergency Management department, administers the plan for the campus.


Business Continuity Plan

Business Continuity Plans are used to continue operations in key campus business units during and immediately after a disaster. Risk management administers the campus program with each key unit responsible for maintaining and implementing their Business Continuity Plans.

Identifying Workplace Hazards

Inspection Overview

Periodic inspections are done to identify and evaluate workplace hazards that cause injury or damage to the facility. Inspections are a critical component to ensure compliance with health and safety requirements and that new hazards that arise are identified and addressed.

Scheduled Inspections by Supervisors

Supervisors and/or Department Safety Coordinators shall conduct scheduled safety inspections at least annually of all work operations within their purview. These inspections must include identifying unsafe physical conditions and unsafe performance of work tasks.  Supervisors must ensure any issues identified during an inspection are corrected.  Supervisors are also responsible for documenting the inspections and corrective actions.  

Documentation shall include:

  • Identity of the individual conducting the assessment/inspection.
  • Clear narrative of the unsafe condition(s) and/or work practice(s).
  • Corrective actions to be taken and dates by which the actions will be completed.

Areas where inspections should take place:

  • Offices – Including departmental areas, breakrooms & departmental kitchen areas
  • Laboratories – areas where chemical, biological, laser or other physical hazards exist
  • Shops – include Carpenter, Plumbing, Electrical, Auto shop & Central plant
  • Storage areas – including Maintenance, Grounds and large custodial storage areas
  • Arts & Theatre- including costume shop, prop storage, theatre (including rigging and cat walk) & scene shop

Periodic Inspections by EHS

EHS shall conduct scheduled periodic safety inspections across campus work spaces. Areas identified as high risk due to the nature of work performed and/or materials used to perform the work, may have a higher frequency of inspection.  Any issues identified that require corrective action will be communicated in writing to the appropriate supervisor and a due date within which to complete the corrective actions, provided. EHS may re-inspect work spaces to verify satisfactory completion of corrective actions. Disciplinary action may be taken against employees who do not comply with completion of corrective actions. EHS will document and maintain a record of these inspections.

Reporting Hazards or unsafe practices

Employees are encouraged to report existing or potentially hazardous conditions or unsafe work practices to their supervisor so that necessary action (including training, purchase of appropriate equipment, etc.) can be taken in a timely manner.

Supervisors or the Department Safety Coordinator, or members of safety committees should make a notification to management or EH&S when made aware of an unsafe condition for which an immediate remedy cannot be implemented. Corrective actions shall be identified and completed by the department.

Additionally if employees need additional support when reporting a hazard or unsafe working condition, they can reach out to EH&S by calling 310-243-3000. Employees who reach out to report can’t be disciplined and complaints can be made anonymously.

Correction of Unsafe Conditions and Workplace Hazards

Upon notification of an unsafe condition or work practice, the responsible supervisor shall take corrective action.  If the unsafe condition cannot be immediately corrected, the responsible supervisor shall develop an appropriate timetable for correcting the unsafe condition This should be dependent on the severity of the hazard.  More imminently Dangerous the hazard is, the more attention should be taken to correct the hazard.

Documentation of corrective actions for unsafe conditions and work practices shall be completed by the responsible supervisor and maintained on file for review by EHS upon request. Any employee who is, or potentially could be, affected by the unsafe condition or practice, shall be notified of the hazard and the status of the investigation and the abatement of the hazard.

When an imminent hazard situation is identified during any hazard assessment, periodic inspection, or otherwise becomes known, immediate corrective action shall be taken by the responsible supervisor to abate the hazardous condition.

When an imminent hazard exists that cannot be immediately abated without endangering employees and/or property, all students and employees shall be evacuated from the area, except those who may be necessary to correct the hazardous condition. Contact EHS at 310-243-3000 immediately upon recognition that such an imminent hazard situation exists. If the hazard requires repair contact Facilities Services at 310-243-3804.

Accidental/Incident Investigation

This section describes the procedures for conducting preliminary and follow-up incident investigations. A workplace incident is considered an unplanned event that results in an injury, accident, illness or property damage and is either arising out of or a causation of employment. A near miss is an unplanned event did not result in an accident, injury, illness or property damage, but very well could have. Non workplace incidents are not covered under this IIPP.

Medical Treatment

For non-emergency medical treatment of work-related injuries or illnesses, employees should be sent to either Concentra Medical Center or Kaiser on the Job. Concentra is located at 1149 W. 190th st. Torrance CA 90248. Phone (310) 324-5777. Kaiser on the Job is located at 18600 S. Figueroa St. Gardena, CA 90248. Phone 1-833-574-2273.  For minor non-serious injuries the employee can visit the Student Health Center during its hours of operation, for first aid treatment and items such as Band-Aids, dressings, topical ointment and some over-the-counter medications.

If immediate medical treatment beyond first aid is required, call 911 from a campus phone, or contact University Police dispatch at 310-243-3333 from off-campus or cell phones. Emergency Medical Services will triage and send injured workers to the most appropriate medical facility.


Serious Injuries

Serious occupational injuries, illnesses or exposures to hazardous substances, as defined by Cal/OSHA, must be reported to EH&S within 8 hours of when they become known to managers or supervisors. Serious injuries include hospitalization for any length of time (for observation or diagnostic testing only are not included) ,deaths, amputations, concussions, loss of an eye, or any exposure to a hazardous substance that could create a realistic possibility of death or serious harm. Supervisors must report injuries that meet the Cal/OSHA definition of Serious Injury by calling University Police dispatch and informing them that this serious injury occurred to an employee as soon as they are notified of the injury. University dispatch will immediately inform Workers Compensations & EH&S. Required information includes the name of the injured employee, a brief summary of the incident, description of the injuries obtained by the employee, and a number where the reporting supervisor can be reached.  EH&S must report the injury to Cal/OSHA  within eight hours of occurrence. Departments are responsible for a minimum payment of a $5000 fine for late reporting. EH&S will conduct the follow up incident investigation with a representative from the injured employee’s department to determine any contributing conditions and develop corrective action plans.

Preliminary Incident Investigation

All workplace incidents to University employees that result in bodily injury, no matter the severity, MUST be reported to the employee’s supervisor immediately. The supervisor shall conduct the preliminary investigation using the Supervisors Report Of Work Incident  . The employee shall forward preliminary incident and injury investigations conducted by employee supervisors to EHS and Workers Compensation within 24 hours of notification of injury or illness. If the employee seeks any medical treatment beyond first aid, then a DWC-1 form must also be completed.

The incident investigation must be documented in writing using the supervisor report of work incident and must include the following:

  • A description of what took place that caused the injury.
  • Interview injured worker and any witnesses
  • Examine the area where the injury occurred to look for causes
  • What caused the situation to occur?
  • Was the employee trained and qualified to perform the task involved?
  • Were proper operating procedures established for the task involved?
  • Were procedures followed, and if not, why not?
  • What are other sources and/or contributing factors?

The person conducting the investigation shall determine which aspects of the operation or process require changes be made. It should be noted that the intent is not to establish blame, but rather, to determine what type of constructive action can be implemented to eliminate the cause(s) of the incident.

What action has been taken?

  • Actions taken to mitigate or eliminate the hazard(s) being investigated should be documented, along with those remaining to be addressed.
  • Any interim or temporary actions to be observed or implemented should be documented.
  • Any pending corrective action(s) and reason(s) for delaying implementation should be identified and documented.

Follow-up Incident Investigations

EHS shall conduct follow-up incident investigations for all serious injuries or illness. A serious injury or illness is defined as any injury or illness occurring at and in relation to employment at the campus, that requires inpatient hospitalization for reasons other than medical observation, or in which an employee suffers a loss of any member of the body or suffers permanent disfigurement.

EHS shall report any serious injury or illness of an employee to the nearest Cal/OSHA District Office as soon as practically possible but no longer than 8 hours after knowledge of, or if with diligent inquiry would have knowledge of, a death or serious injury or illness (8 CCR §342(a)).

Follow-up investigations shall include:

  • The time and date of incident.
  • Employers name, address and telephone number.
  • Name, contact information and Job title, or ID/badge number of person reporting the incident.
  • Address of the site of incident or event.
  • Name of person to contact at site of incident.
  • Name and address of the injured employee(s).
  • Nature of injury.
  • Location where injured employee(s) were moved to.
  • Identity of law enforcement agencies present at the site of the incident.
  • Description of incident and whether the incident scene or instrumentality has been altered.

Training and Instruction

Effective safety training is essential for a successful IIPP. Employees must be trained in areas of their job where hazards exist, including specific instructions on hazards unique to their job assignment. Training must be completed by the department before use of any dangerous equipment, exposure to any known hazardous conditions, or when new hazards are identified.

Managers must ensure supervisors are trained to recognize and abate safety and health hazards to which their employees are exposed. Supervisors are responsible for ensuring their employees receive appropriate safety training and for documenting that this training has been provided. Attendance at training classes and safety meetings is required. Documentation of individual safety training and safety meetings must be kept by the Department or available in CSU learn. These records can be kept with the supervisor or the Department Safety Coordinator.

Safety Training

Cal/OSHA requires that employees receive training and participate in topics relevant to their work assignments. This can be done in a variety of ways and include, but are not limited to, review of safety inspections, tailgates, one on one , fact sheets, review of incident investigations as well as traditional training.
Training and instruction on this IIPP shall be provided:

  • When the IIPP is first established.
  • When new employees are hired.
  • When employees given new job assignments for which training has not previously been received.
  • Whenever new substances, processes, procedures or equipment are introduced into the workplace and present a new hazard.
  • Whenever the employer is made aware of a new or previously unrecognized hazard.
  • When employees become supervisors.

Additional trainings employees should complete:

  • Hazard Communication
  • Emergency Preparedness
  • Ergonomics as it relates to their job (office or industrial)
  • General workplace safety
  • Function specific training that would be unique to their job assignments; BloodBorne Pathogens, Respiratory protection, hazardous waste, lockout/tagout, hot work, heat illness protection, etc.

General Awareness Safety Training

General Awareness training is an overview training typically upon hire to cover general safety requirements of the campus. This training type does not go over departmental specific needs to address workplace hazards. That training needs to be covered by within the specific department or work location.

Human Resources provide General University orientation to all new employees. This training includes IIPP training, information on the University's health and safety policies and practices, employee health and safety rights and responsibilities, health and safety services at the University, and what the employee should expect in terms of further training.


Function-Specific Training

Function-Specific training is provided by the College, Department, EHS, or a Vendor to employees in labs, shops, or other workplaces where special hazards may be encountered.  Examples of training topics include ergonomics, hazard communication, departmental emergency response/evacuation procedures, forklift safety, etc.

Job-Specific Training

Job-Specific training is provided by the supervisor for laboratory researchers and assistants, shop and food service workers, or other employees as appropriate. This training consists of information specific to the hazards and equipment used by these individuals. Training is communicated by one or more of the following methods:  demonstrations, safety meetings (formal or informal), safety data sheets, standard operating procedures (SOPs), job safety analyses (JSA’s), videos, pamphlets, booklets, and/or postings


Safety training

Employee training must be provided at no cost to the employee during the employee’s normal working hours. Safety training may be provided by a knowledgeable supervisor or department member, by representatives from other relevant campus departments and/or by approved vendors. A catalog of select topics for online instruction and classroom training is provided by going to mycsudh.edu and selecting CSU Learn.  All safety training must be documented, which includes all the following:

  • The subject of the training.
  • Date and time of training.
  • Name of the trainer for in-person training.
  • Name of the trainee(s).
  • Wet or electronic signature of the trained employee.

Training records shall be maintained by the department that provides the training or through CSU Learn.

Recordkeeping and Compliance

Records related to the implementation and maintenance of the University’s IIPP shall be retained per the CSU Executive Order 1031 record retention policy and on the Records/Information retention and disposition schedule:: http://www.calstate.edu/recordsretention/documents/EHS.pdf

The following records shall be maintained:

  • The IIPP document.
  • Records of hazard assessments/inspections and corrective actions.
  • Training records.
  • Incident investigation records.

Compliance

Compliance is critical for an effective Injury & Illness Prevention Program. Managers and supervisors serve as role models for working safely and provide resources necessary to ensure a safe work environment for their staff. All employees are required to follow safety policies and operating procedures. Employees will be provided with safety training and information to complete all assigned duties safely. When needed, employees will be provided with additional training and information, or re-training to maintain their knowledge of campus safety policies and procedures.

Employees who demonstrate safe work practices may be rewarded through the use of performance evaluations or incentive programs. Any employee who demonstrates repeated unsafe, unhealthy work practices will be subject to corrective action and/or disciplinary action. Disciplinary action will be in conformance with CSUDH policies and/or corrective bargaining agreements. If the offense is egregious or willful, the action may result in immediate disciplinary action. The Employee Labor Relations Department must be consulted on any disciplinary matter as it relates to compliance with this program.