I. Purpose & Scope
To provide an outline of requirements to ensure safe performance of all workers.
II. Definitions
N/A
III. Policy
A. Responsibility
- The Injury and Illness Prevention Program (IIPP) administrator, the Safety and Health Director, has the authority and responsibility for implementing the provisions of this program for MGE Underground. (1)
- All managers and supervisors are responsible for implementing and maintaining the IIPP in their work areas and for answering worker questions about the IIPP.
B. Compliance
- Management is responsible for ensuring that all safety and health policies and procedures are clearly communicated and understood by all employees. Managers and supervisors are expected to enforce the rules fairly and uniformly.
- All employees are responsible for using safe work practices, for following all directives and policies and procedures, and for assisting in maintaining a safe work environment. (2)
- Our system of ensuring that all workers comply with the rules and maintain a safe work environment include:
- Informing workers of the provisions of our IIPP.
- Evaluating the safety performance of all workers.
- Recognizing employees who perform safe and healthful work practices.
- Providing training to workers whose safety performance is deficient.
- Disciplining workers for failure to comply with safe and healthful work practices.
- Our Program meets minimum state and federal requirements and is reviewed and updated to ensure most current requirements are in compliance.
C. Communication
- We recognize that open, two-way communication between management and staff on health and safety issues is essential to an injury-free, productive workplace. The following system of communication is designed to facilitate a continuous flow of safety and health information between management and staff in a form that is readily understandable and consists of the following items:
- New worker orientation, including a discussion of safety and health policies and procedures.
- Review of our IIPP.
- Workplace safety and health training programs.
- Regularly scheduled safety meetings.
- Effective communication of safety and health concerns between workers and supervisors, including translation where appropriate.
- Posted or distributed safety information.
- A system for workers to anonymously inform management about workplace hazards. (4)
- The safety team that meets regularly, reviews results of the periodic scheduled inspections, reviews investigations of accidents and exposures and makes suggestions to management for the prevention of future incidents, reviews investigations of alleged hazardous conditions, and submits recommendations to assist in the evaluation of employee safety suggestions. (3)
D. Hazard Assessment
- Periodic inspections to identify and evaluate workplace hazards shall be performed by the area safety representatives.
- Periodic inspections performed according to the following schedule:
- Weekly during job site visits.
- When we initially established our IIPP.
- When new substances, processes, procedures or equipment which present potential new hazards are introduced into our workplace.
- When new, previously unidentified hazards are recognized.
- When occupational injuries and illnesses occur.
- Whenever workplace conditions warrant an inspection. (5)
E. Accident/Exposure Investigations
- Procedures for investigating workplace accidents and hazardous substance exposures include:
- Visiting the accident scene as soon as possible.
- Interviewing injured workers and witnesses.
- Examining the workplace for factors associated with the accident/exposure.
- Determining the cause of the accident/exposure.
- Taking corrective action to prevent the accident/exposure from reoccurring.
- Record the findings and corrective actions taken. (6)
F. Hazard Correction
- Unsafe or unhealthy work conditions, practices or procedures shall be corrected in a timely manner based on the severity of the hazards. Hazards shall be corrected according to the following procedures:
- When observed or discovered.
- When an imminent hazard exists that cannot be immediately abated without endangering employee(s) and/or property, we will remove all exposed workers from the area except those necessary to correct the existing condition. Workers necessary to correct the hazardous condition shall be provided with the necessary protection.
- All such actions taken and dates they are completed shall be documented on the appropriate forms.
- Employee are encouraged and required to participate in incident investigation root cause analysis, weekly safety meetings to cover previous incidents and corrective actions and have access to anonymous hazard reporting.
G. Training and Instruction
- All workers, including managers and supervisors, shall have training and instruction on general and job-specific safety and health practices. Training will cover the access and right to obtain a copy of the IIPP. Training and instruction shall be provided as follows:
- When the IIPP is first established.
- To all new employees when they onboard.
- To all workers given new job assignments for which training was not previously provided.
- Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard.
- Whenever the employer is made aware of a new or previously unrecognized hazard.
- To supervisors to familiarize them with the safety and health hazards to which workers under their immediate direction and control may be exposed.
- To all workers with respect to hazards specific to each employee’s job assignment.
- Workplace safety and health practices for all industries include, but are not limited to, the following:
- Explanation of the employer’s IIPP and measures for reporting any unsafe conditions, work practices, injuries and when additional instruction is needed.
- Use of appropriate clothing, including gloves, footwear, personal protective equipment.
- Information about chemical hazards to which employees could be exposed and other hazard communication program information.
- Availability of toilet, hand-washing and drinking water facilities.
- Provisions for medical services and first aid, including emergency procedures.
- In addition, we provide specific instructions to all workers regarding hazards unique to their job assignment, to the extend that such information was not already covered in other training.
H. Employee Access to the IIPP
- Our employees – or their designated representatives – have the right to examine and receive a copy of our IIPP. This will be accomplished by providing unobstructed access through a company server or website, which allows an employee to review, print and email the current version of the program.
- Unobstructed access means that the employee, as part of their regular work duties, predictably and routinely uses the electronic means to communicate with management or coworkers.
I. Recordkeeping
- The following steps will be taken to implement and maintain our IIPP:
- Records of hazard assessment inspections, including the person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and the action taken to correct the identified unsafe conditions and work practices, are recorded on a hazard assessment and correction form; and
- Documentation of safety and health training for each worker, including the worker’s name or other identified, training dates, type(s) of training, and training providers is recorded on a worker training and instruction form. We also include the records relating to worker training provided by a construction industry occupational safety and health program approved by Cal/OSHA.
- Inspection records and training documentation will be maintained for one year.
- OSHA Targets and goals are documented monthly and reviewed during the Safety Meeting and Management meeting for review.
- MGE Underground will keep records of all COVID-19 cases, including the employee’s name, contact information, occupation, location of work, date of the last day at the workplace, and the date of the positive COVID-19 test and/or COVID-19 diagnosis.
- MGE Underground will also maintain records of any notices required by Cal/OSHA regulations, Labor Code section 6409.6, or any other applicable law.
- Personal identifying information of COVID-19 cases or persons with COVID-19 symptoms, as well as employee medical records, will be kept confidential except when required or allowed by law. Unredacted information on COVID-19 cases will be provided immediately upon request by the local health department with jurisdiction over the workplace, CDPH, the Division, and NIOSH, and when required by law.