Now Would Be a Good Time to Update Your Illness and Injury Prevention Programs

By Sean Hogle, Partner, Rooney Nimmo San Francisco

As in many other jurisdictions in the US and abroad, all employers in California, regardless of size or industry, are required by law to have an illness and injury prevention program (IIPP). This requirement is often overlooked but frequently enforced.

In the words of one practitioner, “Cal/OSHA issues more citations under the IIPP standard than any other standard – thousands each year – many of them for a complete failure to have an IIPP. During a Cal/OSHA inspection, one of the first documents asked for is the IIPP, and failure to have one can carry a penalty of up to $25,000.”

Many other states mandate such programs as well. They require employers to proactively detect and remediate workplace hazards, reduce their frequency, and mitigate their harm.

COVID-19 is one such hazard – one that has brought nearly the entire world to its knees. Large parts of the globe are now subject to shelter-in-place orders. Companies everywhere are advising their employees to work from home, with only essential staff allowed to attend their workplaces. IIPP program documents should be updated to deal with the virus, without delay.

We recommend that you review the plans and strategies you have in place to protect your workers from exposure to the coronavirus, verify that they comply with IIPP rules, and ensure that they incorporate the legal requirements and recommended practices set out by the US Occupational Safety and Health Administration (OSHA) and that they otherwise comply with related state laws.  A recent article by Bloomberg Law, titled OSHA Virus Rules for Employers are About More Than Just Masks, highlights the top OSHA standards that apply to the pandemic.

We highly recommend moving quickly to ensure you are compliant. If you would like us to review your IIPP policies, please contact Sean Hogle or Allan Rooney, or visit our website.


This Article Is One Of A Series Intended To De-Mystify Common Legal Issues For The Non-Lawyer And Entrepreneur Audience – They Are Designed To Foster Discussion And Is By No Means Exhaustive. These Materials Are For Informational Purposes Only. Nothing Herein Is Intended Nor Should Be Regarded As Legal Advice. The Distribution Of This Article To Any Person Does Not Establish An Attorney-Client Relationship With Our Firm. Rooney Nimmo Assumes No Liability In Connection With The Use Of This Publication. This Bulletin Is Considered Attorney Advertising Under The Applicable Rules Of New York State. Rooney Nimmo UK Is Regulated By The Law Society Of Scotland And Rooney Nimmo US By The New York Rules Of Professional Conduct. All Attorneys And Solicitors Listed In This Firm Stipulate Their Jurisdictional Limitations. Rooney Nimmo In The USA Is A Law Firm Registered As A New York State Professional Corporation.


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