Injury Illness Prevention Program

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• Mission Statement
• Responsibilities
• Ensuring Compliance
• Communications
• Identifying Hazards, Unsafe Conditions and Practices
• Accident/Exposure Investigations
• Hazard Correction
• Training and Instruction
• Recordkeeping
• Exhibit A
• Appendix

Mission Statement

Claremont McKenna College strives to provide a safe and healthful work and study environment for employees, visitors, and students.  The College recognizes that this responsibility cannot be discharged passively, but requires the active participation and support of all.  The intent of this particular document is to encourage employees to communicate openly on safety and health matters.  The structure allows for and encourages open communication across the College and without fear of reprisal.

This document, the Injury and Illness Prevention Program (IIPP), serves as the framework for us to accomplish our mission and has been prepared in compliance with Title 8, Section 3203 of the California Code of Regulations and consists of the following eight elements:

• Responsibility
• Compliance
• Communication
• Hazard Assessment
• Accident/Exposure Investigation
• Hazard Correction
• Training and Instruction
• Recordkeeping

The Program is designed to be a demonstration of good faith compliance to the above mentioned requirements and to serve as a framework for the Claremont McKenna College Safety Program.

Responsibilities

Responsibility for the implementation and maintenance of the Injury and Illness Prevention Program has been delegated to the Assistant Vice President for Human Resources. 

All managers and supervisors of the College are responsible for implementing and maintaining the Injury and Illness Prevention Program in their work areas, for answering questions about the IIPP and for maintaining a safe work environment. 

Employees are responsible for complying with the elements of the IIPP, reporting hazards, attending training, reporting accidents, following policies and procedures and working safely. 

CMC Building Safety Coordinators (“Coordinators”) are responsible to serve as a representative of staff, faculty, and students and to assist in establishing and maintaining a safe environment and complying with the elements of the Injury and Illness Prevention Program.  Coordinators responsibilities include but are not limited to, attending periodic committee meetings, identifying and reporting hazards, receiving additional safety training, participating in radio drills and serve as main point of contact in the event of a campus wide emergency.  See Exhibit A for the Coordinator Guidelines and Expectations, and a list of members

Ensuring Compliance

All employees are responsible for complying with the IIPP and providing a safe working environment and following healthful work practices.  CMC takes the following steps to ensure that these practices are followed:

• All new employees are provided an orientation on safety policy, procedures and practices. 
• Informs employees of the provisions of the IIP Program on a regular basis.
• Evaluates the safety performance of all employees on a regular basis.
• Provides training as appropriate to employees whose safety performance is deficient. 
• Disciplines employees who willfully fail to comply with safe and healthful work practices. 

Communications

All managers and supervisors are responsible for communicating with employees about safety and safety hazard recognition, pertinent to their work assignments, and in a form that is readily understandable by all employees.  Employees are responsible to communicate with their managers and supervisors about workplace safety hazards and should do so without fear of reprisal.

The CMC safety communication system includes, but is not limited to the following items: 

• Safety Training including a New Employee Safety Orientation
• Training on the elements of the IIPP
• Department specific safety training programs
• Building Safety Coordinators and regularly scheduled safety committee meetings
• Material Safety Data Sheet Program
• Posted or distributed safety information
• Department meetings
• A system for employees to anonymously inform management about workplace hazards.  Employees can report hazards anonymously to CMC Listens at 800-461-9330 or 702-514-4400 if outside the United States

Identifying Hazards, Unsafe Conditions and Practices

Periodic inspections to identify and evaluate workplace hazards shall be performed by the supervisor or a competent observer.  Periodic inspections may be performed:

• When substances, processes, procedures or equipment, which present potential new hazards, are introduced into the workplace
• When new previously unidentified hazards are recognized
• When occupational injuries and illnesses occur
• Whenever workplace conditions warrant an inspection

Additionally, methods to identify and report unsafe conditions and practices may also include:

• Department specific self-inspection checklists and reports submitted to your supervisor
• Employee reporting of hazards to Building Safety Coordinators members
• Employee reporting of hazards to Human Resources at 909-621-8490 or extension 18490
• Employee reporting of hazards directly to Facilities at 909-621-8112 or extension 18112
• Anonymous reporting to CMC Listens at 800-461-9330 in the United States or 702-514-4400 if outside the United States

Accident/Exposure Investigations

Each accident or near miss shall be investigated by the employee’s supervisor to prevent reoccurrence.  The department supervisor is required to complete a supervisor’s report of Occupational Accident form.  Procedures for investigating workplace accidents and hazards substance exposures include:

• Interviewing injured workers and witnesses
• Examining the workplace for factors associated with the accident or exposure
• Determining the root cause of the accident or exposure
• Taking corrective action to prevent the accident or exposure for reoccurring
• Record the findings and actions taken

The department supervisor or manager may request assistance in the investigation process by contacting the Human Resources Department or the Environmental Health and Safety Manager. The completed supervisor’s report of accident form shall be sent by the supervisor to Human Resources.  The supervisor may be contacted to answer questions regarding the report.  For serious accidents, an independent investigation may also be required.

All serious accidents must be reported by the supervisor to Human Resources immediately or to Campus Safety, if after hours, in order to determine if further timely reporting to CAL/OSHA is required.

For definition purposes, a serious accident is defined by CAL/OSHA as:

Any injury or illness in which the following conditions exist:

• Inpatient hospitalization for a period in excess of 24 hours for other than medical observation, or

• An employee suffers a loss of any member of the body, or
• An employee suffers any degree of permanent disfigurement, or
• An accident resulting from a violation of section 385 of the Penal Code, by placing anything within six feet of a high voltage overhead conductor. 

Hazard Correction

Hazards discovered by any of the aforementioned identification methods will be corrected as quickly as possible after discovery of the hazard and based on the severity of the hazard. Supervisors of affected areas are responsible for ensuring that any hazards are corrected in a timely manner.

Hazards correction and control may include:

• Reporting the hazard as defined by the Hazard Assessment protocols outlined above
• Assessing the hazardous condition and prioritized
• Neutralizing the hazard
• Reassessing the hazard and correcting the hazard
• Documenting the correction of the hazard
• Notification to affected employee of the correction
• Retraining, if necessary

If the problem poses an immediate danger of serious harm or bodily injury and cannot be corrected immediately, the area should be cordoned off or the equipment should be locked out until corrections can be made.  The supervisor and Campus Safety must be notified immediately. 

Training and Instruction

All employees shall have training and instruction on the Injury and Illness Prevention Program, Hazard Communication Program and Emergency Plans, as well as job specific safety and health practices. In addition, training and instruction is provided:

• To all employees given new job assignments for which training has not been 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 new or previously unrecognized hazards

Other job related activities may require additional training.  These situation need to be anticipated and evaluated by each manager and supervisor.  Departmental managers are responsible for arranging and scheduling training.  All training shall be documented by the supervisor and rosters of attendance shall be maintained by the supervisor.  These activities may include but are not limited to: 

• Hazardous Chemical Use
• Fall Protection
• Ladder Use
• Fire Extinguisher use
• Slips, Trips and Fall Hazards
• Ergonomics and Repetitive Motion
• Electric Cart Use
• Confined space
• Heavy lifting
• Heat Exposure
• Blood Borne Pathogen exposure

Employee safety training as referenced in this document is provided at no cost to the employee and is conducted during normal working hours. 

Recordkeeping

CMC has taken the following steps to implement and maintain the following records:

• The College shall maintain a “Log of Occupational Injuries and Illnesses”.  The Cal/OSHA Form 300 will be used to maintain these records.  The Claremont Colleges Worker’s Compensation and Disability Administrator is responsible for maintenance of this log.
• Occupational injuries and illnesses shall be reported by the Claremont Colleges Worker’s Compensation and Disability Administrator to the Division of Labor Statistics and Research, as required by law. 
• The Claremont Colleges Worker’s Compensation and Disability Administrator shall be responsible for notifying the College’s workers’ compensation insurance company within 48 hours of a work related injury or illness and shall maintain a record of all accident and illness reports.
• Record of hazard assessment identification and corrections shall be recorded and maintained for 3 years.
• Records of scheduled and periodic workplace inspections will be maintained by the area conducting the inspection, including the person(s) conducting the inspection, any identified unsafe conditions or work practices, and corrective actions. Such documents will be maintained for 3 years.
• Record of safety training shall be documented and include the training date, type of training, who attended the training and who performed the training and shall be maintained by the department for 3 years.
• Records pertaining to employee environmental exposure or industrial health records will be retained for duration of employment plus 30 years.
• Safety committee meeting documentation will be maintained by Human Resources for 3 years.

Exhibit A

CMC Safety Coordinators Guidelines and Expectations 

CMC Building Safety Coordinators play an important and essential role in the Safety Program at Claremont McKenna College.  Building Safety Coordinators are responsible to serve as a representative of staff, faculty, and students and to assist in establishing and maintaining a safe environment and complying with the elements of the Injury and Illness Prevention Program.  Additionally, Building Safety Coordinators are trained first responders and coordinate safety and evacuation efforts during drills or in the event of a campus wide emergency. 

Responsibilities:

Building Safety Coordinators are responsible to:

• Attend monthly committee meetings.
• Set an example for proper behavior, work habits and practices in relation to safety and housekeeping.
• Assisting administration in encouraging safe behavior by all staff, faculty, and students by improving the “work together spirit” between everyone.
• Communicating to the Environmental Health and Safety Manger and/or Assistant Vice President for Human Resources or his or her delegates any suggestions, concerns, and questions regarding safety and good housekeeping.
• Identify and report hazards.
• Disseminating safety information to employees about situations that can cause injury or disease.
• Participating in radio and emergency drills.
• Coordinate safety and evacuation efforts during drills or in the event of a campus wide emergency.
• Maintain emergency supplies
• Facilitate a rapid and safe evacuation, account for individuals, and communicate with Incident Commanders in the event of an emergency.

Ensuring Compliance

Building Safety Coordinators are responsible for complying with the IIPP, providing a safe working environment, following and encouraging healthful work practices. 

Communications

Building Safety Coordinators are expected to regularly attend scheduled safety committee meetings to receive relevant safety information and report hazards.  They are responsible for communicating with employees within their areas about safety and disseminating relevant information to employees provided in Building Safety Committee meetings.  Building Safety Coordinators are expected to ensure that safety and pertinent informational flyers are posted in their respective areas. 

Hazard Assessment   

Building Safety Coordinators are expected to report hazards, unsafe conditions and practices immediately. Building Safety Coordinators may be expected to participate in and/or conduct periodic inspections of their work space to identify and evaluate workplace hazards.

Building Safety Coordinators are expected to report unsafe conditions or hazards in one or more of the following ways:

• Reporting the hazard to supervisor
• Reporting the hazard to safety committee
• Reporting the hazard to the Environmental Health and Safety (EHS) Manager at 909-607-3187
• Reporting the hazard to Human Resources at 909-621-8490 or extension 18490
• Reporting the hazard to Facilities and Campus Services (FACS) at 909-621-8112 or extension X 18112 via the FACS work order system
• Reporting the hazard to anonymous reporting line, CMC Listens, at 800-461-9330 in the United States or 702-514-4400 if outside the United States

Injuries and Illnesses

Each accident, regardless of the severity, shall be investigated by the EHS Manager and department supervisor to determine the “root cause” and shall be documented in an Occupational Accident form by the injured workers supervisor to prevent reoccurrence.  Specific procedures for investigating workplace accidents and hazardous substance exposures include:

• Interviewing injured workers and witnesses
• Examining the workplace for factors associated with the accident or exposure
• Reviewing established procedures to ensure they are adequate and were followed;
• Reviewing training records of affected employees;
• Determining all contributing causes to the accident [equipment, material, people];
• Taking corrective action to prevent the accident or exposure for reoccurring
• Record the findings and actions taken

The department supervisor may request assistance in the investigation process by contacting the EHS Manger or Human Resources Department. 

Accident Instructions

In the event of an injury and/or an illness that is life, limb or eyesight threatening, the supervisor must call Campus Safety at 909-607-2000 or 911 for emergency response.  The supervisor must be sure to provide the dispatch operator the exact physical address or location.  If possible, when in a life, limb or eyesight threatening situation, the supervisor must contact Campus Safety to inform them of the situation.

In the event of an injury that is NOT life, limb or eyesight threatening, the supervisor or manager will call the TravCARE Nurse Line at 1-855-385-6037 to report the claim and assist the injured employee.  The TravCARE Nurse Line is available 24 hours per day/7 days per week.

Supervisors must ensure the employee receives first aid, or if necessary, proper medical treatment at the selected medical clinic or emergency room as recommended by the TravCARE Nurse Line.  If possible, the supervisor or another staff member can accompany the employee to the medical clinic.  If the injured employee is not able to drive themselves to the medical clinic, the supervisor shall contact HR or the EHS Manager for alternate means of transportation for the employee to the medical clinic. 

After ensuring that the sick or injured employee has received the appropriate care and medical attention, the supervisor will promptly, thoroughly and accurately complete all injury and illness reporting forms.  The supervisor of an injured employee must ensure that the Employee’s Report of Occupational Accident and the Supervisor’s Report of Occupational Accident are properly completed and sent to Claremont McKenna’s Human Resources Department and The Claremont Colleges Disability and Worker’s Compensation Office.

Training

All Building Safety Coordinators are required to participate in and cooperate with all training efforts.   Building Safety Coordinators are expected to attend monthly safety committee meetings for additional training opportunities, as necessary.  

Emergency Activation

Building Safety Coordinators play an essential leadership role during an emergency.  Building Safety Coordinators are expected to performing the following functions in a calm, clear and compassionate manner: 

• Facilitate a rapid and safe evacuation.
• Account for all people within the area of responsibility.
• Serve as a communication and control mechanism.

Additionally, Building Safety Coordinators may be required to: 

• Warn people in the area of responsibility of the need to evacuate.
• Evacuate self and others to a safe evacuation area or move group to alternative evacuation area.
• Notify the appropriate officials of the type of incident and its location.
• Assess and report on the situation including but not limited to:
  • assess the condition of the evacuation area
  • account for all people in the area of responsibility
  • if possible, determine location of missing persons
  • request additional assistance

Building Safety Coordinators

Appendix

Forms

• Employee’s Report of Occupational Accident
• Supervisor’s Report of Occupational Accident

Injury and Illness Program Responsibility Guidelines

• Supervisor
• Employee
• Safety Coordinator

Policies and Procedures

The following items listed below are all on the CMC website under Human Resources/Policies

• Bloodborne Pathogens Exposure Control Plan
• Electric Cart Policy
• Hazardous Communication Program
• Return To Work Program
• Violence in the Workplace Prevention Policy

Emergencies

A link to the Emergency Website is available on the CMC website under Emergencies and under Human Resources.

• Emergency Updates
• Emergency Procedures

Original Document: Predates 2008
Revised: February 2017, August 2018