Cal/OSHA Enforcing Repeat Violation Citations
The cost to a department for a Cal/OSHA violation is likely to increase dramatically, with additional penalties for repeat violations.
Our fines will be significantly higher because of proposed legislation and a precedent-setting action by Cal/OSHA that considers UC a single employer, that operates multiple sites.
The week of Oct. 4, one UC location received a repeat citation and additional penalty premiums, based on an earlier citation issued to a different UC location, for deficiencies in their Injury and Illness Prevention Program (IIPP).
Proposed Legislation Would Increase Fines 10x
We anticipate changes to the Occupational Safety and Health Act that would increase the minimum fine for a repeat or willful violation from $5,000 to $50,000. Maximum fines would increase from $70,000 to $700,000.
Critical Importance of an Effective Injury and Illness Prevention Program
Cal/OSHA inspectors visit campus multiple times a year and will always request a copy of the departmental IIPP during an inspection (i.e. serious accident, employee complaint, industry sweep, etc.). It is imperative that departments maintain effective IIPPs.
Cal/OSHA considers an IIPP ineffective, when:
- The IIPP is incomplete IIPP (i.e., no signatures, no Job Safety Analysis, no safety inspections)
- The IIPP has not been reviewed or updated recently
- Employees have not received training on the IIPP
IIPP Fine History at UC Davis (recent)
Top 20 Cal/OSHA Violations Statewide
The employer shall communicate the right and procedure to access the Program to all employees
2. Forklift General Requirements (Title 8, §3650)
3. Heat Illness (Title 8, §3395)
4. Air Tank Permit (Title 8, §461) [>1.5 Gallons]
5. Construction Injury and Illness Prevention Program (Construction Safety Orders Title 8, §1509)
6. Work Space About Electrical Equipment (Title 8, §2340)
7. Lock-Out-Tag-Out (Title 8, §3314)
8. Machinery and Equipment General Safety Order (Title 8, §3328)
9. Hazard Communication (Title 8, §5194)
10. Emergency Medical Services (Title 8, §1512)
11. Reporting Serious Injury (Title 8, §342)
12. Forklift Operator Training (title 8, §3668)
13. Emergency Eyewash/Shower (Title 8, §5162)
14. Process Safety Management (Title 8, §5189)
15. Respiratory Protection (Title 8, 5144)
16. Personal Fall Arrest, Restraint and Positioning Systems (Title 8, §1670)
17. Fire Extinguisher (Title 8, §6151)
18. Compressed Gases (Title 8, §4650)
19. Portable Ladder (Title 8, §3276)
20. Impalement Protection (General Industrial Safety Order, Title 8, §1712)
Get Help With Your IIPP
- Visit the Injury and Illness Prevention Program webpage
- The E-IIPP is available to assist departments in creating and maintaining an effective IIPP that meets Cal/OSHA requirements.
- For more information, questions, or assistance in updating your IIPP, please contact Steve Ball at IIPP@ucdavis.edu.
How the E-IIPP works:
- Invites are sent to complete, review, and update your departmental E-IIPP annually in January
- Once data is entered, the document will be populated for your review the following year
- Required signatures are completed via DocuSign
- Requirements for annual training, worksite inspections, and JSA completion/review need to be addressed prior to submitting the document as either completed or scheduled with a tentative date
- After submittal, EH&S will review your document for completeness and approve or send back for revision
- A final PDF of your E-IIPP, Appendices, and Job Safety Analysis (JSA) will be sent back for departmental use, i.e. website posting, printing, training, etc.
- A Learning Management System (LMS) module has been developed for specific instruction on how to complete the E-IIPP (DAC-HL0020-SAFSVC: UC Davis Electronic Injury and Illness Prevention Program)