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
A typical Cal/OSHA fine for an "ineffective" IIPP is $500-$1,500 and departments are financially responsible. 

IIPP Fine History at UC Davis (recent)

Year Fine Reason
2020 $5,000 No IIPP
2018 $475 Ineffective IIPP
2017 $750 Ineffective IIPP
2015 $1,350 Ineffective IIPP

Top 20 Cal/OSHA Violations Statewide

1. Injury and Illness Prevention Program (Title 8, §3203)
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

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)