injury illness prevention program (iipp) 2016 · bcci has developed and implemented this written...

Injury Illness Prevention Program (IIPP) 2016

Table of Contents

1. Safety and Health Policy Statement 2

2. Assignment of Responsibilities 3

3. Employee Compliance 8

4. Communication of Safety and Health Expectations 10

5. Hazard Assessment and Inspections 12

6. Accident / Exposure Investigations 14

7. Hazard Correction procedures 17

8. Safety Training and Instruction 18

9. Record Keeping 20

2016 IIPP, | BCCI Construction Company | Page 2

SAFETY AND HEALTH STATEMENT BCCI has developed and implemented this written Injury and Illness Prevention Program (IIPP) as part of its health and safety program. The work performed by BCCI personnel is varied, both in nature and location. Under all circumstances, it is the intent of BCCI to provide a safe and healthful work environment for employees. BCCI expects and requires all employees to follow the requirements set forth in this IIPP. In addition, BCCI incorporates safety into every aspect of our daily business operations to not only provide a safe and healthy work environment for our employees but for our sub-contractors and customers as well. Each of our employees is empowered to refuse any work or task that they believe is unsafe or that involves unnecessary risk. We understand and believe that safety is every employee’s responsibility, and that includes everyone in the organization. Each department has safety responsibilities. We expect our employees to be engaged in our safety program which includes ownership in detecting, communicating and mitigating hazards in the workplace, as a condition of employment. Inform your supervisor immediately of any situation beyond your ability or authority to correct. We also understand that our program must include positive reinforcement of desired behaviors as well as a consistent discipline for undesired actions and behaviors, at all levels of our organization. Through coaching, mentoring and excellent safety leadership from our supervisors and the participation of our workforce, we are committed to being a safety leader in our industry. Only through such a cooperative effort can we achieve our goal of making the work environment as safe as possible. Copies of this Injury and Illness Prevention Program can be found at the following locations: (1) A digital copy is readily available on our intranet to all BCCI team members (2) BCCI supervisors keep a copy at their jobsite (3) San Francisco office 1160 Battery Street, Suite 250 (4) Palo Alto office 2445 Faber Place Ste 200

Michael Scribner, President and CEO BCCI Construction Company


ASSIGNMENT OF RESPONCABILITIES - 8 CCR 3203(a)(1) BCCI Construction Company accepts the responsibilities for leadership of the company IIPP, for its effectiveness, improvement, and for providing the safeguards required to ensure safe conditions. Michael Fraley VP Field Operations Mobile: 415.850.1427 Office: 415.817.5113 [email protected] Is responsible for the company IIPP. He has the authority and is responsible for overall management and administration of our Injury and Illness Prevention Program and to coordinate these efforts with all employees to ensure that safety standards are met throughout the organization. It is the objective of BCCI to conduct all operations as safely and efficiently as possible. To accomplish this, we are assigning the responsibility, authority, and accountability for safety to all management and supervisory personnel within their individual area of operation. BCCI employees are responsible for complying with all aspects of this Injury& Illness Prevention Program, including compliance with all laws, rules and regulations, and for continuously utilizing safe work practices while performing their duties. Company Leadership Definition CEO, CFO, and Vice Presidents Responsibilities Leadership is responsible for promoting and funding an organization focused on working in a safe manner. Activities

- Become familiar with the Company IIPP and Code of Safe Work Practices. - Fund the cost of the Safety Program.

mailto:[email protected]


Pre construction Definition Estimators and Project Engineers Responsibilities Supervisors are responsible for their project and those that they supervise, in addition to ensuring that all operations are performed with the utmost regard for the safety and health of all personnel involved, including themselves. Activities

- Become and remain familiar with the company’s IIPP and Code of Safe Work Practices. and maintain a current copy at all times.

- Be able to explain BCCI Safe Work Practices to Subcontractors and Clients. - Include BCCI Safe Work Practices in Scope Letters and Bidding documents,

when appropriate. - Participate in developing safety rules, and ensure they are effective in

preventing injuries and incidents. - Responsible for enforcing our safety policies, programs, procedures and

code of safe work practices. - Assures that safety devices and personal protective equipment are provided. - Assure that all injuries are reported and treated promptly per company

guidelines. - Assist in the investigation of incidents, and near miss incidents. - Assure that no unsafe conditions exist and immediately correct any unsafe

acts, conditions or behaviors. - Report immediately to management any issue that needs corrective actions

which are beyond his/her control or responsibility.


Project Management Definition Project Managers and Assistant Project Managers Responsibilities Supervisors are responsible for their project and those they supervise, and for ensuring that all operations are performed with the utmost regard for the safety and health of all personnel involved, including them. Activities

- Become and remain familiar with the company’s IIPP and Code of Safe Work Practices. Maintain a current copy at all times.

- Responsible for enforcing our safety policies, programs, procedures and code of safe work practices.

- Assures that safety devices and personal protective equipment are provided and used appropriately.

- Assure that all injuries are reported and treated promptly per company guidelines.

- Investigates all incidents, near miss incidents, completes associated reports promptly, and develops lessons learned report that is shared across the company in order to prevent recurrence.

- Assure that no unsafe conditions exist by immediately correcting any unsafe acts, conditions or behaviors.

- Report immediately to management any issue that needs corrective actions which are beyond his/her control or responsibility.

- Conducts inspections and audits to identify unsafe conditions and compliance to safe work practices.


Field Operations Field Operations Managers, Superintendents, Quality Control Coordinators Responsibilities Supervisors are responsible for their project and those they supervise, and for ensuring that all operations are performed with the utmost regard for the safety and health of all personnel involved, including themselves. Activities

- Become and remain familiar with the company’s IIPP and Code of Safe Work Practices. Maintain a current copy of both on site at all times. Use the IIPP, Code of Safe Practices, lessons learned, and other topics for weekly toolbox meetings/safety talks (every 10 days at minimum) to ensure all employees are informed and understand them. All meetings must be documented and employees must sign in for each meeting and all record keeping of these meetings will be stored in accordance with our record keeping policy outlined in this IIPP--which is in compliance with California regulations.

- Enforce safety regulations, coach and mentor employees in safe work practices and behaviors, participate in developing safety rules, and ensuring they are effective in preventing injuries and incidents.

- Ensure that each new employee receives indoctrination in their New Employee Safety Orientation and HazCom training, and have completed all requirement before starting their assignment.

- Responsible for enforcing our safety policies, programs, procedures and code of safe work practices.

- Responsible to ensure that a positive recognition program is in place and effectively recognizes employees that exhibit desired safety behaviors.

- Coordinates safety activities in his/her area of responsibility. - Assures that safety devices and personal protective equipment are provided

and used appropriately. - Assure that all injuries are reported and treated promptly per company

guidelines. - Investigates all incidents, and near miss incidents, and complete reports

promptly and develops lessons learned report that is shared across the company in order to prevent recurrence.

- Assure that no unsafe conditions exist and immediately correct any unsafe acts, conditions or behaviors.


- Report immediately to management any issue that needs corrective actions which are beyond his/her control or responsibility.

- Conducts inspections and audits to identify unsafe conditions and compliance to safe work practices.

Employees Responsibilities

- All employees shall adhere to BCCI safety policies, programs, procedures and Code of Safe Work Practices at all times as a condition of employment.

- Report all injuries, incidents and near misses, no matter how minor, immediately to a supervisor.

- Encourage co-workers to work safely. - Maintain a positive attitude towards safety. - Report unsafe acts and conditions to the supervisor immediately and take

responsibility for their safety and the safety of their co-workers. - Do not perform and work at any job or location that is unsafe, use equipment

that is unsafe or place yourself or your co-workers at risk of injury at any time.


EMPLOYEE COMPLIANCE - 8 CCR 3203(a)(2) All employees are required to follow BCCI company safety policies and procedures. When needed, employees will be provided with additional training and information, or re-training to maintain their knowledge. The disciplinary policy is intended to encourage employee compliance with our IIPP. BCCI understands that our program must include positive reinforcement of desired behaviors as well as a consistent discipline for undesired actions and behaviors, at all levels of our organization. Through coaching, mentoring and excellent safety leadership from our supervisors and the participation of our workforce, we are committed to being a safety leader in our industry. Only through such a cooperative effort can we achieve our goal of making the work environment as safe as possible. Consider using the safety recognition form attached to be completed upon display of exemplary safety performance which will then be included in their employee file and recognized accordingly? Employee Disciplinary Procedures When an employee is disciplined, it must be documented and brought to the attention of management. Additionally, in the interest of employee morale and to prevent legal exposure, it is important that these procedures are applied consistently, fairly, and without prejudice. Employees who fail to comply with safety rules will be subject to disciplinary action up to and including termination. Supervisors will follow the normal disciplinary procedures as follows:

▪ 1st Step -Written Warning Must be documented in the employee's personnel file.

▪ 2nd Step -Written Warning and Suspension Outlining nature of offense and necessary corrective action and one week minimum suspension from work.

▪ 3rd Step - Suspension Without Pay or Termination After two written warnings, or a separate disciplinary action resulting from a serious violation.

▪ Termination. If an employee is to be terminated, specific and documented communication between the supervisor and the employee, as outlined, must have occurred.


Zero Tolerance The Zero Tolerance list indicates items that may result in immediate termination. The following violations may be grounds for immediate termination:

▪ Drugs or alcohol on the job site.

▪ Fighting, threatening or endangering others.

▪ Removing or bypassing safety devices on power tools or equipment; i.e.: removing or pinning saw guards, removing safety spring on nail guns, etc.

▪ Failure to follow a fatality prevention program such as: - Not using fall protection where required. - Not following proper Safe Off procedures. - Not following the Confined Space Program where required - Removing or damaging safety equipment. - Unsafe operation of a vehicle - Knowingly violating a written rule or procedure - Possession of a firearm on a BCCI job site or office location


COMMUNICATION OF SAFETY AND HEALTH EXPECTATIONS - 8 CCR 3203(a)(3) We recognize that, open two-way communication between management and staff on health and safety issues is essential to an injury-free, productive work place. 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 checked and understandable to all employees.

Accordingly, all new employees will go through a safety orientation prior to starting work. This safety orientation will be given in the employee’s normal speaking language and covers topics such as trenching, excavation, scaffolds, blood-borne pathogens, fatality prevention programs, safe work procedures and general worksite hazards and conditions. New employees will be educated in, and made aware of, the company’s safety and health policies and procedures as well as the Code of Safe Practices and our Illness and Injury Prevention Program. A record of this initial training will be recorded on the initial documentation of IIPP training form and will then be stored in accordance with BCCI's record keeping policy which is in compliance with all applicable regulations. The IIPP/Code of Safe Practices and all other safety issues will be communicated in a form readily understandable for all employees. Direct communication of safety matters in the field between employees and supervisors is required and encouraged and translation will be provided when needed. Safety information is posted and distributed via our Operations Department. In addition, BCCI encourages communications from employees to their supervisors and the safety representative(s), regarding unsafe or unhealthy conditions. Any employee who reports a condition that poses a risk to the health and safety of any BCCI employee, sub-contractor, or customer should do so without fear of reprisal or retaliation; however, if any employee reporting a hazard wishes to remain anonymous they can do so upon request. Employees must communicate these hazards in writing to: Michael Fraley VP Field Operations Mobile: 415.850.1427 Office: 415.817.5113 [email protected]



Safety Meetings will be held weekly and will be conducted by the Foreman, Assistant Superintendent, Quality Control Coordinator or Superintendent. All BCCI employees working on the project are required to attend. The supervisor will present the meeting topic for the job. Safety topics will be discussed as they pertain to current operations and hazards on the job. Additional meetings will be held when there are changes in the work process, specific training or updates to the company’s safety policies and procedures. Safety Committee Meetings In accordance with T8 CCR (7)(c)(1) - (7), BCCI elects to use a labor/management safety and health committee that meets all requirements of the aforementioned comply with the communication requirements of subsection (a)(3) of T8 CCR 3203. In response to this, BCCIs Safety Committee Meetings will be held quarterly. Members on the committee will comprise a mix of Project Supervisors (Estimators, Project Managers and Superintendents) and Executive Management. The committee will review all incidents, inspections, and safety training for the quarter. The committee will also discuss other safety matters relating to upcoming training classes and program modifications. Posters and Notices BCCI complies with T8 CCR §9881 for Posting of Notice to Employees. All required employee notification and communication posters will be displayed in areas where employees gather, such as trailer complex, gang boxes, break room, or eating areas. Newsletters and notices will be used to provide additional information to employees on company and safety matters, as needed.


HAZARD ASSESSMENTS AND INSPECTIONS - 8 CCR 3203(a)(4) The goal of this IIPP is to identify and evaluate unsafe work conditions and practices so that accidents, injuries, and job-related illnesses are minimized, if not completely eliminated. To this end, BCCI has instituted the procedures described in this section of the IIPP. The principal approach to reducing accidents at BCCI is through periodic scheduled and unscheduled inspections. Inspections will be conducted as follows: All personnel will be responsible for continuous, ongoing inspection of the workplace. When uncovered, potentially hazardous conditions will be corrected immediately. The safety personnel and their job titles that are responsible for conducting documented job site inspections are as follows:

▪ Labor Foremen

▪ Superintendent

▪ Labor Superintendent

▪ Field Operations Managers

▪ QHSI safety representative

▪ Project Managers

▪ BCCI Safety Committee members Inspections Job site (and office locations?) inspections are an essential part of managing the effectiveness of our safety program. We will utilize our audit program as a positive tool in eliminating hazards and strive to communicate findings throughout the project and company to prevent recurrence and help ensure consistency across our company. Visual Inspections will be conducted daily and routinely by the project manager, superintendent or foreman in an effort to inspect for and correct unsafe conditions and acts. Documented Inspections are to be conducted by the project manager, superintendent or foreman (or other designated individuals) on a daily basis utilizing the BCCI Site Safety Inspection checklist.


Documented Inspections of the workplace will be conducted by using the guidelines listed below: - Daily inspections and whenever workplace conditions warrant an inspection. - Quarterly inspections will be conducted by a third party safety consultant. - Visual inspections are to be done daily prior to the start of the workday and when

changes have affected the work place making it unsafe or unhealthy for our employees.

- When we hire and/or reassign permanent or intermittent workers to processes, operations, or tasks for which a hazard evaluation has not been previously conducted. Inspections also shall occur when:

- When major revisions occur within our IIP Program. - When new substances, processes, procedures, or equipment which present

potential new hazards are introduced to our workplaces. - When new previously unidentified hazards are recognized. - When we hire and or reassign permanent or intermittent workers to processes,

operations, or tasks for which a hazard evaluation has not been previously conducted.

- Whenever work place conditions warrant an inspection.


ACCIDENT / EXPOSURE INVESTIGATIONS - 8 CCR 3203(b)(5) Prompt reporting is critical to responding, investigating and preventing the recurrence of incidents, injuries and work related illnesses. Immediate reporting of all injuries and incidents allows more time to conduct an adequate investigation. No claim, loss, damage or accident is so small that it does not warrant a report. When employee accidents, injuries, or illnesses that require medical care occur on the job, they will be thoroughly investigated within 24 hours of occurrence/knowledge by the Responsible Person listed below: Michael Fraley VP Field Operations Mobile: 415.850.1427 Office: 415.817.5113 [email protected] The investigator(s) will complete the Accident/Injury Investigation Form which is included following this section of the IIPP. The investigation will determine at least the following:

▪ Who and what was directly involved in the accident. ▪ Who and what was indirectly involved in the accident. ▪ Where and when the accident occurred. ▪ The cause of the accident, if known. ▪ Steps/procedures to take to prevent recurrence, if known. Copies of the completed Accident Investigation Form and will be sent to the BCCI's Office where the First Report of Injury/Illness Form will be completed. The completed First Report of Injury/Illness and the Accident Investigation Form will be forwarded to the BCCI's workers’ compensation insurance carrier.



If there is an injury or serious incident we need you to do the following: - Step one

call 911 immediately if serious and contact management.

- Step Two administer first aid and provide professional medical attention as soon as Possible to the injured. If not a 911 emergency, call On Site Health and Safety for first aid. Protect other employees or equipment from the hazard.

- Step Three BCCI management (or an authorized representative) must be present before you speak to any one (if serious). Never speak to the media, refer them to management.

- Step Four Never sign anything. BCCI management will be there with you to discuss and handle the situation.

In order to provide prompt and adequate medical attention it is very important that you report all job related injuries to the Field Administration Manager and your supervisor immediately. If you are injured you must notify your supervisor before seeing medical attention it at all possible. If you are involved in or witness an accident in the workplace, cooperate with your supervisor by helping determine what caused the accident. Your observations and feedback are critical in helping BCCI prevent a similar occurrence. Accident such as slips and falls, near misses, or first aids occur, even if no injury or damage resulted in the incident, shall be reported to your supervisor for investigation and correction. BCCI will carry out a thorough investigation on incidents, injuries and all near misses. Supervisory personnel will be primarily responsible for making an investigation of all incidents in their areas of responsibility. Incidents involving fire, death, serious injury, or extensive property damage will be investigated jointly by the supervisor, safety representative(s), management and/or insurance company representative. The primary goal of the incident investigation program is the prevention of future similar incidents through the use of knowledge derived from the investigations. When an employee is injured at work, the supervisor is responsible for taking emergency action to have first aid administered, to obtain professional medical attention as soon a possible and protect other employees and equipment. The supervisor must then investigate the circumstances of the accident.


Formal Supervisor's Injury & Incident Report must be submitted to the office immediately but no later than 24 hours after the accident. Senior management must be notified if a serious accident or injury occurs. Field Operations Management and the project team will review all incident and injury investigations. The Safety Committee will be charged with reviewing and approving the “Lessons Learned” on all incidents. Lessons learned will be communicated to all employees throughout the company. Requirements for Return to Work - The supervisor must receive a return to work slip from the doctor. - All employees seeking to return to work must be approved by BCCI management. - If an injured employee wants to return to work without an okay from the doctor do

not under any circumstances put him back to work. No exceptions


HAZARD CORRECTION PROCEDURES, – 8 CCR 3203(a)(6) All unsafe or unhealthy work conditions, work practices, and work procedures identified will be evaluated and corrected. Unsafe or unhealthy work conditions, work practices, and work procedures will be corrected in a timely manner, as determined by the severity of the hazard. Under no conditions will BCCI's personnel be required to, or permitted to, work under conditions which pose a clear or imminent hazard. Problems that cannot be corrected immediately will be assigned to the Responsible Person to ensure completion of the corrective action. Once corrected, written documentation of the action taken will be developed or obtained by the responsible person when an imminent hazard exists which cannot be immediately corrected without endangering employees and/or property, the following steps will be followed: 1.Remove all potentially endangered employees. 2.Provide employee(s) responsible to correct the condition with necessary safeguards. 3.Correct the problem. 4.Document the corrective action and date corrected in accordance with this Section. The documentation will be completed by the Responsible Person or his/her designee. Documentation will be maintained on file by the Responsible Person. Unsafe or unhealthy work conditions, work practices, and work procedures needing corrective action will be documented by using: BCCI will use the onsite safety hazards form above completed by the Superintendent or Project Manager and forwarded to the Responsible Person. Engineering controls will be used first to eliminate or minimize unsafe or unhealthy work conditions. If engineering controls are impractical or infeasible, administrative controls will be used. If engineering controls alone, or in combination with administrative control, cannot adequately minimize the hazard, personal protective equipment shall be used. Unsafe work practices and work procedures will be immediately corrected by providing the affected employee(s) with retraining to be provided by the Responsible Person (or his/her designee.) All operating procedures will be reviewed at least and whenever new chemicals or equipment are introduced into the system, or when there is a process change. When changes are made, affected employees will receive additional instruction, with documentation of instruction.


SAFETY TRAINING AND INSTRUCTION - 8 CCR 3203(a)(7) All BCCI employees shall have instruction and training on the safety policies and procedures as follows: - Instruction and explanation to all new employees on the requirements of BCCI

safety policy and procedures by providing instruction on the company’s IIPP and Code of Safe Practices, as well as all other safety programs that would apply to the employee’s occupation.

- Completion of the BCCI New Employee Safety Orientation. - Whenever BCCI is made aware of a new or previously recognized hazard. - Specific instruction will be given to all employees concerning any known hazard

specific to each employee's job assignment, or when changes or revisions occur. - When an employee is given a new job assignment for which training was not

previously given. - Whenever new substances, processes, procedures or equipment are introduced

to the workplace that present 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 IIP Program, emergency action plan and fire prevention plan, and measures for reporting any unsafe conditions, work practices, injuries and when additional instruction is needed.

- Use of appropriate clothing, including gloves, footwear, and 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, BCCI provides specific instructions to all workers regarding hazards

unique to their job assignment, to the extent that such information was not already covered in other training.


TOOLBOX/TAILGATE SAFETY MEETINGS – 8 CCR 1509(e) BCCI's Supervisory personnel at each project’s jobsite conducts toolbox/tailgate safety meetings with all BCCI's jobsite personnel weekly at a minimum of every 10 days. The topic to be discussed shall be pertinent to the operations/work taking place or to be conducted. Topics may either be selected by the project’s Supervisory personnel or the Responsible Person. Each toolbox/tailgate meeting will be documented with the same detail as other training and instruction which must be retained in accordance with T8 CCR 14300-14300.48 Supervisor Training - All supervisors will be trained to provide instruction and explanation to all new

employees on the BCCI IIPP and Code of Safe Practices, as well as all other safety programs that would apply to the employee’s occupation.

- All supervisors will be trained in the OSHA 10 Hour Outreach class for Construction, and will receive other safety training as applicable to the work activities.

- Supervisors will be trained in proper job site inspection and documentation. - Supervisors will be trained in proper incident or injury and near-miss investigation

procedures, and in documentation of all incidents


RECORD KEEPING - 8 CCR 3203(b) In accordance with T8 CCR 14300-14300.48, BCCI will keep records of the actions taken to implement and maintain this IIPP. The records will be maintained on file for a minimum of one year. The records kept by BCCI relating to this IIPP will not adversely affect the retention of medical and exposure records in accordance with Title 8, California Code of Regulations, Section 3204 “Access to Employee Exposure and Medical Records.” Records of scheduled and unscheduled periodic inspections, as well as other records including methods used to identify and evaluate workplace conditions and work practices, shall also be retained for a minimum of one year. Records relating to the inspections shall include, at a minimum, the person(s) conducting the inspection or evaluation; the unsafe conditions and work practices that have been identified; and action(s) taken to correct the identified unsafe conditions or work practices. Records and documentation of safety and health training for each employee shall include, at a minimum, the name of employee and/or employee number; date(s) of training; training topic(s); training format; and instructor(s). These records and documentation shall be maintained for at least one year. Records of employees who have worked for less than one year for BCCI may be turned over to the employee upon termination, as long as the terminated employee signs an acknowledgment letter documenting the records have been turned over to him or her. For recordable injuries, the basic requirement states that the CAL/OSHA 300, 300A, and 301 must be completed and their records need to be maintained in accordance with T8 CCR 14300-14300.48. 1. CAL/OSHA 300 Log - Log of Work-Related Injuries and Illnesses. An entry should be made in the the 300 log at each occurrence of a recordable injury or illness by entering a one or two line description for each occurrence within 7 calendar days. 2. CAL/OSHA 300A - Summary of all 300 log entry in one year to be completed at the end of the year. 3. CAL/OSHA 301 - Incident Report form to be completed in entirety for each recordable injury or illness that is included in the CAL/OSHA 300 Log.

injury illness prevention program (iipp) 2016 · bcci has developed and implemented this written...

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