An Evaluation of the California Injury and Illness Prevention Program

by John Mendeloff, Wayne B. Gray, Amelia M. Haviland, Regan Main, Jing Xia

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Research Questions

  1. Did injury and fatality rates decline in California, relative to other states, after the implementation of the IIPP standard?
  2. Do workplaces that do not comply with the IIPP have worse injury, fatality, and loss performance than compliant firms?
  3. Did workplaces that had been cited for IIPP violations and then came into compliance improve their injury performance relative to other workplaces?

Abstract

The Injury and Illness Prevention Program (IIPP) requirement has been the most frequently cited standard in California workplace health and safety inspections almost every year since it became effective in July 1991. Every workplace safety inspection must assess compliance with the IIPP. This report presents the results of an evaluation of the IIPP's effects on worker injuries in California and should inform policy both in California and in the federal Occupational Safety and Health Administration (OSHA) program, which has made the adoption of a similar national requirement a top priority. Using data from the Workers' Compensation Information System , OSHA Data Initiative statistics, and Workers' Compensation Insurance Rating Bureau of California reports on medical and indemnity claims from single-establishment firms, the evaluation team analyzed the impact of citations for violations of the IIPP on safety performance by (1) using the number of citations as a measure of effectiveness and (2) assessing the number of establishments that were cited for noncompliance and then came into compliance. They found that enforcement of the IIPP appears to prevent injuries only when inspectors cite firms for violations of specific subsections of that standard. Eighty percent of the citations of the IIPP by the California Division of Occupational Safety and Health program are for only a different section, the one that requires employers to have a written IIPP. The specific subsections refer to the provisions that mandate surveying and fixing hazards, investigating the causes of injuries, and training employees to work safely. Because about 25 percent of all inspections cite the IIPP, citations of the specific subsections occur in about 5 percent of all inspections. In those inspections, the total recordable injury rate falls by more than 20 percent in the two years following the inspection.

Key Findings

The California Injury and Illness Prevention Program (IIPP) Has not Had a Clear Impact on Fatality Rates

  • Fatality rates in California did not improve relative to other states in the years after the IIPP took effect in 1991.

Enforcement of Specific Subsections of the IIPP Correlates to Lower Injury Rates

  • Enforcement of the IIPP appears to prevent injuries when inspectors cite firms for violations of specific subsections of the IIPP, but such citations were issued in only 5 percent of inspections.
  • Employers whose only IIPP violation was for lacking an IIPP document performed better than those with no IIPP violations.
  • Employers cited for other violations, especially not training employees and investigating accidents, had higher injury rates or experience-modification factors than those not cited for any IIPP violation or cited only for lacking an IIPP document.

Recommendations

  • The process for enforcing the California Injury and Illness Prevention Program (IIPP) should look beyond paper compliance with its provisions to ensure compliance with all specific subsections of the IIPP.
  • Inspectors should be strongly encouraged to show employers how the hazards that they find and the injuries that occur are related to weaknesses in their IIPP.

Table of Contents

  • Chapter One

    Introduction

  • Chapter Two

    California's Injury and Illness Prevention Program

  • Chapter Three

    Injury and Illness Prevention Program Implementation and Trends in Compliance

  • Chapter Four

    Limitations of Previous Research

  • Chapter Five

    Evaluation Design: The Challenge of Establishing Causality

  • Chapter Six

    State-Level Impact

  • Chapter Seven

    Injury Performance of Compliant and Noncompliant Firms: The Lookback Models 57 Findings

  • Chapter Eight

    Effects of Injury and Illness Prevention Program Violations on Changes in Injuries: The Change Models

  • Chapter Nine

    Conclusions: The Impact of the California Injury and Illness Prevention Program Standard

  • Appendix A

    Construction of the Data Sets

  • Appendix B

    Modifications to the Workers' Compensation Information System and Occupational Safety and Health Administration Data Initiative Data

  • Appendix C

    Lookback Analyses

  • Appendix D

    Regression Results from Change Models

This research was sponsored by the Commission on Health and Safety and Workers' Compensation and was conducted within the RAND Center for Health and Safety in the Workplace, a research center within RAND Law, Business, and Regulation, a research division of the RAND Corporation.

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