Injury and Illness Prevention Program
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USC Environmental Health and Safety – UPC (213) 740-6448, HSC (323) 442-2200
CONTENTS
1.0 PURPOSE
2.0 APPLICABLE REGULATIONS AND STANDARDS
3.0 DEFINITIONS
4.0 RESPONSIBILITY
4.1 Officers of the University
4.2 Environmental Health & Safety
4.3 Manager/Supervisor
4.4 Employee Responsibilities
5.0 COMPLIANCE
6.0 COMMUNICATION
7.0 HAZARD ASSESSMENT
8.0 ACCIDENT/EXPOSURE INVESTIGATION
9.0 HAZARD CORRECTION
10.0 TRAINING AND INSTRUCTION
11.0 RECORDKEEPING AND DOCUMENTATION
12.0 PROGRAM APPROVAL AND REVIEW
Appendix A. Safe Work Practices/Standard Operating Procedures
Appendix B. Safety Meeting Log
Appendix C. Hazard Reporting Form
Appendix D1. General/Office Inspection Form
Appendix D2. Shop Inspection Form
Appendix D3. Laboratory Inspection Form
Appendix D4. Vehicle/Electric Scooter/Cart Inspection Form
Appendix D5. Warehouse Inspection Form
Appendix D6. Dining Facility Inspection Form
Appendix E. Attendance Log
It is the policy of USC to maintain a safe and healthful work environment and to comply with all applicable occupational health and safety regulations. The Injury and Illness Prevention Program (IIPP) is intended to establish a formal, written framework for identifying and correcting workplace hazards.
California: Title 8, General Industry Safety Orders, Section 3203
EH&S - Environmental Health & Safety
FMS - Facilities Management Services
IIPP - Injury and Illness Prevention Program
PPE – Personal Protective Equipment
SOP - Standard Operating Procedure
The Injury and Illness Prevention Program (IIPP) administrator, Charles E. Lane, Associate Senior Vice President, has the authority and responsibility for implementing the provisions of this program for The University of Southern California.
EH&S responsibilities include the following:
- Make the program accessible to all University personnel;
- Distribute safety communications such as injury reports, programs and policies, and EH&S fact sheets throughout the University;
- Provide for safety training and medical surveillance based on individual job requirements;
- Provide leadership and expertise for University safety committees such as the Institutional Biosafety Committee and the Radiation Safety Committee;
- Provide oversight for supervisor investigation of accidents, injuries, and illnesses; and
- Conduct routine inspections of campus work areas and laboratories.
The manager, supervisor, Principal Investigator, or other designated person of authority shall be responsible for implementing all components of the IIPP and ensuring that staff under his/her supervision are in compliance.
Responsibilities include the following:
- Assure that every employee has received and completed safety training required for the job prior to commencing work and that training attendance is documented;
- Monitor work practices and address unsafe acts immediately;
- Ensure identified hazards are corrected in a timely manner;
- Provide periodic safety training as required for the job and provide adequate PPE for the tasks being performed;
- Stop any work that poses an imminent hazard to either the employee or any other individual; and
- Encourage employees to report health and safety issues without fear of reprisal.
It is the responsibility of all employees to comply with all applicable health and safety regulations, policies, and established work practices. This includes, but is not limited to, the following:
- Observance of health and safety-related signs, posters, warning signals, and directions;
- Become familiar with building emergency plans and assembly areas;
- Learn about potential hazards of assigned tasks and work areas;
- Participation in training and departmental safety communications/meetings;
- Adherence to safe work practices;
- Prompt reporting of accidents, injuries, unsafe conditions, or potential hazards to the manager/supervisor. Concerns may also be submitted to EH&S via the main webpage at (http://capsnet.usc.edu/ehs/), or using the form in Appendix D;
- Cooperation and assistance in the investigation of all accidents and incidents; and
- Utilization of required personal protective equipment.
All employees are responsible for complying with safe and healthful work practices. Compliance may be insured by one or more of the following means:
-
Informing employees of the safe work provisions and the contents of the IIPP;
-
Regularly evaluating the safety performance of all employees;
-
Recognizing employees that perform their work in a safe and healthful manner;
-
Providing training to employees with safety performance deficiencies; and
-
Disciplining employees for failure to adhere to safe and healthful work practices.
All managers and supervisors are responsible for communicating to all employees about occupational hazards in a form that is readily understandable by all employees. This communication system includes one or more of the following:
- New worker orientation including a discussion of safety and health policies and procedures;
- Review of the provisions included in the IIPP;
- Training programs tailored to the work being performed;
- Discussing safety issues as part of the work meetings or in separate safety meetings;
- Posting, discussing, or distributing safety information such as EH&S Fact Sheets to staff;
- Reporting of workplace hazards and assigned corrective actions.
The University shall institute scheduled safety audits of its grounds, buildings, laboratories, shops, office spaces, and food facilities. EH&S shall schedule periodic safety audits according to the table below:
INSPECTION |
FREQUENCY |
|
Monthly |
Quarterly |
Biannually |
Annually |
Biennially |
As Needed |
Nuclear medicine |
x |
|
|
|
|
|
gamma knife |
x |
|
|
|
|
|
cyclotron |
x |
|
|
|
|
|
radiation oncology |
x |
|
|
|
|
|
Radiation |
|
|
x |
|
|
|
Radiation contamination |
|
x |
|
|
|
|
X-ray equipment |
|
|
|
x |
|
|
Lasers |
|
|
|
x |
|
|
Vivaria |
|
|
x |
|
|
|
Select agents |
|
|
x |
|
|
|
BSL 2+ |
|
|
x |
|
|
|
High hazard areas |
|
|
x |
|
|
|
Highly regulated areas |
|
|
x |
|
|
|
Laboratories |
|
|
|
x |
|
|
Fire/Life |
|
|
|
x |
|
|
Shops |
|
|
|
x |
|
|
Campus grounds |
|
|
|
x |
|
|
Food Facilities |
x |
|
|
|
|
|
Office |
|
|
|
|
x |
|
Protocol review |
|
|
|
|
|
x |
New labs |
|
|
|
|
|
x |
Closeouts |
|
|
|
|
|
x |
EH&S shall submit to each University department, school, or college its findings and recommendations for corrective action in hard copy or electronic form.
The supervisor shall investigate all injuries sustained by their employees and log the information on the Supervisor’s Report of Injury form (http://capsnet.usc.edu/WC/webPDF/SupervisorRptOfInjury.pdf). The form shall be returned to the Workers' Compensation Office within 24 hours of injury. Injured employees or their representatives shall complete a Workers’ Compensation form (http://capsnet.usc.edu/WC/webPDF/ClaimForm.pdf) and return it to the Workers' Compensation Office within 24 hours of injury.
Unsafe or unhealthy conditions or activities that are discovered as a result of periodic inspections or during normal operations shall be addressed by the department supervisor or principal investigator. Supervisors may receive assistance in developing appropriate corrective actions from EH&S, FMS or other University departments as needed.
The following techniques can be used to prevent unsafe practices or use of unsafe equipment:
- Tagging unsafe equipment with proper signage;
- Stopping unsafe work practices and providing re-training;
- Reinforcing and explaining the necessity for PPE and ensuring its availability; and
- Barricading areas that have chemical spills or other hazards and reporting the hazardous conditions to a supervisor, building coordinator, or EH&S.
If imminent hazards are identified, work must discontinue and the supervisor contacted immediately. If the hazard cannot be immediately corrected without endangering employees or property, then all employees must be evacuated from the area except for those knowledgeable, qualified, and necessary to correct the condition. The qualified personnel will be equipped with proper safeguards prior to corrective action. Emergency conditions must be reported at (213)740-4321 (24 hours/day).
All employees shall be trained on general and job-specific safety and health practices. Training and instruction is provided:
-
To all employees with respect to hazards specific to each employee’s job assignment;
-
To all employees given new job assignments for which training has not previously provided;
-
Whenever new substances, processes, procedures, or equipment are introduced to the workplace and represent a new hazard; and
-
Whenever the department is made aware of a new or previously unrecognized hazard.
Documents related to the IIPP must be kept for at least one year. These include:
- Scheduled and periodic workplace inspections including the persons conducting the inspection, any identified unsafe conditions or work practices, and corrective actions (Appendices D1-D6 or equivalent);
- Employee safety training records including the names of all attendees and instructors, the training date, and material covered (Appendix E or equivalent);
- Reports of unsafe conditions or hazards (Appendix C or equivalent);
- Accident, injury or illness investigation reports (Supervisor’s Report of Injury).
Date Reviewed: November 16, 2005 By: A. Bouziane, E. Becker
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