Injury and Illness Prevention Program

Table of Contents

I. Introduction

A. Background

B. Policy Statement

C. Definitions

D. Employer Information

II. Policy Provisions

A. Responsibility

B. Compliance/Enforcement

C. Communication

D. Hazard Assessment/Inspection

E. Accident/Exposure Investigation & Reporting

F. Hazard Correction

G. Training and Instruction

H. Recordkeeping

III. Appendix

A. Forms
I. INTRODUCTION

A. Background

California requires all employers to provide a safe and healthful workplace for all of their
employees. Title 8 of the California Code of Regulations (CCR) requires California businesses
to implement an Injury and Illness Prevention Program (IIPP), in order to help provide this safe
and healthful workplace.

The IIPP is important for various reasons. Namely, it is designed to help prevent employees from
working in unsafe conditions, which might lead to injury and/or illness. Other benefits are:

 Higher morale
 Reduction of lost worker time and productivity
 Fewer work interruptions
 Less time needed to retrain or reschedule employees
 Less time and cost to repair or replace damaged equipment
 Other cost savings to the company

The program’s policy provisions consist of eight elements:

A. Responsibility
B. Compliance/Enforcement
C. Communication
D. Hazard Assessment/Inspection
E. Accident/Exposure Investigation
F. Hazard Correction
G. Training and Instruction
H. Recordkeeping

The IIPP requires the participation of all who are part of the security team to make it work. All
employees have the responsibility of complying with all of their respective safety requirements
and communicating any unsafe conditions. Hazard assessment will be the responsibility of site
supervisors and client personnel as well as accident/exposure investigation.

Hazard correction will primarily be the responsibility of the employer in charge of their
respective facility. However, site security managers and supervisors will assist in the process
where they are qualified and as required. Training and instruction of security personnel will be
the responsibility of site supervisors, as well as security management, and so will recordkeeping.

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 B. Policy

Injury & Illness Prevention Program Policy Statement

It is company policy to help provide a safe and healthful work environment for all of our
employees and visitors. We will comply with all applicable federal, state and local health,
safety and environmental laws and where statutes or regulations are missing, nationally
recognized health, safety and environmental guidelines will be observed. We do not require
any employee to work in an environment that is unsafe and/or unhealthful. However, we do
require all of our employees to adhere to the IIPP program and report any unsafe conditions
or persons to their supervisor immediately. The company will provide the necessary
training and equipment for our employee to function safely in their work environment, in
order to properly carry out their assigned tasks, and will investigate and respond
accordingly to any hazards or mishaps. Our goal is zero accidents and injuries. Therefore,
let’s all work together under the IIPP and support its mission.

Uhjin Lee 6/20/2018

IIPP Program Administrator Date

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 C. Definitions

Administrative Controls: Method of limiting exposure to hazards administratively, such as by

establishing policy on an operation’s method, time, and place of performance, etc.

Acute: Having a sudden onset, as with an illness.

Bloodborne Pathogen: A pathogen is a disease-producing agent such as a virus, bacterium or

other microorganism. OSHA defines a bloodborne pathogen as … pathogenic microorganisms
that are present in human blood and can cause disease in humans. These pathogens include, but
are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV). Code of
Federal Regulation 29, Section 1910.1030, Bloodborne Pathogens. Cal/OSHA includes hepatitis
C (HCV) in their definition – CCR, Title 8, Section 5193.

Chronic: Having a slow progressive course of indefinite duration, as with an illness.

Engineering Controls: Controls that isolate, minimize, or remove a workplace hazard.

EPA: The Environmental Protection Agency (EPA) is the primary federal agency that regulates
environmental compliance.

Hazard: A hazard is anything that poses a risk of harm such as an unsafe act or condition, or
any potential danger.

Illness: An occupational illness is any abnormal condition or disorder, other than one resulting
from an occupational injury, caused by exposure to factors associated with the workplace.

Injury: An occupational injury is any injury which results from an accident or exposure in the
work environment.

Lost-time Accident: An occupational injury or illness that results in time away from work for
the injured employee.

NAICS Code: The North American Industry Classification System (NAICS) identifies
employers in certain industries who are exempt from OSHA’s injury and illness recordkeeping
requirements unless specifically requested to do so by OSHA in writing. Our NAICS code is
5616 – Investigation and Security Services. Cal/OSHA follows the same requirements under
CCR Title 8: Div 1, Ch 7, Subchapter 1, Article 2 Sec. 14300.

OSHA: The Occupational Health and Safety Administration (OSHA) is the primary federal
agency that regulates safety compliance in the workplace.

OSHA State-plan State: A state that has developed and operates their own job safety and health
program, where health and safety requirements may be over and above the federal requirements,
and who is federal OSHA approved and monitored. States where we operate in that currently
have state-plan programs are: CA.

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PPE: Personal Protective Equipment (PPE) is equipment, such as hearing protection, provided
for the employee by the employer to aid in preventing workplace injuries. PPE is provided when
engineering and administrative measures are unable to eliminate a hazard or potential hazard.
Training in PPE usage is required before the employee is authorized its use in the work
environment.

SDS: Safety Data Sheets (SDS), formerly Material Safety Data Sheets (MSDS), provide
information about ingredients, hazards, spill controls, first aid, etc., for miscellaneous chemicals
in the workplace. The product’s manufacturer is required to create and provide the sheets. This
is part of the Hazard Communication standard.

Worker’s Compensation: Workers injured on the job receive this benefit in the form of medical
benefits, etc., paid by the employer.

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 D. Employer Information

Company Name: Professional Security Consultants

Address: 11454 San Vicente Blvd. 2nd Floor

Los Angeles, CA 90049

Telephone: (310)207-7729

Main Activity: Professional Security Services

NAICS Code: 5616 – Investigation and Security Services

Contact: Uhjin Lee

ulee@pscsite.com

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II. POLICY PROVISIONS

A. Identification of Responsibilities

Safety and injury prevention is the responsibility of all company members from the President of
the company to the security officer in the field.

Management is ultimately responsible for ensuring that their subordinates are in compliance with
all health and safety workplace practices, policies and procedures, as well as the proper
communication of safe and healthful workplace practices, policies and procedures, that accidents
and/or exposures have been investigated, that hazards have been corrected and/or employees are
not working under hazardous circumstances, and that proper health and safety training,
instruction and recordkeeping are being conducted.

Management will also be responsible for establishing new and/or improved safe and healthful
workplace policies, guidelines and practices, as required, as well as providing any necessary
PPE.

Local, regional and national account managers are responsible for setting policy and
providing leadership by participation, setting the example and maintaining a demonstrated
interest in the program.

Responsibilities include:

1. Developing policy.

2. Ensuring the compliance of all safe and healthful workplace policies, procedures and
practices of all of their subordinates.

3. Allocating safety resources such as personal protective equipment and helping to

ensure it is available as required.

4. Reviewing and evaluating results.

5. Monitoring recordkeeping.

IIPP Program Administrator:

The program administrator is responsible for ensuring that all provisions of the IIPP are
implemented.
Responsibilities include:
1. Advising senior management on safety and health policy issues.

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 2. Maintaining current information on local, state and federal safety and health
regulations.

3. Acting as liaison with government agencies.

4. Planning, organizing and coordinating safety training.

5. Preparing and distributing company policies and procedures on workplace safety and
health issues.

6. Developing a code of safe practices and inspection guidelines.

7. Arranging safety and health inspections and follow-up to ensure that necessary
corrective action is completed.

8. Establishing a system for maintaining records of inspection, hazard abatement, and

training.

9. Reviewing injury and illness trends.

The Human Resources Department is responsible for:

1. Implementation and coordination of the Worker’s Compensation program.

2. Recordkeeping.

The Training Department is responsible for:

1. Development and implementation of workplace safety training programs, policy and

procedures.

2. Working with supervisors, and managers in the creation, revision and training of any
new or existing safe and healthful workplace practices, policies and procedures as
well as recordkeeping.

All managers and supervisors are responsible for promoting safe and healthful workplace
practices and for the ensuring compliance of their subordinates with established safety policies,
procedures, and practices. Other duties include working with upper management and the client
to:

1. Communicate safe and healthful workplace practices, policies and procedures to

subordinates.

2. Investigate any occurrences of accidents, exposures and/or near misses.

3. Correct hazards and/or discontinue employee work in a hazardous environment, until

conditions are safe.

4. Provide health and safety training and instruction to their subordinates.

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 5. Report accident/incidents.

6. Aid in providing/obtaining care for subordinates.

7. Keep records.

8. Keep abreast of safety and health regulations affecting operations they supervise.

9. Ensure that each subordinate is able to, and understands how to, complete each
assigned task safely.

10. Advise the Program Administrator of training needs of subordinates.

11. Ensure that subordinates follow safe work practices and health regulations.

12. Ensure that employees under their direction wear required protective equipment.

13. Conduct periodic inspections of their work areas according to the appropriate
inspection checklist.

All Employees are responsible for conducting their assigned duties/tasks in a manner that is
personally safe, safe for their coworkers, clients, visitors and vendors, and safe for the
environment. All employees are responsible for adhering to all safe and healthful workplace
policies, procedures and practices, as well as for reporting safety hazards in the workplace,
reporting those who are not following the rules, reporting any accidents or injuries, and/or
reporting any near-miss events.

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 B. Compliance/Enforcement

For the safety of all, it is important that all employees comply with the safety policies,
procedures and practices of their company and client. Failure to adhere to safety policy and
procedure will result in disciplinary measures.

Managers and supervisors are responsible for ensuring that Company safety and health policies
and procedures are clearly communicated and understood by all employees. Additionally,
managers and supervisors are expected to:

1. Model and encourage safe and healthful workplace policy and procedures.

2. Enforce the rules fairly and uniformly.

3. Evaluate employees for compliance with regard to safe and healthful workplace
policy and procedures.

4. Apply equitable disciplinary actions for violations of the safety rules regardless of
whether an injury occurred to the violator or not.

5. Re-train their subordinates as necessary on any safety policies, procedures and

practices.

6. Notify the Human Resources department for repeat offenders.

We believe that a safety and health accident prevention program is unenforceable without some
type of disciplinary policy.

Our company believes that in order to maintain a safe and healthful workplace, the employees
must be aware and mindful of all company, state, and federal safety and health regulations as
they apply to the specific job duties required.

The following disciplinary policy is in effect and will be applied to all safety and health
violations.

The following steps will be followed unless the seriousness of the violation would dictate going
directly to Step 2 or Step 3.

1. A first time violation will be discussed orally between company supervision and the
employee. This will be done as soon as possible.

2. A second time offense will be followed up in written form and a copy of this written
documentation will be entered into the employee’s personnel folder.

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 3. A third time violation will result in time off or possible termination, depending on the
seriousness of the violation.

Documentation of violations will also be kept on file. See the section on Recordkeeping.

Note: Supervisors and managers are also encouraged to recognize their subordinates who excel
at maintaining personal safety as well as those who promote safety in the workplace through
means such as certificates of recognition and commendation or other awards. For awards of a
monetary value, the supervisor or manager will contact the HR department and/or their Account
Manager for prior approval.

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 C. Communication

The ultimate goal of communicating safety matters is to reduce the number of injuries and/or
accidents and to promote positive attitudes toward safety. Therefore, supervisors and managers
will make it a point to regularly communicate the importance of safety to their subordinates.

All employees are encouraged to direct health and safety related inquiries and concerns to their
supervisors. 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
understandable:

1. New-employee training will include review of the IIPP and a discussion of policy and
procedures that the employee is expected to follow.
2. Safety-related memos and documents are to be read promptly. Other methods of
communicating pertinent health and safety information may include electronic mail or
a safety committee. Questions about the meaning or implementation of this
information will be directed to the supervisor.
3. All employees are encouraged to inform their supervisor, their security manager or
the Program Administrator or their designee of any matter that they perceive to be a
workplace hazard and/or a potential workplace hazard. Employees are also
encouraged to make safety suggestions and safety training suggestions.
4. No employee shall be retaliated against for reporting hazards or potential hazards, or
for making suggestions related to safety.
5. All suggestions will be reviewed by the Program Administrator or their designee,
who will initiate an investigation of each report of a hazard, potential hazard or safety
suggestion in accordance with Company procedures for hazard control.
6. Any directives issued as a result of the investigation shall be distributed to all
employees affected by the hazard, or shall be posted on appropriate bulletin boards.
Note: If any employee does not feel comfortable reporting a safety concern through their
immediate supervisor, then they may:

 Report the concern up the next level in the officer’s chain of command.

The options below are also available to the employee for reporting safety concerns. However, if
at all possible, it would be appropriate to allow us the opportunity to attempt to rectify any safety
concerns prior to reporting a matter to an outside source.

 Report through the PSC Hotline source, a web-based application that specializes in
assisting employees report problems or concerns to their employer.

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  If employees feel that nothing is being done to address the safety concerns they brought
up, they could off course report the incident directly to the governmental agency that has
oversight in the matter (i.e. Cal/OSHA, OSHA, EPA, etc.).

D. Hazard Assessment/Inspections

The IIPP standard requires inspections of all workplaces subject to the standard. All field
supervisors and officers will assist the client as necessary with scheduled workplace safety
inspections and document their findings either on a safety inspection checklist or incident report.

Inspections serve several purposes in injury and illness prevention:

1. Verifying compliance of safe and healthful workplace practices and controls.

2. Identify potential occupational hazards.
3. Evaluation of the effectiveness of safety training, rules, and practices.

Inspection frequency:

Low Hazard Areas (office areas, lobbies, etc.): quarterly.

Moderately Hazardous Areas (warehouses, food services, graphic/print shops): quarterly.

Higher Hazard Areas (maintenance/machine shops, service/repair areas, hazardous

materials/waste storage areas, central plant operations, research areas using hazardous materials):
monthly.

Note: The client is responsible for inspection of all of their work areas. Security Supervisors
and staff, etc., are only responsible for inspecting their office work areas, gate shacks, etc:

1. Quarterly (March, June & September) using the Office Self-inspection form, to ensure
that their work environment is safe and annually, in December, using the Office
Inspection Checklist.

2. Prior to the periodic inspection, the inspector should review workplace injury reports
and inspection reports that have been filed since the last investigation or inspection.

3. Upon the introduction of new substances, processes, procedures or equipment that

present a new, or potentially new, safety/health hazard an inspection will be required
and:

 Each supervisor is responsible for promptly reporting to the Program

Administrator or their designee whenever a new substance (such as a chemical
or solvent), new work procedure or technique, and/or new equipment are
introduced in their particular office area, which may pose a safety risk. The
supervisor should use a Report of Safety Hazard Abatement form.

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  Each supervisor's report should include an evaluation of the potential
hazards(s), training and/or other steps to be taken to provide abatement
solutions for any potential hazards(s).

 Based upon the information, the Program Administrator or their designee will
conduct an inspection and issue any directive that may be necessary.

4. If the Program Administrator becomes aware of a new or previously unrecognized

hazard, either independently or by receipt of information from an employee,
including receipt of a Report of Safety Hazard Abatement form, an inspection will be
completed by the Administrator or their designee.

5. If an occupational injury, occupational illness, or near-miss incident occurs (see

Accident Investigation section) an inspection is required.

Documentation of safety inspections will be kept at the location of the inspection for a minimum
of three years. The sooner a problem can be identified, the likelihood it will cause harm
significantly decreases.

The IIPP standard also requires the abatement of hazards identified during an inspection. The
Safety Inspection forms completed during the inspection/investigation will be used by the
Program Administrator or their designee to describe/document measures taken to abate the
hazard or correct the unsafe work practice.

Actions to be taken may include, but are not limited to:

1. Notifying client and/or security management for corrective actions as required.

2. Fixing or replacing defective company-issued equipment.
3. Implementing safer procedures.
4. Installing guards, modifying equipment as required/authorized.
5. Employee training.
6. Posting warning notices.

Should the officer or supervisor discover any dangerous conditions, which pose an imminent
threat to the safety of workers in the area, security personnel may cease operations, if and as safe
to, and remove personnel out of harm’s-way until the problem can be corrected and/or client
management/supervision can be informed.

Employees shall not enter an imminent hazard area without prior specific approval of the
Program Administrator or their designee. If employees are expected to correct the imminent
hazard, they will be properly trained and provided with necessary safeguards beforehand.

When corrective action involves multiple steps or cannot be complete promptly, an action plan
needs to be developed. A Report of Safety Hazard Abatement form is to be used for this purpose
and filed as directed in Recordkeeping.

While corrective action is in progress, necessary precautions are to be taken to protect or remove
employees from exposure to the hazard. For hazards posing a less serious or less immediate risk,

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the officer is to still bring the matter to the attention of client management/supervision and
document the problem.

All such actions taken and the dates they are completed shall be documented on the appropriate
forms and the forms shall be filed for a minimum of three years.

E. Accident/Exposure Investigation & Reporting

Supervisors and managers are responsible for investigating all accidents and/or incidents (near
misses) that they become aware of – even if the result was not an injury or any damage to
equipment or property. Additionally, supervisors are responsible for reporting their findings to
company and client management in report form.

The Human Resources Department will be notified by the local, regional or national account
manger of any accident resulting in an injury to an employee or damage to company or client
property. The Human Resources Department will also be notified of an injury to any client
personnel resulting from security personnel negligence.

Account managers and/or HR will notify the Training Department of any accidents or near
misses as well as damage to company or client property whether an employee is at fault or not.

Employees who are injured on the job must:

1. Report an injury to their supervisor as soon as possible.

2. Seek medical assistance as required.

3. Ensure that the Human Resources Department has been informed.

Note: Any near-miss event must be reported to the supervisor also as soon as
possible so that any needed corrective actions may occur to help prevent an injury in
the future.

The purpose of an investigation is to find the cause of an accident and prevent further occurrences
and not to fix blame. An unbiased approach is necessary for obtaining objective findings. When
initiating an investigation, supervisors and/or managers are to:
1. Visit the accident scene as soon as possible while the facts are fresh, and before
witnesses forget important details.
2. If possible, interview the injured worker at the scene of the accident and "walk" him or
her through a mock re-enactment.
3. All interviews should be conducted as privately as possible. Interview witnesses one at
a time. Talk with everyone who has knowledge of the accident, even if they did not
actually witness it.
4. Consider taking signed statements in cases where facts are unclear or there is an element
of controversy.

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 5. Document details graphically. Use sketches, diagrams and/or photos as needed, and
take measurements when appropriate.
6. Focus on causes and hazards. Develop an analysis of what happened, how it happened
and how it could have been prevented. Determine what caused the accident itself, not
just the injury.
7. Every investigation should include an action plan. How will you prevent such accidents
in the future?
If a third party or defective product contributed to the accident, save any evidence. It could be
critical to the recovery of claims costs.
All investigative facts, findings and recommendations shall be fully documented on the Work-
related Injury Checklist/Report and the Investigation Checklist and Report forms. These reports are
filed in accordance with the instructions for Recordkeeping.
OSHA Required Notifications
As of January 1, 2015, Federal OSHA requires all employers to report:

 All work-related fatalities within 8 hours

Employers are also required to report the following work-related incidents within 24 hours:

 Inpatient hospitalizations
 Amputations
 Losses of an eye

To make a report, HR and/or account management are to call OSHA at 1-800-321-6742 or call
their nearest OSHA office during business hours or visit http://www.osha.gov/report_online.

CalOSHA requires the employer to immediately (as soon as possible but no later than 8 hours
upon the employer becoming aware) report any serious injury or illness, or death, of an
employee occurring in a place of employment or in connection with any employment to the
nearest OSHA District Office.

For additional OSHA reporting requirements, in OSHA state-plan states, consult the OSHA
Injury-Death Reporting Guide online in HR, Forms, Human Resources.

When notifying OSHA, provide the following:

 The establishment name – employer’s name, address and phone number;

 Name and job title of person reporting the accident and whom to contact at the site of
the accident;

 The location of the incident – address of site of accident or event;

 The time of the incident;

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 The number of fatalities or hospitalized employees;

 The names of any injured employees and their address;

 Location of injured if moved;

 A brief description of the incident and any other information requested.

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 F. Hazard Correction/Reporting

A hazard is anything that poses a risk of harm such as an unsafe act or condition, any potential
danger.

Officers are to:

1. Report any unsafe work practices of other security or client personnel to their
supervisor as soon as possible.

2. Halt any imminently dangerous operations, as safe to, which are putting personnel at
risk of harm.

3. Assist in correction of a safety problem, which is within their skills, training and
authorization, and as safe to do so.

4. Assist in contacting those who can correct safety problems.

5. Monitor the area until the problem has been corrected.

6. Escalate the problem up the chain, if no action has been taken, until the problem has
been addressed and corrected.

7. Document the problem

Supervisors and managers are to:

1. Do all of the above to include ensuring compliance of all their subordinates.

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 G. Training and Instruction

Supervisors will provide and/or arrange for initial safety training for all new officers upon hiring.
Supervisors who recognize their own need for training are encouraged to submit a direct request
for training in any area in which they feel deficient to their supervisor or manager as soon as
possible.

The company recognizes that continuing safety and health training is needed for:

1. Employees given a job assignment for which they have not previously received
training. If the position is supervisory, such training shall include familiarization with
hazards and risks faced by the employees under the supervisor's direction.

2. Whenever new substances, processes, procedures or equipment pose a new hazard.

3. Whenever the supervisor, Program Administrator or designee becomes aware of a

previously unrecognized hazard.

4. All employees for applicable general industry periodic/refresher safety training.

Training may consist of but is not limited to the following:

 First aid/CPR/AED instruction

 Injury Illness Prevention training
 Heat-illness prevention training
 Bloodborne pathogens training
 Fire extinguisher education and/or training
 Usage of required Personal Protective Equipment (PPE) – latex gloves, CPR face-
shields, etc. – job and/or site-specific.

Supervisors will also ensure that refresher training is completed, due to safety mishaps and/or
frequency of training requirements (i.e., annually, etc.) and that any additional training is
conducted as necessary, due to new requirements in the workplace.

Additionally, all records of training will be kept on file at the work site and/or a copy will be
forwarded to the Corporate Office as well as uploaded online in HR in the applicable space
provided. At a minimum, records must indicate:

 Names of attendees and trainer(s).

 Material covered
 Date(s) of training

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Note: Where federal or state-plan state training record requirements for a particular subject are
more extensive, that information will also be included/documented by the trainer.

All sign-in logs will be completed at the time of training, all tests will be administered by the
respective supervisor/trainer and certificates will be issued. All required training documentation
will be filed in the employee’s training file and certificates will be issued and uploaded in the HR
system in their respective places.

Training files for the current year will be kept in the officer’s physical file and all previous
training files will be kept electronically on the supervisor’s/trainers computer indefinitely.
Additionally, all training documentation will be forwarded to the Office for safekeeping and
storage unless otherwise directed.

Managers will ensure compliance of the above.

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 H. Recordkeeping

The company will maintain records and documentation of the IIPP as required by regulatory
agencies.

The Human Resources department will maintain worker’s compensation records of claims,
accident investigations, and medical information related to injuries. The HR department will also
maintain disciplinary action records pertaining to violations of the IIPP.

Site supervisors and directors/managers will maintain records of safety inspections, safety
meetings, and accident investigation reports for a minimum of three years, unless otherwise
specified. Disciplinary action records for violations of the IIPP will be maintained locally as
directed by the HR department.

Site supervisors and directors/managers will maintain records of all safety-related training they
have provided. All training records will be kept electronically on file for the duration of the
worker’s employment and for 3 years after separation.

All medical records will be maintained for at least the duration of employment plus 30 years
unless otherwise specified by law.

Any employee, former employee, or their authorized representative who wishes to view their
records must make a request to the appropriate party.

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III. Appendix

A. Forms

Forms are uploaded in HR in Forms:

IIPP SAFETY INSPECTION CHECKLIST FOR OFFICE AREAS

(To be completed annually in December by the site security supervisor or their designee)

IIPP OFFICE SELF-INSPECTION FORM

(To be completed in March, June and September by the Supervisor or their Designee)

Last review/revision date: Reviewed by:

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