Hotel and Lodging Industry
Cal-OSHA Compliant
Development Guide
California Hotel & Lodging Association
414 29th Street
Sacramento, California 95168
916.444.5780
December 2014
This resource made possible by generous
funding from the American Hotel & Lodging
Education Foundation.
Introduction - How to Use this Guide to Develop and Implement an Effective
Injury and Illness Prevention Program (IIPP)
An Injury and Illness Prevention Program (IIPP) is a basic written workplace safety program that Title 8 of
the California Code of Regulations (Title 8 CCR) section 3203, requires every employer to develop and
implement. An effective IIPP improves the safety and health in your workplace, assists in efforts to prevent
injuries and illnesses of your employees, and can reduce costs by good management and employee
involvement.
This IIPP Guide should be used as a tool to help you develop an IIPP specific for your business. This guide
takes you step-by-step through the IIPP development and implementation process. Utilize this guide and
sample forms to develop your program into an effective, compliant IIPP. Each required section is explained
and guidance is provided so you can perform a comprehensive hazard assessment. To develop your own
written IIPP, customized to your workplace, follow this guideline and make it specific to your operation.
Your IIPP must be specific to your work place and must be specific to the work activities your employees
actually perform and include the policies and procedures they follow. The sections listed in this guide, are
required elements per Cal-OSHA and need to be included in your IIPP. The sample form templates
provided after each required section can help you develop the necessary tools for implementing and
maintaining this program. Forms can be used in their entirety, or modified, to accurately reflect your
business, policies and procedures.
Specific safety and health programs, not included in this model, will have to be added into your IIPP based
upon the specific operations and hazards within you business. Listed below are some of the required
programs;
 Hazard Communication
 Fall Prevention
 Hearing Conservation
 Respiratory Protection, etc.
Following this guide will provide you with the detail and information required to develop your own CalOSHA compliant IIPP and help to ensure the health and safety of your employees, visitors and guests. For
additional resources, you can find many program guides and models on the Cal-OSHA website,
www.dir.ca.gov/DOSH/PubOrder.asp.
Sections of this document are printed in blue to identify them as comments and explanations there for your
reference that can be deleted from your IIPP if you choose.
Disclaimer
The information and recommendations contained in this document have been compiled from various
sources. All of these sources are believed to be reliable and accurate, but the California Hotel & Lodging
Association makes no guarantee as to, or assumes no responsibility for correctness, sufficiency, or
completeness of the information and recommendations.
It is the California Hotel & Lodging Association’s belief that when their members use this document as a
guide that they should essentially comply with the requirements of Cal-OSHA. However, it is each
member’s responsibility to confirm the contents of their specific IIPP are in compliance with the most
current Cal-OSHA requirements. This guide is not meant to be a substitute for or a legal interpretation of
the occupational safety and health standard.
INJURY AND ILLNESS PREVENTION PROGRAM
Sample Form
Company Name:
Company Address:
Company Phone Number:
Other Location(s) Address:
Written By: ________________________
Date:
Approved by:
Date:
Personnel responsible for implementing and maintaining the Injury and Illness Prevention Program:
_______________________________________________________________________
Name
Title
Date
_______________________________________________________________________
Name
Title
Date
_______________________________________________________________________
Name
Title
Date
________________________________________________________________________
Name
Title
Date
TABLE OF CONTENTS
Topic
PAGE
Health and Safety Policy Statement and Assignment of Responsibilities .................................... 1-5
Employee Compliance ................................................................................................................ 6-12
Employee Communication........................................................................................................ 13-23
Training ..................................................................................................................................... 24-32
Hazard Inspections and Corrections ......................................................................................... 33-43
Safe and Healthful Work Practices ........................................................................................... 43-48
Incident and Illness Investigation ............................................................................................. 49-59
Safety and Health Recordkeeping ............................................................................................. 60-64
Appendix of Hazard Awareness Compliance Program Information ...................................... 65-106
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
Emergency Action and Fire Protection Plan ................................................................ 67-68
Hazard Communication Program ................................................................................ 69-70
Ergonomics and Back Injury Prevention ..................................................................... 71-73
Blood borne Pathogen .................................................................................................. 74-92
Personal Protective Equipment (PPE)............................................................................... 93
Heat Illness Prevention Training Guide ............................................................................ 94
The Control of Hazardous Energy – Lock out Tag out (LOTO) ...................................... 94
Confined Space ................................................................................................................. 94
Asbestos ............................................................................................................................ 94
Lead .................................................................................................................................. 95
Sample Self Inspection Checklists ............................................................................. 96-106
HEALTH AND SAFETY
POLICY STATEMENT
AND
ASSIGNMENT
OF
RESPONSIBILITY
Your IIPP should begin with a written Health and Safety Policy Statement describing your commitment to
the safety and health of your employees and people visiting your business. The statement should detail that
your employees are your most important asset and providing them a safe and healthful workplace is the
right thing to do and I good business. There is a sample version of a policy statement included on the
following page.
In addition to a clear policy statement, your IIPP should have clearly defined roles and responsibilities for
each position within your business from the top down. Providing and maintaining a safe and healthful
workplace is everyone’s responsibility and this IIPP is a dynamic process that requires everyone’s attention
to make it successful. Roles and responsibilities can change over time as your business changes. We have
included some roles and responsibilities in this guide for you to use, modify and implement accordingly
into your specific IIPP. It is also important to identify a qualified person(s) to be designated as the Program
Administrator(s) that are responsible for managing all aspects of your specific IIPP. There is a sample form
included in this guide for this purpose and documentation.
1
Health and Safety Policy Statement
Sample Policy Statement
The Injury and Illness Prevention Program (IIPP) administrator,
(name
and title) for
(your property’s name) has the authority and
responsibility for implementing the previsions of this program.
This IIPP is a proactive system for preventing work place accidents and illnesses by identifying and
correcting unsafe conditions and work practices through, Communication, Training, Self-Inspection,
Accident Investigation and Enforcement.
The safety of all employees, guests and the general public is vitally important to our business. Hotels
must have safety programs that are effective and that hold all director, managers, supervisors, and
associates responsible for safety and training.
Every department manager and supervisor is directly responsible for safe operation of areas and the
property under his/her direction. Safety performance will be considered as a key portion of their duties
for purposes of performance review.
Individual employees have the responsibility to comply with all Codes of Safe Practices and
occupations safety and health rules directly applicable to their personal work situation. Employee
conduct or personal habits which interfere with safe performance of their duties will not be tolerated.
They key to any safety program is efficient and dedicated management. Management personnel must
ensure that employees are aware of hazards associated with the job and must enforce the established
Codes of Safe Practices for respective jobs. Departmental meetings are to be used to discuss safety
topics and for personnel to report all unsafe conditions. All injuries shall receive immediate attention
and every accident shall be reported immediately and investigated promptly and completely.
The success of the IIPP is dependent on everybody accepting personal responsibility for safety and
health.
General Manager
Date
2
Departmental Responsibilities
All hotel associates will perform as outlined with in this section their assigned job duties and
responsibilities at
(Location Name)
. This IIPP will only be effective
if all elements are implemented and adhered to throughout all of our operations and departments.
Responsibilities of the General Manager
1.
2.
3.
4.
Allocate appropriate resources to effectively implement this IIPP.
Ensure that managers and supervisors are held accountable for implementing all applicable
components of the IIPP within their departments.
Ensure compliance with legislative regulations and utilize the Program Administrator as a
safety and health resource.
Oversee and guide all activities of the Program Administrator.
Responsibilities of the Program Administrator
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
Initial training for all employees on the provisions of the IIPP, to all newly hired employees,
and to all employees given new job assignments for which training has not been previously
received, and at least annually thereafter.
Evaluating the safety performance of all workers.
Maintaining records on the documentation of the IIPP’s implementation.
Review accident and injury reports and disseminating information required.
Conducting facility inspections.
Develop and facilitate regular safety trainings with all employees.
Coordinate Safety Committee meetings and chair the committee.
Plan and conduct inter-department or property wide safety recognition programs.
Establish and maintain a code of safe practices and inspection guidelines.
Establish and maintain injury and illness records (OSHA log 300, 300A).
Establish a system for recordkeeping, including record of inspection, hazard abatement,
workplace incidents and training.
Communicate safety and health information to managers, supervisors and associates.
Ensure this IIPP is available to each manager and supervisor.
Responsibilities of Department Heads: (managers/supervisors)
1.
2.
3.
4.
5.
6.
Implement and enforce all safety regulations within their department.
Ensure all new employees are properly trained before they start work, and when new tools
or duties are added to the department.
Ensure all trainings and safety communications are done in a language and manner easily
understood by associates.
Conduct regular departmental safety training to ensure a safe environment for employees and
the general public.
Identify an associate(s) from each department to participate in cross-departmental safety
meetings and to represent the department on the Safety Committee.
Ensure all employees have and use the proper tools for their jobs.
3
7.
8.
9.
10.
11.
12.
Conduct periodic safety inspections of area of responsibility and report all hazards, unsafe
conditions, or work habits so corrections can be made.
Encourage associates to report workplace hazards (in regards to equipment availability,
conditions, storage, and maintenance) without fear of reprimand
Maintain documentation concerning inspections, safety meetings, and accident and injury
reporting.
Discipline workers for failure to comply with safe and helpful work practices according to
the defined progressive discipline policy.
Ensure all injuries receive immediate first aid from a trained responder who assumes
responsibility for care, or otherwise by contacting emergency response by dialing 911.
Ensure every accident is reported immediately and properly.
Responsibilities of Associates:
1.
2.
3.
4.
5.
6.
Follow all requirements of the IIPP.
Adhere to healthy and safe practices in the workplace.
Participate in training programs/meetings.
Maintain equipment in good condition, with all safety guards in place when in operation.
Report all potential hazards in the workplace and all workplace incidents.
Encourage co-workers to work safely.
4
Assignment of Responsibility
Sample Form
The employer accepts the responsibility for leadership of the safety and health program, for its
effectiveness and improvement and for providing the safeguards required to ensure safe conditions.
Department Heads are responsible for developing proper attitude toward safety and health in
themselves, in those they supervise, and for ensuring that all operations are performed with the utmost
regard for the safety and health of all personnel involved.
Employees and Associates are responsible for total and genuine cooperation of all aspects of the safety
and health program including compliance with all rules and regulations and for continuously practicing
safety while performing their duties.
The person designated as the IIPP Program Administrator, who is responsible for the overall
administration and oversight of the safety program is assigned to:
________________________
Name
_______________________
Title
(Multiple persons can be assigned to the Program Administrator position)
________________________
Name
_______________________
Title
________________________
Name
_______________________
Title
5
EMPLOYEE COMPLIANCE
6
Employee Compliance
Cal-OSHA requires employers to have a system for ensuring compliance with work practices and
promoting safety and health in the workplace. Compliance with this provision should include recognition
of employees who follow safe and healthful practices. Examples of systems: incentive programs; training
and retraining programs; disciplinary actions; and infraction notices.
Employee Compliance Policy
Outline your procedures for ensuring compliance. For example:
Review a Code of Safe Work Practices (See attached Sample Form) with trained employees and have them
sign and date indicating they understand the policy and are willing to actively participate in the IIPP process.
Employees who fail to follow the company's Code of Safe Work Practices will be subject to disciplinary
actions outlined in Sample Form: Notice of Safety Infraction
Establishing an incentive program is an opportunity to motivate employees to comply with safety rules,
safety policies and correct unsafe acts. (Describe how your incentive program works)
7
Employee Compliance
Cal/OSHA requires employers to have a system for ensuring compliance with work practices and promoting
safety and health in the workplace. Compliance with this provision should include recognition of
employees who follow safe and healthful practices. Examples of systems;
 Incentive programs
 Training and retraining programs
 Disciplinary actions
 Infraction notices
Employee Compliance Policy
All employees comply with safe and healthy work practices. Managers and Supervisors are responsible for
establishing and maintaining good health and safety practices. To ensure compliance:






Employees will be informed of the provisions of this hotel’s Injury and Illness Prevention
Program (IIPP).
Employees who make a significant contribution to maintenance of a safe workplace will be
acknowledged (e.g. oral acknowledgment at associate receptions).
Employees will be trained and retrained, as necessary or required.
Employees will follow and pertain to the Code of Safe Practices see Sample Form on Page 10
Employees who fail to comply with the general safe and healthful practices of the hotel and
department specific safe and healthful work practices will be subject to disciplinary action up to
and including termination. Managers will follow established progressive disciplinary
procedures.
An anti- reprisal policy for employees reporting safety and health concerns is enforced.
Employees who fail to follow the company's code of safe work practices will be subject to disciplinary
actions outlined in Sample Form on Page 12.
Incentive Program
An incentive program is an opportunity to motivate employees to comply with safety rules, safety policy,
and correct unsafe acts. Incentive programs are positive and successful ways to motivate employees to
work safely and comply with the general safety rules and procedures.
Incentive programs are positive and successful ways to motivate employees to work safely and comply with
the general safety rules and procedures. Consider the following activities when you set up your program:
 Presentation of safety awards
 Announcements of safety policy and procedures
 Announcements of contests winners for safety record improvement, or safety poster design
 Displaying safety solutions or new safety equipment
 Display of sign showing days worked without a lost-time accident
 Involve the workers and change the program when motives and attitudes change. When results
change reassess the program and make changes that fit the current situation
 Emphasize that the program is designed to reward employees for working safely, not for
refusing to report and injury
8
Employees need to understand the rules as well as their potential gain to have a successful program.
Involve the workers and change the program when motives and attitudes change. When results change
reassess the program and make changes that fit the current situation. Emphasize that the program is
designed to reward employees for working safely, not for refusing to report an injury, accident, and / or
hazard. Employees need to understand the rules as well as their potential gain to have a successful program.
9
CODE OF SAFE PRACTICES
Sample Form
It is our policy to take all reasonable measures to protect employees, customers and visitors from accidents
or injuries. Safety is a cooperative undertaking requiring participation by every employee. Failure by any
employee to comply with safety rules will be grounds for corrective discipline. Supervisors will insist that
employees observe all applicable Company, State and Federal Safety Rules and Practices and take action
as is necessary to obtain compliance and carry out this policy. Employees will:
1. Report all unsafe conditions and equipment to your supervisor or safety coordinator immediately
2. Report all incidents, injuries and illnesses to your supervisor or safety coordinator immediately
3. Means of egress shall be kept unblocked, well-lighted and unlocked during work hours.
4. In the event of fire, sound alarm and evacuate
5. Upon hearing fire alarm, stop work and proceed to the nearest clear exit. Gather at the designated
location.
6. Only trained workers may attempt to respond to a fire or other emergency.
7. Exit doors must comply with fire safety regulations during business hours.
8. Stairways should be kept clear of items that can be tripped over and all areas under stairways that
are egress routes should not be used to store combustibles.
9. Materials and equipment will not be stored against doors or exits, fire ladders or fire extinguisher
stations.
10. Aisles must be kept clear at all times.
11. Work areas should be maintained in a neat, orderly manner. Trash and refuse are to be thrown in
proper waste containers.
12. All spills shall be wiped up promptly.
13. Files and supplies should be stored in such a manner as to preclude damage to the supplies or injury
to personnel when they are moved. Heaviest items should be stored closest to the floor and
lightweight items stored above.
14. All cords running into walk areas must be taped down or inserted through rubber protectors to
preclude them from becoming tripping hazards.
15. Never stack material precariously on top of lockers, file cabinets or other high places.
16. Never leave desk or cabinet drawers open that present a tripping hazard. Use care when opening
and closing drawers to avoid pinching fingers.
10
17. Do not open more than one upper drawer at a time, particularly the top two drawers on tall file
cabinets.
18. Always use the proper lifting technique. Never attempt to lift or push an object which is too heavy.
You must contact your supervisor when help is needed to move a heavy object.
19. When carrying material, caution should be exercised in watching for and avoiding obstructions,
loose material, etc.
20. All electrical equipment should be plugged into appropriate wall receptacles or into an extension
of only one cord of similar size and capacity. Three-pronged plugs should be used to ensure
continuity of ground.
21. Individual heaters at work areas should be kept clear of combustible materials such as drapes or
waste from waste baskets. Newer heaters which are equipped with tip-over switches should be
used.
22. Appliances such as coffee pots and microwaves should be kept in working order and inspected for
signs of wear, heat or fraying of cords.
23. Fans used in work areas should be guarded. Guards must not allow fingers to be inserted through
the mesh. Newer fans are equipped with proper guards.
24. Equipment such as scissors, staplers, etc., should be used for their intended purposes only and
should not be misused as hammers, pry bars, screwdrivers, etc. Misuse can cause damage to the
equipment and possibly injury to the user.
25. Cleaning supplies should be stored away from edible items on kitchen shelves.
26. Cleaning solvents and flammable liquids should be stored in appropriate containers.
27. Solutions that may be poisonous or not intended for consumption and should be kept in well labeled
containers according to the Hazard Communication Program.
This form should be maintained in the employee’s training file. Items can be deleted, or added, to this form
as needed.
Employee Signature
Date
Manager/Supervisor Signature
Date
(The following is a sample that can be used as a guide and may not be legally applicable for your operations;
it is recommended that you consult a labor attorney before instituting any employee disciplinary policy. If
a collective bargaining agreement is enforced, these disciplinary measures should be reviewed in context
to the agreement)
11
Notice of Safety Infraction
Sample Form
We consider the safety of our employees to be very important. Therefore, to prevent accidents, it is our
policy to strictly enforce company safety rules. Infractions of safety rules will result in the following:
1st Infraction: Written/Verbal Warning
2nd infraction: Written Warning
3rd Infraction: 3 to 5 Day Suspension
4th Infraction: Dismissal
__________________(Insert Employee Name)_____________ you have been observed working in the
following unsafe manner, contrary to company safety rules. Describe the unsafe act, safety
policy/procedure violated, etc,:
This is your (check appropriate box):
 First Infraction
 Second Infraction
 Third Infraction
 Fourth Infraction
Action taken, Therefore Is:
Supervisor
Date
Employee
Date
12
EMPLOYEE COMMUNICATION
13
EMPLOYEE COMMUNICATION
Cal-OSHA requires a system for communicating occupational safety and health issues be included in your
Injury and Illness Prevention Program. The flow of safety and health information between management
and staff is required to be in a form that is readily understandable (including language). Compliance with
this provision includes the following measures:






Formal & Informal Training Programs
Postings and other forms of Written Communication
Labor/Management Safety & Health Committees
Anonymous Hazard Reporting by Employees
Anti-Reprisal Policy
Employee Safety Meetings
The following are examples of each communication system and the required detail that needs to be included.
The following sample form can be used to identify the forms of employee communication currently in use
at your business. Utilize the sections following the sample form to develop and implement effective forms
of communication, if any of the above are missing from your communications.
14
Communication
Sample Form
Communication is an important element of a successful IIPP.
We recognize that open, two-way communication between management and staff on health and safety
issues is essential to an injury-free, productive workplace.
All department heads are responsible for communicating with all workers about occupational safety
and health in a form readily understandable by all workers. We encourage all workers to communicate
with their managers and supervisors about workplace hazards without fear of reprisal.
The communication system includes one or more of the following checked items:
 New Worker orientation including a discussion of safety and health policies and procedures.
 Review of our IIPP.
 Workplace safety and health training programs.
 Regularly scheduled safety meetings.
 Effective communication of safety and health concerns between workers and supervisors, including
translation where appropriate.
 Posted or distributed safety information.
 A system for workers to anonymously inform management about workplace hazards.
 Our establishment has less than ten employees and communicates with and instructs employees
orally about general safe work practices and with respect to hazards unique to each employee’s job
assignment.
 A Safety Committee meets regularly, prepares written records of the safety and health committees
meetings, reviews results of the periodic scheduled inspections, reviews investigations of accidents
and exposures and makes alleged hazardous conditions, and submits recommendations to assist in
the evaluation of employee safety suggestion.
 Other: _______________________________________________________________________
_____________________________________________________________________________
15
Methods for Communicating Safety Policies & Procedures
All employees will receive safety training and instruction:





During orientation for job specific and general safety rules, this will include, but not be limited to,
emergency preparedness and evacuation procedures, and hazard communication
If an employee is given a new job assignment, safety training for the new assignment will be given
during their orientation
Whenever new substances, processes, procedures or equipment are introduced to the workplace
During regularly scheduled safety meetings
Refresher safety training will be conducted on a regular basis and retraining will be available for
employees demonstrating a deficiency in safety knowledge.
General and Department Specific Safety and Health Training
A multifaceted training program will be the method that will be used to communicate, educate, and
inform employees and managers about safety and health. Utilize the Safety Communication Policy
outlined in Sample Form to identify forms of communication and to obtain Management Commitment
to implementing these forms.
At each scheduled department meeting. Each manager will discuss with the employees under his or
her direct supervision such issues as:



Unsafe conditions discovered in the workplace (safety inspection results/ anonymous
notifications/accident investigation);
Causes of recent injuries and illnesses and the methods adopted by the hotel to prevent similar
incidents in the future; and
Any safety and health issue deemed by the manager to require reinforcement.
Copies of the meeting minutes from all monthly departmental meetings are kept on file by the
designated IIPP Program Administrator for three (3) years.
Postings and Bulletin Boards


The Cal-OSHA “Safety and Health Protection on the Job” will be displayed in a prominent
location at the business.
A safety and health bulletin board located at or near the employee cafeteria/break room will be
maintained for informational purposes.
Labor / Management Safety and Health Committees
If you choose to use a Labor / Management Safety Committee, Cal-OSHA requires that the committee:

Meet regularly, but not less than quarterly. Committee may be comprised of the General
Manager, Director of Engineering, Human Resources Manager and those managers and
employees appointed by the IIPP Program Administrator. PLEASE NOTE: In addition to
management representation, the committee must also include a non-management member(s).
16






Prepare and make available to the affected employees, written records of the safety and health
issues discussed at the committee meetings and maintain for review by Cal-OSHA upon
request.
Meeting minutes will be recorded using Sample Form on Page 22 and posted on departmental
bulletin boards.
Safety Team Meetings will be scheduled for a pre-designated date and time to allow members
to coordinate attendance.
Encourage associates to report workplace hazards to management without fear of reprisal as
described in anti-reprisal policy statement.
Encourage associates to report workplace incidents (injuries, exposures and illnesses).
Upon request from Cal-OSHA, verify abatement action taken by the employer to abate citations
issued by Cal-OSHA.
During these meetings, members will:





Review results of the periodic, scheduled worksite inspections.
Review investigations of occupational injuries and illnesses and causes of incidents resulting
in occupational injury, occupational illness, or exposure to hazardous substances, and where
appropriate, submit suggestions to management of the prevention of future incidents.
Review investigations of alleged hazardous conditions brought to the attention of any
committee member. When determined necessary by the committee the committee may conduct
its own inspection and investigation to assist in remedial solutions.
Submit recommendations to assist in the evaluation of employee safety suggestions.
The Self-Inspection Checklist will be reviewed along with required corrective action and
completion schedule.
Anonymous and Confidential Hazard Reporting



Associates are required to immediately report any unsafe condition or work practice that they
discover in the workplace to their manager or the program administrators.
This can be done through the use of a work order, open door communication, verbally or voice
mail.
Employees who wish to remain anonymous may report an unsafe condition or work practice
without identifying themselves via the “STATE METHOD AND LOCATION”.
Anti-Reprisal Policy

Associates shall not be discharged or discriminated against in any manner for bona fide
reporting of health and safety hazards to the hotels management team or to appropriate
governmental agencies. Supervisors and managers will inform associates of this policy and
encourage reporting of workplace hazards to the management team.
17
Employee Safety Meetings
Safety lessons learned during new employee orientation may be forgotten over time and unsafe work
habits may develop. Complacency may occur when working with machinery or potentially hazardous
conditions day after day. Brief safety meetings are reminders to recognize potential hazards and work
safely.
Points to consider




Meetings should be brief and cover only one subject.
Meetings can be more interesting if employees participate in the discussion.
The focus of the meetings should be prevention and not criticism of employees.
Have a bilingual person translate for non-English speaking employees.
Set up a schedule for safety meetings and conduct them on a regular basis. Documentation of the
meeting is required. Also, the safety training topic provided and employee participation is required to
be recorded.
18
Safety Communication Policy
Sample Form
The company recognizes that open two-way communication between management and staff on health and
safety issues is essential to an injury-free productive workplace. Your thoughts regarding safety are
considered important, and we encourage your active participation in our company safety program. Please
feel free to express any of your safety concerns or suggestions in safety meetings or discussions with your
supervisor.
Notification of hazards, potential hazards, or safety suggestions can be made anonymously by depositing
form in (safety suggestion box). All suggestions will be considered seriously and will receive a response.
No employee will be retaliated against for reporting hazards or potential hazards, or for making suggestions
related to safety.
Other forms of safety communication will be provided:
 New Employee Safety Orientation
 Anonymous Suggestion Box
 A Labor / Management Safety Committee
 Current Safety News and Articles
 Safety Reading Material Distributed by Pay Envelope Inserts and / or Newsletter Published (Pick
Monthly, Weekly, Quarterly, Yearly)
 Signs and Posters
 Safety Bulletin Board for Posting Safety Materials and Communications
Safety meetings will be held every (insert desired time frame i.e. quarterly, monthly or weekly) providing
an opportunity for employees to voice opinions regarding safety and receive safety training.
Program Administrator
Date
19
Employee Safety Information Form
Sample Form
This form can be used by employees who wish to provide a safety suggestion, or report an unsafe
workplace condition or practice.
Description of Unsafe Condition or Practice:
Causes or Other Contributing Factors:
Employee's Suggestions for Improving Safety
Has This Matter Been Reported to your Manager/Supervisor?
Yes
No
Employee Name (Optional):
Department:
Date:
For Office Use Only:
Accepted Date:
Denied Date:
Proposed Completion Date:
Actual Completion Date:
Reasons:
Signature:
Date:
(Employees are advised that the use of this form or other reports of unsafe conditions or practices are
protected by law. It would be illegal for the employer to take any action against an employee in reprisal
for exercising rights to participate in communications involving)
20
Employee Safety Meeting Sign Up Sheet:
Sample Form
Date:
Name of Trainer:
Location:
Department:
Subject:
Incident Reviewed (If Applicable):
Suggestions / Recommendations:
Attendees (Please Print Your Name Legibly)
Name:
Department:
21
Safety Committee Meeting Minutes:
Sample Form
In Attendance: (List Participants and Department)
Name / Department
Name / Department
<Insert Current Month> Monthly Safety Topic:
(Topic)
REMEMBER: All Training Rosters must be completed and submitted to
specified due date below. NO EXCEPTIONS.
(Training DUE DATE: _______)
Employee Accidents for the Previous Month:


Reviewed the <Insert Month> accidents, (List Number Reported).
Frequency & Severity numbers TO DATE.
Assigned Monthly Workplace Self-Inspection:

Department Assigned Inspection
Old Business Follow-up:
(Subjects Discussed and Resolution)
Round Table / Subjects Discussed:
(Any New Business- Safety & Wellness Concerns or Improvement needed)
Next Meeting – (Indicate Date: Month, Year)
22
by the
Example Safety Committee Agenda Might Include:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Safety disciplinary action
Employee Safety Meeting Minutes (training), by department/topic
Results of premise safety inspections, by department
Security issues
Safety incentive program results
Employee safety suggestions
Other business discussed
Executive Safety Committee Meeting update
Comments from Safety Committee members and guests
Next Committee meeting date and time
Adjournment
23
TRAINING
24
TRAINING REQUIREMENTS
Cal/OSHA requires that training be provided:




To new employees and all those given new job assignments when training has not
previously been received
Whenever new substances, processes, procedures or equipment are introduced to the
workplace and represent a new hazard
Whenever the employer is made aware of a new previously unrecognized hazard
For supervisors to familiarize themselves with the safety and health hazards to which
employees under their immediate direction and control may be exposed.
Records of training should be kept by an assigned person
The following are possible indicators that training or retraining may be needed:






High turnover
An increase in near misses which could have resulted in injuries or illnesses
An increase in reported injuries
High Injury or Illness incidence
A request for personal protective equipment not currently provided, such as ear plugs or
respirators
Expansion of operations
25
Training and Instruction
The California Hotel and Lodging Association believes that instructing employees in safe and healthful
work practices is critical to preventing accidents that lead to occupational injuries and illnesses in the
workplace. In addition to providing knowledge through instruction, safety and health training is a good
communication method for reinforcing safe work practices and maintaining awareness. Associates will
be made aware of developing trends and hazard exposures as they are identified through pre-shift
meetings, safety minutes posted on bulletin boards and through their respective Safety Committee
members.
Training of employees is ranked by most safety professionals as the most effective means of reducing
injuries and illness. This is particularly true where safety hazards cannot be controlled or eliminated by
engineering and safety must rely in part on safe work practices and personal protective equipment. All
workers shall have training instruction on general and job-specific safety and health practices. NonEnglish speaking employees should be trained verbally in their native language by a translator or a
bilingual employee using the codes of safe practices and other information in this guide. The training
and instruction shall be provided:
1.
2.
3.
4.
When the IIP Program is first established;
To all new workers;
To all workers given new job assignments for which training has not been previously provided;
Whenever new substances, processes, procedures or equipment are introduced to the workplace
and represent a new hazard;
5. Whenever the employer is made aware of a new or previously unrecognized hazard;
6. To supervisors to familiarize them with the safety and health hazards to which workers under
their immediate direction and control may be exposed; and
7. To all workers with respect to hazards specific to each employee's job assignment.
See Safety Training Policy, Employee Safety Training Checklist, and Employee Training Record Sample
Forms below.
Workplace safety and health practices for all industries include, but are not limited to, the following:
1. Introduction to the IIPP including the hotel’s emergency action plan and fire prevention plan, and
2.
3.
4.
5.
6.
measures for reporting any unsafe conditions, work practices, injuries and when additional
instruction is needed.
Use of appropriate clothing, gloves, footwear, and personal protective equipment.
Information about chemical hazards to which employees could be exposed, other hazard
communication program information and blood borne pathogens policy.
Hazard communication and how to read and comprehend Safety Data Sheets (SDS's) and
container labels.
Availability of toilet, hand-washing and drinking water facilities.
Violence in the workplace.
26
Training Documentation
Careful records of training must be maintained as these will be an essential part of Cal-OSHA inspections.
Two types of proof of training documents are needed:
1. A sign-up sheet for group sessions – documents topic, trainer, and attendees.
2. An individual training certificate – can be upon the hiring of a new employee to document the
initial training and its content.
27
Safety Training Policy
Sample Form
(Assigned Person)
Shall be responsible for assuring training is provided that familiarizes supervisors with the safety and health
hazards the employees under their immediate direction and control may be exposed.
Supervisors are responsible to see that those under their direction receive training on general work place
safety as well as specific instructions with regard to hazards unique to any job assignment.
When a supervisor is unable to provide the required training, he / she should notify the assigned person and
request that such training be given to the employee by others.
All company employees will participate in:
 Training whenever job duties or work assignments are expanded or changed.
 Training whenever employees are exposed to new processes, machinery, chemicals, and / or
previously unrecognized hazards.
 Initial and ongoing employee safety training will be provided when new substances processes or
procedures are introduced into the work environment.
 Scheduled safety meetings.
 Other training programs as appropriate.
28
Employee Safety Training Checklist
Sample Form
This form is to be completed by the supervisor, (insert), and the new or reassign employee within (insert)
days after employment or reassignment and filed by (insert).
Employee Name:
Department:
Type of Work:
Past Work Experience:
Date of Hire:
Ask Employee "Can you perform this job with or without reasonable accommodations? If a reasonable
accommodation is necessary, please describe the type of accommodation needed.
Did the employee have a pre-placement physical?
Yes
No
If yes, are any work restrictions indicated (explain):
Safety and Health Orientation Training
Review the following safety policies; check and discuss those that are included in the orientation
–
The Company, State, and Federal safety policies and programs
Date completed
–
General and specific safety rules and regulations pertaining to hazards associated with the
employee's job assignment; including the Code of Safe Work Practices
Date completed
–
The required personal protective equipment necessary for safe work performance
Date completed
–
Procedures for the prompt reporting of accidents and / or "near misses"
Date completed
–
The Company's first-aid program
Date Completed
–
The immediate reporting of hazardous conditions and / or unsafe work practices or conditions to
your supervisor without fear of reprisal
Date completed
–
The Employee Suggestion Box for reporting unsafe conditions and / or unsafe work practices
openly or anonymously
Date completed
–
The company's safety rule enforcement procedures (disciplinary policy)
Date completed
29
–
Positive safety incentives for good safety record
Date completed
–
The company's hazard communication program, emergency preparedness
Date Completed
–
Location of fire extinguishers and emergency procedures
Date completed
–
Use of tools and equipment
Date completed
–
Proper guarding of equipment
Date completed
–
Material handling and lifting procedures
Date Completed
–
Special hazards of the job
Date completed
–
Employee responsibility for prevention of injuries and illnesses
Date completed
–
Safe operations of vehicles
Date completed
Add other items that apply to your specific operations or other Cal/OSHA required training
I have received the above training. I fully understand the items that were discussed, and agree to comply
with the Company's safety policies and procedures with respect to the Company and my department.
Supervisor
Date
Employee
Date
Assigned Person
Date
30
Employee Training Record
Sample Form
Name:
Department:
Training Topic
Date Training
Completed
31
Trainer
Employee
Initials
TIPS FOR DEPARTMENTAL SAFETY TRAINING
Have a timetable – how much skill do you expect employees to have and by what date?
Have everything ready - the right equipment, materials, and supplies.
HOW TO INSTRUCT
Prepare:
Put the employee at ease.
Define the job and find out how much the employee already knows.
Lay out everything in the correct position.
Present:
Tell, show and illustrate one important step at a time.
Stress each key point.
Try Out:
Have employees do the job – correct errors constructively.
Have employee explain key point to you as the job is done again.
Make sure the employee understands.
Continue until YOU believe the employee understands.
Inform them whom they should go to for help.
Follow Up:
Let them perform assigned task on their own.
Check in with them frequently.
Encourage questions.
32
HAZARDS
INSPECTIONS
AND
CORRECTIONS
33
IDENTIFICATION AND CONTROL OF HAZARDS
Cal-OSHA requires that employers maintain a healthful workplace by: using the
Safety and Health Standards to help identify hazards which exist now or could
develop later; and instituting procedures to control hazards and take action to
eliminate them
Employers are required to:

Indicate the frequency of inspections; identify the person responsible for conducting inspections
and correcting unsafe conditions in all work areas

Conduct inspections whenever new substances, processes procedures or equipment are introduced
into the workplace that represent a new occupational safety and health hazard

Conduct inspections whenever a new or previously unrecognized hazard is identified.
Whenever an unsafe or unhealthy condition, practice, or procedure is observed, discovered, or
reported, the assigned person must take appropriate corrective measures in a timely manner based
upon the severity of the hazard. Employees must be informed of the hazard and interim protective
measures taken until the hazard is corrected.
Cal-OSHA guidelines can be used to assist employers in developing hazard
control procedures and to eliminate hazards from machines, processes, material
or work site structures.
1. Abating hazards by controlling exposures to it or guarding against it.
2. Training personnel to be aware of the hazards and to follow safe work practices and
procedures
3. Using signs and personal protective equipment for warning and shielding employees against
hazards.
34
Hazard Assessment
Inspections are a vital process in building and maintain an effective IIPP as well as a safe and healthy
workplace. These inspections are intended to identify and correct hazards before an accident occurs.
Periodic inspections to identify and evaluate workplace hazards shall be performed by a competent observer
in the following areas of our workplace. Each individual property must review its departments and job
activities to assure that all are covered in the hazard assessment and that the information is complete.
Examples where this may be necessary is for a larger more complex operation such as a golf course, tennis
club, and water park. The potential scope of those activities exceeds this guide’s usefulness to the typical
property.
Hotel Operations
Bellman/Guest Services
Concierge/Guest Requests
Front Desk Clerk
Door Attendant/Door Person
Driver
Gift Shop Attendant
Receiving/Issuing Clerk
Security Personnel
Valet Attendant
Restaurant
Bus Person Food Server/Wait Person
Line Cook
Bartender
Kitchen
AM/PM Pantry
Banquet Chefs/Cooks
Banquet Steward
Dishwasher
Floor cleaner
Kitchen Steward
Night Porter
Sous Chef
Trash Compactor/Baler Operator
Utility Person
Housekeeping
Grounds Person
Housekeeper
Housemen/Porter
Laundry Person
Lobby Person
Maintenance
Maintenance/Handyperson
Powerhouse and Shop Engineering
Administration/Office/Management /Sales
Any Other Work Areas
Hazard identification and control procedures are used to detect accident potentials which, when corrected,
will reduce the likelihood of associate injury or illness. The basic objectives of these procedures are to:



Maintain a safe work environment;
Eliminate or minimize the risks of injury and illness;
Maintain operational productivity.
35
Periodic Inspections are Performed According to the Following Schedule:
1. Department Inspections – Quarterly or monthly (circle one) inspections will be conducted in all
departments of the hotel. The IIPP Program Administrator will assign managers and associates
to conduct the inspections. They will use the Inspection Checklist Sample Form on Page 37 and
pages 96-106 and any other effective methods to identify and evaluate workplace hazards.
2. New Practice, Procedure, Product, or Equipment – when a new practice, procedure, product or
piece of equipment is introduced to a department, the Department Manager and/or Program
Administrator will review new items/procedures for potential hazards.
3. Reporting Unsafe Conditions and Work Practices – Associates are required to report any unsafe
condition or work practice immediately to their Department Manager or to the Program
Administrator. This can be done through the use of a work order, open door communication,
verbal notice, email notice, voice mail, or anonymous reporting via our anonymous reporting
policy. No associate will be disciplined or discharged for reporting any unsafe condition or work
practice.
Developing a Hazard Assessment Checklist
The Sample Form on Page 37 can be used to develop an inspection check list. The form is also useful
whenever: new equipment, new substances, new processes, new procedures, new hazards, or previously
unrecognized hazards are introduced into the workplace.
1. Use your own experience to develop a hazard inspection checklist for their operations.
2. The items should be specific and clear enough so that anyone in your department can check off
the items listed.
3. Once you have completed the list, make copies so that a new list does not have to be made every
time you do an inspection.
4. This list should be made part of your IIPP.
5. When doing the inspection for every item, check either box, "Satisfactory" or "Needs Attention"
6. The "Target Date for Completion" and "Date Corrected" boxes are used to follow up inspections
or to note that the item has been corrected. Follow-up inspections and corrections should be
made on a timely basis.
Sample Self Inspection forms can be located on pages 96-106
Documentation of Department Inspections
Records of inspections will be documented on the Hazard Assessment Checklist and will be kept on file by
the Program Administrator for a minimum of one (1) year, unless otherwise specified. The records shall
include:



Name, title, department of person/s conductions in inspection.
Any description of the unsafe condition/s and work practices.
The actions taken to correct the identified unsafe condition/s and work practice/s.
The Hotel industry is also subject to Cal-OSHA standards that require all hotels to have an Emergency
Action and Fire Protection Plans and a Hazard Communication Standard. It is up to each individual
property to tailor these written programs specific to their operations. Hotels that already have established
programs in these areas can reference their existing documentation.
36
HAZARD ASSESSMENT CHECKLIST
Name
Date
37
Date Completed
Target Date for
Completion
HAZARD (DESCRIPTION)
Needs Attention
Satisfactory
Sample Form
Identification and Corrections of Hazards
Hazard Assessment Sample Policy 1
Initial and ongoing employee safety training will be provided when new substances processes or procedures
are introduced into the work environment
Investigation of accidents and/or “near miss” incidents will be conducted to determine causation and the
controls necessary to prevent a recurrence.
Scheduled inspections will be conducted ________________ Weekly/Monthly/Quarterly
by _________________________ Name or Committee to identify unsafe conditions and work practices,
and develop controls to eliminate or control noted deficiencies/hazards.
Inspection results will be discussed during the _________________ Weekly/Monthly safety meetings.
Control Procedures following identification of a new or previously unrecognized hazard:

Eliminate hazards from machines, processes, material, or work site structure

Abate hazards by controlling exposures to it or guarding against it at its source

Train employees to be aware of hazards and to follow safe work practices and procedures.

Prescribe signs and personal protective equipment for warning and shielding employees against hazards

The program administrator or designee shall:
1. Evaluate the severity of the hazard identified, and determine if it can be abated immediately
2. Determine hazard priority for implementing corrective procedures and actions.
38
Identification of a New or Previously Unrecognized Hazard
Hazard Assessment Sample Policy 2
Control Procedures:




Eliminate hazards form machines, processes, material or work site structure
Abate hazards by controlling exposures to it or guarding against it at its source
Train employees to be aware of hazards and to follow safe work practices and procedures.
Prescribe signs and personal protective equipment for warning and shielding employees against
hazards
The Program Administrator or designee shall:


Evaluate the severity of the hazard identified, and determine if it can be abated immediately
Suggest priority of corrective actions for identified hazards
Correction of Unsafe or Unhealthy Conditions
and/or Work Practices
1. Unsafe or unhealthy work conditions or practices must be corrected immediately. Employees must
be removed from affected area(s) until hazard(s) are corrected and new training implemented.
2. Defective equipment and/or work areas are to be taken “out of service” until hazards are corrected.
This should be done by physically tagging-out and locking-out equipment, and removing
employees from affected work areas.
3. Supervisors are responsible for assuring the proper controls have been implemented to correct
hazardous conditions prior to employees resuming work.
39
Hazard Identification and Correction
Cal-OSHA requires that employers maintain a healthful workplace by using the Safety and Health
Standards to help identify hazards which exist now or could develop later, and instituting procedures to
control hazards and take action to eliminate them. This facility is committed to correct unsafe or unhealthy
work conditions in a timely manner, based on the severity of the hazards. See Hazard Correction Form
Sample Form on Page 42.
Schedules for Correcting Hazards
Hazards shall be corrected according the following procedures:
 When observed or discovered;
 When an imminent hazard exists which cannot be immediately abated without endangering
employee(s) and/or property, all exposed personnel will be removed from the area, except those
necessary to correct the existing condition. Employees necessary to correct the hazardous condition
shall be provided with necessary safeguards.
Hazard Control
When identified hazards cannot be eliminated, the hazard will be effectively controlled by, in priority order,
engineering controls, then through administrative practices and, as a last choice in control measures, with
the use of personal protective equipment, or any combination of these measures.
Engineering Control
Whenever possible and feasible, hazards identified at Hyatt will be corrected eliminating the cause of the
hazard at the source. This will include but is not limited to:
1.
2.
3.
4.
5.
Discontinuing or removal of hazardous chemicals, materials, or substances.
Discontinuing from use, or removal, of hazardous equipment until repaired or replaced.
Guarding the hazard
Correction of any unsafe act or conditions by service or training
Evaluation of new products, equipment, or practices before purchase or introduction into the
workplace.
Administrative and Work Practice Controls
The following administrative and work practice controls can be found in separate programs and in detail in
the training section of this program:
General training may include, but is not limited to:
 Introduction to the IIP Program
 Emergency Action and Fire plan
 How to report an injury or illness
 Violence in the workplace
40
Department Specific training may include, but is not limited to:
 Hazard Communication
 Blood borne Pathogens
 Personal Protective Equipment ( PPE)
 Heat Illness Prevention
 Energy Source Hazards- Lockout/Tag out of affected associates
 Respiratory Protection of affected associates
Personal Protective Equipment
When safe work practice cannot be accomplished by Engineering or Administrative Controls,
Personal Protective Equipment will be implemented.
1. An initial Job Hazard Analysis will be conducted by each department manager or supervisor
on each job task in their department to determine, hazard, potential to injury to body part, and
identify PPE required.
2. When any new substance, process, procedure, or equipment introduced into the workplace that
presents a new hazard, the plan administrator, will provide each department supervisor or
manager with the copy of the previous Job Hazard Analysis to be reviewed to ensure they are
complete and correct.
3. The need for PPE will be communicated annually to all affected associates (department/task
specific).
4. Intermittent updates on a new need for PPE, the reason for the PPE.
5. Correct use of the PPE will be communicated to affected associates prior to their assignment
to the task requiring the PPE.
Recordkeeping of Hazard Correction
As corrective actions are implemented, supervisors and/or the IIPP Program Administrator shall document
the effort and maintain such record for at least three (3) years.
Resources
Unsafe conditions that cannot be corrected with resources available to the supervisor or manager must be
reported to the next higher level of management.
41
Hazard Correction Form
Sample Form No.
Department:
Supervisor / Safety Coordinator Name:
Telephone:
Supervisor / Safety Coordinator Signature:
Description and Location of
Unsafe Condition
Date
Discovered
Date:
Required Action and Responsible Party
Completion Date
Projected
42
Actual
Safe and Healthful Work Practices
These are position specific work practices, based on hazard assessments, for Associates to follow when
conducting their job tasks. They can be used to develop safe job procedures and for employee training
43
General Area or Specific Job Safety Class: Housekeeping
1. Carts shall not be overloaded with linen and other material.
2. Electrical cords must be kept to ones’ side while vacuuming.
3. Wet floors shall be indicated with proper signage.
4. Care must be taken when pushing carts over thresholds and must never be lifted to clear thresholds.
5. Carts must be pushed and not pulled.
6. Employees are not to stand on bathroom fixtures to reach high areas.
General Area or Specific Job Safety Class: Kitchen / Stewarding / Cafeteria
1. All knives are to be kept sharpened to prevent cuts.
2. Knives are to be used with extreme caution. Pay attention to the task at hand. Never cut while looking
away from what you are attempting to slice.
3. Knives are to be stored properly after use.
4. All glassware is to be inspected carefully before placing into use.
5. Never pick up broken glassware with your bare hands. A broom and dustpan or rubber gloves are to
be used.
6. Hot utensils are not to be touched with bare hands. Mitts or towels are to be used.
7. Test the water before submerging entire hands into hot water. Use rubber gloves if washing pots and
pans in hot water.
8. Cover hot liquids before attempting to transport.
9. Slicers must never be operated without safety guards in place.
10. Care must be taken in wiping any cutting blades for the purpose of cleaning. Use of appropriate PPE–
gloves are required.
11. Always ease items into hot oil when frying. Never drop from above to cause splashing of hot oil.
12. Storage areas must be kept clean and orderly at all times. Items must be stored securely in their proper
storage place.
13. Top shelf of Queen Mary (carts) must be cleared prior to moving cart.
44
General Area or Specific Job Safety Class: Engineering
1. Power tools must be kept in proper working condition. Remove any faulty equipment immediately out
of service.
2. Eye protection should be used when applicable to task.
3. Ladders must be used to reach high areas. Crates, furniture or chairs will never be used in the place of
a stepladder.
4. Respirators will be used when applicable to task.
5. Painting work areas must be kept properly ventilated.
6. Paints, thinners, and rags must be properly stored.
7. Proper Lockout/Tag Out techniques must be followed when working on equipment.
8. Safety guards must be in working condition and in place when using applicable power tools.
9. Power tools must never be operated while standing on a wet surface.
10. Each time a new chemical is used, a review of the MSDS sheet will be completed.
11. Never try to move a large load by yourself, ask for assistance.
General Area or Specific Job Safety Class: Laundry / Uniform Room
1. All employees must be completely familiar with the operation of the equipment being used.
2. All employees must be aware of the emergency shut off switches of the equipment being used.
3. Do not use equipment while standing on a wet surface.
4. Make certain the machinery has come to a complete stop before attempting to retrieve any stuck linen.
5. Dryer vents must be cleaned regularly to prevent fire hazards.
6. Use extreme caution when sorting soiled linen in baskets, watch for debris and sharp objects such as
glass.
7. Baskets and carts must be loaded and unloaded evenly to prevent tipping over onto the employee.
8. Care must be taken to not touch any of the hot surfaces of ironing equipment.
45
General Area or Specific Job Safety Class: Administrative & Clerical
(Front Desk, Concierge, Reservations, Sales, Catering, Personnel, Accounting, Food & Beverage Cashiers,
Executive Offices and Purchasing)
1. Storage areas are to be kept neat and orderly. Inventory must not be stacked too high and should be
secure in its storage.
2. File cabinet and desk drawers should be opened one drawer at a time. Each drawer must be closed after
its use.
3. Pay close attention to the operation of computer equipment. Power outlets must not be overloaded and
protective equipment must be kept in its place.
4. Do not use chairs or furniture in place of a step ladder.
5. Broken glass must never be picked up by bare hands. A broom and dust pan or protective gloves must
be used.
6. Use care in walking through service hallways and the kitchen areas. Be aware of floor conditions to
prevent slipping.
7. Stairs must be used with caution. Never carry a large load that is too heavy or you cannot see where
you are walking. Handrails must be used at all times.
46
General Area or Specific Job Safety Class: Security / Bell Desk
1. Assure adequate walk space around Bell Stand. Maintain work area in a clean and orderly fashion.
2. Walkways, exits, and corridors must be kept unobstructed by luggage.
3. All employees are to be completely familiar with emergency response responsibilities of their position.
4. All persons must take precautions in emergency situations to protect themselves from body fluids,
which may be hazardous. Use the personal protective equipment provided such as air masks and gloves.
General Area or Specific Job Safety Class: Food & Beverage / Banquets / Convention Services
1. Storage areas are to be kept clean and orderly. Inventory must be secured in its proper storage location.
2. Pressurized cylinders must be kept chained in their upright position at all times.
3. Bus stations and bar areas must be kept clear for pathways of employees.
4. Containers of hot liquids should be covered before attempting to transport.
5. Carts must be guided in a controlled manner and at a safe speed at all times.
6. Care must be taken when loading and unloading drawers to prevent the pinching of fingers and hands.
7. All glassware must be inspected before placing into service.
8. Glasses must not be used as ice scoops.
9. If glass breaks into an ice bin, the entire bin needs to be replaced.
10. All electrical cords must be inspected before plugging into outlet.
11. Care must be taken in handling knives.
12. Stop the cutting action of a knife if attention gets distracted.
13. Always take the time to be aware of the dining area floor. Guest purses and briefcases on the floor can
cause a trip and fall.
14. Use glove provided when handling tables and staging made of wood to prevent splinters.
15. When skirting tables, always point the pin away from fingers to prevent a stick.
47
Sample hazard assessment checklists can be found in the last section of this guide (pages 96 – 106) for
reference. They are designed to be used to evaluate work areas and the various positions within the hotel
and lodging industry. Trained employees should utilize them to identify hazards and unsafe behaviors and
to develop corrective actions to minimize the potential for an incident to occur. Completed checklists
should be reviewed in Safety Committee Meetings and incorporated into employee training as needed.
48
Incident/Illness Investigation Policy
An effective Incident/Illness Investigation Policy is an important component if an IIPP. The purpose of an
incident/illness investigation is to determine all the facts concerning how the incident/illness
occurred. A comprehensive investigation will identify the root cause(s) that contributed to the
incident/illness and identify the proper corrective action(s) that will assist in preventing a similar
occurrence. Minor incidents or “near miss” incidents will also be investigated because they are a
warning of a potential hazard. An investigation must be conducted as soon after an incident as
possible but no later than 24 hours after the incident. Incident investigations must be directed at fact-finding
not fault finding.
To assure that meaningful data will be obtained, all management personnel should be familiar with
injury and illness investigation techniques. In particular, each Supervisor should be well versed in
injury and illness investigation procedures, as well as being the key person in the accident investigation.
The incident investigation team may include the following (these are recommendations):
1. Immediate Supervisor
2. General Manager (or designee)
3. Witnesses
4. Subject matter expert, or health and safety professional
5. Program Administrator (or designee)
The following are the basic rules for conducting an injury and illness investigation:
1. Finding the cause of injury/illness is the purpose of an investigation and not finding fault. An unbiased
approach is necessary to obtain objective findings.
2. Visit the scene of the incident as soon as possible (when it is safe to do so) to get important details from
witnesses while they are fresh in their minds.
3. If possible interview the injured worker at the scene.
4. All interviews should be conducted as privately as possible. Interview witnesses one at a time.
Talk with anyone who has knowledge of the injury and illness even if they did not actually witness it.
5. Consider taking signed statements in cases where facts are unclear or there is disagreement about
the facts
6. Document details graphically. Use sketches, diagrams and photos as needed and take measurements
when appropriate
7. Focus on causes and hazards. Develop an analysis of what happened how it happened and how it could
have been prevented.
8. Determine what caused the incident itself, not just the injury, and the controls necessary to prevent
a recurrence.
9. Follow up safety training is appropriate in many cases
10. Include an action plan. How can the injury or illness be prevented in the future?
11. If a third party or defective product contributed to the injury, save any evidence. It could be critical
to the recovery of claims costs.
Serious injuries, illnesses, or death of an employee must be reported to the nearest District Office of
the Division of Occupational Safety and Health within 8 hours. Serious injury or illness means an
injury or illness which requires: Inpatient hospitalization for more than 24 hours for other than observation;
a loss of any member of the body or; any serious degree of permanent disfigurement.
49
The following are some recommended steps that should be considered when conducting an investigation
and should be included in training programs:
Steps in conducting an investigation
The following steps should be considered when conducting an investigation and applied where relevant:












Arrange immediate, appropriate medical attention for injured person(s);
Control the scene (erect barriers, turn off power, appoint a guard over the site);
Collect physical evidence and information;
Be aware that injured employees and witnesses to injuries may have some emotions involved
that will affect them. Especially if the incident was severe.
Conduct interviews at the scene if possible. Put the individual at ease. Make sure they
understand the primary purpose of the interview is to prevent a recurrence of the incident and
that it can only be done with their help. Ensure witnesses can discuss the incident in relative privacy
where possible;
After each interview repeat the statement back to them to ensure you have correctly recorded their
version of events and have them sign the statement;
If other people stated different facts ask leading questions to discover more information, but
do not contradict what was said in either interview;
Close each interview on a positive note;
Treat people with tact and respect;
Take immediate corrective action where warranted;
Complete the Incident Investigation Form, including recommendations and SPIP development
Schedule follow-up action to ensure the corrective actions have occurred, or are implemented
and track using the SPIP document.
Key Questions to ask during an investigation (These are some examples that can be used as guidance
and are not a complete list)
Who?



Who was involved in the incident?
Who witnessed the incident?
Who else could provide relevant information?
What?





What happened?
What work was being done at the time?
What materials, equipment or substances were involved?
What were there any defects or modifications to the materials, equipment and
substances?
What other relevant information can you add?
50
Where?

Where did the incident actually occur?
o Can you describe the conditions at the location – eg. Lighting, floor conditions,
temperature, climatic conditions, noise and other environmental factors?
When?

When did the incident actually occur (exact time and date)?
o Were there any other relevant timing factors (such as shift change, work cycle,
rest breaks etc)?
How?

How did the incident happen?
o Can you outline the full sequence of events (before, during and after the
incident)?
o Did you notice any unusual or strange events or occurrences?
Why? (Be careful asking these questions because they may make people defensive when
answering):

Why do you think the incident occurred?
o Can you identify other potential direct or indirect causes?
o Can you advise how we can prevent this incident from recurring?
Using the Right Tools



Paper and pencil is the basic tool. Taking notes can jog a memory later on when
you are writing up the incident reports and provide details to the appropriate levels
of management and the client. Record all information (times, places, names, distances,
comments, or anything else you may think will help). Remember that more
information is always better.
Collect pictures. A picture is worth a thousand words. Take an overall picture
first to keep an idea of where the incident took place. Then get any close up shots
to provide additional detail. If needed place a ruler or other object that is of a
known size in the picture so that you can readily identify sizes, or distance within
the picture.
If collecting a picture is not possible, or more detail is necessary, draw a sketch or
diagram. This is useful especially when the incident is complex. Use the diagram to
indicate where key objects or people were in relation to the incident.
51

An investigation kit will be available to management for use during an investigation.
The kit will include the following items:
1. Pens, pencils and Sharpie;
2. Clip board;
3. Disposable camera (a digital camera may be included as well depending
on the work site and where the investigation kit is secured);
4. Graph paper;
5. Pekron Investigation forms;
6. Emergency phone numbers (including the client specific information);
7. Flashlight;
8. Personal Protective Equipment (PPE);
9. Audio recorder;
10. Caution tape;
11. OSHA General and Construction Industry Standards;
12. Tape measure, or measuring wheel and
13. IH monitoring equipment and supplies are available in the Pekron offices.
Arrangements will be made for delivery and use.
Determining The Root Causes
Many times it is easy to identify the work element that contributed to the incident; however,
discovering the system failure that allowed the deficient work element to
occur is often more difficult. This system failure is also known as the root cause(s).
The following diagram and table are provided as guidance to assist in the determination of
root causes during and after the investigation process:
Man
Material
Management
System
Incident
Machine
Methods
Environment
52
Some examples of each of these root cause elements are as follows:
Materials



Defective material(s)
Wrong type of material for the job
Not enough material





Good housekeeping
Job design or work layout
Surfaces poorly maintained
Physical demands of the task
Other conditions (noise, lighting, etc.)


No or poor procedures
Written procedures do not reflect work
practices (observations)
Poor communication
Machine/Equipment




Incorrect selection of tool or equipment
Poor equipment maintenance or design
Poor equipment or tool use
Defective equipment or tool





No or poor management involvement
Poor attention to detail or task
Hazards not properly addressed
Stress
Other (horseplay, training, etc.)




Lack of training or education
Poor employee/management involvement
Poor hazard recognition
Previously identified hazards were not
eliminated
Environment
Man
Methods

Management Systems
53
Employee’s Report of Incident/Near Miss Form
Sample Employee Reporting Form
Instructions: Employees will use this form to report all work related incidents, injuries, illnesses, or “near miss”
events (which could have caused an injury or illness) – no matter how minor. This helps us to identify and correct
hazards before they cause serious incidents. This form will be completed by employees immediately following the
incident and given to their supervisor for investigation.
I am reporting a work related: Illness  Near miss  Incident w/Injury  Incident w/o Injury
Name:
Job title:
Supervisor:
Have you told your supervisor about this incident?
 Yes
 No
Date:
Time:
Names of witnesses (if any):
Where, exactly, did it happen?
What were you doing at the time?
Describe step by step what led up to the incident, illness or near miss. (continue on the back if necessary):
What could have been done to prevent this incident, illness or near miss from occurring?
What parts of your body were affected? If a near miss, how could you have been hurt?
 Yes
Have you seen a doctor about this incident before?
 No
If yes, whom did you see?
Doctor’s phone number:
Date:
Time:
 Yes
Has this part of your body been affected before?
If yes, when?
Supervisor:
Your signature:
Date:
54
 No
Incident Investigation Sample Report
Sample Form
Instructions: Complete this form as soon as possible after any incident that results in an injury or
illness. (Optional: Use to investigate a minor injury or near miss that could have resulted in a serious injury
or illness.)
WARNING: “WORKER’S COMPENSATION INSURANCE FRAUD IS A CRIME PUNISHABLE BY
LAW.”
This is a report of a:
 Death
Date of incident:
 Lost Time
 Dr. Visit Only
 First Aid Only
 Near Miss
This report is made by:  Supervisor  Investigation Team
 Other_________
Step 1: Injured employee (complete this part for each injured employee)
Name:
Department:
Sex:  Male  Female
Job title at time of incident:
Part of body affected: (shade all that apply)
Nature of injury: (most
serious one)
 Abrasion, scrapes
 Amputation
 Broken bone
 Bruise
 Burn (heat)
 Burn (chemical)
 Concussion (to the head)
Age:
This employee works:
 Regular full time
 Regular part time
 Seasonal
 Temporary
Months with
this employer:
Months doing
this job:
 Crushing Injury
 Cut, laceration, puncture
 Hernia
 Illness
 Sprain, strain
 Damage to a body system:
 Other ___________
Step 2: Describe the incident
Exact location of the incident:
Exact time:
55
What part of employee’s workday?
 During meal period
Names of witnesses (if any):
 Entering or leaving work
 During break
 Doing normal work activities
 Working overtime
Written witness statements:
Photographs:
Number of
attachments:
What personal protective equipment was being used (if any)?
 Other___________________
Maps / drawings:
Describe, step-by-step the events that led up to the injury. Include names of any machines, parts, objects, tools, materials
and other important details.
Description continued on attached sheets: 
Step 3: Why did the incident happen?
Unsafe workplace conditions: (Check all that apply)
Unsafe acts by people: (Check all that apply)
 Inadequate guard
 Operating without permission
 Unguarded hazard
 Operating at unsafe speed
 Safety device is defective
 Servicing equipment that has power to it
 Tool or equipment defective
 Making a safety device inoperative
 Workstation layout is hazardous
 Using defective equipment
 Unsafe lighting
 Using equipment in an unapproved way
 Unsafe ventilation
 Unsafe lifting
 Lack of needed personal protective equipment
 Taking an unsafe position or posture
 Lack of appropriate equipment / tools
 Distraction, teasing, horseplay
 Unsafe clothing
 Failure to wear personal protective equipment
 No training or insufficient training
 Failure to use the available equipment / tools
56
 Other: _____________________________
 Other: __________________________________
Why did the unsafe conditions exist?
Why did the unsafe acts occur?
Is there a reason that may have encouraged the unsafe conditions or acts?
 Yes  No
If yes, describe:
Were the unsafe acts or conditions reported prior to the incident?
 Yes  No
Have there been similar incidents or near misses prior to this one?
 Yes  No
Step 4: How can future incidents be prevented?
What changes do you suggest to prevent this incident/near miss from happening again?
 Stop this activity
 Guard the hazard
 Train the employee(s)
 Train the supervisor(s)
 Redesign task steps  Redesign work station  Write a new policy/rule
 Enforce existing policy
 Routinely inspect for the hazard
 Personal Protective Equipment  Other: ____________________
57
What should be (or has been) done to carry out the suggestion(s) checked above?
Description continued on attached sheets: 
See Attached Process Improvement Plan with corrective actions and accountability.
Step 5: Who completed and reviewed this form? (Please Print)
Written by:
Title:
Date:
Names of investigation team members:
Reviewed by:
Title:
Date:
58
Insert Business Name Here
INCIDENT INVESTIGATION – ROOT CAUSE and CORRECTIVE ACTION
SAFETY AND HEALTH PROCESS IMPROVEMENT PLAN (SPIP)
Date
Root Cause
Severity Ranking (1-3)
Corrective Action
Responsible
Person*
Planned
Completion
Date
Actual
Completion
Date
Process Change or
Procedure(s) to Ensure
Hazard does not recurb
Review
Date
Effective
Corrective
Action
(Y/N)
a- The root causes are ranked on a scale of 1-3 with:
1 (Significant)
Root causes that pose a significant threat to employee health or safety and/or
could pose severe regulatory action against the company. These will be
addressed immediately.
2 (Moderate)
Root causes that pose a moderate threat to employee health or safety and/or
moderate regulatory enforcement action.
3 (Limited)
Root causes that pose a limited threat to employee health or safety and/or
may lead to regulatory enforcement action.
b- Process changes and procedures will be evaluated for effectiveness by the Program Administrator, with management & employee involvement, to ensure the
corrective action(s) are working and there is a process in place to prevent recurrence. This evaluation will be performed within two (2) weeks of the actual
completion date listed on this form. Follow-up monthly observations will be made and documented.
* - Items given a severity rating of 1 will be assigned to the Program Administrator for completion. The Program Administrator, with cooperation of
the General Manager will be responsible for evaluating the effectiveness of the corrective actions and ensuring their completion.
59
SAFETY AND HEALTH
RECORDKEEPING
60
Injury and Illness Recording Criteria and Recordkeeping
These records provide information to help you measure and evaluate the success of your safety and health
activities.
Periodic reviews of your records will help monitor the success of your IIPP. Review the records to identify
where your injuries are occurring and in what numbers; look for patterns or repeat situations. These records
can help you identify hazardous areas in your workplace and pinpoint where immediate corrective action
is required.
Five important steps are required by the Cal/ OSHA recordkeeping system:
1. Each employer (unless exempt by size or industry) must record each fatality, injury, or illness
that is work-related, a new case, or meets one or more of the general recording criteria. As of
December 2104, the general recording criteria (Title 8, Section 14300.7) apply to workplace
injuries resulting in death; days away from work; restricted work or job transfer; medical
treatment beyond first aid; los of consciousness; or work-related injury of illness diagnosed by
a physician or other licensed health care professional).
2. Employers must also record cases in several additional categories, including (as of December
2014) cases involving cases of needlestick and sharps injury; medical removal; hearing loss;
tuberculosis; or musculoskeletal disorders.
3. Record each injury or illness on the Cal/ OSHA Log of Occupational Work Related Injuries
and Illnesses (Form 300) according to the instructions.
4. Prepare an Injury and Illness Incident Report (Form 301), or equivalent.
5. Annually review and certify the Cal/OSHA Form 300 and post the Summary of Work-Related
Injuries and Illnesses (Form 300A) no later than February 1 and keep it posted where employees
can see it until April 30.
6. Maintain the last five years of these records in your files.
NOTE: Additional information on recordkeeping can be found on the Internet at:
http//:www.californiaosha.info or www.dir.ca.gov/DOSH
Exposure Records
Injury and illness records may not be the only records you need to maintain. Cal-OSHA standards
concerning toxic substances and hazardous exposures require records of employee exposure to these
substances and sources, physical examination reports, employment records, and other information.
Employers using any regulated carcinogens have additional reporting and recordkeeping requirements. See
Title 8 of the California Code of Regulations for details.
61
Documentation of Your Activities
Essential records, including those legally required for workers’ compensation, insurance audits, and
government inspections, must be maintained for as long as required.
Essential records, including those legally required for workers' compensation, insurance audits, and
government inspections, must be maintained for as long as required. For most employers, Cal/OSHA
standards also require that you keep records of steps taken to establish and maintain your Injury and Illness
Prevention Program (IIPP). They must include:














Hazard Reports (or Reports of Unsafe Conditions or Hazards)
Safety Committee meeting documentation
Training records (database)
o Documentation of health and safety training for each employee shall include: (1)
employee name or other identifier, (2) training dates, (3) type(s) of training, and (4)
training providers. This documentation shall be maintained for at least one year.
Incident and Investigation Reports
Exposure Records
Inspections/Audits, including the persons conducting the inspection, any identified unsafe
conditions or work practices, and corrective actions.
Safety meetings (agendas, minutes, handouts)
Safety talks
Authorizations & Permits (e.g., Confined Space permits, Hot work permits, Biological Use
Authorization, Controlled Substance Use Authorization, Radiation Use Authorization, etc.)
Training records (rosters, tests, training materials)
The IIPP Plan Coordinator will retain all training documentation for one (1) year.
Training records of employees who have worked less than one year for the employer need
not be retained beyond the term of employment if they are provided to the employee upon
termination of employment.
Records of scheduled and periodic inspections as required by the standard to identify unsafe
conditions and work practices. The documentation must include the name of the person(s)
conducting the inspection, the unsafe conditions and work practices identified, and the action
taken to correct the unsafe conditions and work practices. The records are to be maintained
for at least one year. However, employers with fewer than 10 employees may elect to
maintain the inspection records only until the hazard is corrected.
Documentation of safety and health training is required for each employee. The
documentation must specifically include employee name or other identifier, training dates,
type(s) of training and the name of the training provider. These records must also be kept for
at least one year, except training records of employees who have worked for less than one
year. Records need not be retained beyond the term of employment if they are provided to
the employee upon termination of employment.
Also, employers with fewer than 10 employees can substantially comply with the documentation provision
by maintaining a log of instructions provided to the employee with respect to the hazards unique to the
employees’ job assignment when first hired or assigned new duties. Some relief from documentation is
available for employers with fewer than 20 employees who are working in industries that are on the
Department of Industrial Relations (DIR’s) designated list of low-hazard industries, and for employers with
fewer than 20 employees who are not on DlR’s list of high-hazard industries and who have a Workers’
Compensation Experience Modification Rate of 1.1 or less.
62
For these industries, written documentation of the Injury and Illness Prevention Program may be
limited to:
 Written documentation of the identity of the person or persons with authority and responsibility
for implementing the program;
 Written documentation of scheduled periodic inspections to identify unsafe conditions and
work practices; and
 Written documentation of training and instruction.
63
Guidelines for Recordkeeping
Sample Form No.
Records will be kept for all safety program activities that may include, but not limited to:

Training schedule for each employee

Initial orientation training

Job descriptions and / or job analysis

Safety Meetings

Safety Committee Meetings

Vehicle inspections forms

DMV driving records

CPR / First Aid training

Injury and Illness Investigations

Employee and employer claim forms

Cal/OSHA required records (Form 300, medical exposure records, and Form 301 injury reports)

Inspections performed, in-house, and any performed by outside agencies

Disciplinary actions
A copy of all the above records will be maintained and filed by
Name:
Location:
64
APPENDIX OF
HAZARD ASSESSMENT
COMPLIANCE PROGRAM INFORMATION
65
This section includes information on written compliance programs, requirements and sample forms
that can be utilized as a resource when developing your site-specific programs based on the results of
you individual hazard assessments. This appendix includes many of the more common compliance
programs typically required for the hotel and lodging industry, but it is not all inclusive. Always check
with local regulations and authorities when developing your specific programs/policies to ensure they
are compliant with safety and health regulations and the most protective of property and the
environment.
66
Emergency Action and Fire Protection Plan
All employers are required to have an emergency action plan to advise of what to do in the event of an
emergency. Every employer must also have a fire protection plan which describes how fire safety is
achieved at the employer’s facilities.
It should be noted in this regard that regulations adopted by the California State Fire Marshal establish very
specific requirements regarding, among other things, notifying guests of emergency procedures,
establishing fire safety plans for hotels, and conducting fire safety training. This regulation applies
independently of the Cal-OSHA requirement for all employers to establish “emergency action and fire
protection plans,” although the two “plans” should obviously be coordinated and harmonized. In any event,
both regulations must be complied with. The discussion below relates solely to the Cal-OSHA requirement.
The following information at a minimum should be provided by the property:
 Emergency escape routes and procedures for evacuation.
 Procedures for employees who must remain to operate critical equipment before they can evacuate
the facility.
 Procedures to account for all employees following the evacuation.
 Procedures for employees who are assigned to rescue and potentially perform medical duties.
 Means of reporting fires and other types of emergencies.
 Names or job titles of people who must be contacted about the emergency action plan.
 Implementation and testing of an emergency alarm system(s) and emergency response equipment
(ex. fire extinguishers, sprinkler systems, emergency lighting and exits, etc.).
 Types of evacuation and evacuation routes to be used in an emergency.
 Specific procedures for employees and visitors with disabilities in the event of an emergency.
 Employee and management training and retention of documentation for recordkeeping.
How to Plan for Workplace Emergencies and Evacuations – things to consider for your plan:
Fire Protection






Potential fire hazards and proper procedures for handling and storing flammable and combustible
materials. Potential ignition sources and procedures for controlling them. A description of the type
of fire protection, equipment or systems that can control a fire.
Names or regular job titles of those responsible for controlling flammable or combustible materials.
Housekeeping actions to control accumulations of flammable and combustible material and
processes to which the employees are exposed and reviewing with each employee upon initial
assignment those parts of the fire prevention plan that the employees must know to protect
themselves in an emergency.
Maintenance that must be conducted regularly and properly, according to established procedures
on equipment and systems installed in the workplace to prevent or control ignition of combustible
materials.
Testing of alarms and fire protection systems and equipment to ensure they are properly operating
and/or available in the event of an emergency.
Audible and visual testing of alarms for both evacuation and non-evacuation (ex. tornados)
emergencies to ensure they are properly operating.
67
Tornado (non-evacuation emergency)






Where are the safe assembly areas within our business:
o Evaluate and readily identify safe assembly areas (usually interior rooms with no windows
on lower levels)
o Identify them on your emergency plans and maps
Develop written procedures and post accordingly
Determine how employees and visitors will be notified of these emergencies and test the
notification system
Develop procedures for employee and visitor accountability and emergency response by
employees/management and local authorities
Effectively train employees/management on these procedures and conduct periodic drills
Maintain appropriate documentation
Also consider and include procedures for emergencies specific to your properties location such as:
flood, earthquake, bomb threat, electrical power outage, or active shooter. As previously noted, this should
be coordinated with the fire safety plan developed by the innkeeper pursuant to the State Fire Marshal’s
regulation.
68
Hazard Communication Standard
The Cal-OSHA Hazard Communication Standard is a regulation issued by federal and state
Occupational Safety and Health Administrations to assure that employees are advised of the identity
and potential hazards of chemical substances they work with and may be exposed to. This standard requires
employers to establish a formal written program to provide chemical hazard information and training to
employees.
The purpose of this program is to ensure Associates and Management know about hazards and how to
protect themselves and should help to reduce the incidence of chemical exposures, illness and
potential injuries. It is important to mention that no employee will be discharged or otherwise discriminated
against for exercising his/her rights afforded by this program.
Sweeping changes were made in March 2012 to revise the Hazard Communication Standards to
conform with the United Nations Globally Harmonized System of Classification and Labeling of
Chemicals.
Your specific Written Hazard Communication Program must include the below information:






Developing and maintaining an accurate/current chemical inventory
Using proper labels for chemicals (primary and secondary)
Hazard Communication Standard Labels (English: PDF ) (Spanish: PDF ) obtained from the
Cal-OSHA website
Providing access to Safety Data Sheets (SDS) - SDS provide information on physical and health
hazards and safe handling procedures.
o Hazard
Communication
Safety
Data
Sheets
(English: HTML PDF )
(Spanish: HTML PDF )
Exchanging information with other contractors and the customer
Training employees on how to read the SDS, how to safely handle hazardous substances, and the
employees’ right to information on chemical hazards.
o Hazard Communication Standard Pictogram QuickCard (English: PDF) (Spanish: PDF)
obtained from the Cal-OSHA website
Employee’s Rights under the Standard




To be adequately trained and made aware of the chemical hazards in their workplace
To inspect SDS on products and substances that they may be potentially exposed. Management
is required to provide the SDS in a timely manner for review
To request SDS which are not available from the manufacturer/supplier.
o The property is required to request such SDS from the supplier in writing within seven (7)
working days, and the supplier must provide the SDS within 21 working days of receipt of
the employers’ request.
The property is required to have a system for maintaining SDSs for all current hazardous
chemicals/products they have in the workplace.
Compliance with the Hazard Communication Standard
Many hotels will already have a written Hazard Communication Program in place since this standard
has been required since the mid-1980s. This program must be in writing and the employer must be
able to document compliance.
69
Those properties which have not established a written Hazard Communication Program can do so
by complying with the elements discussed above and utilizing the resources available on the CalOSHA website.
Of particular importance will be:
 Performing a hazardous chemical/product inventory
 Requesting current SDSs from the manufacturer/supplier
 Developing a system for maintaining these documents so they are readily available for review
and to be provided to medical personnel in the event of an emergency or exposure
o SDSs must be available 24/7 so an electronic and written (hard-copy) system is usually the
most effective. There are various companies that provide an on-line SDS database and are
very efficient at providing them.
 Properly labeling all containers
 Periodically auditing your program
 Properly training your employees on the written program and standard.
70
Ergonomics and Back Injury Prevention
Ergonomics
A sound IIPP promotes fluid, efficient work operations. Too often, however, an IIPP overlooks the
relationship of ergonomics and employee job performance. Incorporating a good ergonomics program will
help maintain a higher level of production and efficiency, a reduced incident/injury rate, reduced worker’s
compensation claims and costs and increased employee perception.
Identifying ergonomically-related injuries is often difficult because the effects of such injuries develop over
time. Repetitive motions and postures will accrue muscle and ligament strain if carried on long enough.
Operations as simple as changing table or desk height, or buying proper tools can mitigate problems.
The Cal/OSHA standard (GISO 5110, Repetitive Motion Injuries) became effective on July 3, 1997.
This regulation states that if two or more workers performing the same tasks have had diagnosed repetitive
motion injuries (RMIs) in your workplace within the past 12 months, you must implement
the three-step ergonomics program prescribed in the standard.
The program consists of
1) Conducting a worksite evaluation for exposures causing RMIs;
2) Taking steps to control exposures that have caused RMIs; and
3) Implementing a training program that explains what RMIs are and the steps you are taking
to control them.
Back Injury Prevention
Although back injury prevention is not a specific Cal-OSHA standard, if the employer recognizes
the potential for back injuries due to lifting/lowering and other materials handling tasks, or has determined,
based on a review of the Injury and Illness Log, that such injuries are occurring, it must establish a back
injury prevention program.
A good back injury prevention program will help alleviate the problems associated with back injuries
that can result in reduced productivity due to lost work time or light duty tasks, depending on the type
of injury. The back injury program must include certain elements to be effective and, at the same
time, continually be reinforced by management to endure that employees are using the techniques outlined
in the program.
Some sample procedures for employee training to reduce ergonomic injuries are included:
71
LIFTING & MANUAL MATERIAL HANDLING
Sample Policy
Policy:
A majority of work related complaints and accidents involving the back are a result of
improper lifting techniques and attempting to lift heavy objects. Proper lifting techniques
shall be trained, followed and enforced.
Procedure:
1. When attempting to lift an object without a weight indicator label employee shall:
a. Inspect the object looking for a visual indication of the objects weight.
Approach the object with feet approximately shoulder width apart. Squat
down trying to keep the object between the knees and as close to the body
as possible. Grab the object at opposite corners and use your legs, not your
back, to test the weight of the object. If the object is inside a container,
cardboard box, etc. visually inspect the container for defects or damage
and ensure the bottom is supported at all times to prevent it from breaking
through the bottom and landing on your feet or contacting your legs. If
the container has defects or is damaged, do not attempt to lift the object
until the container has been adequately supported or fixed and/or a lifting
device has been obtained (hand truck, etc.).
b. If the employee is capable of safely lifting the object, without straining,
then complete the lift using the legs and keeping the object as close to the
torso as possible. Minimize twisting by lifting the object in an upward
motion and then turning the entire body by moving the feet.
c. If the employee tests the weight of the object and determines the object is
too heavy, or awkwardly shaped, the employee shall get assistance or
utilize a lifting device (hand truck, etc.) to safely move the object. When
two or more employees assist in the lift, proper lifting techniques shall be
used.
2. When attempting to lift an object with a weight indicator label employee shall:
a. Read the label and any other instructions or warnings.
b. If the object's weight is less than 75 pounds, still test the weight of the
object and visually inspect the container or packaging. The weight may
be mislabeled. Assistance may still be necessary to safely lift the object.
c. Follow the above procedure for testing the object's weight and for proper
lifting techniques.
d. If the weight is clearly labeled as 75 pounds or more, do not attempt to lift
the object by yourself. Obtain assistance from another employee or lifting
device.
72
3. Some Words of Wisdom:
a. Don't fall - use a ladder, portable stairs, not a chair, if the object is above
the shoulders.
b. Don't store heavy objects above knee height off the ground.
c. Avoid lifting objects that are high above and/or away from the body.
d. Don't try to pull objects from shelves unless the weight is known and
proper precautions have been implemented to ease the lift.
e. Don't try to catch a falling object. The weight may be unknown.
f. Don't lift too much weight.
g. Don't lift and twist at the same time; turn your feet.
h. Lift how it feels comfortable. If it is not comfortable seek assistance.
73
Blood borne Pathogens
Sample Policy
It is the responsibility of the employer to perform a hazard assessment and determine if their employees
have reasonably anticipated “occupational exposure” to “potentially infectious materials” as defined by
OSHA. A written blood borne pathogens Exposure Control Plan must be developed and implemented if
there is any employee with reasonably anticipated occupational exposure to blood or other potentially
infectious material due to the employee’s assigned duties. Additionally, employers with occupationally
exposed employees must provide special training and have additional responsibilities under the regulation.
Occupational exposure – means reasonably anticipated skin, eye, mucous membrane, or parenteral contact
with blood or other potentially infectious materials that may result from the performance of an employee’s
duties.
If your hazard assessment determines an occupational exposure exists then utilize this document as a guide
to develop a site-specific written program. If your hazard assessment determines an occupational exposure
exists then utilize this document as a guide to develop a site-specific written program. Exposure Control
Plans will likely be necessary in most cases, because hazard assessments at CH&LA members’ facilities will
reveal at least some instances where employees have reasonably anticipated occupational exposure. For
instance, management staff or other employees trained to respond to emergencies at the property will
likely have “occupational exposure,” because contact is reasonably anticipated in the employee’s job (i.e.
responding to an injury that involves bleeding). On the other hand, employees are not occupationally
exposed merely because they might possibly have contact. For instance, while it possible that members of
the housekeeping staff may come into contact with blood or potentially infectious materials, that
possibility of exposure (or even actual exposure) is very remote and does not necessarily make them
occupationally exposed under the regulation. Managers must understand the details of their employees’
work tasks so that hazard assessments accurately identify employees’ whose job tasks result in
“reasonably anticipated” exposure.
Purpose: The purpose of the Blood borne Pathogen Exposure Control Plan is to eliminate or minimize the
possibility that an occupationally exposure employee will be exposed to pathogens that can be transmitted
via blood and other bodily fluids (potentially infectious materials), such as human immune-deficiency virus
(HIV) or hepatitis B virus (HBV). Of course, employers should also maintain a safe work site that also
minimizes the possibility for any contact by non-occupationally exposed employees.
For
instance,associates should always practice Universal Precautions for infection control. According to the
concept of Universal Precautions, all human blood and certain human bodily fluids are treated as if known
to be infectious for HIV, HBV, and other blood borne pathogens.
Responsibility: It is the responsibility of Department Managers and Supervisors, particularly in the
areas of Housekeeping and Laundry, to ensure that all Associates comply with the provisions of your
specific plan. It is the responsibility of “the hotel”’ Safety Coordinator and the general manger of
each business, to ensure that Associates with potential occupational exposure are trained and provided
the appropriate personal protective equipment.
These are example policies for consideration in your written program (Reference the attached written
program):
Housekeeping: Even without occupational exposure, contact with blood or other potentially infectious
materials can occur in guest rooms, specifically from contact with bed coverings, bathroom sinks, counter
areas, toilets and tubs, towels and trash bins. When housekeeping associates notice blood, other bodily
74
fluids, or needles/sharps in these areas, the Associate must exercise Universal Precautions and use the
following precautions and cleaning procedures:
A. Use the appropriate personal protective equipment provided, such as gloves, goggles and
aprons, to avoid bodily contact with the noted fluids.
B. Place all contaminated items in the provided biohazard bags, or containers.
C. Inspect and decontaminate all bins and pails that may have become contaminated.
D. Inspect and decontaminate all surfaces and areas where the bodily fluids were found, using a
10% (minimum) solution of chlorine bleach, Lysol, or other EPA-registered disinfectants. The
solution used must be left in contact with the contaminated surface for at least 10 minutes
before cleaning.
E. Transport the disposal bag or container to the designated removal area.
F. Once the areas have been cleaned and disinfected, the Associate should remove their goggles,
gloves, aprons and other personal protective equipment and place it in the biohazard bag for proper
disposal.
G. Transport the disposal bag or container to the designated removal area.
75
Broken glassware, needles and other sharps will not be picked up directly with the hands. Sweep or
brush the debris, or materials, into a dustpan. Dispose of in an approved sharps container.
Laundry: Contact with blood or other bodily fluids can occur when laundry Associates move, sort
and clean bed coverings and other garments and items. When laundry associates notice blood, other bodily
fluids, needles and/or other sharps in these areas, the Associate must follow the following precautions and
cleaning procedures:
A. Use the appropriate personal protective equipment provided, such as gloves, goggles and
aprons, to avoid bodily contact with the noted fluids.
B. Contaminated laundry must be handled as little as possible with a minimum of agitation.
C. Bag or containerize contaminated laundry at the location where it was used.
D. Place and transport contaminated laundry in the appropriate bags or containers provided.
E. Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through or
leakage from the bag or containers, the laundry must be placed and transported in bags or containers
that prevent leakage, or soak-through.
F. Transport the disposal bag or container to the designated removal area.
G. Employees wash their hands immediately, or as soon as feasible, after removal of potentially
contaminated gloves or other personal protective equipment.
If there is NOT an occupational exposure to blood borne pathogens the following may be used to train
employees and develop a written policy/procedure.
76
BLOOD BORNE PATHOGENS AWARENESS
Policy:
There are no Insert Name Here employees that have a "reasonable potential for occupational
exposure" to Blood borne Pathogens during their assigned or required work activities.
Procedure:
1.
2.
3.
4.
Although Insert Name Here is not required to have a Blood borne Pathogen Program, all
blood and bodily fluids shall be treated as potentially infectious.
Employees are not required to administer first aid nor clean up biological spills. There are
no job functions or positions where occupational exposure is expected.
All First Aid and CPR is performed as a “Good Samaritan” and not on behalf of the
company. Employees trained in First Aid and CPR will follow the written program
and receive the proper training (Attached).
Annual awareness level training will be provided to employees to ensure they are
aware of potential hazards and proper response action steps in the vent they encounter
potentially infectious materials in the work place.
BIOLOGICAL HAZARDS / BLOOD BORNE PATHOGENS AWARENESS TRAINING
This Blood borne Pathogen Awareness contact is designed to protect workers who do not have a reasonable
potential for occupational exposure and are not required to be included in a Blood borne Pathogen program from
contracting disease through direct contact with potentially infectious materials.
DO NOT ATTEMPT TO TOUCH OR CLEAN-UP THE FOLLOWING POTENTIALLY INFECTIOUS
MATERIALS:
 HUMAN BLOOD;
 NEEDLES AND SYRINGES;
 ANY BODILY FLUID MIXED WITH VISIBLE BLOOD; OR
 ANY MATERIAL IN QUESTION.
IF YOU ENCOUNTER ANY OF THE ABOVE, OR HAVE QUESTIONS, CONTACT YOUR SUPERVISOR
OR PROGRAM ADMINISTRATOR IMMEDIATELY.
Only trained and properly equipped personnel are permitted to clean up human blood and other body fluids
contaminated with blood. Under no circumstances shall untrained employees become involved in these types of
activities.
Universal Precautions is defined as a protocol for infection control that treats, “all human blood and certain
human body fluids are treated as if known to be infectious for hepatitis B virus (HBV), hepatitis C (HCV) human
immunodeficiency virus (HIV), and other blood borne pathogens." Universal Precautions involves the use of
protective barriers such as gloves, gowns, aprons, masks, or protective eyewear to reduce the risk of exposure to
potentially infective materials. Precautions shall be observed to prevent contact with blood or other potentially
infectious materials. Under circumstances in which differentiation between body fluid types is difficult or impossible,
all body fluids shall be considered potentially infectious materials.
The following methods of compliance should be observed:
•
•
•
•
•
Contact trained personnel (Client trained emergency response employees) when blood or body fluids
with visible blood must be cleaned or addressed.
If an accidental exposure occurs, the incident shall be treated as any other injury and the effected
employee will be sent for a medical evaluation.
Treat all blood and body fluids with visible blood as if they are known to be infectious with HBV, HCV
or HIV.
Use appropriate personal protective equipment (PPE) as required including gloves, face masks, eye
shields, protective gowns, disposable resuscitation devices, etc.
Efficient hand washing is the single most effective practice to prevent the spread of infection.
77
•
If your hazard assessment determines there IS an occupational exposure to blood borne pathogens
the following may be used to train employees and develop a written policy/procedure.
Methods of Compliance for Blood borne Pathogen Exposure Control Plan (ECP)
Universal Precautions
Insert Name Here has implemented the use of Blood borne Pathogen Awareness and Universal
Precautions. As a result, we treat all human blood and body fluids as if they are known to be
infectious for HBV, HIV or OPIM. In situations where it is difficult or impossible to differentiate
between body fluid types, we assume all body fluids to be potentially infectious.
Engineering Controls
One of the key aspects to our ECP is the use of Engineering Controls to eliminate or minimize
employee exposure to blood borne pathogens. As a result, employees use cleaning and other
protective equipment that is designed to prevent contact with blood or other potentially infectious
materials.
In any instance where proper engineering controls could be implemented to eliminate or minimize
employee exposure to blood borne pathogens, the Program Administrator shall evaluate such
controls prior to their implementation.
Employees who may have occupational exposure are provided with readily accessible hand
washing facilities that furnish soap and water and are required to wash exposed skin as soon as
possible after gloves are removed. If hand washing facilities are not available at a client’s location,
employees will have available suitable alcohol wipes and disinfecting cleansers to properly
disinfect hands, equipment and other materials.
Work Practice Controls
In addition to Engineering Controls, Insert Name Here uses numerous Work Practice Controls to
help eliminate or minimize employee exposure to blood borne pathogens. Insert Name Here has
adopted the following Work Practice Controls as part of our Blood borne Pathogens Compliance
Program:



Employees wash their hands immediately, or as soon as feasible, after removal of potentially
contaminated gloves or other personal protective equipment.
Following any contact of body areas with blood or other potentially infectious materials,
employees wash their hands and any other exposed skin with soap and water as soon as
possible. They also flush exposed mucous membranes with copious amounts of fresh water.
Eating, drinking, smoking, applying cosmetics or lip balm, or handling contact lenses is strictly
prohibited in work areas where there is a potential for exposure to blood borne pathogens.
78

Equipment that becomes contaminated is examined prior to servicing or shipping, and
decontaminated as necessary (unless it can be demonstrated that decontamination is not
feasible). An appropriate biohazard warning label is attached to any contaminated equipment,
identifying the contaminated portions. Information regarding the remaining contamination is
conveyed to all affected employees, the equipment manufacturer and / or the equipmentservicing representative prior to handling, servicing or shipping.
Personal Protective Equipment (PPE)
Personal Protective Equipment is our employee’s “last line of defense” against blood borne
pathogens. Insert Name Here provides (at no cost to the employee) the PPE that they need to
protect themselves against such exposure. This equipment includes, but is not limited to:







Gloves (Hypoallergenic gloves, gloveliners, or similar alternatives are readily accessible to
employees who are allergic to the gloves this facility normally provides)
Safety glasses
Face shields / masks
Goggles
Respirators
CPR mouthpieces / masks / shields
Aprons
Supervisors are responsible for ensuring that all employees have appropriate PPE available when
necessary. The Program Administrator is responsible for approving PPE before use. Employees
are not allowed to purchase their own PPE or use PPE brought from home. Only approved,
Insert Name Here purchased, PPE will be used.
Insert Name Here employees are trained regarding the use of appropriate PPE for responding to
perform First Aid or CPR. Initial training about PPE is completed when the employee becomes
certified in First Aid and CPR. Refresher training is provided annually. Additional training is
provided when an employee is observed not following the parameters of this program. Initial and
refresher training is provided by the Program Administrator.
To ensure that PPE is not contaminated and is in the appropriate condition to protect employees
from potential exposure, Insert Name Here adheres to the following practices:




First Aid and CPR trained/certified employees are responsible for maintaining their own PPE
in the event they choose to perform “Good Samaritan” First Aid or CPR. Replacement PPE is
available.
All PPE is inspected periodically by Management and repaired or replaced as needed to
maintain its effectiveness. PPE is inspected by the employee before each use.
Reusable PPE is cleaned, laundered, and / or decontaminated as needed.
Single-use PPE (or equipment that cannot, for whatever reason, be decontaminated) is disposed
of in accordance with all applicable regulations.
79
To ensure that this equipment is used as effectively as possible, Insert Name Here employees
adhere to the following practices when using their PPE:






Any garments penetrated by blood or other potentially infectious materials are removed
immediately, or as soon as feasible.
All potentially contaminated PPE is removed prior to leaving the work area.
Gloves are worn in the following circumstances:
(1) Whenever employees anticipate hand contact with human blood, human body fluids, or
any other potentially infectious materials.
(2) When handling or touching contaminated items or surfaces.
Disposable gloves are replaced as soon as practicable after contamination or if they are torn,
punctured or otherwise lose their ability to function as an “exposure barrier.”
Masks and eye protection (such as goggles, face shields, etc.) are used whenever splashes or
sprays may generate droplets of potentially infectious materials.
Protective clothing (such as coats, aprons, etc.) is worn whenever potential exposure to the
body can be reasonably anticipated.
In case of an unusual circumstance where temporary failure to use PPE is justified and / or has not
been utilized, the Program Administrator will conduct an investigation of these unusual
circumstances and all findings will be documented.
Housekeeping
Housekeeping will be scheduled in such a manner as to maintain clean and sanitary conditions.
Any surface areas that may have become contaminated with blood, body tissues or bodily fluids
will be cleaned immediately using a disinfectant cleaning solution. This disinfectant cleaning
solution shall be made up of one (1) part sodium hypochlorite (bleach) to ten (10) parts fresh water.
This solution is NOT to be pre-mixed, and will be used within one hour after mixing. All employees
involved in the decontamination of surfaces will wear impermeable gloves. Other PPE will be
worn as necessary as each situation dictates to prevent contaminated fluids from coming into
contact with employee’s skin or clothing.
Generated Waste
Insert Name Here employees are very careful in the handling of regulated waste (including used
bandages, feminine hygiene products, and other potentially infectious materials). The following
procedures shall be used with all of these types of wastes:



They are discarded or “bagged” in containers that are:
 Closeable.
 Puncture-resistant if the discarded materials have the potential to penetrate the container.
 Leak-proof if the potential for fluid spill or leakage exists.
 Red in color or labeled with the appropriate biohazard warning label.
Containers for this regulated waste are collected as close as possible to the potential source of
the waste.
Waste containers are maintained in an upright position, routinely replaced, and are not
permitted to be overfilled.
80


Whenever employees move containers of regulated waste from one area to another, the
containers are immediately closed and placed inside an appropriate secondary container if
leakage is possible from the first container.
Contaminated waste containers are properly disposed of by incineration, or by other
appropriate means. NOTE: It is illegal to dispose of contaminated waste in the same manner
as regular waste.
Hepatitis B Vaccination, Post-Exposure Evaluation and Follow-Up
All Insert Name Here employees recognize that following these exposure prevention practices, first aid
incidents involving the presence of blood or OPIM can occur. As a result, we have implemented a
Post-Incident Hepatitis B Vaccination Program, as well as procedures for post-exposure evaluation and
follow-up should exposure to blood borne pathogens occur.
Hepatitis B Vaccination Program
To protect our employees as much as possible from the possibility of Hepatitis B infection, Insert Name
Here has implemented a Hepatitis B Vaccination Program. This program is available, at no cost, to
any unvaccinated trained and certified employee that performs “Good Samaritan” First Aid
or CPR who has rendered assistance in any situation involving the presence of blood or OPIM.
The vaccination program consists of a series of three (3) inoculations given over a six-month period.
As part of their blood borne pathogens training, our employees have received information regarding
Hepatitis B vaccinations, including its safety and effectiveness. Vaccinations are performed under
the supervision of a licensed physician or other licensed healthcare provider.
Employees who have taken part in the vaccination program have a completed HBV Vaccination Record
Form in their medical file. Employees who have declined to take part in the program have a signed
copy of the Declination Statement Form in their medical file. Samples of these forms can be found in
this Plan.
To ensure that all employees are aware of our vaccination program, it is thoroughly discussed with
all employees during our Blood borne Pathogens training.
If any unvaccinated first-aid provider has rendered assistance in any situation involving the
presence of blood or OPIM, the full Hepatitis B vaccination series is made available to the employee
through a company-selected physician, clinic, hospital or other appropriate healthcare facility. The
vaccination series will commence no later than 24 hours after the exposure incident occurs.
Post-Exposure Evaluation & Follow-Up
Whenever an Exposure Incident occurs, certain precautions must be taken as soon as possible to
protect the employee. NOTE: An Exposure Incident is defined as: A specific eye, mouth or other
mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious
materials that results from the performance of an employee’s duties.
81
The following procedures must be performed as expediently as possible:


The employee will immediately report the incident to their Supervisor and the Program
Administrator.
A complete summary of the incident is to be recorded by the employee’s immediate supervisor
on an Incident Report Form.
The exposed employee will immediately receive a confidential medical evaluation and follow-up,
including at least the following elements:
a) Documentation of the route of exposure, and the circumstances under which the
exposure incident occurred. If the incident involved percutaneous injury from a
contaminated sharp, appropriate information should be entered in the sharps injury log and
the OSHA 300 Log;
b) Identification and documentation of the source individual, unless it can be established that
identification is infeasible or prohibited by state or local law;
c) The source individual’s blood shall be tested as soon as feasible, and after consent is
obtained, in order to determine HBV and HIV infectivity. If consent is not obtained, the
Program Administrator shall establish that legally required consent cannot be obtained.
When the source individual’s consent is not required by law, the blood (if available) shall
be tested and the results documented.
d) When the source individual is already known to be infected with HBV or HIV, testing
for the source individual’s HBV/HIV status need not be repeated.
e) Results of the source individual’s testing shall be made available to the exposed employee,
and the employee shall be informed of applicable laws and regulations concerning
disclosure of the identity and infectious status of the source individual.
Collection and testing of blood for HBV and HIV serological status will comply with the following:
 The exposed employee’s blood shall be collected as soon as feasible and tested after
consent is obtained;
 The employee will be offered the option of having her/his blood collected for testing
of the employee’s HIV serological status. The blood sample will be preserved for up
to 90 days to allow the employee to decide if the blood should be tested for HIV status.
The following information and applicable forms will be forwarded to the Health Care Professional
evaluating the employee:






A copy of the Federal regulation (29 CFR 1910.1030);
A description of the exposed employee’s duties as it relates to his / her exposure;
The circumstances under which the exposure occurred (Incident Report);
Results of the source individual’s blood testing, if available;
All medical records concerning the employee, including HBV vaccination records; and
The Hepatitis B Vaccination Declination Form (if applicable).
A “Post Exposure Evaluation” shall be requested from the Health Care Professional serving the
exposed employee. A form letter has been included in this Plan for the purpose of communicating
with the HCP.
82
The employee shall be provided with a copy of the HCP’s written evaluation within 15 days of the
exposure. Insert Name Here will require the HCP to complete a memo entitled “Physician PostExposure Written Evaluation.” This form has been included in this Plan.
The following information is to be maintained in the employee’s confidential medical record:




Name and Social Security Number,
Copy of the HBV vaccination record, or reason(s) vaccine was not given,
Report of exposure test results and evaluation as provided by the Health Care Professional,
A copy of the information that was forwarded to the HCP.
The employee’s confidential medical information shall not be released within or outside of the
workplace without the employee’s written consent, except as required by law and according to the
OSHA access to medical records requirements.
This information shall be kept on file at Insert Name Here office for the duration of the individual’s
employment. Once the employee/employer has terminated employment, these records must be
maintained for at least 30 years. All records concerning an employee’s exposure shall be kept
confidential, except as required by law.
Recordkeeping
Though covered in other sections of this Plan, the following is the complete requirement for
recordkeeping as outlined by OSHA’s Blood borne Pathogens Standard 29 CFR 1910.1030 and 29
CFR 1910.1020(h):
1. A medical file shall be maintained for each employee with possible occupational exposure and
/ or an exposure incident. The file shall be kept as confidential as released only with the
employee’s written permission, or as required by law. The medical records shall be maintained
for 30 years after the employee’s termination from employment. Transfer of records will be in
compliance with 29 CFR 1910.1020(h). This file shall include, but is not limited to:






The Name and Social Security Number of the employee,
A copy of the HBV vaccination status, including dates of all inoculations,
And medical records relative to the employee’s ability to receive the vaccinations,
A copy of all results of examinations, medical testing, and follow-up,
Pekron copy of the “Health care Professional’s Written Opinion” following an evaluation
of exposure,
A copy of all information forwarded to a Health Care Professional for us in making a postexposure evaluation.
83
2. Training records for employees with possible occupational exposure will be maintained for
three (3) years from the date the training occurred and will contain the following:




The date(s) of the training session(s),
The contents of the training session,
The name(s) and qualifications of the person(s) conducting the training,
The name of all persons attending the training sessions.
3. A Sharps Injury Log will be maintained for the recording of cases that involve percutaneous
injury from contaminated sharps. Information is entered on the log to protect the
confidentiality of the employee. The log is required in addition to completing the OSHA 300
Log.
Declination Statement
The employee who chooses not to accept the vaccine must sign the following statement of
declination of the Hepatitis B vaccination. The statement can only be signed by the employee
following the Post-Exposure Evaluation and consultation with the Health Care Professional
regarding the following information concerning the Hepatitis B Vaccination:




The efficiency and effectiveness,
Method of administration
Benefits of vaccination, and
The fact that the vaccine and vaccination are provided free of charge to the employee.
This statement is NOT a waiver. Employees can request and receive the Hepatitis B vaccination
at a later date if they remain occupationally at risk for exposure. The vaccination will be provided
if requested at the later date.
Communication of Hazards
Labels
Warning labels will be affixed to containers of regulated waste containing blood or
OPIM. The universal biohazard symbol will be used.
Information and Training
All employees trained in First Aid and CPR and with potential exposure to BBP as
identified in this program will receive initial training, additional training within 1 year of
the initial and annual refresher training thereafter. This training is provided at no cost to
the employee and during work hours. Employees will have access to this written program
by request from the Program Administrator. Training topics include the following:
a) A copy of the standard and an explanation of its contents;
b) A discussion of the epidemiology and symptoms of blood borne diseases;
c) An explanation of the modes of transmission of blood borne pathogens;
84
d) An explanation of Insert Name Here blood borne pathogens Exposure Control Plan (this
program), and the method for obtaining a copy;
e) The recognition of tasks that may involve exposure;
f) An explanation of the use and limitations of methods to reduce exposure, such as
engineering controls, work practices, and personal protective equipment (PPE);
g) Information on the types, use, location, removal, handling, decontamination, and disposal
of PPE;
h) An explanation of the basis of selection of PPE;
i) Information on the Hepatitis B vaccination, including efficacy, safety, method of
administration, benefits, and that it will be offered free of charge;
j) Information on the appropriate actions to take and persons to contact in case of an
emergency involving blood or OPIM;
k) An explanation of the procedures to follow if an exposure incident occurs, including the
method of reporting and medical follow-up;
l) Information on the evaluation and follow-up required after an employee exposure incident,
particularly incidents which involve needle-sticks or contaminated sharps; and
m) An explanation of the signs, labels, and color-coding system used to identify biohazards,
regulated waste, and other potential BBP hazards.
85
Blood borne Pathogens
Training Record
Date: ______/______/______
Trainer:_________________________________
Name
NAME OF EMPLOYEE
_________________________
Title
JOB POSITION
86
EMPLOYEE SIGNATURE
Job Positions with Potential Exposure to Blood borne Pathogens
JOB CLASSIFICATIONS IN WHICH EMPLOYEES MAY HAVE POTENTIAL EXPOSURE TO
BLOOD BORNE PATHOGENS
JOB POSITION
DUTIES
List job positions that have occupational exposure to potentially infectious materials as part of their job
duties.
87
Work Activities Involving Potential Exposure to Blood borne Pathogens
Below are listed the tasks and procedures in which employees may come into contact with human blood or
other potentially infectious materials, which may result in an exposure to blood borne pathogens:
TASK / PROCEDURE
JOB POSITIONS
Insert Tasks/Procedures and Job Positions that perform these
duties in this table.
88
HBV Vaccination Declination Statement
Date:
______/______/______
Employee Name:
__________________________________________
Employee ID#: __________________________________________
(Social Security Number)
I understand that, due to the chance of exposure to blood or other potentially infectious materials while
performing First Aid and CPR and related voluntary tasks, I may be at risk of acquiring the Hepatitis B
Virus (HBV) infection. I have been given the opportunity to be vaccinated with the Hepatitis B vaccine at
no charge to me. However, I decline to be immunized with the Hepatitis B vaccine at this time.
I understand that by declining this vaccine I continue to be at risk of acquiring the Hepatitis B virus, a
serious disease. If, in the future, I continue to have occupational exposure to blood or other potentially
infectious materials and I want to be vaccinated with the Hepatitis B vaccine, I can receive the vaccination
series at no charge to me.
Employee Signature
Program Administrator Signature
Program Administrator Name (Printed)
89
HBV Vaccination Record
Employee Name:
___________________________________________
Employee SSN: ___________________________________________
HBV vaccination information provided?
 YES
 NO
Declination Statement signed?
 YES
 NO
Pregnancy or other medical information release?  YES
 NO
Vaccination Administration:
DATE
COMMENTS
1st Injection:
_____/_____/_____
_______________________
2nd Injection:
_____/_____/_____
_______________________
3rd Injection:
_____/_____/_____
_______________________
Health Care Professional:
Facility Name:
HCP in Charge:
Address:
City, State, ZIP
Phone Number:
90
Post-Exposure Evaluation
Dear Dr. ____________________________:
____________________________________, an employee of Insert Name Here, has been referred to you
for a Post-Exposure Evaluation as required by 29CFR1910.1030, OSHA’s Blood borne Pathogens standard,
following an exposure to blood and / or other potentially infectious materials at our facility. The costs of
your services are the sole responsibility of Insert Name Here. The following information must be obtained
and services provided as part of this evaluation:
1)
2)
3)
4)
5)
6)
Circumstances surrounding the exposure
The HBV and HIV exposure possibility based upon source individual’s blood
An evaluation of the employee’s blood HBV and HIV status
Any additional medical testing as deemed medically necessary
Post-exposure prophylaxis as recommended by the U.S. Public Health Service
Counseling and evaluation of reported illness.
All information collected by Insert Name Here which may be able to assist you in your evaluation is
attached for your review.
In accordance with the applicable OSHA standards, a copy of your written evaluation and follow-up
treatment must be provided to the employee within 15 days of exposure. Please forward a copy of your
written evaluation, along with copies of the attached “Physician Post-Exposure Written Opinion,”
“Declination Statement,” and “HBV Vaccination Record” in the enclosed envelope marked
“CONFIDENTIAL.” We are required to maintain the information in the employee’s confidential medical
file.
If you should need any further information or assistance, please do not hesitate to call.
Sincerely,
91
Sharps Injury Log
Year: _______
Date /
Time
Report
No.
Type of Sharp
(syringe, needle,
glass, etc.)
Brand Name
of Device
Work Area where
injury occurred
(Lab, etc.)
NOTE: Retain this Log until 5 years after the end of the current calendar year.
92
Brief description of how injury
occurred and what part of body
was injured
Blood borne Pathogens Exposure Control Plan Annual Review
An annual review of this plan is conducted in accordance with 1910.1030(c)(1)(iv). The Program
Administrator is responsible for reviewing this program and its effectiveness, and for updating as needed.
The purpose of this review is to update new or modified employee tasks and new or revised employee
positions with exposure to blood or OPIM. This review also serves to reflect changes in technology that
eliminate or reduce employee exposure and incorporation of such technology, if feasible.
Date of Review: ______/______/______
Signature and Title of Reviewer:
__________________________________________
Description of Revisions, if any: __________________________________________
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Personal Protective Equipment (PPE)
A PPE Assessment must be performed at your location according to 29 CFR 1910.132(d). It
can be included in the hazard assessment and is meant to identify PPE that will be used on the job
to protect workers’ from hazards. This assessment must be written, reviewed annually by
the Program Administrator and certified. PPE must always be used as a last-line of defense.
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Heat Illness Prevention Training Guide, A Lesson Plan for Employers
Use this training guide to lead interactive training with workers and supervisors. Can be used with
the worksite poster as a training aid. (English: PDF )Heat Illness: Campaign to Prevent Heat Illness
Information Sheet 2014(English PDF) (Spanish: PDF)
The Control of Hazardous Energy – Lockout Tag Out (LOTO)
A Control of Hazardous Energy Program, referred to as Lockout Tag Out (LOTO), is required for any
facility that has employees that perform servicing or maintenance on machinery or equipment, where the
unexpected energizing, start up or release of any type of energy could occur and cause injury.
The LOTO program must comply with the CalOSHA Control of Hazardous Energy Standard GISO 3314,
Federal OSHA 29 CFR 1910.147, and Federal OSHA CFR 1910.333.
Confined Space
A Confined Space Program must be written and maintained for any facility that contains any areas in the
facility that may be classified as "confined space". A "confined space" is any space that:
1. Is large enough and so configured that an employee can bodily enter and perform assigned work;
2. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins,
hoppers, vaults, and pits are spaces that may have limited means of entry.); and
3. Is not designed for continuous employee occupancy.
The Confined Spaced Program must comply with the Cal-OSHA Confined Spaces Standard GISO 5156
and Federal OSHA 29 CFR 1910.146.
Asbestos
Facilities that contain or may contain any Asbestos Containing Materials (ACM) are required to have an
Asbestos Program written and maintained for each facility. The Asbestos Program will contain an Asbestos
Awareness Training and Asbestos Management Program for the facility.
Asbestos Awareness Training is very important for employees whose work activities may contact asbestos
containing material (ACM) or presumed asbestos containing material (PACM) but do not
disturb the ACM or PACM during their work activities.
This training includes but is not limited to
 Information regarding asbestos and its various uses and forms;
 Health effects associated with asbestos exposure;
 Location of Asbestos Containing Materials (ACM) within the facility;
 Instruction in recognition of damage and deterioration of ACM.
The Asbestos Program must comply with Cal-OSHA Asbestos Standard GISO 5156 and Federal OSHA 29
CFR 1910.1001.
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Lead
Facilities containing leaded substances such as lead based paints, lead containing products, etc. are required
to have a Lead Awareness and Protection Program written and maintained for each facility. The purpose
of the program is to ensure that all personnel are provided with the following:
 What lead is and where it can be found;
 Health effects associated with lead;
 Instruction and recognition of potential leaded substances and posted leaded substances / areas;
 Procedures to minimize exposure during operations and maintenance activities.
The Lead Program must comply with Cal-OSHA Lead Standard GISO 5198 and Federal OSHA 29 CFR
1910.1025.
96
Self-Inspection Checklist - Form by Work Areas
1.
2.
3.
4.
5.
6.
7.
Housekeeping
Kitchen/ Stewarding/ Cafeteria
Engineering
Laundry/ Uniform Room
Administrative/ Clerical
Security/ Bell Desk
Food & Beverage/ Banquets/ Convention Services
97
General Area or Department:
Housekeeping
Date of Walk Through:
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
Checked
(Initial)
General Work Area:
Safety Kit Stocked?
Storage Room Neat & Orderly?
SDS Sheets Readily Accessible?
Chemical Containers Labeled?
Eye Wash Station Accessible?
Fire Extinguisher Accessible?
Chemical Dispensing Area has PPE availableGoggles, Gloves, Apron present?
Flammable Storage Cabinet used for flammables
only? Doors kept closed?
Safe Work Practices:
Housekeeping Carts stocked Correctly?
Wheels on Cart free of Debris?
Wet Floor Signs Being Used?
Laundry Chutes Locked?
Personal Protective Equipment On Cart?
Questions for Department Associates:
Where is the closest fire alarm pull box?
What is the hotel emergency number?
How do you access chemical info/ MSDS?
How is Blood or OPIM cleaned up?
How long do you flush chemicals if spilled on you?
How do you report unsafe conditions?
Who is your Safety Committee Rep?
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Correction Action(s)
Needed
Corrective Action (Explain In Detail):
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management Official
Date & Time
99
General Area or Department:
Kitchen
Stewarding
Cafeteria
Date of Walk Through: ____________
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
General Work Area:
Checked
(Initial)
Safety Kit Stocked? (Kitchen, Stewarding, Etc.)
Floor Surfaces Free Of Water & Debris?
Storage Areas Clean & Orderly?
Fire Extinguishers, Systems Accessible?
SDS Sheets Available?
Chemicals Clearly Labeled?
Personal Protective Equipment In Place?
Eye Wash Stations Accessible?
Safety Guards On Slicers Working?
Safe Work Practices:
Proper Lifting Techniques Used?
Employees Using Knives With Full Attention On
Task?
Broken Glassware Being Picked Up Correctly?
Care Taken When Frying In Hot Oil?
Mits Or Towels Used On Hot Utensils?
Are Hot Liquids Being Covered Before
Transporting?
Rubber Gloves Used When Washing Pots?
Ear Protection Being Used When Polishing Silver?
100
Correction Action(s)
Needed
Corrective Action (Explain In Detail):
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management Official
Date & Time
101
General Area or Department:
Engineering
Date of Walk Through:
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
Checked
(Initial)
Correction Action(s)
Needed
General Work Area:
Safety Kit Stocked?
Fire Extinguishers Accessible?
Eye Wash Station Blocked?
Personal Protective Equipment Available?
Flammable Liquids Properly Stored?
SDS Sheets Available?
Safe Work Practices:
Proper Lock Out/Tag Out Procedures Used?
Blade Guards In Working Order?
Power Tools Operated Near Water?
Proper Lifting Techniques Used?
Ladders Being Used?
MSDS Sheets Reviewed Upon Use Of New
Chemical?
Personal Protective Equipment Being Used?
Painting Work Areas Properly Ventilated?
Corrective Action (Explain In Detail):
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management
Date & Time
102
General Area or Department:
Laundry
Uniform Room
Date of Walk Through: __________
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
Checked
(Initial)
Correction Action(s)
Needed
General Work Area:
Safety Kit Stocked?
Floor Free Of Liquids?
SDS Sheets Available?
Chemicals Labeled?
Personal Protective Equipment Available?
Eye Wash Station Blocked?
Fire Extinguishers Blocked?
Safe Work Practices:
Machinery Stopped Before Retrieving Linen?
Are Baskets Being Loaded Evenly?
Ramps On Carts Being Used?
Safe Lifting Techniques Used?
Sorting Being Done With Caution?
Corrective Action (Explain In Detail):
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management Official
Date & Time
103
General Area or Department:
Administrative
Clerical
Date of Walk Through: _______
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
Checked
(Initial)
Correction Action(s)
Needed
General Work Area:
Safety Kits Stocked? (Front Desk, Etc.)
Ample Walk Space Through Areas?
Storage Areas Kept Clean & Orderly?
VDT Stations Have Adequate Back Lighting?
Adjustable Chairs At Work Stations?
Fire Extinguishers Accessible?
Telephone Equipment Room Blocked?
Loading Dock Free Of Standing Water?
Safe Work Practices:
Drawers Opened One At A Time And Closed After
Use?
Is Furniture Being Used In Place Of Ladders?
Are Employees Walking At A Safe Speed Through
Service Hallways?
Corrective Action (Explain In Detail):
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management Official
Date & Time
104
General Area or Department:
Security
Bell Desk
Date of Walk Through:_______
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
Checked
(Initial)
Correction Action(s)
Needed
General Work Area:
Safety Kits Stocked?
Fire Extinguishers Accessible?
Storage Areas Neat & Orderly?
Bell Stand Have Adequate Clearance?
Safe Work Practices:
Walkways Or Corridors Blocked With Luggage?
SDS Sheets Available?
Personal Protective Equipment Available?
Proper Lifting Techniques Used?
Corrective Action (Explain In Detail):
______
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management Official
Date & Time
105
General Area or Department:
F&B
Banquets
Convention Services
Date of Walk Through: _______
People Conducting Walk Through:
Safe Work Condition, Practice Or Personal
Protective Equipment
General Work Area:
Safety Kit Stocked? (Banquets, Stewarding, Etc.)
Floor Surfaces Free Of Water & Debris?
Storage Areas Clean & Orderly?
Fire Extinguishers Accessible?
Safe Work Practices:
Pressurized Cylinders Chained Upright?
Dining Area Set Up With Proper Amount Of Walk
Space?
Bus Stations, Bars Clear Of Obstacles?
Hot Liquids Covered Before Transporting?
Servi-Bar Carts Being Pushed In A Controlled
Fashion?
Is Glassware Being Inspected Before Placing Into
Service?
Are Ice Spills Being Cleaned Up Immediately?
Are Gloves Being Used To Handle Wood Props,
Staging And Tables?
Are Knives Used Without Distraction?
Is Skirting Of Tables Completed With Fingers Out
Of Way Of Pin?
Are Proper Lifting Techniques Used?
Are Ladders Being Used Appropriately?
Is Glassware Being Used As Ice Scoops?
Corrective Action (Explain In Detail):
106
Checked
(Initial)
Correction Action(s)
Needed
Is Lock Out/Tag Out Required Due To Imminent Hazard?
Person Responsible For Correction
Copy Provided
Copy Reviewed By Management Official
Date & Time
107