County Safety Management Program

The Sonoma County Safety Management Program provides for the safety, health and security of all County employees and the public we serve. This responsibility extends to all employees, volunteers, contractors, visitors and the public conducting business on behalf of the County of Sonoma. This policy applies to all agencies, departments and special districts under the direct control and governing authority of the Board of Supervisors.

To get more information on the applicability of this program for a specific County operation please contact the corresponding departmental Safety Coordinator.

Table of Contents

1. Purpose
2. Safety Policy
3. Responsibilities
   1. Board of Supervisors
   2. County Administrator
   3. Risk Management
   4. Department Heads
   5. Department Safety Coordinators
   6. Directors / Managers
   7. Supervisors
   8. Employees
4. Program Management
   1. Communication
   2. County Safety and Health Training
   3. Program Evaluations
   4. Record Keeping
   5. Design Review / Management of Change
   6. Contractor Safety Program Responsibilities
5. Health & Safety Council
   1. Council Membership
   2. Council Functions
   3. Council Administration
6. Employee Hazard Reporting
7. Employee Injuries
   1. Serious Injury Reporting
   2. Injury / Illness / Exposure Reporting Procedure
   3. Accident/Incident Investigations
   4. Injury Data Management
8. Departmental Injury and Illness Prevention Program
   1. Responsibility / Management Commitment
   2. Compliance
   3. Communication
   4. Hazard Assessment
   5. Hazard Correction
   6. Injury Procedures
   7. Department Safety and Health Training
   8. Record Keeping
   9. Program Evaluations
9. Additional County Safety Program Requirements
   1. Emergency Planning
   2. Ergonomics
   3. Chemical Hazard Communication
   4. Bloodborne Pathogens
   5. County Vehicle Use Policy
   6. Job-Specific Safety Program Requirements
10. Further Information

I. Purpose

The purpose of this document is to establish the formal safety management program for the County of Sonoma, in compliance with Title 8, of the California Code of Regulations and other applicable regulations.

The Sonoma County Safety Management Program provides for the safety, health and security of all County employees and the public we serve. This responsibility extends to all employees, volunteers, contractors, visitors and the public conducting business on behalf of the County of Sonoma. This policy applies to all agencies, departments and special districts under the direct control and governing authority of the Board of Supervisors and are referred to as “departments”.

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II. Safety Policy

It is the policy of the County of Sonoma to provide for the protection and well being of employees and the public.  The County of Sonoma is committed to providing a safe and healthy workplace in which to deliver governmental services.

It is the policy of the County of Sonoma to integrate safety and health considerations into business planning, decision-making and daily operations in order to promote continuous performance improvement.  In support of this policy, the management of the County of Sonoma accepts the responsibility for implementing, developing and advocating this Safety Management Program.

It is the policy of the County of Sonoma to conduct all County operations in compliance with all applicable laws and regulations, as well as the County’s own ordinances and established procedures.

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III. Responsibilities

Every County employee is responsible for his or her own personal safety and supporting the safety of the organization.  This section describes in detail the specific roles and responsibilities of each participant in the County Safety Management Program.

A.  Board of Supervisors

The Board of Supervisors provides the leadership and direction of the County’s overall health and safety program.  The Board of Supervisors directs implementation of the overall County Safety Policy as outlined above in Section II.

B.  County Administrator

The County Administrator has ultimate authority and responsibility for the implementation of all Board of Supervisors directives regarding safety in all departments and implementation of the County Safety Management Program.  The County Administrator:

• Provides executive management oversight of the safety program directed through the Risk Management.
• Establishes performance goals in cooperation with Department Heads and with the assistance of Risk Management.
• Prioritizes safety program elements to achieve the maximum reduction of risk and greatest program improvement. 
• Requires all departments comply with the elements of the County Safety Management Program and that the program is periodically evaluated. 
• Considers and evaluates requests for resources to achieve program implementation and success.

C.  Risk Management

Risk Management staff is responsible for advising and supporting the County Administrator and all County departments in implementing and maintaining the County Safety Management Program.  Responsibilities include:

• Advise management and employees on their roles and responsibilities for the safety program.  Provide direction for the continuing development and maintenance of the County Safety Management Program.
• Support departments in developing processes and management systems to guide and document safety program compliance.
• Assist departments in developing Injury and Illness Prevention Programs (IIPP) designed to meet the specific needs for each department as required by the California Code of Regulations, Title 8.
• Evaluate Department IIPP implementation on a periodic basis and report to the County Administrator and the Board of Supervisors using the established performance criteria for the critical program elements.
• Support departments in developing effective programs to manage occupational health and safety, injury prevention, hazardous materials management, fire prevention and emergency preparedness.
• Monitor changes in health and safety regulations and provide updates to departments as applicable.
• Administer countywide training programs on specific safety issues with broad application to multiple County departments.
• Conduct bimonthly Safety Council meetings as a forum to disseminate information on County safety programs and legislative or regulatory changes to Department Safety Coordinators.
• Responds to Employee Hazard Report Appeals and facilitates County Administrator review. 
• Assist departments in identifying safety and accident prevention training needs and assist in the coordination of that training.
• Provide occupational health and safety consultation services to departments.
• Support Departments during Cal-OSHA inspections and assist in the correction of hazards.
• Review Accident/Incident Investigation Reports and assist Department Safety Coordinators with investigations when needed.
• Prepare loss analysis information for Departments to assist in keeping management’s focus on safety, ongoing hazard identification, corrective actions, and training.
• Maintain and distribute Cal-OSHA record keeping requirements.
• Support the County New Employee Orientation in providing current safety materials and information.

D.  Department Heads

Department Heads have the authority and responsibility for the implementation of the County Safety Management Program and the Department Injury and Illness Prevention Program (IIPP).  It is the role of the Department Head to provide visible guidance and operational leadership to implement a culture of safety and continuous improvement.  Department Head responsibilities include:

• Provide leadership and resources necessary to implement the County Safety Management Program within the department.
• Designate and support Department Safety Coordinator(s) consistent with the requirements and responsibilities outlined in this document.
• Promote the development of effective programs to manage occupational health and safety, accident and injury prevention, hazardous materials management, fire prevention and emergency preparedness risks.
• Maintain compliance with health and safety regulatory requirements.
• Assure the development of processes and management systems to guide and document safety program compliance.
• Set departmental safety programs goals and objectives and establish measurable performance criteria.
• Encourage employee participation in safety program elements.
• Require accountability for safety practices.
• Provide job-specific occupational health and safety training to department employees including Cal-OSHA training requirements.
• Require supervisors to conduct prompt and thorough investigations of employee accidents, incidents and Employee Hazard Reports, including an analysis of corrective actions to prevent additional injuries.
• Include safety communications in Department staff meetings and through other forms of organizational communication on an ongoing basis.
• Evaluate the department’s loss analysis information.
• Review job-specific hazard assessments and revise periodically.
• Require that periodic inspection procedures are implemented and documented.
• Identify and correct hazards recognized through inspections, accident investigations or Employee Hazard Reports. 
• Direct annual review and update of Department IIPP to reflect changes in operations or procedures.
• Keep the County Administrator and Risk Management informed of significant safety issues.

E.  Department Safety Coordinator(s) 

Department Safety Coordinator(s) are designated by the Department Head to facilitate the implementation of the County Safety Management Program and the Department’s IIPP.  The designated individual must have the authority, skills and abilities to effectively manage the safety program and have access to the Department Head or his/her designee on safety-related issues.  All departments are required to designate a Department Safety Coordinator.  Departments may assign additional personnel to assist the Department Safety Coordinator with their responsibilities.  In addition, division, program, site or facility safety coordinators may be designated to effectively implement and manage health and safety programs.  Department Safety Coordinator functions may be effectively shared between departments.  

The Department Safety Coordinator is required to obtain through study and training adequate knowledge and skills in the following: 

• Knowledge of County and department safety programs, and their requirements.
• Basic knowledge of safety and health regulations and requirements.
• Knowledge of how to build and manage effective safety and health programs.
• Knowledge of related health and safety programs ( Emergency Action, Ergonomics, Hazard Communication, etc.).
• Knowledge of County Workers’ Compensation Program and injury management procedures

The Department Safety Coordinator responsibilities include:

• Manage, administer and coordinate the County/Department Safety Management Program as directed by the Department Head and Risk Management.
• Prepare periodic and special reports for departmental management regarding injuries and illnesses; identify trends or changes that require management attention and recommend corrective action where appropriate.
• Recommend departmental safety procedures and IIPP updates to maintain safe working conditions and safe work practices.
• Serve as a source of information on safety policies, procedures and requirements to supervisors and employees within the department.
• Actively participate as the department’s designated liaison at the County Health and Safety Council meetings.
• Communicate health and safety information throughout their department.
• Assist Department management and supervisors in the promotion of safety awareness and education programs.
• Review all injury reports and accident investigations, to determine the root cause has been identified and all corrective actions are properly addressed.  Support supervisors as necessary in this effort.
• Facilitate and track to completion all filed Employee Hazard Reports.
• Evaluate loss analysis information in order to provide management with appropriate recommendations.
• Assist department management in conducting periodic audits of hazards, risks and management systems.
• Assist department and division managers in the annual evaluation of the effectiveness of the organization’s IIPP.
• Post the OSHA 300a form provided annually by Risk Management.  Agencies not covered through the County’s Workers Compensation Program must obtain or otherwise create and post their own documents.
• Monitor Cal-OSHA citation responses, notifications and abatement.
• Coordinate the department’s Ergonomics Program.
• Coordinate the department’s Emergency Preparedness Programs.
• Maintain Health and Safety bulletin boards with current information such as required postings, bulletins, notices and other pertinent information.
• Serve as a health and safety resource to employees 

F.  Directors / Managers

Department directors/managers are responsible for County Safety Management Program implementation in the facilities and operations under their immediate control.  These responsibilities include:

• Provide leadership in the implementation of the County Safety Management Program to maintain full program effectiveness
• Conduct periodic audits of hazards, risks and management systems.
• Develop effective programs to manage occupational health and safety, injury prevention, hazardous materials management, fire prevention and emergency preparedness risks.
• Comply with health and safety regulatory requirements.
• Develop of processes and management systems to guide and document safety program compliance.
• Determine that safety program goals and objectives are met.
• Track and gather data as required by the measurable performance criteria established by the department.
• Assure that effective safety practices are in place and promote safety accountability.
• Encourage employee participation in safety program elements.
• Provide effective job-specific occupational health and safety training to employees including Cal-OSHA training requirements.
• Require prompt investigation of employee accidents and incidents by supervisors, including an analysis of corrective actions to prevent further injury.
• Include safety communication in Department staff meetings and other forms of communication throughout the department on an ongoing basis.
• Evaluate loss analysis information.
• Review job-specific hazard assessments and revise periodically.
• Require that periodic inspection procedures are implemented and documented.
• Determine the status of hazard correction resulting from inspections, accident investigations or Employee Hazard Reports. 

G.  Supervisors

All supervisors are responsible for the County’s Safety Management Program implementation in the facilities or operations under their immediate direction.  They are required to be knowledgeable of the County Safety Management Program, their department’s IIPP and all employee job hazards under their direct supervision.  Supervisors must provide the necessary leadership to assure program effectiveness.  The responsibilities include:

• Be knowledgeable concerning potential health and safety hazards for employees under their direct supervision and control.
• Set the example by following and requiring safe work practices.
• Instruct staff in safe work practices to be followed in daily job assignments.
• Conduct training on job specific health and safety hazards and practices.
• Complete the Supervisor’s Report of Occupational Injury/Illness/Exposure as required.
• Investigate promptly and thoroughly, every accident/incident and/or Employee Hazard Report to determine the root cause and identify preventative measures to avoid re-occurrence.
• Enforce department safety practices and procedures.
• Complete the Accident/Incident Investigation Report as required.

H.  Employees

County employees are responsible for their own safety and the safety of others in the workplace.  These responsibilities include:

• Comply with the County Safety Management Program, their department’s IIPP and all other safety practices, programs and procedures.
• Maintain knowledge of their department’s IIPP. Actively participate in department safety activities as requested by managers/supervisors.
• Successfully participate and complete required general and job-specific safety and health training.
• Actively participate in the County Safety Management Program by reporting incidents and injuries, attending safety meetings, reporting problems and recommending improvements, and other related activities.
• Inform their supervisor/manager of any unsafe activity, behavior or condition.

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IV. Program Management

The County Safety Management Program provides provisions and methods to promote the development of effective programs to manage occupational health and safety, injury prevention, hazardous materials management, fire prevention and emergency preparedness.  This Safety Management Program is administered by Risk Management and executed through all County departments.

A.  Communication

The County provides safety communication from Risk Management to all designated departmental personnel through the Health and Safety Council, training programs and direct department communications.  Types of communication may include County Safety Management Program implementation, regulatory updates, technical support, references and resources.

B.  County Safety and Health Training

Risk Management coordinates county training on core health and safety training requirements applicable to a wide range of County operations.  Risk Management provides assistance to departments in the identification and delivery of selected safety training requirements specific to their department operations.  Risk Management, through the Health and Safety Council, also collaborates with departments who have mutual training needs.

C.  Program Evaluations

Risk Management assists departments in conducting periodic evaluations of Department IIPPs.  The purpose of these evaluations is to evaluate IIPP implementation effectiveness and provides feedback for continuing program improvement.  Findings are reported to the County Administrator and Board of Supervisors to document countywide implementation.  A Risk Management evaluation will take the place of the department annual IIPP evaluation for that year.

D.  Record Keeping

Risk Management keeps records of industrial hygiene surveys, consultant reports, and other documentation for projects facilitated by Risk Management.  Departments follow OSHA record keeping requirements outlined in their departmental IIPPs.  In addition, various specific record keeping requirements exist that may require departments to maintain records for more than 30 years.  All records will be kept in accordance with departmental or Common Accounting and Administrative Records (CAAR) retention schedules adopted by the Board of Supervisors.

E.  Design Review/Management of Change

The County establishes and implements processes to identify hazards and potential risks associated with new processes and operations at the design stage of projects or when significant physical plant or operational changes occur.  A design review or management change process may be initiated for new technology, equipment or facilities, new procedures or standards, new materials, significant changes in organizational structure or staffing, or new health and safety regulations are introduced. 

The County establishes and implements a procurement process to identify and evaluate potential health and safety risks associated with products, materials, goods and services purchased by the County.  For example, Material Safety Data Sheets for new materials are evaluated so that unacceptable environmental, health and safety hazards are not introduced into County operations.  

F.  Contractor Safety Program Responsibilities

All County departments that engage contractors are responsible to manage the risk associated with work performed by contractors.  Contractors are non-departmental employees who are under contract to provide goods or perform services.  The designated contract manager(s) in each department establishes and implements processes to identify, evaluate and control potential health and safety risks associated with contractor operations.  Contractor safety requirements include:

• Identification of appropriate contractor health and safety performance criteria in project specifications and the contract documents for each job.
• Establishment of a process to coordinate environmental, health and safety requirements between organizations on multi-employer work sites.
• Identification of compliance procedures so that contractors comply with environmental, health and safety requirements for the job.
• Notification through the contractor, to the contractor’s employees of potential hazards associated with the County’s work area or operations that could affect them.
• Notification to County employees concerning contractor activities in their work area, potential hazards from their activities, equipment or materials involved in their operations.

Internal contracting between County departments will require the same level of responsibility to inform employees of hazards, follow safe work practices and procedures, and monitor compliance with safety requirements.

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V. Health & Safety Council

The Sonoma County Health and Safety Council (SCHSC) provides a forum to communicate and exchange information on matters of occupational health, safety, workplace security, loss prevention and OSHA regulatory compliance.  The SCHSC actively promotes the County Safety Management Program and encourages efforts to maintain active and effective Departmental Injury and Illness Prevention Programs.

The SCHSC supports and promotes efforts to maintain a safe and healthy work environment for all County employees, volunteers, clients and members of the public.  The Council’s activities promote the reduction and elimination of accidents, incidents, injuries and job related illnesses by means of continuous program improvement.

A.  Council Membership

Membership in the SCHSC consists of the CAO, who may designate an Assistant County Administrator or Deputy County Administrator to attend, representatives of all Sonoma County Departments, Agencies, Special Districts and recognized employee organizations.  Risk Management maintains a current list of Council members.  All members actively participate, and contribute in all SCHSC proceedings and activities.  The Chair of the Board of Supervisors shall receive notification of the Health and Safety Council meetings and may attend at their discretion. 

• Department Safety Coordinators or alternates are required to attend all regular SCHSC meetings to assure department representation, continuity and communication to the management and employees they represent.
• Safety Coordinators representing Divisions, Sites or Programs are encouraged to participate as determined by their respective department.

B.  Council Functions

The Sonoma County Health and Safety Council:

• Promotes the interests of health and safety consistent with the objectives of the Safety Policy and the County Safety Management Program.
• Reviews and discusses the current status of health and safety activities conducted by the County, individual departments, divisions and agencies.
• Recommends health and safety training, resources and information to facilitate program implementation and regulatory compliance.
• Reviews and discusses health and safety issues of common interest to the SCHSC members. 
• Solicits input on County Health and Safety program initiatives and administration.
• When necessary, the County Risk Manager or designee will address safety concerns or issues proposed by SCHSC members with County executive management.

C.  Council Administration

Risk Management is responsible for administration and coordination of the SCHSC by providing leadership and technical support on all program matters.

• The County Risk Manager or designee chairs all meetings.
• Meeting agendas address current program initiatives, pertinent regulatory changes, relevant health and safety issues or topics proposed by council members.
• Risk Management provides meeting announcements to all SCHSC members, alternates, Department Heads, and employee organizations
• Risk Management maintains minutes of all meetings and distributes copies of information in a timely manner.
• The Council holds regular meetings bimonthly.

Additional meetings or sessions may be scheduled as necessary, for training or special events.

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VI. Employee Hazard Reporting

Most safety hazards are reported informally, verbally, in writing, or electronically through e-mail.  A hazard may be also reported by completing an Employee Hazard Report form (PDF: 205 kB).  The success of the Sonoma County Health and Safety Program relies upon employees to report all safety hazards.  Occasionally, an employee may encounter a dangerous situation or imminent threat that may result in death, serious injury, prolonged impairment, or hospitalization.  In the event of an emergency requiring medical, fire or law enforcement, an employee shall call 911.  Although these situations are rare, they require immediate reporting and notification of their supervisor.

Employees who elect to formally report an apparent safety hazard, should complete the Employee Hazard Report form (PDF: 205 kB) and forward it to their supervisor.  Employees are encouraged to include their name on the form in order to clarify the concern when necessary, participate in the development of a solution, and receive a written response.  An employee who wishes to remain anonymous may omit their name from the hazard report form or contact their employee representative who may submit an Employee Hazard Report on their behalf. 

An employee who wants to discuss an apparent safety hazard, is searching for information on a safety issue, or is reluctant to submit a hazard report to their supervisor directly, may contact their Department Safety Coordinator.  In addition, employees may directly contact the Risk Management, Occupational Safety and Health Unit for information or guidance.

County recognized employee organizations may submit the Employee Hazard Report and/or the Employee Hazard Report Appeal (PDF: 117 kB) on behalf of an employee or group of employees.

Departments shall follow the hazard report distribution and record keeping process as defined in the applicable department IIPP.

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VII. Employee Injuries

A.  Serious Injury Reporting

Serious injuries as defined in Title 8, Section 330 must be reported to Cal-OSHA within 8 hours of notification.  Departments are responsible to provide such notification to the Santa Rosa District Cal-OSHA office with concurrent notice to Risk Management.  

B.  Injury/Illness/Exposure Reporting Procedure

All injuries/illnesses must be reported to Risk Management within 24 hours.  Supervisors/Managers are responsible to complete the Supervisor’s Report of Occupational Injury/Illness/Exposure form and forward it to Risk Management with a copy to the Department Safety Coordinator and others, according to the Department’s process.  Supervisors must follow the Risk Management report of injury, illness or exposure reporting procedures.

C.  Accident/Incident Investigations

Accident/Incident investigations are important tools used to identify safety concerns, determine how an incident could have been prevented and to make recommendations to prevent re-occurrences.  Departments must follow the Risk Management accident/incident investigation procedures.

Department Safety Coordinators are responsible to review the investigation report for accuracy and completeness.  In addition, the Department Safety Coordinator will collaborate with the Supervisor/Manager in developing recommendations, taking corrective action to prevent future re-occurrences, and elevating safety concerns to the Department Head.  Accident/Incident Investigations are forwarded to Risk Management within 5 working days for record keeping and program monitoring. 

D.  Injury Data Management

Risk Management is responsible for maintaining information on all reported accidents/incidents through the Worker's Compensation management database.  Periodic loss reports are generated from this system and forwarded to departments. OSHA 300 logs and OSHA 300a postings are generated from this system and are provided to departments for posting annually, as required by OSHA regulations and upon request. 

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VIII. Departmental Injury and Illness Prevention Program

The Department Injury and Illness Prevention Program (IIPP) is designed to provide a written plan for the protection of employees and to reduce the losses resulting from work-related injuries and illnesses.  All departments must establish, implement and maintain an Injury and Illness Prevention Program (IIPP).  The requirements for an effective written injury and illness prevention program are contained in Title 8 of the California Code of Regulations, Section 3203.  Written programs have eight required elements:

A.  Responsibility/Management Commitment

Each Department Head must designate a responsible person or persons to implement the departmental Injury and Illness Prevention Program. The Department Head has the overall responsibility and authority for the implementation of the IIPP.  Senior management provides overall direction and designates program implementation through Department Safety Coordinators, Site Safety Coordinators, Training Coordinators, etc.  Senior management is responsible for monitoring program implementation and effectiveness. 

Department Heads, directors, managers and supervisors must demonstrate ongoing commitment and leadership for their IIPP and the County Safety Management Program.  Activities that demonstrate program effectiveness include participation in safety activities with direct interaction with employees such as through department staff meetings with safety on the agenda.  Allocation of appropriate resources for program implementation, including support of the Department Safety Coordinators role is critical to program effectiveness.  The development of effective management systems to monitor program implementation demonstrates ongoing management commitment and support of the overall program.

B.  Compliance

Departments must inform employees of the Injury and Illness Program requirements and the safety program requirements must be enforced.  A system to require employees to comply with safe work practices and procedures should be described in the written IIPP document.  Compliance methods may include employee recognition programs, counseling, re-training, performance evaluations with a safety element, and disciplinary procedures consistent with County policies and Memorandum of Understanding. 

C.  Communication

Departments must develop effective, two-way communication on safety and health issues, including a method for employees to report hazards anonymously.  Specific communication methods at all levels of the organization must be outlined in the department IIPP.  Safety communication methods may include staff meetings, general safety meetings, training programs, written communications, newsletters, safety bulletin boards, and department safety committees.  

Smaller departments can satisfy the communication requirement during regularly scheduled staff meetings.  Larger departments are strongly encouraged to establish a department occupational health and safety committee.  Departments with multiple locations are encouraged to maintain a safety committee for each division, program or site, as appropriate.  Each established department safety committee shall invite at least one member from each employee organization.  

D.  Hazard Assessment

Departments must identify and evaluate the hazards found in their workplace in order to implement effective controls.  

• Job-specific Hazard Assessments
  
  Departmental IIPPs include job-specific hazard assessments.  These are the baseline hazard assessments that are the foundation for developing effective safe work practices. 
  
  Hazard assessment is an ongoing process and evaluations are conducted whenever new or previously unrecognized hazards are identified, new substance, equipment or operation are introduced, and the occurrence of an occupational illness or injury.
• Periodic inspections
  
  Periodic inspections are conducted to identify work area hazards and to evaluate the effectiveness of controls.  Work practice observation can be incorporated into the periodic inspection.  Each Department identifies inspection criteria, develops periodic inspection schedules and designates the responsibility for conducting inspections by work area or facility. 
  Supervisors develop methods for the evaluation of safety procedures for operations conducted off-site.  
• Reporting of Hazards
  
  All managers and supervisors will encourage employees to report workplace hazards without fear of retaliation and will provide prompt reports on the status of hazard correction.  Each Department is responsible to make sure the Sonoma County Employee Hazard Report form (PDF: 205 kB) is readily available to employees in all work locations to facilitate the formal reporting of safety hazards.  The written department IIPPs must clearly describe the locations of report forms and the methods for employees to submit a Hazard Report directly to their supervisor, or to another individual if anonymity is desired.  The IIPP must also describe the method of elevating safety concerns through the department, up to and including the Department Head.

E.  Hazard Correction

The Supervisor, Manager or Department Head, as warranted by the specific condition, will assess hazard severity and identify the method and time it will take to conduct hazard correction.  Upon request of the Department Head, Risk Management will provide assistance to the department on hazard corrections.

Each Department will implement a hazard correction tracking system to identify hazards through periodic inspections, Employee Hazard Reports, accident investigations or other methods are corrected and the correction documented.

F.  Injury procedures

• Injury/Illness/Exposure Procedures
  
  The department IIPP will reference the County of Sonoma Injury/Illness/Exposure Procedures.  Department specific procedures will also be described or referenced.  
• Accident/Incident Investigations
  
  All departments must conduct effective accident/incident investigations to identify the root cause of the accident and to implement adequate control measures.  Accident /incident investigations must be reviewed periodically by department management to determine that thorough investigations are conducted by supervisors and deficiencies in the safety management system are identified.  Opportunities for improvement from investigations can be used for planning and corrective action.
  
  The department IIPP defines the level of investigation that will be performed for accidents and “near miss” incidents.  The IIPP also describes the time frames for investigations, investigation responsibilities for individuals, teams or committees, and follow up procedures described.  

G.  Department Safety and Health Training

Department Heads are responsible to provide all employees with designated department occupational safety and health training on general and job-specific hazards, and safe work practices.  Each department will develop an occupational health and safety-training matrix for employees with similar job hazards that include IIPP training, job-specific training (based on the department IIPP hazard assessment) and regulatory program training requirements.  Departments may choose to include optional topics to reach department best practice goals.

Supervisors and Managers require a higher level of training to include all health and safety hazards to which employees under their immediate direction and control are exposed.  

Each department is responsible for the delivery of job-specific health and safety training to extra-help, temporary, volunteers and contract employees.  This requirement will apply for County employees from other departments assigned to work in their operation or facility.  Departments are not responsible for health and safety training for the employees of other County departments contracted to perform specific facility or infrastructure tasks that are independent of the mission of the department. 

Each department provides safety training and instruction when:

• Safety policies and programs are first established or revised
• New employees are hired (orientation safety training)
• Employees are assigned to a new area or task where specialized training is needed.
• New substances, operations, procedures or equipment are introduced 

Each department shall establish a system to monitor the completion of employee safety training for each individual to effectively manage the delivery of mandatory training requirements.  An assessment of safety training effectiveness is included in periodic evaluations.

H.  Record keeping

IIPP records are maintained consistent with the records retention requirements identified in Common Accounting and Administrative Records (CAAR) retention schedule. 

Specific IIPP record keeping requirements include:

• Periodic inspection records will include the date of the inspection, location, name of the person conducting the inspection, unsafe work practices or conditions identified, and the corrective action taken.
• Occupational health and safety training records will include the employee names and signature (sign-in sheets), instructor, training date and training curriculum or agenda.  Staff meetings where required safety training is delivered will follow the same record keeping format.

I.  Program Evaluations

The Department Safety Coordinator, Department Safety Committee or other designated staff is responsible to evaluate the effectiveness of the departmental IIPP on an annual basis.  A report summarizing department IIPP implementation and program status shall be submitted to the Department Head for review.  Corrective actions to improve program implementation and management system deficiencies will be recommended and the status of corrective actions will be documented.

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IX. Additional County Safety Program Requirements

A.  Emergency Planning

All departments will identify reasonably foreseeable emergencies applicable to their operations to minimize the disruption of County services and to manage health and safety risks to employees and visitors in County facilities and operations.  The development of written plans should be appropriate for the size and needs of the department and should be prepared to meet the Cal-OSHA requirements for written Emergency Action and Fire Prevention Plans (8 CCR 3220, 3221).   Written emergency plans address responses to fire, explosion, bomb threats, chemical releases, natural disasters and workplace security emergencies.   Departments are responsible for periodic testing of the emergency plans through evacuation drills and other training exercises.  Evacuation procedures must also address individuals with special needs.  Plans and procedures will be evaluated annually and revised as needed. 

Risk Management has developed Emergency Action and Fire Prevention Plan templates to assist departments in the preparation of site-specific plans.  Training materials are also available from Risk Management.  

B.  Ergonomics

All departments will implement the Sonoma County Ergonomics Program as required by the California Code of Regulations, Title 8, Section 5110.  All departments are required to designate Ergonomics Coordinators to conduct ergonomic awareness training and basic ergonomic evaluations within the department.  Smaller departments may choose to make arrangements with other County departments to assist them with this function.  Risk Management provides periodic training for Ergonomics Coordinators and professional ergonomic consultation as required.  

C.  Chemical Hazard Communication

Departments will implement the Sonoma County Hazard Communication Program where hazardous substances are used in their operations, as required by the California Code of Regulations, Title 8, Section 5194.  The preparation of a department-specific section of the County Hazard Communication Program is required in order to achieve compliance with this program requirement. 

D.  Bloodborne Pathogens

Departments who have identified employees who may be occupationally exposed to blood or other potentially infectious bodily fluids as required by California Code of Regulations, Title 8, Section 5193 will implement the Sonoma County Bloodborne Pathogens Program.  The completion of the department operation-specific section is required in order to achieve compliance with this program requirement.  

E.  County Vehicle Use Policy

To address hazards associated with motor vehicle operations, the County has developed a Vehicle Use Policy.  All departments are required to implement the County vehicle use policy where employees must drive on County business.  Refer to County Administrator’s Administrative Policy Manual 5-1 Policy for Vehicle Use.

F.  Job-Specific Safety Program Requirements

It is the responsibility of each department to maintain an understanding of health and safety regulations affecting its operations and to identify additional safety program requirements based upon the unique job hazards identified in the Injury and Illness Prevention Program hazard assessment.  An awareness of Cal-OSHA requirements for specific job hazards is required to be in substantial compliance with the regulations.  For example, employees wearing respirators are required to participate in a Respiratory Protection Program; employees operating forklifts are required to participate in an Industrial Vehicle Program.

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X. Further Information

Further information such as requirements, sample programs, procedures and forms are available on the County's Safety website.   

Note:  Where the wording and terms in this Safety Management Program conflict with a Memorandum of Understanding (MOU) between the County and Employee Organizations, the language in the MOU shall prevail.

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