Recent Standards Board Rule Revisions Affect Many Businesses

We are a small machine shop that specializes in custom automotive parts and one of our employees recently requested a copy of our Injury and Illness Prevention Program (IIPP). Is that required? What other non-COVID rule changes have occurred recently?

Injury/Illness Prevention Program

The Occupational Safety and Health Standards Board (OSHSB) recently revised Section 3203 of the General Industry Safety Orders to require supplying the employee a copy of the IIPP.

New Sections 3203(a)(8)(A) through (8)(F) have been adopted that will require employers to provide to an employee or their designated representative access to some sections of the IIPP upon request.

Section 3203(A)(8)(C) limits the information to be given to the program elements in section (a). Records of steps taken to implement or maintain the IIPP are not required to be provided.

The employee may receive one printed copy or an electronic copy if they wish. If the employee requests a second copy within one year, the employer may impose a fee. Where multiple programs exist, only those programs applicable to the requesting employee need to be given.

Toilet Facilities

The regulations for toilet facilities, contained in Title 8 of the General Industry Safety Orders, have been revised to correspond with the Health and Safety Code (HSC) Section 118600.

The term “single-user toilet facility” is now used to be consistent with the HSC. Also, multiple facilities on a single site now may be designated for all-gender use provided the appropriate number of facilities are available for the number of employees.

Construction Elevators

As the result of an Appeals Board Decision after Reconsideration (DAR), Section 1630(a) of the Construction Safety Orders (CSO), Elevators for Hoisting Workers, has been clarified.

As previously written, subsection (a) required a construction elevator for upper floor access if the building to be built was 60 feet or taller in height. Subsection (d) required the first landing to be at 36 feet. It had been common practice to install the lift when the building had reached 36 feet.

The DAR found the elevator did not have to be installed until the building was at 60 feet, a conclusion that was not acceptable to the construction industry. Therefore, the industry petitioned the OSHSB to revise the regulation to clearly indicate the hoist is to be installed at 36 feet.

Fall Protection

Section 8615 of the Telecommunication Safety Orders formerly permitted point-to-point travel at elevated locations by qualified persons without fall protection equipment unless extreme conditions prevented gaining a firm hand or foothold while traveling.

Also, the term “equipment” was not equivalent to federal OSHA’s use of the term. Therefore, to make California’s regulation at least as effective as federal OSHA, references have been made to ensure the fall protection system meets the requirements of Section 1670 of the CSO, Section 2940.6(c) of the Electrical Safety Orders, Section 3270.1 of the General Industry Safety Orders and others.

Column based on questions asked by callers on the Labor Law Helpline, a service to California Chamber of Commerce preferred and executive members. For expert explanations of labor laws and Cal/OSHA regulations, not legal counsel for specific situations, call (800) 348-2262 or submit your question at

Staff Contact: Mel Davis