The program has been the most frequently violated Cal-OSHA standard in every year since 1991, being cited in about 25 percent of all inspections. The California program is also one possible model for federal OSHA's current rule-making effort to develop a safety and health program rule.
The RAND study notes that higher penalties for noncompliance with the program and more extensive activities to make employers aware of their obligations could enhance compliance. However, two other approaches could have a greater impact: having inspectors conduct more in-depth assessments of employer programs and having inspectors link the violations they find and the injuries that have occurred to the program by asking "Why weren't these prevented by your Injury and Illness Prevention Program?"
The study found that employers who were cited for violations of the Injury and Illness Prevention Program in one inspection usually came into compliance in future inspections. However, the overall percentage of inspections finding program violations did not change over time.
Moreover, the percentage of first-time inspections finding violations was the same in 2007 as it was in 1993. These findings indicate that information about the program requirements failed to reach many employers, they failed to be convinced to comply by the threat of penalties, or both.
The 20 percent reduction in injuries following citations for the specific requirements of the California Injury and Illness Prevention Program translates to about 1 injury per year at a workplace with 100 employees. Most estimates of the value of preventing a work injury are in the range of $15,000 to $50,000. The RAND study did not find evidence that the statewide workplace fatality rate had decreased after the introduction of the program standard.
The study of injury effects was carried out using several different
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