IIPP Writing for California Employers

Anyone can write an Injury and Illness Prevention Program in California, and M Squared Safety writes them for California employers. Cal/OSHA's rule, 8 CCR 3203, sets what the program has to contain and holds the employer responsible for it. Nothing in the regulation requires the author to hold a license or a certification. What it requires is a program in writing that covers eight elements, names the people responsible for running it, and is actually followed on your jobsites and floors. We talk with the people who run your work, write the program around what your crews do, and name real people in real roles. For contractors we write the Code of Safe Practices under 8 CCR 1509 at the same time.

Who you'll work with: M Squared Safety is run by Matt Horovitz from our San Clemente office, with twenty plus years managing contractor safety programs. More about us.

The most cited standard in California

Section 3203 was the most frequently cited Cal/OSHA standard in calendar year 2025, and its construction counterpart, section 1509, was third, according to Cal/OSHA's top 10 most frequently cited standards. It is often the first document a general contractor asks a subcontractor for, and one of the first a Cal/OSHA inspector asks to see.

Our own inspection records show the same gap from the other side. On 4,862 inspections since November 2014 where our inspectors checked for a written IIPP, 520 found none in place, about 11 percent.

What we write into your program

Section 3203(a) lists eight elements. Every program we write covers each one in language your supervisors can follow:

1. Responsibility. The person or persons with authority and responsibility for implementing the program, named by role and by name.
2. Compliance. How you make sure employees follow safe work practices: recognition, training and retraining, and discipline.
3. Communication. How you talk with employees about safety in a form all of them understand, including a way to report hazards without fear of reprisal.
4. Hazard assessment. Scheduled periodic inspections, plus inspections when the program starts, when new substances, processes or equipment arrive, and when a new hazard comes to light.
5. Accident and exposure investigation. A procedure to investigate occupational injury or illness.
6. Hazard correction. How unsafe conditions get corrected in a timely manner based on severity, and who clears the area when an imminent hazard cannot be fixed on the spot.
7. Training and instruction. When the program starts, for every new employee, for new assignments, for new hazards, and for supervisors on the hazards their crews face.
8. Employee access. How an employee or a designated representative gets a copy. Section 3203(a)(8) allows no more than five business days, and the first printed copy is free.

We also set up the records section 3203(b) requires: inspection records showing who inspected, what was found and what was corrected, and training records with each employee's name, dates, type of training and provider. Both are kept for at least one year.

For contractors: the Code of Safe Practices and the meetings

Section 1509 adopts the section 3203 program for construction and adds four requirements. We write the first and set up the rest:

• A written Code of Safe Practices that relates to your operations and contains language equivalent to the relevant parts of Plate A-3 of the Appendix. Ours names your trades and leaves out the ones you never run.
• Where the Code lives. Posted at a conspicuous location at each job site office, or provided to each supervisory employee, who has to have it readily available.
• Supervisor meetings held under the direction of management to discuss safety problems and accidents that have occurred.
• Toolbox or tailgate meetings held by supervisors with their crews at least every 10 working days.

On our inspections the Code of Safe Practices check failed 262 times in 2,323 checks, 11.3 percent. Our IIPP and Code of Safe Practices guide breaks those findings down item by item.

How it works

1. The first call. Free. You tell us what the operation looks like and what prompted the call, and we tell you what it would take and what it would cost.
2. We look at what you have. Your current IIPP if there is one, your Code of Safe Practices, training records and injury records, and we walk a jobsite or the floor.
3. We write the program. Built on your operations, with your people named in each role.
4. We train the people who run it, on site, so your supervisors know what the program asks of them.
5. We keep it current project by project, or month to month as part of a Fractional EHS retainer.

When a free template is enough

Cal/OSHA publishes free model programs for high hazard employers and non-high hazard employers, and its Consultation Service helps employers at no charge, separate from enforcement. For a small, low hazard operation, a model program filled in carefully can be enough, and we will tell you so on the first call. A model program becomes a problem when it is filed without being adapted, so it lists trades the company does not run, names people who have left, and promises inspections nobody schedules.

Other written programs we write

Hazard Communication, an Emergency Action Plan, a heat illness prevention plan covering indoor and outdoor work, and for contractors site-specific safety plans. The full list is on the services page.

Where we work

We are based in San Clemente and write programs for employers across six Southern California counties: Orange, Los Angeles, San Diego, Riverside, San Bernardino and Ventura.

Common questions

Who can write an IIPP in California?

Anyone can. 8 CCR 3203 makes the employer responsible for establishing, implementing and maintaining the program, and it does not require the author to hold a license or certification. Some employers write their own from a Cal/OSHA model program. Others hire a safety consultant such as M Squared Safety to write it around their operations and name the people responsible.

Does every California employer need a written IIPP?

Yes. Section 3203(a) requires every employer to establish, implement and maintain an effective program, and the program has to be in writing. Employers with fewer than 10 employees may communicate general safe work practices to employees orally, and some employers with fewer than 20 employees may keep less written documentation of the program, but the program itself still applies.

What has to be in a California IIPP?

Eight elements under section 3203(a): the person responsible, a system for compliance, a system for communication, hazard assessment, accident and exposure investigation, hazard correction, training and instruction, and employee access to the program.

Is a Cal/OSHA model IIPP good enough?

It can be, for a small, low hazard operation that adapts it carefully. A model program filed without the names of the people responsible, the work the crews do and the inspection schedule you keep does not describe your operation, and that is what an inspector reads.

How long do IIPP records have to be kept?

Section 3203(b) requires inspection records and training records to be kept for at least one year. Employers with fewer than 10 employees may keep inspection records only until the hazard is corrected.

Does a construction company need more than an IIPP?

Yes. Section 1509 adds a written Code of Safe Practices related to the employer's operations, rules for where the Code is kept, periodic supervisor meetings under the direction of management, and toolbox or tailgate meetings with crews at least every 10 working days.

Background reading: California IIPP requirements, the eight elements of 8 CCR 3203, the IIPP and Code of Safe Practices guide and what an OSHA compliance consultant does. To talk it through, book a call.

Inspection figures come from M Squared Safety's own inspection records, November 2014 to May 2026, with duplicate copies and test entries removed. Regulation text from DIR's Title 8 pages for sections 3203 and 1509, read 25 October 2026.

M Squared Safety Solutions, Inc., 981 Calle Negocio Suite 200, San Clemente, CA 92673, 949-954-6581.