Association Employers: Are You IIPP Compliant in the Age of COVID-19?

By Mandy D. Hexom, Esq.

As association employees return or continue to work, association employers must review its policies and procedures, making sure they are compliant with the CDC, state, and local guidelines for operating businesses with employees during the pandemic. In addition to these policies that you may already be familiar with, it is now time to make sure association employers are compliant with the IIPP requirement.

An IIPP is an Injury Illness Prevention Program required by law for all employers. Because COVID-19 infection is a potential hazard in an association workplace, the association employer must implement infection control measures, including applicable and relevant documentation from the CDC and a written IIPP.

On May 6, 2020, California Governor Newsom signed an executive order that creates a rebuttable presumption that an employee who tests positive for COVID-19 contracted it within the course and scope of employment for purposes of workers compensation if the employee tests positive within 14 days after performing labor or services at the place of employment and at the employer’s direction. This order is scheduled to remain in place until July 5, 2020 as of the date of this article.

Why do we need an IIPP and what is it?

  • An IIPP is required by Labor Code section 6401.7 and 8 CCR section 3203 for all California employers.
  • The purpose of an IIPP is to protect employees from workplace hazards, including infectious diseases. The California Department of Industrial Relations has created an easy tool on how to create an IIPP, which can be found by clicking here.
  • An IIPP must be in writing and be effective.

Now is the time to be proactive and update or create the necessary policies and procedures in the age of COVID-19.

For more information, visit these useful websites:

If your association has questions about an IIPP or other required policies or procedures related to COVID-19, please contact us.

Keywords: Covid-19, Coronavirus