How to Navigate Cal/OSHA Regulations

In the Golden State, workplace safety within the manufacturing industry isn’t just a moral obligation but a legal imperative. A preventable workplace injury — or, even worse, a fatal accident — could have catastrophic impacts on a business, causing operational disruptions, reputational harm, financial burdens, and serious legal liability. 

The manufacturing sector's inherent risks have prompted Cal/OSHA to develop a regulatory framework designed to protect workers on the job. Cal/OSHA’s guidelines touch on practically every aspect of a manufacturer’s business — from daily operations to long-term planning. 

For the ambitious small and medium-sized manufacturers aspiring to scale, Cal/OSHA is more than a legal checkbox — it’s the foundation for a workplace that puts your team’s life and well-being at the core of its mission.

Ready to explore the intricate web of these regulations?

Understanding Cal/OSHA Regulations

Cal/OSHA is the state's governing body responsible for enforcing safety and health regulations within workplaces. Its charter is to protect and improve the health and safety of workers by: 

• Setting and enforcing standards
• Providing outreach, education, and assistance
• Issuing permits, licenses, certifications, registrations, and approvals 

How does it differ from federal OSHA? 

Cal/OSHA takes the framework established on a federal level and then advances those ideas by implementing more rigorous and specific standards tailored to California’s unique industries, challenges, and legislative rules. For instance, Cal/OSHA fall protection standards are much stricter than federal OSHA standards. 

That said, there are three key differences that separate Cal/OSHA from the federal program: 

1.  Injury and Illness Prevention Standards: Requires employers to have a written Injury and Illness Prevention Program (IIPP) that identifies and addresses workplace hazards.
2.  Reporting Requirements: Cal/OSHA has more stringent reporting requirements.
3.  Coverage: Cal/OSHA covers a wider range of industries, including hospitality, healthcare, and agriculture. 

While Cal/OSHA has general guidelines that govern every industry, they also have industry-specific rules based on the particular hazards and issues most commonly associated with those workplaces, including regulations designed specifically for the manufacturing sector. These manufacturing-specific regulations address challenges unique to the field and are expressly designed to enhance safety and compliance.

The Key Facets of Cal/OSHA for Manufacturers

There are hundreds of pages detailing the regulations and requirements set by Cal/OSHA for the manufacturing industry, with special attention paid to the three major manufacturing industries in the state: metal, lumber, and food. 

Understanding and complying with these rules can be a daunting task. So, here's a condensed look at some of the primary concerns...

Injury & Illness Prevention Program Requirements

The California Labor Code §6400 states: “Every employer shall furnish employment and a place of employment that is safe and healthful for the employees therein.” 

Now combine this with California Labor Code §6401, which states: “Every employer shall do every other thing reasonably necessary to protect the life, safety, and health of employees.”

These labor codes point toward one thing — Cal/OSHA requires building out a comprehensive IIPP. This program establishes various critical elements in writing that must be maintained and followed by employers. Essential aspects of this include: 

• Responsibility: Specifies the individual with the authority for its implementation (employees must be able to identify this individual)
• Compliance: Establishes written policies to ensure employees adhere to safe work practices
• Communication: Establishes that a system for discussing safety matters with employees must be established, including safety meetings, training, and notifications
• Hazard assessment: Details procedures for identifying, evaluating, and addressing common workplace hazards
• Accident/Exposure Investigation: Establishes procedures for investigating workplace injuries or illnesses
• Hazard Correction: Documents methods for timely correction of unsafe work conditions, including specific abatement methods
• Training and instruction: Creates a program designed to instruct employees on safe work practices and job-specific hazards as well as ensure their continued work safety education
• Recordkeeping: Establishes a system for documenting and maintaining records of an IIPP
• Reporting: Creates a process in which all employers report all employees’ serious work-related injuries or fatalities to the nearest office of the Division of Occupational Safety and Health (DOSH) within eight hours

For smaller employers — primarily those with fewer than 20 employees in low-hazard industries — there may be an exemption to the Injury & Illness Prevention Program (or fewer stringent documentation requirements).

Essential Safety Measures for Manufacturers

Within the general Cal/OSHA manufacturing regulations, all manufacturers must pay special attention to the following four areas of OSHA compliance: 

1.  Personal Protective Equipment (PPE) Requirements: High-quality PPE must be provided to workers based on specific workplace hazards. This includes body, head, eye & face, foot, hand, hearing, radiant energy, and respiratory protection. Safety belts are essential as well.
2.  Hazard Materials and Conditions: Employers must educate and protect employees from hazardous materials and conditions like airborne contaminants, exhaust emissions, carcinogens, combustible dust, corrosive liquids, flammable liquids, flammable vapors, and confined spaces. Adequate training and preventive measures must be implemented to mitigate these risks.
3.  Safe Equipment Operation and Maintenance: Ensuring proper and safe operation of machinery and equipment is paramount. Regular maintenance, inspections, and safety protocols must be in place to prevent accidents and ensure smooth operation.
4.  Signage: Employers must hang safety information for employees, including hazard communication, safety information, and compliance obligations.

By incorporating these into your workplace practices, you not only avoid fines or fees from OSHA, but you also keep your team safe.

Inspections, Citations, and Appeals

To ensure that companies comply with Cal/OSHA regulations, OSHA may conduct on-site inspections. 

The most common reason for an inspection is when OSHA receives a complaint of a workplace safety or health hazard or a report of a fatality or serious work-related injury or illness. However, OSHA may conduct targeted, unannounced inspections if they so choose. 

Typically, when a complaint is lodged, OSHA will take one of two actions: 

1.  Conduct an unannounced on-site inspection
2.  Send an investigative letter to the employer 

After an on-site inspection by Cal/OSHA, the employer is notified of any violations and corresponding citations and fines. A citation packet, including appeal instructions, is provided, and the employer must post copies of citations or a letter of the findings to employees. 

Employers have the right to file an appeal. If they do so, hazard correction may be delayed until after the hearing.

OSHA Penalties

The range of fines and fees resulting from Cal/OSHA violations can vary widely, reflecting the severity and frequency of the infractions. If violations are found to be willful, the financial consequences may escalate even further. As such, fines can span from mere hundreds of dollars for minor or isolated incidents to tens of thousands for each violation in cases of repeated or intentional disregard for safety regulations.

CMTC Partnership: Supporting Manufacturers’ Cal/OSHA Compliance

Navigating the multifaceted landscape of Cal/OSHA compliance is no small feat — particularly for small and medium-sized manufacturers in California, where regulations are ever-changing. That's where CMTC comes in. Whether you need expert guidance to demystify the complex web of Cal/OSHA regulations, support in crafting safety assessments and tailor-made plans, or practical training that spans best practices and compliance, CMTC is here to help. 

CMTC’s goal is to ensure that the companies we work with understand the applicable safety standards and continuously keep employee safety in mind. We provide smaller manufacturers with the resources of larger companies. 

Our manufacturing experts analyze risks from an industrial safety standpoint and advise on potentially hazardous situations. And, when they are found? Our team will make recommendations about how to remediate the hazards so that the client can ensure that safety gaps are closed and compliance is maintained with regulatory and legal requirements.

Don't wait — reach out to CMTC today!