California IIPP Template for NEMT Companies: The Injury and Illness Prevention Program

A driver strains her back lifting a rider over a curb. A lift platform pinches a hand. A van’s air conditioning quits at 2 p.m. in Riverside with a dialysis rider on board. California’s Injury and Illness Prevention Program rule, 8 CCR 3203, asks every employer to find hazards like these, fix them, train for them, and write down how. This template is that program, filled in for vans, lifts, curbside pickups, and the dispatch office, and sized for a company with a handful of employees.

How to use this template

1. Name the person responsible in Part 1. In a small company that is usually the owner. Write down who helps, such as a lead driver who trains or a fleet manager who handles repairs.
2. Walk through your operation before you fill in Part 4: ride along on a few trips, watch a lift cycle and a wheelchair securement, look at the yard and the office, and ask drivers what worries them.
3. Fill in Parts 2 to 11. Change the sample rows to match what you really do. Delete what does not fit and add what is missing.
4. Do the first inspection with Part 5 and fix what you find with Part 7. Section 3203 requires an inspection when the program is first set up.
5. Train everyone on the program with Part 8, in a language each employee understands, and record it.
6. Attach your other written plans or note where they are kept: the workplace violence prevention plan, the heat plan in Part 9, and an exposure control plan if drivers clean up blood.
7. Sign it and keep it where employees can reach it, and tell every employee how to get a copy (Part 10).
8. Review it after any injury, when you add a new kind of vehicle or service, and at least once a year.

What to do in a storm, a wildfire, or a road closure lives in your NEMT emergency plan. The injury log, the job safety poster, and the reporting rules are in the OSHA guide for NEMT companies. This program sits above both: it is how the company finds and fixes hazards to its own workers.

The template

Part 1: Program details and the person responsible

Field	Entry
Company name
Effective date
Program administrator, with the authority and responsibility to run this program: name, title, phone
Others with duties (trainer, fleet or maintenance lead, dispatch lead) and what each does
Workers covered: every employee, plus any worker we control and directly supervise
Written plans that are part of this program, and where each is kept	Workplace violence prevention plan: ______. Heat illness plan: Part 9. Exposure control plan: ______. Emergency plan: ______.
Where employees can read this program
Approved by the owner, signature and date

Part 2: How we make sure everyone works safely

Method	How we do it here
Before the first solo trip	Training in Part 8 and a road test with a trainer
Spot checks	Ride-alongs, lift and securement checks every ______
Recognition	______ for drivers who follow safe practices and report hazards, never for having no injuries on record
Retraining	After an injury, a near miss, a crash, a securement complaint, or a failed spot check
Discipline	Written steps for ignoring safety rules, applied to everyone, supervisors included

Part 3: How we talk about safety

Method	How often	Who runs it
Safety meeting, in person or by call
Safety notes with the weekly schedule or by text
Hazard report form or phone line, name optional
Alerts about a new hazard (a loose dog at an address, a broken ramp at a clinic, a road closure)	As soon as dispatch learns of it	Dispatch
Posted notices at dispatch and the yard

We talk about safety in words and a language each employee understands. Report any hazard, injury, or near miss to ______. No one is punished for reporting a hazard or an injury, or for complaining about safety to us or to Cal/OSHA.

Part 4: Hazards in our work and how we control them

Hazard	Our controls	Checked by and date
Lifting and transfers: car seat to wheelchair, curbs, steps	Gait belts to guide, never to lift, no lifting a rider’s full weight by hand, a stair chair or second person for steps, and the right to stop and call dispatch (safe transfers)
Ramps and lifts	Lift check before the first trip of the day (lift log), stand clear of the platform edge, know the manual backup
Securing wheelchairs at floor level	Knee pads, room to kneel, four tie-downs and a lap and shoulder belt every time, no twisting under load
Driving: phones, fatigue, speed, backing	Phones mounted and used hands-free (Vehicle Code 23123.5), no shift longer than ______ hours, a walk-around before backing, seat belts on for everyone
Heat inside vans and at the curb	Part 9
Blood, vomit, and other body fluids	Gloves and a spill kit in each van, and the exposure control plan
Violence and threats from riders or strangers	The workplace violence prevention plan
Slips and trips at homes and clinics: wet ramps, dark steps, ice, pets	Non-slip shoes, a flashlight in each van, a call ahead to put pets away, unsafe entries reported to dispatch
Oxygen tanks	Secured against shifting, away from heat, no smoking in or near the van (riders with oxygen)
Cleaning and disinfecting products	Use and store each one as its label says, gloves on, doors open while cleaning
Yard, fueling, and charging	Lighting, marked walkways, no running engines in closed spaces
Office and dispatch	Breaks from screens and headsets, adjustable chairs, a clear exit

Part 5: Inspections

We inspect:

• When this program is first set up
• When we add a vehicle, lift, stretcher, chemical, or procedure that brings a new hazard
• When we learn of a new or overlooked hazard, from an injury, a near miss, or a report
• On a schedule: each vehicle every ______, the yard and office every ______, a ride-along with each driver every ______

Date	Vehicle or area	Inspected by	Unsafe condition or practice found	Fix, by whom, and date done

Part 6: Investigating an injury or illness

1. Get first aid or call 911. Make sure the employee is not alone.
2. If an employee died or was seriously injured, such as admitted to a hospital beyond observation, call Cal/OSHA as soon as you can and no later than 8 hours after you knew. Cal/OSHA’s definition of a serious injury leaves out injuries from a crash on a public street or highway outside a construction zone.
3. If the injury needs treatment beyond first aid or costs time beyond the shift, give the employee a workers’ comp claim form and a notice of potential eligibility for benefits within one working day.
4. Protect the scene. Take the van or lift out of service if it may be at fault, and take photos.
5. Talk with the employee and any witnesses the same day.
6. Find the causes, not just the act: equipment, procedure, training, schedule, staffing, or conditions at the stop.
7. Fix them with Part 7, and tell employees what changed.

Field	Entry
Date, time, and place
Employee and job
What happened
Injury or illness
Causes found
Fix and date done
Cal/OSHA called (date, time, by whom), if required
Claim form given (date)
Investigated by, and date

Part 7: Fixing hazards

We fix unsafe conditions and practices in a timely way, faster for worse hazards. When a hazard could seriously hurt someone and cannot be fixed at once, we pull everyone away from it except the people needed to fix it, and we protect them while they do. A van with failing brakes, or a lift whose safety interlock fails, comes out of service until it is repaired.

Date found	Hazard	How bad (imminent, serious, minor)	Fix	Who	Date done

Part 8: Training

We train	Done
Every employee when this program starts
Every new employee before working alone
Every employee given a new kind of work, such as a first stretcher run or a first dispatch shift
Everyone affected when we add a vehicle, lift, chemical, or procedure that brings a new hazard
Everyone affected when we learn of a new or overlooked hazard
Supervisors, on the hazards their staff face

Topics: this program and how to get a copy, how to report hazards and injuries, the hazards and controls in Part 4, lift and securement, safe transfers, heat (Part 9), body fluids, violence and threats, and what to do after an injury (Part 6).

Employee name or ID	Date	Type of training	Trainer

Part 9: Heat illness prevention plan

This plan is written in English and in ______, the language most of our employees understand.

Item	Our procedure
Water	Cold, clean drinking water in every van, free, at least 1 quart per employee for each hour of the shift, refilled at ______
Cooling off	A van running with working air conditioning, or a cool indoor space at the stop. A van sitting in the sun without the air conditioning running does not count. Any employee may take a cool-down rest whenever they need one.
Air conditioning	Checked on every pre-trip inspection. If it fails on a hot day, the driver calls dispatch, and we swap the van or end the route.
Heat waves and new drivers	Dispatch checks in with every driver during a heat wave, and watches a driver new to hot routes closely for their first 14 days
Emergency response	Know the signs, cool the person, call 911 and give the exact location, and never leave someone with symptoms alone or send them home without first aid
Training	Before the first shift in hot weather: the risk factors, water and rest, acclimatization, the signs and first aid, and how to call for help
Hot vans without air conditioning	If the temperature or heat index in a van reaches 87 degrees with an employee in it, we measure and record it and use controls to bring it down

Part 10: Employee access to this program

Any employee, or a representative they authorize in writing, may read and get a copy of this program. We provide it within 5 business days of the request. The first printed copy is free, and an electronic copy is fine if the person agrees. To ask, contact ______, or open it at ______.

Part 11: Records we keep

Record	Keep at least	Where we keep it
Inspections and fixes (Parts 5 and 7)	1 year, or until the hazard is fixed if we have fewer than 10 employees
Training (Part 8)	1 year
Injury investigations (Part 6)	______
Indoor heat measurements (Part 9)	12 months, or until the next measurements, whichever is later
Cal/OSHA injury and illness log and summary, if we must keep them	5 years
Safety committee minutes, if we use a committee	1 year
Workplace violence incident log, hazards, and investigations	5 years

What 8 CCR 3203 requires, part by part

Section 3203 asks for a written program that is effective in practice, not just on paper. Cal/OSHA’s guide to the rule (June 2024) warns that an inspector may ask you to show the program works. Each part of the template answers one piece of the rule.

Template part	What it covers	8 CCR 3203
Part 1	The person responsible	(a)(1)
Part 2	Making sure employees follow safe practices	(a)(2)
Part 3	Communication, and reporting hazards without fear	(a)(3)
Parts 4 and 5	Finding hazards, with scheduled inspections	(a)(4) and (b)(1)
Part 6	Investigating injuries and illnesses	(a)(5)
Part 7	Fixing hazards, including imminent ones	(a)(6)
Part 8	Training, and training records	(a)(7) and (b)(2)
Part 10	Employee access to the program	(a)(8)
Part 11	Records	(b)

• Who it covers. The program covers all your employees and any other worker you control or direct and directly supervise on the job, such as a temp from an agency (Labor Code 6401.7(h)).
• Communication. It must be in a form every affected employee can understand, and it must encourage employees to report hazards without fear of reprisal (8 CCR 3203(a)(3)). Labor Code 6310 bars firing or punishing an employee for a safety complaint to you or to Cal/OSHA. A labor and management safety committee that meets at least quarterly, keeps minutes for a year, reviews inspections and injury investigations, and does the other tasks 3203(c) lists is presumed to meet the communication rule.
• Inspections and training. Both are required when the program starts, when new substances, processes, procedures, or equipment bring a new hazard, and when you learn of a new or overlooked hazard. Training also goes to every new employee, to employees given new assignments, and to supervisors on their staff’s hazards (3203(a)(4) and (a)(7)).
• Records. Inspection records name who inspected, what was found, and what was done, and are kept at least 1 year. Training records show the employee’s name or another identifier, the dates, the type of training, and the trainer, also kept at least 1 year (3203(b)).
• Access. Since July 1, 2020, an employee or an authorized representative can get the program within 5 business days of asking, and you must tell every employee how to ask (3203(a)(8)). The copy need not include your records.

Rules for companies under 10 and under 20 employees

Small companies still need the program, with less paperwork:

• Fewer than 10 employees. You may communicate and give general safety instruction out loud, with specific instruction on each job’s hazards. You may keep each inspection record only until the hazard is fixed, and record training as a log of the instructions each employee got when hired or given new duties (3203(a)(3) and (b)).
• Fewer than 20 employees. If your industry is not on the high hazard industry list Cal/OSHA keeps under Labor Code 6401.7(e)(3) and your workers’ comp experience modification rate is 1.1 or less, the written documents may be limited to who runs the program, the scheduled inspections, and the training (3203(b), Exception 3). Cal/OSHA’s High Hazard Industry List for federal fiscal year 2026 to 2027 does not include special needs transportation (NAICS 485991). It does include other ambulatory health care services (NAICS 6219), the group that holds ambulance services (621910). Check which code describes your company before you count on the exception.
• A high experience mod. If your experience modification is 2.0 or higher, your workers’ comp insurer must review your IIPP and write a report within six months of the start of the first policy term (Labor Code 6401.7(l)). See workers’ comp for NEMT.

Even with lighter paperwork, the other plans still have to be in writing: the workplace violence plan, the heat plan, and an exposure control plan where it applies.

The written plans that sit inside or beside your IIPP

• Workplace violence prevention. Labor Code 6401.7(a)(7) lists a workplace violence prevention plan that meets 6401.9 among the program’s elements. You may keep that plan as a stand-alone section of the IIPP or as a separate document (6401.9(c)(1)(B)). A place with fewer than 10 employees at a time and no public access is exempt only if it complies with section 3203 (6401.9(b)(2)(F)). Your vans carry riders, so use the California workplace violence prevention plan template. Work covered by Cal/OSHA’s health care violence rule, 8 CCR 3342, which names medical transport, follows that rule instead (6401.9(b)(2)(A)), and the template explains how to tell which applies.
• Heat, inside the van. Under 8 CCR 3396, operative July 23, 2024, indoor means a space under a ceiling and enclosed by walls, doors, windows, or other barriers, whether open or closed. That describes a van, and the rule names vehicles in its exceptions. The rule applies when an indoor work area reaches 82 degrees with employees present. Its exception for short exposures does not apply to vehicles without effective, working air conditioning, and vehicles with it are exempt from the measuring step (3396(a) and (e)). At 87 degrees, by temperature or heat index, you must measure, record, and use controls to bring the heat down.
• Heat, outside the van. All work areas that are not indoor are outdoor and covered by 8 CCR 3395: loading at the curb, walking a rider to the door, waiting at the yard. It requires fresh, free, suitably cool water, enough for 1 quart per employee per hour when it is not plumbed, and shade when it is over 80 degrees. Under its definition of shade, a car in the sun is not shade unless it is running with air conditioning (3395(b) to (d)). Passenger transportation is not on the list of industries that must follow the high-heat procedures at 95 degrees (3395(a)(2)). Both heat rules require a written plan in English and the language most employees understand, and both let you put it in the IIPP (3395(i) and 3396(i)).
• Blood and body fluids. An employer with employees who have occupational exposure needs a written exposure control plan consistent with section 3203 (8 CCR 5193(c)).
• First aid. Where no clinic or hospital is in near proximity, someone must be trained in first aid to a level equal to the American Red Cross. First aid materials approved by the consulting physician must be readily available on every job and inspected often (8 CCR 3400(b) and (c)). Treat each van as a job site, and stock it with the first aid kit checklist.

For everything else a NEMT company needs in California, from Medi-Cal enrollment to vehicle rules, see the California guide. To turn Part 4 into written driver rules, see NEMT policies and procedures.

What a missing or weak IIPP costs, and free help

As section 336 of title 8 reads in October 2026 (last amended operative January 1, 2025), Cal/OSHA may assess up to $16,285 for a general or regulatory violation. A serious violation carries up to $25,000, starting from an $18,000 base before adjustments. A willful violation runs from $11,632 to $162,851. The gravity-based penalty comes down 40 percent for employers with 10 or fewer employees, 30 percent for 11 to 25, 20 percent for 26 to 60, and 10 percent for 61 to 100, with further reductions for good faith and history (8 CCR 336). If you have no working injury prevention program, a serious violation’s penalty can come down only for size, not for good faith or history (336(d)(8)).

Cal/OSHA Consultation gives free help by phone, email, or a visit, at 1-800-963-9424. Its guide to developing an IIPP (June 2024) and its model programs are worth reading next to this template. Fill in your own program rather than copying a model word for word, because the program has to match the hazards you really have.