Understanding the Differences Between the Fed/OSHA General Duty Clause and the Cal/OSHA Injury and Illness Prevention Program

Presented by Rachel Conn, Megan Shaked, and Andrea Chavez

The Federal OSHA General Duty Clause requires employers to provide a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Employers may be cited under this provision when a serious, recognized hazard exists, and reasonable steps to prevent or correct the hazard have not been taken. Because it applies when no specific OSHA standard addresses a particular risk, the General Duty Clause often serves as a broad, catch-all enforcement tool.

In contrast, California’s Injury and Illness Prevention Program (IIPP) is a proactive, mandatory safety regulation that requires every employer to maintain a written and effectively implemented workplace safety program. The IIPP goes beyond addressing only serious or fatal hazards—it requires employers to identify, evaluate, investigate, and correct unsafe or unhealthy conditions, work practices, and procedures. As a result, IIPP violations are among the most frequently cited by Cal/OSHA.

This webinar will compare the scope, requirements, and enforcement of the General Duty Clause and the IIPP, highlighting their key similarities and differences. Attendees will gain practical guidance on compliance expectations and actionable steps employers can take to strengthen safety programs and reduce enforcement risk.

The request for 1.00 General California Minimum Continuing Legal Education (MCLE) credit is pending approval.