My X-Mod is 127% and I Got a Cal OSHA letter!
Employer Question: I just got a letter from Cal OHSA because my X-Mod exceeds 125%. What do I do now?
ESM Answer: This is notification of Cal OSHA’s High Hazard Program.
Cal OSHA can inspect employers with the “highest incidence of preventable occupational injuries and illnesses” per Labor Code §6314.1
Some of the High Hazard Triggers are:
X-Mods greater than 125%
DART “Days away, restricted, or transferred”
You must reply to the Cal OSHA letter and answer the questions as the letter directs. If you reply within the allocated time allowance you will be placed on a secondary inspection list.
If you do not reply, you will be placed on the primary inspection list and subject to inspection by Cal OSHA.
Your reply letter should describe your plan to reduce your occupational injury rates. It should identify the safety director of your IIPP, your safety committee and frequency of meetings.
Your letter should also identify your key safety hazards and how you avoid potential injury through planning, inspection, and training of employees.
If possible, identify the reason your X-Mod is over 125%, and what safety procedures or trainings that you have implemented to reduce injuries and reduce your X-Mod.
Please contact your ESM Advocate if you need assistance.