WVPP vs IIPP: What's the Difference Under SB 553?
Your IIPP does not satisfy SB 553 requirements. Learn exactly how a Workplace Violence Prevention Plan differs from an Injury and Illness Prevention Program.
Why They Must Be Separate
This is the single most common compliance mistake California employers make. Many assume their existing IIPP — which has been required since 1991 under California Labor Code Section 6401.7 — covers workplace violence prevention. It does not meet SB 553 standards.
Cal/OSHA has explicitly stated that the WVPP must be a separate document. While your IIPP covers general workplace hazards (slips, falls, chemical exposure, ergonomics), your WVPP must specifically and exclusively address workplace violence with the 12 sections required by Section 6401.9.
Key Differences
Legal basis: Your IIPP is required under Labor Code Section 6401.7 and Cal/OSHA Title 8 Section 3203. Your WVPP is required under Labor Code Section 6401.9 (SB 553). Different statutes, different requirements, different citations.
Scope: Your IIPP addresses all workplace hazards broadly. Your WVPP addresses workplace violence specifically — including types of violence (Type 1 through Type 4), specific risk factors in your workplace, and violence-specific emergency response procedures.
Incident logging: Your IIPP uses the OSHA 300 log for recording injuries. Your WVPP requires a completely separate Violence Incident Log (VIL) that captures all workplace violence incidents, even those that do not result in physical injury.
Employee involvement: While your IIPP should include employee participation, SB 553 makes employee involvement in WVPP development a specific, enforceable requirement. You must document how employees participated in creating and reviewing the plan.
Training requirements: IIPP training covers general workplace safety. WVPP training must specifically cover workplace violence prevention, recognition of warning signs, de-escalation techniques, emergency response, and how to use your reporting procedures.
Can They Reference Each Other?
Yes. Your WVPP and IIPP can reference each other, and they should where overlapping concerns exist. For example, your WVPP emergency response section can reference your IIPP's general emergency action plan. However, the WVPP must still contain all 12 required sections as a standalone document — you cannot simply write "see IIPP" in place of required content.