A contractor with six employees brings a new solvent into the yard in March, has an outside safety consultant walk the site in June, and is told in September of a hazard nobody had recognised before. Which of these events triggered an IIPP hazard inspection duty?
Explanation
Section 3203(a)(4) names the triggers as events, not as a date on the calendar: when the programme is first established, whenever a new substance, process, procedure or equipment is introduced that represents a new occupational safety and health hazard, and whenever the employer is made aware of a new or previously unrecognised hazard, alongside scheduled periodic inspections. The March solvent and the September hazard are two of those triggers. A consultant's visit satisfies none of them by itself. There is no small-employer exemption from having and running a written programme; fewer than ten employees only changes how long inspection records must be kept.
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