Section 3203 of Title 8 of the California Code of Regulations (8 CCR § 3203) requires all California employers to have a written, effective Injury and Illness Prevention (IIP) program that addresses hazards pertaining to the particular workplace covered by the program. The IIP Program facilitates employers and employees working together to carry out effective accident, injury, and illness prevention on the job.
The Cal/OSHA Consultation Service publishes guidelines and model programs to help employers develop and carry out their IIP Programs. Onsite consultation assistance is also available for evaluating and improving the program. Development and conscientious implementation of a comprehensive program may result in lower injury, illness, and fatality rates as well as reduced workers’ compensation costs.
Reasons for a Workplace Injury and Illness Prevention Program
Taking risks is part of running a business, particularly for small business owners. Employers take risks in product development, marketing, and advertising in order to stay competitive, but one of the risks employers should not gamble with is the safety and health of its employees.
Accidents Can Be Costly
Safety organizations, states, small business owners, and major corporations all realize that the actual cost of a lost workday injury is substantial. For every dollar employers spend on the direct costs of a worker’s injury or illness, they spend much more to cover the indirect and hidden costs. Consider what one lost workday injury would cost in terms of:
- Productive time lost by an injured employee.
- Productive time lost by employees and supervisors attending the accident victim.
- Clean up and start up of operations interrupted by the accident.
- Time to hire or to retrain other individuals to replace the injured worker until his or her return.
- Time and cost for repair or replacement of any damaged equipment or materials.
- Cost of continuing all or part of the employee’s wages, in addition to compensation.
- Reduced morale among employees, and perhaps lower efficiency.
- Increased workers’ compensation insurance rates.
- Cost of completing paperwork generated by the incident.
To reduce the costs and risks associated with workplace injuries and illnesses, employers must address safety and health right along with production. An effective way to do this is by setting up an Injury and Illness Prevention Program. In developing the program, an employer can identify what has to be done to promote the safety and health of its employees and worksite, and then outlines policies and procedures to achieve these safety and health goals.
Cal/OSHA Injury and Illness Prevention Program
As stated previously, all California employers are required by law to provide a safe and healthful workplace for their employees. Title 8 (T8) of the California Code of Regulations (CCR), requires every California employer to have an effective Injury and Illness Prevention (IIP) Program in writing that must be in accord with T8 CCR § 3203 of the General Industry Safety Orders. Additional requirements in the T8 CCR Safety Order Sections address specific industries:
- Construction — § 1509.
- Petroleum — §§ 6507, 6508, 6509, 6760, 6761, 6762.
- Ship Building, Ship Repairing, Ship Breaking — § 8350.
- Tunnels — § 8406.
Elements of an IIP Program
All of the following elements must be established and maintained — in writing — in the employer’s IIP Program:
- Management commitment/assignment of responsibilities.
- Safety communications system with employees.
- System for assuring employee compliance with safe work practices.
- Scheduled inspections/evaluation system.
- Accident investigation.
- Procedures for correcting unsafe/unhealthy conditions.
- Safety and health training and instruction.
- Recordkeeping and documentation.
Management Commitment/Assignment of Responsibilities
An employer’s commitment to safety and health shows in every decision and every action the employer takes. Employees will respond to that commitment.
The person or persons with the authority and responsibility for the safety and health program must be identified and given management’s full support. Management can demonstrate commitment through personal concern for employee safety and health and by the priority placed by the company on these issues.
For maximum production and quality, employers need to control potential workplace hazards and correct hazardous conditions or practices as they occur or are recognized. Management and the company must commit by building an effective Injury and Illness Prevention Program and integrating it into the entire operation. This commitment must be backed by strong organizational policies, procedures, incentives, and disciplinary actions as necessary to ensure employee compliance with safe and healthful work practices.
These practices should include:
- Establishment of workplace objectives for accident and illness prevention, like those you establish for other business functions such as sales or production for example: “Ten percent fewer injuries next year,” “Reduce down-time due to poorly maintained equipment.”
- Emphasis on staff’s safety and health responsibilities and recognition by supervisors and employees that they are accountable. Advise management staff that they will be held accountable for the safety record of the employees working under them, and then back it up with firm action.
- A means for encouraging employees to report unsafe conditions with assurance that management will take action.
- Allocation of company resources including financial, material, and personnel for:
- Identifying and controlling hazards in new and existing operations and processes, and potential hazards.
- Installing engineering controls.
- Purchasing personal protective equipment.
- Promoting and training employees in safety and health.
- Setting a good example. If, for instance, hard hats are required to be worn in a specific area, then management must also wear a hard hat in that area. If the management team does not support and participate in the program, the program is doomed to failure from the start. It is especially important for plant supervisors and field superintendents to set a good example.
The IIP Program must include a system for communicating with employees — in a form readily understandable by all affected employees — on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal.
While this section does not require employers to establish labor-management safety and health committees, it is an option that should be considered. If chosen, remember that employers who elect to use a labor-management safety and health committee to comply with the communication requirements are presumed to be in substantial compliance if the committee:
- Meets regularly but not less than quarterly.
- Prepares and makes available to affected employees written records of the safety and health issues discussed at the committee meetings, and maintained for review by the Division of Occupational Safety and Health (division) upon request.
- Reviews results of the periodic scheduled worksite inspections.
- Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness, or exposure to hazardous substances, and where appropriate, submits suggestions to management for the prevention of future incidents.
- Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, it may conduct its own inspection and investigation to assist in remedial solutions.
- Submits recommendations to assist in the evaluation of employee safety suggestions.
- Upon request of the division, verifies abatement action taken by the employer to abate citations issued by the division.
If employees are not represented by an agreement with an organized labor union, and part of the employee population is unionized, the establishment of labor-management committees is considerably more complicated. Request clarification from the Cal/OSHA Consultation Service.
If electing not to use labor-management safety and health committees, be prepared to formalize and document the required system for communicating with employees.
Here are some helpful tips on complying with this difficult section:
- The communication system must be in a form “readily understandable by all affected employees.” This means that employers should be prepared to communicate with employees in a language they can understand, and if an employee cannot read in any language, the information must be communicated to him or her orally in a language “readily understandable.” The communication system must be “designed to encourage employees to inform the employer of hazards at the workplace without fear of reprisal”; it must be a two-way system of communication.
- Schedule general employee meetings at which safety is freely and openly discussed by those present. Such meetings should be regular, scheduled, and announced to all employees so that maximum employee attendance can be achieved. Remember to do this for all shifts. Many employers find it cost effective to hold such meetings at shift change time, with a brief overlap of schedules to accomplish the meetings. If properly planned, effective safety meetings can be held in a 15 to 20 minute time frame. Employers should concentrate on:
- Occupational accident and injury history at their own worksite, with possible comparisons to other locations in the company.
- Feedback from the employee group.
- Guest speakers from the workers’ compensation insurance carrier or other agencies concerned with safety.
- Brief audio-visual materials that relate to the industry.
- Control of the meetings.
- Stress that the purpose of the meeting is safety. Members of management should attend this meeting.
- Training programs are excellent vehicles for communicating with employees.
- Posters and bulletins can be effective ways of communicating with employees. Useful materials can be obtained from Cal/OSHA, the workers’ compensation insurance carrier, the National Safety Council, or other commercial and public service agencies.
- Newsletters or similar publications devoted to safety are also effective communication devices. If an entire publication is not plausible, make safety a featured item in every issue of the company newsletter.
- A safety suggestion box can be used by employees, anonymously if desired, to communicate their concerns to management.
- Publish a brief company safety policy or statement informing all employees that safety is a priority issue with management, and urge employees to actively participate in the program for the common good of all concerned (see model policy statement).
- Communicate concerns about safety to all levels of management.
- Document all communication efforts in order to demonstrate that a system of effective communication is in place.
Hazard Assessment and Control
Periodic inspections and procedures for correction and control provide a method of identifying existing or potential hazards in the workplace, and eliminating or controlling them. Hazard control is the heart of an effective Injury and Illness Prevention Program.
If hazards occur or recur, this reflects a breakdown in the hazard control system. The hazard control system is also the basis for developing safe work procedures and injury/illness prevention training.
The required hazard assessment survey of an employer’ establishment, when first developing the Injury and Illness Prevention Program, must be made by a qualified person. This survey can provide the basis and guide for establishing an effective hazard assessment and control system. The survey produces knowledge of hazards that exist in the workplace, and conditions, equipment, and procedures that could be potentially hazardous.
An effective hazard control system will identify hazards that exist or develop in the workplace, how to correct those hazards, and steps employers can take to prevent their recurrence. If an effective system for monitoring workplace conditions is in place:
- Many hazards may be prevented from occurring through scheduled and documented self-inspections. Make sure established safe work practices are being followed and those unsafe conditions or procedures are identified and corrected properly. Scheduled inspections are in addition to the everyday safety and health checks that are part of the routine duties of managers and supervisors. The frequency of these inspections depends on the operations involved, the magnitude of the hazards, the proficiency of employees, changes in equipment or work processes, and the history of workplace injuries and illnesses. Inspections should be conducted by personnel who, through experience or training, are able to identify actual and potential hazards and understand safe work practices. Written inspection reports must be reviewed by management and/or the safety committee. The review should assist in prioritizing actions and verify completion of previous corrective actions. Overall inspection program results should be reviewed for trends.
- Know which Cal/OSHA safety orders contained in Title 8 of the California Code of Regulations apply to your workplace and use them to identify potential hazards. A Cal/OSHA Consultation Service consultant or outside consultant can assist you in identifying safety orders applicable to your work.
- Employees should be encouraged to tell management or their supervisors of possibly hazardous situations, knowing their reports will be given prompt and serious attention without fear of reprisal. In letting them know that the situation was corrected (or why it was not hazardous), management creates a system by which employees continue to report hazards promptly and effectively.
- Workplace equipment and personal, protective equipment should be maintained in safe and good working condition. In addition to what is required by Cal/ OSHA standards, an employer’ own program monitors the operation of workplace equipment, and can also verify that routine preventive maintenance is conducted and personal protective equipment is reliable. This makes good safety sense, and proper maintenance can prevent costly breakdowns and undue exposures.
- Hazards should be corrected as soon as they are identified. For any that cannot be immediately corrected, set a target data for correction based on such considerations as the probability and severity of an injury or illness resulting from the hazard; the availability of needed equipment, materials and/or personnel; time for delivery, installation, modification or construction; and training periods. Provide interim protection to employees who need it while correction of hazards is proceeding. A written tracking system such as a log helps monitor the progress of hazard correction.
- Continue to review and prioritize the program based on the severity of the hazard.
A primary tool employers should be using in an effort to identify and recognize the areas responsible for accidents is a thorough and properly completed accident investigation. It should be in writing and adequately identify the cause(s) of the accident or near-miss occurrence.
Accident investigations should be conducted by trained individuals, and with the primary focus of understanding why the accident or near miss occurred and what actions can be taken to preclude recurrence. In large organizations this responsibility may be assigned to the safety director. In smaller organizations the responsibility may lie directly with the supervisor responsible for the affected area or employee. Questions to ask in an accident investigation include:
- What happened? The investigation should describe what took place that prompted the investigation: an injury to an employee, an incident that caused a production delay, damaged material or any other conditions recognized as having a potential for losses or delays.
- Why did the incident happen? The investigation must obtain all the facts surrounding the occurrence: what caused the situation to occur; who was involved; was/were the employee(s) qualified to perform the functions involved in the accident or near miss; were they properly trained; were proper operating procedures established for the task involved; were procedures followed, and if not, why not; where else this or a similar situation might exist, and how it can be corrected.
- What should be done? The person conducting the investigation must determine which aspects of the operation or processes require additional attention. It is important to note that the purpose here is not to establish blame, but to determine what type of constructive action can eliminate the cause(s) of the accident or near miss.
- What action has been taken? Action already taken to reduce or eliminate the exposures being investigated should be noted, along with those remaining to be addressed. Any interim or temporary precautions should also be noted. Any pending corrective action and reason for delaying its implementation should be identified.
Corrective action should be identified in terms of not only how it will prevent a recurrence of the accident or near miss, but also how it will improve the overall operation. This will assist the investigation in offering solutions to management. The solution should be a means of achieving not only accident control, but also total operation control.
If the organization has a safety and health committee, its members should review investigations of all accidents and near-miss incidents to assist in recommending appropriate corrective actions to prevent a similar recurrence.
Thorough investigation of all accidents and near misses will help to identify causes and needed corrections, and can help employers determine why accidents occur, where they happen, and any accident trends. Such information is critical to preventing and controlling hazards and potential accidents.
Safety Planning, Rules, and Work Procedures
Planning for safety and health is an important part of every business decision, including purchasing, engineering, changes in work processes, and planning for emergencies. Safety and health planning are effective when the workplace has:
- Rules written to apply to everyone and addressing areas such as personal protective equipment, appropriate clothing, expected behavior, and emergency procedures. Management and employees should periodically review and update all rules and procedures to make sure they reflect present conditions. Rules and procedures should be written for new exposures when they are introduced into the workplace.
- Safe and healthful work practices developed for each specific job.
- Discipline or reward procedures to help assure that safety rules and work procedures are put into practice and enforced. Reward or positive reinforcement procedures such as bonus, incentive, or employee recognition programs should provide positive motivation for compliance with safety rules and procedures.
- A written plan for emergency situations. The plan must include a list of emergencies that could arise and a set of procedures in response to each situation. Some emergency procedures, such as those covering medical emergencies or fire evacuation, are mandated by Cal/OSHA regulations.
- If the workplace has operations involving hazardous substances, procedures, or processes, the employer must designate emergency response teams to be specifically trained and equipped to handle possible imminent hazards.
Safety and Health Training
Training is one of the most important elements of any Injury and Illness Prevention Program. It allows employees to learn their job properly, brings new ideas into the workplace, reinforces existing ideas and practices, and puts the program into action.
Employees benefit from safety and health training through fewer work-related injuries and illnesses, and reduced stress and worry caused by exposure to hazards. The employer benefits from reduced workplace injuries and illnesses, increased productivity, lower costs, higher profits, and a more cohesive and dependable work force.
An effective Injury and Illness Prevention Program includes training for both supervisors and employees. Training for both is required by Cal/OSHA safety orders.
Employers may need outside professionals to help develop and conduct the required training program. Assistance is available from the Cal/OSHA Consultation Service, the employer’ workers’ compensation insurance carrier, private consultants, and vendor representatives.
Employers should consider outside trainers as temporary, as eventually in-house training capabilities will be needed in order to provide training that is timely and specific to the needs of the workplace and employees.
To be effective and also meet Cal/OSHA requirements, a training program needs to:
- Let supervisors know:
- They are key figures responsible for establishment and success of the Injury and Illness Prevention Program.
- The importance of establishing and maintaining safe and healthful working conditions.
- They are responsible for being familiar with safety and health hazards to which their employees are exposed, how to recognize them, the potential effects these hazards have on the employees, and rules, procedures, and work practices for controlling exposure to those hazards.
- How to convey this information to employees by setting good examples, instructing them, making sure they fully understand and follow safe procedures.
- How to investigate accidents and take corrective and preventive action.
- Let employees know:
- The success of the company’s Injury and Illness Prevention Program depends on their actions as well as management’s.
- The safe work procedures required for their jobs and how these procedures protect them against exposure.
- When personal protective equipment is required or needed, how to use it and maintain it in good condition.
- What to do if emergencies occur in the workplace.
An effective Injury and Illness Prevention Program requires proper job performance by everyone in the workplace. Employers must ensure that all employees are knowledgeable about the materials and equipment they are working with, what known hazards are present, and how they are controlled.
Each employee needs to understand that:
- No employee is expected to undertake a job until he or she has received instructions on how to do it properly and safely, and is authorized to perform the job.
- No employees should undertake a job that appears to be unsafe.
- No employee should use chemicals without fully understanding their toxic properties and without the knowledge required to work with them safely.
- Mechanical safeguards must always be in place and kept in place.
- Employees are to report to a superior or designated individual all unsafe conditions encountered during work.
- Any work-related injury or illness suffered, however slight, must be reported to management at once.
- Personal protective equipment must be used when and where required, and properly maintained.
Supervisors must recognize that they are the primary safety trainers in the employer’s organization. Encourage and help them by providing supervisory training. Many community colleges offer management training courses at little or no cost.
The employer is required under Cal/OSHA standards to establish and carry out a formal training program. A professional training person, an outside consultant, or supervisors may provide injury and illness prevention training to employees.
This program must, at a minimum, provide training and instruction:
- To all employees when the program is first established.
- To all new employees.
- To all employees given new job assignments for which training has not been previously received.
- Whenever new substances, processes, procedures, or equipment are introduced to the workplace and present a new hazard.
- Whenever you or your supervisors are made aware of a new or previously unrecognized hazard.
- For all supervisors to assure they are familiar with the safety and health hazards to which employees under their immediate direction and control may be exposed.
Creating an Injury and Illness Prevention Program
Employers must create a plan to suit their individual workplace. Decide exactly what is to be accomplished, and determine what steps are necessary to achieve these goals.
Then plan out how and when each step will be carried out and who will do it and put this plan in writing. In developing the plan, consider your company’s immediate needs and provide for ongoing worker protection.
Employers can call the Cal/OSHA Consultation Service for assistance. A Consultation Service consultant can help determine what is needed to make an Injury and Illness Prevention Program effective. The consultant will work with an employer on a plan for making these improvements, and assist in establishing procedures for making sure the employer’ program remains effective.
The following sections describe the process in establishing an Injury and Illness Prevention Program. Remember that not all steps must be done at once.
Decide who in the company will be given responsibility and authority to manage the program. In many cases, this may be the owner. Sometimes the plant manager or a ranking member of the management team is the one to develop and set up the program. It could even be an engineer, personnel specialist, or other staff member.
The person assigned must be identified by name in the program. The program’s success hinges on the individual chosen, and he or she cannot succeed without full cooperation and support. Remember, though, that even when someone is appointed as the safety manager and has been delegated authority to manage the program, the ultimate responsibility for safety and health in the workplace still rests with the employer.
When considering responsibility, do not forget to include employees. Give each employee training and responsibility to follow safety and health procedures, and to recognize and report hazards in his or her immediate work area.
All employees must be informed of their responsibility under Cal. Labor Code § 6407.1, which requires every employee to comply with occupational safety and health standards applicable to their own actions and conduct.
Before making any changes in current safety and health operations, gather as much information as possible about current conditions at the workplace, and work practices that are already part of the Injury and Illness Prevention Program. This information can help identify workplace problems and determine what is involved in solving them.
Assessment of the workplace should be conducted by the person responsible for the Injury and Illness Prevention Program, and/or a professional occupational safety and health consultant.
Review consists of the activities described in the next sections.
Safety and Health Survey
Conduct a comprehensive safety and health survey of the facility to identify existing or potential safety and health hazards. This survey should evaluate workplace conditions with respect to: safety and health regulations and generally recognized safe work practices and physical hazards; use of any hazardous materials; employee work habits; and a discussion of safety and health problems with employees. The survey must be documented if made for the purpose of establishing an Injury and Illness Prevention Program.
The safety and health survey includes:
- Equipment. Make a list of equipment and tools, including the principle locations of their use. Special attention should be given to inspection schedules, maintenance activities, and the facility’s layout.
- Chemicals. Make a list of all chemicals used in the workplace, obtain material safety data sheets on the materials used, and identify where they are used.
- Work practices. Detail specific work practices associated with equipment, tools, and chemical use. Special attention should be given to personal protective equipment, guarding, ventilation, emergency procedures, and use of appropriate tools.
- Cal/OSHA Standards. Review standards applicable to the type of operation, equipment, processes, materials, etc. These standards are minimum requirements for workplace safety and health. Most workplaces come under Title 8, California Code of Regulations, General Industry Safety Orders. If the business is construction, petroleum, mining, or tunneling, there will be additional standards specific to that industry.
Evaluate the existing Injury and Illness Prevention Program to identify areas that may be working well and those that may need improvement.
Examine the company’s:
- Accident, injury, or illness data.
- Workers’ compensation costs.
- Rates of employee turnover or absenteeism.
- Information on safety and health activities ongoing or previously tried.
- Company policy statements.
- Rules — both work and safety.
- Guidelines for proper work practices and procedures.
- Records of training programs.
- Compliance with requirements of California’s Right to Know Law and Hazards Communications Standard.
- Employee capabilities — make an alphabetical list of all employees, showing the dates they were hired, what their jobs are, and their experience and training. Special attention should be given to new employees and employees with handicaps. Joint labor-management safety and health committee activities.
- Other safety-related programs.
Review and Compare
After all facts are gathered, employers should review how the information on their workplace corresponds with the standards, and with the critical components of an Injury and Illness Prevention Program: management commitment/assignment of responsibilities; safety communications system with employees; system for assuring employee compliance with safe work practices; scheduled inspections/evaluation system; accident investigation; procedures for correcting unsafe/unhealthy conditions; safety and health training and instruction; recordkeeping and documentation.
Compare this information with the Non-Mandatory Checklist Evaluation for IIP Programs.
Non-Mandatory Checklist Evaluation Injury and Illness Prevention Programs
- Does the written Injury and Illness Prevention Program contain the elements required by § 3203(a)?
- Are the persons with authority and responsibility for implementing the program identified?
- Is there a system for ensuring that employees comply with safe and healthy work practices (i.e., employee incentives, training and retraining programs, and/or disciplinary measures)?
- Is there a system that provides communication with affected employees on occupational safety and health matter (i.e., meetings, training programs, posting, written communications, a system of anonymous notification concerning hazards, and/or health and safety committees)?
- Does the communication system include provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal?
- Is there a system for identifying and evaluating workplace hazards whenever new substances, processes, procedures, or equipment are introduced to the workplace and whenever the employer receives notification of a new or previously unrecognized hazard?
- Were workplace hazards identified when the program was first established?
- Are periodic inspections for safety and health hazards scheduled?
- Are records kept of inspections made to identify unsafe conditions and work practices, if required?
- Is there an accident and near-miss investigation procedure?
- Are unsafe or unhealthy conditions and work practices corrected expeditiously, with the most hazardous exposures given correction priority?
- Are employees protected from serious or imminent hazards until they are corrected?
- Have employees received training in general safe and healthy work practices?
- Do employees know the safety and health hazards specific to their job assignments?
- Is training provided for all employees when the training program is first established?
- Are training needs of employees evaluated whenever new substances, processes, procedures, or equipment are introduced to the workplace and whenever the employer receives notification of a new or previously unrecognized hazard?
- Are supervisors knowledgeable of the safety and health hazards to which employees under their immediate direction and control may be exposed?
- Are records kept documenting safety and health training for each employee by name or other identifier, training dates, type(s) of training, and training providers?
- Does the employer have a labor-management safety and health committee?
- Does the committee meet at least quarterly?
- Is a written record of safety committee meetings distributed to affected employees and maintained for division review?
- Does the committee review results of the periodic, scheduled worksite inspections?
- Does the committee review accident and near-miss investigations and, where necessary, submit suggestions for prevention of future incidents?
- When determined necessary by the committee does it conduct its own inspections and investigations, to assist in remedial solutions?
- Does the committee verify abatement action taken by the employer as specified in division citations upon request of the division?
Develop an Action Plan
An action plan is a specific, written description of problems and solutions — it can and should be changed to correspond with changes in the workplace.
A good action plan has two parts. One is an overall list of major changes or improvements needed to make the Injury and Illness Prevention Program effective. Assign each item a priority and a target date for completion, and identify the person who will monitor or direct each action.
The second part of an action plan involves taking each major change or improvement listed and working out a specific plan for making that change. Write out what to accomplish, the steps required, who would be assigned to do what, and when to be finished. This part of the action plan helps keep track of program improvement so that details do not slip through the cracks.
Put the plan into action, beginning with the item assigned highest priority. Make sure it is realistic and manageable, then address the steps that have been written out for that item. More than one item can be worked on at a time. Priorities may change as other needs are identified or as the company’s resources change.
Open communication with employees is crucial to the success of a program’s efforts. Cooperation depends on understanding what the Injury and Illness Prevention Program is all about, why it is important to employees, and how it affects their work. The more an employer does to keep employees informed of the changes being made, the smoother the transition will be.
By putting an action plan into operation at the workplace, a major step will have been taken toward having an effective Injury and Illness Prevention Program. Remember, an Injury and Illness Prevention Program is a plan put into practice.
Maintain the Program
Schedule a review — quarterly, semiannually, or annually — to look at each critical component in the Injury and Illness Prevention Program, determine what is working well, and what changes, if any, are needed. When needs are identified that should be addressed, it forms the basis for new safety and health objectives for program improvement.