OSHA Debuts Safety Champions Program for Employers
New federal guidelines offer a three-step roadmap for workplace safety, though experts suggest weighing participation against enforcement risks.
- By Scott Hecker
- Mar 17, 2026
To support employer compliance through education and assistance, OSHA recently added a new option to its array of cooperative programs administered by the agency’s Directorate of Cooperative and State Programs (DCSP).
The stated main goal of the Safety Champions Program is to prevent workplace injuries, illnesses and deaths. OSHA plans to achieve this by shepherding employers through a progressive three-step framework designed “to develop and implement . . . effective safety and health program[s].”
Core Elements of the Framework
Participants will be guided by the core elements of OSHA’s recommended practices:
- Management Leadership
- Worker Participation
- Hazard Identification and Assessment
- Hazard Prevention and Control
- Education and Training
- Program Evaluation and Improvement
- Communication and Coordination for host employers, contractors, and staffing agencies
The Three-Step Process
The Safety Champions Program, or SCP, follows a clear progression:
- Introductory Step: At this Step, SCP participants are introduced to the seven core elements of OSHA’s Recommended Practices for Safety and Health Programs. Participants will assess their worksite for safety and health hazards and begin developing or revising safety and health programs to align with the seven core elements.
- Intermediate Step: At this Step, SCP participants focus on implementing their SHPs.
- Advanced Step: At this Step, participants have fully developed and implemented SHPS and routinely assess and improve their SHPs’ policies and practices.
According to a Feb. 24 program manual, OSHA organized its step guide to break each phase into actionable portions.
For example, under Management Leadership, the Step Guide lists an initial goal for employers to communicate their commitment to their safety and health programs, and explains how that goal can be achieved in each Safety Champions step:
- Introductory Actions: Develop a written policy signed by top management with worker input; communicate mission statements to all workers and contractors; establish annual goals; and create fear-free communication channels.
- Intermediate Actions: Continue regular communication of mission/policy statements and incorporate them into all new worker and contractor orientations.
- Advanced Actions: Ensure policy understanding across all worker types; make safety a routine part of communication and operational visibility; and review safety "to-do" lists at the start of work meetings.
Program Oversight and Tracking
OSHA plans to release a Safety Champions Tracker that will allow employers to memorialize their progress through each step. Special government employees, known as SGEs, will evaluate progress and confirm improvements.
The agency uses SGEs to foster safety through collaboration with industry, including under the Voluntary Protection Programs (VPP). According to SCP information sessions presented on March 10 and 12, the agency is designating a specific group to support the SCP. A coordinator will run the program from OSHA’s national office, connecting participants with SGEs.
While the program is self-paced, the agency directive calls for “continuous improvement.” So, to maintain participation, employers must be prepared to act in good faith to move through the SCP at a reasonable cadence, all the while communicating with OSHA and seeking needed feedback from SGEs.
Employers will receive recognition certificates from the Director of DCSP upon completion of the Introductory and Intermediate steps, followed by one from the Assistant Secretary for OSHA after finishing the Advanced step.
Remaining Concerns for Employers
OSHA has steadily increased resources addressing the SCP since its initial announcement and launch of its minimalist website. This includes the Directive, Step Guide, information sessions, and a Fact Sheet. Nonetheless, questions about the Program and concerns about participation remain, such as:
Will State Plans implement SCPs?
OSHA is strongly encouraging state plans to adopt the program. During initial sessions, the agency indicated it is working through details on how employers might participate. This includes State Plan jurisdictions that decide against implementing the Program, or an “as effective” state version.
What is the incentive for participating?
The program coordinator will perform OSHA enforcement activity searches when worksites sign up and whenever a step review is requested.
The directive states that worksites with open enforcement activity cannot participate until the activity is closed in the OSHA Information System. New enforcement activity may delay step completion or lead to removal from the program.
Participating employers open themselves up to regular reviews of their enforcement activity through involvement and advancement in the SCP. While involvement may bolster an application for the Voluntary Protection Programs, it does not guarantee acceptance.
How should employers approach identified hazards?
OSHA counsels that workplace hazards that are uncovered through hazard assessments, self-inspections, incident investigations and reviewing injuries and illnesses must be addressed promptly. Participants must provide effective interim protection as necessary to keep workers safe and address hazards while permanent corrections are made.
Depending on the context, citations could result when OSHA becomes aware of these hazards. The SCP is a voluntary program and operates separately from OSHA’s enforcement. Accordingly, participation has no impact on any existing OSHA enforcement activity or determination.
How should employers proceed?
Cautiously.
Despite optimism about the Program, it is in its early stages with no historical record to consider. Employers should look to join only if they are committed to the process. If OSHA perceives efforts to be lackadaisical or guarded, that perception could have negative repercussions.
Welcoming OSHA to dig into enforcement history, the uncertainty surrounding State Plan involvement, and the expectation to identify and address interim hazards all carry risks – particularly when the benefits of participation are not yet clear. Employers should gather as much information as possible about the SCP to make informed participation decisions.