Written Safety Plans: Your Top Questions Answered
By Tricia Hodkiewicz, EHS Editor at J. J. Keller & Associates, Inc.
To assist you in building your own full-service safety program, J. J Keller’s trusted team of in-house subject-matter experts have compiled the ten questions they’re most frequently asked regarding written safety plans below.
Does OSHA require written safety plans?
OSHA has over 35 written plan, program, procedure, or manual requirements throughout OSHA 29 CFR 1910 for general industry. Over 20 more are found in 29 CFR 1926 for construction. While that’s a lot of written plans, it’s unlikely all of them apply to your operation.
You’ll want to review the requirements one-by-one to see which ones apply.
Do written plan requirements still apply if our establishment has only a few employees?
For most written safety plans it makes no difference how many employees your establishment has. However, the emergency action plan and the fire prevention plan each have a small employer exemption. These two plans are required to be in writing UNLESS you are an employer with 10 or fewer employees. In that case, you may communicate your plans orally to employees. Those are the only two plans with that option. All other applicable plans are required to be in writing if you have one or more employees.
What is the difference between a written plan and a written program?
Plans and programs both document your establishment’s overall approach to protecting employees from a safety or health hazard. The words plan and program are often used interchangeably. OSHA calls for a written exposure control plan for bloodborne pathogens, but when it comes to communicating chemical hazards, the agency wants a written hazard communication program. You may also document procedures, which are step-by-step instructions for safely performing a task. OSHA has many requirements for procedures, but not all of them are required to be in writing.
May we use a template?
You can certainly use a template when writing your plan, but you must tailor your plan to your own site and its operations, employees, and hazards.
What are some tips to help avoid problems with written plans?
A. Include required elements—A written plan should contain all the elements OSHA requires. In most cases, OSHA provides at least some instruction on the written plan requirements. For example, 29 CFR 1910.134 lists nine required elements for the written respiratory protection plan.
B. Do what you say—If you go beyond the basic regulatory requirements, be sure that you follow through on any additional elements. You don’t want to document something that your establishment is not actually carrying out in practice.
C. Leave room for discretion—For instance, if a plan has a detailed inspection checklist, it may create the impression that your establishment will only follow that checklist. This can prevent the flexibility necessary to ensure a thorough inspection is conducted when other safety issues or concerns arise during a walkthrough.
Can we use job titles, instead of names, in our plans?
When you have employee turnover, plans with names must be updated, but if you have job titles, updates may not always be needed. Most plan requirements do not require names, but instead mandate the designation of the responsible person. That could be the job title only, name only, or both. Names do have one benefit though—they may be easier for you and your employees to recognize. Regardless, always check the regulations to see what OSHA requires in a given plan.
Do written plans need to be translated into languages other than English?
While OSHA does not require it, translating plans is a good idea if you have employees who don’t read English. In some cases, it may be critical, such as for lockout/tagout procedures. Your programs should be in a language all employees can understand and follow.
Can we keep written plans electronically?
Yes, OSHA allows a written plan to be kept in either paper or electronic format, as long as it meets all other requirements of the standard in question. Where the OSHA standard requires that the written plan be made available to employees, you must ensure that employees know how to access the document and that there are no barriers to employee access. If you keep plans electronically, consider how they will be made available to employees and to any OSHA inspector who knocks on your door. Printing a copy is usually acceptable for OSHA inspectors.
If OSHA does not require a given plan, may we simply communicate it orally?
Potentially yes, but keep in mind that an industry consensus standard may call for written plans even if OSHA does not. For instance, federal OSHA requires lockout/tagout procedures to be in writing, but not the entire energy control program. However, ANSI Z244.1, the consensus standard for lockout/tagout, does mandate a written program for hazardous energy control. Other benefits to putting non-required plans into writing include consistent and streamlined safety efforts, defined safety roles and responsibilities, lower injury and illness rates and costs, increased profit and competitiveness, and clear evidence of your commitment to safety.
How often should we review and update our written plans?
It’s a good idea to review and update your written plans as often as necessary. Many regulations will call for updates as necessary. But some plans also require annual reviews and/or updates. For example, under the Bloodborne Pathogen Standard, the exposure control plan must be reviewed and updated at least annually, but also as necessary to include new or modified tasks and procedures.
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