Is a Written Safety Program Required?

OSHA recognizes that effective safety and health programs can be organized and presented in a variety of ways. For large businesses, a written program is essential because authority, responsibility, and accountability must be clearly assigned to avoid confusion and uncertainty. For small businesses with less complex operations and few potential hazards, it may be possible to effectively communicate policies and procedures orally and by example. Although OSHA’s general policy is that “performance counts more than paperwork,” it is to the employer’s benefit to have a written program to show the OSHA compliance officer during a workplace inspection.

A formal written safety and health program serves as a framework for systematically detecting and correcting OSHA violations, as well as for remedying hazards not covered by OSHA standards. The program also focuses the company’s work practice rules and employee training by showing where safety rule development, enforcement and training is needed.

A number of OSHA standards require employers to have written compliance programs. The most far-reaching is the hazard communication program, which affects most employers. Other written program requirements include blood borne pathogens, respiratory protection, personal protective equipment and process safety management of highly hazardous chemicals. These programs can be incorporated into the general safety and health program.

According to an OSHA Standard Interpretation letter, dated March 20, 2000, the agency suggests that a safety and health program should contain five core elements. These elements are:

1. Management leadership and employee participation;
2. Hazard identification and assessment;
3. Hazard prevention and control;
4. Information and training; and
5. Evaluation of program effectiveness.

Additionally, OSHA disapproves of incentive-based safety programs because the agency feels that they encourage under reporting of workplace injuries.

Construction

A limited safety program requirement is currently in effect for construction work. Section 1926.20(b) requires construction employers to have “accident prevention programs” that provide for regular inspections of worksites, materials, and equipment by a “competent person.”

State activity

A number of states that have adopted their own OSHA-approved state plan for safety and health enforcement have also adopted provisions requiring employers to establish safety and health programs or safety committees or both.

Other benefits

Avoiding or reducing OSHA liability is only one reason for having a company safety and health program Other business purposes may also be furthered, including fewer employee absences, improved morale, lower workers’ compensation costs, enhancement of the company’s public image, and reduced downtime and equipment repair costs. Assistance in establishing a safety and health program is available from OSHA-sponsored state consultation agencies, insurance carriers, trade associations, and private safety consultants. Companies with established programs that are participating in the OSHA Voluntary Protection Program offer “mentoring” to other employers in developing safety programs.