Did You Know . . .
You must develop and implement OSHA-Required written safety plans/programs?
Written plans and procedures commonly required by OSHA include:
Injury & Illness Prevention
OSHA is developing a rule requiring employers to implement an Injury and Illness Prevention Program. Thirty-four states and many nations around the world already require or encourage employers to implement such programs. The key elements include management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement. It involves planning, implementing, evaluating, and improving processes and activities that protect employee safety and health.
OSHA has substantial data on reductions in injuries and illnesses from employers who have implemented similar effective processes. The Agency currently has voluntary Safety and Health Program Management Guidelines (54 FR 3904 to 3916), published in 1989. An injury and illness prevention rule would build on these guidelines as well as lessons learned from successful approaches and best practices under OSHA’s Voluntary Protection Program Safety and Health Achievement Recognition Program and similar industry and international initiatives.
Emergency Action & Fire Prevention – 29 CFR 1926.35 / 1910.38 & 29 CFR 1926.24 / 1910.39
An Emergency Action & Fire Prevention Plan is designed to address reasonably foreseeable emergency situations and to provide appropriate hazard and emergency preparedness information to employees, external emergency response agencies, and the community. It documents necessary management and employee actions required during fires and other emergencies, protocol for employees who must remain to operate critical equipment, method(s) to account for employees during an evacuation, rescue and first aid responsibilities, and employee training.
Hazard Communication – 29 CFR 1910.1200 / 1926.59
Companies with workers exposed to hazardous chemicals must prepare and implement a Hazard Communication Program. The written program must contain a list of hazardous chemicals and must detail how the employer will comply with the requirements for labeling and other forms of warning, obtaining and maintaining Safety Data Sheets (SDS), providing information and training to employees, and recordkeeping.
Note: By 6/1/06, employers must update their written Hazard Communication Program to comply with the new GHS requirements. GHS stands for Globally Harmonized System of Classification and Labeling of Chemicals, the system which uses universal hazard statements, pictograms and signal words to communicate information on product labels and Safety Data Sheets.
Control of Hazardous Energy (Lockout/Tagout) – 29 CFR 1910.147
Lockout/Tagout (LO/TO) is a safety procedure critical for the service and maintenance of machinery or electrical systems in cases where employees could be hurt by the unexpected start up, or energization of the equipment. It applies to all energy sources including mechanical, hydraulic, pneumatic, chemical, thermal, and even gravity. An effective Lockout/Tagout Program can help protect workers by ensuring that machines and circuits are properly shut off (or de-energized) and not turned on (energized) again until the work is completed. It documents energy control procedures, employee training, periodic inspections, and recordkeeping.
According to OSHA, machine-specific LO/TO procedures are required for any piece of equipment that has more than one energy source, including both lockable and non-lockable energy. Therefore, there are very few pieces of equipment within a facility that do not require a LO/TO procedure.
Bloodborne Pathogens Exposure Control – 29 CFR 1910.1030
Bloodborne pathogens are infectious materials in blood that can cause disease in humans, including hepatitis B and C and human immunodeficiency virus, or HIV. Employers must protect workers whose jobs put them at a reasonable risk of coming into contact with blood and other potentially infectious materials. Exposure to bloodborne pathogens can be minimized or eliminated when the development of an Exposure Control Plan addresses and implements, at the minimum, the following elements: universal precautions, combination of engineering and work practice controls, personal protective equipment, appropriate decontamination/ housekeeping, communication of hazards and training, medical surveillance which includes the offering of the hepatitis B vaccination and post-exposure evaluation & follow-up, and recordkeeping.
Respiratory Protection – 29 CFR 1910.134 / 1926.103
Companies with workers required to use respirators on the job must prepare and implement a Respiratory Protection Program. The program documents procedures for selection of proper respiratory protection, employee use, medical evaluations, fit testing, inspections, cleaning, maintenance and storage, employee training, and recordkeeping.
Hearing Conservation – 29 CFR 1910.95 / 1926.52
Companies with workers exposed to excessive noise levels on the job (e.g., conditions that make normal conversation difficult) may be required to implement a Hearing Conservation Program. The program documents procedures for exposure monitoring, engineering controls, selection of proper hearing protection devices, audiometric testing, and training, as well as noise reduction strategies.
Chemical Hygiene – 29 CFR 1910.1450
OSHA requires a Chemical Hygiene Plan for implementing practices to minimize exposure to hazardous chemicals. The plan should include procedures for laboratory safety, standard operating procedures, methods of control, measures for appropriate maintenance and use of protective equipment, medical examinations, employee training, and recordkeeping.
Note: This list is not comprehensive – other plans/programs may be required based on your operations.
Many companies compile their written safety plans/programs and standard operating procedures into a single Safety Manual.