• There is no requirement for a formal safety and health management program at the federal OSHA level.
• Some state agencies may be more stringent than federal OSHA.

At the federal Occupational Safety and Health Administration (OSHA) level, there is currently no requirement for employers to have a formal safety and health management program or system. However, some state workplace safety or workers’ compensation agencies may be more stringent than federal OSHA and, in fact, require some kind of safety and health program. Check state workplace safety or workers’ compensation laws and regulations for requirements, if any.

While not specifically required by federal OSHA, all employers covered by the Occupational Safety and Health (OSH) Act could benefit from implementing a safety and health program. The program would apply to hazards covered by the General Duty Clause, or 5(a)(1) of the Act, and by OSHA standards. For “multi-employer” worksites, programs should be coordinated and communicated to ensure that the host employer and contractor, subcontractor, or temporary staffing agency understand their respective responsibilities for controlling hazards.

Based on the growing support for safety and health programs, OSHA issued its first “Safety and Health Program Management Guidelines” in January 1989. In October 2015, OSHA updated the 1989 guidelines with two publications: OSHA 3885 “Recommended Practices for Safety and Health Programs,” and OSHA 3524 “Recommended Practices for Safety and Health Programs in Construction.” These guidelines are not standards or regulations, nor do they create an obligation under the Occupational Safety and Health (OSH) Act.