A safety and health program provides systematic policies, procedures, and practices that are adequate to recognize and protect employees from occupational safety and health hazards. An effective safety and health program includes provisions for the systematic identification, evaluation, and prevention or control of general workplace hazards, specific job hazards, and potential hazards that may arise from foreseeable conditions. To be effective, the program will also look beyond specific OSHA regulations and seek to address hazards and prevent injuries and illnesses whether or not compliance is at issue.
The term, “safety and health program” is synonymous with other terms, such as, but not limited to, “safety and health management systems,” “injury and illness prevention program” (or I2P2), and “accident prevention program.” Whatever the name, the common goal of these approaches is to help employers reduce workplace injuries, illnesses, and fatalities through a systematic process that proactively addresses workplace safety and health hazards.
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 Section 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 OSH Act.
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. Employers should check the state comparison table to see whether their states require a safety and health program (or program by another name).
While federal OSHA does not “require” employers to put in place a safety and health program, the agency offers guidelines to provide them with a sound, flexible framework for addressing safety and health issues in diverse workplaces. The 39-page, November 2015 draft guidelines give the latest recommendations from the agency. However, the guidelines can be boiled down to seven core elements:
Some state agencies may be more stringent than federal OSHA and, in fact, require some kind of safety and health program. Check your state workplace safety or workers’ compensation laws and regulations for requirements, if any.