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Written safety plans (or programs) are records of how an establishment is protecting or plans to protect employees overall for a safety or health hazard. The words plan and program can be and have been used interchangeably. Both document what a facility is doing to keep employees safe and healthful. While safety procedures may also document how an establishment is protecting employees, they do this in a step-by-step fashion rather than in an overall way, and safety procedures may be a part of written safety plans or programs. Safety policies, on the other hand, document an establishment’s philosophy or rules towards safety and health. Policies, too, can be rolled into a larger written plan or program.
Note: For this ez Explanation, the use of the terms written safety plan, written plan, or safety plan will refer to all types of safety plans, programs, procedures, and policies that are put into writing. The terms will not include other safety records.
Essentially, written safety plans are the cornerstone of a complete safety and health program. Whether required or not, written plans may have several purposes and benefits:
Helps to meet regulations
Streamlines safety efforts
Sets goals and objectives
Provides direction of effort
Defines safety roles/responsibilities
Keeps safety and health a priority
Provides expectations and boundaries
Provides an element of control
Sets standard procedures
Sets rules and provides disciplinary justification
Lowers injury and illness rates
Decreases costs of injuries, illnesses, and property damage
Lowers insurance costs
Helps to lower the experience modification rate (MOD rate)
Increases competitiveness
Provides efficient use of budget use
Raises the profit margin and profitability
Shows management's safety commitment
Provides evidence of good faith
Decreases OSHA fines
Scope
Written safety plan requirements are found throughout the OSHA regulations, and, therefore, these documents cover a number of different work operations and hazards. Because written plans are required for specific hazard topics on a standard-by-standard basis, their scope depends on the scope of the standards that carry written plan provisions. Put another way, most regulations have a scope and applicability section(s), so if an employer finds that the regulation applies, the employer will want to check if there’s a written plan requirement.
29 CFR 1926 Subpart R App. A — Guidelines for Establishing the Components of a Site-Specific Erection Plan: Non-Mandatory Guidelines for Complying with 1926.752(e)
Notes: Section 5(a)(1) of the Occupational Safety and Health Act of 1970 requires every working man and woman to be provided with a safe and healthful workplace. This section, known as the General Duty Clause, states: “Each employer shall furnish to each of his employees employment and a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
This means that each employer may be obligated to protect its employees from serious, recognized hazards at work even if there is not an OSHA standard which applies to the situation or if hazards still exist after compliance with applicable standards. In effect, the General Duty Clause obligates employers to take additional steps toward safety if the well-being of employees is in jeopardy. Developing and implementing written safety plans (even if not required specifically by the regulations) is often one of the added steps taken to protect employees.
Moreover, employers should check to see whether their states require other written safety plans, beyond those required by federal OSHA. States may be more stringent.
Key definitions
Written safety plan or program: A record of how an establishment is protecting or plans to protect employees overall for a safety or health hazard.
Written safety procedure: A detailed, step-by-step record of how employees or management must perform a task to be safe and healthful.
Written safety policy: A record of an establishment’s philosophy toward safety/health.
Other safety records: Documentation that is not a written safety plan, program, procedure, or policy.
Summary of requirements
Carefully read and follow written safety plan requirements that apply. Be sure to check the written plan requirement to see if it provides a list of required plan elements and other more specific provisions.
General industry
Develop and implement any required, applicable written safety plans identified in the non-substance-specific regulations at 29 CFR 1910:
Hazard assessment certification (for personal protective equipment) (technically not a “written safety plan,” but listed here for your reference), 1910.132
Methylenedianiline compliance program, plus emergency situations plan, 1910.1050
Respirable crystalline silica exposure control plan, 1910.1053
Vinyl chloride compliance program, plus emergency situations operational plan, 1910.1017
Construction
Develop and implement any required, applicable written safety plans for construction identified in the non-substance-specific regulations at 29 CFR 1926:
Develop and implement any required, applicable written safety plans for construction identified in the substance-specific regulations at 29 CFR 1926 Subparts D and Z:
Acrylonitrile compliance program, plus emergency situations plan, 1926.1145
