Safety plans

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.

Regulatory citations

Notes: Section 5(a)(1) of the Occupational Safety and Health Act of 1970 requires that every working man and woman must be provided with a safe and healthful workplace. This section, more commonly known as the General Duty Clause, specifically 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.”

In simple terms, this statement means that each employer may be obligated to protect its employees from serious, recognized hazards in the workplace 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. In many cases, developing and implementing written safety plans (even if not required specifically by the regulations) is one of the added steps taken to protect employees.

Moreover, employers should check to see whether their states require any other written safety plans, beyond the ones required by federal OSHA. States may be more stringent than federal OSHA.

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 and health.
• Other safety records: Documentation that is not a written safety plan, program, procedure, or policy.

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.

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.