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.
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.
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:
- Assured equipment grounding conductor program, 1910.304
- Chemical hygiene plan (for laboratories), 1910.1450
- Commercial diving operations safety practices manual, 1910.420
- Dispute resolution procedures for mechanical power presses, 1910.217 Appendix C
- Emergency action plan (EAP), 1910.38
- Emergency action plan (powered platforms for building maintenance), 1910.66
- Energy control procedure (lockout/tagout), 1910.147 and 1910.269
- Exposure control plan (for bloodborne pathogens), 1910.1030
- Fall protection plan, 1910.28
- Fire prevention plan (FPP), 1910.39
- Fire brigade organizational statement, 1910.156
- Grain handling facility housekeeping program, 1910.272
- Hazard assessment certification (for personal protective equipment) (technically not a “written safety plan,” but listed here for your reference), 1910.132
- Hazard communication program, 1910.1200
- HAZWOPER emergency response plan, 1910.120
- HAZWOPER safety and health program, 1910.120
- HIV/HBV research lab and production facility biosafety manual and entry and exit policies and procedures, 1910.1030
- Hot tap operation procedures, 1910.147
- Permit-required confined space program, 1910.146
- Procedures for work on or near exposed de-energized parts, 1910.333
- Process safety management program, 1910.119
- Respiratory protection program, 1910.134
- Rim manual (or charts) (technically not a “written safety plan,” but listed here for your reference), 1910.177
- Develop and implement any required, applicable written safety plans identified in the substance-specific regulations at 29 CFR 1910 Subpart Z:
- Acrylonitrile compliance program, plus emergency situations plan, 1910.1045
- Asbestos compliance program, 1910.1001
- Benzene compliance program, 1910.1028
- Beryllium exposure control plan, 1910.1024
- 1,3-butadiene compliance plan, plus exposure goal program and emergency situations plan, 1910.1051
- Cadmium compliance program, plus emergency situations plan, 1910.1027
- Coke oven emissions compliance program, plus inspection and cleaning, charging, emissions control, and maintenance and repair procedures, 1910.1029
- Cotton dust compliance program, plus dust minimization work practices program, 1910.1043
- 1,2-dibromo-3-chloropropane compliance program, plus emergency situations plan, 1910.1044
- Ethylene oxide compliance program, 1910.1047
- Formaldehyde corrective actions description, 1910.1048
- Inorganic arsenic compliance program, plus housekeeping and maintenance plan, 1910.1018
- Lead compliance program, 1910.1025
- 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:
- Assured equipment grounding conductor program, 1926.404
- Emergency action plan (EAP), 1926.35
- Fall protection plan, 1926.501, 1926.502, and 1926 Subpart M, Appendix E
- Fire prevention plan (FPP) for methylenedianiline, 1926.60 and 1910.39
- Hazard communication program, 1926.59
- HAZWOPER emergency response plan, 1926.65
- HAZWOPER safety and health program, 1926.65
- Permit-required confined space program, 1926.1203 - .1204
- Process safety management program, 1926.64
- Respiratory protection program, 1926.103
- Site-specific steel erection plan, 1926.752, 1926.757, and 1926 Subpart R, Appendix A
- 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
- Benzene compliance program, 1926.1128
- Beryllium exposure control plan, 1926.1124
- Cadmium compliance program, plus emergency situations plan, 1926.1127
- Coke oven emissions compliance program, plus inspection and cleaning, charging, emissions control, and maintenance and repair procedures, 1926.1129
- 1,2-dibromo-3-chloropropane compliance program, plus emergency situations plan, 1926.1144
- Ethylene oxide compliance program, 1926.1147
- Formaldehyde corrective actions description, 1926.1148
- Inorganic arsenic compliance program, plus housekeeping and maintenance plan, 1926.1118
- Lead compliance program, 1926.62
- Methylenediananiline compliance program, plus emergency situations plan, 1926.60
- Respirable crystalline silica exposure control plan, 1926.1153
- Vinyl chloride compliance program, plus emergency situations operational plan, 1926.1117
