If OSHA came to your door, what’s one of the first things the inspector might ask to see? The answer is … your Hazard Communication Plan. Is your written plan up for that kind of scrutiny? How about your other safety and health plans? Are you sure you have all the required written plans you need in place?
Not all OSHA regulations require written plans, but many do. The question is which ones? Take a look at the bulleted list of general industry regulations requiring written plans. For your convenience, we’ve put them in order from most-violated down to least-violated plans, according to the latest OSHA statistics:
- Hazard communication – 1910.1200(e)
- Lockout/tagout (energy control procedures)- 1910.147(c)(4)
- Respiratory protection – 1910.134(c)(1)
- Process safety management – 1910.119(d),(e)(1),(f)(1),(j)(1),(l)(1),(m)(4),(o)(3)
- Personal protective equipment (hazard assessment) – 1910.132(d)
- Bloodborne pathogens – 1910.1030(c)
- Emergency action plans – 1910.38(b)
- Permit-required confined spaces – 1910.146(c)(4)
- Hazardous waste operations and emergency response – 1910.120(b)(1),(l)(1),(p)(1),(q)(1)
- Electrical safety (assured equipment grounding conductor program and lockout/tagout procedures for work with energized parts) – 1910.304(b)(3)(ii) and 1910.333(b)(2)(i)
- Fire prevention plans – 1910.39(b)
- Laboratory standard (chemical hygiene plan) – 1910.1450(e)
- Commercial diving operations (safe practices manual) – 1910.420
- Powered platforms for building maintenance (emergency action plan) – 1910.66(e)(9)
When OSHA considers a safety or health hazard to be serious, the agency usually requires written documentation of the steps an employer takes to counteract the hazard. You can see that the above list covers some of the most serious hazards faced by workers today, including but not limited to chemical exposures, process explosions, fire, electrocution, and bloodborne pathogens.
As an employer, not all of these plans will necessarily be applicable to your workplace, so you’ll want to review the scope and applicability of these regulations to see if your company falls under any of them. For the applicable ones, make sure your written plans meet all the OSHA-required elements specified in the regulations.