If an OSHA inspector came knocking on your door today, the first thing the inspector would likely ask to see is your Hazard Communication Plan. Is your written plan current and ready for that kind of scrutiny? How about your other safety and health plans? Are you sure you have all of the required written plans you need in place? Since not all OSHA regulations require written plans, the question is which ones do? Take a look at the bulleted list of general industry regulations requiring written plans. For your convenience, these are in order from most-violated down to least-violated plans, according to the latest OSHA statistics:

  • Hazard Communication – 1910.1200(e)
  • Lockout/ Tagout (LOTO) (Energy Control Procedures) – 1910.147(c)(4)
  • Respiratory Protection – 1910.134(c)(1)
  • Process Safety Management (PSM) – 1910.119(d),(e)(1),(f)(1),(j)(1),(l)(1),(m)(4),(o)(3)
  • Personal Protective Equipment (PPE)(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 – 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)
  • Powered Platforms for Building Maintenance (Emergency Action Plan) – 1910.66(e)(9)

For all serious safety or health hazards, OSHA 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 blood borne pathogens. For all applicable plans, up-to-date documentation of employee training is always required.

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. CTI can help you be in-compliance by conducting a Site Safety Assessment for your facility. CTI can also assure your written plans meet all the OSHA-required elements specified in the regulations and that your training is complete.

Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

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