OSHA Safety Manual Requirements

Standards set by the Occupational Safety & Health Administration require employers to have written programs covering specific health and safety topics. In addition to these mandatory documents, OSHA recommends employers initiate a customized injury and illness prevention program that spells out company policy on employee education, hazard identification and prevention, program evaluation and the roles management and employees have in workplace safety.

Assembling all safety-related policies into a safety manual allows for easy reference and updating. Moreover, when presented to an OSHA compliance inspection officer, this may result in penalty-assessment leniency.

Required Plans

Although the construction, health care and maritime industries have specific workplace hazards to address, safety manuals for most employers must include illness and injury prevention programs for any of these 6 topics that apply to them:

  • Bloodborne Pathogens Exposure Control Plan
  • Emergency Action Plan
  • Lockout/Tagout
  • Hazard Communication Safety Plan
  • Hearing Conservation Program
  • Respiratory Protection

Bloodborne Pathogen Exposure Control

Standard 1910.1030 explains OSHA’s requirement for a bloodborne pathogen safety program. Your company's written plan to protect employees from body fluid hazards must document:

  • A list of jobs with exposure risk,
  • A list of all tasks and procedures performed by employees in these jobs
  • Personal protective gear and clothing to be used
  • Related training topics and training policy
  • Availability of hepatitis B vaccinations
  • Disposal methods and containers
  • Applicable labels or signs
  • Recommended procedures for performing tasks to minimize exposure
  • Post-exposure procedures and reporting

OSHA offers a sample bloodborne pathogen exposure control plan you can adapt to suit your organization.

Emergency Plan

The emergency action plan your safety manual should comply with Standard 1910.38 Emergency preparedness ensures employees know what to do, where to go and who is in charge when they must evacuate their building. Small businesses with fewer than 11 employees must have an emergency action plan, but can convey it verbally rather than in writing. OSHA's 10-step e-tool can help you create a basic emergency action plan that meets the standard by detailing:

  • Evacuation steps and emergency escape route assignments
  • Reporting procedures
  • Post-evacuation attendance to account for everyone
  • Steps plant operations managers must take
  • Assignment of key safety and first aid contacts and their duties

Hazardous Energy Control

If your facility has any type of equipment or machinery that gets serviced, such as a large trash compactor, you need a lockout/tagout policy in your safety manual to comply with OSHA standard 1910.147. Your plan must address three key items:

  1. Specific procedures to shut off the units, including authorized personnel, tagging and placing the required lock to prevent inadvertent use of the machine during maintenance
  2. Conducting inspections periodically to verify tool quality and ensure employees understand and follow procedures
  3. Assigned responsibility for training employees, training content and class calendar

OSHA's online lockout/tagout training program is a good reference for small businesses.

Hazard Communication Safety Plan

OSHA's sample for a hazard communication plan that meets standard 1910.120 serves as a template that you can customize to your business. Your hazard communication program must touch on container labeling, safety data sheet access and upkeep, and training, in addition to establishing guidelines on periodic reviews to ensure information is current. For example, the list of chemicals and hazardous substances found in your facility should change when you change products.

Hearing Conservation Program

Exposure to occupational noise jeopardizes employee well being. If your workers are exposed to 85 dBA over eight hours – or 90 dBA for construction workers – your safety manual needs a hearing conservation program. OSHA recommends your plan covers risk identification, noise monitoring, testing and monitoring of employee hearing, hearing protective equipment policy and worker education on hearing protection.

Respiratory Protection

Standard 1910.134 mandates you have a program in place on respiratory protection when your employees may be exposed to harmful fumes, dust, sprays, mists, smoke or fog. Include criteria to be used to select respirators and how employees will be trained on their use and maintenance. Your plan also should cover proper fit, name a program administrator and outline program evaluation steps.

References

About the Author

Trudy Brunot began writing in 1992. Her work has appeared in "Quarterly," "Pennsylvania Health & You," "Constructor" and the "Tribune-Review" newspaper. Her domestic and international experience includes human resources, advertising, marketing, product and retail management positions. She holds a master's degree in international business administration from the University of South Carolina.