JERROLD J. SCHARNINGHAUSEN, Ph.D.
Directorate of Assessments and Prevention
Workplace Safety Division
U.S. Army Combat Readiness Center
Fort Rucker, Alabama
The Occupational Safety and Health Administration (OSHA) maintains a list of the top 10 most frequently cited standards following inspections of worksites by federal OSHA inspectors. The main purpose is to provide leading indicators to employers so they can take preventive steps to analyze and abate recognized hazards. One of the most common citations issued by OSHA in the construction industry is the lack of a written plan. During fiscal year 2020 (FY20), five of the top 10 violations occurred in areas where a written plan is required.
Not all OSHA regulations require written plans. When OSHA considers a safety or health hazard to be serious, it requires written documentation of the steps an employer takes to counteract or prevent the hazard. The question is which ones apply to your facility? It depends on several factors. Is your workplace covered under the General Industry Standard (29 CFR 1910) or the Construction Standard (29 CFR 1926)? Are there any processes involving toxic or hazardous substances (Subpart Z)? Are workers required to wear personal protective equipment (PPE) or are engineering controls in place to eliminate the hazard? There are too many variables for the Army to develop a one-size-fits-all policy.
So how do you determine which OSHA standards apply to your workplace? Supervisors must perform an assessment of each operation in their workplace to determine what standards apply. Assistance is available in making this determination, depending upon the standard involved, from the various safety offices, industrial hygiene office, occupational health office, preventive medicine office, the environmental office and the fire department. Review the scope and applicability of the regulations below to see if your operations are similar. For the applicable standards, make sure your written plan meets all the OSHA-required elements specified in the regulations.
Although ensuring that you have created written plans for all the required areas looks like a major undertaking, the U.S. Army Combat Readiness Center (USACRC) has developed a program to assist you and your unit into compliance with federal law. Previously published general industry-required written plans include: Hazard Communication Plan 29 CFR 1910.1200; Lock-out/Tag-out Plan 29 CFR 1910.147; Personal Protective Equipment (PPE) 29 CFR 1910.132; Respiratory Protection Plan 29 CFR 1910.134; Bloodborne Pathogens Plan 29 CFR 1910.1030; Emergency Action Plan (EAP) 29 CFR 1910.38; Permit Required Confined Space Plan 29 CFR 1910.146; Fire Prevention Plan 29 CFR 1910.39; Hearing Conservation Plan 29 CFR 1910.95; Chemical Hygiene Plan 29 CFR 1910.1450; and Exposure Control Plans required for Toxic and Hazardous Substances 29 CFR 1910.1000, Subpart Z, for beryllium, cadmium, chromium, lead and silica. These templates require an edit in order to include the site-specific information required by OSHA.
The USACRC Workplace Safety website, located at https://safety.army.mil/ON-DUTY/Workplace, now has additional templates for OSHA-required written plans. New templates include:
Crane/Hoisting Inspection Program (OSHA 29 CFR 1910.179, 184 or 1926.251, 550, 552): If personnel are involved in operations involving cranes or hoisting material, a written program is required. The program consists primarily of documented equipment inspections. Employees are to be trained in proper inspection techniques to identify potential hazards. Depending upon equipment and use, inspections may be daily, monthly or from one to 12 months. Assistance can be obtained from the equipment manufacturer or commercial crane inspection companies. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/templates/Crane_And_Hoist_Safety_Program_template_29CFR1926_v3.doc?ver=2020-11-23-141658-840
Fall Protection Program (OSHA 29 CFR 1926, Subpart M): A written fall protection program is required for all construction-related activities as defined in Subpart M of CFR 1926. A written plan is required and should include the following key elements: 1) Conduct fall hazard assessment, 2) Establish policy and develop procedures, 3) Determine appropriate hazard control measures, 4) Elimination/engineering controls, 5) Selection and use of applicable systems, 6) Orientation and training, 7) Inspection and maintenance, and 8) Program audit. Templates have been published for both ground and aviation maintenance areas. A full program will be published next year in the Leaders Guide to Fall Protection.
Ground maintenance fall protection template https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/templates/Ground_Maintenance_Written_Fall_Protection_Template.docx?ver=2020-11-23-141655-277
Aviation maintenance fall protection template https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/templates/Aviation_Maintenance_Written_Fall_Protection_Template.docx?ver=2020-11-23-141655-123
Powered Industrial Truck Operator (Forklift) Training (OSHA 29 CFR 1910.178 and 1926.602(d)): A written powered industrial truck training program is required for operations involving forklifts. Employers shall ensure each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by completion of training and evaluation. Training elements include: 1) Formal instruction, 2) Demonstrations performed by the trainer, 3) Practical exercises performed by the trainee, and 4) Evaluation of the operator's performance in the workplace. Training program content shall include: 1) Truck-related topics, 2) Workplace-related topics, and 3) Specific requirements spelled out in the standard. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/OSHACORNER/OSHASIGNIFICANTISSUES/Standard/Forklift_Safety_Program.docx
Lock-out/Tag-out (OSHA 29 CFR 1926.417): If you perform servicing, cleaning and maintenance of machines and equipment in which the unexpected startup or energization (turning the power back on) or release of stored energy (power press at top of cycle) could cause injury to employees, a written plan is required. This standard applies to all energy release, not just electrical, and it includes, but is not limited to, hydraulic systems and pressurized pipes. Written lock-out/tag-out procedures must be provided for work on the electrical systems. There is an additional previously published lock-out/tag-out template available for general industry OSHA 29 CFR 1910.147. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/LOCKOUTTAGOUT/Standard/29CFR1910.147_Lockout_Tagout_Plan_Template_v3.doc
Trenching and Excavation (OSHA 29 CFR 1926.651 and 652): Before beginning the job, it is important to establish and maintain a written excavation plan for the worksite that provides adequate systematic policies, procedures and practices to protect employees from, and allow them to recognize, excavation safety and health hazards. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/templates/29CFR1926_Subpart_P_Trenching_and_Excavation_v6.doc?ver=2020-11-23-141655-967
Silica (Construction) Exposure Control Plan required for Toxic and Hazardous Substances (29 CFR 1910.1000 Subpart Z): OSHA requires site-specific written exposure control plans for any exposure to a toxic or hazardous substance that exceeds the permissible exposure limit. Silica exposure control plans are available for both general industry and construction. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/TOXICANDHAZARDOUSSUBSTANCES/Standard/Written_Silica_Exposure_Control_Plan_Template.docx
Ergonomics: While not a required written plan, it does fall under OSHA’s best practices guidelines. There are no specific ergonomics regulations within OSHA, although they will cite ergonomic injuries under the General Duty Clause of the Occupational Safety and Health Act, Section 5. Enforcement of a written ergonomics policy decreases the likelihood of OSHA discovering ergonomic issues in the workplace. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/templates/Ergonomics_template_v7.docx?ver=2020-11-23-141658-530
Safety Policy: The safety policy is an OSHA best practice designed to comply with the standards of the Occupational Safety and Health Act and to endeavor to maintain a safe and injury-/illness-free workplace. A written safety policy is designed to prevent workplace injuries and illnesses; improve compliance with laws and regulations; reduce costs, including significant reductions in workers' compensation premiums; engage workers; enhance social responsibility; and increase productivity and enhance overall business operations. https://safety.army.mil/Portals/0/Documents/ON-DUTY/WORKPLACE/templates/safety_policy_template_v4.doc?ver=2020-11-23-141656-043
Conclusion
The USACRC will develop additional templates to help you get into compliance with the OSHA standards as required. Future plans include publishing templates for the applicable sections for 29 CFR 1904 OSHA Reporting, 29 CFR 1915 Occupational Safety and Health Standards for Shipyard Employment, 29 CFR 1917 Marine Terminals and 29 CFR 1918 Safety and Health Regulations for Longshoring. These templates will be posted as they are developed.