OSHA Written Plans
JERROLD J. SCHARNINGHAUSEN, PhD
Workplace Safety Division
Directorate of Assessments and Prevention
U.S. Army Combat Readiness Center
Fort Rucker, Alabama
If an Occupational Safety and Health Administration (OSHA) inspector appeared at your workplace this morning, would you be prepared? OSHA is responsible for the administration and enforcement of the laws enacted to protect the safety and health of workers in the United States. Congress passed the OSH Act of 1970 to ensure employers were providing employees safe and healthy working conditions. The OSH Administration was created in 1971 to help with enforcing workplace laws and standards as well as to provide training, outreach, education and assistance to employers and their employees.
Congress enacted the OSH Act in response to workplace accidents that resulted in 14,000 worker deaths and 2.5 million disabling injuries annually. Since its inception, OSHA has cut the work-fatality rate by more than half, and it has significantly reduced the overall injury and illness rates in industries where OSHA has concentrated its attention. OSHA determines which standards and requirements apply to which workplace environments and then enforces employer adherence to those standards and requirements. OSHA sets these standards and requirements based on workplace research as well as input from technical experts, employers, unions and other stakeholders. OSHA officials can issue fines ranging into the tens of thousands of dollars for violations, and they can refer violators for criminal prosecution if they deem such action is warranted.
One of the most common citations issued by OSHA is the lack of a written plan. Not all OSHA regulations require written plans, but many do. When OSHA considers a safety or health hazard to be serious, the agency usually requires written documentation of the steps an employer takes to reduce the risk of injury or protect workers from the hazard. The question is which ones apply to your facility? Unfortunately, the answer is that it depends. There are too many variables for the Army to develop a one-size-fits-all policy.
So how do you determine what OSHA standards actually apply to your workplace? Supervisors must perform an assessment of each operation in their workplace to determine what hazards actually exist and then determine which standards apply. Assistance is available on most installations to help supervisors in making this determination. Seek assistance from your local safety office, industrial hygiene office, occupational health office, preventive medicine office, the environmental office and the fire department to determine applicable standards.
The U.S. Army Combat Readiness Center (USACRC) has developed several templates of written plans to assist you with getting into compliance. The USACRC Workplace Safety website, located at https://safety.army.mil/ON-DUTY/Workplace, has posted templates for 29 CFR 1910 OSHA-required written plans. These templates require an edit in order to include the site-specific information required by OSHA. The following written plan templates are available from the USACRC:
Hazard Communication Plan 29 CFR 1910.1200. This standard is designed to ensure employers and employees know about hazardous chemicals in the workplace and how to protect themselves. Employers with employees who may be exposed to hazardous chemicals in the workplace must prepare and implement a written hazard communication program and comply with other requirements of the standard. https://safety.army.mil/ON-DUTY/Workplace/Hazard-Communication
Lock-out/Tag-out Plan 29 CFR 1910.147. If you perform servicing and maintenance on machines and equipment where an unexpected start up or release of stored energy could injure personnel, a written plan is required. This standard applies to all energy release, not just electrical, and 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. https://safety.army.mil/ON-DUTY/Workplace/Lock-Out-Tag-Out
Personal Protective Equipment (PPE) 29 CFR 1910.132. If PPE is being utilized by any personnel, then a written plan is required. Note that engineering controls and work practices are the preferred methods for protecting personnel. OSHA generally considers PPE to be the least desirable means of controlling employee exposure. https://safety.army.mil/ON-DUTY/Workplace/Personal-Protective-Equipment
Respiratory Protection Plan 29 CFR 1910.134. If personnel are required to use respirators in the workplace, then a respiratory protection program that meets the requirements of OSHA's respiratory protection standard must be established. Medical clearance and fit-testing is required in addition to a written PPE plan. https://safety.army.mil/ON-DUTY/Workplace/Personal-Protective-Equipment
Bloodborne Pathogens Plan 29 CFR 1910.1030. If employees may be exposed to blood or bodily fluids as part of their assigned duties, you may be subject to OSHA's bloodborne pathogens standard. This does not refer to a co-worker having a bloody nose; it means reasonably anticipated skin, eye, mucous membrane or parental contact with blood or other potentially infectious materials that may result from the performance of duties. This normally includes all medical and custodial personnel. Medical facilities normally have a site-specific plan developed by their infection control officer. The link provides a plan for non-medical units. This will include — but is not limited to — emergency responders, law enforcement, accident investigators, custodial personnel and instructors. https://safety.army.mil/ON-DUTY/Workplace/Biological-Hazards
Emergency Action Plan (EAP) 29 CFR 1910.38. An EAP describes the actions employees should take to ensure their safety in a fire or other emergency situation. If fire extinguishers are required or provided in your workplace, and if anyone will be evacuating during a fire or other emergency, then OSHA requires you to have an EAP. The EAP will also include the use of any powered platforms for building maintenance. https://safety.army.mil/ON-DUTY/Workplace/Emergency-Planning-and-Response
Permit-Required Confined Space Plan 29 CFR 1910.146. OSHA defines confined space as being large enough and so configured that an employee can bodily enter and perform assigned work and has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults, pits, etc.) and is not designed for continuous employee occupancy. If personnel have access to permit-controlled confined space, then a written confined space entry program is required. A formal plan must include procedures for entry and rescue. No employee shall be required to enter any permit-required confined space unless a written confined space entry procedure is developed and implemented. https://safety.army.mil/ON-DUTY/Workplace/Confined-Space
Fire Prevention Plan 29 CFR 1910.39. OSHA recommends all employers have a fire prevention plan; however, it is mandatory only when required by an OSHA standard. These standards include ethylene oxide, methylenedianiline, and 1,3-butadiene. This plan is not a written requirement for most military units, as they are covered by the garrison plan. https://safety.army.mil/ON-DUTY/Workplace/Fire-Protection-Life-Safety-Code
Hearing Conservation Plan 29 CFR 1910.95. If personnel are exposed to excessive noise (e.g., 85 dBA time-weighted average), a written hearing conservation program is required. Military personnel are automatically enrolled in the program. Civilians can be scheduled at no cost for an audiogram by contacting their local occupational health office. https://safety.army.mil/ON-DUTY/Workplace/Physical-Hazards
Chemical Hygiene Plan 29 CFR 1910.1450. Chemical hygiene referred to as the laboratory standard specifies the mandatory requirements of a chemical hygiene plan (CHP) to protect laboratory workers from harm due to hazardous chemicals. The CHP is a written program stating the policies, procedures and responsibilities that protect workers from the health hazards associated with the hazardous chemicals used in that particular workplace. https://safety.army.mil/ON-DUTY/Workplace/Toxic-and-Hazardous-Substances
Exposure Control Plans required for Toxic and Hazardous Substances 29 CFR 1910.1000 Subpart Z. OSHA requires site-specific written exposure control plans for any exposure to toxic or hazardous substances that exceed the permissible exposure limit. The most common potential overexposures within the Army occur in maintenance facilities and include beryllium, cadmium, chromium, lead and silica. https://safety.army.mil/ON-DUTY/Workplace/Toxic-and-Hazardous-Substances
Over the coming months, the USACRC will develop templates to help you get into compliance with OSHA construction standard 29 CFR 1926. These templates will be posted as they are developed.