Written Program Requirements

Employers are required to develop and implement a written respirator program if respirators are being worn or if the permissible exposure limits (PELs) exceed those required by OSHA.. OSHA s 1910.134 respiratory protection standards require the following components. 

Proper cleaning Disinfecting Storing Inspecting Repairing Discarding 

For atmosphere-supplying respirators, procedures are needed to ensure adequate air quality and flow of breathing air. 

Employees must be trained to recognize and protect themselves from the respiratory hazards during routine work and emergency situations. 

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United States Department of Labor, Occupational Safety and Health Administration. Citation Policy for Paperwork and Written Program Requirement Violations (OSHA Instruction CPL 2.111). Washington, D.C. U.S. Department of Labor, November 27,1995. 

The requirements of the hazard communication program including the location and availability of the written program, required lists of hazardous chemicals, and... 

Is a written program required for workplaces that have permit-required confined spaces, but never enter them ... 

Is a written program required if an employer requires respirators to be worn even though employees are not exposed to airborne contaminants in excess of the permissible exposure limit ... 

OSHA Instruction CPL 2.II I. November 27, 1995, Citation Policy for Paperwork and Written Program Requirement Violations. 

In assessing the effectiveness of a safety and health program that is not in written form, compliance officers should follow the general principles laid out in OSHA Instruction CPE 2.111. Citation Policy for Paperwork and Written Program Requirement Violations. That is ... 

The employer should establish and maintain a respiratory proteetion program when respirators are required to proteet the health of the employee. The program should be in writing and eontain all of the elements speeified in the standard. If the written program has all of the required elements but the employer has not taken one or more of the aetions required, he or she ean be eited for eaeh element that has not been met. 

A written respiratory protection program is required when necessary to protect the health of the employee from workplace contaminants or when the employer requires the use of respirators. A limited written program is also required when respirators (other than dust masks) are being voluntarily worn by employees. This latest document states It is the intent of the standard that the employer would not be required to incur any costs associated with voluntary use of filtering facepieces other... 

Compliance with the written program can be verified during the walkaround by personal observation and employee interviews. If respirators are required to be worn in the workplace or respirators other than dust masks are worn by voluntary users, a written program is required. An overexposure is not required to cite. Discrepancies between the written program and implemented work practices at the worksite should be cited. Use of a elastomeric or supplied-air respirator, even when voluntary on the part of the employee, will require the employer to include all elements in a written program that will make sure that there is proper use of these respirators so that they do not create a hazard. 

The employer is required to address in its written program the type of regular surveillance of the workplace necessary to evaluate the effectiveness of the respirator program. Other items discussed in the standard include ... 

Contractors at Sites E, H, and J had documented confined space programs but had not fully implemented these programs. The Site H contractor had established a permit-required confined space entry program consistent with HAZWOPER requirements however, onsite procedures were not completely consistent with the written program or OSHA requirements. For example, the confined space permit form used at Site H was not the form included in the written program. The audit team also found evidence that employee training was insufficient for safe... 

Written programs are complete and satisfy the regulatory requirements. 

Probably one of the most important safety and healtli standards ever adopted is tlie OSHA hazard communication standard, more properly known as tlie right to know laws. The liazard communication standard requires employers to communicate information to tlie employees on liazardous chemicals tliat e.vist witliiii the workplace. The program requires employers to craft a written luizard communication program, keep material safety data sheets (MSDSs) for all haztirdous chemicals at the workplace and provide employees with training on tliose hazardous chemicals, and assure tliat proper warning labels are in place. 

The cGMP requirements dictate that the calibration of instruments should be performed at suitable intervals in accordance with an established written program. Instruments not meeting established specifications must not be used. Each instrument should have a calibration sticker with information related to the status of the system, when the calibration was performed, who did the calibration, and the next calibration date. A systematic program is required to maintain the instruments in a state of calibration. The following points should be considered when setting up an instrument calibration and maintenance program. 

Dow s Critical Instruments Program requires that written records of critical instrument tests, with the name of the tester and information on any unsatisfactory performance, be kept for the current and preceding year. In addition, the Critical Instruments Program is included in the plant s program of safety audit and is audited on an annual basis. 

Be monitored according to a written program and scheduled for compliance with the requirements. 

Replacement of gate valves with ball valves (within the plant valve specifications or within regular usage for that service). (Depending on the level of maturity of your organization, and your written program, this valve substitution and the two examples that follow could require an MOC for this type of situation.)... 

No program covering the health and safety job requirements No written program... 

Competency case application. Figure 14.2 gives the current competency program flowchart. The work group brainstormed to discuss all process steps of the current complex competency program. Pharmacists are oriented to departmental operations and also to clinical programs. Competency exams are written and require manual grading and are distributed to... 

Chemical manufacturers, importers, or employers evaluating chemicals shall describe in writing the procedures they use to determine the hazards of the chemical they evaluate. The written procedures are to be made available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director. The written description may be incorporated into the written hazard communication program required under paragraph (e) of this section. 

Walls, floors, ceilings, and equipment in a clean area are cleaned and, when required, disinfected in accordance with a written program. The program differentiates between the daily procedures and those undertaken when a different drug is fabricated. 

Table 2.1 Requirements of stability program 211.166(a) Written program must include ...

Does the written program provide employees (including contractor employees) and their representatives access to PHAs and all other information developed as required by the PSM standard . 119(c)(3) ... 

One of the biggest differences between the RMP and PSM standards is that EPA requires that a formal, written program be prepared, and which is then placed in the public domain. OSHA does not require this. EPA needs a written plan because the RMP is very concerned with making sure that members of the public are fuUy informed as to what hazards are in their community, and what to do if there is an accident, and how the various emergency agencies can work together. 

There are two aspects to this requirement. First, management must prepare a formal, written program as to how they intend to manage change in their facUity. Second, all changes made... 

For employers using hazardous chemicals, the most important aspect of the written program in terms of MSDSs is to ensure that someone is responsible for obtaining and maintaining the MSDSs for every hazardous chemical in the workplace. The list of hazardous chemicals required to be maintained as part of the written program will serve as an inventory. As new chemicals are purchased, the list should be updated. Many companies have found it convenient to include on their purchase orders the name and address of the person designated in their company to receive MSDS. 

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