Written programs, OSHA required

Bloodborne Pathogens. A brief discussion of the OSHA requirements by for bloodborne pathogens is essential. Show employees a copy of the written program, PPE requirements, cleanup procedures, proper disposal methods, and the requirements of this particular regulation. If a nurse is available, he/she could perform these training duties. 

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... 

The OSHA Hazard Communication Standard, better known as the Right-to-Know law, requires that the hazards of all chemicals produced in or imported into the United States are evaluated and that employers provide their employees with all appropriate hazard information. This involves providing employees with hazard communication/training programs and access to material safety data sheets (MSDSs) and written records. OSHA considers the MSDS the primary vehicle for transmitting detailed hazard information to downstream employers and employees. 

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. 

OSHA requires that the Employee Participation program be written down. This can be difficult to do well because Employee Participation is involved in so many areas of process safety and because participation represents a state of mind rather than a specific program. 

Keep in mind that this Toolbox Talk covers the voluntary use of dust masks only. It does not cover the voluntary use of other respirators, such as elastomeric air-purifying respirators or powered air-purifying respirators. In those cases, there are further provisions for you to follow at 1910.134, such as for medical evaluation, scheduling, and certain elements of a written program. Also, this Toolbox Talk does not cover surgical masks, which are not considered respirators nor dust masks. Finally, if dust masks are required to be used by the employer, even when not required by OSHA, they cannot be considered Voluntary use. ... 

Most of the OSHA-required written programs are referenced in other portions of this text. As a review or summary, most are pre-... 

Nearly every company needs some written programs. The above are the most common ones required by OSHA for general industry. In addition companies must post the OSHA poster, and those with 11 or more employees are also required to maintain accident records as outlined in chapter 3 under recordkeeping. 

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. 

Obviously, to get accurate data upon which to base its judgment, OSHA requires extensive recordkeeping for written programs, injuries, illnesses, safety audits, inspections, corrections, and training. Training is a major part of the OSH Act. Almost every regulation requires some sort of transmission... 

The following sample safety and health programs are intended to provide examples of written programs on various workplace safety and health topics. They are not intended to supersede the requirements in OSHA standards. Employers should consult the applicable OSHA standards for the specific requirements applicable to their workplaces. Employers can use these sample programs as guidance when developing their own customized programs that are tailored to their specific workplaces. 

The irony is that the area that OSHA checks first is the one that the employer most frequently leaves for last. A large percentage of the OSHA citations have been issued due to the lack of, or an inadequate, written program. In fact, deficiencies to the written hazard communication program requirement has topped the list of federal OSHA violations as the most cited standard for many years. 

The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program—an assurance that all aspects of the requirements have been addressed. It serves to communicate to your employees and to OSHA exactly what you have done to comply with the HCS. In general, the written program must describe how the requirements for labels and other forms of warning, safety data sheets, employee information, and training are going to be met in your facility. 

This section deals with some of the programs that can be used to improve a plant s safety performance. The first part briefly describes the most prominent techniques for process hazard analysis. A formal written program for analysis of certain facilities, with schedule for completion, is now required by OSHA (29CFR1910.119). 

The first thing discussed in this chapter is a written program for hazard communication that is going to be important in staying in compliance with the requirements set forth by the OSHA standard. The specific methods described are used as a sample written program, and are for illustrative purposes and not intended to make up your entire program. Other effective methods can be substituted into this sample to satisfy the needs of the company for which you are working. 

This perceived need for written programs must be tempered with a view to their practical development and implementation. A very small employer who employs one to four employees and no supervisors in all likelihood needs only a very basic written plan, along with any other written programs that are required as part of an Occupational Safety and Health Administration (OSHA) regulation. However, as the size of the company and the number of employees increase, the employer becomes more removed from the hands-on aspects of what now may be multiple facilities or worksites. 

Although federal regulations do not currently require employers to have a written safety and health program, the best way to satisfy OSHA requirements and reduce accidents is for employers to produce one. In addition, distributing a written safety and health program to employees can increase employee awareness of safety and health hazards while, at the same time, reducing the costs and risks associated with workplace injuries, illnesses, and fatalities. 

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 ... 

As discussed previously, OSHA regulations do not require written comprehensive HSE programs for the construction industry, although some specific regulations call for written programs or plans and some states and countries require an IIPR... 

The question becomes What is required to ensure that a facility s CHP meets all OSHA requirements or guidelines— so that it can stand alone as the lab s written safety and health program ... 

The Occupational Safety and Health Administration s (OSHA s) r ulation for Occupational Exposures to Hazardous Chemicals in Laboratories, 29 CFR 1910.1450 (the standard), requires that each facUity engaged in the laboratory use of hazardous chemicals develop and implement a written program known as a Chemical Hygiene Plan, which sets forth procedures, equipment, personal protective equipment, and safe work practices that will ... 

Is there a comprehensive written program that meets OSHA requirements ... 

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