OSHA provides employers with a "General Duty" to provide employees with "safe and healthful working conditions, in workplaces free of recognized hazards" which comply with OSHA standards for general industry, construction, and other industry segments.
States like Virginia accept delegation of OSH Act requirements and provide similar requirements. To meet this General Duty, each employer must first recognize workplace hazards at their place of business. This can be thought of as two different types of inquiry:
(1) Review standards issued by the Occupational Safety and Health Administration (OSHA) or your state's OSH agency, and identify and comply with those applicable to your workplace.
(2) Evaluate your workplace for potentially hazardous conditions that are not yet subject to a specific OSHA standard to make sure you also recognize and control those otherwise unregulated hazards.
Employers and their supervisors naturally focus on the first piece, which involves codified requirements that an employer is aware of. The second piece can be less concrete, and is often neglected until an employee is hurt by an otherwise unregulated hazard (e.g., mold, repetitive-motion ergonomic hazards, and even workplace violence).
OSHA has not yet adopted a national standard which codifies how employers are required to meet their General Duty responsibilities. In 1989, OSHA first issued "Safetyand Health Program Management Guidelines" - and then updated them in 2015. Meanwhile, many states (including California, Minnesota, Nevada, North Carolina, Oregon, and Washington) require, or at least recommend, that employers create such written programs. California calls these programs Injury and Illness Prevention Programs (IIPPs), while Washington and most others call them Accident Prevention Programs (APPs). Since 2010 Federal OSHA has been working on a rulemaking to codify a requirement to do so, in what OSHA calls Injury and Illness Prevention Programs [with the acronym I2P2].
Since all these programs derive from OSHA's 1989 Guidelines, they all impose similar requirements. In its original Guidelines, OSHA suggests at least the following four elements:
Management commitment and employee involvement
Worksite analysis-to identify hazards
Hazard prevention and controls-addressing the hazards identified
Safety and health training
In its IIPP regulations, California clarifies and expands the list to include all of the following elements:
Responsibility-identify the person responsible for implementing the IIPP
Compliance-system to ensure employees comply with safe and healthful work practices
Communication-system for communicating occupational safety and health information in readily understandable forms to employees
Hazard Assessment-system for identifying and evaluating workplace hazards, including periodic inspections
Accident/Exposure Investigation-procedures to investigate reported workplace injuries and illnesses
Hazard Correction-methods and procedures for timely correction of unsafe and unhealthful conditions and work practices
Training and Instruction-training for all new and reassigned employees in safeand healthful work practices
Recordkeeping-retention of certain IIPP-related compliance records
OSHA Health and Safety Checklist
- Has the organization established a general workplace safety and health program?
- If so, does it comply with applicable requirements?
- Does the organization take effective steps to identify and correct workplace hazards, including:
- Audit the workplace to identify potentially hazardous operations and locations, and assess the nature of each hazard
- Identify OSHA/state requirements applicable to those hazards, and institute required compliance measures
- Review external information about types of hazards and generally identified practices for hazard management
Does the organization administer a thorough health and safety program, including the following steps:
- Assign specific qualified personnel to administer health and safety protection program elements
- Evaluate how employees may be exposed to recognized hazards, by routine and non-routine activities and situations in the workplace
- Evaluate how engineering controls, administrative controls and procedures, and personal protective equipment (PPE) can be applied to manage hazards to acceptable levels
- Define administrative controls and procedures, and training to operate activities in compliance with applicable requirements and consistent with practices necessary to conduct unregulated activities safely
- Establish appropriate training programs, identify personnel who require specific training, and deliver training
- Establish recordkeeping procedures
- Establish ongoing workplace evaluation/inspection and recordkeeping programs sufficient to verify adequate implementation of designed programs and elements
- Establish incident response procedures
- Establish procedures for reviews of operations and protective procedures, periodically and after incidents, and for implementation of identified enhancements
Comment: SRA specializes in helping clients identify and mitigate costly workplace hazards -- including hazard assessments, written safety plans, and management objectives to protect employees from hazards and reduce costs. The National SafetyCouncil reports an estimated 600% return-on-investment related to effective safetymanagement regardless of company size or industry.