By Julia Kunlo, CSP, Vice President

CFA Consulting Member

A written safety manual is often seen as the backbone of a workplace safety program. Documented processes are powerful tools, helping to outline expectations, train employees, bid work, and even avoid legal trouble. What many people do not know, however, is that the Occupational Safety and Health Administration has strict guidelines pertaining to what topics must be included in a written safety program. Are you sure that your company’s safety manual is OSHA compliant?

Authoring a safety manual that meets OSHA standards requires knowledge and research. Lucky for you, we have done the required digging through multiple references so you can quickly understand what your business needs. Based upon your business category (construction, general industry, or both), read below to learn what topics are required and their corresponding OSHA standard.

1. Global Requirements (Regardless of Industry)

Regardless of whether your business is categorized as “construction” or “general industry,” the following topics must be addressed in your manual:

• OSHA recordkeeping (OSHA 29 CFR 1904)
• Hazard communication (OSHA 29 CFR 1926.59 and 1200)
• Emergency action planning (OSHA 29 CFR 1926.35 and 38)
• Fire prevention plan (OSHA 29 CFR 1926.150 and 39)
• First aid (OSHA 29 CFR 1910.151 and 50)
• Lockout/tagout (OSHA 29 CFR 1910.147, 333, and 417)
• Personal protective equipment (OSHA 29 CFR 1910.132 and 1926 Subpart E)
• Hearing conservation (OSHA 29 CFR 1910.95 & 101)
• Crane/hoisting inspection program (OSHA 29 CFR 1910.179, 184, 251, and 552)
• Respiratory protection program (OSHA 29 CFR 1910.134 and 103)
• Powered industrial truck operator training (OSHA 29 CFR 1910.178 and 602[d])

2. Construction Industry Requirements

If your business is categorized as construction, then OSHA 29 CFR 1926 applies. In addition to the global requirements, the following topics must be address in your manual:

• General safety and health provisions (OSHA 29 CFR 1926.20)
• Trenching and excavations (OSHA 29 CFR 1926.651 and 652)
• Fall protection (OSHA 29 CFR 1926 Subpart M)
• Safety training and education (OSHA 29 CFR 1926.21)

3. General Industry Requirements

If your business is categorized as general industry, then OSHA 29 CFR 1910 applies. In addition to the global requirements, the following topics must be address in your manual:

• Electrical safety-related work practices (OSHA 29 CFR 1910.331, 332, 333, 334, 335, and 399)
• Bloodborne pathogen exposure (OSHA 29 CFR 1910.1030)
• Confined space entry (OSHA 29 CFR 1910.146)
• Machine guarding (OSHA 29 CFR 1910 Subpart O)
• Hot work program (OSHA 29 CFR 1910.106, 119, and 252)
• Laboratory chemical safety (OSHA 29 CFR 1910.1450)
• Spill response plans (OSHA 29 CFR 1910.120)

When building a written safety manual, it is important that companies understand the minimum requirements outlined by OSHA. This understanding will help to create a program that is equipped to protect businesses from legal or regulatory trouble. It is equally as important to build a manual that can be used as a practical and helpful tool for your business, training your team on how you expect them to perform safely in the field. Consider adding additional best-in-class procedures to your manual (such as information on defensive driving, heat/cold stress, job hazard analysis, etc.) to build a written program that is truly top level. If you need assistance with auditing your current manual or making improvements, the experts at ESR are ready and available to help. We offer free consultations and will develop complimentary improvement plans.