• OSHA Releases Updated Recommended Practices for Safety and Health Programs
  • November 17, 2016
  • Law Firm: Shawe Rosenthal LLP - Baltimore Office
  • The Occupational Safety and Health Administration has updated its 30-year old guidance on safety and health programs with new Recommended Practices for Safety and Health Programs. While these recommended practices are not legally required, OSHA’s intent is to help employers establish a proactive approach to managing workplace safety and health.

    The Recommended Practices, which are built around seven core elements, present a step-by-step approach to implementing a safety and health program. These core elements are interrelated, and each has associated action items, which may or may not be appropriate for a particular employer. While the Recommended Practices guidance provides much more detail and offers specific suggestions on how to accomplish each action item, these core elements and action items can be summarized as follows:

    1. Management Leadership
    • Communicate commitment to a safety and health program
    • Define program goals
    • Allocate resources
    • Expect performance
    2. Worker Participation
    • Encourage workers to participate in the program
    • Encourage workers to report safety and health concerns
    • Give workers access to safety and health information
    • Involve workers in all aspects of the program
    • Remove barriers to participation
    3. Hazard Identification & Assessment
    • Collect existing information about workplace hazards
    • Inspect the workplace for safety hazards
    • Identify health hazards
    • Conduct incident investigations
    • Identify hazards associated with emergency and nonroutine situations
    • Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control.
    4. Hazard Prevention & Control
    • Identify control options
    • Select controls
    • Develop and update a hazard control plan
    • Select controls to protect workers during nonroutine operations and emergencies
    • Implement selected controls in the workplace
    • Follow up to confirm that controls are effective
    5. Education & Training
    • Provide program awareness training
    • Train employers, managers, and supervisors on their roles in the program
    • Train workers on their specific roles in the program
    • Train workers on hazard identification and controls
    6. Program Evaluation & Improvement
    • Monitor performance and progress
    • Verify that the program is implemented and is operating
    • Correct program shortcomings and identify opportunities to improve
    7. Communication and Coordination for Host Employers, Contractors and Staffing Agencies
    • Establish effective communication with contractors, staffing agencies, and workers
    • Establish effective coordination with contractors and staffing agencies
    It is worth noting the last core element, which is a new addition to the guidance. This focus on temporary staffing or contractor employees is part of a larger landscape of federal agencies generally addressing the obligations of host employers to such workers under various employment laws. Along with OSHA, the National Labor Relations Board, the Equal Employment Opportunity Commission, and the Department of Labor have all recently addressed the issue of joint employer status for the host employer with regard to these workers.

    OSHA has a webpage dedicated to the Recommended Practices, with additional informational resources and tools, including templates, worksheets and reference materials.