Buying a generic safety manual can create a false sense of security. OSHA requirements are hazard- and activity-specific, and several standards require written programs or procedures only when their applicability criteria are met.
The right question is not “Do I need a safety manual?” It is “Which standards apply to our work, and which of those standards require a written plan, procedure or program?”
What written safety programs does OSHA require?
OSHA does not publish one universal list that applies identically to every company. An employer should first identify its industry, workplace hazards, employee exposures and covered activities, then determine which OSHA standards apply. Those applicable standards determine which written plans, programs, procedures and records are required.
For example, an employer with 60 employees does not automatically need a different set of written programs simply because it has 60 employees. The controlling questions are what work employees perform, what hazards and exposures exist, and which standards apply. Employer size can matter for particular provisions—such as the limited oral emergency-action-plan allowance for employers with 10 or fewer employees—but it does not replace the hazard-by-hazard review.
What written safety programs does OSHA require?
OSHA does not publish one universal list that applies identically to every company. An employer should first identify its industry, workplace hazards, employee exposures and covered activities, then determine which OSHA standards apply. Those applicable standards determine which written plans, programs, procedures and records are required.
For example, an employer with 60 employees does not automatically need a different set of written programs simply because it has 60 employees. The controlling questions are what work employees perform, what hazards and exposures exist, and which standards apply. Employer size can matter for particular provisions—such as the limited oral emergency-action-plan allowance for employers with 10 or fewer employees—but it does not replace the hazard-by-hazard review.
Common federal OSHA written-program triggers
A written document is only one part of compliance
A compliant written program normally has to connect to real implementation. A respiratory program, for example, is not complete because a document exists; the standard also addresses respirator selection, medical evaluations, fit testing, use, maintenance, training, program evaluation and records.
Likewise, a HazCom program must match the chemicals actually present, the workplace labeling system, SDS availability and employee training. Generic language that does not reflect the workplace can be difficult to defend and even harder for employees to use.
State-plan and industry differences matter
Federal OSHA is not the only possible layer. OSHA-approved state plans can have requirements that are at least as effective as federal OSHA and may differ in important ways. Industry classification also matters: construction, maritime and agriculture use different regulatory structures for many hazards.
A practical way to build the program list
- Identify jurisdiction and industry.
- List significant hazards, equipment and exposures.
- Map each hazard to the current regulation.
- Identify written-program, procedure, permit, inspection and recordkeeping requirements.
- Assign program owners and review dates.
- Link training and field records back to the written program.
Primary sources
Use the current regulation and agency guidance for decisions about your workplace. These links were reviewed when this resource was published.
Important boundary
This resource is general educational information, not a legal determination that a particular OSHA, state-plan, DOT or other requirement applies to your company. Applicability depends on industry, jurisdiction, tasks, exposures, equipment, employee duties and other facts.