Written Program Requirements
The written program is the employer’s statement as to how he/she will protect employees from a specific hazard. Once the program is written, you must follow the program. Use care in writing it and ensure that it is actually what you will do in the workplace.
Before you begin writing a written program, read the TOSHA regulation that requires it. Trying to write a good program without having read the standard is just a stab in the dark. You should always read a standard before you try to comply with it. You may need someone more knowledgeable on the standard, such as a TOSHA consultant, to answer questions for you, but you will find it difficult to comply if you have not read the standard.
Well Written Programs
- are site-specific
- cover only what is needed for each site--short and sweet
- are practical and tested
- are updated as needed
Poorly Written Programs
- are not written for the site
- just restate the standard
- are written without knowledge of the standard
- have missing information or blanks
When you write your program, address all elements that the standard requires. You program will not be deemed effective if you omit portions that are required to be addressed.
Make your program accessible to your employees and to management. Tell them where it is kept and what the procedures are if they wish to obtain a copy of the program. Generally, accessibility of written programs must follow the requirements in 29 CFR 1910.1020.
There are many helpful resources available at www.osha.gov. Visit the site regularly and learn how to navigate it to find what you need.