Several regulatory agencies direct which documents are required when performing a company’s tasks. In some cases, federal and state requirements must be adhered to for the same task or hazard. For example, in the United States, the U.S. Environmental Protection Agency (US EPA) and state environmental agencies such as the Massachusetts Department of Environmental Protection (MA DEP) regulate potential environmental impacts that can occur during performance of a task. For workplace safety, requirements are handed down from the U.S. Department of Labor (DOL) and its sub-department, the Occupational Safety and Health Administration (OSHA). Canada has its own version of OSHA — the Canadian Centre for Occupational Health and Safety, or CCOHS.
Currently, 22 U.S. states have their own state-approved occupational safety agency with regulatory oversight over private business:
- New Mexico
- North Carolina
- Puerto Rico
- South Carolina
This article explores the typical safety documents required to comply with U.S. federal OSHA standards. Every company should familiarize itself with these requirements and comply with any other regulations that apply to their business.
OSHA provides guides for developing safety programs. The format depends on whether the requirement is applicable to the specific work being performed. These guides can be found on the OSHA.gov website: https://www.osha.gov/employers. Canadian employers regulated by CCOHS can find guidelines and samples at https://www.ccohs.ca/topics/legislation/programs/.
Before developing a program, policy, plan, or procedure — and the training that goes with them — it is important for a company to know the scope of work and where the work will occur, as the requirements change depending on work location. For example, U.S. work performed in a construction setting might not have the same requirements as work performed in a general industry setting. Additionally, not all OSHA requirements are applicable to a specific setting. For example, if the company performs entry into enclosed spaces only, but does not enter into confined spaces that require a permit, the program should indicate that and training must include that information. The program would not need to cover entry into permit-requiring confined spaces, even though enclosed and confined spaces are found in the same OSHA regulation.
JOB HAZARD ANALYSIS
A job hazard analysis (JHA) is an important tool to analyze the work to be performed and the hazards associated with each step in performing the work. Companies should take the time to create JHAs to better understand which hazards their employees will encounter. In some instances, such as in construction, a JHA is required per OSHA. JHAs can be known by other names, such as a job safety analysis (JSA) or even just a hazard analysis (HA), but they all have essentially the same outcome: identification of known hazards associated with completion of a task. Pre-job briefs, if detailed enough, can be a suitable substitute for a JHA. To view a sample OSHA JHA, visit
Once a JHA has been completed, known hazards will be identified. The completed JHA should be reviewed with all personnel performing the work. Once a hazard is identified, the appropriate OSHA or CCOHS regulation can aid in creating a program, policy, procedure, or training.
Policies can be short, sweet, and to the point. Think of these as a description sheet for a task or hazard. They are a position statement on how a company will address an issue, whether it is safety, environmental, procedural, or even human resource-related. It is usually not heavily detailed, but can be if the topic can be covered succinctly, and it references other pertinent information. For example, a policy for respiratory protection might only state when wearing a respirator would be necessary and that the company provides the respirator and training. If a topic requires greater detail, it is usually fully documented in a procedure or program. Policies outline who and when but are not detailed when it comes to how the work is accomplished. Policies may also refer to what can occur should a task not be completed as required.
Programs are designed for extensive detail. Think of a program as a detailed instruction sheet, including all components necessary for the work. A program highlights the requirements as set forth by the regulatory agency and reviews the training necessary prior to beginning the task. It gets into the specifics of who, what, where, when, why, and how. The program references the documents (i.e., inspection forms) required to comply with the regulations.
Programs are fairly extensive, and often mimic a regulation line for line to ensure compliance. For example, a program states what employees are required to do, where they can find information on performing the task, and how to remain in compliance with requirements. It also reviews what the company is required to perform to maintain compliance with the regulation. Each applicable hazard usually has its own program. To continue the example, a respiratory protection program details the training, which areas require a respirator, how to determine whether a respirator is required, how to select the type of respirator, how to maintain a respirator, medical clearances necessary for use, and even how an employee is issued a respirator.
Procedures are very task-oriented. Think of a procedure as a detailed step within a set of instructions that is very specific for each task performed. It references requirements as stated in programs, and give physical direction on how a task is to be performed line for line. It also generally discusses the hazards associated with each step of performing the task. Continuing the example again, a procedure would detail how to maintain a respirator. The program will state that a respirator is to be cleaned daily, but the procedure will tell the employee in specific detail how to properly clean the respirator.
Think of these as a general overview. A manual is usually designed as a reference for a program. A manual contains only the information pertinent to how an employee is to comply with all of the company’s requirements. In some cases, a company may replace individual programs with a manual, essentially making the manual a collection of programs — each chapter becoming its own program. This depends on how much information is being relayed. If the chapter is extensive, or the regulation the company is attempting to comply with contains requirements that do not apply to all of the company’s tasks, then it would make sense to summarize only the information critical to how the company will comply. A separate program would be created detailing the specifics of what is required for compliance, what is not, and why. Continuing the previous example, if the employee is required to use a new respirator, a manual may just tell them where to obtain one. Details as far as types used or any requirements for type used would be contained in the program.
Training must cover all information the employee needs to know to reduce or mitigate the hazard while performing the task. The employee is not required to review the applicable program, but some companies choose to perform training in this manner. Since a program is written to reflect the relevant regulation, this can be pretty boring. Because of this, some companies choose to train using other methods, such as presentations, videos, or even just on-the-job (OJT) training. However, the company must ensure the employee is competent to perform the task before they perform the task. In some cases, competency must be observed and refreshed on a regular basis, depending on the regulatory requirement. To document competency, a company can use quizzes or tests or even simple sign-off sheets indicating that the employee reviewed and understood the information. No matter how training is conducted, this documentation must be completed and maintained on file so long as the employee works at that company.
Companies must comply with many requirements, and there are many ways to go about complying with those regulations. But no matter how a company chooses to comply, it cannot avoid the eventual paperwork and documents that must be created to reach and maintain compliance. A JHA is a good starting point for determining which hazards are present when performing a job. Once you have identified the hazard, you can more easily identify the regulation created to mitigate the hazard. Once a company fully complies with the regulation and informs the employee of those requirements, it will go a long way to preventing injuries. After all, knowledge is power, and the more an employee knows about a hazard and how to mitigate it, the less likely it is for an employee to be injured by that hazard.
Paul Chamberlain has been the Safety Manager for American Electrical Testing Co. LLC since 2009. He has been in the safety field since 1998, working for various companies and in various industries. Paul received a BS from the Massachusetts Maritime Academy.