The short answer
OSHA's standards are written hazard by hazard, and so are the paperwork requirements. If you have hazardous chemicals, you need a written hazard communication program. If anyone services a machine, you need written lockout procedures. If anyone wears a required respirator, a written respiratory protection program. And so on down the list below. If you don't have the hazard, you don't need the program, and having a 400-page manual full of programs for hazards you don't have mostly creates things an inspector can cite you for not following.
The one all-purpose written program, an injury and illness prevention program covering everything, is required by several state plans (California, Washington, Minnesota in listed industries, Nevada over 10 employees), by many general contractors and owners, and by almost every prequalification system. Federal OSHA recommends one and publishes guidelines, but does not require it.
Start from your hazards, not from a binder. Walk the shop or the job, list what is there, and the table tells you what has to be on paper.
General industry: Part 1910
| Program | When it is required | Rule |
|---|---|---|
| Hazard communication program | Any hazardous chemical in the workplace beyond consumer-product use. Written program, chemical inventory, labels, safety data sheets, training. The most-cited paperwork standard in general industry. | 1910.1200(e) |
| Emergency action plan | Wherever another standard calls for one, which in practice means any workplace where employees are expected to evacuate for a fire instead of fighting it. Written and kept at the workplace; may be communicated orally with 10 or fewer employees. | 1910.38 |
| Fire prevention plan | Same trigger structure as the EAP, and usually written with it. Lists the fire hazards, the ignition sources, the housekeeping, and who maintains the fire equipment. Oral allowed with 10 or fewer employees. | 1910.39 |
| PPE hazard assessment | Every workplace. Not a program: a written certification that the hazard assessment was done, naming the workplace, the person who did it and the date, plus training for each PPE user before they use it. | 1910.132(d), (f) |
| Respiratory protection program | Whenever respirators are required. Written, worksite-specific, with a trained program administrator, medical evaluations, fit testing and training. Voluntary use of filtering facepieces (N95s) only requires Appendix D; voluntary use of other respirators requires parts of the program. | 1910.134(c) |
| Hearing conservation program | Noise exposure at or above an 8-hour average of 85 dBA. Monitoring, annual audiograms, hearing protection, training, records. The rule does not say "written," but it cannot be run without the documents. | 1910.95(c) |
| Lockout/tagout energy control program | Anyone services or maintains machines where unexpected startup or stored energy could injure them. Documented procedure for each machine, annual inspection of each, training records. | 1910.147(c) |
| Permit-required confined space program | Employees enter permit spaces. Written program, permits, attendants, rescue arrangements, training. If nobody enters, you still have to identify the spaces, post them and keep people out. | 1910.146(c) |
| Bloodborne pathogens exposure control plan | Any employee with occupational exposure to blood, which includes workers you designate to give first aid. Written plan reviewed annually, hepatitis B vaccination offered, training. | 1910.1030(c) |
| Powered industrial truck training | Forklifts, pallet jacks, telehandlers. Not a written program, but a training and evaluation record for each operator, with an evaluation at least every three years. | 1910.178(l) |
| Silica exposure control plan | Where exposures can reach the action level of 25 µg/m³: abrasive blasting, cutting or grinding concrete, stone, brick or engineered stone, foundries. Written plan. | 1910.1053(f)(2) |
| Lead, asbestos, cadmium, benzene, formaldehyde, methylene chloride | Exposures above the action level or PEL for that substance. Each standard requires its own written compliance program, monitoring and medical surveillance. | 1910.1025, 1910.1001, 1910.1027, 1910.1028, 1910.1048, 1910.1052 |
| Hazardous waste operations and emergency response | Cleanup sites, treatment and disposal facilities, and anyone who responds to chemical releases beyond incidental spills. Written safety and health program; written emergency response plan. | 1910.120 |
| Process safety management | Threshold quantities of highly hazardous chemicals, including anhydrous ammonia refrigeration and flammables over 10,000 pounds. Fourteen written elements. | 1910.119 |
| Chemical hygiene plan | Laboratories using hazardous chemicals. | 1910.1450(e) |
| Electrical safety work practices | No written program required by the rule; training for anyone who faces electrical risk. The industry expectation, and what insurers and customers ask for, is an electrical safety program under NFPA 70E. | 1910.332, 1910.333 |
| Fall protection, machine guarding, exits, first aid | No written program required. Training by a qualified person for fall hazards (1910.30), guards in place, exit routes maintained, a trained first-aid person when there is no clinic nearby. These get cited constantly; they just get cited for conditions, not for paperwork. | 1910.28, 1910.30, 1910.212, 1910.36, 1910.151 |
Construction: Part 1926
| Program | When it is required | Rule |
|---|---|---|
| Accident prevention program | Every construction employer: "initiate and maintain such programs as may be necessary," with frequent and regular inspections by a competent person. The rule does not say "written." Every GC, owner and prequal system does, and it is the only way to prove you have one. | 1926.20(b) |
| Hazard communication program | Same as general industry: any hazardous chemical on the job. Fuel, concrete, adhesives, solvents, welding gases. | 1926.59 (adopts 1910.1200) |
| Emergency action plan | Where another standard requires one. Written; oral with 10 or fewer employees. | 1926.35 |
| Fire protection program | Every job: develop a fire protection program for all phases of the work. Extinguishers, hot work, flammable storage, temporary heat. | 1926.24, 1926.150(a) |
| Respiratory protection program | Required respirators: silica, lead, asbestos, spray painting, welding in enclosed spaces. Written, with a program administrator, medical evaluation, fit testing. | 1926.103 (adopts 1910.134) |
| Silica exposure control plan | Every construction employer whose work can expose employees at or above the action level: cutting, grinding, drilling, jackhammering concrete, masonry, stone. Written plan with the tasks, the controls, housekeeping, and a designated competent person. | 1926.1153(g) |
| Fall protection plan | Only when conventional fall protection is infeasible for leading edge, precast or residential work. Written by a qualified person, site-specific, kept on site. Most contractors never need one, because guardrails, nets or harnesses are almost always feasible. | 1926.502(k) |
| Fall protection training certification | Everyone exposed to fall hazards: a written record with the name, the training dates and the trainer's signature. | 1926.503(b) |
| Permit-required confined space program | Entry into permit spaces: manholes, vaults, tanks, pits, crawl spaces with hazards. Written program; a competent person identifies the spaces first. | 1926.1203(d), 1926.1203(a) |
| Lead compliance program | Exposures above the PEL: demolition, torch cutting, abrasive blasting of old coatings, bridge work. Written compliance program plus monitoring and medical surveillance. | 1926.62(e)(2) |
| Asbestos, cadmium, MDA, methylene chloride | Each has its own written requirements when the work disturbs the material. | 1926.1101, 1926.1127, 1926.60, 1926.1152 |
| Assured equipment grounding conductor program | Only if you use it instead of GFCIs on temporary power. A written description of the program, with the test records. | 1926.404(b)(1)(iii) |
| Demolition engineering survey | Before demolition starts: a survey of the structure by a competent person, and written evidence that it was done. | 1926.850(a) |
| Excavation designs and inspections | No written program. Tabulated data or an engineer's design on site when you use them for sloping or shoring; the competent person's daily inspections, which the rule does not require in writing but every investigation asks for. | 1926.652, 1926.651(k) |
| Cranes | No written program. Documented monthly and annual inspections, operator certification, signal person qualification records, and assembly/disassembly procedures from the manufacturer or an equivalent. | 1926 Subpart CC |
| Steel erection site-specific plan | Only if the erector chooses alternate methods to the rule's defaults. | 1926.752(e) |
| Training records with specific content | Scaffolds, ladders and stairways, aerial lifts, powder-actuated tools, flaggers, forklifts and telehandlers each require training; forklift training is certified in writing, and powder-actuated tool operators carry the manufacturer's card. | 1926.454, 1926.1060, 1926.453, 1926.302(e), 1926.201, 1926.602(d) |
| Site-specific safety plan | Not an OSHA requirement. Required by most general contractors and owners before you mobilize, and by the Army Corps as an Accident Prevention Plan under EM 385-1-1. | Contract |
What the state plans add
- California: a written Injury and Illness Prevention Program for every employer (8 CCR §3203), a Code of Safe Practices for construction (§1509), written heat illness prevention plans outdoors (§3395) and indoors (§3396), and a workplace violence prevention plan for nearly all employers (Labor Code §6401.9).
- Washington: a written Accident Prevention Program for every employer (WAC 296-800-140), an outdoor heat plan, and a wildfire smoke plan.
- Oregon: heat illness prevention plan and wildfire smoke plan (OAR 437-002-0156 and -1081); safety committee or meetings with minutes for every employer.
- Minnesota: a written AWAIR program for employers in the industries on its list, which includes most construction trades, manufacturing, trucking and warehousing (Minn. Stat. §182.653 subd. 8).
- Nevada: a written workplace safety program for employers with more than 10 employees (NRS 618.383).
- Maryland: a written heat-related illness prevention plan (COMAR 09.12.32).
The written programs in the federal tables still apply in every state-plan state; these are additions.
The ten-or-fewer rule
Two programs, the emergency action plan and the fire prevention plan, may be communicated orally instead of in writing when you have 10 or fewer employees. That is the whole list. The hazard communication program, lockout procedures, respirator program, confined space program, silica plan and bloodborne pathogens plan are written at any size, including a three-person shop. The 10-employee threshold people remember is the exemption from keeping the OSHA 300 log (10 or fewer all of last year), and it has nothing to do with written programs.
What a program that passes contains
An inspector, a GC's safety director and an insurance auditor all read a program the same way. They check that it matches the rule, then they check that it matches the site.
- The rule it answers, cited by paragraph, so the reviewer can check it against the standard and so you know what to update when the standard changes.
- Who is responsible, by role: the program administrator for respirators, the competent person for silica, the authorized employees for lockout. A program that names a "safety director" you don't have fails on page one.
- The procedures for your work, not for work in general. Your machines, your chemicals, your tasks, your sites. Lockout procedures per machine. Silica tasks per Table 1 entry. Confined spaces by name.
- Training: who, what, when, and how you verify understanding, with the records that prove it happened, in the language the crew understands.
- Records and review: what you keep, how long, and a date for the next review. Most programs are reviewed yearly and whenever the work changes.
- A date and a signature, and a revision history. An undated program is presumed stale.
One more test: hand it to the foreman. If he cannot find what his crew is supposed to do on page one, the crew will not do it.
Mistakes we find in the binder
- A purchased manual with 60 programs, 50 of them for hazards the company does not have, and an inspector who asks why the confined space program's quarterly drills never happened.
- A hazard communication program with no chemical inventory and SDSs nobody can find at 2 a.m.
- A lockout "program" with no machine-specific procedures and no annual inspection.
- A respirator program for required N95 use with no medical evaluations and no fit tests.
- No silica plan on a concrete crew, because "we use water on the saw." The water is the control; the plan is still required.
- A program that names a safety manager who left in 2023.
- English only, for a workforce that is half Spanish-speaking.
- No training records behind any of it. The program says workers are trained; nothing shows they were.
- Last reviewed: the date the company bought it.
Thirty-six written programs, built from the rule, that match your work
29Safety's programs are written to the paragraph they answer, filled in with your company, your sites, your machines and your competent persons, in English and Spanish. You turn on the ones your hazards require, the training that each program calls for shows up on the crew's cards, and the review date is tracked so nothing in the binder goes stale.
See exactly what you'd get
The JHA plus a toolbox talk record, an inspection and more, in one PDF: five documents for a jobsite crew, or three for a plant. No watermark.
Plans from $199 a month. No per-person fees. 14 days free.
Rather have us write it? Two written programs ($295)
Questions we get
Does OSHA require a written safety manual?
No federal standard requires a general safety manual. Specific standards require specific written programs when their hazard is present: hazard communication, lockout/tagout procedures, respiratory protection, permit-required confined spaces, silica, bloodborne pathogens, emergency action plans and others. California, Washington, Minnesota (listed industries) and Nevada (more than 10 employees) do require an all-hazards written program under state law.
Do I need an IIPP in Texas?
Not by law. The Injury and Illness Prevention Program is a California requirement (8 CCR §3203), and Texas is a federal OSHA state. Federal OSHA recommends a safety and health program and many general contractors and prequalification systems require one, so most Texas contractors end up writing the equivalent anyway. The specific federal written programs in this guide apply in Texas like everywhere else.
I have eight employees. What do I actually need in writing?
It depends on your hazards, not your size. With eight people you still need a written hazard communication program if you use hazardous chemicals, lockout procedures if anyone services equipment, a respirator program if respirators are required, a silica plan if you cut concrete or masonry, a confined space program if anyone enters one, a bloodborne pathogens plan if you designate first aiders, and a PPE hazard assessment certification. The emergency action plan and fire prevention plan may be oral at 10 or fewer employees.
Do written programs have to be in Spanish?
The programs themselves are not required to be translated, but the training they call for has to be in a language and vocabulary workers understand, which OSHA has enforced since 2010. In practice that means the procedures the crew follows, the lockout steps, the silica controls, the emergency plan, exist in Spanish for a Spanish-speaking crew, and the training records say which language was used.
How often do written programs have to be reviewed?
Some standards set it: the bloodborne pathogens exposure control plan at least annually (1910.1030(c)(1)(iv)), lockout procedures inspected at least annually (1910.147(c)(6)), the permit-required confined space program reviewed within a year of entries (1910.146(d)(14)), the respirator program as necessary to reflect workplace changes (1910.134(c)(1)). For the rest, yearly and whenever the work, the equipment, the chemicals or the rule changes.
Who has to sign a written program?
The standards do not generally require a signature, with exceptions like the PPE hazard assessment certification, which names the person certifying it, and the fall protection training certification. A signature from the owner or the person in charge, with a date, is what makes the program credible to an inspector, a GC and a court, and it is how you show management committed to it.
Not sure how this applies to your work? in the chat, or email safetyteam@29safety.com.