Blueprint for Safety: Creating Effective Emergency and OSHA Compliance Plans
by William T. Paletski PE, CSP
Keystone (formerly East Coast Risk Management)
Lehigh Valley, PA
Does your organization plan for emergencies? What if a hazardous spill occurs? Do employees have procedures for lockout/tagout? Do you have any idea what you will do in case of exposure to blood?
Planning is a huge part of having a positive safety culture. In fact, without planning, you simply have no roadmap on where you are going. It is like having a goal and not thinking about how you plan to get there.
If you look towards workplace safety, OSHA has a variety of regulations that require the employer to have a written plan for many topics. A written Plan is a document of how an establishment is protecting or plans to protect employees from a safety or health hazard. It acts as a guide for compliance too.
Something that organizations seem to forget is that if a topic pertains to you, then OSHA can ask to see a written plan when it is required in one of the regulations. For example, this may be for bloodborne pathogens, emergency action plan, fire prevention plan, grain handling facility housekeeping plan, hazard communication plan, and many more. It is essential that organizations read the regulations and understand what they say. For example, OSHA’s HazCom regulation 1910.1200 states that “Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following…”
As mentioned above, a written Plan should be prepared for those activities you perform in the workplace. Think about how you interact with contractors and temps. Think about those assignments conducted once per year or every other year, such as cleaning rafters, the roof, or certain tanks or unground spaces. Do you have fleet drivers? Do you go into confined spaces?
Now one thing to remember is that a written record is not a written plan. A written record is a testimony that attests to some action or protocol completed. Some terms used are certification or authorization. The record pertains to items like audiometric tests for hearing, employee medial records, hot work permits, or training records. The written Plan is bigger in scope and should be your guiding document on how you intend to be compliant with OSHA and to minimize exposure of employees to unsafe acts and unsafe conditions.
There is no one type of format for the written plan. Organizations should read the OSHA regulations and develop an outline of what needs to be addressed for worker safety. Get input from your safety committee or 3rd party support experts on how to address training, and conditions required to minimize risk.
If you have not done so already, here is a brief (not comprehensive) list of topics that written plans may be required to have at your workplace:
- Bloodborne Pathogens
- Emergency Action Plan
- Fire Prevention Plan
- Hazard Communication
- Lab Standard-Chemical Hygiene Plan
- Process Safety Management
- Respiratory Protection
William T. Paletski PE, CSP
Senior Environmental, Health & Safety Consultant
Keystone (formerly East Coast Risk Management)
Lehigh Valley, PA
We are honored to have “Bill” lead our Workplace Safety Forum. With an EHS career that began in 1985, Bill brings decades of experience in manufacturing and construction safety. His impressive credentials include Professional Engineer (PE); Certified Safety Professional (CSP); Certified Workers’ Compensation Advisor (CWCA) and OSHA Outreach Instructor for General Industry & Construction. Bill’s expertise also extends to data analysis and thermography, making him a well-rounded authority in environmental health and safety.
To join the MRC Workplace Safety Forum, please contact Diane Lewis at (610) 554-5196 or diane.lewis@mrcpa.org ,