The Seven Core Elements of a Safety and Health Program
Beyond individual standards, what does OSHA say a workplace safety and health program should contain? OSHA answers that in its Recommended Practices for Safety and Health Programs, which its Safety Management page describes as "a step-by-step approach to implementing a safety and health program, built around seven core elements that make up a successful program." For an employer, it is a ready-made structure for managing safety as a whole instead of one rule at a time.
These practices are guidance, not a regulation
The Recommended Practices are OSHA guidance, not a standard. The disclaimer at the front of the publication (OSHA 3885) says:
"These practices for safety and health programs are recommendations only. Employers are not required to have a safety and health program that complies with them and will not be cited for failing to have a safety and health program that complies with this document."
That is why this article says "should" and "recommends" throughout. Nothing here changes what any OSHA standard requires.
On scope, the Safety Management page says the practices "are designed to be used in a wide variety of small and medium-sized business settings." The disclaimer adds that construction has its own separate recommended practices.
What are the seven core elements?
Here they are, named and ordered as OSHA lists them. Each has its own osha.gov page with action items.
- Management Leadership. OSHA's page says management "provides the leadership, vision, and resources needed to implement an effective safety and health program." Action items include "Communicate your commitment to a safety and health program" and "Allocate resources." One suggested step is a written policy signed by top management.
- Worker Participation. The page says any program "needs the meaningful participation of workers and their representatives." Action items include "Encourage workers to report safety and health concerns" and "Remove barriers to participation." In an effective program, the page says, workers do not experience retaliation when they raise safety and health concerns.
- Hazard Identification and Assessment. The page calls the failure to identify or recognize hazards one of the "root causes" of workplace injuries, illnesses, and incidents. Action items include "Inspect the workplace for safety hazards" and "Conduct incident investigations," which the page says should cover close calls and near misses.
- Hazard Prevention and Control. The page says employers should evaluate control options using a "hierarchy of controls." Action items include "Select controls" and "Follow up to confirm that controls are effective." The hierarchy puts engineering solutions (including elimination or substitution) first, followed by safe work practices, administrative controls, and finally personal protective equipment.
- Education and Training. The page says this gives employers, managers, supervisors, and workers the knowledge and skills to work safely and to identify, report, and control hazards. Action items include "Provide program awareness training" and "Train workers on hazard identification and controls." OSHA recommends training in the language(s) and at a literacy level all workers can understand.
- Program Evaluation and Improvement. The page says employers "should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals." Action items include "Monitor performance and progress" and correcting program shortcomings when you find them.
- Communication and Coordination for Host Employers, Contractors, and Staffing Agencies. This covers worksites where staffing agency workers, contractors, or subcontractors work at a host employer's site. The two action items are "Establish effective communication" and "Establish effective coordination." The page says information should be shared before on-site work starts and again, as needed, if conditions change.
How do the elements fit together?
The publication (OSHA 3885) says: "The seven core elements are interrelated and are best viewed as part of an integrated system. Actions taken under one core element can (and likely will) affect actions needed under one or more other elements."
It gives two examples. Workers need training in reporting procedures and hazard identification to be effective participants, so Education and Training supports Worker Participation. And goals set under Management Leadership work better when you routinely check progress under Program Evaluation and Improvement.
OSHA's "How Do I Get Started?" page adds that you "do not need to have every detail planned before getting started" and that you "do not need to proceed in a strictly sequential manner."
Where should you start?
If that looks like a lot, OSHA publishes a short list called "10 Ways to Get Your Program Started," simple steps that give you a base for the more structured actions. In OSHA's words and order:
- Establish safety and health as a core value.
- Lead by example.
- Implement a reporting system.
- Provide training.
- Conduct inspections.
- Collect hazard control ideas.
- Implement hazard controls.
- Address emergencies.
- Seek input on workplace changes.
- Make improvements.
For the reporting system, OSHA's list says workers should be able to report "without fear of retaliation," with an anonymous option.
If you need help, the "How Do I Get Started?" page suggests OSHA's On-Site Consultation Program, which it says provides free assistance to small businesses.
Related guides
Source
OSHA's Recommended Practices for Safety and Health Programs are voluntary guidance, not a regulation. In OSHA's words, they "are recommendations only." Pages used: Safety Management; the element pages for Management Leadership, Worker Participation, Hazard Identification and Assessment, Hazard Prevention and Control, Education and Training, Program Evaluation and Improvement, and Communication and Coordination for Host Employers, Contractors, and Staffing Agencies; How Do I Get Started?; 10 Ways to Get Your Program Started; and the publication itself, OSHA 3885. The regulation itself always controls. States that run their own OSHA-approved State Plans may have additional or stricter rules.
Published by TSG Safety. This page explains the rules in plain English and is not legal advice. Browse all articles.