5 OSHA Compliance Considerations for All General Industry Employers

This is the third and last article in a three-article series looking at OSHA compliance requirements for general industry employers.

In the first article, we looked at six compliance requirements that apply for most general industry employers.

In the second article, we looked at an additional nine compliance requirements that may also apply to those employers.

And in this third article, we're going to kind of "mop up" and provide a series of five additional compliance considerations that all general industry employers should keep in mind.

The information in these articles is coming from OSHA's handy online Compliance Assistance "Quick Start" Guide for General Industry. If you're not familiar with it, we definitely encourage you to check it out.

And with that, let's continue and wrap up our series.

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As we work our way through the final sections of the OSHA Compliance Assistance Quick Start Guide, we'll look at the following issues:

• Surveying the workplace for hazards
• Safety and health management/jobsite safety and health programs
• Safety and/or EHS training for employees
• Recordkeeping, reporting, and posting obligations
• Additional resources for compliance assistance

We'll give a quick overview of what OSHA discusses in each section, and we'll list out and link to helpful resources that OSHA provides for each section as well.

In addition, we'll give you some tips for training your workers on topics related to each of the sections. In doing that, we'll provide some sample videos from our online environmental, health, and safety training course library.

As you read, remember we're focusing on the general industry suggestions.
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Survey Workplace for Additional Hazards

OSHA recommends employers survey the workplace for additional hazards beyond what we've discussed in earlier articles.

To help with this, they offer the following resources:

• Self-Inspection Checklists in their Small Business Handbook
• OSHA's Hazard Identification Training Tool (admission--I've never been able to get this to work--anyone else?)
• OSHA's Safety and Health Information Bulletins

On the training front, a course on the Job Hazard Analysis may prove a helpful contribution here.

Other training related to workplace hazards and hazard identification may also help.

For example, some training on general safety and health issues may help workers assist you in identifying hazards in the work area.

Likewise, you could provide training on Equipment Hazards in general or training on hazards associated with specific equipment as well.

It may also help to provide some training on hazards and safety issues associated with maintenance, as there are special requirements here.

In addition, providing training on Machine Operator Basic Care may help your employees identify any hazards and flag them for correction before an incident occurs.

In wrapping up this section, OSHA also provides some resources for the following types of hazards:

• Distracted driving, in the form of their Distracted Driving PDF
• Heat exposure and illness, in the form of their Heat Illness Prevention webpage and their Occupational Health Exposure web page.

In keeping with OSHA's focus on those topics, training you could consider might include topics like:

Training on distracted and alert driving.

And training on Heat Stress Symptoms and Prevention.

For more on this topic, check out our article on performing a job hazard analysis (JHA) and download the free JHA guide/template there.

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Develop a Comprehensive Jobsite Safety and Health Program

In the next step, the OSHA Quick Start Guide notes that "While OSHA does not require employers to develop comprehensive safety and health programs, development and implementation of these programs is an effective way to comply with OSHA standards and prevent workplace injuries and illnesses. The information you've obtained from the steps above is a good start for developing a comprehensive safety and health program."

OSHA offers the following resources to help with this:

• OSHA's Voluntary Safety and Health Program Management Guidelines (1989)
• Effective Workplace Safety and Health Management Systems Fact Sheet
• OSHA Sample Safety and Health Program for Small Businesses
• OSHA Safety and Health Management Systems eTools
• OSHA On-Site Consultation Program
• New Safety and Health Management Program Guidelines (in development)

In addition, in case you're not sure why you'd want to do this, OSHA also offers these resources to show you how they can contribute value to your organization:

• Safety and Health Add Value PDF
• Safety Pays Program Online Tool
• OSHA Safety and Health Topic Page: Making the Business Case for Safety and Health

And finally, you may find the following articles from the Convergence Training blog about safety and health management programs interesting or helpful:

• Safety and Health Management in 5 Steps (based on ANSI Z10 and OSHA's new guidance)
• Safety and Health Management Best Practices (an overview of OSHA's new guidance)
• The first article in our multi-article series on safety and health management (introduces several different standards and guidelines than look in detail at ANSI Z10)
• What Is a Safety and Health Management Program? (blog post based on current, soon-to-be replaced OSHA safety and health management materials, but there's still a lot of good stuff in it)

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Safety and Health Training for Your Employees: Compliance Requirements and Resources

The next step deals with providing proper safety and health training to employees.

OSHA provides a number of resources to help with this. One of the most important is this list of Training Requirements in OSHA Standards. This training guide can help you identify any training requirements that working through the OSHA Compliance Quick Guide as you've been doing has left uncovered.

In addition, OSHA provides the following resources:

• OSHA's Training Resources page
• OSHA"s Training and Reference Materials page
• OSHA's Outreach Training Program
• OSHA 10-Hour General Industry Outreach Trainer Presentations (free download)
• Training Materials Developed by OSHA's Susan Harwood Training Grant Program Grantees
• Courses Available at OSHA Training Institute in Arlington Heights, Illinois
• Courses Offered at OSHA Training Institute at OTI Education Centers around the U.S.

For additional safety training needs, you can want to check the EHS Training Library from Convergence Training. We've included a short video that shows some highlights from those and other workforce training courses, below.

For administering your safety training, including automating assignments, tracking completion, storing training records, reporting, and more, you may find that a learning management system (LMS) is very helpful. The short video below explains this more.

You can sample our online health and safety courses and even get them in pay-per-view versions online here; you might also be interested in our LMS for safety training management and administration and our mobile apps for mobile safety training.

In addition, here's a small sample of the articles at the Convergence Training blog that can help you with your training program:

• Free Guide to Effective EHS Training (downloadable PDF)
• Effective EHS Training On-Demand, Recorded Webinar (free)
• Tips for Writing Training Materials
• How to Create Your Own EHS eLearning Course
• Safety Manager Tips for Making Safety Training More Fun
• Online Safety Training Buyer's Guide Checklist

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OSHA Injury and Illness Recordkeeping and Reporting, Plus additional Posting Requirements

Another aspect of OSHA compliance involves recordkeeping, reporting, and posting.

Let's look at some of the resources OSHA provides for each.

Recordkeeping of Workplace Injuries and Illnesses

• Recording and Reporting Occupational Injuries and Illnesses Standard (29 CFR 1904)
• OSHA Recordkeeping Forms (Download them Here)
• OSHA Recordkeeping Webpage

You might be interested in our OSHA Recordkeeping online course, shown below:

Reporting Fatalities and Severe Injuries

• Regulatory requirement: Reporting Fatalities, Hospitalizations, Amputations, and Losses of an Eye as a Result of Work-Related Incidents to OSHA (29 CFR 1904.39)
• OSHA's Recordkeeping Rule

Electronic Submission of Injury and Illness Data

Current status of OSHA's soon-to-be-implemented Online Reporting and Recordkeeping System (as of June 2017)

OSHA Poster

Employers must post the OSHA Poster or a state-plan equivalent). Get it here.

Access to Employee Exposure and Medical Records

Access to Medical and Exposure Records PDF

Get Help with OSHA Recordkeeping & Reporting

Many workplaces now use some form of online system, like the Convergence Training Incident Management Software highlighted below, to help create and store OSHA injury/illlness reports, handle the new OSHA online submission requirements, and more.

Find Additional Compliance Assistance Information

In the final step of their compliance assistance guide, OSHA offers a bunch of other resources for "all the other stuff."

Here's what they've got for you.

For Small Businesses

• OSHA Small Business Page
• OSHA On-Site Consulting

For Spanish-Speaking Employees

• OSHA's Spanish-Language Resources
• OSHA's Spanish-Language Website

Temporary Workers

OSHA's Protecting Temporary Workers Page

Heat Illness for Outdoor Workers

OSHA's Heat Illness Prevention Page

Ergonomic and Musculoskeletal Disorder (MSD) Concerns

OSHA's Ergonomics Page

Industry-Specific Compliance Aids

OSHA's Industry-Specific Resources

OSHA's Voluntary and Cooperative Programs

Cooperative Programs, including Alliance, OSPP, VPP, OSHA Challenge Program, and SHARP

Concerns about Pandemic Influenza

OSHA's Pandemic Influenza Safety and Health Topics page

Keeping Updated on Compliance Assistance Resources

• OSHA's Help for Employers Page
• OSHA's Quick Takes biweekly e-newsletter

Additional Questions

• OSHA Website, including site index and search
• OSHA's 800-Number (1-800-321-6742)
• OSHA FAQ
• Contact OSHA by email
• Contact Your Local OSHA Office or State Plan Office
• On-Site Consultation

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Conclusion: OSHA General Industry Compliance Ain't Easy, But The Guide Sure Helps

While OSHA general industry compliance isn't something you can do with no planning and with absolute ease, it's also far from impossible, and OSHA provides many resources to help you out.

Their compliance quick-start guide is a great resource for general industry employers. In particular, perhaps, for smaller companies that don't have large safety and health staffs or don't have a lot of experience putting together a compliance program and sticking with it.

In addition to the guide, remember that our three-article series presented the information this way:

1. Six compliance requirements that apply at most all companies
2. Nine additional compliance requirements that may apply at your company
3. Five final compliance considerations to keep in mind (this article)