Oregon OSHA's

Health and Safety Resource

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April 2017

Develop and implement:
A guide to Oregon OSHA's program-related rules

Among all of Oregon OSHA's workplace safety and health rules, there are 108 that require employers to establish a program. Few people – if anyone – can name all of those rules or all of the programs that the rules require (the list ). However, it's quite likely that many employers have encountered at least one of those rules, which often starts with the words: "the employer shall develop and implement a program ..." Those rules are also a source of frustration for some employers – at least measured by the number of violations of Oregon OSHA's program-related requirements.

So what is a program, and what does it mean to develop and implement one?

A program is simply a means for achieving a goal. "Develop and implement" is a bureaucratic way of saying that, if a particular program is required for your workplace, then you must create it and make sure that your employees follow it. You also need to maintain it to keep it current. Of course, the devil is often in the details; some programs are more difficult to development, implement, and maintain than others.


How to development, implement, and maintain a program in four easy steps

1

Review the rule that requires the program.
The more you know about the rule, the easier it is to determine what requirements affect your workplace.

2

Determine the program's requirements.
A required program may have different requirements for employers in different industries.

3

Determine what you need to do to accomplish the program's requirements.
Some required programs have very specific requirements.

4

Review the program periodically.
Programs do not live forever. Employees come and go and procedures and policies can change. All of those changes can affect a program's status. A program left unattended is not likely to be effective.

Develop and implement – an example: Hazard communication

Are your employees exposed to hazardous chemicals when they are working? If the answer is "yes," then Oregon OSHA's hazard communication standard (1910.1200) requires you to "develop, implement, and maintain" a hazard communication program.

This requirement has also been Oregon OSHA's most-violated rule every year since 2008. Employers make mistakes, and hence get cited, for one of three reasons: they don't develop the program, they don't implement the program, or they don't maintain the program.

An effective hazard communication program ensures that workers who may be exposed to hazardous chemicals know about the chemical's hazards and understand how to protect themselves.

How to develop a hazard communication program

  • Prepare a list of workplace chemicals that your employees could be exposed to.
  • Describe how you will make sure that hazardous chemical containers at your workplace have labels that identify the chemicals and provide required information about their hazards.
  • Determine where you will keep safety data sheets (they must be readily accessible to all employees).
  • Describe how you will train your employees about the chemical's hazards they are exposed to.
  • Describe how you will inform employees about the hazardous chemicals and substances they may be exposed to.
  • Describe how you will inform contractors and other employers about the hazardous chemicals and substances they may be exposed to.

Implementing a hazard communication program

  • Tell employees about the program and the places in their work areas where hazardous chemicals are present.
  • Tell employees where they can find the list of hazardous chemicals and the safety data sheets for those chemicals.
  • Train employees about the program when they are first hired and whenever a new chemical hazard is introduced into their work area.

Maintaining a hazard communication program:

  • Update your list of hazardous chemicals when you receive new chemicals. Make sure there is a safety data sheet for each chemical on the list.
  • Maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals.
  • Train employees about the program when they are first hired and whenever a new chemical hazard is introduced into their work area.

Put it in writing

For some required programs, such as hazard communication, the entire program must be "in writing," which means that you must document how you will accomplish the program's requirements and make that information available to your employees. Other examples include respiratory protection [1910.134(c)]

and confined spaces [437-002-0146(5)]. You can find templates for these programs on Oregon OSHA "Forms" webpage that you can modify or use to write your own program.

For other required programs, only parts of the program must be in writing.

Oregon OSHA rules that have requirements for programs

 
This list includes all Oregon OSHA rules that have requirements for programs. *A paragraph mark () in the first column indicates that at least one of the program-related requirements must be in writing.

Print version of this table

* Division Subdivision Rule Rule description
1   437-001-1035 Loss prevention services
1   437-001-1040 Required loss prevention services
1   437-001-1055 Self-insured and group self-insured employer loss prevention programs
  1   437-001-1060 Self-insured and group self-insured employer loss prevention effort
2 E 437-002-0042 Emergency action plan
2 E 437-002-0043 Fire prevention plan
2 F 1910.66 Powered platforms for building maintenance
  2 G 1910.94 Ventilation
2 G 1910.95 Occupational noise exposure
2 H 1910.109 Explosives and blasting agents
2 H 1910.119 Process safety management of highly hazardous chemicals
2 H 1910.12 Hazardous waste operations and emergency response
  2 H 437-002-0118 Oregon rules for reinforced plastics manufacturing
2 I 1910.134 Respiratory protection
2 J 1910.147 The control of hazardous energy (lockout/tagout)
  2 J 437-002-0141 Additional Oregon sanitation requirements
2 J 437-002-0146 Confined spaces
  2 K 437-002-0161 Medical services and first aid
2 L 437-002-0182 Oregon rules for firefighters
  2 L 437-002-0187 Portable fire extinguishers
  2 N 1910.177 Servicing multi-piece and single-piece rim wheels
2 N 1910.178 Powered industrial trucks
2 N 1910.179 Overhead and gantry cranes
  2 N 1910.181 Derricks
2 O 1910.217 Mechanical power presses
2 O 437-002-0256 Stationary compactors, self-contained compactors and balers
2 R 1910.272 Grain handling facilities
  2 R 437-002-0310 Work procedures
2 RR 437-002-2302 Hazardous energy control procedures
2 S 1910.304 Wiring design and protection
2 Z 1910.1001 Asbestos
2 Z 1910.1003 13 carcinogens
2 Z 1910.1004 Alpha-napthlamine
2 Z 1910.1006 Methyl chloromethyl ether
2 Z 1910.1007 3,3'-dichlorobenzidine
2 Z 1910.1008 Bis-chloromethyl ether
2 Z 1910.1009 Beta-naphthylamine
2 Z 1910.101 Benzidine
2 Z 1910.1011 4-aminodiphenyl
2 Z 1910.1012 Ethyleneimine
2 Z 1910.1013 Beta-Propiolactone
2 Z 1910.1014 2-acetylaminofluorene
2 Z 1910.1015 4-dimethylaminoazobenzene
2 Z 1910.1016 N-nitrosodimethylamine
2 Z 1910.1017 Vinyl chloride
2 Z 1910.1018 Inorganic arsenic
2 Z 1910.1025 Lead
2 Z 1910.1027 Cadmium
2 Z 1910.1028 Benzene
2 Z 1910.1029 Coke oven emissions
2 Z 1910.1043 Cotton dust
2 Z 1910.1044 1,2-dibromo-3-chloropropane
2 Z 1910.1045 Acrylonitrile
2 Z 1910.1047 Ethylene oxide
2 Z 1910.1048 Formaldehyde
2 Z 1910.105 Methylenedianiline
2 Z 1910.1051 1,3 butadine
2 Z 1910.1052 Methylene chloride
2 Z 1910.12 Hazard communication
2 Z 437-002-0364 MOCA (4,4'-Methylene BIS (2-Chloro-Aniline)
  2 Z 437-002-0373 Oregon rules for Thiram
2 Z 437-002-1025 Lead respiratory protection program
2 Z 437-002-1027 Cadmium
2 Z 437-002-1028 Benzene
2 Z 437-002-1029 Coke oven emissions respiratory protection program
  2 Z 437-002-1044 1,2-Dibromo-3-Chloropropane respiratory protection program
  2 Z 437-002-1045 Acrylonitrile respiratory protection program
  2 Z 437-002-1047 Ethlylene Oxide respiratory protection program
  2 Z 437-002-1050 Methylenedianiline respiratory protection program
  2 Z 437-002-1051 1,3-Butadiene respiratory protection program
  2 Z 437-002-1052 Methylene Chloride respiratory protection program
  3 C 1926.2 General safety and health provisions
  3 C 1926.24 Fire protection and prevention
3 D 1926.59 Hazard communication
3 D 1926.6 Methylenedianiline (MDA)
3 D 1926.62 Lead
  3 D 437-003-0062 Lead Respiratory Protection Program
  3 C 437-003-0920 Project plans
  3 D 437-003-3060 Methylenedianiline respiratory protection program
  3 F 1926.15 Fire protection
3 K 437-003-0404 Branch circuits
3 M 437-003-0503 Training requirements
  3 R 1926.761 Training
  3 X 1926.106 Training requirements
3 Z 1926.1101 Asbestos
3 Z 1926.1126 Chromium (VI)
3 Z 1926.1127 Cadmium
3 Z 1926.1152 Methylene Chloride
  3 Z 437-003-1101 Asbestos respiratory protection program
3 CC 1926.1427 Operator qualification and certification
3 CC 437-003-0081 Crane Operator Safety Training Requirements
  4 C 437-004-0251 Safety committees and safety meetings
  4 G 437-004-0630 Noise exposure
4 I 437-004-1041 Respiratory protection
4 J 437-004-1275 The control of hazardous energy (lockout/tagout)
4 N 437-004-1700 Forklifts and other powered industrial trucks
4 W 170.104 Exemptions, workers
4 W 170.13 Pesticide safety training for workers
4 W 170.204 Exemptions, pesticide handlers
4 W 170.23 Pesticide safety training for handlers
4 W 170.24 Personal protective equipment
  4 Z 437-004-9720 Thiram
4 Z 437-004-9800 Hazard communication
7 B 437-007-0100 Safety and health program
  7 B 437-007-0110 Supervisory responsibilities
7 B 437-007-0145 Annual program evaluation
7 B 437-007-0105 Management commitment
7 N 437-007-1305 General requirements

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