By Ellis Brasch
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.
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.
Determine the program's requirements.
A required program may have different requirements for employers in different industries.
Determine what you need to do to accomplish the program's requirements.
Some required programs have very specific requirements.
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.
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.
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.
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.
|¶||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||1910.95||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||J||1910.147||The control of hazardous energy (lockout/tagout)|
|2||J||437-002-0141||Additional Oregon sanitation requirements|
|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||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||RR||437-002-2302||Hazardous energy control procedures|
|¶||2||S||1910.304||Wiring design and protection|
|¶||2||Z||1910.1006||Methyl chloromethyl ether|
|¶||2||Z||1910.1029||Coke oven emissions|
|¶||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||437-002-1029||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||437-003-0062||Lead Respiratory Protection Program|
|3||D||437-003-3060||Methylenedianiline respiratory protection program|
|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||J||437-004-1275||The control of hazardous energy (lockout/tagout)|
|¶||4||N||437-004-1700||Forklifts and other powered industrial trucks|
|¶||4||W||170.13||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|
|¶||7||B||437-007-0100||Safety and health program|
|¶||7||B||437-007-0145||Annual program evaluation|
If you want to receive the Resource Newsletter, sign up for future issues here.
Reprinting, excerpting, or plagiarizing any part of this publication is fine with us. Please send us a copy of your publication or inform the Resource editor as a courtesy. If you have questions about the information in Resource, please call 503-378-3272.
For general information, technical answers, or information about Oregon OSHA services, please call 503-378-3272 or toll-free within Oregon, 800-922-2689.