In this article
A workplace safety program gives your company a practical way to identify hazards, assign responsibilities and follow up on safety concerns. Supporting legal compliance also requires checking the standards that apply to your work and putting the required protections into practice.
Contractors often manage a second set of requests through customer accounts: written programs, training records and questionnaires. Those requests should reflect how your company works. An accepted document or account grade cannot confirm that every requirement is being met on the job.
What is safety regulation non-compliance?
Safety regulation non-compliance means failing to meet an applicable legal safety requirement. The issue could involve training, workplace conditions, required records or another obligation that applies to the employer’s operations.
OSHA’s employer guidance explains that employers are responsible for providing a safe workplace. Coverage can be through federal OSHA or an OSHA-approved state program. The rules relevant to a particular company depend on its work and jurisdiction; an online checklist cannot establish every obligation.
Keep these questions separate when reviewing a customer request:
| Question | What needs review |
|---|---|
| Are we meeting applicable safety requirements? | The employer’s practices, hazards and legal obligations |
| Does the written program describe our work? | The program’s scope, procedures and assigned responsibilities |
| Have we met this customer’s account requirements? | The requested documents, responses and customer review |
A rejected upload can be a formatting or documentation problem. A file accepted by a platform can still need changes when the work changes. Review both the document request and the underlying practice.
Assign responsibilities people can carry out
OSHA’s management leadership recommendations call for clear responsibilities, resources and management involvement. A small contractor may have one person filling several roles, but the team still needs to know who can make decisions and who follows up.
Write down who will maintain the program, arrange training, review reported concerns and authorize the resources needed to address them. Supervisors need to know how to raise a problem that they cannot resolve themselves.
For each recurring administrative task, assign a person and a backup. Someone should know where the current program is kept and who updates the customer account after an approved change. The person uploading a certificate should not be left to decide whether it establishes a worker’s qualification.
Include workers in program reviews
Workers can explain where the written procedure and the actual assignment differ. OSHA’s worker participation guidance recommends involving employees in program development, hazard reporting and evaluation, with protection against retaliation.
Make reporting straightforward. Tell workers whom to contact, how to report a concern and how they will hear about the response. Provide time to participate and an opportunity to raise questions.
When a worker points out a problem, record the concern and give it an owner. A report that disappears into an inbox is difficult to follow up. A short update explaining what is happening helps the person who raised it understand the next step.
Review hazards as the work changes
OSHA’s hazard identification recommendations describe an ongoing process that includes inspections, worker input and reviewing incidents or near misses. Routine work, unusual tasks and changes in equipment or materials all need consideration.
Have the person responsible for safety review the planned work and identify where additional expertise is needed. A program written for one service may not address a newly added activity or a different customer’s facility.
Keep a record of what was reviewed, which issues need attention and who is responsible for deciding the appropriate controls. The employer’s safety team or qualified adviser should determine the protections needed for the actual conditions.
Use the findings to review the written program and the training needed for the assigned employees. Updating the company name on a template does not complete that review.
Keep useful records and track corrective actions
Organize the evidence your company actually uses: current written programs, applicable training records, inspections and follow-up actions. Retention periods and specific documentation requirements vary, so check the relevant rules and customer requirements before setting a records policy.
A working action list can include the concern, responsible person, target date, current status and evidence of completion. It should show unresolved questions clearly. Keep completion evidence separate from a promise to make a change.
For account work, track which approved document was uploaded, where it was submitted and whether the customer requested another step. Protect employee information and limit access to people who need it.
These records can help your team answer a customer’s question without rebuilding the history from email. They also make it easier to see when a written procedure needs review.
Coordinate with the host employer before work starts
At a customer’s location, your crew’s work can affect other employers and their employees. OSHA’s guidance for host employers and contractors recommends exchanging hazard information and coordinating safety activities before work begins.
Discuss the scope of work, site requirements, emergency arrangements and how changes or concerns will be communicated. Identify contacts on both sides who have the authority to resolve questions.
Ask how the host will communicate hazards associated with the facility and how your company should communicate hazards introduced by its work. Review differences between company and site procedures before sending the crew to perform the assignment.
Document the agreed responsibilities and outstanding actions. Revisit the arrangements if the work, schedule or staffing changes. The host’s orientation and the contractor’s own safety program need to address their respective responsibilities.
This coordination supports injury prevention, but it does not transfer every safety duty to one party. Legal responsibilities depend on the circumstances and applicable requirements. Get qualified advice when the responsibilities are unclear.
Evaluate whether the program is working
OSHA’s program evaluation recommendations call for an initial review and periodic evaluations, at least annually. Changes or incidents can also prompt another review.
Look beyond whether the manual is complete. Ask whether workers can report concerns, required training is being completed and corrective actions are being followed through. Include workers in deciding what needs improvement.
Review recurring issues together. A repeated missing record may point to an unclear assignment, while repeated reports about a task may need a review of the work itself.
Where CMS can help
CMS helps contractors with written safety programs, questionnaires and account document requests. We can help work through what the account is asking for and organize the documentation. The employer remains responsible for implementing its safety program and meeting applicable requirements.
Send us the request or call 888-490-0641 if you need help with the paperwork.
Frequently asked questions
Does a written safety manual prove OSHA compliance?
A manual documents policies and procedures. Compliance also depends on applicable requirements and what happens in practice, including training and the protections provided for the work.
Who should be involved in developing a contractor safety program?
Management, supervisors and workers should contribute. Assign clear responsibilities and involve a qualified safety adviser where the hazards or requirements call for specialized expertise.
Who handles safety when contractors work at a customer’s site?
The host employer and contractor need to exchange relevant information and coordinate their activities. Their specific responsibilities depend on the work and applicable requirements; a customer account approval does not settle those responsibilities.