OSHA-Required Paperwork

J.J.
KellerWebcast
OSHARequiredPaperwork:
SafetyPlansandOtherRecordsMandatedbytheAgency
July12th,2016
Safety plans and other records

mandated by the agency
July 12th, 2016
Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.
Take a Proactive Approach to Safety and Compliance
J. J. Keller OSHA Compliance program

On-site guidance and resources to improve workplace compliance
Protect your company and ensure compliance
Identify your greatest risks and have an action plan to improve
them
Leverage industry knowledge and experience that you may
lack internally
Have access to a team of experts at a moment's notice
Save significant time and internal resources
NEW! Industrial Hygiene Services now available!
Learn more, call us at
888.473.4638
Or visit JJKeller.com
2016J.J.Keller&Associates,Inc.
J.J.KellerWebcast
July12th,2016
Editor
Workplace Safety
22 years at J. J. Keller
Subject-Matter Expert
Areas:
Bloodborne Pathogens
HAZWOPER
SPCC
Signs & Labels
Written Plans
Editor For
Published in numerous
trade publications
Editor
Workplace Safety
8 years at J. J. Keller
Subject-Matter Expert Areas:

Solid and Hazardous Waste
Greenhouse Gases
Heat and Cold Stress
OSHA Injury and Illness
Recordkeeping/Reporting
Editor For
Contributing writer to leading trade

magazines
Member of Federation of
Environmental Technologists (FET)
How would you rank your level of OSHA

expertise?
A.
B.
C.
OSHA Expert!
Pretty good understanding but have a few
questions
Just getting started in OSHA
J.J.KellerWebcast
July12th,2016
OSHA-required paperwork examples:
Written plans and permits
Policies or statements
Postings
Sampling and exposure monitoring data
Hazard assessments and analyses
Inventories and data sheets
Medical evaluations/records and fit tests
Operating procedures
Maintenance and repair records
Inspection/Test records
Training records
Injury and illness logs
Reports to OSHA
Common
paperwork under 29 CFR 1910,

1903, and 1904
See
CFRs for all your paperwork

requirements
Well
focus on federal OSHA

and general industry, not
state-plan states
or other industries
Big
picture: Paperwork
location, format, access,
retention, and destruction
Check
OSHA regulations
Readily
accessible or available
Depends
on record
Confidential,
private info?
sensitive, or
Secure location
Separate from personnel files
Laws: ADA, FMLA, GINA, etc.
How do you secure copier,

printer, scanner, fax, email?
Labtop and mobile devices?

J.J.KellerWebcast
July12th,2016
Who
will have access?

responsible for
gatekeeping confidential,
secure, private info?
Check paperwork requirement
Check 1910.1020 access
provisions for exposure and
medical records
Whos
Retention
Check paperwork requirement
If no duration specified, think:
Duration of employment
Number of years, i.e., 30
Replacement in kind
Advice of an attorney
Destruction
Destroy when allowed to
Method of destruction
Secure records
Destruction record
Employee exposure records preserved for at least

30 years:
Monitoring/Sampling toxic substance/physical agent

Biological monitoring results: urine/blood tests
Safety data sheets
Chemical inventory
Employee medical records preserved for the duration

of employment plus 30 years:
Records made by healthcare professional concerning health

Include medical/employment questionnaires/histories,
medical exam or lab test results, medical opinions, first aid
records, treatment desc. prescriptions, medical complaints
J.J.KellerWebcast
July12th,2016
Six minimum plan elements:
1. Procedures for reporting fire or
emergency
2. Emergency evacuation procedures
3. Procedures for workers who
operate critical plant operations
before evacuating
4. Procedures to account for workers after evacuation
5. Procedures for workers performing rescue/medical
duties
6. Name or job title of workers to contact for more info
about plan or an explanation of duties
Five minimum plan elements:

1. List of major fire hazards, procedures for
hazmat handling/storage, ignition sources
and their control, and type of fire
protection equipment for major hazards
2. Procedures to control accumulations of
flammable/combustible waste materials
3. Procedures for maintenance of heat-producing
equipment
4. Name or job title of workers who maintain
equipment
5. Name or job title of workers who control fuel
source hazards
When
is an EAP/FPP required?
9 standards require EAP under 1910.38

4 standards require FPP under 1910.39
(Click JJKeller.com, Workplace Safety, View All News and Alerts,

January 2015)
When
is an EAP/FPP required
to be in writing?
In writing if employer has over

10 workers at location
If 10 or fewer, then may
communicate plan orally
J.J.KellerWebcast
July12th,2016
Noise
exposure measurements
Audiometric
tests
Name/Job classification
Date of audiogram
Examiner's name
Date of last calibration of
audiometer
Worker's most recent noise exposure assessment
Measurements of background sound pressure levels in
audiometric test rooms
Process safety information

Process hazard analysis (PHA)
Operating procedures
Training records
Contractor safety performance info,
injury/illness log
Procedures to maintain process equipment
integrity
Process inspection/testing documentation
Hot work permit for hot work on/near processes
Management of change procedures
Incident investigation reports
Emergency action plan
HAZWOPER-related plans, if applicable
Compliance audit reports
Initial/Refresher
training
certification records
Equivalent training records
Medical surveillance records
Written plans:
Safety and health program

Emergency plan for hazardous
substance releases:
Emergency response plan

Emergency action plan
J.J.KellerWebcast
July12th,2016
PPE
hazard assessment (HA):
Record workplace that is evaluated, person certifying

that HA was performed, date(s) of HA, that document
is a certification of HA
Respiratory
Electrical
protection records:
Respiratory protection program

Medical evaluations
Fit tests
Certification of emergency-use respirator
Certificate of analysis of cylinders
protective equipment record:
Certify equip. tested, passed test, date

Permit-required
confined
space program
Entry permits
Alternate procedures:
Documented data supporting

use of alternate procedures
Certification for alternate
procedures
Certification
Training
for reclassification of permit space

certification
Energy
control
procedure(s)
Periodic
inspection
certification
Training
certification
J.J.KellerWebcast
July12th,2016
Portable
fire extinguishers
Annual maintenance check

Certification record of hydrostatic
testing
Automatic
Fixed
sprinkler systems
Acceptance test dates

Hydraulically designed system
records
extinguishing systems
Inspection/Maintenance dates
Record of last semi-annual check
Operator
training certification
Operator name
Training date
Evaluation date
Trainer/Evaluator identity
Overhead & gantry cranes
Crawler, locomotive, & truck

cranes
Certification of hook and hoist

chain inspection
Rated load test reports
Certification of rope inspection
Inspection records
Rated load test reports
Derricks
J.J.KellerWebcast
July12th,2016
Alloy
steel chain slings
Inspection record
Certificate of proof test
Wire
rope slings
Metal
mesh slings
Repair/Maintenance records
Synthetic
web slings

Mechanical power presses
Pull-out device inspection/maint. records

Power press inspection certification records
Presence sensing device initiation (PSDI)
brake monitor certification
PSDI alternative safeguard certification
Records of safety system installation certif.
Operator training certification
Reports of press operator injuries
(see www.osha.gov/pls/powerpress/mechanical.html)
Forging machines
Records of periodic/regular maintenance safety checks

Records of inspection of guards, point of operation
protection devices
General
Written permit for welding/cutting
Oxygen-fuel
Resistance
gas welding and cutting
Personnel rules/instructions
Report to supplier indicating
trouble with cylinder valves
Acetylene generator operating
instructions
welding
Periodic inspection certification record
J.J.KellerWebcast
July12th,2016
Assured
equipment grounding
conductor (AEGC) program
Records
of tests performed
under AEGC program
Documentation
of all areas
designated as hazardous
(classified) locations
Procedures
for work on/near

exposed de-energized parts
Exposure control plan
Written schedule for cleaning

surfaces and method of
decontamination
Hepatitis B vaccination declination
Medical records
Sharps injury log
Training records
Copy of 1910.1030
Hazard communication program,

including chemical inventory
Safety data sheets
Trade secrets:
Disclosure when needed for

emergency/first aid treatment
May request written statement of
need/confidentiality
Disclosure upon written request when
needed for non-emergency medical
services
Written denial for disclosure
10
J.J.KellerWebcast
July12th,2016
Exposure
monitoring records
notification of
monitoring results (in writing
or posted)
Chemical hygiene plan
Safety data sheets and
reference materials
Respiratory protection program
Info provided to physician post-exposure
Medical records including physicians written
opinion
Employee
Written programs
Exposure monitoring records
Respiratory protection program, fit testing
records
Medical and medical surveillance records
Training records and contents
Safety data sheets
Notation of periodic cleaning/maintenance
of dust collection/ventilation equipment
Written engineering/work practice control
procedures equivalent to regulation
Job rotation schedule
Copy of standard and its appendices
Inform clothing launderers in writing of hazards
Objective data relied upon to comply with regulation
Transfer records to successor employer
Written safety plans:
29 CFR:
Acrylonitrile compliance program, plus emergency situations plan
1910.1045
Asbestos compliance program
1910.1001
Benzene compliance program
1910.1028
1,3-butadiene compliance plan, plus exposure goal program, emergency situations plan
1910.1051
Cadmium compliance program, plus emergency situations plan
1910.1027
Coke oven emissions compliance program, plus inspection and cleaning, charging, emissions
control, and maintenance and repair procedures
1910.1029
Cotton dust compliance program, plus dust minimization work practices program
1910.1043
1,2-dibromo-3-chloropropane compliance program, plus emergency situations plan
1910.1044
Ethylene oxide compliance program
1910.1047
Formaldehyde corrective actions description
1910.1048
Inorganic arsenic compliance program, plus housekeeping and maintenance plan
1910.1018
Lead compliance program
1910.1025
Methylenedianiline compliance program, plus emergency situations plan
1910.1050
Respirable crystalline silica exposure control plan
1910.1053
Vinyl chloride compliance program, plus emergency situations operational plan
1910.1017
11
J.J.KellerWebcast
July12th,2016
OSHA poster (OSHA 2203 or 3165)
Post citation until violation abated
or for 3 working days (whichever is
later)
Abatement verification within
10 calendar days after
abatement date
Post copy of abatement documents
(or summary) within same time
provided to OSHA
Failure to meet posting rules may
bring $12,471 fine
OSHA
300: Log of
Work-Related Injuries
and Illnesses
OSHA
301: Injury and

Illness Incident Report
OSHA
300A: Summary of
Work-Related Injuries
and Illnesses
Equivalent
forms may also be used
9/18/2014: Final rule
1/1/2015: Effective date
Employers must report:
Within 8 hours, all work-related:
Within 24 hours, all work-related:
Fatalities
In-patient hospitalizations
Amputations
Losses of an eye
Reports will be made public and

OSHA may inspect
Failure to report can bring $5K to

$124K fine per instance
12
J.J.KellerWebcast
July12th,2016
5/12/2016, 5/20/2016: Final rules

Requires e-submission of injury/
illness records to OSHA for
covered employers:
Sites with 250+ workers send

Forms 300, 300A, & 301 info annually
Sites with 20+ workers in high-hazard industries
send Form 300A info annually
Sites with 1+ workers may be notified to submit info
Data made public, used to focus enforcement

Corporate-wide reports accepted
First submissions due 7/1/2017 covering 2016
State-plan states must adopt nearly identical rules
Not
required
Inspector
may request them
May
help to provide employee

misconduct defense, which includes:
1.
2.
3.
4.
A work rule adequate to prevent

the violation,
Effective communication of rule
to workers,
Methods for discovering violations
of work rules, and
Effective rule enforcement when
violations discovered
More
paperwork
requirements found
in OSHA regulations
Review
finer details
found in OSHA
regulations
Know
whats required
and whats not
13
J.J.KellerWebcast
July12th,2016
Take a Proactive Approach to Safety and Compliance
J. J. Keller OSHA Compliance Program

On-site guidance and resources to improve workplace compliance
Protect your company and ensure compliance
Identify your greatest risks and have an action plan to improve
them
Leverage industry knowledge and experience that you may
lack internally
Have access to a team of experts at a moment's notice
Save significant time and internal resources
NEW! Industrial Hygiene Services now available!
Learn more, call us at
888.473.4638
Or visit JJKeller.com
Make a poll selection to learn more about

J. J. Keller Consulting Services!
Learnmore.Callusat18884734638
To view and register for

upcoming, FREE J. J. Keller
webcasts, visit: JJKeller.com,
click on the Events and
Education tab, then Webcasts
Learn more at:

www.JJKeller.com
Or call 888.473.4638
14
J.J.KellerWebcast
July12th,2016
Due to the constantly changing nature of government
regulations, it is impossible to guarantee the total and absolute
accuracy of the material contained herein or presented.
J. J. Keller & Associates, Inc., cannot and does not assume any
responsibility for omissions, errors, misprinting or ambiguity
contained. J. J. Keller, shall not be held liable in any degree for
any loss, damage or injury caused by any such omission, error,
misprinting or ambiguity present. It is made available with the
understanding that J. J. Keller is not engaged in rendering legal,
accounting or other professional service. If legal advice or other
expert service is required, the services of such a professional
should be sought.
15

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Safety plans and other records

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Take a Proactive Approach to Safety and Compliance

J. J. Keller OSHA Compliance program

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Subject-Matter Expert Areas:

Contributing writer to leading trade

How would you rank your level of OSHA

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

paperwork under 29 CFR 1910,

CFRs for all your paperwork

focus on federal OSHA

Separate from personnel files

Laws: ADA, FMLA, GINA, etc.

How do you secure copier,

Labtop and mobile devices?

will have access?

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Check paperwork requirement

If no duration specified, think:

Number of years, i.e., 30

Destroy when allowed to

Employee exposure records preserved for at least

Monitoring/Sampling toxic substance/physical agent

Employee medical records preserved for the duration

Records made by healthcare professional concerning health

Five minimum plan elements:

9 standards require EAP under 1910.38

(Click JJKeller.com, Workplace Safety, View All News and Alerts,

In writing if employer has over

Process safety information

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Safety and health program

Emergency response plan

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

hazard assessment (HA):

Record workplace that is evaluated, person certifying

Respiratory protection program

protective equipment record:

Certify equip. tested, passed test, date

Documented data supporting

for reclassification of permit space

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Annual maintenance check

Acceptance test dates

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

Overhead & gantry cranes

Crawler, locomotive, & truck

Certification of hook and hoist

Certification of rope inspection

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.

steel chain slings

Certificate of proof test

Certificate of proof test

Certificate of proof test

Mechanical power presses

Pull-out device inspection/maint. records

Records of periodic/regular maintenance safety checks

Copyright 2016 J. J. Keller & Associates, Inc. All rights reserved.