Understanding Safety Plan Requirements
Not sure if you need a written safety plan? Let's break down the requirements by category.
Federal OSHA Requirements
General Duty Clause 5(a)(1)
All employers must provide a workplace "free from recognized hazards." While OSHA doesn't mandate a single comprehensive document called a "safety plan," it does require:
- Hazard identification and assessment
- Written programs for specific hazards
- Training documentation
- Emergency procedures
In practice, a site-specific safety plan addresses all these requirements in one document.
Specific Written Program Requirements
OSHA explicitly requires written programs for:
- Hazard Communication (29 CFR 1910.1200)
- Fall Protection Plan (29 CFR 1926.502)
- Respiratory Protection (29 CFR 1910.134)
- Confined Space Entry (29 CFR 1926.1204)
- Lockout/Tagout (29 CFR 1910.147)
- Scaffolding (29 CFR 1926.451)
Who Specifically Needs a Plan?
General Contractors ✓
Absolutely required.
- Controlling employer responsibilities
- Multi-employer site coordination
- Overall site safety management
- Subcontractor oversight
Subcontractors ✓
Yes, your own plan.
- Specific to your scope of work
- Your employees, your responsibility
- Coordinate with GC requirements
- May be contractually required
Solo Contractors with Employees ✓
Yes, if you have even ONE employee.
- Any employee = employer obligations
- Part-time, full-time, temporary—all count
- Documentation protects everyone
Self-Employed Individuals
Technically exempt from OSHA, but consider:
- GC may require one anyway
- Insurance may require documentation
- Best practice for liability protection
State Requirements
State Plan States
26 states operate their own OSHA programs. Some have additional requirements:
California (Cal/OSHA):
- Injury and Illness Prevention Program (IIPP) mandatory
- Written program required for ALL employers
- Specific documentation requirements
Other State Plans may have additional requirements:
- Oregon
- Washington
- Michigan
- North Carolina
- And others
Check your state's requirements!
Contractual Requirements
General Contractors Require Plans From:
- All subcontractors before starting work
- Specialty contractors with high-hazard operations
- Anyone whose employees will be on site
Owners Often Require:
- Pre-qualification safety documentation
- Project-specific safety plans
- Evidence of safety programs
Insurance Companies Require:
- Written safety programs
- Documentation of training
- Inspection records
Government Projects
Federal Projects
FAR (Federal Acquisition Regulation) often requires:
- Comprehensive safety programs
- Documented procedures
- Regular safety reports
State and Municipal Projects
Often have specific safety documentation requirements beyond OSHA minimums.
The Business Case
Even if not strictly required, smart contractors have safety plans because:
- Win more bids: Pre-qualification requirements
- Lower insurance costs: Documented programs = lower premiums
- Reduce liability: Evidence of due diligence
- Protect workers: The right thing to do
Quick Decision Guide
| Your Situation | Need a Safety Plan? |
|---|---|
| GC with employees | ✓ Yes |
| Subcontractor with employees | ✓ Yes |
| Solo with employees | ✓ Yes |
| Self-employed, GC requires it | ✓ Yes |
| Self-employed, no requirements | Recommended |
When in doubt, document. SafetyPlanPro makes creating a comprehensive safety plan easy and affordable. Protect your workers and your business in minutes.