Written Safety Program for a Small Contractor: What to Put in It

What OSHA expects from a small contractor’s safety program

The starting point is 29 CFR 1926.20(b), “Accident prevention responsibilities”:

(b)(1): it is the employer’s responsibility to initiate and maintain such programs as may be necessary to comply with Part 1926.
(b)(2): those programs shall provide for frequent and regular inspections of the job sites, materials and equipment by competent persons designated by the employer.
(b)(3): machinery, tools, materials or equipment that do not comply are not to be used. They must be tagged or locked out, or removed.
(b)(4): only employees qualified by training or experience may operate equipment and machinery.

Add 1926.21(b)(2), which requires instructing each employee in recognizing and avoiding unsafe conditions, and you have the core: someone checks the work, unsafe gear comes out of service, and people are trained.

Part 1926 does not name a single document called a “written safety program”. Several rules do require specific written pieces (listed below), and many general contractors and insurers ask subcontractors for a written program before they hire them. A short program that covers the rules plus those written pieces answers both.

Pieces some rules require in writing

Whether each one applies depends on the work you do. The rule text says when:

Written item	Rule	When it comes up
Hazard communication program	29 CFR 1926.59	Workers use hazardous chemicals (sealants, solvents, fuels, cement). 1926.59 applies the same requirements as OSHA’s general industry hazard communication rule, which include a written program, labels, safety data sheets and training.
Emergency action plan	29 CFR 1926.35	When a particular OSHA standard requires one. It must be written, except that employers with 10 or fewer employees may communicate it orally (1926.35(e)(3)).
Silica written exposure control plan	29 CFR 1926.1153(g)	Work covered by the construction silica standard, such as cutting, grinding or drilling concrete, masonry or stone.
Assured equipment grounding conductor program	29 CFR 1926.404(b)(1)(iii)	If you use this program for cords and tools instead of GFCIs, a written description must be available at the jobsite.
Fall protection plan	29 CFR 1926.502(k)	Only for leading edge, precast concrete or residential work where conventional fall protection is shown to be infeasible or more hazardous. Prepared by a qualified person for the specific site.
Fall protection training certification	29 CFR 1926.503(b)	Each employee trained on fall hazards: name, training dates and the trainer’s or employer’s signature.

Two more duties are worth writing down even where the rule does not say “written”: the fire protection and prevention program in 29 CFR 1926.24, and the procedure for employees to report injuries in 29 CFR 1904.35.

A 10-section outline for a small crew

This outline follows the duties above. Most small contractors can cover each section in a page or two.

Safety policy and who is responsible. A short statement signed by the owner. Name who runs the program and who the competent person is for each kind of work (scaffolds, excavations, fall protection).
Jobsite inspections. Who inspects, how often, what they check (falls, ladders, scaffolds, excavation, electrical, housekeeping), and how problems get fixed. This is 1926.20(b)(2).
Tagging out unsafe equipment. How a damaged tool, cord or ladder gets tagged or removed, and who can return it to service (1926.20(b)(3)).
Training and new hire orientation. What every new worker learns on day one, what training each job needs, and how you record it. Weekly toolbox talks go here.
Personal protective equipment. What PPE each task needs and who provides it. 29 CFR 1926.28 makes the employer responsible for requiring appropriate PPE where there is exposure to hazardous conditions.
Your main job hazards. One short page each for the hazards your crews actually face, with the rule to follow: fall protection, ladders, scaffolds, trenching, electrical, silica.
Hazard communication. Your chemical list, where safety data sheets are kept, labeling and training.
Emergencies and first aid. 29 CFR 1926.50 requires arranging for prompt medical attention before a project starts, a person with valid first aid training at the site when no clinic or hospital is reasonably accessible, first aid supplies checked before each job and at least weekly, and posted emergency numbers where 911 is not available. Add evacuation steps and a contact sheet.
Injury reporting and recordkeeping. How workers report an injury (1904.35 requires a reasonable procedure and bars retaliation), who decides if it is recordable, and who keeps the OSHA 300 log. Include when to call OSHA for a severe injury (29 CFR 1904.39).
Incident investigation and review. How you look into injuries and near misses, and when you review the program (at least yearly, and when the work changes).

The competent person

Many Part 1926 rules depend on a competent person: inspections under 1926.20(b)(2), and daily excavation inspections, scaffold inspections and fall protection training, among others. 29 CFR 1926.32(f) defines a competent person as one who is capable of identifying existing and predictable hazards in the surroundings or working conditions, and who has authorization to take prompt corrective measures to eliminate them.

Both halves matter. Someone who knows the hazards but cannot stop the work does not fit the definition. On a small crew, this is often the owner or the lead on each job. Write their names in section 1.

Keeping it simple enough to use

Write for your own work. A roofing crew’s program should be mostly about falls. Skip sections for work you never do.
Use checklists instead of paragraphs. An inspection checklist gets used; a page of prose does not.
Keep a copy on each job. In the truck or the job box, with the emergency contact sheet on top.
Tie it to records. Inspection checklists, toolbox talk sign-in sheets, a training log and the OSHA log are how you show the program is running.
Review it. Once a year and whenever you take on a new kind of work. For an emergency action plan, 1926.35(e)(2) lists when to review it with each employee: when the plan is developed, when their duties change and when the plan changes.

Free help from OSHA

OSHA’s Recommended Practices for Safety and Health Programs lay out seven core elements, including management leadership, worker participation and hazard identification, and are written for small and medium-sized businesses. OSHA’s On-Site Consultation Program offers no-cost, confidential consultations, mainly for smaller businesses, to help identify hazards and set up or improve a safety program.

The rule text is on osha.gov: 29 CFR 1926.20, 1926.35, 1926.50 and 1926.59. This page explains what the rules say; it is not legal advice.

Rules cited: 29 CFR 1926.20, 29 CFR 1926.21, 29 CFR 1926.24, 29 CFR 1926.28, 29 CFR 1926.32, 29 CFR 1926.35, 29 CFR 1926.50, 29 CFR 1926.59, 29 CFR 1926.404, 29 CFR 1926.502, 29 CFR 1926.503, 29 CFR 1926.1153, 29 CFR 1904.35. Read the current text at osha.gov.

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