This week OSHA announced that it is seeking public comment on its updated voluntary Safety and Health Program Management Guidelines (OSHA-2015-0018) which it hopes “will provide employers and workers with a sound, flexible framework for addressing safety and health issues in the workplace.” Comments must be received by February 15th, 2016.

The Safety and Health Program Management Guidelines were originally published in 1989. They have been updated to reflect modern technology and practices as well as incorporate approaches taken in two other OSHA programs – the Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP) – and similar initiatives, for example, ANSI/AIHA Z10.

The guidelines take a proactive approach by helping employers collaborate with their employees in establishing health and safety management plans. OSHA believes that they will be especially useful for small to mid-sized businesses and in multi-employer situations. The Agency emphasizes in the News Release that these guidelines are “advisory only and do not create any new legal obligations or alter existing obligations created by OSHA standards or regulations.”

The 42 page draft guidelines are detailed, informative, clearly presented, and illustrated. They are divided into seven, color-code “core elements”:

  • Management Leadership
  • Worker Participation
  • Hazard Identification and Assessment
  • Hazard Prevention and Control
  • Education and Training
  • Program Evaluation and Improvement
  • Coordination and Communication on Multi-employer Worksites.

Each section provides a brief overview followed by Action Items and steps on “how to accomplish it.” Two appendices follow: Appendix A offers Implementation Tools and Resources which, when viewed online, contain links to various training tools and related OSHA materials; Appendix B, entitled “Relationship of Guidelines to Existing OSHA Standards,” contains color-coded tables detailing the existing standards with their connection to the seven core elements.

OSHA’s updates don’t end with the Guidelines. The webpage itself reflects changes which improve user experience. A countdown clock has been introduced counting down the number of days left in the comment period. Large, colorful icons link to information, easy access to the guidelines, and the option to submit comments directly from the webpage.

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Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.