HR Hero Line

OSHA compliance planning calendar

by John E. Hall

Occupational Safety and Health Administration (OSHA) regulations and standards include numerous training, posting, or other compliance actions that are required annually or at other regular intervals. There are a number of issues you should consider for your compliance planning calendars, including:

  • A facility with employees who have occupational exposure to blood or potentially infectious materials must have an exposure control plan that is reviewed and updated at least annually. This is required by OSHA standard 29 CFR § 1910.1030.
  • Employers must inform employees upon their initial hire and at least annually about the existence of and their right to access their medical exposure records. This includes the name of the person maintaining the records and their location. The relevant standard is 29 CFR § 1910.1020(g)(1).
  • Powered industrial truck operators (e.g., forklift drivers) must have their performance evaluated at least every three years as required by 29 CFR § 1910.178(l)(4)(ii).
  • Employees exposed to an eight-hour time-weighted average noise level at or above 85 decibels must have a new audiogram at least annually under 29 CFR § 1910.95(g)(6).
  • OSHA’s permit-required confined space standard mandates that the program be reviewed using canceled entry permits within one year of each entry. A single annual review using all entries during that time may also be performed. The relevant standard for this requirement is 29 CFR § 1910.146(d)(14).
  • Under the hazardous energy control standard (29 CFR § 1910.147(c) (6)), lockout/tagout procedures must be reviewed at least annually, and the review must be certified.
  • Recordable injury and illness cases must be entered on the facility’s log within seven days of receipt of information on the case. The calendar summary must be posted annually from February 1 through April 30.
  • Effective training must be provided annually to employees who are required to use respirators.
  • Employers using products subject to OSHA’s substance-specific health standards should be aware of their requirements for periodic monitoring and training.

Since these periodic requirements take time (reviewing and updating programs) and money (training and testing), we encourage employers to develop an annual OSHA calendar―so that you can budget both the time and the money to keep compliant.

John E. Hall is the OSHA consultant for Lehr Middlebrooks & Vreeland, P.C. Before working with the firm, he was the OSHA area director and worked for 29 years with the agency in training and compliance programs, investigations, enforcement actions, and setting OSHA priorities. He may be contacted at jhall@lehrmiddlebrooks.com .