Employer duties

When is a written plan mandatory in the United States?

In the US the duty arises not from a general plan but from particular work. The four conditional plans measured are: the emergency action plan (only when another OSHA standard expressly requires it, and it must be written), the fall protection plan (only in leading edge, precast concrete erection and residential construction work where conventional fall protection is infeasible or creates a greater hazard), the site safety and health plan (only in hazardous waste operations, with ten listed content items) and the permit-required confined space programme.

Four conditional plans

PlanWhen mandatoryForm
Emergency action planOnly when another OSHA standard expressly requires oneMust be written; content listed in the rule
Fall protection planLeading edge, precast concrete erection and residential construction, where conventional fall protection is infeasible or creates a greater hazardPrepared by a qualified person, kept on site
Site safety and health planOnly in hazardous waste operationsKept on site; ten listed content items
Permit-required confined space programmeWhere entry into a permit-required confined space will take placeUnauthorised entry prevented, hazards identified, equipment provided at no cost

A difference of logic

The European approach starts from the site: if there is a site there is a plan. The US approach starts from the work: if the work carries a particular hazard, that hazard has a plan. Both aim at the same place, but compliance work starts from a different end.

The practical consequence

A contractor moving from Türkiye to the US cannot comply by translating its single general plan. The right route is to break the work down hazard by hazard and see which conditional plan is triggered.

The ones with content lists

The hazardous waste site plan's ten items include risk analysis, training assignments, personal protective equipment, medical surveillance, monitoring, site control, decontamination, the emergency response plan and confined space entry. So content-listed plans do exist — each tied to particular work.

Manage this in Optifora

Optifora is not a single program but a compliance platform assembled from modules. The catalogue states which module is ready today and which is on the roadmap.

See what Optifora is