Interpretation: OSHA permits written programs to be in paper or electronic format (1/21)
Richard E. Fairfax, OSHA’s Director of Enforcement Programs, issued the following letter of interpretation regarding whether written programs may be kept solely in an electronic format, posted on OSHA’s web site January 16. Here are excerpts:
”As you pointed out in your letter, a number of standards require programs that are written and accessible to all employees on site. Examples of these provisions are 29 CFR 1910.1030(c)(1)(i) and 1910.1030(c)(1)(iii) (bloodborne pathogens), 29 CFR 1910.1200(e)(1) and 1910.1200(e)(4) (hazard communication), and 29 CFR 1910.146(c)(4) (permit-required confined spaces). Traditionally, these programs have been kept in separate binders in appropriate work areas in order to comply with the standards. Maintaining multiple copies of these manuals can be both challenging and time-consuming.
”You have also stated that placing safety materials, programs, checklists, and forms on a company intranet can provide significant benefits in consistency, ease of use, and accuracy in maintaining and updating these materials in a timely manner. And, just as hard copy programs can be photocopied upon request, so can an electronic version be printed out upon request.
”Computers are much more common in the workplace now than when most OSHA standards were written. We agree that in many instances electronic access to programs could be beneficial. Therefore, OSHA would allow a written program to be in either paper or electronic format, as long as the program meets all other requirements of the standard in question.
”Where the standard requires that the written program must be made available to employees, the employer must ensure that employees know how to access the document and that there are no barriers to employee access.”
”As you pointed out in your letter, a number of standards require programs that are written and accessible to all employees on site. Examples of these provisions are 29 CFR 1910.1030(c)(1)(i) and 1910.1030(c)(1)(iii) (bloodborne pathogens), 29 CFR 1910.1200(e)(1) and 1910.1200(e)(4) (hazard communication), and 29 CFR 1910.146(c)(4) (permit-required confined spaces). Traditionally, these programs have been kept in separate binders in appropriate work areas in order to comply with the standards. Maintaining multiple copies of these manuals can be both challenging and time-consuming.
”You have also stated that placing safety materials, programs, checklists, and forms on a company intranet can provide significant benefits in consistency, ease of use, and accuracy in maintaining and updating these materials in a timely manner. And, just as hard copy programs can be photocopied upon request, so can an electronic version be printed out upon request.
”Computers are much more common in the workplace now than when most OSHA standards were written. We agree that in many instances electronic access to programs could be beneficial. Therefore, OSHA would allow a written program to be in either paper or electronic format, as long as the program meets all other requirements of the standard in question.
”Where the standard requires that the written program must be made available to employees, the employer must ensure that employees know how to access the document and that there are no barriers to employee access.”
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