17.3 Writing Safety Directives, Objectives & Written Programs
Key Takeaways
- OSHA requires written programs for hazard communication, lockout/tagout energy control procedures, permit-required confined spaces, respiratory protection, bloodborne pathogens, process safety management, and emergency action plans, among others.
- 29 CFR 1910.38(b) permits an employer with 10 or fewer employees to communicate the emergency action plan orally; every larger employer must have it in writing, kept in the workplace and available to employees.
- A directive hierarchy runs policy, program, procedure, work instruction, with each level answering a different question, and collapsing them produces documents that are simultaneously too vague to follow and too detailed to read.
- Directives must assign obligations to named roles rather than to named individuals or to the passive voice, because a requirement with no accountable role cannot be enforced or audited.
- Vague qualifiers such as "as appropriate", "where feasible", and "adequate" without defined criteria convert a requirement into an opinion and are the most common defect in safety writing.
17.3 Writing Safety Directives, Objectives & Written Programs
"Write directives to meet safety objectives and activities" is a named skill in the BCSP blueprint, and it is one of the few genuinely craft-based competencies the credential tests. A safety management professional spends a substantial share of their working life producing written instruments — policies, programs, procedures, work instructions, bulletins, objectives — and the quality of that writing determines whether technical analysis ever becomes practice.
The failure is almost never that the author did not know the subject. It is that the document does not say who must do what, by when, to what standard, and what happens if the condition is not met.
Which Written Programs Are Actually Required
Many organizations write documents nobody requires while missing ones that are mandatory. The principal federal written requirements:
| Requirement | Citation |
|---|---|
| Hazard communication program, including the list of hazardous chemicals | 29 CFR 1910.1200(e) |
| Energy control (lockout/tagout) procedures | 29 CFR 1910.147(c)(4) |
| Permit-required confined space program | 29 CFR 1910.146(c)(4) |
| Respiratory protection program with worksite-specific procedures | 29 CFR 1910.134(c) |
| Bloodborne pathogens Exposure Control Plan | 29 CFR 1910.1030(c) |
| Process safety management elements including written operating procedures | 29 CFR 1910.119 |
| Emergency action plan | 29 CFR 1910.38 |
| Fire prevention plan | 29 CFR 1910.39 |
| Hearing conservation elements within the noise program | 29 CFR 1910.95 |
| PPE hazard assessment certification | 29 CFR 1910.132(d)(2) |
| HAZWOPER safety and health program | 29 CFR 1910.120(b) |
| Lead and asbestos compliance programs where exposures exceed the PEL | 29 CFR 1910.1025, 1910.1001 |
| Fall protection plan (narrow circumstances) | 29 CFR 1926.502(k) |
A frequently tested nuance: 29 CFR 1910.38(b) provides that an emergency action plan must be in writing, kept in the workplace, and available to employees for review, but an employer with 10 or fewer employees may communicate the plan orally. The same structure appears in the fire prevention plan standard.
The Directive Hierarchy
Each level answers a different question. Collapsing them produces the characteristic organizational document that is simultaneously too vague to follow and too long to read.
| Level | Question it answers | Typical length | Approved by |
|---|---|---|---|
| Policy | What do we commit to, and why? | 1 page | Chief executive |
| Program | How is this hazard managed across the organization, and who is accountable? | 5–20 pages | Function head |
| Procedure | How is this task performed, step by step? | 2–10 pages | Department manager |
| Work instruction / job aid | What exactly do I do at this machine, right now? | 1 page, often visual | Supervisor |
| Directive / bulletin | What changes, effective when, pending revision of the above? | 1 page | Issuing authority |
A directive is the instrument for a change that must take effect before the underlying program can be revised — after an incident, a regulatory change, or a newly identified hazard. Its discipline is that it must carry an effective date and either an expiry date or a commitment to fold the change into the governing document, or the organization accumulates a shadow rule set that nobody can reconcile.
Writing Safety Objectives
ISO 45001 requires objectives to be consistent with the policy, measurable or capable of performance evaluation, monitored, communicated, and updated. In practice, use SMART:
- ❌ "Improve contractor safety performance."
- ✅ "By 31 March 2027, 100 percent of contractors in risk tiers 1 and 2 will have completed prequalification through the new platform, with the procurement manager accountable and monthly reporting to the operations director."
Three cautions specific to safety objectives:
- Do not set objectives on injury rate alone. A target expressed only as a recordable rate creates direct pressure to suppress reporting. Pair any outcome target with leading activity and quality measures.
- Assign the objective to the line, not to the safety department. An objective owned by safety is a safety department objective; an objective owned by the operations director is an organizational one.
- Make the measurement method explicit at the point the objective is written, not after the period closes.
Drafting Rules That Produce Enforceable Text
Name the accountable role, never a person, never the passive voice.
- ❌ "Inspections shall be conducted monthly."
- ✅ "The area supervisor shall inspect each fall-protection anchor point at least once per calendar month and record the result in the maintenance system."
Use "shall" or "must" for requirements, "should" for recommendations, and say which you mean at the front of the document. Mixing them without definition makes the whole document advisory.
One requirement per sentence, one action per step. Compound steps hide missed actions.
Define the measurable criterion. This is the single most valuable habit in safety writing.
- ❌ "Adequate lighting shall be provided."
- ✅ "Illumination at the work surface shall be at least 50 foot-candles, verified with a light meter at commissioning and after any change to the lighting layout."
Eliminate the escape hatches. "As appropriate", "where feasible", "as necessary", "adequate", "sufficient", "in a timely manner", and "as required" convert a requirement into an opinion, and an auditor cannot test them. If discretion is genuinely intended, say who exercises it and on what basis: "The competent person may authorize an alternative anchorage where the designed anchorage is unavailable, provided the alternative is documented on the permit and rated for 5,000 pounds per attached worker."
State the stop condition. Good safety documents say what to do when the requirement cannot be met. A procedure with no exception path guarantees an undocumented workaround.
Write for the reader who will use it. A work instruction for a production line is written at the line's reading level, in the workforce's language, with photographs of the actual equipment — not in regulatory prose.
Reference, do not duplicate. Copying regulatory text into a procedure means it becomes wrong the moment the regulation changes. Cite it.
Document Control
Every controlled safety document needs a unique identifier, version number, effective date, approval authority, review cycle, and change history. Two disciplines matter most in practice:
- A review trigger, not just a review date. Documents must be reviewed on a fixed cycle and on specified triggers: a relevant incident, a process or equipment change, a regulatory change, an audit finding.
- Controlled distribution and withdrawal. Superseded versions must be removed from circulation. The most dangerous document in an organization is an obsolete procedure still hanging at a workstation, because it carries full apparent authority.
Senior manager pitfall. Judging the program by the binder. A thick, well-formatted, current-on-its-face manual that nobody at the workface has read is worse than a thin one, because it creates management confidence that the hazard is handled and it gives an investigator a written standard the organization demonstrably failed to meet. Test the document by asking a worker to perform the task from it.
A safety management professional is drafting a requirement for machine guarding inspections. Which formulation is most defensible as an auditable directive?
A 7-employee machine shop has no written emergency action plan. The owner has walked all employees through evacuation routes, assembly points, and reporting procedures verbally and can describe the content in detail. Is the shop compliant with 29 CFR 1910.38?
An executive team asks the safety director to propose the corporate safety objective for the coming year and suggests "reduce the total recordable incident rate by 25 percent." What is the most professionally sound response?
During an audit, a safety manager finds that a laminated lockout/tagout procedure posted at a bottling machine describes an isolation sequence for equipment that was replaced eighteen months ago. The current written procedure exists in the document management system and is correct. What is the most serious aspect of this finding?
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