17.3 Writing Safety Directives, Objectives & Written Programs

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:

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.

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:

1. 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.
2. 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.
3. 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.