When employers violate OSHA standards, OSHA requires them to create a corrective action plan. How do employers go about developing, implementing, and monitoring this plan?
This article discusses the important details of an OSHA corrective action plan.
Table of Contents
What Is a Corrective Action Plan?
An OSHA (Occupational Safety and Health Administration) corrective action plan is a structured program that addresses safety and health issues identified during OSHA inspections or an employer’s internal incident inspection process. When OSHA inspects a worksite and finds violations, it issues citations and recommends creating a corrective plan of action. OSHA also strongly encourages employers to conduct their own OSHA incident investigation when a workplace incident occurs.
The OSHA corrective action plan should show the employer’s specific steps to rectify workplace violations, hazards, or deficiencies. It helps employers comply with OSHA regulations and avoid further legal fines and penalties. Moreover, the plan helps identify and correct the root causes of a violation, preventing workplace injuries and fatalities.
The Importance of an OSHA Corrective Action Plan
A corrective action plan for employee safety saves lives and money. National Safety Council (NSC) data shows that in 2022, the U.S. experienced 4,695 preventable injury-related deaths at work and 4.5 million medically-consulted injuries. An OSHA Incident Investigation presentation says that a workplace injury has an estimated cost of $39,000 and a fatality over $1.4 million. Added to this is the suffering of workers and their families, which cannot be quantified. If an employee corrective action plan helps resolve poor employee performance, the OSHA corrective action plan helps prevent workplace incidents that could cost thousands of lives and millions of dollars.
Who Develops the Corrective Action Plan?
It’s up to the employer to develop a corrective plan depending on the results of the OSHA inspection or their own internal audit. OSHA, unlike other regulatory agencies, doesn’t issue a corrective action plan in response to an audit. Instead, OSHA requires employers to develop a corrective action plan for violations. It also gives citations and penalties to employers violating safety and health standards.
How to Develop and Implement a Corrective Action Program
Here are the steps in developing and implementing a corrective action plan as derived from the same OSHA incident investigation presentation mentioned above:
1. Find the root causes
Incident investigations help employers identify workplace hazards and improvements they can make in their safety and health programs. The incident investigation should focus on finding the root cause of the fatality, injury, illness, or close call/near misses. It should not be geared toward finding someone to blame.
Root causes are the underlying reasons for the unsafe conditions and reflect the failures in management, design, planning, organization, and operations. Carelessness, human error, or failure to follow a procedure are not actual root causes. Instead, dig deeper. Ask why the problem exists and why it was not addressed earlier. Finding the root causes leads to systemic changes and measures.
2. Collect information
Employers should preserve documentation relevant to any incident investigation. Gather the name and incident description of the affected employee. Document the scene of the incident through video, photographs, or sketches. Preserve the scene using cones, tapes, or guards. Remember to complete the OSHA 300 log and notify the OSHA of workplace incidents within the required timeframe.
In addition, investigators should find other sources of information. Preserve interviews, company records and policies, maintenance schedules, training records, audits and follow-up reports, and previous corrective action plans. These measures help create an informed action plan. They can also serve as proof or support during OSHA investigations.
See also: Understanding OSHA Inspections
3. Create a written plan with specific, actionable steps
Develop the corrective action plan based on root causes and all the information and documents gathered. Avoid superficial conclusions such as, “Employee A should have been more careful in handling the equipment,” or weak actions such as “Employees should always wear respiratory protection.”
For example, the issue is that “employees lack proper training on using personal protective equipment (PPE) when handling hazardous chemicals.” You identified the root cause as a “lack of comprehensive training program specifically on PPE.” General steps may include:
- Identify the employees who need PPE training
- Schedule training sessions
- Deliver training with a qualified trainer
- Assess competency
- Document training records
- Provide access to PPE
- Provide ongoing refresher training
- Monitor compliance
- Ask for employee feedback
- Periodically review and update the program
4. Put the plan into action
Avoid procrastinating on implementing your plan. Create a realistic timetable to complete each part of the program. However, employers should not be impatient in implementing the corrective action plan. Remember that some root causes take time to resolve.
Monitoring and Evaluating the Effectiveness of the Corrective Action Plan
A successful corrective action plan should not end with implementation. Take time for periodic evaluations and employee feedback. When an incident occurs, record and preserve documentation to adjust the plan accordingly. Also, OSHA training for employees is necessary as it equips them with the knowledge and competence they need to perform their work safely.
