If you approach any manufacturing or distribution company, safety is their normal number-one priority. ISO 45001 was published in 2018 for an organization to develop and manage a Health and Safety program to enhance requirements in the Code of Federal Regulations 29 (Title 29). Since its publication there have been numerous articles with regards to ISO 45001 but very little about OSHA and its requirement in Occupational Safety and Health Standards 29 CFR 1910. Let’s begin with an introduction of OSHA.

The Occupational Safety and Health Administration, normally referred to as OSHA, is a governmental agency under the Executive Branch which enforces safety regulations. The OSH Act enacted in 1971 also formed two additional organizations the National Institute for Occupational Safety and Health (NIOSH) and Occupational Safety and Health Review Commission (OSHRC). The responsibility is to improve worker safety and health protection.

Individual states can create state specific OSHA plans which are required to be as effective as Federal OSHA. Twenty-two state plans cover private sector and government workers while seven state plans only cover government workers.

OSHA enforces the regulations by inspections and citations performed by Compliance Safety Health Officers. Details can be found in 29 CFR 1903. Violations include:

The ten most common cited standards are

1. Fall Protection General Requirements
2. Hazard Communications
3. Ladders
4. Scaffolding
5. Powered Industrial Trucks (e.g. Forklifts)
6. Control of Hazardous Energy (LOTO)
7. Respiratory Protection
8. Fall Protection Training Requirements
9. Personal Protective and Lifesaving Equipment; Eye and Face Protection
10. Machine Guarding

It must be noted that from year to year the order may change. But these remain constant as the top ten citations.

For those working with ISO45001, I hopefully realize that OSHA is only a small part of the requirements. Even the OSHA requirements need additional requirements from the Consensus Standards:

• American National Standards Institute (ANSI)
• American Conference of Governmental Industrial Hygienists (ACGIH)
• National Institute for Occupational Safety and Health (NIOSH)
• National Fire Protection Agency (NFPA)

There are also Industry specific regulations such as Maritime, Mining, Agricultural and construction. These industry specific regulations are often stricter than the OSHA regulations.

29 CFR 1904 defines requirements for recording and reporting. The most common document is the OSHA 300 Log which is the annual log for OSHA recordable injuries. There are some organizations that are exempt from submitting this log. There are also recordable exceptions such as voluntary participation in a wellness, medical or fitness activity.

There has been one recent change that impacts chemical manufacturers/distributors and the organizations under this change that are ISO45001 certified. Effective July 19, 2024 changes were for labeling of small chemical containers, bulk chemical shipments and outer containers. Compliance with the standard modifications is not required until 2026. Training programs will need to be revised and employees trained.

I hope you obtained more insight in the OSHA regulations and how ISO45001 is a part of an effective safety program. Realize that this article only scratched the surface on the regulations.