Quick answer: Under OSHA 29 CFR 1926.20, every construction employer must maintain a written safety and health program. This guide covers what must be included, what causes citations, and where to get a compliant template — without paying $3,000 to a consultant.

What A Written Safety Program Actually Is

A Written Safety Program is your company's master safety document. It says: here are the hazards our workers face, here's how we identify them, here's how we train workers to address them, here's who's responsible, here's what happens when something goes wrong.

Every construction contractor needs one. Big or small. Union or non-union. Specialty trade or GC.

What OSHA Requires (The Actual CFR)

29 CFR 1926.20 — General Safety and Health Provisions

"It shall be a condition of each contract... that no contractor or subcontractor shall require any laborer or mechanic employed in the performance of the contract to work in surroundings or under working conditions which are unsanitary, hazardous, or dangerous to his health or safety."

The subsections require employers to "initiate and maintain such programs as may be necessary to comply with this part" and provide training and inspection.

29 CFR 1926.21 — Safety Training and Education

Employers must instruct each employee in the recognition and avoidance of unsafe conditions and applicable regulations. Documentation of this training is what OSHA looks for.

Program-Specific Written Requirements

Beyond the general requirement, OSHA explicitly requires written programs for:

The 10 Sections Every Written Program Needs

1. Safety Policy Statement

One page. Signed by the highest-ranking company official. States the company's commitment to worker safety. Non-negotiable — must exist.

2. Scope and Applicability

Who this program applies to (all workers, subcontractors, visitors). What sites/operations it covers.

3. Roles and Responsibilities

Named or role-based responsibilities for:

4. Hazard Identification Process

How your company identifies hazards: job walks, JHAs, incident reviews, worker input. Frequency and documentation.

5. Training Program

Required training for each role. Frequency. Documentation method. New hire orientation. Refresher training.

6. Inspection Program

Daily foreman walks, weekly formal inspections, monthly audits. Checklists used. Findings documented. Corrective actions tracked.

7. Incident Reporting & Investigation

Definitions of recordable vs. reportable vs. near-miss. Timeline for reporting. Investigation process. Corrective actions.

8. Discipline & Enforcement

Progressive discipline: verbal → written → suspension → termination. Applied consistently. Documented.

9. Recordkeeping

Retention schedules for training records (3 years typical), inspection records (permanent), incident reports (5 years), medical surveillance (30 years).

10. Program Review

Annual review process. Trigger events for interim updates. Document control.

Written Safety Program Templates — From $12.99

Complete written programs for fall protection, HazCom, respiratory, confined space, LOTO, and more. Fully editable Word + PDF. Instant download.

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What Your GC Probably Requires (Beyond OSHA)

General contractors typically require more than OSHA baseline. Common additional requirements:

Common Written Program Mistakes

DIY vs Template vs Consultant

Approach Cost Time Quality
DIY from scratch $0 40-100 hrs Variable
Template + customize $12-500 4-16 hrs High if picked well
Consultant $2K-$15K 2-6 weeks High

Frequently Asked Questions

Is a written safety program required by OSHA?
For construction under 29 CFR 1926.20(b), yes — employers must "initiate and maintain such programs as may be necessary to comply with this part." Specific written programs are explicitly required for HazCom (1910.1200), Bloodborne Pathogens (1910.1030), Respiratory Protection (1910.134), Emergency Action Plans (1910.38), Fall Protection where conventional means are infeasible (1926.502(k)), and others.
What must be in a written safety program?
Core elements: (1) Safety policy statement, (2) roles and responsibilities, (3) hazard identification, (4) training, (5) inspection procedures, (6) incident reporting, (7) discipline, (8) recordkeeping. Program-specific requirements add sections based on your work (e.g., HazCom program adds chemical inventory + SDS access + labeling).
Can I use a template from Google?
Free templates are starting points, not finished documents. They're typically generic, outdated, or missing specific requirements. A template + 4-8 hours of customization gets you compliant. A template + zero customization gets you cited.
How is a written safety program different from a health and safety plan?
The Written Safety and Health Program is the master company-wide document. The Site-Specific Health and Safety Plan (HASP) is per-project, addressing site conditions. Most contracts require both. Your written program is the framework; your HASP is the site-specific implementation.
What triggers a written safety program update?
New work types, new equipment, new chemicals, incidents or near-misses, OSHA rule changes, contract requirements from your GC. At minimum, annual review with dated documentation.

OSHA New Contractor Starter Kit — 25 Files

Everything a new construction contractor needs. Master safety program + JHAs + toolbox talks + inspection forms + training records. $19.99.

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Article by Anthony Forbes. 20 years field experience in wind, transmission, HVDC, and live-line 500kV work. Currently field supervisor on major-component exchange projects. All templates on this site are written by Anthony directly.