OSHA Defense Package Readiness

1. Written safety & health programs

That the hazards of your work are addressed by a real program, not improvised. This is the single largest driver of the good-faith reduction.

HazCom 29 CFR 1910.1200(e); Respiratory 1910.134(c)(1); LOTO 1910.147(c)(4); Fall Protection plan 1926.502 — a written, implemented program is the core good-faith criterion (FOM CPL 02-00-164 Ch.6)

2. Training records (dates, topics, workers, trainer)

That each affected worker was trained on the specific hazard before the work — with a signed, dated record. Where no standard requires the record, it is how you show an inspector that the training happened.

HazCom training 29 CFR 1910.1200(h)(1) (no record required); fall-protection training certification 1926.503(b)(1) (written certification record required); some other standards also require a record

3. Corrective-action / CAPA log (dated, owner, completion proof)

That when a hazard or near-miss was found, it was assigned, fixed, and verified — the proof an inspector and an attorney both look for.

29 CFR 1903.19 is the abatement-verification rule (certification of abatement, abatement plans and dates); a good-faith penalty reduction rests on an effective program (FOM chapter 6), and a working corrective-action loop evidences one

4. Self-inspection logs (scheduled, competent person)

That you look for hazards proactively on a schedule — a documented, recurring self-inspection record.

29 CFR 1926.20(b)(2) — frequent and regular inspections of the jobsite, materials, and equipment by competent persons

5. Job Hazard Analyses (JHAs) for your tasks

That each task's steps, hazards, and controls were identified before work began — the document that shows you recognized and controlled the risk.

Recommended practice, OSHA Publication 3071; operationalizes the General Duty Clause (OSH Act 5(a)(1)) and 1926.20(b)(2)

6. SDS library, chemical inventory & container labels

That every chemical on site has a current, reachable SDS, is on your inventory, and is properly labeled — the most-cited HazCom pillars.

SDS readily accessible 29 CFR 1910.1200(g)(8); chemical list 1910.1200(e)(1)(i); labels 1910.1200(f)

7. Competent-person designations

That a qualified, authorized person was named for the activities that require one — with the record to show who and when.

Competent person defined at 29 CFR 1926.32(f); required by the applicable subpart (e.g. scaffolds 1926.451, excavation 1926.651, fall protection 1926.502)

8. Equipment & scaffold inspection records

That the gear that fails most — scaffolds, ladders, PIT/vehicles, cranes — was inspected and tagged out when defective, on a dated log.

Scaffold inspection by a competent person before each shift (29 CFR 1926.451(f)(3)); equipment/vehicle checks (1926.601/1926.602)

9. Near-miss reporting & investigation

That you capture and investigate the free warnings before they become injuries — the mark of a program that manages risk, not just paperwork.

Leading-indicator best practice; root-cause analysis of near-misses evidences a proactive program (supports good faith)

10. OSHA 300 / 300A / 301 recordkeeping

That injuries are recorded correctly and the log is defensible — the record insurers, primes, and OSHA all read.

29 CFR 1904 — injury & illness recordkeeping for covered employers (partial exemptions apply)

11. Organized, timestamped, retrievable on demand

That everything above can be assembled and exported as one dated, organized package — the litigation-ready evidence file, not a scramble through binders.

The difference between having records and having a defense package — records must be producible when a compliance officer or an attorney asks