Can “Written Programs” Required By OSHA Be Computerized

  editor |   Laws & Regulations

About The Expert

Glenn Demby is an OSHA attorney and editor-in-chief of SafetySmart Compliance

QUESTION
Can we post a copy of our confined spaces entry program on our intranet and get rid of the cumbersome paper binders we have now?
ANSWER
Yes, as long as all affected employees have access to the program.
EXPLANATION
The OSHA Permit Confined Spaces standard (Sec. 1910.146(c)(4)) requires employers to implement a “written” program for entering permit confined spaces (assuming, of course, the employer allows for such entry).  In an April 8, 2008 Interpretation Letter, OSHA  acknowledges that computers weren’t as prevalent when the standard was written.  “We agree,” says the Letter, “that in many instances electronic access to programs could be beneficial.”
The Letter concludes that where written programs are required, either paper or electronic formats would be okay subject to one condition: The program must meet all the other requirements of the standard in question.
The “other requirement” that OSHA is referring to is the obligation to make the written program available to employees. In other words, all employees must:

  • Know how to access the program by computer; and
  • Be able to access it without any barriers.

Thus, for example, having just an electronic program wouldn’t comply if affected employees don’t have access to or don’t know how to use the computer. The employer would either have to remove the access barriers or make sure there’s also a written copy of the program accessible at the site.
Other Written OSHA Programs Can Also Be Computerized
The OSHA Interpretation Letter applies equally to other standards that require employers to have a written and accessible program at the site, including but not limited to:

 
 
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