OSHA regulations require written plans for a range of specific safety and health topics, but there is no universal requirement for a single, all-encompassing written EHS (Environmental Health and Safety) plan and an EAP (Emergency Action Plan) for every employer. The need for your EHS program depends on the hazards and operations present at each workplace you manage.

Robust EHS and EAP plans protect workers, shields the company from fines and lawsuits, and helps keep projects on schedule. Treat it as a living document tied directly to how you bid, schedule, and build — not as paperwork you file and forget. Employers should review applicable OSHA standards to determine which written plans are required for their operations.

For instance, OSHA standards codified in 29 Code of Federal Regulations (CFR) 1910.120 call for the implementation of a written safety and health program for employees involved in hazardous waste operations. The program should identify, evaluate, and control safety and health hazards, and provide for emergency response for hazardous waste operations.

Your plan should do the following:

1. Spot the hazards
2. Size up the risk
3. Spell out the fix—with a plan for “what if?”

Below, we’ll walk you through the essential components of an effective EHS program and EAP (emergency action plan).

Hazard Identification and Risk Assessment

First, map the threats: chemical spills, falls from ladders, toxic fume exposure, and so on.

For every item on your list, ask two questions:

“What could go wrong?” and “How bad and how likely is it?”

Plot the answers on a simple risk matrix; red boxes get priority. Then consider the hierarchy of controls:

1. Eliminate (e.g. stop using the hazardous material)
2. Substitute (e.g. switch to a less hazardous material)
3. Engineer (e.g. install a local exhaust ventilation system)
4. Administrative (e.g. provide additional training to employees)
5. PPE (e.g. use respirators — note that this is the last line of defense, not the first)

Update the matrix whenever the scope changes. Don’t file and forget your plan. Refer to it often.

Emergency Preparedness and Response

Establish procedures and plans for responding to emergency situations that may occur.

A lean, field-tested Emergency Action Plan covers:

• Alarms and Talk-Back: Horns, radios, bilingual instructions.
• Evacuation Routes: Two clear paths, marked in daylight and dark.
• Critical Shutdown: Who turns offthe generator or secures the crane?
• Spill and Fire Gear: Extinguishers, absorbents, and trained hands within 50 ft.
• Medical: First-aid kits and someone certified, reachable in three minutes.

Run drills quarterly; log who attended and what went sideways. Paper plans don’t save lives, but muscle memory does.

Training and Education

OSHA’s rule of thumb: “Train in a language and vocabulary workers understand.” A better rule: “Train until they can teach the next person.”

Mix it up with different presentations:

• Hands-on demos (how to react to a chemical spill)
• Toolbox talks (ten minutes at daybreak; one topic only)
• Short e-modules (for refresher quizzes)
• Competency checks (a signature alone won’t prevent a disaster)

Track it all. Self-designed spreadsheet, computer learning management system (LMS), documentation posted on the jobsite — just be able to show an inspector a real record.

Occupational Health and Safety Controls

Identify potential occupational health hazards and implement appropriate controls to mitigate risks. These could include falls, electrocution, respiratory hazards, heat stress, noise exposure, confined spaces, and more.

Ask yourself: “Does the control eliminate the root risk or do we normally just use PPE?” Aim high on the hierarchy.

Environmental Management

A clean job site is cheaper, safer, and simply looks better to passersby. Identify and manage environmental impacts associated with the workplace or site, including air and water quality, waste management, and energy conservation.

• Dust and Diesel: Water trucks, silt fencing, Tier 4 engines, idle-off rules.
• Stormwater: SWPPP (Stormwater Pollution Prevention Plan) in place, wattles checked after every rain, logs signed.
• Waste: Separate hazardous (solvents, lead wipe) from non-hazardous materials; label drums; ship within 90 days.
• Energy: LED light towers, battery scissor lifts, power-down policies.

A tidy site gives you bragging rights and shows the world you care.

Regulatory Compliance

Federal OSHA is only the front door. List applicable local and state laws, regulations, and standards related to environmental health and safety for the project.

You’ll likely juggle:

• EPA: air permits, NPDES stormwater, RCRA waste rules
• DOT: 49 CFR hazmat if you haul diesel or acetylene
• State and Local: State OSHA extras such as fire-marshal hot-work permits, city noise curfews, and more.

Build a compliance matrix: law → activity → person in charge → proof. Digital binders beat a milk crate full of coffee-stained printouts.

Incident Reporting and Investigation

Establish a system for reporting and investigating incidents and near misses to identify the root cause and prevent future occurrences. Near-miss today, ambulance tomorrow — that’s the progression often seen.

• Report all mishaps and “near misses” within 24 hours.
• Investigate with the “Five Whys” or a fishbone diagram — don’t list “worker error” as your go-to description.
• Correct errors, whether human or equipment.
• Share the lesson in the next toolbox talk.

Digital apps make reporting painless. Transparency breeds trust; cover-ups breed repeats.

Auditing, Monitoring and Continuous Improvement

Schedule regular monitoring and auditing of the EHS plan to identify areas for improvement and ensure ongoing compliance. Safety is a loop, not a line.

Adopt a systematic approach:

• Weekly superintendent walk-throughs
• Monthly management scorecard review
• Quarterly third-party audit
• Annual top-to-bottom program rewrite

Making the Plan a Living Document

A rock-solid EHS plan is:

1. Site-specific — names the trench by location, not an abstract “excavation area.”
2. Accessible — QR code on every foreman’s phone, hard copy in appropriate languages on the wall.
3. Dynamic — updates when the crane is relocated or the paint formula changes.
4. Integrated — safety decisions drive scheduling, procurement, and quality.

Revamp your plan when regulations or situations change, but keep safety in sight.

Where FACS Fits In

Crafting a plan that satisfies regulators and the real world can take you way too long, and you can miss way too much. Our team of industrial hygienists and environmental scientists has done the heavy lifting on hundreds of sites.

FACS employs experienced industry leaders that can assist in developing a site specific EHS plan customized to your project: No cookie-cutter PDFs — each plan is hand-built for your specific needs.

Let’s put a custom EHS plan to work for you. Call FACS at (888) 711-9998 or contact us online here.