This article was originally posted at some time between 2015 and September, 2020. It is being re-posted now as part of our website reconstruction. Some of the dates mentioned in this article may reference the time period from which it was originally posted.
I frequently get calls from organizations asking if I could send them a template AWAIR, Right to Know, Hazard Communication (Haz. Comm.) program.
A template program is a policy or program that has been written in a “fill in the blanks” format. There are consultants and other organizations who sell these template documents to employers who need to develop these written programs and policies to comply with OSHA. Often, this need arises after an OSHA inspection. These buyers don’t have experience writing these programs so they find the idea of a template very attractive.
But buyer beware.
There’s nothing wrong with templates per se. I admit that I use them extensively for training programs, written policies, procedures, forms, etc. I almost never start any project from a blank page. But they are for my own internal use.
But people shopping for templates need to be very careful about purchasing and using template programs. A few things to think about:
- Templates, even after they have been edited, are often extremely general and are not adequately customized to reflect the employer’s operations. To be acceptable, the final product must accurately reflect and represent the company to which it applies, and this goes beyond just filling in the name of the company at the top of page 1. Be sure your program doesn’t include phrases like “this company”, and other suspiciously general phrases. These are dead giveaways that your program isn’t authentic. Also, be sure the job titles listed in the program actually exist within your company.
- Be sure the template has required content. Very often, they don’t. OSHA not only mandates that an employer have a written program, but also what it must discuss. Certain vendors don’t bother to research the requirements.
- Be sure the template is appropriate for the jurisdiction. About 50% of all U.S. states administer their own OSHA program. In many cases, their requirements are not perfect reflections of Federal rules. Hence, a template which is based on a Federal requirement may, or may not be sufficient to meet a specific state’s requirements.
- It’s really not that difficult or expensive to do it correctly. I can write a genuine, compliant, customized program for you, for about $200.
Everything above also applies to template/generalized training programs as well.
Again, there’s nothing wrong with using an AWAIR template, Employee Right to Know template, Hazard Communication template, Respiratory Protection template, etc. Even Minnesota OSHA (MNOSHA) has no formal regulations against using them as long as they are used only as a starting point to craft a program that truly reflects your operation, and they meet the content requirements. Just remember that there are better options, such as working with your insurance carriers or a qualified, experienced consultant (my email is firstname.lastname@example.org), and if you must use a template, be sure you use them properly.
Have any of you used template vendors in the past? How did it work out for you? Please comment below.