Guidelines for Products Developed by OSHA's Alliance Program Participants
(Effective date: Sep. 9, 2014)
- Overview of Product Goals, Messaging, and Other Characteristics
- Product Development Process
- Required Standard Language
As part of their activities, Alliance participants may develop products, such as fact sheets, case studies, posters, toolbox talks, safety manuals, training tools, videos, and best practice documents. These guidelines define the expectations and requirements that apply to such products, including their goals, the processes for their development, review, update or withdrawal, and other requirements.
Overview of Product Goals, Messaging, and Other Characteristics
The principal goal of all Alliance products is to provide employers and workers tools and guidance to help eliminate and/or prevent workplace health and safety hazards. At a minimum, Alliance products will help employers comply with OSHA rules and standards. Ideally, however, they should help employers go "beyond compliance" by adopting best practices for the industry(ies) or hazard(s) which are their focus.
Alliance products should add value to existing OSHA or other workplace safety and health materials, or fill gaps where such materials do not exist. Alliance products should be more than simple re-packaging of existing materials, unless the purpose is to convey the information via new and potentially more effective means, such as adapting text to a video format.
Audiences, Language Criteria, and Key Messages
The audience for the product must be clearly defined and the products should be drafted with the audience in mind. The audiences are typically workers, employers, and/or occupational health and safety professionals. The products should use language and vocabulary appropriate to the target audiences, including translation to non-English-speaking segments of the workforce when appropriate.
Whatever their principal audience, products should always make clear that the employer has the primary responsibility under the law to provide a safe workplace. Products should not put the burden on employees to correct hazards, as they typically do not have control over the worksite, the equipment or the rules in the workplace. Products must include information regarding employer responsibility and worker rights under the Occupational Health and Safety Act of 1970. (See standard language in section IV below.)
Alliance products are developed by Alliance participants with OSHA input and review, undergo a well-defined review process, and are expected to receive wide dissemination, primarily by the Alliance participants (see section III.E). Alliance participants own the products, but agree to make them available to the public for free.
Alliance products should strive to fill gaps in, or improve upon, existing materials focused on the hazards or issues they address. For example, Alliance products may be entirely new products resulting from an Alliance, substantive updates in content or effectiveness to existing materials, or reworking of existing technical materials for different audiences or purposes (such as for an industry lacking such materials tailored to its needs, translations of existing products for workers with limited English proficiency, or adaptations to different or complementary media, such as videos). The use of pictures, graphics or video material is strongly encouraged, whenever possible, in order to broaden the audience for which the products will be helpful.
The following are some examples of the types of products that Alliances have developed:
- Fact Sheet
- Case Study
- Best Practice Document
- Safe Operation Manual or Procedure (or equivalent)
- Toolbox Talk
- Training Presentation
Product Development Process
Proposed products should be in line with an Alliance's goals and work plan, as well as aligned with broader OSHA priorities. Alliance participants develop product proposals in coordination with the Alliance implementation team, including the OSHA Alliance Coordinator and OSHA subject matter experts.
Alliance participants should use relevant data to help determine what products to develop, such as data that can help to identify and focus on the most serious or widespread hazards in a given industry or trade. Such data may include injury and illness rates, workers' compensation data, and information about the known and suspected exposures to hazards in an industry, as well as best practice controls.
The Alliance participant submits product proposals to the OSHA Alliance Coordinator who in turn obtains expert OSHA review. When consensus with the Alliance has been reached, the Coordinator obtains any necessary approvals for the proposal and promptly notifies Alliance participants when the proposal has been approved.
- The Alliance participant submits the draft product to the OSHA Alliance Coordinator.
- The Office of Outreach Services and Alliances (OOSA) completes an initial review and provides comments to the Alliance participant. (Note that this review may be eliminated if OOSA determines that the product is ready for OSHA subject matter expert review.)
- The Alliance participant submits an updated draft, based on the comments received from OSHA.
- OSHA subject matter expert(s) review the product. OOSA forwards any comments to the Alliance participant.
- The Alliance participant submits a final draft.
- OOSA may submit the final draft for review by OSHA's Office of the Assistant Secretary (OAS) in the following limited circumstances:
- the product addresses a high-profile or politically sensitive issue, or
- OOSA has questions about whether the product is consistent with OSHA's priorities and audience/messaging guidelines (see section II B, above, and section IV below).
- In those cases when OAS provides comments, the Alliance participant makes any additional changes as per OAS review and submits an updated final draft.
After final approval of the product:
- The Alliance participant posts the product on its web page. To enable OSHA to link to the products, the Alliance participant must post the product in a format that is in compliance with the federal government's web accessibility guidelines. This generally means that the products must be posted in html or PDF text-based formats, not image-based PDF format. Videos must be close-captioned. After the Alliance participant posts the product, OSHA will add links to the product on OSHA web pages (Alliance and other relevant pages).
- In addition to posting/linking to the products on their web sites, Alliance participants are strongly encouraged to use other means of promotion, such as: 1) promoting or publishing the products through their newsletters, magazines, social media channels and other avenues; 2) distributing print or electronic copies of the products at events; 3) sending email alerts to theirs stakeholders; 4) making the products available to other interested stakeholders for distribution by them; and 5) distributing them through other outreach activities, such as conferences and similar events.
Alliance participants should periodically review completed Alliance products, together with OSHA, to determine if updates are necessary, if the product can be re-issued in a more effective format, such as converting text materials into videos, or if the product should be removed. Products should be reviewed at least every two years (or sooner if warranted, such as issuance of a new/revised OSHA standard addressed in the product). Every two years (or sooner), the Alliance participant(s) and OSHA will review the products and determine whether 1) no updates are necessary, 2) there is a need to update or re-format the product, or 3) the product should be discontinued. Updated products will be counted as an activity under the Alliance. (See flow chart below.)
NOTE: The following guidelines apply to Alliances that conclude after the effective date of these guidelines. OSHA's Office of Outreach Services and Alliances is reviewing its policy for Alliance products developed by Alliances that concluded before the effective date of these guidelines.
After an Alliance concludes, Alliance products are initially still considered Alliance products. Every two years, OSHA expects that the former Alliance participant and the agency will review the products to determine 1) if no updates are necessary; 2) updates are necessary, or 3) that the product should be discontinued.
If the former Alliance participants determine that no updates are necessary, they shall inform OSHA and the product will continue to be an Alliance product (unless OSHA independently determines otherwise). If the former Alliance participant decides to update an Alliance product, OSHA and the Alliance participant will determine how to proceed. In most cases, the product will become an exclusive product of the former Alliance participant, and no longer an Alliance product. In some cases, OSHA may determine that it is worth devoting the resources to review the updates and to have the updated product remain an Alliance product. If the former Alliance participant decides to discontinue a product, they will inform OSHA so the agency can remove the links from its Web site. (See flow chart below.)
In conjunction with the OSHA Alliance Coordinator, Alliance participants should design and implement ways to evaluate the impact of their Alliance products, by means such as post-implementation surveys, audits, impact studies and the like. One example of an Alliances effort to evaluate the impact of their Toolbox Talks can be found at: SWR Institute Toolbox Talks Survey
Required Standard Language
All Alliance products must include the following disclaimer:
Through the OSHA and [insert name of Alliance participant] Alliance, [insert name of Alliance participant] developed this [insert product type] for informational purposes only. It does not necessarily reflect the official views of OSHA or the U.S. Department of Labor. Month/Year
Required Employer Responsibilities and Worker Rights Language
Alliance products must also include the following standard language, or close equivalent, on employer responsibilities and worker rights. This can be included, for example, in a box or section at the end of the product.
Under the Occupational Safety and Health Act, employers are responsible (www.osha.gov/as/opa/worker/employer-responsibility.html) for providing a safe and healthy workplace and workers have rights (www.osha.gov/workers/index.html). OSHA can help answer questions or concerns from employers and workers. OSHAs On-site Consultation Program (www.osha.gov/consultation) offers free and confidential advice to small and medium-sized businesses, with priority given to high-hazard worksites. For more information, contact your regional or area OSHA office (www.osha.gov/html/RAmap.html), call 1-800-321-OSHA (6742), or visit www.osha.gov.
NOTE: The Alliance participant can determine whether to include the parentheticals that spell out the URLs in the standard language above. For example, it may be helpful to have the spelled-out URLs if the product will be printed.
Alliance products should include the Alliance logo and the logo of the Alliance participant. The Alliance logo is available at: OSHA Alliance Program - Alliance Logo.
In addition to making sure that Alliance products use language and vocabulary consistent with their target audiences, OSHA strongly encourages Alliance participants to translate Alliance products into the primary languages of any important segments of the workforce in their industries. The Alliance implementation team should determine if the language(s) of the target workforce makes it a good candidate for translation. Many Alliance products have been translated into Spanish because of the large number of Spanish-speaking workers in the US workforce, but other languages may also be appropriate. Alliance participants can use the OSHA English-to-Spanish dictionaries to help with translation of certain OSHA terms: OSHA Dictionaries - English-to-Spanish and Spanish-to-English.
The following is an outline of the review process for Alliance product translations:
- The Alliance participant submits the draft translation to the OSHA Alliance Coordinator.
- OSHA reviews the translation.
- The Alliance participant makes updates based on OSHA comments and submits an updated draft.
- OSHA gives final approval to the translation.