1.1 This policy ensures the Organization's full compliance with the Occupational Safety and Health Act of 1970 (OSH Act), as amended, and all applicable OSHA standards, regulations, directives, and reporting requirements codified in 29 CFR Parts 1900–1999. The Organization is committed to providing employment and a place of employment that are free from recognised hazards causing or likely to cause death or serious physical harm to employees, as required by Section 5(a)(1) of the OSH Act, known as the General Duty Clause. This policy establishes the framework for meeting OSHA compliance obligations, maintaining required records, training employees, and cooperating with OSHA inspections and enforcement activities. The policy applies to all workplaces, operations, and work activities subject to OSHA jurisdiction.

1.2 This policy applies to all US-based employees, supervisors, managers, and contractors of the Organization, and to all workplaces under the Organization's control, including corporate offices, manufacturing and production facilities, warehouse and distribution centres, construction and field operation sites, and any other locations where Organization employees perform work. Where the Organization operates in states with OSHA-approved State Plans that impose additional or more stringent requirements than federal OSHA standards, the Organization shall comply with the applicable State Plan requirements. The safety team shall maintain a current list of all applicable federal and state OSHA standards relevant to the Organization's operations and shall update the list whenever the Organization expands into new states or new types of work activities.

1.3 The Organization shall appoint a qualified Safety Director, holding at minimum a Certified Safety Professional (CSP) or Associate Safety Professional (ASP) credential, who shall be responsible for overseeing OSHA compliance across all Organization operations. The Safety Director's responsibilities shall include developing, implementing, and continuously improving the Organization's safety and health program, ensuring compliance with all applicable OSHA standards and the General Duty Clause, managing OSHA recordkeeping and reporting obligations under 29 CFR Part 1904, coordinating employee safety training programs, serving as the Organization's primary liaison with OSHA during inspections, consultations, and correspondence, and reporting to the executive leadership team on safety performance, compliance status, and improvement initiatives at least quarterly.

2.1 The Organization shall conduct a comprehensive review of its operations, processes, materials, and equipment to identify all applicable OSHA standards and shall implement the safety programs, engineering controls, administrative procedures, and personal protective equipment requirements specified in those standards. Key areas of compliance shall include Hazard Communication (29 CFR 1910.1200) including Safety Data Sheets and chemical labelling, Personal Protective Equipment (29 CFR 1910 Subpart I) including hazard assessment and PPE selection, Electrical Safety (29 CFR 1910 Subpart S), Fire Protection (29 CFR 1910 Subpart L), Walking-Working Surfaces (29 CFR 1910 Subpart D), Machine Guarding (29 CFR 1910 Subpart O), and any industry-specific standards applicable to the Organization's operations. The safety team shall maintain a compliance matrix mapping each applicable standard to the Organization's current compliance status and responsible personnel.

2.2 The Organization shall develop, implement, and maintain written safety programs as required by applicable OSHA standards. These programs shall include, at minimum, a Hazard Communication Program with a written plan, chemical inventory, Safety Data Sheets, and employee training; a Respiratory Protection Program (29 CFR 1910.134) where respiratory hazards are present; a Lockout/Tagout Program (29 CFR 1910.147) for the control of hazardous energy; a Confined Space Entry Program (29 CFR 1910.146) where permit-required confined spaces exist; a Bloodborne Pathogens Exposure Control Plan (29 CFR 1910.1030) where occupational exposure is possible; and any other written programs required by applicable standards. All written programs shall be readily accessible to employees at each applicable workplace, shall be reviewed and updated at least annually, and shall be revised whenever changes in operations, equipment, or standards necessitate updates.

2.3 In addition to compliance with specific OSHA standards, the Organization shall comply with the General Duty Clause of the OSH Act, Section 5(a)(1), by identifying and abating recognised hazards in the workplace that are causing or are likely to cause death or serious physical harm to employees, even where no specific OSHA standard addresses the hazard. The safety team shall monitor OSHA enforcement trends, National Emphasis Programs, and hazard alerts to identify recognised hazards relevant to the Organization's operations. Examples of General Duty Clause hazards that shall be proactively addressed include workplace violence, ergonomic hazards causing musculoskeletal disorders, heat illness in indoor and outdoor work environments, and combustible dust accumulations. Where a recognised hazard is identified and no specific standard exists, the Organization shall implement feasible controls to eliminate or minimise the hazard based on industry best practices, OSHA guidance documents, and consensus standards.

3.1 The Organization shall comply with all OSHA recordkeeping requirements under 29 CFR Part 1904. The safety team shall maintain accurate and complete records of all recordable work-related injuries and illnesses on OSHA Form 300 (Log of Work-Related Injuries and Illnesses), OSHA Form 300A (Summary of Work-Related Injuries and Illnesses), and OSHA Form 301 (Injury and Illness Incident Report), or equivalent approved state forms. The OSHA 300A annual summary shall be certified by a company executive and posted in a conspicuous location at each establishment from February 1 through April 30 of each year. Records shall be retained for a minimum of 5 years following the end of the calendar year that they cover. The safety team shall ensure that recordable injuries and illnesses are properly classified using OSHA's recording criteria and that all required fields are completed accurately and contemporaneously.

3.2 The Organization shall report to OSHA any work-related fatality within 8 hours of the Organization learning of the event, and any work-related in-patient hospitalisation, amputation, or loss of an eye within 24 hours of the Organization learning of the event, as required by 29 CFR 1904.39. Reports shall be made by telephone to the nearest OSHA Area Office, by telephone to the OSHA hotline at 1-800-321-OSHA (6742), or electronically through OSHA's online reporting system. The Safety Director or their designee shall be responsible for making timely reports and shall maintain documentation of all reports submitted, including the date, time, method, and content of the report. Failure to report within the required timeframes is a citable violation. The safety team shall establish an internal notification protocol to ensure that the Safety Director is immediately informed of any event that may trigger OSHA reporting obligations.

3.3 The Organization shall comply with OSHA's electronic recordkeeping submission requirements under 29 CFR 1904.41. Establishments with 250 or more employees in the previous calendar year that are required to keep OSHA injury and illness records shall submit Form 300A data electronically through OSHA's Injury Tracking Application (ITA) by the annual deadline of March 2. Establishments with 20 to 249 employees in designated high-hazard industries listed in Appendix A to Subpart E shall also submit Form 300A data. The Safety Director shall verify the accuracy of all data before submission and shall maintain a copy of the submitted data for the Organization's records. Additionally, establishments meeting the higher threshold of 100 or more employees in designated high-hazard industries shall submit Forms 300 and 301 data as required by the updated reporting rule. The safety team shall monitor OSHA rulemaking for any changes to electronic reporting requirements and shall adjust compliance procedures accordingly.

4.1 The Organization shall cooperate fully with OSHA compliance inspections conducted at its workplaces. Upon arrival of an OSHA Compliance Safety and Health Officer (CSHO), the front desk or security shall immediately notify the Safety Director and the legal department. The Safety Director or a designated management representative shall participate in the opening conference, accompany the CSHO during the workplace walkthrough, observe all sampling and monitoring activities, and participate in the closing conference. The management representative shall take detailed notes during the inspection, including areas inspected, documents reviewed, photographs taken, employees interviewed, and any concerns raised by the CSHO. The Organization shall not refuse entry to an OSHA inspector but reserves the right to require the inspector to obtain an administrative warrant if there is no valid consent, employee complaint, or other basis for entry. All inspection-related documents, correspondence, and citations shall be maintained by the legal department.

4.2 The Organization recognises and supports employees' rights under the OSH Act, including the right to report workplace safety and health concerns to OSHA without fear of retaliation, the right to request an OSHA inspection if they believe imminent danger or a serious hazard exists, the right to participate in OSHA inspections as an authorised employee representative, the right to access their OSHA injury and illness records and exposure monitoring data, the right to request a Health Hazard Evaluation from NIOSH, and the right to refuse work that they reasonably believe poses an imminent danger of death or serious injury when there is insufficient time to seek OSHA intervention. The Organization shall not discharge, discipline, or discriminate against any employee for exercising their rights under the OSH Act. Any allegation of retaliation shall be investigated by the HR department under the Organization's anti-retaliation policy, and substantiated claims shall result in appropriate corrective action and remedies for the affected employee.

4.3 If the Organization receives an OSHA citation for any violation, the citation and any accompanying penalty notification shall be posted at or near the location of the violation for 3 working days or until the hazard is abated, whichever is longer, as required by 29 CFR 1903.16. The Safety Director shall immediately convene a citation response team comprising safety, operations, legal, and HR personnel to review the citation, evaluate the merit of each alleged violation, develop and implement corrective actions within the specified abatement period, prepare abatement certification documentation, and advise the executive leadership team on whether to accept the citation, seek an informal settlement conference, or file a formal contest with the Occupational Safety and Health Review Commission within the 15-working-day contest period. The Organization shall track all citations, penalties, and abatement actions in its safety management system, and shall analyse citation trends to identify systemic compliance gaps requiring program-level improvements.

5.1 The Organization shall provide all safety training required by applicable OSHA standards in a language and vocabulary that employees can understand, as mandated by multiple OSHA standards and reinforced by OSHA enforcement policy. Training shall be provided at the time of initial assignment, when new hazards are introduced, when employees are assigned to new tasks, and at the intervals specified by each applicable standard. At minimum, employees shall receive training in Hazard Communication including chemical hazards and Safety Data Sheet access, proper selection, use, and maintenance of Personal Protective Equipment, emergency action and fire prevention plans, Lockout/Tagout procedures for authorised and affected employees, and any other topic-specific training required by applicable standards. All training activities shall be documented with the date, topic, trainer name and qualifications, attendee names and signatures, and a summary of the content covered. Training records shall be retained for the period specified by the applicable standard or for 3 years, whichever is longer.

5.2 This policy shall be reviewed at least annually by the Safety Director in consultation with the legal department, the Safety Committee, and external safety consultants as appropriate. The review shall consider new or revised OSHA standards, directives, and enforcement guidance, OSHA National Emphasis Programs and regional enforcement priorities, findings from OSHA inspections, internal audits, and self-assessments, changes to the Organization's operations, processes, equipment, or locations, industry trends in OSHA enforcement actions and penalties, and recommendations from the Organization's insurance carrier and risk management advisors. Proposed amendments shall be approved by the Chief Operating Officer and Chief Executive Officer before implementation. The Organization shall also monitor proposed OSHA rulemaking and participate in public comment periods when proposed standards may significantly affect Organization operations or compliance obligations.