Accident Prevention Program - Washington (DOSH)

Every Washington contractor has an Accident Prevention Program. The question an inspector from the Division of Occupational Safety and Health (DOSH) asks is not whether it is on the shelf, but whether it runs every week. Washington's construction standard turns the program into a weekly routine: a crew leader-crew safety meeting, a walk-around safety inspection done jointly by management and an employee the crew elected, and minutes that prove both happened. This Washington Accident Prevention Program Toolbox Talk walks the crew through what WAC 296-155-110 requires — including the meeting you are sitting in right now.

Where the boundary of this talk sits#

This talk covers the written Accident Prevention Program (APP), the safety orientation, the weekly crew safety meeting, and the weekly walk-around inspection. Injury reporting, first-aid requirements, stop-work authority, and task hazard analysis belong to their own talks.

The anchor#

Here is the distinction that carries this whole talk: in Washington the week is the unit of the safety program — at the start of each job and at least weekly after that, the employer must hold a crew leader-crew safety meeting and a walk-around safety inspection made jointly by one member of management and one employee the employees elected, and each meeting must review the last walk-around, any citation, and any accident investigation since the last meeting — so the meeting is not a lecture on a random topic but the place where the week's inspection findings and incidents come back to the crew, with attendance and subjects written down.

Management owns the program#

WAC 296-155-100(1) makes it management's responsibility to establish, supervise, and enforce, in a manner which is effective in practice, a safe and healthful working environment, an accident prevention program, and training programs to improve the skill and competency of all employees. A program that exists only on paper is not "effective in practice."

A written program, tailored to the job#

WAC 296-155-110(2) requires the employer to develop a formal accident prevention program tailored to the needs of the particular plant or operation and to the type of hazard involved. Subsection (4) requires each program to be outlined in written format.

Tailored means a roofing contractor's program talks about roofs. A generic template with a new company name is not tailored.

The safety orientation: seven elements#

Subsection (3) sets the minimum elements for all employers: a safety orientation program describing the employer's safety program and including:

• (a) how, where, and when to report injuries, including the location of first-aid facilities;
• (b) how to report unsafe conditions and practices;
• (c) the use and care of required personal protective equipment;
• (d) the proper actions to take in emergencies, including the exit routes;
• (e) identification of the hazardous gases, chemicals, or materials involved, with instructions on safe use and emergency action after accidental exposure;
• (f) a description of the employer's total safety program; and
• (g) an on-the-job review of the practices needed to perform the initial job assignments safely.

Element (g) is easy to skip. The orientation is not finished in the trailer. It finishes at the work, with someone showing the new worker how to do the first assignment safely.

Crew safety meetings: start of job, then weekly#

Subsection (5) requires crew leader-crew safety meetings at the beginning of each job and at least weekly thereafter, tailored to the particular operation. Subsection (6) says every meeting must address:

• (a) a review of any walk-around safety inspection conducted since the last meeting;
• (b) a review of any citation, to assist in correcting hazards;
• (c) an evaluation of any accident investigations conducted since the last meeting, to decide whether the causes were properly identified and corrected;
• (d) documented attendance; and
• (e) documented subjects discussed.

A topic like this one is fine, but this week's walk-around findings and injuries go on the agenda too.

Minutes: kept on site, kept for a year#

Subsection (7) requires minutes of each crew leader-crew meeting, with a copy kept at the location where the majority of the employees of each construction site report for work each day. Subsection (8) requires the employer to retain the minutes for at least one year and make them available to department personnel on request.

Subcontractors and the prime's meeting#

A note in the rule allows subcontractors and their employees, with the general contractor's permission, to meet the meeting-frequency and tailoring requirements of subsection (5) by attending the prime contractor's crew leader-crew meeting. Anything in subsections (6)(a), (b), (c), and (7) that the prime's meeting does not cover — reviewing the sub's own inspections, citations, and accident investigations, and preparing minutes — stays the responsibility of each individual employer.

Walk-around inspections: management plus an elected employee#

Subsection (9) adds a second weekly duty. At the beginning of each job, and at least weekly thereafter, the employer must conduct a walk-around safety inspection jointly by one member of management and one employee, elected by the employees as their authorized representative. The inspection must be documented, the documentation must be available to the department, and the records must be kept until the job is complete.

The crew chooses that employee, not the foreman, and what they find comes back to the next meeting.

Who is exempt#

Subsection (1) exempts workers of employers whose primary business is not construction, doing only maintenance and repair work, including painting and decorating, but only if the work is on the employer's own premises or facility, the project lasts no more than one week, and the employer complies with the general accident prevention program and safety committee rules in WAC 296-800-140 and 296-800-130. A construction contractor is not exempt.

Washington versus federal#

The federal rule, 29 CFR 1926.20(b), makes it the employer's responsibility to initiate and maintain such programs as may be necessary, and says those programs shall provide for frequent and regular inspections of job sites, materials, and equipment by competent persons the employer designates. It sets no written program elements, no weekly meeting, no minutes, and no employee-elected representative on the inspection. Washington requires all of these.

Where the duty sits#

WAC 296-155-100 makes management responsible for an accident prevention program effective in practice. WAC 296-155-110 sets the exemption (1); a formal, tailored program (2); the seven orientation elements (3); written format (4); meetings at job start and weekly (5); the meeting content, attendance, and subjects (6); minutes on site (7); one-year retention (8); and weekly joint walk-around inspections, documented and kept until job completion (9). For contrast, federal 29 CFR 1926.20(b).

What can go wrong?#

• The APP is a generic template that never mentions the hazards on this job.
• A new hire gets the orientation video but no on-the-job review of the first assignment.
• The weekly meeting covers a canned topic and skips this week's walk-around findings and last Tuesday's injury.
• The foreman picks the employee for the walk-around instead of the crew electing one.
• The minutes are in the home office, not where the crew reports each day.

How do we manage this properly?#

• Tailor the APP — write it for this job's hazards, not any job's.
• Finish the orientation at the work — cover all seven elements, including the on-the-job review.
• Meet at job start and weekly — review the walk-around, citations, and accident investigations.
• Document it — attendance, subjects, and minutes kept on site for at least a year.
• Walk the site weekly — one manager plus the crew's elected representative, written up.
• Subs: close the gaps — if you attend the prime's meeting, cover your own inspections, investigations, and minutes.

Before you start#

Check that you signed in today. Know who your elected walk-around representative is. Ask what the last walk-around found and whether it has been fixed.

Talk it over#

• Who did the crew elect for the walk-around, and when was the last one?
• What did the last walk-around find, and is it fixed?
• Has anyone been hurt or had a near miss since last week's meeting?

The bottom line#

Washington requires a written Accident Prevention Program tailored to the job and a safety orientation with seven elements, ending with an on-the-job review. Crews meet at the start of each job and at least weekly, reviewing the last walk-around, any citation, and any accident investigation, with attendance, subjects, and minutes kept on site for at least a year. Each week, one manager and one employee elected by the crew walk the site together and write it up. The meeting and the walk-around are one loop: find it, fix it, tell the crew.

Frequently asked questions about the Washington Accident Prevention Program#

How often must Washington construction crews hold safety meetings?

At the beginning of each job and at least weekly after that, under WAC 296-155-110(5). Each meeting must review any walk-around inspection, citation, or accident investigation since the last meeting, and attendance and subjects must be documented. Minutes are kept on site and retained for at least one year.

Download the Washington accident prevention program toolbox talk PDF#

Download this Washington Accident Prevention Program Toolbox Talk as a printable PDF in English and Spanish, and use it for this week's crew leader-crew safety meeting.

Related toolbox talks#

• Incident Reporting
• Near Miss Reporting
• Stop Work Authority
• Job Hazard Analysis

Sources#

• Washington State Legislature, WAC 296-155-110 — Accident prevention program ((1) exemption for non-construction maintenance and repair on own premises, one week or less; (2) formal program tailored to the operation; (3)(a)–(g) safety orientation elements; (4) written format; (5) crew leader-crew meetings at beginning of each job and at least weekly; (6)(a)–(e) walk-around, citation, and accident investigation review, attendance and subjects documented; note on subcontractors; (7) minutes kept where most employees report; (8) retained at least one year; (9) weekly joint walk-around by management and an employee-elected representative, documented, kept until job completion; WSR 16-09-085, effective 5/20/16): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-110
• Washington State Legislature, WAC 296-155-100 — Management's responsibility ((1) establish, supervise, and enforce, effective in practice, an accident prevention program and training): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-100
• OSHA, 29 CFR 1926.20(b)(1)–(2) (programs as may be necessary; frequent and regular inspections by competent persons): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.20

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

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