Employee participation is the first element of OSHA's Process Safety Management standard and sets the tone for your entire program. Under 29 CFR 1910.119(c), employers must develop a written plan of action for employee involvement in PSM and provide workers with access to process safety information. This guide walks you through building a compliant employee participation program that goes beyond checking a box to genuinely engage your workforce in process safety. Ecesis PSM software supports employee participation through mobile access, training delivery, and incident reporting tools.
What OSHA Requires
Under 29 CFR 1910.119(c), employers must:
- Develop a written plan of action regarding the implementation of employee participation
- Consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements of process safety management
- Provide employees and their representatives access to process hazard analyses and to all other information required to be developed under the PSM standard
Step-by-Step Implementation
Write the Employee Participation Plan
The written plan of action is the foundational document OSHA auditors will ask for first. It does not need to be lengthy, but it must clearly define:
- How employees will be consulted on PHA development and other PSM elements
- How employees can access PHAs and other PSM information
- Specific participation mechanisms (safety committees, suggestion programs, PHA team membership, incident investigation roles)
- How the employer will communicate PSM-related decisions and changes to affected employees
Date the plan, identify the responsible parties, and review it at least annually to ensure it reflects current practices.
Establish Participation Mechanisms
The written plan needs to be backed by real mechanisms that enable meaningful participation. Effective approaches include:
- PHA team membership: Include operators and maintenance personnel who work directly with covered processes on every PHA team
- Safety committees: Form or expand safety committees to include PSM-specific agenda items with documented meeting minutes
- Hazard reporting: Implement a system for employees to report process safety concerns, near misses, and improvement suggestions with feedback on actions taken
- Incident investigation: Include frontline employees on investigation teams, especially for incidents involving their work areas
- Procedure reviews: Involve operators in the annual review and certification of operating procedures
Provide Information Access
OSHA requires that employees have access to PHAs and all other PSM information. This does not mean posting everything on a bulletin board, but it does mean employees can request and receive information in a reasonable timeframe. Practical approaches include:
- Making PSI, PHAs, operating procedures, and incident reports available through a centralized software platform or document management system
- Providing electronic access through workstation kiosks or mobile devices in process areas
- Maintaining a physical location where hard copies can be reviewed on request
- Documenting how employees are informed about their right to access this information
Document and Track Participation Activities
Maintain records that demonstrate active employee participation, not just a plan on paper. Track and document:
- Safety committee meetings with PSM agenda items and attendee lists
- Employee participation on PHA teams (names, dates, roles)
- Hazard reports submitted and employer responses
- Procedure review participation
- Incident investigation team composition including employee representatives
This documentation becomes critical evidence during OSHA audits and compliance reviews.
Common Pitfalls to Avoid
How Software Supports This Element
Employee participation thrives when workers have easy access to information and simple tools for engagement. Ecesis PSM software supports this element through:
- Mobile EHS app: Employees can report incidents, submit hazard observations, complete safety forms, and access PSM documents from any location
- Document management: Centralized document storage with role-based access ensures employees can view PHAs, procedures, and safety information when needed
- Training delivery: App-based training on PSM awareness and employee rights keeps the workforce informed and engaged
- Task tracking: Action items from safety committees and PHA reviews are assigned, tracked, and documented to completion
Frequently Asked Questions
What must be in a written employee participation plan?
The plan must describe how employees will be consulted on PHAs and other PSM elements, how they can access PSM information, and what specific participation mechanisms are in place. It should identify responsible parties and be dated and periodically reviewed.
Do contractors need to participate in the employee participation element?
The employee participation element under 1910.119(c) applies to the employer's own employees. However, contractors working on covered processes have separate requirements under 1910.119(h) for training and information access. Many facilities extend participation opportunities to contract employees as a best practice.
Can employees refuse to participate in PSM activities?
Employers must develop the plan and provide opportunities for participation, but individual employees cannot be forced to serve on PHA teams or safety committees. However, employers should document that opportunities were made available and encourage voluntary participation.
How often should the participation plan be reviewed?
OSHA does not specify a review frequency for the participation plan, but best practice is to review it annually alongside your compliance audit cycle to ensure it reflects current practices and workforce changes.
What is the most common OSHA citation for this element?
The most frequent citation is either the absence of a written plan entirely, or having a plan that exists on paper but cannot be supported with evidence of actual employee participation activities such as PHA team involvement, safety committee minutes, or documented information requests.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
