Background

The Program features three progressive steps: Introductory, Intermediate, and Advanced, each building on the prior step. At each step, employers are expected to achieve specific goals and complete defined actions across seven elements OSHA believes are critical to a successful safety and health culture: (1) management leadership; (2) worker participation; (3) hazard identification and assessment; (4) hazard prevention and control; (5) education and training; (6) program evaluation and improvement; and (7) communication and coordination for host employers, contractors, and staffing agencies. Participants use a Safety Champions Tracker to monitor their progress through each step. Notably, participants must continue meeting criteria from previously completed steps as they progress through the Program.

Below is a summary of what OSHA expects employers to accomplish during each step in the Program.

• Introductory step – Employers focus on foundational actions like developing written safety and health policies, establishing safety committees, creating initial hazard inventories, and building training plans.
• Intermediate step – Employers implement the programs developed in the Introductory step, increase worker involvement, conduct regular hazard inspections at least semi-annually, and provide refresher training.
• Advanced step – Employers are expected to demonstrate mature, fully integrated safety and health programs with continuous improvement processes, routine self-inspections at least monthly, and annual trend analyses of safety and health data.

Role of Special Government Employees

Participants can work through the Program independently or with the assistance of an SGE assigned by OSHA. SGEs may review safety and health program documentation, provide feedback on progress, and answer questions on an as-needed basis. When a participant believes it has completed all actions within a step, OSHA will assign an SGE to conduct a formal review. The SGE may then recommend the participant for step completion or identify areas where further progress is needed.

Implications for employers

Though employers may view the Program with a healthy dose of skepticism, the Program represents a shift in OSHA’s posture toward employer engagement. Employers should consider whether participation, or even informal use of the Program framework as a self-assessment benchmark, could help improve their safety and health program performance and compliance posture. The structured, step-based approach may be particularly useful for organizations looking to formalize safety practices, engage workers in safety initiatives, and build a documented track record of continuous improvement. Also, because of the Program’s step-by-step approach, employers should participate in the Program only if they are focused on continuous improvement of their safety and health programs.

The Program operates separately from OSHA’s enforcement activities, and OSHA has made clear that participation has no impact on any enforcement activity or determination. Though a strong safety program may reduce the risk of workplace incidents that may trigger an inspection, employers should not participate in the Program with the expectation that it will shield them from an OSHA inspection or citations. 

Additional resources on the Safety Champions Program are available on OSHA’s dedicated webpage.

Client Alert 2026-70