Massachusetts — Workplace Safety

Massachusetts operates an OSHA-approved state plan that covers only state and local government workers. The Massachusetts Workplace Safety and Health Program (WSHP), administered by the Department of Labor Standards, received initial approval from OSHA in August 2022. Private-sector employers and their workers remain under federal OSHA jurisdiction. The state plan requires public employers to comply with federal OSHA standards under 454 CMR 25.00, which incorporates the General Duty Clause and the full set of OSHA safety and health standards (29 C.F.R. Parts 1903, 1904, 1910, 1915, 1917, 1918, 1926, 1928, and 1977).

Source: OSHA Massachusetts State Plan page | 454 CMR 25.00

Public-sector employers in Massachusetts must maintain injury and illness records in accordance with federal OSHA recordkeeping standards under 29 C.F.R. Part 1904, as incorporated by 454 CMR 25.02 and 454 CMR 25.06. The Massachusetts Workplace Safety and Health Program (WSHP) applies the federal recordkeeping framework without substantive modification.

Exemptions from recordkeeping

Employers with 10 or fewer employees at all times during the prior calendar year are partially exempt from OSHA recordkeeping unless the Department of Labor Standards (DLS) or the Bureau of Labor Statistics notifies them in writing to keep records under 29 C.F.R. § 1904.41 or § 1904.42. The 10-employee threshold is measured by peak employment across the entire employer (all establishments combined), not on an establishment-by-establishment basis, under 29 C.F.R. § 1904.1.

Certain low-hazard industries listed in Appendix A to Subpart B of 29 C.F.R. Part 1904 are also partially exempt from recordkeeping. Public-sector employers in those NAICS codes need not maintain logs unless directed in writing by DLS, OSHA, or BLS. Notably, NAICS code 6111 (Elementary and Secondary Schools) appears in Appendix A; this means K-12 public schools are classified as a partially exempt industry, and are therefore not required to maintain OSHA 300 Logs absent written notice from the DLS, OSHA, or BLS. See Appendix A to Subpart B of 29 C.F.R. Part 1904 for the full NAICS listing.

Even when exempt by size or industry, all public-sector employers must still report to WSHP any work-related incident that results in a fatality, an in-patient hospitalization of one or more employees, an employee amputation, or an employee loss of an eye, under 29 C.F.R. § 1904.39 (incorporated via 454 CMR 25.02).

Required forms

Non-exempt public employers must maintain three linked forms:

• OSHA Form 300 (Log of Work-Related Injuries and Illnesses): a running log of all recordable injuries and illnesses, updated within seven calendar days after the employer receives information that a recordable case has occurred (29 C.F.R. § 1904.29).
• OSHA Form 301 (Injury and Illness Incident Report): a detailed incident report for each recordable case; employers may substitute the Massachusetts Department of Industrial Accidents Form 101 or another equivalent form that captures the same information (29 C.F.R. § 1904.29(b)(3); 454 CMR 25.06).
• OSHA Form 300A (Summary of Work-Related Injuries and Illnesses): an annual summary compiled from the Form 300 Log (29 C.F.R. § 1904.32).

Records may be maintained electronically or at a central location, but employers must be able to produce establishment-specific data when requested by DLS.

Annual summary posting requirement

Covered employers must post the completed and certified Form 300A each year from February 1 through April 30 of the year following the calendar year covered by the form (29 C.F.R. § 1904.32(b)(6); 454 CMR 25.02). The form must be posted in a conspicuous location where employee notices are customarily posted, and it may not be altered, defaced, or covered by other materials. Even if zero recordable injuries or illnesses occurred during the year, the employer must complete and post the Form 300A with zeros in the summary columns.

A company executive must certify the Form 300A before posting. Under 29 C.F.R. § 1904.32(b)(3), the certifying official must be an owner, an officer of the corporation, the highest-ranking company official working at the establishment, or the immediate supervisor of that official. The signature certifies that the executive has examined the Form 300 Log and reasonably believes, based on knowledge of the recordkeeping process, that the annual summary is correct and complete.

Retention

The OSHA 300 Log, the 301 Incident Reports, and the 300A Summary (or their approved equivalents) must be retained for five years following the end of the calendar year that the records cover, under 29 C.F.R. § 1904.33 (incorporated via 454 CMR 25.02).

Electronic submission to OSHA

Public-sector employers in Massachusetts under the state plan are not required to electronically upload their OSHA 300A data to the federal OSHA Injury Tracking Application (ITA) website. However, approximately 275 public-sector employers are selected each year to participate in the Bureau of Labor Statistics Annual Survey of Occupational Injuries and Illnesses; those selected are required to respond and submit data from their OSHA 300, 300A, and 301 forms.

Source: 454 CMR 25.00 | Federal Register, 87 FR 51194 (Aug. 18, 2022) | 29 C.F.R. § 1904.1 | 29 C.F.R. § 1904.32 | Appendix A to Subpart B of 29 C.F.R. Part 1904—Partially Exempt Industries | Massachusetts State Plan Information

Massachusetts currently operates its public-sector OSHA state plan under initial (developmental) approval status. On August 18, 2022, OSHA granted Massachusetts initial State Plan approval for covering state and local government employees only. This approval triggered a three-year period during which Massachusetts is required to complete additional developmental steps before the plan can be considered for final approval and full certification under 29 C.F.R. Part 1956 (which governs state plans limited to state and local government workers, setting criteria and procedures for initial and final OSHA approval; see especially §§ 1956.23, 1902.33, and 1902.34).

Initial approval vs. final (certified) status

• Initial approval means the State Plan meets federal criteria sufficient to begin operation but is still subject to federal oversight and ongoing review. Massachusetts’s plan operates under this status as of June 2026.
• Final approval—also called "certification" or an "18(e) determination"—is a formal OSHA decision that a State Plan is at least as effective as federal OSHA in actual operation, has achieved all required milestones, and (for public employees) thus results in state, not federal, enforcement authority. As of June 2026, no final approval or certification has been published for the Massachusetts State Plan.

Current status as of June 2026

• The Federal Register notice granting initial approval (87 FR 51194, Aug. 18, 2022) states “Massachusetts must complete development steps within three years” of the initial approval date for OSHA to consider final approval.
• As of June 2026, there is no published Federal Register notice or entry on OSHA’s primary lists indicating that Massachusetts has achieved final State Plan approval.
• The official OSHA “Approved State Plans” table lists Massachusetts with only its initial (Aug. 18, 2022) approval date and leaves its “Certified” and “18(e) Final Approval” fields blank.

Bottom line: Massachusetts remains under initial (developmental) State Plan approval for public-sector workplace safety. The plan has not received final approval or certification from OSHA as of June 2026.

Source: OSHA—Federal Register Initial Approval (Aug. 18, 2022) | OSHA State Plans Table

Public-sector employers in Massachusetts—including state agencies, municipalities, and public schools—must report serious workplace incidents directly to the Massachusetts Department of Labor Standards (DLS) through the Workplace Safety and Health Program (WSHP), not to federal OSHA. This state-level reporting requirement covers any incident that results in:

• a work-related fatality (report within eight hours);
• the in-patient hospitalization of one or more employees (within 24 hours);
• an employee amputation (within 24 hours); or
• an employee loss of an eye (within 24 hours).

This reporting duty is codified in 454 CMR 25.06(2), which incorporates the corresponding federal trigger and timeframes from 29 C.F.R. § 1904.39, but modifies the recipient: public sector employers must notify the Massachusetts DLS, not federal OSHA. Reports to DLS can be made via phone, email, or any notification method prescribed by the DLS. Forms or further guidance are typically provided on the official WSHP website.

Private-sector employers, by contrast, remain under federal OSHA jurisdiction for all reporting and recordkeeping, and must report these same serious incidents directly to federal OSHA under 29 C.F.R. § 1904.39. (When in doubt about public/private status, see the "State OSHA plan—public-sector coverage only" section above.)

Source: 454 CMR 25.06 Source: Learn about the Massachusetts State Plan

Coverage under the Massachusetts OSHA State Plan is determined by the status of the specific employer and employee—not simply by whether an operation takes place at a public facility.

Who is a "public employer"? Under the Massachusetts State Plan, a "public employer" includes any state agency, county, municipality, public school district, public college or university, and any quasi-public independent authority or entity established by the legislature to serve a public purpose. This definition is clarified in the Federal Register notice of plan approval and is generally interpreted to match M.G.L. c. 149, § 6½. Quasi-publics—such as the Massachusetts Bay Transportation Authority (MBTA) or the Massachusetts Port Authority (Massport)—are therefore covered, as are traditional executive agencies and public universities.

Employee status, not location, controls Coverage follows the specific employer-employee relationship:

• Employees of public agencies/entities (including quasi-publics and public universities) are covered under the Massachusetts Workplace Safety and Health Program (WSHP) and are subject to state standards incorporated at 454 CMR 25.00.
• Private-sector employees—including those who work at or are contracted to a public facility—remain under federal OSHA jurisdiction. This applies even when private contractors perform work for, or within, a public university, school, or building. Their employment relationship is not with a "public employer" for State Plan purposes.

Mixed operations and practical examples:

• A research lab housed at a public university but operated by a private company: the company’s employees answer to federal OSHA; any directly-employed university staff are covered by the State Plan.
• A quasi-public entity, like Massport: covered by WSHP for all its staff, regardless of function, provided they are employed by Massport.
• A private janitorial service contracted to clean a town hall: its employees fall under federal OSHA, not the State Plan, even though their workplace is a public building.

The bottom line: Coverage under the Massachusetts State Plan hinges on the employer's status as a "public employer" and the employee's position, not merely on the public nature or ownership of the job site. Private contractors and vendors, no matter where assigned, remain under federal oversight.

Source: OSHA Federal Register, 87 FR 51194 (Aug. 18, 2022) | Learn about the Massachusetts State Plan (mass.gov)

Massachusetts enforces workplace safety and recordkeeping standards for public-sector employers through the Department of Labor Standards (DLS) via the Workplace Safety and Health Program (WSHP). The relevant rules are codified at 454 CMR 25.00. For recordkeeping and most safety violations, Massachusetts public-sector employers face a penalty regime distinct from federal OSHA's approach (which does not apply to state or local government entities in Massachusetts).

Penalty structure and process Under 454 CMR 25.00, when a public-sector employer (e.g., state agency, municipality, public school district) is found to have violated safety or recordkeeping requirements (including those incorporated from 29 CFR Part 1904), DLS-WSHP typically first issues a Written Warning and Order to Correct. Monetary (civil) penalties are not automatically assessed:

• Civil penalties may only be imposed if a violation is willful, repeated, has caused or could cause serious injury, or if the employer has failed to abate a hazard after being ordered to correct it. This procedure is set by 454 CMR 29.03(1)-(2), which requires notice and an opportunity to cure before fines attach except in cases meeting these higher thresholds.
• Maximum penalty: For all violations subject to penalty, the maximum is $1,000 per violation, as set by 454 CMR 29.04 and referencing the statutory authority at M.G.L. c. 149, §§ 6F½, 6G.

Contrast with federal OSHA Federal OSHA’s penalty framework for recordkeeping violations (under 29 CFR 1904 and 29 CFR 1903.15) allows for substantially higher fines—up to several thousand dollars per violation, adjusted annually for inflation, and does not generally require a written warning or order to abate as a precondition to penalty. Federal OSHA’s schedule is published at 29 CFR 1903 and via annual bulletins. In Massachusetts, this federal schedule applies only to private-sector employers; public employers are subject to WSHP’s state-specific process and penalty cap.

Bottom line: For public-sector employers, the key points of divergence are WSHP’s warning-first approach, higher threshold for fines, and a strict $1,000 per-violation penalty cap under 454 CMR 29.00, in contrast to federal OSHA’s immediate-citation system and much higher penalty ceiling for similar violations.

Source: 454 CMR 25.00 | 454 CMR 29.00 | Learn about the Massachusetts State Plan | OSHA Massachusetts State Plan page

The Massachusetts Department of Labor Standards (DLS), through its Workplace Safety and Health Program (WSHP), enforces the public-sector OSHA plan and is authorized to assess civil penalties against state and local government employers for violations of workplace safety requirements codified at 454 CMR 25.00.

Penalty authority and process

Under 454 CMR 25.00 (public-sector OSHA plan rules) and 454 CMR 29.00 (penalties), the DLS can issue civil penalties for willful, repeated, or unabated violations of state occupational safety rules by public employers, including those that incorporate federal OSHA standards. A civil penalty may only be imposed if the employer commits a willful or repeated violation, fails to correct a cited hazard, or if the violation has caused or could cause serious injury or death. Most first-time violations result in a written warning and order to correct rather than an immediate fine (454 CMR 29.03(1)-(2)).

Maximum penalty amount

For public-sector employers under the Massachusetts state OSHA plan, the maximum civil penalty is $1,000 per violation. This penalty cap is set by 454 CMR 29.04 and is authorized in statute at Mass. Gen. Laws ch. 149, §§ 6F½, 6G. Each instance of a violation may be treated as a separate offense, subject to a separate $1,000 cap. The DLS determines penalty amounts within this cap based on the severity and nature of the noncompliance. By contrast, federal OSHA fines for private employers are much higher (with a separate, annually-adjusted federal cap) but do not apply to Massachusetts public employers.

Bottom line: For violations of the state OSHA plan by a Massachusetts public-sector employer, DLS can levy up to $1,000 per violation after notice and an opportunity to cure, in line with 454 CMR 25.00, 454 CMR 29.00, and authorizing statutes.

Source: 454 CMR 29.00 | 454 CMR 25.00 | OSHA Massachusetts State Plan Federal Register Notice (Aug. 18, 2022) | M.G.L. c. 149, § 6 | M.G.L. c. 149, § 6F½ | M.G.L. c. 149, § 6G

Massachusetts public-sector employers—including state agencies, municipalities, public school districts, and quasi-public entities—must report certain serious workplace incidents directly to the Massachusetts Department of Labor Standards (DLS) through its Workplace Safety and Health Program (WSHP). The timeframes for these reports largely parallel federal OSHA deadlines, but are codified in state regulation and apply to the state, not federal, authority.

Who must report: All public-sector employers covered by the Massachusetts State Plan (see "State OSHA plan—public-sector coverage only" above) must report:

• Any work-related fatality (within eight hours),
• Any work-related in-patient hospitalization of one or more employees (within 24 hours),
• Any work-related amputation (within 24 hours), or
• Any work-related loss of an eye (within 24 hours).

Authority and comparison to federal OSHA: These reporting triggers and deadlines are identical to the federal OSHA requirements for private-sector employers under 29 C.F.R. § 1904.39, but Massachusetts regulation at 454 CMR 25.06(2) specifically requires reporting to DLS rather than OSHA. The regulation incorporates the federal incident types and timeframes verbatim, ensuring consistency between state and federal rules—except that the recipient is the state agency for public employers.

How to report: Reports must be made to the DLS by telephone, email, or by any other method specified by the Department. The DLS may update or supplement acceptable reporting methods on its official WSHP webpage.

Bottom line: For public-sector employers in Massachusetts, the reporting timeframes are: 8 hours for fatalities, 24 hours for in-patient hospitalizations, amputations, or loss of an eye—the same as under federal OSHA, but reported to the DLS (not OSHA).

Source: 454 CMR 25.06(2) Source: 29 C.F.R. § 1904.39

Massachusetts enforces public-sector workplace safety standards under 454 CMR 25.00 and a separate penalty structure spelled out in 454 CMR 29.00, rather than adopting the federal OSHA penalty framework. The Department of Labor Standards (DLS) administers the Workplace Safety and Health Program (WSHP) and is responsible for inspections, enforcement, and penalties involving state and local government employers.

Enforcement process:

• The DLS typically starts with a Written Warning and Order to Correct when it discovers a violation of workplace safety standards. This warning describes the nature of the violation, the standard or rule violated, and sets a correction deadline. Public-sector employers must be given a defined period to correct most violations before any monetary penalty attaches, except in cases of willful, repeated, or serious violations, or when an employer has failed to abate a hazard. This notice requirement is set by 454 CMR 25.05(2)-(3).

Civil citations and penalties:

• If a public-sector employer does not correct the violation (or if the violation is willful, repeated, or causes/could cause serious injury or death), the DLS can issue a civil citation and assess a monetary penalty. Under 454 CMR 29.00, civil penalties are capped at $1,000 per violation. Each separate violation may be penalized individually. These penalties are authorized by statute at M.G.L. c. 149, §§ 6F½ and 6G. The DLS has discretion in assessing penalties within the statutory/regulatory cap, based on the severity and nature of the hazard and employer history.

Federal vs. state penalty framework:

• Federal OSHA penalty schedules (which impose much higher possible fines) do not apply to Massachusetts public-sector employers. The Massachusetts penalty structure—written warnings, capped penalties, and a more remedial approach—is unique to the state plan. Private-sector employers in Massachusetts remain subject to federal OSHA enforcement and penalty rules.

Bottom line: For public employers, Massachusetts mandates a warning-first process, with monetary penalties up to $1,000 per violation, as set by 454 CMR 29.00, rather than the federal OSHA fine schedule.

Source: 454 CMR 25.00 Source: 454 CMR 29.00 Source: M.G.L. c. 149, § 6F½ Source: M.G.L. c. 149, § 6G

Who may file a complaint: Any Massachusetts public-sector employee (state, municipal, public school, or quasi-public authority), or their representative, can file a workplace safety or health complaint with the Department of Labor Standards (DLS) through the Workplace Safety and Health Program (WSHP) if they believe workplace conditions violate occupational safety or health standards. Complaints may be made anonymously.

How to file: Complaints are accepted by email or phone (see the DLS website for current contact information). The complaint should describe the hazardous condition as specifically as possible, giving the employer’s name, location, and details of the issue. The DLS may request additional information but cannot require a complainant to identify themselves. There is no statutory deadline to file a workplace hazard complaint: the regulation at 454 CMR 25.06 is silent on filing timeliness, so complaints may be raised at any time after discovery. DLS investigates credible complaints directly under 454 CMR 25.00, following up with the employer and, if warranted, conducting an on-site inspection.

Whistleblower (retaliation) protection: Massachusetts prohibits retaliation against public-sector employees for making a workplace safety complaint to DLS, participating in an investigation, or exercising related safety rights. If an employee experiences retaliation (such as demotion, suspension, discharge, or any action that would dissuade a reasonable employee from reporting), they must file a retaliation (whistleblower) complaint with DLS within 30 days of the adverse action to preserve their rights. The DLS investigates whistleblower claims under 454 CMR 25.07 and may order remedies if retaliation is substantiated.

Bottom line:

• Any public employee or representative may file a safety complaint with DLS at any time (no deadline specified by regulation).
• For retaliation claims, the complaint must be filed within 30 days of the retaliatory act.

Source: 454 CMR 25.00 Source: WSHP—File a Complaint (mass.gov) Source: 454 CMR 25.07

Massachusetts public-sector employees (state and local) have a regulated—but not unlimited—right to refuse work they reasonably believe exposes them to “imminent danger,” as defined in 454 CMR 25.08. This right is implemented via express adoption of federal OSHA imminent danger procedures under 29 C.F.R. § 1903, but is subject to the conditions and steps spelled out by DLS regulation.

Definition and scope of imminent danger 454 CMR 25.08 defines “imminent danger” as "any conditions or practices in any place of employment which are such that a danger exists which reasonably could be expected to cause death or serious physical harm immediately or before the imminence of such danger can be eliminated through the enforcement procedures." This tracks the federal definition but is a prerequisite—the risk must be both immediate and severe for refusal rights to attach.

Procedures for refusing unsafe work 25.08 incorporates federal procedural steps from 29 C.F.R. § 1903:

• The employee (or representative) must notify the employer of the hazard and ask for correction, if feasible.
• If the employer fails or is unable to correct, and the danger still presents an imminent risk, the employee can refuse to perform only the specific task or operation at issue (not all work).
• The worker should remain at the work location unless ordered to leave by the employer.
• The condition must leave insufficient time to remedy the hazard through regular inspection or enforcement channels.
• The DLS may respond by conducting an inspection or issuing orders, but is not required to investigate each refusal—25.08 authorizes enforcement where warranted based on the report and risk.

Protection against retaliation 454 CMR 25.07 makes it unlawful for a public-sector employer to discharge, discipline, discriminate, or retaliate against an employee for exercising any right under M.G.L. c. 149, § 6½, including refusal of unsafe work under 25.08. Covered acts include reporting hazards, participating in inspections, or refusing work where imminent danger exists under the procedures above. To be protected, a retaliation (whistleblower) complaint must be filed with the Department of Labor Standards not later than 30 days after the adverse action. The DLS has authority to investigate and order relief for substantiated retaliation.

Federal framework—scope of incorporation The right and procedures apply only insofar as incorporated by 454 CMR 25.08; broader OSHA guidance is illustrative but not binding for Massachusetts public employers beyond what the regulation adopts.

Source: 454 CMR 25.08 (imminent danger procedures) Source: 454 CMR 25.07 (anti-retaliation protection) Source: OSHA—Right to Refuse Dangerous Work (federal framework)

Massachusetts received initial approval as a developmental State Plan under Section 18(c) of the OSH Act on August 18, 2022. This means OSHA determined the state's plan for public-sector workplace safety met baseline federal criteria but still required substantial developmental steps—including regulatory adoption, administrative procedures, staffing, and systems development—before being eligible for full certification. This three-year developmental window is detailed in the Federal Register notice at 87 FR 51194, which specifies that Massachusetts must complete its remaining steps "within three years" to qualify for final approval.

Under 29 C.F.R. §§ 1956.23 and 1902.34, "final approval" or certification is a separate administrative determination—OSHA publishes notice in the Federal Register only after the state demonstrates it has fully met developmental requirements and achieved independent operational capability. As of June 16, 2026, OSHA has not issued such a certification or 18(e) final approval notice for the Massachusetts plan. The official OSHA state plans summary table confirms Massachusetts is listed as "Initial Approval" with no certification/final approval date.

While Massachusetts operates its plan and is monitored under the Federal Annual Monitoring Evaluation (FAME) process, the absence of a certification notice means it remains officially in developmental status and subject to federal oversight. Employers and HR practitioners should monitor for updates, as only publication of a final approval (certification) notice signals the completion of all developmental commitments and full handoff of coverage from federal OSHA to the state.

Source: OSHA Federal Register Initial Approval (Aug. 18, 2022) Source: OSHA State Plans Approved Table Source: 29 C.F.R. § 1956.23

Massachusetts requires all public-sector employers—including state agencies, municipalities, public school districts, and quasi-public entities—to report workplace fatalities and certain serious injuries directly to the Department of Labor Standards (DLS) through the Workplace Safety and Health Program (WSHP). This is a core feature of the Massachusetts OSHA State Plan, which covers only public-sector employees (private employers remain under federal OSHA).

Triggering events under the Massachusetts state plan:

• Workplace fatality: Any work-related death must be reported to the DLS/WSHP within 8 hours.
• In-patient hospitalization: The in-patient hospitalization of one or more employees must be reported within 24 hours.
• Amputation or loss of an eye: An amputation or the loss of an eye must also be reported within 24 hours.

These triggers and timeframes are codified at 454 CMR 25.06(2), which expressly incorporates the equivalent federal OSHA requirements from 29 C.F.R. § 1904.39, with the modification that public-sector employers in Massachusetts notify DLS (WSHP) rather than federal OSHA. The report may be made by telephone, email, or any method specified by WSHP. The state agency periodically clarifies preferred reporting methods on its WSHP webpage. (A dry reminder: Always check for updated contact channels on the DLS/WSHP website—methods may change.)

Consequences of non-compliance: Failure to report a covered fatality or serious injury within the required timeframe can result in warnings, corrective orders, or civil penalties up to $1,000 per violation, as set by 454 CMR 29.04.

Bottom line: The reporting duty focuses on timely notification to state authorities: 8 hours for fatalities, 24 hours for in-patient hospitalizations, amputations, or loss of an eye. Public employers should review the WSHP landing page for the most current hotline or email.

Source: 454 CMR 25.06 | 29 C.F.R. § 1904.39 | OSHA Massachusetts State Plan—Federal Register Initial Approval (2022)

Public-sector employers in Massachusetts must comply with federal OSHA standards by operation of the state’s OSHA-approved Public-Sector State Plan enforced by the Workplace Safety and Health Program (WSHP). That Plan incorporates the written-program requirements found in federal OSHA regulations—most prominently hazard communication (29 C.F.R. § 1910.1200), respiratory protection (29 C.F.R. § 1910.134), and lockout/tagout (29 C.F.R. § 1910.147)—including the duty to establish and maintain written programs where the federal rule requires one.

Massachusetts General Laws Ch. 149, § 6½ requires public employers to provide “at least the level of protection” afforded under the federal Occupational Safety and Health Act, encompassing both federal standards and the General Duty Clause (Section 5(a) of the OSH Act; 29 U.S.C. § 654). This duty is implemented by 454 CMR 25.00, which mandates state and local government employers in Massachusetts follow incorporated OSHA standards—including all written program requirements contained within them; the state plan does not overlay additional written-program obligations unique to Massachusetts.

The Department of Labor Standards (through WSHP) does, however, clarify and facilitate compliance by listing model template programs on its “Safety Programs for the Public Sector” page. That resource identifies several written programs as “Required” for public employers—such as Hazard Communication Program, Lockout/Tagout Plan, Respirator Program (for Fire/EMS), Emergency Action Plan, Fire Prevention Plan, and Bloodborne Pathogen Plan—each of which is sourced from a corresponding mandatory OSHA standard. These are not Massachusetts-unique requirements; rather, they reflect the standards already binding under the incorporated federal rule. Public employers should use these templates as a baseline for compliance but should always refer to the text of the controlling OSHA standard and 454 CMR 25.00.

Source: Mass.gov: Safety Programs for the Public Sector Source: 454 CMR 25.00 Source: OSHA Federal Register, 87 FR 51194 (Aug. 18, 2022)