OSHA requires that PHA recommendations be resolved and that the resolution, including the basis for any rejected recommendation, be documented and communicated to affected employees. Facilities frequently struggle with what constitutes adequate resolution. Is it sufficient to close a recommendation with no action and acceptable risk? Must every recommendation be implemented? What level of documentation is required for rejected recommendations? These letters address the resolution standard, the role of risk ranking in prioritization, and the obligation to communicate outcomes to the workforce.

What OSHA Has Said

Oct 2, 2020
PHA Recommendation Resolution and Documenting Rejected Recommendations
OSHA addresses the documentation standard for recommendations that management decides not to implement. A simple rejected notation is insufficient. OSHA expects documented rationale including the basis for concluding that current safeguards are adequate.
Read OSHA Letter ↗
Oct 31, 1996
Timely Resolution of PHA Recommendations
OSHA clarifies that recommendations must be resolved in a timely manner. Unresolved recommendations from a prior PHA cycle carry over and become compliance findings if the employer cannot show active progress toward resolution.
Read OSHA Letter ↗
Jul 18, 1994
Communication of PHA Findings to Affected Employees
OSHA addresses the requirement to communicate PHA findings and recommendations to employees in the process. This communication must occur promptly after the PHA is complete, not waiting until the next training cycle.
Read OSHA Letter ↗

⚡ Key Compliance Takeaway

Every PHA recommendation must reach a documented resolution, including accept, reject, or defer, with written rationale. Acceptable risk is a valid conclusion but must be supported by documented analysis, not just asserted. Communicate outcomes to the workforce promptly, not at the next annual training.