Is a written risk assessment mandatory in the United States, and how often must it be reviewed?

No general written risk assessment is required by federal OSHA law, so there is no general review interval either. Instead, specific standards require written hazard assessments or programmes, several with fixed review periods, and some State Plans (California in particular) require a written prevention programme for every employer.

Short answer

• Federal law: no equivalent of the EU or Turkish duty to assess all risks in writing.
• PPE hazard assessment (1910.132(d)): required wherever PPE may be needed, certified in writing with the workplace, the certifier's name and the date. No fixed review period; repeat it when the work changes.
• Process safety (1910.119): process hazard analysis revalidated at least every 5 years; compliance audit at least every 3 years.
• Lockout/tagout (1910.147): written energy control procedures, inspected at least annually.
• Silica (1910.1053): written exposure control plan reviewed at least annually.
• States: California requires a written Injury and Illness Prevention Program with scheduled periodic inspections (Title 8, Section 3203), and Washington a written accident prevention program (WAC 296-800-140).

Why there is no general risk assessment duty

The OSH Act is built on two duties: comply with the specific standards, and keep the workplace free from recognised hazards likely to cause death or serious physical harm (the General Duty Clause). Neither requires a documented assessment of all risks. In the EU, Framework Directive 89/391/EEC requires the employer to evaluate all risks, and in Türkiye, Law No. 6331 Art. 10 requires the employer to carry out or commission a risk assessment (risk değerlendirmesi).

In practice, US employers still need to identify hazards to meet the General Duty Clause and to show what they knew. OSHA's voluntary Recommended Practices for Safety and Health Programs list hazard identification and assessment as one of seven core elements, and ISO 45001 certified sites assess risks anyway.

Written assessments and programmes the standards do require

Other standards add written programmes without a fixed review period, for example hazard communication and respiratory protection.

How to document it if you work to EU or Turkish practice

A company used to EU or Turkish risk assessments can keep its method (5x5 matrix, Fine-Kinney or job safety analysis) in the US, but it should also produce the documents OSHA asks for by name. An inspector will look for the PPE certification, the energy control procedures, the HazCom programme and the other items in the table, not for a generic risk register.

Common mistakes

• Writing one generic risk assessment and stopping. OSHA expects the specific documents in the format each standard sets.
• Missing fixed intervals. The 5-year PHA revalidation, the 3-yearly PSM audit and the annual lockout inspection need a calendar, not good intentions.
• Forgetting state rules. California and Washington require a written prevention programme in their core rules, and other State Plans have their own requirements.

Related on excodex

• Occupational safety and health in United States: law, authorities and employer duties
• OSHA written certification of the PPE hazard assessment
• Which facilities are covered by OSHA PSM?
• Lockout/tagout: control of hazardous energy

Standards and further reading

• 29 CFR 1910.132 Personal protective equipment, general requirements: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.132
• 29 CFR 1910.119 Process safety management: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.119
• 29 CFR 1910.147 Control of hazardous energy: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147
• OSHA Recommended Practices for Safety and Health Programs: https://www.osha.gov/safety-management
• California Code of Regulations, Title 8, Section 3203: https://www.dir.ca.gov/title8/3203.html
• Washington Administrative Code 296-800-140, accident prevention program: https://app.leg.wa.gov/wac/default.aspx?cite=296-800-140

This article is general occupational safety and health information prepared by the excodex editorial team. It does not replace the applicable legislation, standards, manufacturers' instructions or the assessment of a competent OSH professional or occupational physician.