Washington Accident Prevention Program Template for NEMT Companies: The Written Safety Program L&I Requires

A driver strains a shoulder securing a wheelchair on a van floor. A lift platform sticks halfway down at a dialysis center. Another driver sits through a July afternoon in a van whose air conditioning quit an hour ago. Washington’s Department of Labor & Industries (L&I) expects your written accident prevention program to have dealt with each of these before it happens. Under WAC 296-800-140 and 296-800-14005, every employer keeps a program that is in writing, fitted to its own hazards, and carried out in practice.

This template is that program for a NEMT company with a handful of employees. It follows the elements in WAC 296-800-14005, adds the outdoor heat plan from WAC 296-62-095 that has to live inside it, and builds in the reporting and investigation duties of WAC 296-27 and WAC 296-800-320. L&I’s Division of Occupational Safety and Health enforces all of them under the Washington Industrial Safety and Health Act (chapter 49.17 RCW). L&I also publishes a free General Industry sample program, but it runs more than 35,000 words and covers forklifts, asbestos, and spray booths. Use this template for what a NEMT company really does, and borrow from L&I’s sample only where it helps.

How to use this template

1. Count your employees two ways. The most employees on one shift at one location decide whether you need a safety committee or may hold monthly safety meetings (Part 3). Your company’s peak headcount last year decides whether you keep an OSHA injury log.
2. Name who runs safety in Part 1. WAC 296-800-140 makes you responsible to establish, supervise, and enforce the program, so one person needs the time and authority to do it. In a small company that is usually the owner.
3. Walk the work before you write. Ride along on two trips. Watch a lift cycle and a wheelchair securement. Look at the yard and the dispatch desk. Ask each driver what worries them, and let those answers shape Part 4.
4. Fill in Parts 1 to 9. The sample entries are starting points. Change every one that does not match your operation, and delete rows you do not need.
5. Give every employee the Part 2 orientation, current staff once now and new hires before their first ride. L&I’s free checklist, form F417-276-000, covers the same ground if you prefer a printed form.
6. Hold the first safety meeting, or the committee’s first meeting, within 30 days. Safety meetings then run every month, and a committee sets its own schedule. Use the 12-month driver safety meeting calendar for topics.
7. Decide whether the heat plan applies. Add up the minutes a driver spends outdoors in a busy hour. If it passes 15 on days that reach 80 degrees, fill in Part 7.
8. Post and keep. Put L&I’s Job Safety and Health Law poster where employees see it, keep this program where they can read it, and tell them where it is.
9. Review it after any serious injury, when you add a new kind of vehicle or service, and at least once a year. No Washington rule sets a review date for the program itself. The monthly meeting is where the program gets evaluated, and a yearly sit-down keeps it from going stale.

The OSHA injury log, the federal reporting rules, and the poster are in the OSHA guide for NEMT companies. Driver records, driving rules, and crash reviews belong in a fleet safety program, so this program points to one instead of repeating it. Washington’s company licensing, broker contracts, and L&I workers’ comp account are in the Washington guide. If you also run vans in California, that state’s program has a different shape: see the California IIPP template.

The template

Part 1: Program details and who runs it

Field	Entry
Company name
Effective date and version
Person who runs safety and enforces this program: name, title, phone
Who fills in when that person is away
Each place employees report for work (yard, office, dispatch)
Most employees on one shift at one place
How we talk about safety (circle one)	Safety committee / Monthly safety meetings
Where employees can read this program
Approved by the owner: signature and date

Part 2: Safety orientation for every employee

Cover all seven items before the employee’s first ride. Initial each line together.

Required item	What we cover	Initials: trainer and employee
Our total safety and health program	This program, who runs it (Part 1), how safety meetings work, and that no one is punished for raising a safety concern
On-the-job orientation for the first assignments	A ride-along with ______, a lift and securement demonstration, and ______ supervised trips before driving alone
How and when to report an injury, and where first aid is kept	Tell dispatch at once at ______. The first aid kit and spill kit in each van are at ______
How to report unsafe conditions and practices	Call ______ or fill in the hazard form. A hazard at a rider’s home or a clinic goes to dispatch the same day
Use and care of required protective equipment	______ (gloves, eye protection): where each is kept, how to put it on and take it off, how to throw it away, and when to replace it
What to do in an emergency, including how to get out	Van: stop safely, set the brake, get riders out through ______. Yard and office: exits at ______, meeting point at ______. Call 911, then dispatch
Hazardous gases, chemicals, and materials we use, and what to do after an accidental exposure	Our list: ______ (disinfectant, spill kit powder, fuel, washer fluid, rider oxygen cylinders). Safety data sheets are kept at ______

Record each employee’s name and orientation date in Part 8.

Part 3: Safety committee or monthly safety meetings

Whichever method we use in Part 1, each meeting reviews inspection reports, the accident investigations since the last meeting, and this program. It records who attended and what was discussed.

Date	Who attended	Inspection reports and accident investigations reviewed, and whether each cause was fixed	Changes to this program suggested	Subjects discussed

Safety meetings are led by ______, and a member of management attends every one. If we have a committee: employee-elected members ______, employer-selected members ______, elected chair ______, meets ______, minutes kept for one year.

Part 4: Hazards in our work and how we control them

Washington asks for a program tailored to the hazards of your own work. These rows are starting points. Change them to match what happens in your vans.

Hazard	Our controls	Who checks, and how often
Lifts and ramps	Run the lift through a full cycle before the first trip each day and log it (lift log). Stand clear of the platform edge. A lift that sticks or drifts comes out of service until it is fixed
Securing wheelchairs on the van floor	Room to kneel, four tie-downs and a lap and shoulder belt every time, and no rushed securement to make up time
Helping a rider move	No lifting a rider’s full weight by hand. A gait belt to steady, a second person or a stair chair for steps, and the right to stop and call dispatch (safe transfers)
Driving	Seat belts on for everyone. Phones mounted, because holding one while driving is a traffic infraction (RCW 46.61.672). No driver works more than ______ hours without a break. A walk around the van before backing. No alcohol or narcotics at work (WAC 296-800-11025) (phone policy)
Heat at the curb and in the van	Part 7
Blood and body fluids	Part 6
Violence or threats from a rider or a stranger	The driver may stop the trip at a safe place and call dispatch, and calls 911 if anyone is in danger. Dispatch records every incident (difficult passengers)
Slips and trips at homes and clinics	Non-slip shoes, a flashlight in each van, a call ahead about dogs, and a report to dispatch of wet ramps, ice, and dark steps
Oxygen cylinders	Secured so they cannot slide, kept away from heat and flame, no smoking in or near the van (riders with oxygen)
Cleaning and disinfecting products	Use each as its label says, wear the gloves named in Part 2, and keep the safety data sheet where drivers can reach it
Yard, fueling, and office	Lit walkways, a fueling routine, a clear exit, and screen breaks for dispatch

Part 5: Reporting hazards, injuries, and close calls

1. Any employee who is hurt, or who sees a hazard or a close call, tells ______ right away. No one is punished for reporting.
2. Get first aid. Call 911 when in doubt, and never leave the person alone.
3. For a death or an inpatient hospital admission, call L&I within 8 hours at 1-800-423-7233. For an amputation or loss of an eye without admission, call within 24 hours. Do not move the equipment involved unless it is needed to help the person or prevent another injury.
4. If the employee saw a doctor, was hospitalized, or lost work time, report it to L&I’s workers’ comp side right away and help the employee with the claim (employee injury report form).
5. Investigate the same day with the employee’s supervisor and any witnesses.
6. Find the cause, fix it (Part 4), and bring the investigation to the next safety meeting to confirm the cause was found and fixed.

L&I’s free forms F417-277-000 (report of a workplace hazard) and F417-278-000 (report of an injury, illness, or close call) work with these steps.

Field	Entry
Date, time, and place
Employee and what they were doing
Who was present
What happened
Cause found (equipment, training, schedule, or conditions at the stop)
Fix, who does it, and date done
L&I called: date, time, and by whom, if required
Investigated by: our designee, the supervisor, witnesses, and an employee representative
Reviewed at the safety meeting on

Part 6: First aid and blood

Employee trained in first aid	Course and provider	Date	Renew by

A first aid kit and a spill kit ride in every van (first aid kit checklist). Jobs with exposure to blood, decided as if no one wore gloves: ______. Our written exposure control plan is kept at ______ and reviewed every year (exposure control plan template). The hepatitis B vaccine is offered at no cost to every employee with exposure, within 10 working days of first assignment.

Part 7: Outdoor heat exposure plan

This plan is needed when employees work outdoors at 80 degrees or more for more than 15 minutes in any 60-minute period. It is part of this program, written in ______ and in the language our employees understand, and any employee may have a copy.

Required element	Our procedure
Cool drinking water	Cool water in every van, enough for 1 quart per employee each hour, refilled at ______
Shade or another way to cool down, and where	The van with its air conditioning running, or ______. A van in the sun without air conditioning is not shade
Emergency response for signs of heat illness	Relieve the employee from duty, cool them, call 911 with the exact location when needed, and stay with them. Dispatch sends ______
Getting used to the heat	Close observation for a driver’s first 14 days at 80 degrees or more, after any absence of 7 days or more, and on heat wave days
High heat procedures, 90 degrees and above	Paid cool-down rest of 10 minutes every 2 hours at 90 degrees or more, and 15 minutes every hour at 100 degrees or more, unless air conditioning or scheduling keeps exposure under 90
How we closely observe employees	Dispatch calls each driver every ______ minutes, or drivers work in pairs. A phone counts only where reception is reliable
Preventive cool-down rests	Any driver may take a paid cool-down rest whenever they feel the need, and we encourage it
Training	Before the first outdoor shift in heat and every year after, for drivers and for supervisors

Part 8: Training record

Topics: orientation, protective equipment, first aid, bloodborne pathogens (every year), chemical hazards, lift and securement, heat (before outdoor work and every year), and any new vehicle or procedure.

Employee	Date	Subject	Trainer	Employee initials

Part 9: Records and yearly review

Record	How long we keep it	Where
Safety committee minutes	1 year
Safety meeting attendance and subjects	1 year (the rule sets none; this matches committee minutes)
Bloodborne pathogens training records	3 years from the date of the training
Protective equipment hazard assessment certification and training records	______ (the rule sets no period)
Heat training dates	______
Injury investigations (Part 5)	______
OSHA 300 log, 301 reports, and 300A summary, if we must keep them	5 years after the year they cover

We review this program after any serious injury, when we add a new kind of vehicle or service, and at least once a year. Last reviewed on ______ by ______.

What the Washington rules ask for, part by part

WAC 296-800-14005 is short. It asks for a written program tailored to your workplace and the hazards of your operation, and it names two elements: a safety orientation and a safety and health committee. WAC 296-800-14025 adds that the program must be effective in practice, and WAC 296-800-14020 requires training programs with on-the-job instruction before an employee’s job assignment. All three have read the same since December 7, 2018.

Template part	What it covers	Washington rule
Part 1	Who runs the program and enforces it	WAC 296-800-140, 296-800-11035
Part 2	The seven-item safety orientation	WAC 296-800-14005(2)(a)
Part 3	Safety committee or meetings	WAC 296-800-14005(2)(b), 296-800-130, 13020, 13025
Part 4	Hazards tailored to your work	WAC 296-800-14005(1), 296-800-11005, 11010, 14025
Part 5	Reports, investigations, and L&I calls	WAC 296-800-12005, 296-800-320, 296-27-031
Part 6	First aid and blood	WAC 296-800-150, chapter 296-823
Part 7	Outdoor heat plan	WAC 296-62-09530 to 296-62-09560
Part 8	Training	WAC 296-800-14020, 296-800-16035, 296-823-12005, 296-901-14016, 296-62-09560
Part 9	Records	WAC 296-800-13020(3), 296-823-12015, 296-27-02107

• What L&I cites most. In its federal fiscal year 2025, October 2024 through September 2025, the rules L&I cited most outside construction and agriculture began with safety committees and safety meetings, then chemical hazard communication (WAC 296-901-140), protective equipment (WAC 296-800-160), and the accident prevention program itself. First aid (WAC 296-800-150) came seventh. The template covers all five: meetings in Part 3, chemicals and protective equipment in Parts 2, 4, and 8, first aid in Part 6, and the program itself throughout.
• The seven orientation items. The rule’s list is a safety program overview, on-the-job orientation for initial assignments, how and when to report injuries and where first aid is, how to report unsafe conditions and practices, use and care of protective equipment, emergencies including how to exit, and hazardous gases, chemicals, or materials used on the job with the emergency action after accidental exposure. A rider’s oxygen cylinder is a gas to list there.
• Protective equipment. If you require gloves, eye protection, or any other equipment, WAC 296-800-16005 asks you to look for hazards and decide whether protective equipment is needed. WAC 296-800-16010 then requires a written certification that names the workplace, its address, who certified the hazard assessment, the date or dates, and a statement that it is the certification of hazard assessment for protective equipment. WAC 296-800-16035 requires written proof that each employee got and understood the training, with name, date, and subject.
• Chemicals. Employers must keep a written hazard communication program with a list of hazardous chemicals, labels, safety data sheets, and employee training (WAC 296-901-14010 and 14016, with 14010 amended effective February 1, 2026). A consumer product used as its maker intended, with no more exposure than a consumer would get, is exempt (WAC 296-901-14004(6)(i)). Whether a driver’s disinfecting stays within a consumer’s range is a judgment call. A quick wipe once a day may, and a van disinfected after every ride may not. When employees travel between workplaces during a shift, the written program may stay at your primary facility.
• Poster and bulletin board. Post the Job Safety and Health Law poster where employees can easily see it (WAC 296-800-20005). L&I’s page lists the current English-Spanish version as F416-081-909, dated July 1, 2025. The same rule points to L&I’s job injury notice, F242-191-909, dated December 1, 2024. A fixed workplace with eight or more employees also needs a safety bulletin board (WAC 296-800-19005).

Safety committee or monthly safety meetings: which one Washington requires

WAC 296-800-130 asks every employer for a way to raise and evaluate safety issues. Count the employees on your largest shift at one location.

• 11 or more on the same shift at the same location: a safety committee (WAC 296-800-13020). Employee-elected members must equal or outnumber employer-selected ones, and employees picked by a union count as elected. Elected members serve at most one year, with no limit on how many terms, and a vacancy is filled by election before the next meeting. The committee elects its chair and decides how often, when, and where it meets. L&I’s note says meetings should run an hour or less unless a majority votes to extend them. Keep minutes for one year and make them available to L&I’s consultation staff.
• 10 or fewer employees, or 11 or more split across shifts or widely separate locations with 10 or fewer at each: monthly safety meetings (WAC 296-800-13025). A management representative attends, and L&I describes a safety meeting as one that includes all employees, so plan it around your drivers’ schedules. You may meet more often. The only paperwork the rule asks for is who attended and what was discussed.

The five topics are the same for both: inspection reports, the accident investigations since the last meeting and whether their causes were found and corrected, your accident prevention program and ideas to improve it, attendance, and subjects discussed. The rule does not say how to count drivers who start from home. If you are close to 11, ask an L&I consultant and write down the answer. Keep the notes: L&I cited this rule more than any other outside construction and agriculture in its 2025 fiscal year.

Does the outdoor heat rule cover a NEMT van?

Washington’s outdoor heat rule, WAC 296-62-095 through 296-62-09560, has read as it does now since July 17, 2023. It names no season. It applies when employees work outdoors in heat at or above 80 degrees Fahrenheit, or 52 degrees for workers in nonbreathable clothing such as chemical suits, and the exposure is more than incidental. Three tests decide whether your drivers are covered:

• How long are they outside? Exposure is incidental when an employee is not required to work outdoors more than 15 minutes in any 60-minute period, and you may apply that test every hour of the shift (WAC 296-62-09510). The rule counts a work activity outdoors, and loading a rider at the curb fits those words. Two pickups of 8 minutes each in one hour add up to 16. If your pickups run close to the line, ask an L&I consultant how they count curb time.
• Is the van’s temperature managed? WAC 296-62-09520 says work inside vehicle cabs may be considered outdoors if engineering controls do not manage the temperature, and it lists air conditioning as an engineering control. A van with its air conditioning running is managed by an engineering control, so the definition does not make it outdoors. A van with broken air conditioning may be treated as outdoors. The same definitions say a car in the sun is not shade unless it is running with air conditioning.
• Is it 80 degrees or more? If so, the plan in Part 7 must sit inside your accident prevention program, in a language your employees understand, and employees and their representatives can ask for a copy (WAC 296-62-09530).

Three air temperatures change what the rule asks of you.

Air temperature	What the rule adds
80 degrees or more	A written plan, cool water, a way to cool down, paid cool-down rests when needed, close observation of new workers, training
90 degrees or more	Mandatory paid cool-down rest of 10 minutes every 2 hours, and close observation, unless controls keep exposure under 90
100 degrees or more	Mandatory paid cool-down rest of 15 minutes every hour

The details are in the later sections of the rule. When exposure is at or above the trigger, employees must be able to drink at least 1 quart of water an hour, and cool water must be readily accessible at all times (WAC 296-62-09540). You may start a shift with less water if you have a way to refill. Close observation applies for 14 days to employees newly assigned to work at or above the trigger and to those returning after 7 or more days away. It also applies on a heat wave day, meaning a predicted high at or above the trigger and at least 10 degrees above the average high of the previous five days (WAC 296-62-09545).

At 90 degrees or more, watch employees by regular phone or radio contact with anyone working alone, a mandatory buddy system, or another effective means (WAC 296-62-09547). A phone counts only where reception is reliable (WAC 296-62-09550). The 90-degree rest may run at the same time as a meal or rest break required under WAC 296-126-092, and it must be paid unless taken during an unpaid meal period. An employee with signs of heat illness must be relieved from duty and cooled, and watched to see whether medical attention is needed.

Train every employee and supervisor before outdoor work where heat exposure might occur, and at least once a year after that, in a language and manner they understand (WAC 296-62-09560). The rule does not require temperature records. L&I filed a preproposal for a separate indoor heat rulemaking for all industries on August 18, 2026. It has no draft yet, so the outdoor rule is the one that applies to your drivers today.

How soon to report a serious injury to L&I

A serious injury sets off several duties, and the first has the shortest clock.

• Call L&I. Under WAC 296-27-031, effective October 3, 2025, report a work-related death or an inpatient hospital admission within 8 hours. Report an amputation or loss of an eye that does not need admission within 24 hours. Call 1-800-423-7233, which L&I’s reporting page lists with option 1. If you did not know about the event when it happened, the clock starts when you or your agent learn of it. A hospital stay only for observation or testing is not reportable, a death counts only if it happens within 30 days of the incident, and a heart attack at work that kills or hospitalizes an employee is reportable. Have ready your business name, the address and time of the incident, the names and number of employees hurt, a phone contact, and a short description.
• Know where Washington differs from federal OSHA. Federal OSHA allows 24 hours for a hospital admission and excludes a crash on a public street or highway outside a construction work zone (29 CFR 1904.39). Washington’s deadline is 8 hours, and the one transport exception in its rule is an incident on a commercial or public transportation system, such as an airplane, train, subway, or bus (WAC 296-27-031(9)). It does not repeat the public street exception. When a driver is admitted after a crash, call L&I and ask before you assume the report is not needed.
• Keep the scene and help the investigation. After a death, hospital admission, amputation, or loss of an eye, do not move the equipment involved until an L&I representative investigates and releases it, unless moving it is needed to remove victims or prevent further injuries (WAC 296-800-32010). If a lift was involved, leave it as it is until L&I releases it. Assign the supervisor and witnesses to help L&I (WAC 296-800-32015). Run a preliminary investigation with a person you designate, the supervisor, witnesses, and an employee representative, and document it (WAC 296-800-32020 and 32025). The rule’s own list of what to note is where, when, who was present, what the employee was doing, and what happened. Part 5 follows that list.

The workers’ comp report is separate. When an employee has been treated by a physician or nurse practitioner, hospitalized, kept from work, or has died, RCW 51.28.025 requires you to report it to L&I immediately on its forms. It also bars claim suppression, with a penalty of $250 to $2,500 for each offense as the statute reads in October 2026. Washington does not allow private workers’ comp coverage, so most employers buy it from L&I. See workers’ comp for NEMT for classes and premiums.

An employee who reports an injury or a safety concern is protected. RCW 49.17.160 bars firing or discriminating against an employee who files a complaint or uses a right under the act, and WAC 296-27-02113 covers reporting an injury. The employee has 90 days to complain to L&I, which can order reinstatement and back pay with interest of 1 percent a month, plus a civil penalty up to the maximum for a serious violation for a first offense.

On the OSHA injury log: if your company had 10 or fewer employees at all times last calendar year, Washington does not require injury and illness records unless L&I, OSHA, or the Bureau of Labor Statistics says so in writing, though the reporting duty above still applies (WAC 296-27-00103). Washington’s list of exempt industries does not include passenger transportation (NAICS 4859) or ambulance services (6219), so a company that had more than 10 employees at any time last year keeps a log (WAC 296-27-00105). Keep the log, summary, and incident reports 5 years (WAC 296-27-02107). The OSHA guide walks through the forms.

Blood, violence, chemicals, and protective equipment

Blood. Chapter 296-823 WAC applies to any employer with employees who have occupational exposure to blood or other potentially infectious materials, even if no exposure has happened. Its list of typical jobs names employees assigned to give emergency first aid, as a main or a side duty, and hotel and motel employees who clean up blood. The list is only an illustration, and a job missing from it is not outside the rule (WAC 296-823-100). A driver you assign to give first aid is on it by name, and a driver who cleans blood from a van does the same kind of work as those hotel employees. You then need a written exposure determination (11005) and exposure control plan (11010) that you review at least yearly and give an employee within 15 days of a request. You also need training before the task and at least yearly, free and on paid time, in words your employees understand (12005), training records kept 3 years (12015), and the hepatitis B vaccine offered at no cost within 10 working days of assignment, with a signed declination for anyone who refuses (13005). A driver who gives first aid only as a side duty has another route: offer the vaccine within 24 hours after any first-aid incident involving blood, have such incidents reported before the shift ends, and write each one down (13005(5)(b)). The exposure control plan template covers the rest, and the vehicle cleaning checklist covers the cleanup.

Violence. L&I describes chapter 49.19 RCW as requiring health care employers to keep a workplace violence program with policies, training, and incident records. RCW 49.19.010 defines the settings it covers as hospitals, home health, hospice, and home care agencies, evaluation and treatment facilities, behavioral health programs, and ambulatory surgical facilities. Transportation companies are not on the list as of October 2026. L&I is writing a new chapter, 296-830 WAC, to turn the health care duties into rule, and its project page gives no adoption date. Your program must still deal with violence as a hazard if your drivers face it, because WAC 296-800-14005(1) asks for a program tailored to your hazards and RCW 49.17.060 requires a workplace free of recognized hazards that are likely to cause serious injury or death.

First aid. Where no infirmary, clinic, or hospital is in near proximity, someone must be adequately trained to give first aid (WAC 296-800-15005, which adopts 29 CFR 1910.151(b)). Supplies must suit your work and the response time of emergency services, be easy to reach, be in clearly marked containers that are not locked, and be able to travel to an injured worker (WAC 296-800-15020). For a van on the road, that usually means trained drivers. The CPR guide for NEMT drivers covers course choices.

What L&I’s claims data says about van work

L&I’s November 2025 report on ergonomic rulemaking lists risk class 1404, cabulance and paratransit, among the classes whose rate of compensable muscle, tendon, joint, and back injury claims runs at least twice the statewide rate. For 2019 through 2023 it was 8.4 claims per 1,000 full-time workers, 2.1 times the statewide 4.1. That is the kind of injury lifting, transfers, and securement cause, and class 1404-12 is where Washington’s workers’ comp rules place driving passengers with special needs in accessible vans (WAC 296-17A-1404).

This is not a rule. The same report says a ten-year trend points below twice the state rate by 2026, and it leaves class 1404 off L&I’s high-priority list. L&I picked airline ground crews (class 6802) for its first ergonomic rule and fulfillment centers (class 2103) for its second, and the law lets L&I adopt only one new set of ergonomic rules in any 12 months (RCW 49.17.520). L&I publishes a new eligible list every November. Until a rule names your class, the program is where strain injuries get handled: the controls in Part 4, safe transfer methods, and the investigation habit in Part 5.

What L&I can charge, and free help

As of October 2026, the most L&I can assess for a serious violation is the federal maximum or $7,000, whichever is higher (WAC 296-900-14010 and 296-900-14015). The federal maximum in 29 CFR 1903.15(d) is $16,550 for penalties proposed after January 15, 2025, and the Department of Labor cancelled its 2026 inflation increase, so that figure still stands. A willful or repeated violation can cost up to $70,000 under RCW 49.17.180, or up to the federal maximum of $165,514 when the state must match it. A willful violation carries a $5,000 minimum, raised to the federal minimum of $11,823 when the state must match that too. A first general violation, one that would not cause serious physical harm, carries no penalty (WAC 296-900-14010, Table 7).

Adjustments then bring a penalty down for a small company. WAC 296-900-14015 cuts it 70 percent for 1 to 10 employees, 60 percent for 11 to 25, 40 percent for 26 to 100, and 20 percent for 101 to 250. It takes up to 20 percent off for good faith, judged on evidence of a safety program that includes a written accident prevention program, other required written programs, and training, and it adds 20 percent for below-average good faith. Fixing a hazard on the spot, with a lasting fix, takes off 15 percent, unless the violation contributed to a hospitalization or a death. A poor inspection history adds 10 percent. No good-faith or quick-fix reduction applies to a willful, repeat, or failure-to-abate violation.

L&I’s consultation service is confidential and free. Its page says no fines or penalties result from issues found during a consultation, although consultants ask you to correct any serious issues, and it does not schedule one while an inspection is in progress until the citations become final. Ask a consultant to read this program against your actual vans, lifts, and routes. Fill in the program with your own hazards rather than copying any sample word for word, because the rule asks for a program that matches your work and works in practice.