The Sample Abatement Plan or Progress Report form is explicitly nonmandatory and provided only as a template employers may use. See the Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) which labels the form "Nonmandatory." You can use this template as-is or submit abatement documentation in another format that meets OSHA's requirements under Part 1903.
The abatement plan or progress report should include the inspection number, citation number(s), item number(s), line-item actions, proposed completion dates (for abatement plans) or actual completion dates (for progress reports), and a date required for final abatement, plus an attesting signature and contact information. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) shows these fields and the required attestation/signature block. Employers must provide sufficient documentation to show abatement as required under 1903.19.
Yes—abatement plans or progress reports for multiple citation items may be combined in one submission only when the abatement actions and the proposed or actual completion dates are the same for each cited item. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) includes a specific note stating this rule. If actions or dates differ, prepare separate entries or separate plans so each item’s abatement is clear.
Checking "Abatement Plan" indicates you are providing proposed abatement actions and proposed completion dates, whereas checking "Progress Report" indicates you are reporting actual completion dates for actions already taken. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) shows separate columns for "Proposed Completion Date (for abatement plans only)" and "Completion Date (for progress reports only)." Employers should use the correct column so OSHA can easily verify planned versus completed abatement under 1903.19.
An authorized representative of the employer must sign the form and attest that the information is accurate; the template contains a signature block and space for a typed or printed name. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) includes this attestation and signature requirement. Providing a signed attestation supports OSHA’s verification process under 1903.19.
You should put the Area Director and the U.S. Department of Labor – OSHA Area Office address exactly as shown on the citation at the top of the form. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) shows the header line "(Name), Area Director U. S. Department of Labor – OSHA Address of Area Office (on the citation)" so the submission is routed to the OSHA office that issued the citation, consistent with procedures in Part 1903.
OSHA will normally require employers to submit documentation of abatement and will initiate on-site follow-up inspections only if the documentation is not submitted or is inadequate; however, OSHA also conducts on-site follow-up inspections for High Gravity Citation Cases as part of an Enhanced Enforcement Policy. The Enhanced Enforcement Policy (Mar. 12, 2003) explains that OSHA typically asks for abatement documentation under 1903.19 and will do on-site follow-ups when documentation is lacking or in High Gravity cases.
You record your required final abatement date in the blank labeled "Date required for final abatement" near the bottom of the template. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) provides this specific field so OSHA and the employer have a clear target for final abatement while complying with 1903.19.
List each discrete action or sub-step on its own line under the item’s action section and give a proposed or actual completion date for each line as appropriate. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) shows multiple rows beneath each numbered item so you can break complex abatement into separate steps. This level of detail helps OSHA verify abatement under 1903.19.
Including the name and telephone number of a primary point of contact is optional on the template but recommended so OSHA can follow up quickly. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) shows an optional space for "Name of primary point of contact for questions" and "Telephone number." Providing a contact helps OSHA verify abatement efficiently under 1903.19.
If an employer properly files a notice of contest, the obligation to abate the specific cited condition and to pay penalties is generally suspended until the matter is adjudicated or settled; therefore, employers normally do not have to submit an abatement plan for contested items while the contest is pending. The Policy on contesting citations (Sept. 11, 2023) explains that abatement obligations for contested citations are suspended pending adjudication, and the Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) is therefore not normally used for items under a proper contest. Note, however, OSHA reserves authority to act when there is an imminent danger or other circumstances that warrant action while the contest is pending.
You should enter the exact inspection number and the citation number(s) exactly as shown on the OSHA citation at the top of the form so the submission ties directly to the cited items. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) includes labeled blanks for "Inspection Number" and "Citation Number(s)" to ensure accurate tracking during verification under 1903.19.
Yes—use the template as a progress report to document partial or completed steps by filling the "Completion Date (for progress reports only)" column for actions already finished and leaving proposed dates for remaining actions. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) is designed for either abatement plans or progress reports to show status, which OSHA will use to verify abatement under 1903.19.
OSHA may prioritize follow-up inspections at other sites of the same overall corporate employer when the originating establishment was the subject of a High Gravity Citation Case; follow-up inspections at other establishments may occur after the citations become final orders. The Enhanced Enforcement Policy (Mar. 12, 2003) explains that OSHA will normally conduct follow-up inspections for High Gravity cases and may inspect other establishments of the same employer to verify abatement and similar violations, in addition to relying on documentation submitted under 1903.19.
Yes—clearly list each action with a short plain-language description and include a concrete date format (month/day/year) for proposed or actual completion so OSHA can verify abatement without follow-up. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) provides columns for actions and dates; using clear, specific descriptions and unambiguous dates speeds verification under 1903.19.
Yes—reference supporting documents (e.g., invoices, photos, certifications) by naming the attachment and indicating the attachment number or page so OSHA can match the evidence to the action line. While the Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) is a simple template, including labeled attachments and cross-references helps OSHA verify abatement under 1903.19.
If your abatement timeline changes, submit a revised abatement plan or a progress report that clearly identifies the change, the reason, and new proposed or actual completion dates so OSHA has an updated record. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) is intended to document status and changes; timely and accurate updates support OSHA’s verification obligations under 1903.19.
OSHA generally will not issue an additional citation for the exact same condition, equipment, and location while the original citation is under contest, but OSHA reserves the right to take enforcement action if necessary to protect workers, including seeking relief for imminent danger. The Policy on contesting citations (Sept. 11, 2023) explains that obligations for abatement and penalties are typically suspended during a properly filed contest and OSHA normally will not issue duplicate citations, though it may act in urgent circumstances; see also documentation expectations under 1903.19.
Yes—the template can still be used to document abatement for citations tied to a specific inspection or inspection number regardless of establishment type; however, ensure the form lists the correct inspection number and address information as shown on the citation. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) provides fields for inspection and citation numbers so abatement documentation can be linked to the inspection record kept under Part 1903. For guidance on recordkeeping across multiple work locations, see related recordkeeping interpretations in OSHA guidance materials.
No—the template is nonmandatory and employers are not required to use the exact layout; the key requirement is to provide clear, accurate documentation of the actions taken and dates so OSHA can verify abatement. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) is offered as a convenient format, but employers may submit equivalent documentation that meets the verification needs described in 1903.19.
Yes—abatement plans should describe administrative controls (for example, the training to be performed, dates, and responsible persons) with the same specificity as engineering fixes so OSHA can verify the abatement measures were implemented. The Sample Abatement Plan or Progress Report (Nonmandatory) (1903.19 App B) supports listing actions and dates for any type of abatement, and clear documentation of administrative measures helps OSHA verify abatement under 1903.19.
If the abatement documentation submitted is incomplete or unclear, OSHA may request clarifying information or initiate an on-site inspection to verify abatement; the agency’s field guidance notes that documentation must be adequate and if not, on-site verification may follow. The Enhanced Enforcement Policy (Mar. 12, 2003) explains OSHA typically relies on abatement documentation under 1903.19 but will perform an on-site inspection if documentation is missing or inadequate.