Create a comprehensive Lone Worker Policy compliant with the OSHA General Duty Clause §5(a)(1), 29 CFR 1910.38 emergency action plans, and state OSHA requirements. Covers lone worker definitions, risk assessments, communication procedures, check-in systems, prohibited activities, training requirements, and emergency response protocols.
What Is a Lone Worker Policy?
A Lone Worker Policy is a formal written document that establishes an employer's procedures for protecting employees who work alone or in isolation without close or direct supervision. The policy defines lone working within the organization, identifies the associated hazards, describes risk assessment and control measures, establishes communication and check-in procedures, specifies prohibited activities, sets out training requirements, and details emergency response protocols.
In the United States, there is no single OSHA standard dedicated exclusively to lone workers. However, the OSHA General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (29 U.S.C. 654), requires every employer to furnish a place of employment free from recognized hazards that are causing or are likely to cause death or serious physical harm. This obligation applies equally to employees who work alone. OSHA has used the General Duty Clause to cite employers who fail to protect lone workers from foreseeable hazards, particularly in cases involving workplace violence.
Several specific OSHA standards are directly relevant to lone working. The Emergency Action Plans standard (29 CFR 1910.38) requires employers to develop emergency procedures that account for all employees, including those working alone. The Permit-Required Confined Spaces standard (29 CFR 1910.146) explicitly requires the presence of an attendant and rescue team, making confined space entry a prohibited lone working activity. The Control of Hazardous Energy standard (29 CFR 1910.147) may require multiple workers for certain lockout/tagout procedures.
States with approved OSHA state plans may impose additional requirements. For example, Cal/OSHA in California has enacted a workplace violence prevention standard (Labor Code Section 6401.9) that requires employers to develop and implement a workplace violence prevention plan, which is particularly relevant for lone workers who interact with the public.
When Do You Need a Lone Worker Policy?
A Lone Worker Policy is needed by any employer whose employees work alone or in isolation for any period of time. This includes a wide range of industries and job functions, from field service technicians and property inspectors to night security guards, delivery drivers, home health aides, utility workers, and agricultural workers.
The policy is particularly critical in industries where lone workers face elevated risks. These include healthcare and social services (home health visits), utilities and telecommunications (field technicians), property management and real estate (property inspections), transportation and delivery (commercial drivers), security services (overnight patrols), construction and maintenance (remote site work), and agriculture (farm workers in remote areas).
The policy should be established before any employee begins lone working and should be reviewed at least annually. It must also be reviewed following any incident involving a lone worker, any material change to lone working activities, any organizational change that affects lone working, or any change in applicable OSHA requirements or state regulations.
OSHA inspectors may request to see the employer's lone worker procedures during an inspection, particularly following a workplace injury involving a lone worker. Having a written policy with documented risk assessments, communication procedures, and training records demonstrates compliance with the General Duty Clause and provides important protection in enforcement proceedings.
What to Include in Your Lone Worker Policy
A comprehensive Lone Worker Policy must address several essential elements to comply with OSHA requirements and protect employees who work alone.
The scope and definition section should clearly define what constitutes lone working within the organization and identify all job roles and activities that involve lone working. The definition should encompass fixed-location lone working (such as night shift security), mobile lone working (such as field technicians), and remote or isolated lone working.
The risk assessment section should document the results of a job hazard analysis for each lone working activity, identifying the specific hazards and the control measures implemented. Under the General Duty Clause, the employer must demonstrate that recognized hazards have been identified and addressed.
Communication and check-in procedures are essential. The policy should specify the communication equipment provided, the check-in frequency and method, the designated emergency contact, and the escalation procedure when a lone worker fails to check in. Emergency procedures should address how lone workers report emergencies, the OSHA reporting requirements under 29 CFR 1904.39, and post-incident support.
Prohibited activities must be clearly listed. Certain OSHA standards, including 29 CFR 1910.146 for confined spaces and 29 CFR 1910.147 for lockout/tagout, require multiple workers and are therefore prohibited for lone workers.
Training requirements should describe the content and frequency of lone worker safety training, including hazard recognition, communication device operation, personal safety techniques, and emergency response. Responsibilities should be clearly assigned to senior management, supervisors, and individual employees. The policy review schedule and policy owner should be identified.