Having a safety program that is completely free of deficiencies is a tall order. Many companies have had programs in place for years without ever reviewing them for completeness, or to ensure that what is outlined in the program is also being practiced in training and in the field/on the production floor.
The professionals at Hettrick, Cyr and Associates have years of experience reviewing programs for all of the federally mandated content. Did you know that in each workplace a PPE Hazard assessment is required for each task or job and that it must be certified by an individual who is competent in the process? Did you know that eaach piece of equipment in your facility must have its own energy control procedure (lockout/tagout) and that those procedures must be reviewed each year to ensure that they are accurate? Did you know that in addition to simply training your employes on the existance of HazCom and GHS, you also must train them on the specifc substances they are working with? These are all specific regulations out of CFR 1910, and these all need to be part of your program.
With the volume of regulations pertaining to a facility, its understandable that there may be some "holes" in any given safety or compliance program.