Although federal OSHA doesn't require a safety manual/plan, at least two dozen states do require them including MN, CA, WA, OR, VA. If you are in one of those 24 states, state laws are stricter than federal OSHA concerning written safety plans. Someone mentioned MN. If you are in MN, you were visited by an official from the MN Dept of Labor and Industry and not federal OSHA unless you are a federal facility. MN law requires many employers including "business services" to have a written Workplace Accident and Injury Reduction Program so maybe you're regulated under that category. Check your state rules carefully; sometimes the safety plan rules are put under worker's comp laws.
One of my clients subscribes to the BLR service and they have a generic general safety plan that can be customized.
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