Construction Safety

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Course Learning Outcomes for Unit III

Upon completion of this unit, students should be able to:

2. Apply Occupational Safety and Health Administration standards and related practices to construction. 2.1 Identify standards that align with safety oversight functions at construction sites. 2.2 Illustrate the requirements for a valid OSHA citation under the General Duty Clause of the OSH

Act. 2.3 Describe OSHA’s workplace inspection priorities and procedures.

3. Describe the Occupational Safety and Health Administration’s multi-employer worksite policy. 3.1 Determine the four employer classifications under the multi-employer worksite policy.

8. Examine training and hazard communication strategies. 8.1 Identify training required on a construction worksite.

Course/Unit Learning Outcomes

Learning Activity

2.1 Unit III Lesson Required Readings Unit III Assessment

2.2 Unit III Lesson Required Readings Unit III Assessment

2.3 Unit III Lesson Required Readings Unit III Assessment

3.1 Unit III Lesson Required Readings Unit III Assessment

8.1 Unit III Lesson Required Readings Unit III Assessment

Reading Assignment

In order to access the following resources, click the links below.

Occupational Safety and Health Administration. (n.d.). Competent person: OSHA standards. Retrieved from https://www.osha.gov/SLTC/competentperson/standards.html

Occupational Safety and Health Administration. (n.d.). OSHA fact sheet: OSHA inspections. Retrieved from https://www.osha.gov/OshDoc/data_General_Facts/factsheet-inspections.pdf

Occupational Safety and Health Administration. (1993). Regulations (Standards – 29 CFR): Definitions. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10618#1 926.32(f)

UNIT III STUDY GUIDE

General Safety and Health Provisions

https://www.osha.gov/SLTC/competentperson/standards.html

https://www.osha.gov/OshDoc/data_General_Facts/factsheet-inspections.pdf

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10618#1926.32(f)

UNIT x STUDY GUIDE

Title

Occupational Safety and Health Administration. (1993). Regulations (Standards – 29 CFR): Employee emergency action plans. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10621

Occupational Safety and Health Administration. (1999). Multi-employer citation policy. Retrieved from https://www.osha.gov/OshDoc/Directive_pdf/CPL_2-0_124.pdf

Occupational Safety and Health Administration. (2008). Regulations (Standards – 29 CFR): General safety and health provisions. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10606

Please review pp. 4-9 to 4-18 in the resource below.

Occupational Safety and Health Administration. (2016, August 2 ). CPL-02-00-160 Field Operations Manual. Retrieved from https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-00-160.pdf

Please review pp. 143–238 in the resource below.

Occupational Safety and Health Administration. (2015). Training requirements in OSHA. Retrieved from https://www.osha.gov/Publications/osha2254.pdf

Unit Lesson

OSHA Points the Way

As we learned in previous units, there are ethical, regulatory, economic, and practical factors that determine why a construction company develops a comprehensive safety and health program. Effective safety and health programs include safety and health policies, goals, roles and responsibilities, procedures, inspections, training, and emergency response. In the United States, the Occupational Safety & Health Administration (OSHA) drives program excellence in the construction industry through the promulgation and enforcement of standards and by providing a broad spectrum of program guidance documents. In this unit, we will examine some of the administrative standards that influence program development.

There are several recurring concepts that OSHA has woven throughout the construction standards. Perhaps foremost among them is the competent person requirement. OSHA defines a competent person as:

one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. (Occupational Safety & Health Administration [OSHA], 1993, para. 7)

A requirement for a competent person appears in nearly every subpart in the construction standards. For example, the standard for rigging equipment (29 CFR 1910.251) requires that slings be inspected daily by a competent person. While there are no OSHA standards that further define the training and experience necessary to be designated a competent person, OSHA has offered some clarification in its standards interpretation letters to employers. OSHA often highlights the importance of training and knowledge, as well as a demonstrated ability to recognize hazards. OSHA also notes that the employer must give the designated competent person the authority to take prompt action (Swanson, 2005).

A less surprising, but critical thread in the standards involves training. Experienced safety practitioners understand the importance of training employees to recognize and avoid hazards as a cornerstone of effective accident prevention efforts. It is not surprising that OSHA included specific training requirements for nearly every published construction standard. Many of the standards include details of what must be included in the training, the duration of the training, and the frequency with which it must be provided. OSHA also offers non-mandatory guidelines to help employers develop effective training programs.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10621

https://www.osha.gov/OshDoc/Directive_pdf/CPL_2-0_124.pdf

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10606

https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-00-160.pdf

https://www.osha.gov/Publications/osha2254.pdf

UNIT x STUDY GUIDE

Title These guidelines include a seven-step process (OSHA, 1998):

1. determining if training is needed, 2. identifying training needs, 3. identifying goals and objectives, 4. developing learning activities, 5. conducting the training, 6. evaluating program effectiveness, and 7. improving the program.

Note that the steps represent a continuous improvement process. This process is seen throughout the current safety management literature. A critical step in the process is evaluating program effectiveness, yet many organizations stop the process after conducting the training. We have all experienced ineffective training sessions that are done simply because they are required but are never evaluated and improved to make them more effective.

Who’s On First?

Large construction projects often involve many layers of contracts. A company awarded a contract to build an apartment complex may hire subcontractors to do specialty work like drywall installation or finish carpentry. Subcontractors may be needed to provide and operate cranes and other construction equipment. Subcontractors may even hire their own subcontractors. One of the ways contractors used to avoid OSHA compliance issues was to hire contractors to do the most hazardous work. Compliance became the responsibility of the subcontractor, and any injuries were not counted against the main contractor. In 1999, OSHA issued a multi-employer worksite citation policy, and removed most of the loopholes that allowed contractors to insulate themselves from safety responsibilities. While the policy is a directive to OSHA compliance officers and not a published standard, violations issued under it have been upheld in a number of local and district courts, most recently in 2011, in Washington, D.C. (Griffen & Fonte, 2012). The core of the policy is in the four classifications of employers: creating employer, exposing employer, correcting employer, and controlling employer (OSHA, 1999). In addition to the definitions of these terms, OSHA’s directive includes examples of how to determine an employer’s classification. The directive is available to all employers on OSHA’s website (www.osha.gov).

The multi-employer policy is a good start, but it has not solved all the problems. For example, major power companies historically have some of the lowest accident rates in the country. Yet electrical power installers have a high fatality rate. One reason may be that utility companies often hire local contractors when extra crews are needed during power outages (Schneider, 2009). If you followed the Deepwater Horizon oil spill in 2010, you may have had a tough time figuring out who was responsible because British Petroleum (BP) was the primary contractor, but Transocean owned the rig, and two other companies were part owners of the well with BP.

Generally Speaking

Perhaps the most quoted section of the Occupational Safety and Health Act of 1970 (OSH Act) is Section 5(a)(1):

Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. (OSHA, n.d., Section 5)

Commonly referred to as the General Duty Clause, this section was included by the writers of the OSH Act because they recognized that it would not be possible for OSHA to anticipate every imaginable workplace hazard in its published and enforced standards. The clause gives OSHA a way to address hazards not previously recognized or new hazards created by advances in industrial technology.

Employers and inexperienced safety practitioners might presume that the General Duty Clause gives ultimate power to OSHA’s enforcement efforts and that Compliance Officers can simply cite it whenever they cannot find an applicable standard. If that were true, then there would not be much need for the detailed standards

http://www.osha.gov/

UNIT x STUDY GUIDE

Title that OSHA has promulgated. In its own guidance documents, OSHA limits the use of the General Duty Clause to very specific situations. Four criteria must be met for the clause to be used as a citation:

 The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed.

 The hazard was recognized.

 The hazard was causing or was likely to cause death or serious physical harm.

 There was a feasible and useful method to correct the hazard.

You can search OSHA’s Integrated Information Management Systems (IMIS) database at this link: http://www.osha.gov/pls/imis/generalsearch.html to find examples of how OSHA has applied the General Duty Clause over the years.

Reducing Construction Risks

In the first three units of the course, we built the foundation for an effective construction safety program, drawing from both OSHA and industry best practices to outline the critical basic requirements. We noted that one of the keys to successful accident prevention involves identifying and controlling workplace hazards. Construction sites are constantly changing, and new hazards can be introduced daily. In the remaining units in this course, we will examine some of the more common construction hazards and how the risks they represent can be reduced. Once again, we will be turning to OSHA and industry best practices to guide our study.

References

Griffen, D., & Fonte, G. (2012). OSHA's multi-employer worksite liability doctrine upheld yet again. Retrieved from http://www.hklaw.com/publications/OSHAs-Multi-Employer-Worksite-Liability-Doctrine-Upheld- Yet-Again-01-18-2012

Occupational Safety & Health Administration. (n.d.). OSH Act of 1970. Retrieved from: http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=OSHACT&p_toc_level=0&p_ke yvalue=&p_status=CURRENT

Occupational Safety & Health Administration. (1993). Regulations (Standards – 29 CRF) Definitions. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10618#1 926.32(f)

Occupational Safety & Health Administration. (1998). Training requirements in OSHA standards [Brochure]. Retrieved from https://www.osha.gov/Publications/osha2254.pdf

Occupational Safety & Health Administration. (1999). OSHA instruction: Multi-employer citation policy [Brochure]. Retrieved from https://www.osha.gov/OshDoc/Directive_pdf/CPL_2-0_124.pdf

Scheider, S. (2009). Is dangerous work being outsourced? Retrieved from http://www.lhsfna.org/index.cfm/lifelines/november-2009/is-dangerous-work-being-outsourced

Swanson, R. (2005). Requirements for being designated a competent person under Part 1926 Subpart L (Scaffolds). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_i d=25088