2304 VIII JRNL

OSH 2304, Introduction to Contractor Safety 1

Course Learning Outcomes for Unit VIII Upon completion of this unit, students should be able to:

1. Discuss hazards unique to contract work.

2. Summarize regulatory policies for multi-employer worksites.

3. Discuss contractor safety-related best practices.

4. Summarize methods for ensuring contractor accountability.

5. Discuss contractor safety from a safety management systems perspective. 5.1 Explain management commitment to the safety and health program. 5.2 Summarize education and training options for safety and health programs. 5.3 Compare methods for promoting safety and health.

Required Unit Resources Chapter 12: Promoting Safety, Safety Training, and Mentoring In order to access the following resource, click the link below. Occupational Safety and Health Administration. (2016, October). Recommended practices for safety and

health programs in construction (OSHA Document No. 3886). United States Department of Labor. https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf

Unit Lesson This course has demonstrated the difficulties that can be present in developing an effective written safety and health program. Most construction sites have multiple employers present with overlapping safety responsibilities. Even the best written safety program will not reduce occupational injuries and illnesses if it is not implemented and maintained well. In many cases, a lot of effort is put into writing a safety and health program with less effort expended to implement the policies contained within the program. The construction industry has always been a focus of the Occupational Safety and Health Administration (OSHA) because of the number of injuries and illnesses that occur. OSHA published a document specifically to improve the effectiveness of safety and health programs in the construction industry. Within the document, OSHA lists seven core elements for recommended practices; management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication and coordination for employers on multiemployer worksites (OSHA, 2016). This class has covered some of those elements in earlier units. During this unit, we will look at management leadership, worker participation, education and training, program evaluation and improvement, and communication and coordination for employers on multiemployer worksites.

Management’s Role One of the most important elements of an effective safety program is how management support is viewed by employees. One way management can show their commitment to the program is through the company safety policy. The written company safety program is a primary method that management can use to communicate their expectations of employees related to safety practices. OSHA (2016) recommends the written safety

UNIT VIII STUDY GUIDE Tying it all Together – Promoting Safety in Construction

OSH 2304, Introduction to Contractor Safety 2

UNIT x STUDY GUIDE Title

policy as a way to show employees that safety and health is as important as productivity and profitability. The written policy should be signed by senior management and communicated to all employees, subcontractors, and temporary workers. Simply writing a safety policy is not adequate to totally indicate management support of the safety and health program. Specific, actionable items should also be required of management. Management can further show their support by establishing some meaningful, measurable goals related to safety and health and hold all employees (including management) accountable for achieving the goals (OSHA, 2016). An example of this process would be to set a goal to reduce the OSHA injury and illness rate to a specified level. Then, each supervisor would have that goal included in their annual performance review. Another important action that management should take is to hire someone to oversee the safety and health program and then to allocate the necessary resources to allow that person to reach the specified goals (OSHA, 2016). Finally, management must also be expected to follow all the safety rules just like workers are required to do. Nothing shows a lack of management leadership than the owner of a construction company showing up at a worksite and not wearing the required PPE. Just as important as management commitment is employee participation in the safety and health program. Many injuries and fatalities are caused by employees failing to follow proper safety rules that have been established in the safety and health program. There are many reasons for workers not following the required safety rules. They can range from the PPE not being comfortable, to not feeling the need to follow the rules because management does not follow the rules. Whatever the reason, the safety and health program needs to develop methods to include employees in all aspects of the safety and health program and to provide a method for the workers to report unsafe practices and conditions (OSHA, 2016). Over the years, companies have developed many different methods to accomplish these goals. Identifying unsafe work practices and conditions is essential to providing a safer workplace. The worker is in the best position to identify these unsafe practices and conditions (OSHA, 2016). It can be difficult to get workers to report unsafe conditions and practices, including near-miss incidents. A program that encourages workers to report these incidents can greatly improve the effectiveness of a safety and health program. Management can take actions that will encourage workers to report incidents. Management actions can also discourage workers from reporting incidents. Workers must feel that they are safe in reporting the incidents and that the reports will be taken seriously, and effective controls will be implemented. When workers are included in the development of a reporting system, including how the reports will be evaluated and how controls are chosen and implemented, the program will also be more effective. If workers believe they will be punished for reporting incidents or that the reports will not be taken seriously, they will be likely not report the incidents (OSHA, 2016).

Conflicts of Interest At times, safety and health programs may unintentionally overlap, producing undesired results. For example, earlier in this lesson, we mentioned a practice where a supervisor’s annual performance review is partially tied to the injury and illness rate for the company. This practice may result in the supervisor discouraging workers from reporting incidents in order to keep the rates low to improve their annual performance review. Some companies develop incentive programs that can be tied to several safety goals, including reporting incidents, injury and illness rates, and days without a recordable injury or illness. Awards for these incentive programs can be quite substantial leading to peer-pressure to achieve the goals that have been set. These types of program may also discourage workers from reporting incidents. OSHA has recognized the problems associated with these types of incentive programs. OSHA stated that incentive programs that discourage workers from reporting near misses and injuries and illnesses are problematic and may violate OSHA regulations (Fairfax, 2012). This means that any incentive program that is developed and implemented must be evaluated by management to make sure that it does not discourage workers from reporting safety incidents.

Education and Training Another important element of an effective safety and health program is education and training of management and employees. At the most basic level, management and employees must be trained on the basics of the safety and health program (OSHA, 2016). This will provide everyone with the required knowledge of what is

OSH 2304, Introduction to Contractor Safety 3

UNIT x STUDY GUIDE Title

expected of them under the program, who to contact if they have issues, how to report near misses, injuries and illnesses, what to do in an emergency, and their rights under the Occupational Safety and Health Act (OSHA, 2016). This training is commonly conducted as an introductory class when someone is newly hired as an orientation class and oftentimes is provided by the site safety officer. Most companies provide additional training depending on the job description of the worker. Two common training classes are the 10-hour and 30-hour classes for the construction industry (Goetsch, 2018). These classes cover some basic safety requirements in the construction regulations, and participants are provided with a certificate after they complete the class. Because the trainer requires some specific training in order to teach the class, these two training classes are often performed off site or through an online class. In many cases, local community colleges and safety organizations offer the classes for a fee. Ongoing safety training can always be effective in reinforcing safe work habits. The textbook mentions one popular on-going training technique called toolbox talks (Goetsch, 2018). These talks involve discussing one safety topic for a brief period of time each day or week. With continuing toolbox talks, the company can cover a wide range of safety topics. Multiple toolbox talks have been developed through an OSHA alliance program and can be used for these talks. See a list of topics at the OSHA website (OSHA, n.d.). The method used to present the training can also influence the effectiveness of the learning (Goetsch, 2018). Researchers have long held that different students may prefer different styles of training (Quinn et al., 2018). While there are many learning styles that have been described, there are four main considerations; is the student an active or reflective learner, a sensing or an intuitive learner, a visual or a verbal learner, or is the student a sequential or global learner (Quinn et al., 2018). What this means to developing a safety training program is that some workers will learn better by hearing someone tell them the information, some will learn better by reading the information, some will learn better by performing a hands-on task, some will learn better by being provided with small amount of information at a time, while others will learn better when provided with all the information at once. A safety professional has to look at providing the safety information using several different approaches.

Mentoring Mentoring is another approach that has been used to make safety and health programs more effective. Mentoring involves placing a new worker with an experienced employee for a period of time. Mentoring can be very effective as long as the mentor has been trained in the process and understands the safety and health program. Placing a new employee with a mentor that takes shortcuts to avoid some safety and health rules because they believe the rules slow production will produce more employees who use unsafe practices. A mentoring program can be effective, but it must be developed and managed properly.

Conclusion OSHA promotes the concept of continuous improvement for safety and health programs (OSHA, 2016). This process provides a method for on-going evaluation of the program, identification of weaknesses, improvements to the program to improve those weaknesses, and reevaluation of the program at a specified frequency. This process requires the safety professional to track leading indicators of the program like injury and illness rates, near misses, and compliance with safety rules. This is a good reason for the safety professional to be walking through the worksite on a regular basis. By analyzing the leading indicators, the safety professional can identify trends that can indicate weaknesses in the program and can implement changes to the program. For example, if the analysis shows that there has been a large increase in the reports of near misses involving falls, there may be a lack of compliance with fall protection among workers. The safety professional can implement new training for fall protection and continue to provide periodic training until the near misses are reduced.

References Fairfax, R. E. (2012, March 12). Memorandum to regional administrators, whistleblower program managers:

Employer safety incentive and disincentive policies and practices. Occupational Safety and Health Administration, United States Department of Labor. https://www.osha.gov/as/opa/whistleblowermemo.html

OSH 2304, Introduction to Contractor Safety 4

UNIT x STUDY GUIDE Title

Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson. Occupational Safety and Health Administration. (n.d.). Alliance program participants developed products.

United States Department of Labor. https://www.osha.gov/alliances/products Occupational Safety and Health Administration. (2016, October). Recommended practices for safety and

health in construction (OSHA Document No. 3886). United States Department of Labor. https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf

Quinn, M. M., Smith, T., Kalmer, E. L., & Burgoon, J. M. (2018, July/August). What type of learner are your

students? Preferred learning styles of undergraduate gross anatomy students according to the Index of Learning Styles questionnaire. Anatomical Sciences Education, 11, 358–365. https://bit.ly/38ayiJo

Suggested Unit Resources In order to access the following resources, click the links below. According to OSHA the construction industry has the highest fatal injury rate across all industries. These resources highlight why that is and offer guidance on reducing workplace fatalities. Occupational Safety and Health Administration. (2005). Worker safety series: Construction (OSHA Document

No. 3252-05N). United States Department of Labor. chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https:/www.osha.gov/sites/default/files/publications/osh a3252.pdf

Occupational Safety and Health Administration. (n.d.). Preventing fatalities. United States Department of

Labor. https://www.osha.gov/SLTC/etools/construction/index.html Occupational Safety and Health Administration. (n.d.). Construction enforcement memos. United States

Department of Labor. https://www.osha.gov/enforcementmemos Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. OSHA has produced numerous videos on various topics related to construction safety. Go to the OSHA website, and view the list of videos. View some of the videos that are of interest to you. What did you learn that you could apply to the lessons in this course?

OSH 2304, Introduction to Contractor Safety 1

Course Learning Outcomes for Unit VIII Upon completion of this unit, students should be able to:

1. Discuss hazards unique to contract work.

2. Summarize regulatory policies for multi-employer worksites.

3. Discuss contractor safety-related best practices.

4. Summarize methods for ensuring contractor accountability.

5. Discuss contractor safety from a safety management systems perspective. 5.1 Explain management commitment to the safety and health program. 5.2 Summarize education and training options for safety and health programs. 5.3 Compare methods for promoting safety and health.

Required Unit Resources Chapter 12: Promoting Safety, Safety Training, and Mentoring In order to access the following resource, click the link below. Occupational Safety and Health Administration. (2016, October). Recommended practices for safety and

health programs in construction (OSHA Document No. 3886). United States Department of Labor. https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf

Unit Lesson This course has demonstrated the difficulties that can be present in developing an effective written safety and health program. Most construction sites have multiple employers present with overlapping safety responsibilities. Even the best written safety program will not reduce occupational injuries and illnesses if it is not implemented and maintained well. In many cases, a lot of effort is put into writing a safety and health program with less effort expended to implement the policies contained within the program. The construction industry has always been a focus of the Occupational Safety and Health Administration (OSHA) because of the number of injuries and illnesses that occur. OSHA published a document specifically to improve the effectiveness of safety and health programs in the construction industry. Within the document, OSHA lists seven core elements for recommended practices; management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication and coordination for employers on multiemployer worksites (OSHA, 2016). This class has covered some of those elements in earlier units. During this unit, we will look at management leadership, worker participation, education and training, program evaluation and improvement, and communication and coordination for employers on multiemployer worksites.

Management’s Role One of the most important elements of an effective safety program is how management support is viewed by employees. One way management can show their commitment to the program is through the company safety policy. The written company safety program is a primary method that management can use to communicate their expectations of employees related to safety practices. OSHA (2016) recommends the written safety

UNIT VIII STUDY GUIDE Tying it all Together – Promoting Safety in Construction

OSH 2304, Introduction to Contractor Safety 2

UNIT x STUDY GUIDE Title

policy as a way to show employees that safety and health is as important as productivity and profitability. The written policy should be signed by senior management and communicated to all employees, subcontractors, and temporary workers. Simply writing a safety policy is not adequate to totally indicate management support of the safety and health program. Specific, actionable items should also be required of management. Management can further show their support by establishing some meaningful, measurable goals related to safety and health and hold all employees (including management) accountable for achieving the goals (OSHA, 2016). An example of this process would be to set a goal to reduce the OSHA injury and illness rate to a specified level. Then, each supervisor would have that goal included in their annual performance review. Another important action that management should take is to hire someone to oversee the safety and health program and then to allocate the necessary resources to allow that person to reach the specified goals (OSHA, 2016). Finally, management must also be expected to follow all the safety rules just like workers are required to do. Nothing shows a lack of management leadership than the owner of a construction company showing up at a worksite and not wearing the required PPE. Just as important as management commitment is employee participation in the safety and health program. Many injuries and fatalities are caused by employees failing to follow proper safety rules that have been established in the safety and health program. There are many reasons for workers not following the required safety rules. They can range from the PPE not being comfortable, to not feeling the need to follow the rules because management does not follow the rules. Whatever the reason, the safety and health program needs to develop methods to include employees in all aspects of the safety and health program and to provide a method for the workers to report unsafe practices and conditions (OSHA, 2016). Over the years, companies have developed many different methods to accomplish these goals. Identifying unsafe work practices and conditions is essential to providing a safer workplace. The worker is in the best position to identify these unsafe practices and conditions (OSHA, 2016). It can be difficult to get workers to report unsafe conditions and practices, including near-miss incidents. A program that encourages workers to report these incidents can greatly improve the effectiveness of a safety and health program. Management can take actions that will encourage workers to report incidents. Management actions can also discourage workers from reporting incidents. Workers must feel that they are safe in reporting the incidents and that the reports will be taken seriously, and effective controls will be implemented. When workers are included in the development of a reporting system, including how the reports will be evaluated and how controls are chosen and implemented, the program will also be more effective. If workers believe they will be punished for reporting incidents or that the reports will not be taken seriously, they will be likely not report the incidents (OSHA, 2016).

Conflicts of Interest At times, safety and health programs may unintentionally overlap, producing undesired results. For example, earlier in this lesson, we mentioned a practice where a supervisor’s annual performance review is partially tied to the injury and illness rate for the company. This practice may result in the supervisor discouraging workers from reporting incidents in order to keep the rates low to improve their annual performance review. Some companies develop incentive programs that can be tied to several safety goals, including reporting incidents, injury and illness rates, and days without a recordable injury or illness. Awards for these incentive programs can be quite substantial leading to peer-pressure to achieve the goals that have been set. These types of program may also discourage workers from reporting incidents. OSHA has recognized the problems associated with these types of incentive programs. OSHA stated that incentive programs that discourage workers from reporting near misses and injuries and illnesses are problematic and may violate OSHA regulations (Fairfax, 2012). This means that any incentive program that is developed and implemented must be evaluated by management to make sure that it does not discourage workers from reporting safety incidents.

Education and Training Another important element of an effective safety and health program is education and training of management and employees. At the most basic level, management and employees must be trained on the basics of the safety and health program (OSHA, 2016). This will provide everyone with the required knowledge of what is

OSH 2304, Introduction to Contractor Safety 3

UNIT x STUDY GUIDE Title

expected of them under the program, who to contact if they have issues, how to report near misses, injuries and illnesses, what to do in an emergency, and their rights under the Occupational Safety and Health Act (OSHA, 2016). This training is commonly conducted as an introductory class when someone is newly hired as an orientation class and oftentimes is provided by the site safety officer. Most companies provide additional training depending on the job description of the worker. Two common training classes are the 10-hour and 30-hour classes for the construction industry (Goetsch, 2018). These classes cover some basic safety requirements in the construction regulations, and participants are provided with a certificate after they complete the class. Because the trainer requires some specific training in order to teach the class, these two training classes are often performed off site or through an online class. In many cases, local community colleges and safety organizations offer the classes for a fee. Ongoing safety training can always be effective in reinforcing safe work habits. The textbook mentions one popular on-going training technique called toolbox talks (Goetsch, 2018). These talks involve discussing one safety topic for a brief period of time each day or week. With continuing toolbox talks, the company can cover a wide range of safety topics. Multiple toolbox talks have been developed through an OSHA alliance program and can be used for these talks. See a list of topics at the OSHA website (OSHA, n.d.). The method used to present the training can also influence the effectiveness of the learning (Goetsch, 2018). Researchers have long held that different students may prefer different styles of training (Quinn et al., 2018). While there are many learning styles that have been described, there are four main considerations; is the student an active or reflective learner, a sensing or an intuitive learner, a visual or a verbal learner, or is the student a sequential or global learner (Quinn et al., 2018). What this means to developing a safety training program is that some workers will learn better by hearing someone tell them the information, some will learn better by reading the information, some will learn better by performing a hands-on task, some will learn better by being provided with small amount of information at a time, while others will learn better when provided with all the information at once. A safety professional has to look at providing the safety information using several different approaches.

Mentoring Mentoring is another approach that has been used to make safety and health programs more effective. Mentoring involves placing a new worker with an experienced employee for a period of time. Mentoring can be very effective as long as the mentor has been trained in the process and understands the safety and health program. Placing a new employee with a mentor that takes shortcuts to avoid some safety and health rules because they believe the rules slow production will produce more employees who use unsafe practices. A mentoring program can be effective, but it must be developed and managed properly.

Conclusion OSHA promotes the concept of continuous improvement for safety and health programs (OSHA, 2016). This process provides a method for on-going evaluation of the program, identification of weaknesses, improvements to the program to improve those weaknesses, and reevaluation of the program at a specified frequency. This process requires the safety professional to track leading indicators of the program like injury and illness rates, near misses, and compliance with safety rules. This is a good reason for the safety professional to be walking through the worksite on a regular basis. By analyzing the leading indicators, the safety professional can identify trends that can indicate weaknesses in the program and can implement changes to the program. For example, if the analysis shows that there has been a large increase in the reports of near misses involving falls, there may be a lack of compliance with fall protection among workers. The safety professional can implement new training for fall protection and continue to provide periodic training until the near misses are reduced.

References Fairfax, R. E. (2012, March 12). Memorandum to regional administrators, whistleblower program managers:

Employer safety incentive and disincentive policies and practices. Occupational Safety and Health Administration, United States Department of Labor. https://www.osha.gov/as/opa/whistleblowermemo.html

OSH 2304, Introduction to Contractor Safety 4

UNIT x STUDY GUIDE Title

Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson. Occupational Safety and Health Administration. (n.d.). Alliance program participants developed products.

United States Department of Labor. https://www.osha.gov/alliances/products Occupational Safety and Health Administration. (2016, October). Recommended practices for safety and

health in construction (OSHA Document No. 3886). United States Department of Labor. https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf

Quinn, M. M., Smith, T., Kalmer, E. L., & Burgoon, J. M. (2018, July/August). What type of learner are your

students? Preferred learning styles of undergraduate gross anatomy students according to the Index of Learning Styles questionnaire. Anatomical Sciences Education, 11, 358–365. https://bit.ly/38ayiJo

Suggested Unit Resources In order to access the following resources, click the links below. According to OSHA the construction industry has the highest fatal injury rate across all industries. These resources highlight why that is and offer guidance on reducing workplace fatalities. Occupational Safety and Health Administration. (2005). Worker safety series: Construction (OSHA Document

No. 3252-05N). United States Department of Labor. chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https:/www.osha.gov/sites/default/files/publications/osh a3252.pdf

Occupational Safety and Health Administration. (n.d.). Preventing fatalities. United States Department of

Labor. https://www.osha.gov/SLTC/etools/construction/index.html Occupational Safety and Health Administration. (n.d.). Construction enforcement memos. United States

Department of Labor. https://www.osha.gov/enforcementmemos Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. OSHA has produced numerous videos on various topics related to construction safety. Go to the OSHA website, and view the list of videos. View some of the videos that are of interest to you. What did you learn that you could apply to the lessons in this course?