Electrical safety terminology 3

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Multi-employer Worksites & Exposure Management

Multi-employer Worksite

• What is a multi-employer worksite?

OSHA Multi-Employer Citation Policy

• OSHA Instructional Directive CPL 02-00-124, dated Dec. 10, 1999

• Clarifies responsibilities of employers

• More than one employer may be citable

– Two-step process to determine

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Two-Step Process

1. What category of employer?

– Creating

– Exposing

– Correcting

– Controlling

– (Multiple roles possible)

2. Did employer meet obligations for that category?

Creating Employer

1. “The employer that caused a hazardous condition that violates an OSHA standard”

2. Must not create violations / hazards.

– Citable even if only employees of other employers are exposed

Exposing Employer

1. “An employer whose own employees are exposed to the hazard.”

– Even if they created the hazard.

2. If not the creating employer, citable if:

– Knew hazard, or would have with reasonable diligence and

– Failed to take steps to protect employees.

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Exposing Employer

• If exposing employer does not have authority to correct hazard, must:

– Ask creating or controlling employer to correct

– Inform employees of hazard

– Take reasonable alternative protective measures

• Imminent danger? Remove employees!

Correcting Employer

1. Engaged in a common undertaking, same worksite as exposing employer and Responsible for correcting a hazard

2. Must exercise reasonable care in

– Preventing and discovering violations

– Meeting obligation to correct hazard

Controlling Employer

1. General supervisory authority

– Power to correct or require others

– By contract or in practice

2. Reasonable care to prevent & detect

– Lesser extent than for own employees

– Less frequent inspections

– Less knowledge of trade standards

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Controlling Employer

• Factors on how often to inspect:

– Project scale

– Nature/pace of work, changing hazards

– How much known about subcontractor

– More frequent inspections for unknown or previously non-compliant subcontractor

– Less frequent inspections for subcontractor with strong safety and health efforts

Controlling Employer

• Factors to evaluate reasonable care:

– Periodic inspections, frequent enough

– Effective system to correct hazards

– Effective compliance with safety & health, graduated enforcement and follow up inspections

Controlling Employer

• Types of Controlling Employer:

– Established by Contract

– Combination of Contract Rights

• Not explicitly granted in contract but broad responsibility for site safety

• Dispute resolution, schedules, sequencing

– Architects / Engineers, as above

– Control without Explicit Contractual Authority

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Multiple Roles

• May be an exposing employer in combination with other roles

• May be a correcting employer if authorized to correct hazard

NFPA 70E 110.3 (A) Host and Contract Employers’ Responsibilities

• Host employer shall…

– inform contract employers of the following:

• Known hazards covered by 70E that are related to the contract employer’s work, and that may not be recognized by the contract employer or its employees.

• Information about the employer’s installation that the contract employer needs to make the assessments required in 70E

– report observed contract employer-related violations of 70E to the contract employer.

NFPA 70E 110.3 (B) Host and Contract Employers’ Responsibilities

• Contract employer shall ensure their employees … – are instructed in the hazards communicated by the host.

– follow the work practices required in 70E and safety-related work rules required by the host.

• Contract employer shall advise the host employer of the following: – Unique hazards presented by the contract employer’s work.

– Hazards identified during the course of work that were not communicated by host.

– Measures taken by contractor to correct violations reported by host and to prevent future reoccurrence.

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NFPA 70E 110.3 (C) Host and Contract Employers’ Responsibilities

• Documentation

– When the host knows about the hazards covered by 70E that are associated with the contractor’s work, there shall be a documented meeting between the host and contractor.

Exposure Management

Exposure

• Each component of the electrical safety program should attempt to influence only one leg of the injury triangle.

“Electrical” Hazard

Accident

Exposure Management

Exposure

• How would you address the “Electrical” Hazard side of the triangle?

• Exposure?

• Accident?

“Electrical” Hazard

Accident

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Next week…

• Monday (Sept 26) – Elements of an Electrical Safety Program – Review NFPA 70E - Informative Annex E – Electrical Safety Program

• Wednesday (Sept 28) – Exam 1 – Remember that you can use “your” copy of 70E and “your” notebook on

the exam.

– Exam will include material covered prior to September 26th.

• Friday (Sept 30) – Discussion Forum – Opens Monday @ 8:00am and closes Sunday @ 11:59pm.