Constructing a Good Safety Plan
When the Occupational Safety and Health Administration (OSHA) originally set up its regulations in the early 1970s it decided that three separate areas of compliance would be needed: General Industry, Construction and Shipbuilding. Workers on active construction projects fall under the Construction Regulations. When employees are doing work that isn’t on an active construction project, they fall under the General Industry Regulations. Whichever category, employers can protect their employees from OSHA citations under these regulations—and save their lives at the same time.
Safety On PaperRoadway workers should have some sort of a Health and Safety Program. The General Industry Regulations only require that a company have the separate elements of programs that are needed for its particular operation. A complete Written Health and Safety Program is certainly a good idea for those working under General Industry but it is not mandatory. Not only must you have the Written Health and Safety Program in construction, it must be readily available to each employee. If a project has a jobsite office, most contractors keep their program in that office. Since surveying employees are very transient in nature, it only makes sense to keep the program in the field vehicle. (Protect written safety materials kept in vehicles in a giant zipper-type food storage bag.)
Some major contractors now require that all programs be kept in a central jobsite trailer for the duration of the project. Along with this same requirement, many contractors require all subcontractors to show their programs before the subcontractors start work. Some even make it a requirement before signing the contract. Many general contractors, construction managers and owners have found that verification of safety training helps keep the overall project running smoothly and sometimes weeds out subcontractors who may not be putting safety first in the workplace. In some parts of the country, general contractors have signed “voluntary” agreements with Area OSHA offices (after receiving citations) that “assign” the lead person from each subcontractor to attend a 10-hour OSHA Voluntary Compliance Class. Some surveyors must complete this course as well.
OSHA’s former Form 200 Summary of Injury and Illnesses are now known as the OSHA Recordkeeping Regulations Form 300 and 300A. There are a number of surveyors who must now keep this report updated and provide the information to the construction supervisor who looks to see if a particular company is prone to having a number of injuries. One of the ironic things about this is that under current and previous OSHA Recordkeeping Regulations, surveyors only have to keep these records if OSHA or the Bureau of Labor Statistics (BLS) requests them. So, in essence, surveyors have to keep injury records just to work with a particular company. This shows how cautious many contractors are becoming.
There are also requirements for first aid and medical services for General Industry. OSHA quite frequently cites workers on remote construction projects for personnel without current training in first aid and CPR. The exact regulation states:
“In the absence of an infirmary, clinic, hospital or physician that is reasonably accessible in terms of time and distance to the worksite, which is available for the treatment of injured employees, a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid.”
Only one person with a valid first-aid certification is required on a jobsite, but a problem arises when that person is the one injured. It is wise for all field personnel to take an acceptable first aid and CPR course and keep current in the requirements.
Hazard Communications RequirementsHazard Communications continues to be a problem in construction work. This is how my company, RoSaKo Enterprises, was started. A surveyor on a construction site was cited $5,000 for not having a Material Safety Data Sheet (MSDS) on a can of inverted spray paint. After attending a conference and hearing about the citation, a surveyor friend of mine asked if I could use my safety knowledge to help him comply with certain regulations. One thing led to another and our company got off the ground. Those MSDSs and overall compliance with the Hazard Communications standard are imperative when working on construction sites. Along with the Written Health and Safety Program, all MSDSs must be readily available to your employees. This means keeping them in each field vehicle. Anyone who works at a multi-employer site has the right to see any of the MSDSs of products stored or used at that location. Although the written materials, the Hazard Communications Program and MSDSs are three things OSHA looks for during an inspection, they will very likely ask employees if they have been trained on chemical hazards use and handling as well. Effective training on Hazard Communications is the only way to meet this need.
Compliance with Personal Protective Equipment (PPE) regulations is also a top item in construction citations. Hardhats, protective eyewear and hearing protection can be extremely important on a construction site. (For a list of common PPE items for surveyors, see the POB homepage at www.pobonline.com.) Keeping PPE items readily available in work trucks is imperative when working on construction projects. Employees can’t just go to a cabinet and get what they need.
Safety in the RoadwayTraffic safety on transportation projects can get tricky. On major interstate projects, much of the work of surveyors during construction may be behind enormous concrete barricades. In my previous article on traffic safety (POB September 2001.) I explained the different types of vests and for which application each vest is rated to protect employees. Wearing that vest at all times is essential. Not only will it protect from the dreaded OSHA compliance officer, it may save someone’s life. However, the exact requirements for vests may be changing, so check with OSHA for new regulations.
Vehicles used on projects are definite hazards to surveyors. Surveyors often dodge loaders, graders, earthmovers and other types of machinery. Unfortunately, there are many reports of resultant fatalities over the years. One of our customers related how on a job a loader had passed a total station while an employee was taking readings. The loader backed up and ran right over the total station even though he had seen the employee seconds before. Luckily, the employee managed to jump out of the way. The jobsite superintendent didn’t even think it was a serious thing. “So what’s the big deal; we’ll replace the transit.” It wasn’t a big deal until he found out what a totaled total station costs! Imagine if that had been the employee and not the equipment. Awareness is probably the most important factor when working on transportation-related projects. There is always something happening. Workers must worry about traffic and roadway machinery, and sites are constantly changing.
OSHA and most states have separate compliance officers for General Industry and Construction, allowing a stronger emphasis on construction projects. High profile projects often get OSHA’s attention along with roadway projects. Compliance officers may even drive by sites to get to work each day.
Since the probability of getting a visit from OSHA is greater on transportation projects, compliance up front only makes sense. Not only will you protect your employees, but you just might save yourself from getting a $5,000 citation for a can of spray paint.