Construction Safety- Overview 2008

By:  Janine M. Legg, MBA-Safety Engineer/Risk Manager

HHC Services, Inc. 25 N. Duke St., Suite 100, York, PA  17401-Phone:717-509-4618

As 2008 enters the end of the First quarter, the construction General Contractors and Trades begin to ramp back up. This year’s Local Enforcement Program (LEP) of the Occupational Safety and Health Administration, (“OSHA”) for the construction industry, centers around enforcement of fall hazards in construction, (OSHA, Local Emphasis Programs,” 2007, August, para. 1). For the Region III Harrisburg District, the LEP for enforcement includes: fall hazards in construction, and concrete block and brick.  Residential Construction is a Local Enforcement Program in the Philadelphia, Allentown, Pittsburgh, Erie, Charleston, and Wilmington areas. Roof Trusses are a Local Enforcement Program in the Charleston area, (Alternative procedures for Residential Construction can be found in STD 03-00-001). Silica in Concrete is an enforcement program in the Charleston area.  Silica in cut stone is an enforcement program in the Allentown area.  Noise exposure is a local enforcement program in the Pittsburgh and Erie areas.  An enforcement inspector is not precluded from performing an inspection, soley, on the local emphasis program (Ibid).  Last year, the most frequently cited standards were: Scaffolding, Fall protection in construction, and Ladders in construction, (OSHA, 2007, October, para. 2).

There seems to be a constant struggle, between the General Contractors and their trades, on how to build a culture of safety on a construction jobsite. Part of the needed education process for the trades, includes what is actually required by OSHA, as a minimum standards.

Small Contractors, at times, have a hard time determining the level of safety plan to implement.  The OSH Act applies to all employers but certain small entities are exempt, such as: self-employed persons, farms that employ only immediate family members, certain federal agencies, and generally employees of state and local governments.  There is an exemption for the record-keeping requirement, (of maintaining the OSHA 300 log), for employers who have less than 10 employees (USDOL, Employment Law Guide, 2007, p. 1-8).

Employers must ensure that they are providing safe work places for their employees. Employers must understand the safety standards of the Occupational Safety and Health Administration and they also must eliminate workplace hazards. Employers must train their employees on the specific programs that fit the job duties, actions and conduct.  Employers are responsible for furnishing a “place of employment that is free from recognized hazards that are causing, or are likely to cause death or serious physical harm to his employees,” (USDOL, OSHA Employment Law Guide, 2007, pp. 1-2).

All this said, it becomes imperative that Job Hazard Analyses (“JHA”) and Personal Protective Hazard Assessment (“PPE Hazard Assessment”) become part of the trades Safety Program.  The General Contractors would be well served to require that each of their trades incorporate a JHA and PPE Hazard Assessment in their Safety Programs.  In response to the OSHA LEP, the trades safety programs would be greatly enhanced by incorporating a Daily Fall Protection Checklist (daily inspection of fall protection Personal Protective Equipment) as well as becoming more educated about fall hazards, which are then documented in a Job Hazard Analysis and Personal Protective Equipment Hazard Assessment.

References

U.S. Department of Labor. (2007, July). Employment Law Guide: Chapter Occupational Safety and Health. Washington, D.C. Retrieved February 6, 2008, from http: www.dol.gov/compliance/guide/osha.htm

U.S. Department of Labor, Occupational Safety and Health Administration (OSHA). (2007, August 23). Local Emphasis Programs. Washington, D.C. Retrieved January 9. 2008, from http://www.osha.gov/dep/local emphasisprograms.html

U.S. Department of Labor, Occupational Safety and Health Administration (OSHA). (2007, October 03). Most Frequently Cited Standards. Washington, D.C. Retrieved January 17, 2008, from http://www.osha.gov/dcsp/compliance_assistance/frequent_stanards.html

Still have questions? Please contact us anytime! We look forward to hearing from you.

Contact us at 717-509-4618 for a free Consultation!