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  • Section Two, number 10 of the OSHA Act mandates that OSHA provide an effective enforcement program for established occupational health & safety standards. Inspection protocol: Display credentials Opening conference Walk around inspection Closing conference
  • Section 8 of the Act lists OSHA’s rights for inspections Normally no advance notice Imminent danger or inspect after normal business hours, less than 24 hour notice If advance notice is given, employers are to notify employees.
  • Section 13 of the Act covers OSHA’s power to protect against imminent danger workplace hazards. Reports can be referrals from other agencies, or employees exposed. Imminent Danger: Reasonable certainty a danger exists expected to cause death or serious harm before normal enforcement procedures.
  • For fatalities involving one or more employees and catastrophes resulting in the hospitalization of three or more employees Employers must report to OSHA within 8 hours Call 1 800 321-OSHA, or nearest OSHA office. OSHA determines if standards were violated & prevent recurrence
  • If OSHA chooses not to inspect a facility based on an employee complaint, the employee may request that OSHA provide an informal meeting to discuss the decision. Employees filing complaints against their employer may request that there identity be withheld and OSHA will then not reveal the source of the complaint.
  • Programmed High-Hazard inspections can also be the result of an OSHA special emphasis program, which can be regional or national in scope.
  • If an employer has failed to abate a violation, the compliance officer informs the employer that they are subject to “Notification of Failure to Abate” alleged violations and may face additional proposed daily penalties while such failure or violation continues.
  • Prior to inspection, the compliance officer becomes familiar with as many relevant facts as possible about the workplace, taking into account such things as the history of the establishment, the nature of the business and the particular standards likely to apply. Preparing for the inspection also involves selecting appropriate equipment for detecting and measuring fumes, gases, toxic substances, noise, etc..
  • An OSHA compliance officer carries U.S. Department of Labor credentials bearing his or her photograph and a serial number than can be verified by phoning the nearest OSHA office. Anyone who tries to collect a penalty at the time of inspection, or promotes the sale of a product or service at any time, is not an OSHA compliance officer.
  • An authorized employee representative also is given the opportunity to attend the opening conference and to accompany the compliance officer during inspection. If union, ordinarily will designate the employee representative to accompany the compliance officer. If no representative, inspector will consult with some employees during inspection, may be in private.
  • While talking with employees, the compliance officer makes every effort to minimize any work interruptions. The compliance officer observes conditions, consults with employees, may take photos (for record purposes), takes instrument readings and examines records.
  • Posting and recordkeeping are checked. The compliance officer will inspect records of deaths, injuries and illnesses which the employer is required to keep. He or she will check to see that a copy of the totals from the last page of OSHA No. 300 has been posted and that the OSHA workplace poster (OSHA 2203) is prominently displayed.
  • The compliance officer discusses with the employer all unsafe or unhealthful conditions observed on the inspection and indicates all apparent violations for which a citation may be issued or recommended. The employer is told of appeal rights. The compliance officer does not indicate any proposed penalties. Only the OSHA area director has that authority, and only after having received a full report.
  • Citations inform the employer and employees of the regulations and standards alleged to have been violated and of the proposed length of time set for their abatement. The employer will receive citations and notices of proposed penalties by certified mail. The employer must post a copy of each citation at or near the place a violation occurred, for three days or until the violation is abated, whichever is longer.
  • S ubstantial probability that death or serious physical harm could result and that the employer knew, or should have known, of the hazard. Mandatory penalty of up to $7,000 for each violation is proposed. A penalty for a serious violation may be adjusted downward, based on the employer's good faith, history of previous violations, the gravity of the alleged violation, and size of business.
  • The employer either knows that what he or she is doing constitutes a violation, or is aware that a hazardous condition existed and made no reasonable effort to eliminate it. A proposed penalty for a willful violation may be adjusted downward, depending on the size of the business and its history of previous violations. Usually, no credit is given for good faith.
  • If an employer is convicted of a willful violation of a standard that has resulted in the death of an employee, the offense is punishable by a court-imposed fine or by imprisonment for up to six months, or both. A fine of up to $250,000 for an individual, or $500,000 for a corporation, may be imposed for a criminal conviction.
  • A violation of any standard, regulation, rule, or order where, upon reinspection, a substantially similar violation can bring a fine of up to $70,000 for each such violation. To be the basis of a repeated citation, the original citation must be final; a citation under contest may not serve as the basis for a subsequent repeated citation.
  • Failure to abate a prior violation may bring a civil penalty of up to $7,000 for each day the violation continues beyond the prescribed abatement date.
  • De minimis violations are violations of standards which have no direct or immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation, but are not included on the citation.
  • Assaulting a compliance officer, or otherwise resisting, opposing, intimidating, or interfering with a compliance officer while they are engaged in the performance of their duties is a criminal offense, subject to a fine of not more than $5,000 and imprisonment for not more than three years. Citation and penalty procedures may differ somewhat in states with their own occupational safety and health programs.
  • If an inspection was initiated due to an employee complaint, the employee or authorized employee representative may request an informal review of any decision not to issue a citation. Employees may not contest citations, amendments to citations, penalties or lack of penalties. The may contest the time in the citation for abatement of a hazardous condition.
  • When issued a citation or notice of a proposed penalty, an employer may request an informal meeting with OSHA's area director to discuss the case. Employee representatives may be invited to attend the meeting. The area director is authorized to enter into settlement agreements that revise citations and penalties to avoid prolonged legal disputes.
  • The written petition should specify all steps taken to achieve compliance, the additional time needed to achieve complete compliance, the reasons such additional time is needed, all temporary steps being taken to safeguard employees against the cited hazard during the intervening period, that a copy of the PMA was posted in a conspicuous place at or near each place where a violation occurred
  • There is no specific format for the Notice of Contest; however it must clearly identify the employer's basis for filing the citation, notice of proposed penalty, abatement period, or notification of failure to correct violations. Citations must be posted in a prominent location, or at or near the location of the apparent violation for a period of three working days or until the violation is corrected.
  • Commission assigns case to an administrative law judge Judge can disallow or schedule hearing Rulings can be appealed to U.S. Court of Appeals
  • Background . OSHA's Field Inspection Reference Manual (FIRM) of September 26, 1994 (CPL 2.103), states at Chapter III, paragraph 6. C., the Agency's citation policy for multi-employer worksites. The Agency has determined that this policy needs clarification. The new policy provides clearer and more detailed guidance. New Policy is Directive 2-0.124 Multi-Employer Citation Policy 12/10/99
  • A single employer may have multiple roles. Once you determine the role of the employer, go to Step Two to determine if a citation is appropriate. (NOTE: only exposing employers can be cited for General Duty Clause violations). Note that the extent of the measures that a controlling employer must take to satisfy its duty is less than what is required of an employer with respect to protecting its own employee.
  • The employer that caused a hazardous condition that violates an OSHA standard. Employers must not create violative conditions. An employer that does so is citable even if the only employees exposed are those of other employers at the site.
  • If the exposing employer created the violation, they can be cited for the violation as a creating employer. If the violation was created by another employer, the exposing employer can be cited if they (1) knew of the hazardous condition or failed to exercise reasonable diligence to discover the condition, and (2) failed to take steps consistent with its authority to protect is employees.
  • This usually occurs where an employer is given the responsibility of installing and/or maintaining particular safety/health equipment or devices. The correcting employer must exercise reasonable care in preventing and discovering violations and meet its obligations of correcting the hazard.
  • An employer who has general supervisory authority over the worksite, including the power to correct safety and health violations itself or require others to correct them. Control can be established by contract or, in the absence of explicit contractual provisions, by the exercise of control in practice.
  • Prior to issuing citations to an exposing employer, it must first be determined whether the available facts indicate if that employer has a legitimate defense to the citation
  • If an exposing employer meets ALL these defenses, that employer shall not be cited
  • Under previous agency policy all construction inspections were comprehensive in scope, addressing all areas of the workplace and by inference all classes of hazards. This guidance may have caused compliance officers to spend too much time and effort on a few projects looking for all violations and, thus, too little time overall on many projects inspecting for hazards which are most likely to cause fatalities and serious injuries to workers.
  • The Focused Inspections Initiative that became effective October 1, 1994 is a significant departure from how OSHA has previously conducted construction inspections. Recognizes the efforts of responsible contractors who have implemented effective safety and health programs, and encourages other contractors to adopt similar programs.
  • Under the Focused Inspection Initiative, CSHO's shall determine whether or not there is project coordination by the general contractor, prime contractor, or other such entity and conduct a brief review of the project's safety and health program/plan to determine whether or not the project qualifies for a Focused Inspection.
  • The Focused Inspections Initiative policy applies only to construction safety inspections. Construction health inspections will continue to be conducted in accordance with current agency procedures.
  • Although other conditions are important, the time and resources spent to pursue them on a few projects can be better spent pursuing conditions on many projects related to the four hazard areas most likely to cause fatalities or serious injuries.
  • Assessment of safety and health programs/plan shall consider: a. the comprehensiveness of the program/plan; b. the degree of program/plan implementation; c. the designation of competent persons as are required by relevant standards; and d. how the program/plan is enforced, including management policies and activities, effective employee involvement, and training.
  • During the course of focused inspections, citations shall be proposed for the four leading hazards and any other serious hazards observed.
  • Other-than-serious hazards that are abated immediately, and this abatement is observed by the CSHO, shall not normally be cited.
  • CSHO makes the determination as to whether a project's safety and health program/plan is effective If conditions observed on the project indicate otherwise, the CSHO shall immediately terminate the Focused Inspection and conduct a comprehensive inspection.
  • Request for a warrant will not affect determination as to whether project will receive a Focused Inspection. On jobsites where unprogrammed inspections (complaints, fatalities, etc..) are being conducted, the determination as to whether to conduct a Focused Inspection shall be made only after the complaint or fatality has first been addressed.
  • The compliance officer will interview employees to determine their knowledge of the safety and health program/plan, their awareness of potential jobsite hazards, their training in hazard recognition and their understanding of applicable OSHA standards. If the project safety and health program/plan is found to be effectively implemented the compliance officer will terminate the inspection.
  • Examples of safety and health programs can be found in the Safety and Health Program Management Guidelines published January 26, 1989 in the Federal Register (54 FR 3904), in the ANSI A10.33 "Safety and Health Program Requirements for Multi-Employer Projects", and in Owner and Contractor Association model programs that meet the 29 CFR 1926 Subpart C standards.
  • If the project does not qualify for a focused inspection, then the CSHO is to conduct the same type of inspection that would have been conducted previous to the focused inspection policy.
  • OSHA - 1 FORM
  • CONSTRUCTION FOCUSED INSPECTIONS INITIATIVE Handout for contractors and employees
  • OSHA Instruction STD 3-1.1 June 22, 1987 Office of Construction and Maritime Compliance Assistance. Background. Due to OSHA's increasing emphasis on preventing construction injuries and illnesses, OSHA is reemphasizing the review of the contractor's safety citation policy regarding 29 CFR 1926.20 through 1926.23 and 29 CFR 1904.2. It also provides uniform field procedures for evaluation of safety and health programs in the construction industry.
  • 1. An evaluation of the safety and health program will be completed. These guidelines will be modified, based on the CSHO's professional judgment, to account for size and type of construction. A key indicator of an effective program will be the degree of knowledge which employees have of potential site specific safety and health hazards. This knowledge requires training (site familiarization) of skilled as well as non-skilled crafts in hazard recognition based on the employee's specific work environment and job related hazards.
  • 2. Program deficiencies such as lack of management policy, safety and health rules, inadequate assignment of responsibility, or poor employee awareness/participation shall be discussed with the employer.
  • 3. Violations of the requirements for instruction, first aid, recordkeeping, and identification and control of hazards shall be cited as indicated in the appropriate section of 29 CFR 1926.20, 29 CFR 1926.21, 29 CFR 1926.23, or 29 CFR 1904.2.
  • Note that 1926.21(b) requires only safety and health instructions. Employers are required to implement a safety and health program in accordance with the above mentioned standards. However, employers should be encouraged to implement a formal safety and health training program with the guidelines in Appendix A.
  • CFR 1926.20 (b) Accident prevention responsibilities: Such programs shall provide for frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employers. The use of any machinery, tool, material, or equipment which is not in compliance with any applicable requirement of this part is prohibited. Such machine, tool, material, or equipment shall either be identified as unsafe by tagging or locking the controls to render them inoperable or shall be physically removed from its place of operation. The employer shall permit only those employees qualified by training or experience to operate equipment and machinery.
  • Where construction employees are subject to common supervision, but do not report or work at a fixed establishment on a regular basis or where employees are engaged in physically dispersed activities, records for such employees shall be maintained as follows:
  • a. Records must be maintained either at the field office or at the mobile base of operations. b. Records may also be maintained at an established central location. If records are maintained centrally: (1) The address and telephone number of the place where the records are kept must be available at the worksite, and (2) There must be personnel available at the central location during normal business hours to provide information from the records.
  • Std 3-1.1 Appendix A Employers Safety and Health Program - Sample Guidelines
  • Std 3-1.1 Appendix A Employers Safety and Health Program - Sample Guidelines
  • Std 3-1.1 Appendix A Employers Safety and Health Program - Sample Guidelines
  • Std 3-1.1 Appendix A Employers Safety and Health Program - Sample Guidelines
  • Std 3-1.1 Appendix A Employers Safety and Health Program - Sample Guidelines
  • Std 3-1.1 Appendix A Employers Safety and Health Program - Sample Guidelines
  • 510 inspections

    1. 1. Inspections & Citations Focused InspectionMulti-Employer Worksite Citation Policy
    2. 2. Most Frequently Cited Serious Violations in Construction – FY 2008 501(b)(13) - M 2012 Fall protection – Residential construction 6’ or moreStandard & Subpart - 1926. 501(b)(1) - M 1901 Fall protection - Unprotected sides & edges 453(b)(2)(v) - L 1576 Aerial Lifts - Body belt and lanyard 100(a) - E 1536 Head protection 503(a)(1) - M 1386 Fall hazards training program 451(g)(1) - L- 1300 Scaffolds - Fall protection 1053(b)(1) - X 1239 Portable ladders 3 feet above landing surface 451(e)(1) - L 1123 Scaffolds - Access 451(b)(1) - L 1057 Scaffolds - Platform construction 454(a) - L 898 Training for employees using scaffolds
    3. 3. Most Frequently Cited Serious Violations in Construction – FY 2009 Fall protection – Residential construction 6’ or more 501(b)(13) - M 2226 Fall protection - Unprotected sides & edgesStandard & Subpart - 1926. 501(b)(1) - M 1869 Fall hazards training program 503(a)(1) - M 1576 Head protection 100(a) - E 1525 Portable ladders 3 feet above landing surface 1053(b)(1) - X 1433 Aerial Lifts - Body belt and lanyard 453(b)(2)(v) - L 1395 Scaffolds - Fall protection 451(g)(1) - L 1241 Scaffolds - Access 451(e)(1) - L 1128 Scaffolds - Platform construction 451(b)(1) - L 1052 Eye & face protection 102(a)(1) - E 1036
    4. 4. Inspections - OSHA’s Rights• Authority to inspect• “Enter without delay…..”• “Inspect and investigate….”
    5. 5. Inspection Priorities• Imminent Danger, given top priority• Employees notify employer of imminent danger• If no action taken, notify OSHA
    6. 6. Inspection Priorities• Catastrophes and Fatal Accidents, given second priority
    7. 7. Inspection Priorities• Employee Complaints, Third priority• Referrals from employees & outside agencies of unsafe or unhealthful conditions• Informal review available for decisions not to inspect• Confidentiality is maintained on request
    8. 8. Inspection Priorities• Programmed High-Hazard Inspections, given fourth priority• Aimed at high hazard industries, occupations, or health substances• Selection criteria examples: – Death – LWII rates – Exposure to toxic substances
    9. 9. Follow-up Inspections• Determines whether previously cited violations have been corrected.• “Notification of Failure to Abate” Failure to Abate
    10. 10. Inspection Process• Compliance officer becomes familiar with facility• History• Nature of business• Relevant standards• IH equipment selection
    11. 11. Inspector’s Credentials• Inspection begins when C.O. arrives at facility• Displays credentials• Employers should always ask to see ID• USDOL with photo and serial number• Employer should verify by phoning OSHA
    12. 12. Opening Conference • CSHO explains why facility was selected • Explains purpose of visit, inspection scope and applicable standards • Complaint copies distributed • Employee representative may be summoned
    13. 13. Inspection Tour• Route and duration determined by CSHO• Consults with employees• Photos• Instrument readings• Examine records
    14. 14. Inspection Tour• CHSO will point out unsafe conditions observed & possible corrective action if employer requests• Apparent violations can be corrected immediately• May still result in citation
    15. 15. Closing Conference• Discussion of problems, questions and answers• Discussion of recommended citations• Time needed for abatement• Only Area Director issues citations and assess $$$ amounts
    16. 16. Types of Violations• Other Than Serious Violation• Normally would not cause death or serious injury• Up to $ 7,000• Adjusted downward as much as 95%• Factors: – Good faith – History of violations – Size of business
    17. 17. Types of Violations• Serious Violation• High probability of death or serious harm• Mandatory $ 7,000• Adjusted downward: – Good faith – Gravity of alleged violation – Violation history – Size of business
    18. 18. Types of Violations• Willful Violation• Employer knowingly commits with plain indifference to the law• Either knows action is a violation, or is aware of hazardous condition with no effort to eliminate• Up to $ 70,000 for each• Minimum of $ 5,000
    19. 19. Types of Violations• Willful Violation• If convicted of WV that has resulted in death, court imposed fine, up to six months in jail, or both• Criminal conviction, up to $ 250,000 for individual;• $ 500,000 corporation
    20. 20. Types of Violations • Repeat Violation • Same or substantially similar, up to $ 70,000 for each violation
    21. 21. Types of Violations• Failure to Abate• Up to $ 7000/day
    22. 22. Types of Violations• De Minimis Violation• No direct relationship to safety or health
    23. 23. Additional Violations• Falsifying records• Up to $ 10,000, six months in jail, or both• Violations of posting requirements• Civil fine up to $ 7,000• Assaulting, interfering with, intimidating a CSHO while performing their duties, up to three years prison, and $ 5,000 fine
    24. 24. Appeals Process - Employees• Employees may request informal review• Employees can contest abatement time-frame• Employees may request informal conference to discuss inspections, citations, employer notice of intent to contest
    25. 25. Appeals Process - Employers• Employers can request informal conference• Area Director authorized to enter into settlement agreements that revise citations
    26. 26. Petition for Modification of Abatement• Employers written petition to extent abatement time for conditions beyond their control• Includes steps taken, how much additional time, temporary steps
    27. 27. Notice of Contest• 15 days to notify Area Director in writing• Copy given to employee representative• Or posted in prominent location
    28. 28. Review Procedure• Notice of contest forwarded to the Occupational Safety and Health Review Commission (OSHRC)• Independent of OSHA and DOL
    29. 29. Multi-Employer Worksites• More than one employer may be cited for a hazardous condition• Two-step process: – 1. Determine is a creating, exposing, correcting, or controlling employer. – 2. Employers actions were sufficient to meet their obligations under OSHA.
    30. 30. The Creating Employer• The employer who actually creates the hazard.
    31. 31. The Exposing Employer • An employer whose own employees are exposed to the hazard.
    32. 32. The Correcting Employer• An employer who is engaged in a common undertaking, on the same worksite, as the exposing employer and is responsible for correcting a hazard.
    33. 33. The Controlling Employer• The employer who is responsible, by contract or through actual practice, for safety and health conditions on the worksite; i.e., the employer who has the authority for ensuring that the hazardous condition is corrected
    34. 34. Exposing Employer Legitimate Defense• 1. The employer did not create the hazard;• 2. The employer did not have the responsibility or the authority to have the hazard corrected• 3. The employer did not have the ability to correct or remove the hazard
    35. 35. Exposing Employer Legitimate Defense• 4. The employer can demonstrate that the creating, the controlling and/or the correcting employers, as appropriate, have been specifically notified as the hazard to which his/her employees are exposed• 5. The employer has instructed his/her employees to recognize the hazard and,
    36. 36. Exposing Employer Legitimate Defense• 5a. Where feasible, an exposing employer must have taken appropriate alternative means of protecting employees from the hazard.• 5b. When extreme circumstances justify it, the exposing employer shall remove his/her employees from the job to avoid citation
    37. 37. Introduction• The Focused Inspections Initiative became effective October 1, 1994.• Recognizes the efforts of responsible contractors.
    38. 38. Introduction• More focus needed on the leading causes of fatalities in construction:• 90% of all construction fatalities are: – falls from elevations - 33%; – struck by - 22%; – caught in/between - 18%; – electrical shock - 17%.
    39. 39. Introduction• The CSHO will conduct comprehensive inspections only on those projects where there is inadequate contractor commitment to safety and health. CSHO
    40. 40. Focused Inspection Guidelines• The leading hazards are: • falls from elevations (e.g., floors, platforms, roofs) • struck by (e.g., falling objects, vehicles) • caught in/between (e.g., cave-ins, unguarded machinery, equipment) • electrical shock (e.g., overhead power lines, power tools and cords, outlets, temporary wiring)
    41. 41. Focused Inspection Guidelines• CSHO determines whether or not there is project coordination by the general contractor & prime contractor• Conducts a brief review of the projects safety and health program/plan to determine whether or not the project qualifies for a Focused Inspection. PC Plan
    42. 42. To Qualify• A) Safety and health program/plan meets the requirements of 29 CFR 1926 Subpart C, General Safety and Health Provisions.• B) There is a designated competent person responsible for and capable of implementing the program/plan. CP
    43. 43. To Qualify• If the project meets the criteria, an abbreviated walk-around inspection shall be conducted focusing on: • Verification of the safety and health program/plan effectiveness by interviews and observation; • The four leading hazards • Other serious hazards observed by the CSHO.
    44. 44. What gets inspected?• The CSHO conducting a Focused Inspection is not required to inspect the entire project.• Only a representative portion of the project need be inspected as stated in OSHA Instruction CPL 2.103
    45. 45. How serious is serious?• The discovery of serious violations during a Focused Inspection need not automatically convert the Focused Inspection into a comprehensive inspection.• These decisions will be based on the professional judgment of the CSHO.
    46. 46. Specific Guidelines• Applies only to construction safety inspections.• A project determined not to be eligible for a Focused Inspection shall be given a comprehensive inspection with the necessary time and resources to identify and document violations.
    47. 47. Specific Guidelines• All contractors and employee representatives shall, at some time during the inspection, be informed, why a focused or a comprehensive inspection is being conducted.• This may be accomplished either by personal contact or posting the "Handout for contractors and employees" (see attachments, per FIRM, Chapter II, section A. 3.)
    48. 48. Specific Guidelines• Although the walk-around inspection shall focus on the four leading hazards, citations shall be issued for any serious violations found during a Focused Inspection, and for any other-than-serious violations that are not immediately abated.• Other-than-serious violations that are immediately abated shall not normally be cited nor documented.
    49. 49. Specific Guidelines• Only contractors on projects that qualify for a Focused Inspection will be eligible to receive a full "good faith" adjustment of 25%.
    50. 50. Forms for the Focused Inspection• For Focused Inspections an OSHA-1 will be completed in accordance with the multi-employer policy as stated in the Field Inspection Reference Manual for the: – General contractor, prime contractor or other such entity and – Each employer that is issued a citation. OSHA-1
    51. 51. CONSTRUCTION FOCUSED INSPECTIONS INITIATIVEHandout for contractors and employeesThe goal of Focused Inspections is to reduce injuries, illness and fatalities by concentrating OSHAenforcement on those projects that do not have effective safety and health programs/plans andlimiting OSHAs time spent on projects with effective programs/plans.To qualify for a Focused Inspection, the project safety and health program/plan will be reviewed and a walkaroundwill be made of the jobsite to verify that the program/plan is being implemented.During the walkaround, the compliance officer will focus on the four leading hazards that cause 90% of deathsand injuries in construction. The leading hazards are: •falls (e.g., floors, platforms, roofs) •struck by (e.g., falling objects, vehicles) •caught in/between (e.g., cave-ins, unguarded machinery, equipment) •electrical (e.g., overhead power lines, power tools and cords, outlets, temporary wiring.)The compliance officer will interview employees to determine their knowledge of the safety and healthprogram/plan, their awareness of potential jobsite hazards, their training in hazard recognition and theirunderstanding of applicable OSHA standards.If the project safety and health program/plan is found to be effectively implemented, the compliance officer willterminate the inspection.If the project does not qualify for a Focused Inspection, the compliance officer will conduct a comprehensiveinspection of the entire project.If you have any questions or concerns related to the inspection or conditions on the project, you are encouragedto bring them to the immediate attention of the compliance officer or call the area office at _________________.________________________________ qualified as a FOCUSED PROJECT.
    52. 52. Construction Inspection Guidelines• An evaluation of the safety and health program will be completed.• Size and type of construction• Degree of Knowledge
    53. 53. Construction Inspection Guidelines• Safety discussion with employer: – Policy – Rules – Responsibilities – Employee involvement
    54. 54. Construction Inspection Guidelines• CSHO will cite as appropriate from: – 29 CFR 1926.20, – 29 CFR 1926.21, – 29 CFR 1926.23, or – 29 CFR 1904.2.
    55. 55. Construction Inspection Guidelines• Where the conditions warrant a citation for violation of 1926.20 or 1926.21, it may be issued even if additional 29 CFR 1926 alleged violations were not documented.
    56. 56. Construction Inspection Guidelines• Violations for 29 CFR 1926.20(b) in a routine inspection may be cited as other-than-serious or serious as circumstances warrant.
    57. 57. Construction Inspection Guidelines• Recordkeeping violations (29 CFR 1904) shall be cited where records are not available for the individual site.• Except that:
    58. 58. Construction Inspection Guidelines• Field office or mobile base• Centrally maintained: – Address & telephone – Personnel available
    59. 59. A. Management Commitment and Leadership. 1. Policy statement: goals established, issued, and communicated to employees. 2. Program revised annually. 3. Participation in safety meetings, inspections; agenda item in meetings. 4. Commitment of resources is adequate. 5. Safety rules and procedures incorporated into site operations. 6. Management observes safety rules.
    60. 60. B. Assignment of Responsibility. 1. Safety designee on site, knowledgeable, and accountable. 2. Supervisors (including foremen) safety and health responsibilities understood. 3. Employees adhere to safety rules.
    61. 61. C. Identification and Control of Hazards. 1. Periodic site safety inspection program involves supervisors. 2. Preventative controls in place (PPE, maintenance, engineering controls). 3. Action taken to address hazards. 4. Safety Committee, where appropriate. 5. Technical references available. 6. Enforcement procedures by management.
    62. 62. D. Training and Education. 1. Supervisors receive basic training. 2. Specialized training taken when needed. 3. Employee training program exists, is ongoing, and is effective.
    63. 63. E. Recordkeeping and Hazard Analysis.1. Records maintained of employeeillnesses/injuries, and posted.2. Supervisors perform accident investigations,determine causes and propose corrective action.3. Injuries, near misses, and illnesses are evaluatedfor trends, similar causes; corrective actioninitiated.
    64. 64. F. First Aid and Medical Assistance.1. First aid supplies and medical service available.2. Employees informed of medical results.3. Emergency procedures and training, where necessary.