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Managing Construction Safety & Health
- 1. Managing Safety & Health in Construction OSHA 1926.20, Subpart C GENERAL SAFETY & HEALTH PROVISIONS 1 PPT-129-01 Bureau of Workers’ Compensation PA Training for Health & Safety (PATHS)
- 2. Subpart C Sections 1926.20 General safety and health provisions 1926.21 Safety Training and Education 1926.23 First aid and medical attention 1926.24 Fire protection and prevention 1926.25 Housekeeping 1926.26 Illumination 1926.27 Sanitation 1926.28 Personal protective equipment 2 PPT-129-01
- 3. Subpart C-General Safety & Health OSHA Violations 2014 1. Fall Protection (1926.501) 6,143 2. Hazard Communication (1910.1200) 5,161 3. Scaffolding (1926.451) 4,029 4. Respiratory Protection (1910.134) 3,223 5. Lockout/Tagout (1910.147) 2,704 6. Powered Industrial Trucks (1910.178) 2,662 7. Electrical, Wiring Methods (1910.305) 2,490 8. Ladders (1926.1053) 2,448 9. Machine Guarding (1910.212) 2,200 10.Electrical-General Requirements (1910.303) 2,056 3 PPT-129-01
- 4. Subpart C-General Safety & Health OSHA Top 10 Hazards 2015 Scaffolding Fall Protection Hazard Communication Respiratory Protection Lockout/ Tagout Electrical and wiring methods Powered Industrial Trucks Ladders Electrical-General Requirements Machine Guarding 4 PPT-129-01
- 5. Definitions Competent Person: Has authorization to take corrective action & is able to recognize existing and predictable hazards. Authorized Person: A person assigned by the employer to perform a duty or to be at a particular jobsite. 5 PPT-129-01
- 6. Definitions Construction Work: means work for construction, alteration, and/or repair, including painting and decorating. Employer: means contractor or subcontractor. 6 PPT-129-01
- 7. Definitions Qualified: means one who, by possession of a: Recognized degree, Certificate, or Professional standing, or Who by extensive knowledge, training, and experience, has successfully demonstrated their ability to solve or resolve problems relating to the subject matter, the work, or the project. 7 PPT-129-01
- 8. 1926.20 Contractor Requirements Subpart C, 1926.20-35, General Requirements No laborer or mechanic performing contract work allowed to work under working conditions which are: Unsanitary Hazardous Dangerous To their health or safety 8 PPT-129-01
- 9. 1926.20 Accident Prevention Responsibility of the employer to initiate and maintain programs necessary to comply (CFR Part 1926 Construction Industry) 9 PPT-129-01
- 10. Machinery and Tools • Must be in compliance with regulations • Tools not in compliance must be identified as unsafe by: Tagging or locking controls to render inoperable Physically removed from place of operation 10 PPT-129-01
- 11. Training and Experience Employer shall permit only those employees qualified by training or experience to operate equipment or machinery 11 PPT-129-01
- 12. Safety Training & Education 1926.21 • Instruct each employee in the recognition and avoidance of unsafe conditions. • Also All 29 CFR 1926 regulations that apply to the work. • Control or eliminate any hazards or other exposure to illness or injury. 12 PPT-129-01
- 13. Safety Training & Education 1926.21 Employees required to handle poisons, caustics & other harmful substances shall be instructed in such handling and use 13 PPT-129-01
- 14. Safety Training & Education 1926.21 Instruction on avoiding injury from plants & animals where present & first aid procedures to be used in the event of injury 14 PPT-129-01
- 15. Safety Training & Education 1926.21 • Employees required to enter confined spaces instructed to nature of hazards involved • Necessary precautions • Use of PPE 15 PPT-129-01
- 16. Safety Training & Education 1926.21 Confined space: Limited means of egress Subject to accumulation of hazardous contaminants or, Oxygen deficient atmosphere Tanks, bins, boilers, ducts, pipelines, open-topped spaces more than 4 feet deep 16 PPT-129-01
- 17. 1926.23 First Aid/Medical Provisions made by employer for every employee for: • First aid, • Medical attention, • Emergency facilities 17 PPT-129-01
- 18. 1926.24 Fire Protection Employer responsible for the development and maintenance of an effective program at the jobsite throughout all phases of the construction, repair or demolition work 18 PPT-129-01
- 19. 1926.24 Fire Protection Ensure availability of fire protection equipment as required by Subpart F of this part 19 PPT-129-01
- 20. 1926.25 Housekeeping Form and scrap lumber with protruding nails and all other debris kept cleared from work areas. Combustible scrap removed at regular intervals 20 PPT-129-01
- 21. 1926.25 Housekeeping Containers provided for collection of wastes Covered for flammable, hazardous wastes 21 PPT-129-01
- 22. 1926.26 Illumination Construction areas, aisles, stairs, ramps, corridors, offices & storage where work is in progress shall be lighted with natural or artificial illumination 22 PPT-129-01
- 23. 1926.27 Sanitation • Sanitation requirements are found in Subpart D (1926.51) • Cover requirements for drinking water (potable). • Water for other purposes. • Toilet requirements. • Eating and drinking areas. • Vermin control. 23 PPT-129-01
- 24. Personal Protective Equipment Employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions Includes fall protection. 24 PPT-129-01 1926.28
- 25. 1926.29 Acceptable Certifications Pressure vessels Boilers 25 PPT-129-01
- 26. Shipbuilding/Repairing 1926.30 Safety and health regulations in part 1915 of this title, Shipyard Employment apply. 26 PPT-129-01
- 27. Incorporation by Reference 1926.31 Only the mandatory provisions (containing the word “shall”) of standards incorporated by reference are adopted as standards under OSHA. 27 PPT-129-01
- 28. Definitions 1926.32 ANSI: means American National Standards Institute. With reference to standards: Shall: means mandatory. Should: means recommended 28 PPT-129-01
- 29. Medical Records Access 1926.33 The requirements applicable to construction work under this section are identical to those set forth in General Industry Standards 1910.1020 29 PPT-129-01
- 30. Recordkeeping/Hazard Analysis • First aid supplies and medical service available • Employees informed of medical results • Emergency procedures and training, where necessary 30 PPT-129-01
- 31. Egress 1926.34 • In every building or structure, free & unobstructed egress from all parts, when occupied • No locks to prevent free escape (except mental & penal institutions) • Exits marked by readily visible sign • Means of egress continually maintained 31 PPT-129-01
- 32. Egress Maintenance 32 PPT-129-01 Correct hazardous conditions before emergencies occur
- 33. 1926.35 Emergency Plans In writing Procedures and routes assigned Covers actions employees must take to protect themselves from fire & emergencies 33 PPT-129-01
- 34. PPT-129-01 34 • Total Costs = Direct + Indirect Expenses • Direct (insured) = e.g. wage loss, medical • Indirect (uninsured, cost to company) = e.g. downtime, property damage, morale of injured worker and others in department, hiring, training, possible OSHA citations Hidden Costs of Accidents
- 35. Accident Categories Contact (struck by, energy source(s), abrasion, etc. Caught (in, on, between, under) Fall (from elevation or same level) Electrocution 35 PPT-129-01
- 36. Accident Categories Exertion (stress or strain) Exposure (exposed to fume, gas, mist, chemical, etc...) 36 PPT-129-01
- 37. Construction Safety Programs • Although compliance with the law, including specific OSHA standards, is an important objective, an effective program looks beyond specific requirements of law to address all hazards. • It will seek to prevent injuries and illnesses, whether or not compliance is at issue. 37 PPT-129-01
- 38. Major Program Elements Management Commitment and Employee Involvement Worksite Analysis Hazard Prevention and Control Safety and Health Training 38 PPT-129-01
- 39. Management’s Role Commitment and Leadership Policy statement: goals established, issued and communicated to employees. Program revised annually. Participation in safety meetings, inspections; agenda items in meetings. 39 PPT-129-01
- 40. Management’s Role Commitment and Leadership Commitment of resources is adequate Safety rules and procedures incorporated into site operations Management observes safety rules 40 PPT-129-01
- 41. Worksite Analysis Conduct comprehensive baseline worksite surveys for safety and health Perform routine job hazards analyses. Assess risk factors of ergonomics applications to workers' tasks. 41 PPT-129-01
- 42. Worksite Analysis Conduct regular site safety and health inspections. Provide a system for employees to notify management about hazardous conditions. 42 PPT-129-01
- 43. Hazard Prevention/Control Use engineering techniques where feasible. Establish safe work practices. Provide personal protective equipment when engineering controls are infeasible. Use administrative controls reduce duration of exposure. 43 PPT-129-01
- 44. Hazard Prevention/Control o Maintain the facility and equipment to prevent breakdowns. o Plan and prepare for emergencies, and conduct training and emergency drills. o Establish a medical program that includes first aid onsite. 44 PPT-129-01
- 45. Safety & Health Training Ensure that all employees understand and are aware of the hazards to which they may be exposed and the proper methods for avoiding such hazards. 45 PPT-129-01
- 46. Safety & Health Training • Maintain physical protection in their work areas. • Understand their safety and health responsibilities. 46 PPT-129-01
- 47. Safety & Health Training • Limit certain job assignments to employees who are "certified," "competent," or "qualified," meaning that they have had special previous training. • This should be an essential part of every employer's program for protecting workers from accidents and illnesses. 47 PPT-129-01
- 48. Training & Education Supervisors receive basic training Specialized training taken when needed Employee training program exists, is ongoing, and is effective 48 PPT-129-01
- 49. Assignment of Responsibility Safety designee on site, knowledgeable, and accountable Supervisors (including foremen) safety and health responsibilities understood Employees adhere to safety rules 49 PPT-129-01
- 50. Hazard Identification & Control Action taken to address hazards Safety Committee, where appropriate Technical references available Enforcement procedures by management 50 PPT-129-01
- 51. S & H Program Review Hazard Analyses – assessment Hazard Prevention and control Policies and Procedures Employee training Follow-up Inspections (Audits) Enforcement (Discipline) 51 PPT-129-01
- 53. Contact Information Health & Safety Training Specialists 1171 South Cameron Street, Room 324 Harrisburg, PA 17104-2501 (717) 772-1635 RA-LI-BWC-PATHS@pa.gov 53 PPT-129-01 Like us on Facebook! - https://www.facebook.com/BWCPATHS
- 54. Bibliography OSHA 1926.20, Subpart C, General Safety and Health Provisions. 54 PPT-129-01
Editor's Notes
- This section covers several important health & safety provisions required by OSHA for conducting safe construction operations.
- Subpart F-Fire Protection and Prevention provides additional specific requirements for construction fire safety. Additional sections: Acceptable certifications (.29) Shipbuilding and ship repairing (.30) Incorporation by reference (.31) Definitions (.32) Access to employee medical records (.33) Means of egress (.34) Employee emergency action plans
- Citations issued are usually similar from year to year. The top three citations indicate an area of focus for viewers of this presentation to take note of.
- Many hazards noted occur each year although some years their “order of listing” changes.
- A competent person must be able to STOP THE WORK to correct any hazardous conditions or problems.
- Construction includes demolition as well.
- The importance of the concept of a qualified employee is that only qualified employees are allowed to operate equipment and machinery.
- The following slides cover important highlights and requirements of Subpart C 1926.20 - 35. Subpart C is one of the most important subparts because it covers an overview of many of the major safety requirements for construction work. The above is 1926 (a) (1) Contractor requirements. These requirements are every contractor’s responsibility.
- The above is 1926.20 (b) ( 1) The programs established must provide for frequent and regular inspections of the jobsite by a competent person designated by the employer.
- The above is 1926 (b) (3) Any machine or tool not in compliance with any applicable regulation of Part 1926 is prohibited. Includes the General Duty Clause.
- This is referenced from 1926.20 (b) (4)
- The employer should take advantage of the training and education that OSHA provides. The goal is for all employees going home safe at the end of each shift. Illnesses include exposures to dusts, chemicals, fumes and vapors.
- Workers must be made aware of the potential hazards, personal hygiene, and personal protective measures required. The Hazard Communication Standard for General Industry (1910.1200) applies in its entirety to construction.
- Training and education should also include instruction on avoiding injury from plants & animals where present & first aid procedures to be used in the event of injury.
- Any employees required to enter confined spaces should be trained in the hazards that may be encountered upon entry as well as receiving more detailed and specific training on the requirements of entering Permit Required Confined Spaces (PRCS).
- The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas. Procedures for confined space work can also be found in General Industry Standard 1910.146.
- Subpart D contains specific requirements for the provision of first aid, medical attention, and emergency facilities.
- The employer shall ensure the availability of the fire protection and suppression equipment required by Subpart F of this part.
- Subpart F covers: protection and prevention and: Flammable liquids LP gas Heating devices Extinguishers Detection and alarm requirements
- Throughout the course of construction debris must be kept cleared from work areas. Note: it is required that a safe means be provided for scrap & debris removal
- Provided for the collection and separation of waste, trash, oily and used rags, and other refuse. Containers used for garbage and other oily, flammable, or hazardous wastes, such as caustics, acids, harmful dusts, etc.. shall be equipped with covers. Garbage and other waste shall be disposed of at frequent and regular intervals.
- As required by Subpart D of this part (See 1926.56). Table D-3 in 1926.56 gives the lighting requirements in foot-candles. General construction requires 5 foot candles of illumination. A foot-candle is the light emitted by a candle as seen from a distance of one foot. Local camera shops carry them. Image: forconstructionpros.com
- Potable water meets US Public Health Service Drinking Water Standards 42 CFR Part 72. Stores or sources of non-potable water must clearly indicate they are not for drinking, cooking or washing. One toilet provided for up to 20 workers. Toilet plus urinal for per 40 workers. Over 200 employees one toilet and urinal per 50 workers.
- PPE requirements are found in Subpart E. Includes: Foot Head Hearing Eye & Face Respiratory Safety belts, lifelines, & lanyards
- Deemed in compliance when evidence of current and valid certification by an insurance company or regulatory authority attesting to the safe installation, inspection, and testing is presented.
- General. Shipbuilding, ship repairing, alterations, and maintenance performed on ships under Government contract, except naval ship construction, is work subject to the Act.
- Amended June 18, 1998
- Other regulations by such agencies as ANSI (American National Standards Institute) are also adopted by reference.
- Medical records must be kept for the duration of employment plus 30 years. An employer shall assure that access is provided in a reasonable time, place, and manner.
- OSHA considers recordkeeping an important part of managing safety and health programs whether those records deal with injuries, confined space entry permits or forklift operators. Records should be maintained in a manner that they are accessible in the event of an OSHA inspection.
- Access to exits shall be marked by readily visible signs in all cases where the exit or way to reach it is not immediately visible to the occupants.
- Means of egress shall be continually maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.
- Emergency Action Plans or EAP’s are an integral part of any operation. These plans should address anticipated emergencies and provide detailed instructions as to what actions should be taken to ensure the safety of all concerned. Employees should know where these plans are located and what their involvement is during an emergency.
- It is commonly accepted that the direct cost of accidents represents only one-fourth to one-fifth the total cost of accidents, which included indirect costs. An analogy is the portion of an iceberg visible are direct costs, the part underwater the indirect part. The costs of accidents are both direct (insured) costs, such as wage loss, medical costs, and indirect of the uninsured costs to include property damage, morale, downtime and possible OSHA citations (if you’re covered by OSHA). Together, they are the total costs of accidents. The goal is to reduce overall accidents thereby reducing overall costs. Direct costs of accidents/incidents are usually something that can be determined rather easily and include: Deductible part of insurance policy Lost wages for those not insured Wages paid to injured persons not covered by worker compensation Overtime work required as a result of an accident Supervisor time related to an accident: ▪ Repairing, replacing or cleaning up ▪ Reduced productivity of injured worker ▪ Learning period for new worker ▪ Accident investigation cost ▪ Costs to prepare and file reports ▪ Uninsured medical costs ▪ Costs of litigation The indirect cost of accidents are generally greater than the direct costs.
- Accident categories pertain to inspection criteria under OSHA’s Focused Inspection policy. Accident categories pertain to inspection criteria under OSHA’s Focused Inspection policy. The four leading causes of construction fatalities are: Contact/struck by Caught in/between Falls from elevations Electrocution
- Repetitive Strain Injuries (RSI) and exposure type injuries are two leading causes of non-fatal lost time construction injuries.
- An effective program includes provisions for the systematic identification, evaluation, and prevention or control of general workplace hazards, specific job hazards, and potential hazards that may arise from foreseeable conditions. The extent to which the program is described in writing is less important than how effective it is in practice. As the size of a worksite or the complexity of a hazardous operation increases, however, the need for written guidance increases to ensure clear communication of policies and priorities as well as a consistent and fair application of rules. Image: Axiacon.com
- An effective occupational safety and health program will include the above four main elements: management commitment and employee involvement, worksite analysis, hazard prevention and control, and safety and health training.
- Develop a worksite policy on safety and working conditions, so that all personnel at the site understand the importance of safety and health protection in the organization. Establish and communicate a clear goal for the safety and health program so everyone understands their responsibilities. Arrange for and encourage employee involvement in the structure and operation of the program and in decisions that affect their safety and health Image: ccorpusa.com
- Assign and communicate responsibility for all aspects of the program so that managers, supervisors, and employees in all parts of the organization know what performance is expected of them. Provide adequate authority and resources to responsible parties so that assigned responsibilities can be met. Hold managers, supervisors, and employees accountable for meeting their responsibilities so that essential tasks will be performed. Image: qpsinc.com
- Analysis of the work environment involves a variety of worksite examinations to identify existing hazards and conditions and operations in which changes might occur to create new hazards. Hazards stemming from failure to examine the worksite is a sign that safety and health policies and/or practices are ineffective. Use checklists.
- Conduct regular site safety and health inspections so that new or previously missed hazards and failures in hazard controls are identified. Workers should receive timely responses. Encourage workers to use the system without fear of reprisal. This system utilizes employee insight and experience in safety and health protection and allows employee concerns to be addressed.
- Where feasible, workplace hazards are prevented by effective design of the job site or job. Where it is not feasible to eliminate such hazards, they must be controlled to prevent unsafe and unhealthful exposure.
- Understanding and compliance are a result of training, positive reinforcement, correction of unsafe performance, and if necessary, enforcement through a clearly communicated disciplinary system.
- The complexity of training depends on the size and complexity of the worksite as well as the characteristics of the hazards and potential hazards at the site.
- Reinforce employee training on the nature of potential hazards in their work and on needed protective measures through continual performance feedback and, if necessary, through enforcement of safe work practices.
- Many researchers conclude that those who are new on the job have a higher rate of accidents and injuries than more experienced workers. This may be due to ignorance of specific job hazards and/or of proper work practices, and if so, training may help provide a solution.
- It is a good safety and business practice for employers to keep records of all safety and health training. Records can provide evidence of the employer's good faith and compliance with OSHA standards. Documentation also can supply an answer to one of the first questions an accident investigator will ask: "Was the injured employee properly trained to do the job?"
- Effective health and safety programs have accountability as a key element.
- Periodic site safety inspection program involves supervisors Preventative controls in place (PPE, maintenance, engineering controls)
- In summary, a good Safety and Health Program includes the items listed on the slide. A good program can go a long way in helping to prevent workplace accidents.
- We invite you to contact us for other available free training programs and resources.