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SAFETYSOLUTIONS


 OSHA’S
 TOp 10
 LiST:
 Documents to
 Have on HanD
 By amanda mayer



 W
             hen people think of Top 10 lists these days, comedy
             is the first thing that comes to mind. But if an
             Occupational Safety and Health Administration
 (OSHA) inspector arrives on the jobsite, good jokes won’t go
 very far. Contractors need to prove that their company and
 employees are serious about safety. One of the best ways to do
 that is to have all safety documentation and reports up to date
 and handy when the OSHA inspector asks for them. Below are
 the 10 documents and reports they ask for most often when
 visiting construction sites.

 1. The OSHA 300 Log
 OSHA Form 300 is the document used to track injury and
 illness records if a company has at least 10 employees. It’s one
 that OSHA nearly always requests, so it’s important to keep it
 up to date. The supervisor or other team member responsible
 for keeping the log needs to have a thorough understanding           and the hazards that workers may encounter. For example,
 of what constitutes recordable injuries or illnesses, so that the    if there will be excavation on the site, OSHA will expect
 company is not recording any that don’t belong there.                evidence that workers have participated in excavation safety
                                                                      training.
 2. Hazard Communications Program
 The inspector will probably check to see that the company has        4. Emergency Action Plan
 a written Hazard Communications Program, and verify that it          What are workers supposed to do if a fire breaks out or a
 covers all of the required elements. This plan should address        funnel cloud bears down on the work site? The company’s
 workplace hazards, where employees can access Material Safety        Emergency Action Plan is supposed to spell out the actions
 Data Sheets (MSDS), and how hazards are going to be labeled          workers should take when confronted by situations like those.
 on the jobsite, as well as how the company’s training program        Generally speaking, the contractor that is in control of the site
 will address these issues.                                           is required to develop the plan, so if a company is one of the
                                                                      subcontractors or another party, it will need to demonstrate
 3. Training Records                                                  that its team is familiar with the plan.
 While there isn’t an easy standard for these records, rest assured
 that OSHA is going to want to see proof that the company is          5. Lockout and Tagout Program
 providing the training that’s appropriate for the work it is doing   If crews are going to work around electrical or mechanical


                               amanda mayer joined safety management Group in June 2006 and currently serves as
 Aboutthe                      a safety advisor in the safety services Group. safety management Group is a nationwide
                               professional service organization that provides workplace safety consulting, training,
 Author                        staffing, and program planning. For more information, please call 800.435.8850, e-mail
                               amandamayer@safetymanagementgroup.com, or visit www.safetymanagementgroup.com.


54   | AUGUST2008                                                                                         moderncontractorsolutions.com
systems that could create a hazard when activated, the             what types of permits are required for specific work, and who
 company will need to provide details of how it will provide        will oversee safety during those activities.
 protection. Simply stating that it will use a lockout and tagout
 program isn’t enough; it is necessary to spell out how it works    9. Material Safety Data Sheets
 and show evidence that it has been explained to the affected       This was mentioned under the Hazard Communications
 workers.                                                           Program, but it bears repeating. Companies need to be
                                                                    sure that they have an MSDS for every chemical on-site or
 6. Excavation and Trenching Oversight                              available quickly from the home office. If there is an incident
 If a company’s crews will be involved in excavation or             involving a specific material, the company can expect OSHA
 trenching, or if they’ll work in areas affected by another         to request the MSDS. In other inspections, they’ll probably
 contractor’s excavation or trenching activities, OSHA will         focus on how the sheets are being maintained and whether
 expect to see written documentation of safety procedures. In       they are accessible to employees.
 addition, depending on the nature of the work, the company
 may need to provide written logs to verify that proper             10. Hazard Assessment
 inspection procedures are being followed.                          A formal hazard assessment identifies jobsite hazards that
                                                                    require the use of personal protective equipment, and OSHA’s
 7. Fall Protection                                                 expectations for documentation will depend largely on the
 Here again, if the situations workers will experience require      nature of the site and the activities. In some cases, they’ll
 the use of fall protection, OSHA will want to see a written        simply want to see that the company has a program in place.
 program that explains the nature of the protective gear and its    In others, they’ll expect written documentation that hazards
 use. They may also ask to see records of specific training for     are identified, and proper equipment and training are provided
 fall protection equipment.                                         each day.

 8. Confined Space                                                  OnE ExTRA POinT
 As with excavation and fall protection, if anyone under the        While it is important to have the right information on hand,
 company’s supervision will be working in a confined-space          and to be responsive when the OSHA inspector asks for more
 situation, OSHA will expect to see a written safety program.       detail or clarification, never feel compelled to volunteer
 That program should spell out the training for entry teams,        information that the inspector has not requested.




moderncontractorsolutions.com                                                                                          AUGUST2008     | 55

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OSHA_Top_10_Documents

  • 1. SAFETYSOLUTIONS OSHA’S TOp 10 LiST: Documents to Have on HanD By amanda mayer W hen people think of Top 10 lists these days, comedy is the first thing that comes to mind. But if an Occupational Safety and Health Administration (OSHA) inspector arrives on the jobsite, good jokes won’t go very far. Contractors need to prove that their company and employees are serious about safety. One of the best ways to do that is to have all safety documentation and reports up to date and handy when the OSHA inspector asks for them. Below are the 10 documents and reports they ask for most often when visiting construction sites. 1. The OSHA 300 Log OSHA Form 300 is the document used to track injury and illness records if a company has at least 10 employees. It’s one that OSHA nearly always requests, so it’s important to keep it up to date. The supervisor or other team member responsible for keeping the log needs to have a thorough understanding and the hazards that workers may encounter. For example, of what constitutes recordable injuries or illnesses, so that the if there will be excavation on the site, OSHA will expect company is not recording any that don’t belong there. evidence that workers have participated in excavation safety training. 2. Hazard Communications Program The inspector will probably check to see that the company has 4. Emergency Action Plan a written Hazard Communications Program, and verify that it What are workers supposed to do if a fire breaks out or a covers all of the required elements. This plan should address funnel cloud bears down on the work site? The company’s workplace hazards, where employees can access Material Safety Emergency Action Plan is supposed to spell out the actions Data Sheets (MSDS), and how hazards are going to be labeled workers should take when confronted by situations like those. on the jobsite, as well as how the company’s training program Generally speaking, the contractor that is in control of the site will address these issues. is required to develop the plan, so if a company is one of the subcontractors or another party, it will need to demonstrate 3. Training Records that its team is familiar with the plan. While there isn’t an easy standard for these records, rest assured that OSHA is going to want to see proof that the company is 5. Lockout and Tagout Program providing the training that’s appropriate for the work it is doing If crews are going to work around electrical or mechanical amanda mayer joined safety management Group in June 2006 and currently serves as Aboutthe a safety advisor in the safety services Group. safety management Group is a nationwide professional service organization that provides workplace safety consulting, training, Author staffing, and program planning. For more information, please call 800.435.8850, e-mail amandamayer@safetymanagementgroup.com, or visit www.safetymanagementgroup.com. 54 | AUGUST2008 moderncontractorsolutions.com
  • 2. systems that could create a hazard when activated, the what types of permits are required for specific work, and who company will need to provide details of how it will provide will oversee safety during those activities. protection. Simply stating that it will use a lockout and tagout program isn’t enough; it is necessary to spell out how it works 9. Material Safety Data Sheets and show evidence that it has been explained to the affected This was mentioned under the Hazard Communications workers. Program, but it bears repeating. Companies need to be sure that they have an MSDS for every chemical on-site or 6. Excavation and Trenching Oversight available quickly from the home office. If there is an incident If a company’s crews will be involved in excavation or involving a specific material, the company can expect OSHA trenching, or if they’ll work in areas affected by another to request the MSDS. In other inspections, they’ll probably contractor’s excavation or trenching activities, OSHA will focus on how the sheets are being maintained and whether expect to see written documentation of safety procedures. In they are accessible to employees. addition, depending on the nature of the work, the company may need to provide written logs to verify that proper 10. Hazard Assessment inspection procedures are being followed. A formal hazard assessment identifies jobsite hazards that require the use of personal protective equipment, and OSHA’s 7. Fall Protection expectations for documentation will depend largely on the Here again, if the situations workers will experience require nature of the site and the activities. In some cases, they’ll the use of fall protection, OSHA will want to see a written simply want to see that the company has a program in place. program that explains the nature of the protective gear and its In others, they’ll expect written documentation that hazards use. They may also ask to see records of specific training for are identified, and proper equipment and training are provided fall protection equipment. each day. 8. Confined Space OnE ExTRA POinT As with excavation and fall protection, if anyone under the While it is important to have the right information on hand, company’s supervision will be working in a confined-space and to be responsive when the OSHA inspector asks for more situation, OSHA will expect to see a written safety program. detail or clarification, never feel compelled to volunteer That program should spell out the training for entry teams, information that the inspector has not requested. moderncontractorsolutions.com AUGUST2008 | 55