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OSHA's Big Four
IN 1994, OSHA made a big change in how it inspects construction job sites. Previously, construction inspections were comprehensive in scope, addressing all areas of the workplace and, by inference, all classes of hazards. This may have forced compliance officers to spend too much time and effort focusing on a few projects looking for all violations--and too little time overall on many projects inspecting for the hazards most likely to cause fatalities and serious injuries to workers.
Previously, a contractor was likely to be cited for hazards that were unrelated to the four leading causes of death that make up 90 percent of all construction fatalities:
1. Falls from elevations
2. Struck by
3. Caught in/between
4. Electrical shock
Quoting from OSHA's Letter of Interpretation of Aug. 22, 1994, Guidance to Compliance Officers for Focused Inspections in the Construction Industry: "Although these 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. The goal of OSHA's construction inspections is to make a difference in the safety and health of employees at the worksite."
This new direction in inspections is called the “Focused Inspection Initiative.” The goal of focused inspections is to reduce injuries, illness, and fatalities in those top four hazards. When deciding whether to conduct a focused inspection, OSHA compliance officers will determine whether there is project coordination by the general contractor and prime contractor.
The officers will look at two factors:
• Is there an adequate safety and health program or plan?
• Is a designated competent person responsible for, and capable of, implementing the program or plan?
OSHA compliance officers will conduct comprehensive inspections only on those projects where there is inadequate contractor commitment to safety and health.
Since 1994, the Focused Inspection Initiative has been a driving force in how OSHA inspections are done.
Falls from floors, platforms, and roofs are the leading cause of construction workers' fatalities. Each year, several hundred workers die and thousands are injured as a result of falls at construction sites. Special trade contractors, such as roofers, carpenters, and structural steel erectors, are especially vulnerable to this hazard.
Fall protection rules
The requirements for fall protection in construction are spread throughout the 1926 standard. The subparts that regulate fall protection are:
• Subpart M: Fall Protection
• Subpart L: Scaffolding
• Subpart N: Cranes, Derricks, Hoists, Elevators, and Conveyors
• Subpart R: Steel Erection
• Subpart S: Underground Construction, Caissons, Cofferdams, and Compressed Air
• Subpart E: Personal Protective and Life Saving Equipment
• Subpart V: Power Transmission and Distribution
• Subpart X: Stairways and Ladders
OSHA's fall protection rules cover most construction workers. OSHA exempts those who inspect, investigate, or assess workplace conditions prior to the actual start of work or after all work is done. This exemption applies because their exposure to fall hazards is for very short durations, if at all.
OSHA identifies areas or activities where fall protection is needed. These include:
• Ramps, runways, and other walkways
• Hoist areas
• Formwork and reinforcing steel
• Leading edge work
• Unprotected sides and edges
• Overhead bricklaying and related work
• Roofing work
• Precast concrete erection
• Wall openings
• Residential construction
• Other walking/working surfaces
What is the threshold height?
The threshold height is that height where you must provide fall protection for the areas or activities previously described above. For the construction industry, the threshold height is 6 feet. When you have employees working at or above this level, you must provide the equipment and training to protect them.
Selection of equipment
You have to select fall protection measures and equipment to fit the type of work being done. The three most common methods of providing fall protection are guardrails, personal fall arrest systems, and safety nets.
OSHA requires that you provide workers with training, done by a competent person, any time they are exposed to fall hazards. The training must include:
• Recognizing and minimizing fall hazards
• Procedures for erecting, maintaining, disassembling, and inspecting the fall protection equipment
• An understanding of the applicable OSHA fall protection rules.
"Struck by" is the second category among OSHA's big four hazards. These hazards include being hit by vehicles, heavy equipment, flying objects, or falling materials.
Working around heavy construction equipment can be very dangerous. Bulldozers, dump trucks, cranes, backhoes, and forklifts are all capable of enormous amounts of work. They are also capable of killing or injuring employees working nearby.
Here are some important steps you and your employees can take to protect yourselves when working around heavy construction equipment:
• Don't assume the operator can see you. If you're out of the operator's line of sight, he/she may not know you're there.
• Never cross the path of a backing vehicle. Keep your eye on the equipment at all times.
• Stay away from heavy equipment when it's operating. Don't walk next to it: It could turn suddenly and hit you, or the load it's carrying could shift and fall on you.
• Don't touch any construction equipment operating near power lines or other electrical equipment. You could be electrocuted if it accidentally makes contact with the hazard.
• Never walk under a load that is being moved by a crane or forklift.
• Never ride on any construction equipment unless you're completely inside the cab and there's plenty of room for the operator to do his/her job.
• Be aware of the swing radius of cranes and backhoes and do not enter that zone.
Employees can be hit by flying objects, such as nails from a powder-actuated tool, pieces of metal from grinding operations, and chunks of concrete from pavement-breaking work.
For employees using nail guns, you have to:
• Train employees using powder-actuated tools in the operation of the particular tool.
• Avoid nailing into materials easily penetrated unless those materials are backed by a substance that will prevent the nail from passing completely through and creating a flying missile hazard on the other side.
• Provide eye protection to operators and assistants using powder-actuated tools.
Regarding the grinding operation and pavement breaking, you should assess the hazards of the job and provide the proper personal protective equipment.
It's no wonder employees are struck by falling material, tools, or equipment when work is being done simultaneously at different heights. To prevent these types of accidents, do the following:
• Inspect and maintain rigging and equipment in a safe operating condition as required by general provisions of OSHA's standards.
• Erect toeboards, screens, or guardrail systems to prevent objects from falling from higher levels.
• Erect a canopy structure and keep objects that could fall far enough from the edge of the higher level so those objects would not go over the edge if they were displaced.
• Barricade the area, prohibit employees from entering the barricaded area, and keep objects that may fall far enough away from the edge of a higher level so those objects would not go over the edge if they were displaced.
The third category is "caught in or between." The types of hazards in this category include being:
• Caught in machinery
• Buried in a trench/excavation collapse
• Pinned between equipment and a solid object, such as a wall or another piece of equipment
• Crushed by heavy equipment after the equipment tips over
• Buried by scaffolding that collapsed
• Crushed by a falling wall during demolition operations.
Here are some important steps you and your employees can take to protect yourselves from these hazards:
• Install guards on moving parts of equipment with which employees may come into contact.
• Shore, slope sheet, or brace sides of trenches dug in unstable material. There must be a means of escape from a trench, such as a ladder. Trench work is to be inspected daily by a competent person.
• Instruct each employee on the danger of passing between swinging superstructures of large construction equipment and solid objects at the job site.
• Provide seat belts in material handling equipment that has rollover protective structures.
• Have a competent person inspect scaffolds and scaffold components for visible defects before each work shift and after any occurrence that could affect the scaffold's structural integrity.
• Except for authorized persons, anyone not involved with the demolition work in progress must be prohibited from being in a demolition area.
Common electrical hazards are caused by overhead power lines, defective power tools and cords, and improperly installed outlets and temporary wiring. Protecting employees from electrical hazards is essential to prevent accidents.
According to OSHA, protective methods that may be used on your job site include:
• Circuit protection devices
• Personal protective equipment.
Circuit protection devices
At construction sites, the most common electrical hazard is the ground fault electrical shock. OSHA requires every company to provide either:
Ground fault circuit interrupters (GFCIs) for receptacle outlets, or
• An assured equipment grounding conductor program.
Either method will eliminate ground fault electric shock hazards.
Circuit protective devices, such as fuses, circuit breakers, and GFCIs, automatically limit or shut off current flow during a ground fault, overload, or short circuit in a wiring system. Fuses and circuit breakers protect conductors and equipment. They prevent overheating of wires and components that could create hazards and open the circuit under certain hazardous ground fault conditions.
It's important that employees check their equipment daily for insulation breakdown. Things to look for are broken or exposed wires and scuffed insulation on extension cords. Wearing insulated non-conductive gloves and shoes is important. Non-conductive coatings on tool handles also aid in insulating from electrical shock.
OSHA requires that live parts of electrical equipment operating at 50 volts or more be guarded to avoid accidental contact. Entrances to areas with live electrical parts must be marked with warning signs. The signs should forbid entrance except by qualified persons.
Grounding protects everyone from electrical shock, safeguards against fire, and protects electrical equipment from damage. There are two kinds of grounding:
• Service or system ground, where one wire, the neutral conductor, is grounded. This type of ground is designed to protect machines, tools, and insulation.
• Equipment ground, which provides a path for current from a tool or machine to ground. This safeguards the operator in the event of a malfunction.
Personal protective equipment
If your employees work where there are electrical hazards, you must provide them with appropriate electrical protective equipment.
Thoughts to Take With You
Effective in 1994, the Focused Inspections Initiative was a significant departure from the way OSHA previously conducted inspections. The initiative directs OSHA compliance officers to concentrate, while doing inspections, on the four construction hazards (falls, struck by, caught in/between, and electrical shock) that account for the most fatalities and serious injuries.
Firm data aren't available on how many lives have been saved because of the initiative. However, employees surely now have a better chance of going home safe at the end of the day.
This article originally appeared in the June 2007 issue of Occupational Health & Safety.