Course 618 - Managing Safety and Health: Construction

Worksite Analysis

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The purpose of worksite analysis is to improve the CSMS.

Improving safety on a construction worksite is one of the most important contractor activities. To do this, we need to analyze the ways to identify the hazards on site. Next, we need to compare those hazards with the control methods we know work best. Once we have this information, we can then make improvements.

In this module, we'll study the general steps in the worksite analysis, evaluation and improvement process. Failing to conduct a comprehensive worksite analysis on each worksite is a costly decision on the part of the employer.

Let's take a look at OSHA's Top 10 Most Frequently Cited Violations for Fiscal Year 2020 to get a better idea where to focus our efforts:

  1. Fall Protection - Construction (1926.501)
  2. Hazard Communication (1910.1200)
  3. Respiratory Protection (1910.134)
  4. Scaffolding (1926.451)
  5. Ladders (1926.1053)
  6. Lockout/Tagout (1910.147)
  7. Powered Industrial Trucks- General Industry (1910.178)
  8. Fall Protection- Training (1926.503)
  9. Eye and Face Protection (1926.102)
  10. Machinery and Machine Guarding- General Requirements (1910.212)

Ergonomics is not covered by OSHA. Ergonomic hazards cause back injuries, strains, sprains, and other musculoskeletal disorders. Although there is no OSHA specific rule on ergonomics, it is the cause of most injuries on the worksite: One cause for this is a lack of reporting by injured workers. OSHA may resort to the use of the "General Duty Clause" to cite employers for ergonomics-related violations or issue an ergonomic hazard alert letter.

Check out this short audio clip by Dan Clark of the Safety managers, ATTENTION! Check hazards, provide safety training, and ensure proper use of PPE.

1. Although OSHA cites fall protection requirement violations the most, what is the cause of most injuries on a construction worksite?

a. Eye and face injuries
b. Ergonomic injuries
c. On-site traffic accident injuries
d. Injuries due to excessive noise
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Worksite analysis plan.
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Plan for Worksite Analysis

Worksite analysis is a combination of systematic actions to provide you with the information you need to recognize and understand the hazards and potential hazards of your workplace. We will discuss five important processes in the worksite analysis plan. The first of these important processes should be the baseline survey that helps the employer determine the current status of the CSMS. When planning for a construction worksite analysis, be sure to include at a minimum all the following processes:

  • Comprehensive baseline surveys (insurance inspections, OSHA On-site, etc.)
  • Job Hazard Analyses (JHAs)
  • Hazard identification, both hazardous conditions and exposure to those hazards
  • Analysis of changes in the workplace (new equipment, new processes)
  • Regular site safety and health inspections (employee and management)

2. Which of the many worksite analysis processes should be the first to be conducted?

a. Identification of energy sources
b. The baseline survey
c. Injury and illness trend analysis
d. Job Hazard Analysis

The Comprehensive Baseline Survey

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Conduct an initial baseline survey first.
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A comprehensive hazard survey is the most basic of all the tools used to establish the inventory of hazards and potential hazards at the worksite. After a baseline has been established, periodic comprehensive surveys need to be done to take advantage of new information about hazards or the introduction of new hazards into the workplace. Each time there is a change of facilities, equipment, processes or materials in your workplace, they should be analyzed for hazards before they are introduced. Ideally, auditing segments of the survey should be assessed for continuous improvement.

The baseline survey should include a review of the following:

  1. copies of written inspections and surveys by: fire department, in-house as required by safety and health standards (e.g., overhead crane inspections, powered industrial truck daily inspection, etc.);
  2. employee report of hazards or potential hazards;
  3. accident and incident investigations with corrective actions and follow-up;
  4. injury and illness trend analysis;
  5. personal protective equipment assessment;
  6. ergonomic analysis;
  7. specific identification of confined spaces; and
  8. identification of energy sources for specific machines.

As part of the worksite analysis process, the employer/general contractor should also require subcontractors to perform a baseline analysis as necessary in accordance with OSHA and company requirements. The subcontractors should share pertinent information with the general contractor, and/or other subcontractors.

3. When should analysis occur after the initial baseline survey?

a. When OSHA requires it
b. When the project if finished
c. At least annually
d. Anytime there is a change

Identifying Hazards and Exposure

Do you see any hazardous conditions in this image?
Both physical and environmental exposure is mitigated here.

A very important part of the hazard identification process is to look for the hazardous conditions, themselves, and the circumstances which may result in exposure to hazardous conditions. To have an event that results in an injury or illness, a hazard and exposure to the hazard must exist. So, let's briefly look at the two concepts:

  1. A hazard is an unsafe condition that could cause injury or illness to an employee. Examples include an improperly guarded power saw, an exposed electrical circuit, or an employee who is under the influence of a dangerous drug.
  2. Exposure usually refers to an employee's placement relative to the hazard's "danger zone". If the employee is within the danger zone, the employee is exposed. There are two types of exposure: Physical and Environmental.
    • Physical exposure means the employee is within arm's length of the hazard. For instance, an employee who came into contact with a sharp object and was cut, had physical exposure to the hazard.
    • Environmental exposure means the employee may come in contact with the hazard no matter where he or she is located. If an employee entered a confined space that lacked an adequate oxygen level, and lost consciousness, he or she experienced exposure to a hazardous environment.

When analyzing the construction worksite, it's important we don't just look for hazardous conditions. We also need to identify potential opportunities for exposure to the hazard's conditions.

The following is a list of topics relevant to worksite analysis by identifying worksite hazards:

  • Evaluate operations, procedures, facilities, and equipment to identify hazards.
  • Monitor exposure levels.
  • Conduct regular safety inspections and accident investigations.
  • Determine hazard control strategies to eliminate or mitigate hazards and exposure.

4. When a construction worker suffers an injury as a result of an unguarded saw, what type of exposure has occurred?

a. Physical exposure
b. Environmental exposure
c. Psychological exposure
d. Unnecessary exposure

Recognized and Foreseeable Hazards

Do you see any hazardous conditions in this image?
Both industry- and employer-recognized hazards on this site.

When conducting the worksite analysis, it's important to look for hazards that are generally recognized within the construction industry. Recognized hazards are generally foreseeable on the worksite OSHA will require that these hazards are properly eliminated or controlled.

"Recognized" Hazards

As described in OSHA's Field Operations Manual, recognition of a hazard is established based on industry recognition, employer recognition, or "common sense" recognition criteria.

  • Industry Recognition: A hazard is recognized if the employer's industry recognizes it. Recognition by an industry, other than the industry to which the employer belongs, is generally insufficient to prove industry recognition. Although evidence of recognition by the employer's specific branch within an industry is preferred, evidence that the employer's industry recognizes the hazard may be sufficient.
  • Employer Recognition: A recognized hazard can be established by evidence of actual employer knowledge. Evidence of such recognition may consist of written or oral statements made by the employer or other management or supervisory personnel
  • Common Sense Recognition: If industry or employer recognition of the hazard cannot be established, recognition can still be established if it is concluded that any reasonable person would have recognized the hazard. This argument is used by OSHA only in flagrant cases. Note: Throughout our courses we argue that "common sense" is a dangerous concept in safety. Employers should not assume that accidents in the worksite result from a lack of common sense.

5. Which of the following types of "recognition" is used by OSHA in citing employers is used only in flagrant cases?

a. Industry Recognition
b. Sector Recognition
c. Common Sense Recognition
d. Employer Recognition

The Five Workplace Hazard Categories

Do you see any hazardous conditions in this image?
Do you see imminent danger in this image?

To help identify workplace hazards categorize them into easy-to-remember categories. The first three categories represent hazardous physical conditions that, according to SAIF Corporation, account for only 3% of all workplace accidents. The fourth category describes behaviors in the workplace which may contribute up to 95% of all workplace accidents. The last category, the system, contributes to both the hazardous conditions and unsafe behaviors. If you consider both the surface and root causes for accidents, failures in the CSMS are ultimately responsible for most accidents in the workplace.

  1. Materials: Hazardous materials include hazardous:

    • Liquid and solid chemicals, such as acids, bases, solvents, and explosives. The hazard communication program is designed to communicate the hazards of chemicals to employees, and to make sure they use safe work practices when working with them.
    • Solids, such as metals, wood, and plastics. . Raw materials used to manufacture products are usually bought in large quantities and can cause injuries or fatalities in many ways.
    • Gases, such as hydrogen sulfide and methane. Gas may be extremely hazardous if leaked into the atmosphere. Employees should know the signs and symptoms related to hazardous gases in the workplace.
  2. Equipment: This area includes machinery and tools used to produce or process goods. These examples all represent hazardous conditions in the workplace. Hazardous equipment includes machinery and tools.
  3. Environment: This area includes facility design, hazardous atmospheres, temperature, noise, factors that cause stress, etc. Are there areas in your workplace that are too hot, cold, dusty, dirty, messy, wet, etc. Is it too noisy, or are dangerous gases, vapors, liquids, fumes, etc., present?
  4. People: This area includes unsafe employee behaviors at all levels in the organization such as taking short cuts, not using personal protective equipment, and ignoring safety rules.
  5. System: Every company has, to some degree, a CSMS. It's good to think of the "state" of the CSMS as a condition. For instance, management may develop and implement ineffective policies, procedures and safety rules. A flawed CSMS is a systemic hazardous condition because it could increase the number accidents.

Note: To remember the five categories, just use the acronym "MEEPS" (Materials, Equipment, Environment, People, System).

6. Which hazard category is ultimately responsible for most accidents?

a. Equipment
b. System
c. People
d. Materials

Job Hazard Analysis (JHA)

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Prepare a JHA for each hazardous task.

A Job Hazard Analysis (JHA) is a technique that focuses on job tasks to identify hazards before they occur. It focuses on the relationship among the worker, the task, the tools, and the work environment. Ideally, after you identify uncontrolled hazards, you will take steps to eliminate or reduce them to an acceptable risk level.

A JHA should be conducted for all hazardous jobs/procedures to determine potential hazards and identify methods to reduce exposure to those hazards at construction worksites. Here are the steps in a basic JHA:

  1. List the steps in the job or procedure.
  2. Describe the safety and health hazards in each step.
  3. Develop preventive measures.
  4. Write a safe job procedure.

Click here to see a sample JHA.

The JHA also serves as an excellent training tool that trainers can use to train hazardous procedures. The step-by-step format is great for on-the-job practice. You can learn more about conducting a JHA in course 706 Job Hazard Analysis.

7. Which of the following should be conducted for all hazardous procedures and tasks on the construction site?

a. Proactive accident investigation
b. Job Hazard Analysis (JHA)
c. Phase Hazard Analysis (PHA)
d. Employee interviews and surveys

Change Analysis

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In construction, the only constant is change.

As you know, change is continuous on a construction worksite. Change analysis is simply the management of that change, conducted by competent persons, to make sure it does not introduce new hazards or unsafe procedures in the work environment.

A designated person should analyze how changes on the worksite can affect equipment, processes, and materials for hazards and potential hazards. Findings should be documented and plans developed to minimize or design out the new hazards.

Changes in the following categories need to be reviewed:

  1. worksite layout
  2. materials
  3. process technology
  4. equipment

To more specifically analyze how changes worksite layout, materials, processes and equipment, affect the work being conducted, include the following in your analysis:

  • emergency routes
  • site entrance and traffic routes/surfaces
  • covered walkways
  • protection from falling objects
  • danger areas
  • storage and personnel areas
  • hazardous materials/dangerous goods
  • barriers and fences
  • loading and unloading areas
  • bays and ramps
  • working slopes for excavators, dump trucks etc.
  • safety signage
  • protection of pedestrians
  • site security
  • housekeeping and cleanliness

8. Change analysis should be conducted in each of the following categories EXCEPT _____.

a. weather conditions
b. materials
c. process technology
d. equipment

Safety Inspections and Reports

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The inspection process is important in identifying hazards.

Employees play a key role in identifying, controlling, and reporting hazards that may occur or already exist in your workplace. Safety inspection reports of potential hazards can be an effective tool to trigger a closer look at a piece of equipment, operation, or how work is being performed. The only caveat related to safety inspections is that, although, they may be good at uncovering hazardous conditions, they are not so good at uncovering unsafe behaviors. Reports of potential hazards can also provide suggestions to eliminate a hazard.

There are many positive reasons for conducting safety inspections, including:

  • helping ensure compliance with OSHA and meet other legal responsibility
  • involving both management and employees
  • identifying areas of high risk and controlling hazards
  • developing positive attitudes - demonstrating leadership
  • suggesting better methods of doing procedures safely

9. Safety inspections are better at uncovering hazardous conditions than _____.

a. lack of common sense
b. actual OSHA violations
c. unsafe behaviors
d. system weaknesses

Controlling Hazards and Exposure

The Hierarchy of Controls
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Information obtained from the various hazard analysis processes is most useful when hazard control strategies are developed and incorporated into the worksite. It's important to recognize that not all hazard control strategies are equal. Some are more effective than others at reducing the risk in the job.

Remember, a very basic hazard control principle is that we must either (1) eliminate the hazard or (2) control exposure to the hazard. The second principle is that it's more effective to eliminate the hazard, if you can, than to control exposure to the hazard. After all, if you can get rid of the hazard, you don't have to manage the exposure. These two important principles help guide safety and health professionals in constructing a "hierarchy" of hazard control strategies.

Traditionally, a hierarchy of controls has been used to determine how to implement feasible and effective controls. ANSI Z10, Occupational Health and Safety Management Systems, encourages employer employ the following hierarchy of hazard control strategies:

  • Elimination and substitution, while most effective at reducing hazards, also tend to be the most difficult to implement in an existing process. If the process is still at the design or development stage, elimination and substitution of hazards may be inexpensive and simple to implement. For an existing process, major changes in equipment and procedures may be required to eliminate or substitute for a hazard.
  • Engineering controls are used to remove a hazard or place a barrier between the worker and the hazard. Well-designed engineering controls can be highly effective in protecting workers and will typically be independent of worker interactions to provide this high level of protection. The initial cost of engineering controls can be higher than the cost of administrative controls or personal protective equipment, but over the longer term, operating costs are frequently lower, and in some instances, can provide a cost savings in other areas of the process.
  • Warnings, administrative controls and personal protective equipment are frequently used with existing processes where hazards are not particularly well controlled. Administrative controls and personal protective equipment programs may be relatively inexpensive to establish but, over the long term, can be very costly to sustain. These methods for protecting workers have also proven to be less effective than other measures, requiring significant effort by the affected workers.

The idea behind this hierarchy is that the control methods at the top of the list are potentially more effective and protective than those at the bottom. Following the hierarchy normally leads to the implementation of inherently safer systems, ones where the risk of illness or injury has been substantially reduced.

10. Which of the following hazard control strategies is best at preventing exposure to hazards?

a. Elimination
b. Administrative controls
c. Best work practices
d. Engineering controls

Include Safety Committees

Safety committees function best when they understand their purpose is to play the role of an internal consultant to the employer. The safety committee can assist by helping the employer analyze and evaluate CSHM programs and making written recommendations to improve the program where applicable.

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Benchmarks are industry best practices defining quality.

Determine the Benchmark

To conduct an evaluation, we need to take the information gathered from the baseline survey and rate it against an established benchmark. A benchmark is a standard by which the system can be measured or judged, for instance, we might say XYZ's CSMS is the "benchmark of quality" in our industry.

OSHA has two excellent partnership programs to help companies achieve their benchmarks:

OSHAcademy and the American Society of Safety Engineers have excellent publications. We recommend purchasing:

11. An industry standard by which all others are judged is called _____.

a. an apogee
b. an apex
c. a benchmark
d. a top rung

Improving Hazard Controls

Deming's PDSA Improvement Process
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Dr. W. Edwards Deming is considered by most to be the father of Total Quality Management and Continuous Improvement. His PDSA Cycle uses a systematic series of steps to gain data for the continual improvement of a product or process. The process is called a "cycle" because the steps are continually repeated. As the image to the right shows, the PDSA Cycle contains four primary steps. These four steps may be used when improving the worksite through the use of hazard controls as follows:

  1. Plan: The first step is to plan the design and development of the hazard control strategy. Base your design on objective facts about the hazard and best practices within the industry to eliminate or mitigate the hazard.
  2. Do: Next, implement the control strategy in a limited manner. This is done to limit the "damage" should the control strategy not work. If you have many facilities, implement the control strategy in one facility (unless an imminent danger situation exists).
  3. Study: Analyze the change in work to see if the control strategy has improved the process or work area. Once you have the data, discuss the results objectively.
  4. Act. If the control strategy works, then adopt and deploy it to all relevant worksites. If it doesn't work, revise the strategy by making small changes or throw it out completely and start over. It is also important to conduct follow-up analysis by moving on once again to the first step of the cycle.

Each of the four steps in the PDSA Cycle are important and must not be skipped.

12. What is the correct action to take if hazard control did not work as anticipated?

a. Hope that others do not find out
b. Use it since time was spent developing it
c. Revise it or throw it out
d. Stop the process because it's not working

Check your Work

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Final Exam
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