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Frequent work site inspections should be conducted by competent persons and should include inspections of equipment and all materials to be used in construction. Employee should be required to report unsafe conditions to their supervisors promptly, and any unsafe practices identified should be immediately corrected.

Safety and health programs should require frequent (daily) and regular (weekly or monthly) inspections of job sites, buildings, plants, material, equipment, tools and surrounding environment. Safety inspections should be conducted only by competent and qualified personnel. Follow-up inspections should be conducted and documented. Detailed written inspection records should be maintained.

At least weekly, the worksite supervisor or construction manager should conduct worksite safety inspections. The project manager should conduct weekly project inspections for all projects valued at more than $500,000 and at least monthly for projects valued at less than $500,000.

Companies that have developed the most effective safety and health programs require daily inspections because of the possibility of rapid change on construction sites. Companies should also require documentation of the results, along with immediate correction of identified hazardous conditions and unsafe work practices.

Emergency Action/Response Plans

Work is continuous and fast on the construction site. Hazards may develop quite quickly and accidents may involve more than one employee. Therefore, emergency response planning is essential. It is important to make sure the safety and health plan specifically address foreseeable emergencies. They should also require all employees at the site:

  • be made aware of appropriate emergency procedure
  • be trained in these procedures and that the procedures
  • conduct drills or other exercises to ensure effectiveness of procedures

The contractor's safety and health program should consider and incorporate provisions for safely and expeditiously handling possible emergency situations. A written Emergency Response Plan (ERP) should be developed and communicated to all affected employees. The ERP should specify procedures for handling serious injuries, fatalities, structural failures, or other emergencies, including administration of first-aid and other medical treatment. The ERP should be tested to ensure effectiveness. Firefighting and other emergencies should be reviewed during new employee orientation. Emergency telephone numbers and reporting instructions should be posted at the work-site

ERP responsibilities assigned and proper training provided to all employees assigned to handle emergencies. Warning systems should be installed and tested and emergency telephone numbers and reporting instructions posted at the job-site.

At the start of each job, Post the names and locations of nearby emergency medical facilities that should be contacted. All supervisors should be knowledgeable about emergency procedures. Worker training should include training in emergency procedures and location of first-aid facilities.

First Aid/Medical Requirements

Employer should make sure medical personnel are available to provide advice and consultation. Plans to provide prompt medical attention should be developed and implemented prior to project startup. First aid and medical requirements should be addressed in orientation of all employees. First aid supplies should be accessible when required. When medical attention by emergency medical technicians or other professional health care providers can not be given within five minutes, a group of 2 or more employees should be first-aid and CPR certified.

First-aid equipment needs will vary by size and location of job. Individuals who work alone in remote areas should be trained in first-aid. Where fewer than 100 workers/shift, first-aid supplies in the form of one 16-unit kit/25 employees, and at least one employee certified in first-aid per shift. Where 300-1,000 workers are employed, an infirmary equipped to handle outpatient treatment and staffed by nurse or EMT full time. Where more than 1,000 workers are employed, infirmary equipped to handle short-term inpatient care, with ambulance service, and staffed by full-time physician and adequate nursing staff.

Accident Investigation, Reporting, and Analysis

Most safety and health plans for construction sites emphasize the importance of accurate analysis of incidents/accidents to identify trends and determine the root causes of workplace accidents. Some employers require subcontractors to submit historical data related to accidents. The failure to break down injury statistics by contractor and subcontractor can obscure poor safety performance. Maintaining separate statistics for contractors and subcontractors is increasingly practiced in the construction industry. It is also important that a consistent definition of lost-time injuries. All non-injury incidents and accidents, no matter how minor, should be investigated at the worksite. All OSHA 300 recordable injuries and illnesses should be thorough analyzed for root causes.

Employees should be held accountable for reporting injuries and illnesses to the supervisor as soon as possible. Procedures for reporting accidents and incidents are addressed in the orientation for all employees. Supervisor should report injuries and illnesses according to the following suggested schedule:

  • Report and investigate serious accidents immediately. Contractor should conduct a complete, and submit written report of findings.
  • Report and investigate non-serious incidents and accidents as soon a possible. A comprehensive narrative report should be submitted within 3 working days.
  • Report and investigate potentially serious accidents immediately. The equipment and/or work site involved should be secured until an investigation has been completed by the contractor.
  • Report serious injuries to OSHA within 24 hrs when employees have been admitted overnight to a hospital for treatment of injuries.
  • Report fatalities to OSHA within 8 hours.

The safety and health program should contain procedures for investigating, recording and reporting incidents in accordance with OSHA requirements. Procedures for investigating job-related accidents and illness should include root cause analysis. Only a qualified person (safety manager, staff) should be designated to review incident/accident reports to make sure they are accurate and complete.

The senior project supervisor should maintain all accident and illness records for entire project, including records for each Contractor. This should be kept in a daily Project Safety and Health Log. The senior contractor supervisor, or representative, should also ensure all accidents ate investigated and measures implemented to prevent recurrence.

Training/Safety Meetings

The construction employer should make sure construction safety training programs are provided as required by OSHA regulations. The employer should be responsible for employee safety and health training. This should include:

  • Supervisory Training. Supervisors should be competent instructors and should be given supervisory training.
  • Safety Staff. Safety delegates and safety and health committee members should be trained.
  • New-Hire Training. Employees should receive orientation in company's safety policies, craft training, and job-specific training.
  • Job and Site-specific training. Held on a regular basis for review of accidents and hazardous conditions. Pre-Job Meeting: Management and safety staff discuss safety after bid documents are received. Start of Job Meeting: Supervisory personnel review safety plans and delegate responsibilities for safety.
  • Safety meetings. Held regularly with employees for review of safe methods, accidents, and near accidents.

The employer should provide job-specific training. Employees should receive orientation and continuing technical training. Pre-phase training, based on the AHA for that phase, should be conducted and documented for all employees on the affected work crews. When training hazardous procedures and practices, employees should certified as having adequate knowledge and skills to perform. Employees should be allowed to practice the procedure or practice before exposure to hazards.

The intent of OSHA law is that individual knowledge and skills must be determined. To accomplish this written tests should be administered and employees should be given an opportunity to practice skills and demo All safety and health programs, documents, and labels should be provided in the employee's primary language. Each employee should receive training to recognize and avoid job-specific hazards prior to starting a job assignment. On-site training should be provided to those handling specific hazardous materials or tools. Minimum contents of training include, but are not limited to:

  • General contractor safety policies and rules
  • Incident/accident reporting requirements;
  • Emergency response and medical treatment procedures and reporting;
  • Potential and actual worksite hazard reporting and methods to correct
  • Job-specific hazards and control measures.

Weekly safety "tool-box," or "tail-gate" meetings to inform, review and update employees on worksite safety issues should be held and documented. A record of attendance should be adequate for safety meetings. However, technical training should be documented with a formal certification. Monthly safety meetings for supervisors, foremen, and managers should be conducted to cover management-related safety issues.

All safety meetings should include safety and health training, review of past activities, and planning for new/changed operations. Monthly safety meetings should review the effectiveness of the contractor's safety effort, to resolve safety and health problems, and provide a forum for planning safe future construction activities;

On-site supervisors, including foremen, should receive at least an annual 4-hour general review of applicable safety and health requirements. The contractor should provide first-aid training for all contractor foremen so that they maintain current first-aid certification.

All training records should be maintained by the construction contractor on the construction work site

Joint Safety Committees

Construction employers should establish joint management/labor safety committees. Safety committee should be tasked with helping the employer identify, analyze, and evaluate the employer's safety and health programs, plans, procedures, practices. The safety committee should function as an internal consultative team, providing written recommendations for corrective actions and program improvement as necessary.

Safety committees usually carry out regular inspections of the construction site and make recommendations for hazard control. For joint committees to be successful, they should encourage open and candid two-way discussion of health and safety issues. It's important that safety committees have direct-line communications with top management. They should conduct regularly-scheduled committee meetings, use agendas and keep minutes. Committees should communicate safety and health information to employees regularly.

Contractor/Subcontractor Relationship for Safety and Health

The general contractor and subcontractor may make their own arrangements with respect to obligations with the understanding that they are jointly responsible for worksite safety. In no case should the general contractor be relieved of overall responsibility for compliance with OSHA requirements. To the extent that a subcontractor of any tier agrees to perform any part of the contract, he also assumes control and responsibility for complying with OSHA standards. Thus, the general contractor assumes the entire responsibility, and subcontractor assumes responsibility with respect to his portion of the work.

The general contractor should include subcontracted work in Safety and Health Plan as well as measures contractor will take to control worksite hazards. The general contractor should coordinate and control subcontractor work and should specify requirements for subcontractor to carry out Safety and Health Program. The plan should be job-specific and include work performed by subcontractors and measures to control hazards associated with materials, etc., provided by suppliers. The general contractor should review subcontractor safety and health program and history before bidding and during construction to include subcontractor areas in inspections and audits, and to require subcontractors to correct any recognized hazards.

Contractors should include provisions for compliance with OSHA requirements in the terms and conditions of all contracts, subcontracts, and supply contracts. To help do this, the general contractor should:

  • Hold a pre-phase planning meeting for all affected contractors to coordinate and assign responsibility for all activities.
  • Evaluate contractor safety and health programs and monitor their implementation
  • Ensure contractor compliance with ANSI and OSHA standards and abatement of hazardous conditions; and
  • Audit contractor safety and health documents at least monthly.

Contractual and working relationships among employers, contractors, subcontractors and individuals may be quite complex, and lines of authority, reporting relationships, and work activities should be carefully understood by all parties. Efficient and effective coordination is the goal to make sure appropriate attention is paid to worker safety and health.

Greater general contractor responsibility for subcontractor performance in this area is being emphasized lately because on a typical multi-employer construction project it is important that safe practices be required and enforced in a uniform and consistent manner.

General contractors are more likely going to review subcontractor safety and health records. Some contractors require subcontractors to have experience modification rates (MOD) of less than 1.0 to be considered during the bid process. The General contractor may also develop a project-specific safety plan that is binding on all subcontractors. Weekly safety talks with various subcontractor work crews are a common occurrence. Another effective strategy has the general contractor conducting frequent inspections of subcontractor work areas. If work is found to be seriously deficient, the general may actually stop work.

The safety and health manager should monitor and coordinate implementation of general and subcontractor safety and health plans, and ensure that the principles of safety and prevention are applied in a consistent manner. The safety and health manager/coordinator should ensure cooperation between employers, including successive employers on the same site, with a view toward protecting workers and preventing accidents and occupational health hazards.

Source: Various

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Copyright ©2000-2019 Geigle Safety Group, Inc. All rights reserved. Federal copyright prohibits unauthorized reproduction by any means without permission. Disclaimer: This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirement and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency. CertiSafety is a division of Geigle Safety Group, Inc., and is not connected or affiliated with the U.S. Department of Labor (DOL), or the Occupational Safety and Health Administration (OSHA).