OSHA: "Focused Construction Enforcement Policy" OSHA's recently initiated "Focused Construction Enforcement Policy" limits the scope of job site inspections to four major hazard areas when the controlling employer has an effective safety and health program, and a competent person to implement the program
The purpose of the focused construction inspection policy is to keep compliance officers focused on the job sites where fatalities are most likely to occur. This policy will reduce the number of citations and fines given for violations such a incomplete material safety data sheet files, incomplete written hazard communication programs, improper container labeling lack of OSHA posters and other such violations.
The OSHA program includes the following elements:
∗ OSHA will continue to target job sites for inspections as it always has through fatality reports, employee complaints referrals from other agencies, a general schedule and random selection.
∗ When the compliance officer arrives on the site, he or she will start the process by conducting an opening conference with the controlling employer.
∗ At the opening conference the compliance officer will determine whether the controlling employer has an effective safety' and health program and a competent person to implement the program by viewing the written safety and health program, and by interviewing the controlling employer.
∗ If the compliance officer is not satisfied with the safety and health program or competent person, a full scale inspection will be conducted.
∗ If the compliance officer is satisfied with the safety and health program and competent person, a second opinions conference will be conducted with the other contractors and subcontractors on the site to let them know the inspection will focus on four hazard areas,
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including fall hazards, electrical hazards, struck by hazards, and caught in between hazards.
∗ If serious hazards are found in any of these areas, the compliance officer may at his or her discretion conduct a full scale inspection.
∗ If no hazards are found, or only non-serious hazards are found but abated immediately, no citations will be issued and the compliance officer will leave the site immediately.
∗ At a minimum the contractor's safety and health program will have to be written and show:
• Management Commitment
• Worksite Hazard Analysis
• Hazard Prevention and Control
• Safety and Health Training
• "Employee Participation" (“Employment participation" has not been determined by OSHA at this time)
∗ States such as Minnesota with state plans are not required to use the enforcement policy, however, OSHA is encouraging them to do so. It is anticipated that most of the state plan states will utilize the policy.
∗ OSHA will begin training its compliance officers to carry out the new policy in the near future, and likely be prepared to implement the new policy nationwide by Spring 1995.
Introduction To OSHA Standards The purpose of this discussion is to provide you with the information you will need in order to apply the OSHA standards to hazards in the workplace.
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Origin of OSHA Standards Before we proceed brief look at the origin of the OSHA standards. Initially, the OSHA standards were taken from three sources: consensus standards, proprietary standards, and federal laws in effect when the Occupational Safety and Health Act became law.
Consensus Standards are developed by industry-wide standard developing organizations and are discussed and substantially agreed upon through consensus by industry. OSHA has incorporated the standards of the two primary standards groups, American National Standards Institute (ANSI) and the National Fire Protection Association (NFPA), into its set of standards.
An example, ANSI Standard B56.1-1969, Standard for Powered Industrial Trucks, covers the safety requirements relating to the elements of design, operation and maintenance of powered industrial trucks.
Another census standard source was the NFPA standards. NFPA No. 30-1969 Flammable and Combustible Liquids Code was the source standard for Part 1910, Section 106. It covers the storage and use of flammable and combustible liquids with flash points below 200°F.
Proprietary standards are prepared by professional experts within specific industries, professional societies, and associations. The proprietary standards are determined by a straight membership vote, not by consensus.
An example of these would be the "Compressed Gas Association, Pamphlet P-l, Safe Handling of Compressed Gases." This proprietary standard covers requirements for safe handling, storage and use of compressed gas cylinders.
Some preexisting federal laws are enforced by OSHA, including the Federal Supply Contracts Act (Walsh-Healey); the Federal Service Contracts Act (MidAmerica-O'Hara); the Contract Work Hours and Safety Standards Act b(Construction Safety Act); and the National Foundation on the Arts and Humanities Act. Standards issued under these Acts are now enforced in all industries where they apply.
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Horizontal and Vertical Standards
Standards are sometimes referred to as being either horizontal or vertical" in their application. Most standards are horizontal or “general” which means they apply to any employer in any industry. Standards relating to fire protection, working surfaces and first aid are examples of horizontal standards.
Some standards, though, are relevant only to a particular industry, and are called vertical, or particular standards. Examples are standards applying to the longshoring industry or the construction industry and to the special industries covered in Subpart R of 1910.
Code of Federal Regulations
Probably one of the most common complaints from people having to use the Code of Federal Regulations is "how do you wade through hundreds of pages of standards and make sense out of them?" From time to time you may have experienced this frustration and been tempted to throw the standards in the "round file."
One of our many goals at the OSHA Learning Institute is not only to teach hazard recognition but also to develop an understanding, by the student, of the Code of Federal Regulations system, the format to which the standards are written, and a simplified color coding method for using the code. These aids take a lot of the “fog” out of the standards and make them much easier to comprehend and use.
The Code of Federal Regulations is a codification of the general and permanent rules published in the Federal Register by the Executive departments and agencies of the Federal Government. The Code is divided into 50 titles which represent broad areas subject to Federal regulation. Each title is divided into chapters that usually bear the name of the issuing agency. Each chapter is further subdivided into parts covering specific regulatory areas. Based on this breakdown the Occupational Safety and Health Administration is designated Title 29 Labor, Chapter XVII.
Each volume of the Code is revised at least once each calendar year and issued on a quarterly basis approximately as follows:
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Title 1 through Title 16..................................as of 01 January
Title 17 through Title 27..................................... as of 01 April
Title 28 through Title 41...................................... as of 01 July
Title 42 through Title 50................................as of 01 October
OSHA's regulations (Title 29) are therefore issued as of 01 July. The approximate revision date is printed on the cover of each volume.
The Code of Federal Regulations is kept up to date by the individual issues of the Federal Register. These two publications (the CFR and the Federal Register) must be used together to determine the latest version of any given rule.
To determine whether there have been any amendments since the revision date of the Code volume, in which the user is interested, the following two lists must be consulted the:
• "Cumulative List of CFR Sections Affected" issued monthly
• "Cumulative List of Parts Affected" which appears daily in the Federal Register.
These two lists will refer you to the Federal Register page where you may send the latest amendment of any given rule. The pages in the Federal Register are numbered sequentially from 01 January to 01 January of the next year.
We have discussed the fact that under Title 29, Chapter XVII is set aside for the Occupational Safety and Health Administration. Under Chapter XVII, the regulations are broken down into Parts. Part 1926, for example, is the standard you are all familiar with, "Occupational Safety and Health Standards," commonly known as the "Construction Industry Standards." Under each part, such as Part 1926, major blocks of information are broken down into Subparts. The major Subparts in the 1926 standards include:
Subpart C General Safety and Health Provisions
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Subpart D Occupational Health and Environment
Subpart E Personal Protective and lifesaving
Equipment
Subpart F Fire Protection and Prevention
Subpart G Signs, Signals and Barricades
Subpart H Materials Handling, Storage, Use and Disposal
Subpart I Tools Hand and Power
Subpart J Welding and Cutting
Subpart K Electrical
Subpart L Scaffolding
Subpart M Floors and Wall Openings
Subpart N Cranes, Derricks, Hoists, Elevators and Conveyors
Subpart O Motor Vehicles, Mechanical Equipment and Marine Operations
Subpart P Excavations
Subpart Q Concrete and Masonry Construction
Subpart R Steel Erection
Subpart S Underground Construction, Caissons, Cofferdams and Compressed Air
Subpart T Demolition
Subpart U Blasting and Use of Explosives
Subpart V Power Transmission and Distribution
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Subpart W Rollover Protective Structures; Overhead Protection
Subpart X Stairways and Ladders
Each Subpart is further broken down into sections.
Let's look at one subpart in detail: Subpart D - Occupational Health and Environmental Controls. The index of Subpart D is shown on the next page.
SUBPART D - OCCUPATIONAL AND ENVIRONMENTAL CONTROLS
1926.50 Medical Services and First Aid
1926.51 Sanitation
1926.52 Occupational Noise Exposure
1926.53 Ionizing Radiation
1926.54 Nonionizing Radiation
1926.55 Gases, Vapors, Fumes Dusts and Mists.
1926.56 Illumination
1926.57 Ventilation
1926.58 Asbestos, Tremolite, Anthophyllite and Actinolite
1926.59 Hazard Communication
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Paragraph Numbering System
Title
Code of
Fed. Reg.
Part
Section
29 CFR 1926 .59 (h)
We have now become familiar with some of the basic organization of the construction industry standards. Let’s review some of the terminology we have discussed and relate it to the paragraph numbering system in the Federal Register. We’ll use an example from Section 59 of the 1926 standards.
29 CFR 1926.59 (h)(2)(ii)
Title
Code of
Fed. Reg.
Part
Section
29 CFR 1926 .59 (h)(2)(ii)
Employee training shall include at sical and health
hazards of the chemicals in the work area.
least the phyLower Case Alphabetical
As you can see from this example, the first number 29 stands for the title. Next we have CFR which of course stands for Code of Federal Regulations. Next we have 1926 which is Part 1926. Next you see a period. Following that is an Arabic number which will always be the section number, in this case, Section 59 for hazard communication. If the number was 150, you would relate it to fire protection. Section 451 relates to scaffolding.
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29 CFR 1926.59 (h)(2)(ii)
Title
Code of
Fed. Reg.
Part
Section
29 CFR 1926 .59 (h)
Employee training shall include at least the physical and health hazards of the chemicals in the work area.
Lower Case Alphabetical
Now, let's go to the next breakdown of paragraphs and study the numbering system. As you can see, the first tier of paragraphs beneath the section level will be numbered in parentheses (a), (b), (c), (d) etc., as will all further designations. If you only had three major paragraphs of information under a section, they would be numbered 59(a), 59Cb), 59(c).
29 CFR 1926.59 (h)(2)(ii)
Title
Code of
Fed. Reg.
Part
Section
29 CFR 1926 .59 (h)(2)
Employee training shall include at least the physical and health hazards of the chemicals in the work area.
Lower Case Alphabetical
Arabic Number
The next level of numbering involves the use of Arabic numbers. As an illustration, if there were three paragraphs of information between subheadings (a) and (b), they would be numbered (a)(1), (a)(2), and (a)(3).
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29 CFR 1926.59 (h)(2)(ii)
Title
Code of
Fed. Reg.
Part
Section
29 CFR 1926 .59 (h)(2)(ii)
Employee training shall include at least the physical and health hazards of the chemicals in the work area.
Lower Case Alphabetical
Arabic Number
Lower Case Roman
The next level uses lower case roman numeral. An example would be between paragraphs (2) and (3). If there were five paragraphs of information pertaining to Arabic (2) they would be numbered (2)(i), (2)(ii), (2)(iii), (2)(iv), and (2)(v).
Color Coding Now lets see what we can do to simplify the use of the standards. It is suggested that one thing you can do is color code your standards book. Although there are many ways to do this, we will suggest the method shown below.
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29 CFR 1926.59 (h)(2)(ii)
Title
Code of
Fed. Reg.
Part
Section
29 CFR 1926 .59 (h)(2)(ii)
Employee training shall include at least the physical and health hazards of the chemicals in the work area.
Lower Case Alphabetical
• DOT-YELLOWArabic Number
Lower Case Roman
Pink - Full Column Width
It is suggested that you highlight every section head, full column width, in pink.
All of the subsection headings, that is, the (a), (b), (c), etc., should be colored with yellow full column width. At this point the purpose of color coding becomes more apparent when you realize an Arabic "1" in typeset looks exactly like the lower case alpha letter”," and it is obviously important to differentiate between them. Another situation is the lower case alpha (i) that is the same typeset as lower case roman numeral (i). You should realize the value of this color coding. The next step is to dot yellow all of the Arabic numbers. We can now easily find the beginning of each subsection beginning with a lower case alpha by looking for the horizontal yellow lines. The Arabic number subparagraphs are easily located by the yellow dots. Generally speaking color coding two levels below the section heading will be adequate.
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In summation, you are now prepared to color code those particular sections of the standards that you use frequently. It should also be pointed out that there is a subject index in the back of the standards book. This index can be very helpful to locate specific standards when you pick out a key word from any given hazard description.
If you try to locate information within the standards by using the Table of Contents, remember that the particular Section number contained on each page is printed in the upper corners of that page. Hopefully this information will help you in taking the "fog” out of these standards and also assist you in helping others to understand and better utilize the Occupational Safety and Health Standards.
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Standards
Incorporated by Reference Into
29 CFR 1926 Subpart C
1926.30 Shipbuilding and Ship Repairing
29 CFR 1915 - Ship Repairing
29 CFR 1916 - Shipbuilding
Subpart D
1926.100 Illumination
ANSI A11.1 - 1965, R 1970
Subpart E
1926.100 Head Protection
ANSI Z89.1 - 1969
ANSI Z89.2 - 1971
1926.104 Safety Belts. Lifelines, Lanyards
Federal Specification QQ-P-416
(Type I, Class B)
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Subpart F
1926.150 Fire Protection
NFPA No. 10A-1970 Maintenance and Use of
Portable Fire Extinguishers
1926.152 Flammable and Combustible Liquids
NFPA No. 251-1969 Standard Methods of Fire
Test of Building Construction
and Material
NFPA No. 80-1970 Standard for Fire Doors & Windows
NFPA No. 30-1969 Flammable & Combustible
Liquids code
NFPA No. 13-1969 Standard for the Installation
of Sprinkler Systems
NFPA No. 385-1966 Standard for Tank Vehicles for
Flammable & Combustible
Liquids
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1926.153 Liquefied Petroleum Gas
49 CFR Part 178 Shipping Container
Specifications
Subpart G
1926.200 ANSI D6. 1-1971 Manual on Uniform Traffic
Control Devices and Equipment
ANSI Z35.1-1968 Specifications for Accident
Prevention Signs
ANSI Z35.2-1968 Specifications for Accident
Prevention Tags
1926.201 ANSI D6.1-1971 Manual on Uniform Traffic
Control Devices and
Equipment
Subpart I
1926.300 ANSI B15.1-1953 Safety Code for Mechanical
Power (Revision 1958)
Transmission Apparatus
1926.302 Power Operated Hand Tools Safety Requirements for
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Schedule 30; US Bureau of Mines Explosive-Actuated Fastening
ANSI A10.3-1970 Tools
1926.303 Abrasive Wheels and Tools Safety Code for the Use of
ANSI B7.1-1970 and Protection of Abrasive
Wheels
1926.304 Woodworking Tools Safety Code for Woodworking
ANSI 01.1-61 Machinery
Subpart I
1926.350 Gas Welding and Cutting
49 CFR Part 178 Specifications for Cylinders
(Subpart C)
ANSI Z49.1-1967 Safety in Welding and
Cutting “NEC Article 630,
NFPA 70-1971
ANSI C-1-1971 Electrical Welders
(Revision 1968)
1926-351 Arc Welding and Cutting Minimum Federal Safety
DOT 49CFR192 Standard for Gas Pipelines
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Subpart K
1926.407 Hazardous (Classified Locations)
NEC, NFPA 70
Subpart N
1926.550 Cranes and Derricks Safety Code for Crawler,
ANSI B30.5-1968 Locomotive or SAEJ959-1966
and Truck Cranes
ANSI B15.1-1958 Safety Code for Mechanical
Power Transmission Apparatus
49 CFR 177 and 393; Power Crane and Shovel
Association Mobile
Hydraulic Crane Standard
ANSI B30.6-1969 Safety Code for Derricks
ANSI B30.2-1967 Safety Code for Overhead and
Gantry Cranes
1926.552 Material Hoists, Personnel Hoists and Elevators
ANSI A10.5-1969 Safety Requirements for
Material Hoists
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ANSI A10.4-1963 Safety Requirements for
Workman’s Hoists
ANSI A17.1-1965
A17.1a-1967; A17.16-1968;
A17.1c-1969;d-1970;
A17.2-160; A17.2a-1965;
A17.2-1967 Permanent Elevators
ANSI B20-1-1957 Safety Code for Conveyors,
Cableways, and Related
Equipment
1926.556 Aerial Lifts Vehicle Mounted Elevating and
ANSI A92.2-1969 Rotating Work Platforms
Subpart O
1926.601 49 CFR Part 571 (Department of Transportation
Federal Motor Vehicle
Safety Standards)
1926.602 SAE J386-1969 Seat Belts for Construction
Equipment
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SAE J333a-1970 Operator Protection for
Agricultural and Light
Industrial Tractors
SAE J237-1971 Loader Dozer
SAE J236-1971 Graders
SAE J319b-1971 Scrapers
SAE J166-1971 Trucks
SAE J231a-1970 Fenders for Pneumatic Tired
Earthmoving Haulage
Equipment
1926.602 PCSA No. 1, 2, 3 Power Shovel and Crane
Associations. Standards No. 1
and No. 2-1968, No. 3-1969
ANSI B56.1-1969 Safety Standards for Powered
Industrial Trucks
1926.603 Pile Driving Equipment
ASME Power Boilers (Section I)
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ASME Pressure Vessels (Section VI)
1926.605 29 CFR 1918 Safety and Health Regulations
for Longshoring
Subpart U
1926.902 14 CFR 103 Air Transportation
46 CFR 146-149 Water Carriers
49 CFR 171-179 Highways and Railways
49 CFR 180 Pipelines
49 CFR 390-397 Motor Carriers
26 CFR 181 IRS Storage of Explosives
and Blasting Agents
26 CFR 181 Commerce in Explosives
Subpart V
1926.951 Tools and Equipment
ANSI J6.6-1971 Rubber Insulating Gloves
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ANSI J6.7-1935 Rubber Matting for Use Around
(Revision 1971) Electric Apparatus
ANSI J6.4-1971 Rubber Insulating Blankets
ANSI J6.2-1950 Rubber Insulating Hoods
(Revision-1971)
ANSI J6.1-1950 Rubber Insulating Line Hose
(Revision-1971)
ANSI J6.5-1971 Rubber Insulating Sleeves
ANSI Z89.2-1971 Industrial Protective Helmets for
Electrical Workers (Class B)
Subpart W
1926.1002 Protective Frame (ROPS)-for Wheel type Agricultural and Industrial Tractors Used in Construction
SAE J168-Protective Enclosures, Test (July 1970) Procedures, and Performance Requirements
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Inspecting for Job Safety and Health Hazards
The Mandate The Occupational Safety and Heath act of 1970 seeks to “...assure so far as possible every working man and woman in the Nation safe and healthful working conditions.”
As one way to promote worker protection, the Act authorizes the Occupational Safety and Health Administration (OSHA) to set and enforce safety and heath standards. The agency conducts inspections to make sure these specific standards are met and that the workplace is generally free from recognized hazards likely to cause death or serious physical harm.
The CSHOs OSHA calls its inspectors compliance safety and heath officers (CSHOs). They are experienced professionals whose goal is to help employers and worker reduce on-the-job hazards.
Inspection Priorities Not all of the 6 million workplaces covered by federal and state OSHA's can be inspected. The most hazardous conditions need attention first.
• Imminent Danger: Imminent danger situations have top priority. An imminent danger is a hazard that could cause death or serious physical harm immediately, or before the danger could be eliminated through normal enforcement procedures. When compliance officers find imminent danger conditions, they will ask for immediate voluntary correction d the hazard by the employer w removal of endangered employees from the area If an employer tails to do so, OSHA can go to the nearest federal district court for appropriate legal action.
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• Catastrophes and Fatal Accidents: High priority is also given to investigation of job fatalities and accidents hospitalizing three or more employees. Such accidents must be reported to OSHA immediately and within 24 hours.
• Complaints: OSHA investigates written and signed complaints by current employees or their representatives of hazards that threaten serious physical harm to workers. Complaints, other than imminent danger, received from anyone other than a current employee or employee representative, or unsigned by a current employee, or received anonymously, may result in a letter from the agency to the employer describing the allegation(s) and requesting a response. OSHA will not reveal the name of the person filing the complaint, if so requested.
• Programmed Inspections: OSHA routinely conducts safety and health inspections in high-hazard industries, like manufacturing or constructional me agency develops its general schedule for inspecting the most hazardous industries based on various statistical data, such as job injury/illness rates, worker compensation, and other information.
After entering a workplace in a high/hazard business OSHA inspectors consult and verily the log of injuries and illnesses which all employers with more than 10 employees are required to keep. About five percent of OSHA programmed Inspections focus on firms in low hazard manufacturing industries and an additional five percent in non-manufacturing industries
• Follow-up Inspections: The agency may re-inspect firms cited for imminent danger conditions, or for willful, repeat or serious violations OSHA may also conduct follow-up inspections to check the progress of long term hazard correction programs by employers.
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The Inspection
• CSHO "Homework": To prepare for an inspection, compliance officers become familiar with the history d the establishment, the operations and processes in use, and the standards most likely to apply. They gather all equipment necessary to test for health and safety hazards.
• At the Worksite: When an OSHA inspector arrives, he or she displays official credentials and asks to see the employer. Employers should always insist upon seeing the compliance officer's U.S. Department of Labor credentials bearing their photos and serial number which can be verified by the nearest OSHA office. Employers have the right to require OSHA to obtain a warrant before permitting entry.
• Opening Conference: The compliance officer will explain the nature of the visit, the scope of the inspection and the applicable standards. Information on how to obtain copies of the OSHA regulations will be tarnished. A copy of any employee complaint (edited, it requested', to conceal the employee's identity) will be provided. The employer will be asked to select an employer representative to accompany the compliance officer during the inspection. An authorized representative of the employees, if any, also has the right to go along. The compliance officer will consult with a reasonable number of employees.
• Walk-around Inspection: After the opening conference, the compliance officer and the representatives go through the workplace, inspecting for workplace hazards. When talking with workers, compliance officers will try to minimize work interruptions. The Act prohibits discrimination in any form by employers against workers because of anything they say or show the compliance officer during the inspection or for any other OSHA
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protected safety-related activity. The compliance officer will discuss any apparent violations noted during the walk-around and will offer technical information on how to eliminate hazards.
• Closing Conference: The compliance officer reviews any apparent violations with the employer and discusses possible methods and time periods necessary for their correction. This compliance officer explains that these violations may result in a citation and a proposed financial penalty, describes the employer's rights and responsibilities, and answers all questions.
• Citations: OSHA is required by law to 'issue citations for violations of safety and health standards. The agency is not permitted to issue warnings. Citations include: 1) a description of the violation; 2) the proposed penalty, if any; and 3) the date by which the hazard must be corrected. In most cases the citations are prepared at the OSHA Area Office and are mailed to the employer. Employers have 15 working days after receipt to file an intention to contest OSHA citations before the independent Occupational Safety and Health Review Commission.
• Settlement Agreements: if an employer believes OSHA's citations are unreasonable or wishes for my other reason to discuss the OSHA enforcement action, he or she may request an informal conference with the Area Director to discuss any actions issued. The agency and the employer may work out a settlement agreement to resolve any dispute and to eliminate the hazard.
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PENALTIES 1) $70,000 WILLFUL, REPEAT
2) $7,000 SERIOUS
3) $210,000 FAILURE TO ABATE
4) $5,000 REPORTING FATALITY
5) $3,000 POSTING OF CITATION
6) $1,000 OSHA POSTER,
OSHA 200 LOG
POSTING 200 SUMMARY
MULTI-EMPLOYER POLICY 1 ) EXPOSING
2) CREATING
3) CONTROLLING
4) CORRECTING
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TWENTY-FIVE MOST CITED IOWA OSHA STANDARDS January 1, 1993 - March 31, 1994 Construction Industries Safety And Health Inspections
Number Standard Violated Total Serious Other Repeat Willful
120.6 Right to Know/Employee Training 27 2 25 0 0
120.3(1) Right to Know/Written Program 26 5 21 0 0
120.5(1) Right to Know/Material Safety Data Sheets 17 1 16 0 0
3.1 OSHA Poster 11 0 11 0 0
1926.403(b)(2) Approved Conductors/Installation & Use 11 5 6 0 0
120.3(4) Right to Know/Program Available 10 0 10 0 0
