Construction Project Safety Management Best Practices Handbook

Construction Project Safety Management Best Practices Handbook
Construction Project Safety-Management
Best-Practices Handbook
CONSTRUCTION PROJECT
SAFETY MANAGEMENT BEST
PRACTICES HANDBOOK
Sathyanarayanan Rajendran
and
Mandi Kime
TABLE OF CONTENTS
Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
Chapter 1 – Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Chapter 2 – Overview of the Construction Industry and Safety . . . . . . . . . . . . . . . . . . 3
Chapter 3 – Project Team Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Chapter 4 – Safety in Contracts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Chapter 5 – Pre-Bid and Pre-Construction Meetings . . . . . . . . . . . . . . . . . . . . . . . . . 45
Chapter 6 – Project Safety Staffing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Chapter 7 – Designing for Construction Worker Safety . . . . . . . . . . . . . . . . . . . . . . . 69
Chapter 8 – Use of Modern Technology in Construction Safety Management . . . . . 81
Chapter 9 – Project Safety Startup Guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
Chapter 10 – Construction Site Public Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . 107
Chapter 11 – Construction Site Employee Wellness Program . . . . . . . . . . . . . . . . . . 121
Chapter 12 – Development of Site Specific Safety Plan (SSSP) . . . . . . . . . . . . . . . . 127
Chapter 13 – Job Hazard Analysis & Pre-Task Planning . . . . . . . . . . . . . . . . . . . . . 139
Chapter 14 – Safety Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161
Chapter 15 – Workplace Substance Abuse Program . . . . . . . . . . . . . . . . . . . . . . . . . 185
Chapter 16 – Accident Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197
Chapter 17 – Construction Site Emergency Management . . . . . . . . . . . . . . . . . . . . . 225
Chapter 18 – Employee Recognition Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235
Chapter 19 – Return to Work Program Management . . . . . . . . . . . . . . . . . . . . . . . . 243
Chapter 20 – Construction Work-Related Musculoskeletal Disorders (WMSDS) . . 261
Chapter 21 – Safety Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 271
Chapter 22 – Safety Performance Measurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . 281
Chapter 23 – Construction Site Environmental Management . . . . . . . . . . . . . . . . . . 291
Chapter 24 – Project Commissioning and Turnover . . . . . . . . . . . . . . . . . . . . . . . . . 311
Chapter 25 – Project Safety Records Management . . . . . . . . . . . . . . . . . . . . . . . . . . 315
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ACKNOWLEDGMENTS
Funding and support for this project have been provided by the State of Washington, Department of
Labor and Industries, Safety and Health Investment Projects (SHIP) grant (Grant No. 2013ZH00237).
This project would not have been possible without the hard work and dedication of the project team.
Safety and Health Investment Projects (SHIP), Department of Labor and Industries, State of
Washington
Associated General Contractors of Washington (AGC of WA)
o Mandi Kime, Director of Safety; Coauthor and Grant Project Manager for AGC of WA
o Andrew Ledbetter, Safety Specialist
o Penny Schmitt, Administrative Support
Central Washington University
o Dr. Sathyanarayanan (Sathy) Rajendran, Ph.D. CSP; Author and Grant Project Manager
for CWU
o Heather Harrell, Post-Award Manager, Grant Accounting
o Julie Guggino, Director, Research and Sponsored Programs
The project team would like to thank the construction safety subject matter experts for serving as
chapter peer reviewers. We acknowledge the input of the handbook development committee members
for their valuable input and guidance throughout the development of this handbook. This handbook
would not be possible without their contributions, insight, and advice. We wish to acknowledge the
support we received from the contractors who shared their best practices in the form of pictures,
forms, programs, and processes. We also express our sincere thanks to the safety and health management and construction management students from Central Washington University who assisted with
the data collection.
Handbook Development Committee Members
• Drew Rosenfelt, LEED AP; PSF Mechanical, Inc.
• Jamie Stuart; Valley Electric Co.
• John L. Burdick, PCL Construction Services, Inc.
• Jon Andersen, CSP, CHST, CET; Centennial Contractors Enterprises, Inc.
• Mandi Kime; Associated General Contractors of Washington
• Mark Gauger; G.L.Y. Construction
• Pete Campbell; BNBuilders
iii
Peer Reviewers
• Cole Davis, NOVA Group Inc.
• Chris Grover, CSP, CRIS, RRE; CNA Insurance
• Donna Emmert, CPDM; Zurich Services Corporation
• Drew Rosenfelt, LEED AP; PSF Mechanical, Inc.
• Gavin Banks, Turner Construction Company
• Jamie Stuart; Valley Electric Co.
• Jerry Shupe, CSP; Hensel Phelps Construction Co.
• John Gambatese, Ph.D., P.E., Oregon State University
• John L. Burdick, PCL Construction Services, Inc.
• Jon Andersen, CSP, CHST, CET; Centennial Contractors Enterprises, Inc.
• Keith Dyer, CSP; Walsh Pacific
• Kerry Soileau; Ferguson Construction, Inc.
• Kimberley Gamble, CHST; Andersen Construction
• Mandi Kime; Associated General Contractors of Washington
• Mark Gauger; G.L.Y. Construction
• Melanie Preusser; Zurich Services Corporation
• Mike Andler, CRIS; Central Washington University
• Pete Campbell; BNBuilders
• Rick Zellen, CSP, ARM, CRIS, STS-C; Zurich Services Corporation
Construction Contractors
• Andersen Construction Co., Inc.
• Andgar Corporation
• Balfour Beatty Construction
• BNBuilders
• Exxel Pacific Inc.
• G.L.Y. Construction
• Gary Merlino Construction Company
• Goodfellow Bros., Inc.
• Guy F. Atkinson Construction, L.L.C.
• Hensel Phelps Construction Co.
• Hoffman Construction Company of Oregon
• Hudson Bay Insulation
• Korsmo Construction
• Lydig Construction
• Morley Builders
• NOVA Group Inc.
• PCL Construction Services, Inc.
• PSF Mechanical, Inc.
• Sellen Construction
• SNC-Lavalin
• Turner Construction Company
iv
1
INTRODUCTION
Construction worker safety and health continues to be an important concern for the Washington
construction industry. The industry has consistently experienced higher injury and illness rates
compared to other states. In fact, the 2011 WA construction total recordable case rate per 100 full-time
workers was the highest in the nation (8.7).1 Not only are construction injuries a significant cause of
humanitarian concern, but the high cost associated with these injuries and deaths is also a motivation
for an improved safety performance in the construction industry.
The “technical” causes of injuries and illnesses (e.g. falls) in construction have long been recognized,
and their persistence continues to frustrate construction safety and health practitioners. Improvement
in project safety management practices is needed to lower the level of risk and improve worker safety
and health performance. There is a great deal of knowledge of specific successful management practices,
from pioneering safe companies, which can be used to enhance construction safety and health of the
overall industry.
To prevent injuries, illnesses, and fatalities, many construction contractors have implemented successful
strategies (“best practices”), which are “above and beyond” regulatory compliance that have helped
them improve worker safety and health performance. Even though the construction industry shares
a common goal of creating an injury and incident free work environment on its jobsites, there is no
common medium to share these best practices that will benefit other contractors and the industry as a
whole. These best practices, if shared, can benefit the industry to fulfill its goals of creating an injuryfree work environment on construction sites. Instead of re-inventing the wheel, contractors, who are
interested in improving their safety performance, can implement proven best practices during different
project phases (e.g. Design or Construction) within their projects, thereby improving their project
safety and health performance.
1.1 PURPOSE
The purpose of the Construction Project Safety Management Best Practices Handbook is to provide
comprehensive coverage of best practices from contractors of all phases of a construction project
from project planning, design, project start-up, construction, commissioning, and closeout, in separate
chapters. The handbook also provides various templates of safety planning forms and checklists
(e.g. Pre-construction safety meeting checklist). They can be easily replicated by medium or smaller
companies who otherwise cannot afford to create these tools from scratch. Each chapter has an
“additional resources” section at the end for those who wish to explore more deeply into the topic area.
The handbook’s scope is limited to safety management, administration, and programs in construction.
The handbook’s primary focus is on project safety administration/management programs.
1 BLS (2013).
State Occupational Injuries, Illnesses, and Fatalities, available at http://www.bls.gov/iif/oshstate.htm#WA (accessed 7 October 2013).
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1.2 SCOPE
The handbook is written to meet the needs of project owners, and small and medium-sized contractors
as a ready reference guide for project site safety management. It will also be helpful as a safety
management training manual for entry-level safety, and construction professionals. University and
college instructors can use this handbook as a construction safety management course textbook for
students who are pursuing safety management or construction management degrees.
1.3 REGULATORY JURISDICTION
All regulatory requirements referenced in this handbook are based on Washington Division of
Occupational Safety and Health (DOSH) regulations. However, the handbook contains several safety
management best practices from various contractors in the form of safety forms, checklists, programs,
etc., as exhibits in most chapters. These best practice tools are only included as an example, and the
readers should be aware that these contractors may reference safety regulations depending on their
regulatory jurisdictions. It is the reader’s responsibility to ensure that they adapt the best practices
provided in this handbook for their jurisdiction and comply with all applicable local, state, and federal
regulations affecting their workplace. In addition, please note the materials available in this handbook
are intended to provide general information about the subject matter covered. They are not meant
to provide legal advice. Readers should contact their attorney to obtain advice with respect to any
particular issue or problem.
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2
OVERVIEW OF THE
CONSTRUCTION INDUSTRY AND SAFETY
Construction worker safety continues to be a major concern for the U.S. construction industry. It is
one of the most hazardous industries in the United States, historically employing about five percent
of the country’s workforce, yet has accounted for a disproportionate number of on-the-job injuries.
It is important that readers understand the characteristics of the industry, before reviewing the safety
management best practices that will help them improve worker safety and health performance. Hence,
this handbook included this opening chapter to provide a basic overview of the construction industry
for readers who are unfamiliar with the industry including:
Nature of the construction industry
Industry classification
The construction team
The project life cycle
The project team
Influence of project factors on safety
Safety in the construction industry
2.1 NATURE OF THE CONSTRUCTION INDUSTRY
The construction industry serves the human needs by building new structures and adding to, altering,
repairing, and maintaining existing structures. These structures include but not limited to buildings,
highways, bridges, dams, power plants, refineries, airports, railroads, docks, canals, levees, sewage
treatment plants, and many others. The construction sector is one of the largest of all U.S. industries,
with its total expenditures accounting for typically 6 to 12 percent of the Gross National Product
(GNP). The total annual volume of new construction in the U.S. was $930 billion in 2013.
According to the U.S. Census Bureau, there were 729,345 U.S. establishments that can be classified
as construction firms in 2007, with an average of ten employees per establishment. However, not all
businesses are similar. Some establishments are gigantic, generating revenues in billions of dollars, and
few generate revenues in millions, and a majority generate tens of thousands of dollars. Some firms
engage in international work, but most do business close to their primary office location. Remember
there are very stringent requirements to run a construction business, mainly in the form of contracting
licenses, to ensure public health and safety.
The construction establishments have one of the highest failure rates in the U.S. due to the high risk
involved. Smaller firms have a high failure rate, compared to larger ones. The industry has a very lowprofit margin mainly due to the competitive nature of the industry. During the 2008 recession, some
companies were doing work for less than 1% profit. In addition, the construction industry is cyclic,
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responds quickly to changes in the nation’s economy. The amount of construction work taking place
at any given time is dependent on several factors including government expenditures, business needs,
tax laws, seasonal changes, and others.
A construction firm’s work on each structure is commonly referred to as a “project.” Construction
projects are very complex, especially because each project is unique, and custom-built on the site by,
to some degree, by an entirely different construction team. The workforce engaged in the building of
these projects are classified based on their association with the union as a closed shop or open shop.
A construction firm having a contract with one or more trade unions to employ only union members
is called a closed shop firm. On the other hand, a company that employs workers without regard to
union membership is called an open shop firm. There are companies that use a combination of these
both arrangements.
2.2 INDUSTRY CLASSIFICATION
The construction industry is commonly divided into four broad categories such as residential, building,
engineering, and industrial construction (Table 2-1). While few construction firms specialize in all
these four areas, many companies limit their scope to one or two.
Table 2-1: Four Common Construction Industry Divisions and Example Projects1
Type
Residential
Building
Engineering
Industrial
Examples
Single-family house
Healthcare
Bridges
Refineries
Multifamily house
Offices
Tunnels
Steel mills
Condominiums
Educational
Dams
Power plants
Low-rise apartments
Religious
Levees
Smelters
High-rise apartments Public safety
Market Share
Ownership
40-45 percent
Mostly private
Sewage treatment Chemical plants
Amusement
Water treatment
Nuclear
Recreation
Railroads
Aviation
Government
25-30 percent
Mostly private
Pipelines
20-25 percent
Public
5-10 percent
Private
2.3 THE CONSTRUCTION TEAM
The construction team includes the owner, general contractors, specialty contractors, architects,
engineers, workers, consultants, unions, vendors, suppliers, sureties, lending agencies, regulatory
agencies, other government agencies, insurance companies, attorneys, consultants, and others.
The major stakeholders are the owner, designer (Architect/Engineers (A/E)), general contractor,
subcontractors, and the craft workers.
1 Clough, R.H, Sears, G.A., and Sears, SK. (2005). Construction Contracting – A Practical Guide to Company Management. Seventh Edition.
John Wiley & Sons Inc. New Jersey.
4
2.3.1 Owner
The owner is an individual or entity who initiates, funds and enjoys the benefits of the completed
project. Construction projects are typically classified as privately funded or publicly funded (local,
state, or federal). In 2013, approximately 72% ($664 billion) of construction was privately financed,
and various public agencies funded 28% ($266 billion) of construction. In this handbook, the term
owner is used to designate this role.
2.3.2 Architect / Engineer (A/E)
The A/E, commonly referred to as a designer, performs the design of the construction project. The
architect’s services are predominantly used when designing residential or building projects, and
engineers are commonly used to design industrial and heavy civil projects. Upon the owner’s request,
the designers also provide construction phase services such as, oversee change order management,
perform site inspections, review and approve progress payments and many other functions. In this
handbook, the term designer is used to designate the A/E.
2.3.3 General Contractor (GC)
The general contractor (GC), also known as the prime or controlling contractor, is the construction
firm that is in “contract” with the owner to construct the project, according to the designer’s plans
and specifications. In this handbook, the term general contractor will be used to designate the prime
contractor. While some GC firms will have tradespeople to perform a part of the project scope (e.g.,
concrete scope) called self-performed work, they mostly hire specialized contractors to perform
significant portions of the construction work.
The GC is responsible for completing a successful project by controlling the four crucial project
elements: safety, quality, cost, and schedule. The GC frequently interacts with the designer to implement
the project design, gather and evaluate subcontractor bids, obtain necessary government permits, and
coordinate all subcontractors. The GC can be held liable for the negligence of subcontractors.
2.3.4 Subcontractor
The subcontractor or specialty contractor is also a construction firm that contracts with the GC
to perform a portion of the project scope (e.g., site preparation, structural, mechanical work, and
electrical work), but are not responsible for the entire project. Subcontractors may also give part
of their contract to other contractors, who are commonly known as “sub-tier” subcontractors. For
example, a mechanical subcontractor sometimes will subcontract insulation of pipes and HVAC
system to specialized insulation contractors.
2.3.5 Craft workers
The specialty contractor, depending on their trade, will hire construction crafts from diverse trades.
Common tradespeople one can see on a typical construction site include:
Construction laborers and helpers
Construction equipment operators/Operating engineers
Truck driver
Boilermaker
5
Welder
Carpenters
Cement finishers
Structural iron and steel workers
Masons – brick, block, and stone
Electricians
Drywall and ceiling tile installers, and tapers
Elevator installers
Glaziers
Painters
Plumbers, pipefitters, and steamfitters
Sheet metal workers
Insulation workers
Tile and marble setters
Roofers
Hazardous materials removal workers
Please refer the occupational outlook handbook by the U.S. Bureau of Labor Statistics, which provides
a detailed description of these occupations and commonly performed tasks on the construction site.2
The construction workforce is very diverse, with about 2 million construction workers in 2010 were
born in foreign countries, with 24% Hispanic workers in the industry. Construction had the highest
percentage of Hispanic workers in 2010, only second to agriculture.3 Union members in construction
have advantages in educational attainment, wage and fringe benefits, training, and longer employment
tenure, compared with non-union workers.4 In 2011, more than 1 million construction workers were
union members accounting for 15.2% of the 6.7 million wage-and-salary workers in construction. In
2010, the average age of a construction worker was 41.5.
2.4 THE PROJECT LIFE CYCLE
The project lifecycle starts with the conceptual planning phase and continues through design,
procurement, construction, startup and commissioning, operations, and maintenance.
2.4.1 Planning Phase
During the planning phase the owner expresses the need for a new structure, identifies project needs and
scope, hires consultants to perform project feasibility study (i.e., in terms of finance, schedule, risks),
and makes the decision whether to proceed with the project. This phase also involves the selection of
the project designer.
2 U.S. Bureau of Labor Statistics. Occupational Outlook Handbook, 2013-14 Edition. http://www.bls.gov/ooh/construction-and-extraction/
(Accessed December 2014)
3 The Center for Construction Research and Training (CPWR). The Construction Chart Book, 5th Edition.
http://www.cpwr.com/sites/default/files/publications/5th%20Edition%20Chart%20Book%20Final.pdf (Accessed December 2014)
4 The Center for Construction Research and Training (CPWR). The Construction Chart Book, 5th Edition.
http://www.cpwr.com/sites/default/files/publications/5th%20Edition%20Chart%20Book%20Final.pdf (Accessed December 2014)
6
2.4.2 Design Phase
The project designer starts the design phase with a preliminary design concept that meets the owner’s
specifications regarding the project’s use, appearance, and cost. Once the owner reviews the preliminary
design and approves it, the designer will then develop detailed drawings and specifications for the
construction of the project. The owner also obtains any land use approvals and any appropriate
permits, and sometimes even orders long-lead equipment that will be part of the final facility.
2.4.3 Contract Phase
The project is now ready for construction. Thus, the owner will begin the general contractor (GC)
selection process. The construction drawings and specifications are given to the prospective GCs for
bidding, which will allow them to prepare an accurate estimate of the project cost. Readers should
have some basic understanding of the most common contracting methods and project delivery
methods. A brief overview is provided in this chapter. There are three common ways of delivering a
construction project:
Design-bid-build (DBB) – The DBB is the traditional and most common project delivery
method to deliver projects. It involves three distinct phases: the design phase, the bid phase,
and the build phase. There is no overlap between the three phases, and each phase is finished
before the next one begins. The owner contracts separately with the design firm to design the
project and develop construction plans and specifications, and the GC to construct the project.
Design-build (DB) – The DB method also called as fast-tracking method, overlaps the project
design and construction phase. The DB method has gained popularity in the last two decades,
and might overtake DBB as the most common method of project delivery. There are several
variations, but in all cases the owner maintains a single contract:
1. The owner contracts with a “single entity” (integrated design-builder) to provide both
design and construction services.
2. The owner contracts with a “joint-venture” between design and construction firms to
provide design-build services.
3. The owner contracts with a “GC” as the design-builder, and then the GC subcontracts
the design to an A/E firm.
4. The owner contracts with a “design firm” as the design-builder, and then the design firm
subcontracts the construction scope to a GC.
Though many variations exist, compensation for the DB firm is usually based on a fixed price
or a guaranteed maximum price (GMP). The owner is essentially asking the DB firm to finish
their scope of work within a certain dollar amount.
Construction Manager/General Contractor (CM/GC) – The CM/GC is a modified DB process
in which the owner enters into a contract with a design firm and a CM/GC firm separately.
The CM/GC is selected at an early point in the design phase, typically using a competitive
selection process. The construction input during the design by the CM/GC firm is one of the
major advantages of this method. The CM/GC firm can collaborate with the designer on the
development of the design and preparation of design documents. Once the design has progressed
to an acceptable level, the CM/GC firm submits a guaranteed maximum price (GMP) for the
project to the owner. After reaching a GMP agreement, the construction begins.
7
There are two major types of contracting methods used by construction owners to select a contract
with the GC. They are competitive bidding and negotiated contract.
Competitive Bidding – A majority of the public owners obtain competitive bids or hard-bid,
from multiple GCs, and awards the project to the lowest responsible bidder using a “lumpsum” contract. Many state statutes require hard-bids. Any change in scope or price needs
a change order to be approved by the owner or designee. Hard-bid contracts can create
adversarial relationship between owner, A/E, and GCs; since most times the A/E acts as the
owner’s representative during the construction phase by reviewing change orders approvals and
progress payments approvals.
Negotiated Contract – Without going through the competitive bidding process, most private
owners negotiate a contract for a project with a preselected construction firm, based on
experience on similar projects, qualifications, reputation, and other reasons. This method
is gaining popularity in recent years. With many state legislations allowing for negotiated
contracts, even public agencies are using this approach over the past few years. The negotiated
contract typically involves a cost plus an agreed upon percentage of the GC’s overhead and
profit. Since this method does not require bid, it saves some time for the owner.
2.4.4 Construction Phase
Once the owner gives the approval to proceed with construction, the GC procures the services of
several subcontractors to complete the project using either competitive bidding or negotiated contract.
The primary objective of the GC is to build the project per the drawings and specifications. There are
four main aspects of construction that the contractor will control. They include safety, cost, schedule,
and quality. At substantial completion, a punch list is prepared which identifies items that must be
completed before the project can be accepted by the owner. Final completion occurs when all of the
punch list items have been taken care by the GC.
2.4.5 Turnover Phase
Commissioning, closeout, and turnover is the next stage of the construction project life cycle.
Commissioning is done to ensure the building systems, equipment, and the overall facility functions
correctly. During this phase, the contractor typically moves out of the project.
2.4.6 Operations and Maintenance
The final stage is the operations and maintenance phase, which includes all the services required to
ensure a facility or equipment functions as designed.
2.5 THE PROJECT TEAM (CONTRACTOR HIERARCHY)
Construction projects are complex and need a team with a variety of professionals. A sample
contractor hierarchy is shown in Figure 2-1 that will help readers understand the construction
site hierarchy. Figure 2-1 is an example, remember the hierarchy will vary from project to project,
depending on project size, and complexity. But, the critical thing is to understand is that these are
the members who are responsible and accountable for safety. The primary focus should be on the
supervision and craft workers:
8
Project Manager
Superintendent
General Foreman – assigned when there are 3 to 5 foremen
Foreman – typically 10 or fewer craft workers are assigned to a foreman, called the crew.
Craft Workers
General Contractor
2nd Tier Subcontractors
Vendors/Suppliers
Subcontractor # 1
Project Manager
Self-perform Work
Project Manager
Project Superintendent
Supervision
Superintendent
Project Engineers, Field
Superintendents, etc.
Estimators
1-2 General Foreman
Safety
3-5 Foremen
Security
10 Workers
Schedulers
Contract Managers
Clerical Staff
Figure 2-1: Example General Contractor, Subcontractor, and Supervision Hierarchy
2.6 INFLUENCE OF PROJECT FACTORS ON SAFETY
This chapter discusses the influence of various project factors and on project safety such as:
Project life cycle
The construction team
Project delivery methods
2.6.1 Project Life Cycle vs. Safety
When should a project consider construction worker safety? In order to have a high influence on project
safety performance, construction safety should be a primary consideration during the conceptual and
preliminary design phases of the project development process as shown in the time-safety influence
curve in Figure 2-2.
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Figure 2-2: Time / Safety Influence Curve5
2.6.2 Construction Team Players vs. Safety
The parties who have significant control of and/or influence on the construction worker safety and
health are the owner, general contractor, subcontractor, and designer. Just as each party influences
and contributes to the completed project in its own way, each affects the construction site safety
differently. A wealth of literature exists in the area of construction safety that has identified the roles
and influence of the four major parties (owner, constructors, subcontractors, and designers) that are
summarized below:
Owners – Safety elements that should be implemented by owners to improve safety are:
o Owner safety commitment
o Selection of GCs based on safety (injury rates, qualifications of safety and project
management staff, quality of contractor safety program)
o Safety requirements in contracts (safety representative, resume of safety personnel, site
specific safety plan, CEO safety commitment letter, and minimum training)
o Owner involvement in safety activities during pre-planning, design, and construction
phases
General Contractors - There seems to be a consensus among the safety researchers and
professionals that the major elements that will help achieve better safety performance mostly
revolve around the nine zero accident techniques:6
o Demonstrated management commitment
o Staffing for safety
5 Szymberski, R. (1997). Construction Project Safety Planning. TAPPI Journal, 80(11), 69-74.
6 Hinze, J., Mathis, J., Frey, P.D., Wilson, G., DeForge, P., Cobb, M., and Marconnet, G. (2001). “Making Zero Accidents a Reality,” Annual
Conference of the Construction Industry Institute, San Francisco, CA.
10
o
o
o
o
o
o
o
Safety planning
Safety training and education
Worker participation and involvement
Recognition and rewards
Subcontractor management
Accident/incident reporting and investigations
Drug and alcohol testing
Subcontractors – Research on a subcontractor’s role in construction safety has been minimal.
Some of the significant subcontractor safety elements include:
o Task coordination by analyzing project schedule
o Have fewer contractors on the project
o Hiring known subcontractors by the GCs
o GC or CM provided a full-time project safety representative
o GC discussed safety at coordination meetings and pre-job meetings
o GC monitored project safety performance
o GC required full compliance with the safety regulations from subs
o Top management commitment/involvement in project safety
o Minimizing worker turnover
o Implementing employee drug testing
o Training with the assistance of contractor associations
Designers – Some of the significant designer elements include:7
o Safety during conceptual planning stages of the project
o Safety in design concept
o Safety during constructibility reviews
o Life cycle safety review
o Safety training for designers
o Inclusion of hazard symbols in project plans
o Involvement of foremen (GC) in constructibility review/design process
o Use of the Design for Construction Safety Toolbox
After examining the list above, the readers will understand that the best practices of the owner, general
contractor, and subcontractors are similar in nature.
2.6.3 Project Delivery vs. Safety
Construction project delivery method is the one of the most important factors that impact the project
safety performance. Three questions to consider when choosing a project delivery method:
Which method allows the complete coordination of the entire project team (owners, designers,
and GCs)?
Which method permits the incorporation of safety during the early phases of the project
lifecycle?
Which method provides significant limitations to worker safety and health?
7 Rajendran, S. (2006). “Sustainable Construction Safety and Health Rating System.” Doctor of Philosophy Dissertation, Oregon State University,
Corvallis, Oregon, December 2006.
11
Table 2-2 summarizes the advantages and disadvantages of the construction worker safety with respect
to the delivery and contracting methods.
Method
DBB
Table 2-2: Impact of project delivery methods on construction safety
Advantages
Disadvantages
o Fully designed scope of work o Selection of GC/subs based on past safety
minimizes surprises
performance is not possible
o No GC involvement in the design to incorporate safety
o No constructibility review
DB
o Selection of GC/subs based
on past safety performance
o GC provides input into project design improving constructibility
o Designer can incorporate
safety into project design
o GMP given earlier in the
process allows negotiation of
safety budget upfront
CM/GC o Selection of GC/subs based
on past safety performance
o GC provides input into project design improving constructibility
o Designer can incorporate
safety into project design
o Potential to ignore safety to save costs
o Difficult to incorporate safety in design if
the designer is unfamiliar with design for
safety concepts
o Difficult to incorporate safety in design if
the designers is reluctant to consider safety
during design due to liability concerns
o Difficult to incorporate safety in design if
the designer is unfamiliar with design for
safety concepts
o Difficult to incorporate safety in design if
the designers is reluctant to consider safety
during design due to liability concerns
o GMP given earlier in the
process allows negotiation of
safety budget upfront
2.7 SAFETY IN THE CONSTRUCTION INDUSTRY
Construction is a hazardous industry. The fatal and non-fatal injury rates have considerably declined
since the early 1990s, but the rate is among the highest of all U.S. industries. The following chapters
presents the industry accident statistics, cost of accidents, common accident causes, and common
hazards, to provide the readers a better understanding of the safety issues faced by the industry.
12
2.7.1 Construction Safety Management Risks
The typical hazards found on construction sites are discussed later in this chapter. Readers should
understand the common risks associated with safety management so that it can be eliminated,
minimized, or transferred. A non-exhaustive list of typical construction risks include:
1.
2.
3.
4.
Worker injuries and illnesses
Damage to GC and subcontractors equipment, vehicle, material, and property on the site
Injuries to the members of the public due to negligence of contractors
Damage to equipment, vehicle, material, and property of the general public due to negligence
of contractors
5. Negligence of one contractor resulting in an injury to another contractor or property damage
6. Environmental damages
7. Business interruptions due to any of the items 1 through 7
Care should be taken to eliminate or minimize these risks, in addition to purchasing proper insurance
coverage.
2.7.2 Accident Statistics
Out of 3,929 worker fatalities in private industry in calendar year 2013, 796 or 20.3% were in
construction; that is, one in five worker deaths were in construction. Table 2-3 presents some of the
most important safety statistics. The data presented in this paragraph are from two sources: the U.S.
Bureau of Labor Statistics8 and the Construction Chart Book, the Center for Construction Research
and Training, 5th edition.9
Table 2-3: U.S. Construction Industry Injury and Illnesses Statistics
Description
Statistics
3.8
2013 Total Recordable Injury Rate (TRIR)
2013 Days away, restricted, transfer rate (DART)
2.2
2012 Median days away from work due to injury
11
2012 Number of construction fatalities (most of all industries)
806
9.9
2012 Number of fatalities per 100,000 full-time equivalent workers
2012 Age group with highest number of nonfatal injuries and illnesses 25-34
2012 Percentage of injuries involving employees with service <3 months 16%
2.7.3 Accident Costs
Construction accidents are very expensive, accounting for billions of dollars in direct and indirect
costs. Direct costs are workers’ compensation claims that pay for medical, loss of wages, and
rehabilitation for an injured worker. Many employers do not realize the indirect costs associated
with accidents such as:
8 The Bureau of Labor Statistics. Injuries, Illnesses, and Fatalities (IIF) program. www.bls.gov/iif/ (Accessed December 2014)
9 The Center for Construction Research and Training (CPWR). The Construction Chart Book, 5th Edition.
http://www.cpwr.com/sites/default/files/publications/5th%20Edition%20Chart%20Book%20Final.pdf (Accessed December 2014)
13
Increase in workers’ compensation insurance premiums
Lost reputation or damage to public image
Loss of contracts due to poor safety records
Work stoppage associated with accidents
DOSH citations and other regulatory agency citations
Damaged or spoiled materials
Replacement of damaged tools or equipment
Investigation time
Lower worker morale
Loss of valuable workers
Hardship to worker family
There are estimates that the indirect cost is anywhere between 1 to 20 times the direct cost depending
on the accident.
2.7.4 Accident Causes
According to the Bureau of Labor Statistics (BLS)8, the leading causes of worker deaths on construction
sites were falls, followed by struck by object, electrocution, and caught-in/between. These “Fatal Four”
were responsible for more than half (58.7%) the construction worker deaths in 2013. Eliminating the
Fatal Four would save 468 workers’ lives in America every year. Based on the author’s experience, the
other common causes of accidents on a construction site include but not limited to:
Trips and slips
Improper use or failure to use, Personal Protective Equipment (PPE)
Defective PPE
Improper material storage
Lack of warning system
Use of defective tools, equipment, or materials
Failure to follow safety procedures or policies
Failure to identify and control hazards using pre-task plans
Failure to maintain focus on the work at-hand
No management accountability and responsibility system
Act of violence or horseplay
Improper lifting and hoisting
Inadequate guards or barriers
Insufficient safety training for workers
Mechanical failure of equipment
Noise exposure
Chemical exposure
Fire or explosions
Inadequate illumination
Inadequate ventilation
Reduced visibility
Poor housekeeping
Poor communication
Language barrier
14
Temperature extremes
Under influence of alcohol and/or other drugs
using defective equipment
Weather Conditions
Fatigue due to workload
2.7.5 Construction Site Hazards
Hazard and risk identification is perhaps the most crucial part of the construction site safety
management process because an exposure that is not identified cannot be properly managed. Some of
the most common health hazards are listed in Table 2-4. Other hazards on construction sites include:
Caught In/Between
Compressed Gases
Confined Spaces
Crane
Electrical Shock
Elevated Work
Explosion
Falls from Elevations/Same level
Fire
Inadequate Access
Ladders
Lockout/Tagout
Mobile Equipment
Particles in Eyes
Poor Housekeeping
Rigging
Scaffolding
Sharp Objects
Struck By
Slips and trips
Thermal Burns
15
Table 2-4: Common Hazards on Construction Sites
Chemical
Physical
Biological
Fungi
Temperature
Gases
Bloodborne Pathogens
Noise
Vapors
Bacteria
Vibration
Fumes
Poisonous Plants
Ionizing Radiation
Dusts
Poisonous Animals
Non-Radiation
Fibers
Infectious Animals
Mists
Examples:
Examples:
Examples:
Hand-held power tools West Nile virus
Acids
Lyme disease
Equipment
Alkalis
Heat illnesses
Histoplasmosis
Asbestos
Hantavirus
Cold illnesses
Bleaches
X-rays
Poison oak
Cadmium
Sumac
UV light
Carbon monoxide
Bee
Infrared radiation
Cutting oil mists
Yellow jacket
Lasers
Epoxy resins
Bird droppings
Formaldehyde
Sewage
Hexavalent chromium
Lead
Oils
Silica
Solvents
Spray paints
Welding fumes
Ergonomic
Repetitive Motion
Awkward Postures
Excessive force
Static loading
Contact stress
Examples:
Strains
Sprains
Tendonitis
CTS
Back pain
2.7.6 Workplace Safety and Health in Washington and Enforcement10
Regulatory agencies play a crucial role in creating a safe and healthy workplaces in Washington. Some
of the common names you might have heard are OSHA, WISHA, and DOSH? What are OSHA,
WISHA, and DOSH and how do they Relate? With the Occupational Safety and Health Act of 1970,
Congress created the Occupational Safety and Health Administration (OSHA) to develop and enforce
workplace safety and health rules throughout the country. OSHA allows states to run their own safety
and health programs as long as they are at least as effective as OSHA. OSHA accepted Washington as
a state plan state.
WISHA is the Washington Industrial Safety and Health Act, Chapter 49.17 RCW, enacted in 1973 by
the Washington State Legislature. The purpose of this law is to ensure that Washington’s employers
provide their workers with safe and healthy workplaces. The Department of Labor & Industries (L&I)
administers WISHA through its Division of Occupational Safety and Health (DOSH). Washington is
one of 27 states that administers its own workplace safety and health program. The OSHA enforces
safety and health requirements in the remaining states. OSHA monitors and partially funds DOSH.
DOSH (the Division of Occupational Safety and Health) is part of the L & I that:
10 Division of Occupational Safety and Health (DOSH).
http://www.lni.wa.gov/SAFETY/TOPICS/ATOZ/ABOUT/DEFAULT.ASP
(Accessed January 2015)
16
•
•
•
•
develops safety and health rules;
enforces safety and health rules by inspecting worksites for unsafe working conditions;
provides free on-site consultations to help employers create safe and healthy workplaces;
provides free training, safety and health programs, and other resources to help prevent, find,
and fix hazards; and
• was called WISHA Services (Washington Industrial Safety and Health Administration) until
2006.
What about RCWs and WACs? RCW/RCWs stands for the “Revised Code of Washington” and:
• is the collection of all state laws (the RCW) or a single statute (WISHA is an RCW, Chapter
49.17)
• is maintained by the Office of the Code Reviser (not by DOSH);
• gives “teeth” to regulations by giving them the force of law.
WAC/WACs (pronounced “wack/wacks”) stands for “Washington Administrative Code” and:
• is the body of rules (the WAC) or individual rules (WACs) created to implement an RCW;
• spells out, in Chapter 296, L&I’s safety and health requirements for employers.
Creating and maintaining a safe workplace begins with Washington State’s “safety and health core
rules” contained in Chapter 296-800 WAC. These rules explain the minimum requirements for safe
workplaces that employers must follow. These core rules include requirements for your Accident
Prevention Program, personal protective equipment, first aid, and hazard communication program. In
addition to the core rules, other rules apply to specific industries – for example, noise control, confined
space, forklift safety and respiratory protection. For example, the new rule regarding the Globally
Harmonized System (GHS) for hazard communication is contained in Chapter 296-901, WAC. The
rules for Safety Standards for construction work is part of Chapters 296-155, WAC.
By law, DOSH conducts workplace compliance inspections. The terms “compliance,” “enforcement,”
and “inspections” all describe the inspection process, found in WAC 296-900. A workplace inspection
helps an employer discover any potential hazards within the workplace and determines if applicable
minimum workplace safety and health rules have been followed. DOSH’s Compliance Safety and
Health Officers (CSHOs) conduct inspections. It should be noted that sometimes the acronym CSHO
is also used to refer Consultation Safety and Health Officers. DOSH conducts inspections without
advance notice, except in rare circumstances (e.g. Imminent Danger). If they find any violation, they
may issue citations.
Under the WISHA employers also sometimes have a responsibility for the safety and health of other
employees as a creating, correcting or controlling employer. On March 29, 1990, the Washington
Supreme Court held in Stute v. PBMC11 that a general contractor could be held liable for an injury to a
subcontractor’s employee that occurred as a result of a Washington Industrial Safety and Health Act
(WISHA) violation. The Stute decision and subsequent rulings have established that general contractors
may be liable for WISHA violations committed by subcontractors under their control. Because the general
contractor has authority to influence working conditions on a construction site, the general contractor has
11 114 Wb,2d 454, 788 p.2D 545 (1990)
17
ultimate responsibility under WISHA for job safety and health at the job site in all common work areas,
including work areas defined in all contracts under the scope of work to be performed at the jobsite. Please refer
WISHA Regional Directive 27.00, “Contractor Responsibility Under Stute v. PBMC,” for more information.
The most common construction safety & health rules cited during L&I inspections for federal fiscal
year 2013 are:12
Accident Prevention Program (APP)
Fall Protection
First-Aid Training and Certification
Ladder Use
Tools – Hand and Power
Personal Protective Equipment (PPE)
Guardrails, Handrails and Covers
Excavation, Trenching and Shoring
Scaffolding – General Requirements
Stairways
This information can help strengthen your workplace safety program and prevent costly injuries and
illnesses.
2.8 SUMMARY
The intent of this chapter was to make the readers familiar with the construction industry and a
typical construction project, to best use the information provided in the upcoming chapters.
Additional Resources, Reading, and References
Clough, R.H, Sears, G.A., and Sears, SK. (2005). Construction Contracting – A Practical
Guide to Company Management. Seventh Edition. John Wiley & Sons Inc. New Jersey.
12 Division of Occupational Safety and Health (DOSH).
http://www.lni.wa.gov/Safety/Topics/AToZ/SafetyTopTens/?F=HDI
(Accessed January 2015)
18
3
PROJECT TEAM SELECTION
3.1 PURPOSE
The parties who have significant control of and influence on the construction worker safety and health
are the owner, general contractor, subcontractor, and the designer. An owner can impact worker safety
and health by selecting safe contractors and designers. An owner can further improve safety by requiring
general contractors to select safe sub-contractors by including safe contractor selection requirements
in the contracts. The purpose of this chapter is to present contractor and designer selection guidelines
for use by Owners and Contractors. The guidelines presented in this chapter are best practices that
can be implemented by project owners when selecting designers and general contractors, or by general
contractors when selecting subcontractors for upcoming bids or selecting subcontractors for a specific
project.
3.2 DESIGNER SELECTION
Eliminating or engineering as many hazards as possible by safe design is the number one control
method to protect workers, and should be a primary objective of the project team. In order to achieve
this objective, a project team should consist of designers who are willing to incorporate worker safety
and health into the project design phase. The owner should choose a project designer in part based on
experience, knowledge, and willingness to incorporate worker safety and health in the project design.
Selection should include: checking past records on designer experience, knowledge of safety and
health in design concepts, and personal interviews/knowledge. An owner can objectively evaluate each
designer’s safety qualification using the criteria listed in Table 3-1. Multiple designers can be compared
using the total rating that will help the owner to select a designer who will incorporate worker safety
and health in the project design.
19
Table 3-1: Designer Selection Criteria
Criteria used in designer selection
Past safety experience
Knowledge of construction safety and health
Willingness to design for safety
Personal interviews/knowledge
Total Rating
Evaluator Comments: Why the above ratings were awarded?
Rating (1 to 5)*
*Rate each criteria on a scale from 1 to 5, 1 = Very low, 2 = Low, 3 = Moderate, 4 = High, 5 = Very high
3.3 CONTRACTOR SELECTION
Contractors in this chapter refer to general contractors, subcontractors, and sub-tier contractors. The
selection of contractors should be based in part on past safety performance. This is typically done
using a well-established safety management best practice called contractor safety pre-qualification.
The primary rationale behind this practice is to establish and use a pre-qualification process to select
contractors who are likely to complete a construction project safely.
3.3.1 Assessment Metrics
The first step in the pre-qualification process involves identifying the metrics that will be used to assess
the past safety performance of the contractors. A common mistake made by this step is just to use
lagging indicators such as incident rates, etc., which sometimes does not paint an accurate picture
of a contractor’s safety performance. Hence, the past safety performance assessment metrics should
include both leading safety indicators and lagging safety indicators. A contractor pre-qualification
assessment should include all or a combination of the following metrics:
Experience Modification Rating (EMR)
Insurance Loss runs for Workers’ Compensation, General Liability, and Auto
Fatality History
OSHA Total Recordable Incident Rate (TRIR)
OSHA Days Away, Restricted, and Transfer Case Rate (DART)
Regulatory Government Agency (i.e. DOSH, EPA, DOT) Citations (RGAC)
Personal knowledge of the contractor’s safety performance from prior jobs
Reference from former owners or contractors
Review of the contractor’s safety program (RCSP)
Review of contractor’s safety team qualifications (i.e. experience, education, and professional
certifications)
20
Accredited safety training above regulatory government agency requirements (e.g., employees
trained on OSHA 500, OSHA 10-hour or OSHA 30-hour training)
Top Management involvement/commitment to worker safety and health
3.3.2 Questionnaire
The second step in the pre-qualification process is to obtain the safety performance information from
contractors with the help of a form typically called “Pre-qualification Safety Questionnaire.” It is
critical to make this questionnaire as simple and straightforward as possible. A sample pre-qualification
safety questionnaire template is presented in this chapter as Exhibit 3-1, to assist contractors looking
to develop or improve their pre-qualification process. Even though the majority of the construction
firms still collect this information using manual forms, few companies have started to use online forms
with provisions to upload supporting documentation. Both formats are acceptable business practices;
the company should decide what format to use for their pre-qualification questionnaire.
3.3.3 Supporting Documentation
In order to avoid any errors, omission, or misrepresentation about safety performance metrics, it is
always best practice to verify the information provided by the contractors by requiring them to submit
support documentation. Typically the following documentation, for each of the last three calendar
years, is requested from the contractors as part of the pre-qualification process:
Experience Modification Rate (EMR)
o Certified letter from insurance carriers listing the EMR
o Letter of explanation with corrective action plan if EMR shows a negative trend over
the three years
Incident Rates (IR)
o Signed copies of OSHA 300 Logs and OSHA 300A summaries for each of the past three
calendar years
Claims
o Copies of loss runs for the three previous years workers’ compensation, general liability,
and auto claims
Fatality
o Detailed description of each fatality that the firm has experienced
Regulatory Government Agency Citations (RGAC)
o Copies of all citations received from local, state, or federal government agencies
o Letter of explanation with corrective action plan implemented in response to the citations
Safety Program
o Copy of the firm’s written safety program
o Information about any recent safety initiatives that were beyond regulatory compliance
Construction Quality Program
o Copy of the firm’s written quality control/assurance program (if any)
o Information about any recent initiatives that were implemented to improve quality
21
Safety Professionals
o Resumes of the firm’s key Safety and Health personnel
3.3.4 Assessment
The assessment of the contractors based on the safety metrics is the most critical step in the selection
process. The pre-qualifying firm should define a safe contractor, whom it will allow to bid or perform
work on its projects. A safe contractor should be defined in terms of lagging and leading indicators.
There is a wide variation in defining a safe contractor across the industry. For example, some prequalifying companies have set a “fixed” benchmark for safe contractors such as:
EMR ratings of 1.0 or lower for the last three years
OSHA Total Recordable Injury/Illnesses Rate (TRIR) <= 4.0
Days Away, Transfer, and Restricted Case Rate (DART) <= 2.0
Zero fatalities in last three years
While other companies instead of setting fixed benchmarks uses a sliding scale for classifying
contractors as shown in Table 3-2.
It is always advisable to use both lagging (e.g., EMR, DART, TRIR, Fatality) and leading indicators
(e.g., citations and safety program review) during the assessment. The quantitative parameters such as
incident rates, number of citations, etc., are simple and easy to evaluate. The qualitative parameters
such as a safety program review, safety personnel qualifications, etc., needs qualitative assessment.
In order to be consistent between contractors. Table 3-2 presents one way to quantify the qualitative
review of the contractor’s written safety and health program (WSHP). For example, chapter 5 of the
sample pre-qualification safety questionnaire lists multiple questions as a way to determine the quality
of the contractor’s WSHP. You can quantify this assessment by using a metrics such as the percentage
of questions answered “yes” and use it as part of your assessment.
Table 3-2: Contractor Classification based on Safety Performance Metrics
For the three previous calendar years
Class
TRIR/EMR
WSHP
EMR
DART
TRIR
RGAC
Fatality
Trend
Conformance
0.75 or less 0.8 or less 4.0 or less Improving
0
0
More than 90%
I
0.76 to 1.00 0.9 to 2.0
4.1 to 5.5
Improving
1 to 2
0
75% to 90%
II
1.00 to 1.25 2.1 to 2.9
5.6 to 7.9
Declining
3 to 5
1
50% to 74%
III
1.26 or more 3.0 or more 8.0 or more Declining
5 or more > 1
Less than 50%
IV
3.3.5 Action
Based on the assessment the prospective contractors can be classified into one of the four classes: Class
I, Class II, Class III, and Class IV, as shown in Table 3-2. The pre-qualifying firm now has to determine
the course of action for contractors that fall under different classes. A sample pre-qualification
assessment action guideline is provided in Table 3-3. Note that it is up to the individual companies
based on factors such as geographic location, availability of skilled contractors, etc., to decide their
course of action for their prospective contractors.
22
Table 3-3: Final Action of Contractors
Action by the Pre-qualifying company in terms of “Acceptability” to bid or perform work on its
Class
projects
Perfectly Acceptable – top safety and health performance, no further action required.
I
II
Slightly Acceptable – average safety and health performance, corrective action plan “may” be
required prior to acceptance.
III
Slightly unacceptable – below average safety and health performance, probationary status,
only acceptable to bid or perform work with a detailed corrective action plan and concurrence by the project manager and safety director.
IV
Totally unacceptable – poor safety and health performance, ineligible.
The guidelines and the template questionnaire presented in this chapter are based on industry best
practices. It is up to the pre-qualifying firm to develop pre-qualification or selection guidelines that
suit them. These guidelines can be used as a starting point to establish “acceptable” standards for a
contractor or designer selection process as it pertains to safety and health performance.
3.3.6 Preferred Contractor List
Another method of selecting a contractor is by developing a preferred contractor’s list. A preferred
contractor’s list has the ability to make timely and accurate contractor selection for a project that is
time sensitive. It can also reduce the repetitive nature, time and expense of collection and evaluation
of pre-qualifying information. This list is usually determined by repeated successful submission and
acceptance of pre-qualification information from a contractor(s) who perform work on multiple
projects during the course of a given calendar year. A single successful submission and acceptance
of pre-qualifying information on the first project of the year from the previously approved contractor
can verify the continued acceptability for the contractor to bid or perform work in that calendar year.
Additional Resources, Reading, and References
Rajendran, S. (2006). “Sustainable construction safety and health rating system.” Doctoral
dissertation, Oregon State University, Corvallis, OR.
23
Exhibit 3-1: Contractor Pre-qualification Safety Questionnaire Template
Any contractor interested in working for <<Company Name>> must be pre-qualified to be included
on the bid list. Interested contractors should complete this questionnaire with all requested support
documentation for <<Company Name’s>> review prior to being added to the bid list. Failure to
provide support documentation or reporting false information on this questionnaire will deem your
submission unacceptable, and your company will be not able to bid on <<Company Name>> projects.
This Chapter is for <<Company Name>> Use Only
Contractor Name _____________________________________
Contractor Classification (circle one): I II III IV
Reviewed by: ____________________________ Date: _______________________________
Recommendation:
Company Name:___________________________________________________________________
Address: _________________________________________________________________________
Submitted by (please print): __________________________________________________________
Title: ____________________________________________________________________________
Telephone Number: ______________________ Email Address: __________________________
I certify that the information provided in this questionnaire and all accompanying documentation
is true and correct.
Signature: ______________________________
Date: __________________________________
1. Experience Modification Rate (EMR): List your company’s EMR for the last three years. Attach a
copy of a letter from your insurance carrier or state fund (on their letterhead) verifying the EMR
information. Submit a letter of explanation for the cause and corrective action implemented if any
of the EMR is above 1.00 and/or upward trends in EMR.
Year
20 ___
20 ___
20 ___
EMR
_________
_________
_________
2. OSHA Injury/Illness Statistics: Provide the Total OSHA Recordable Injury/Illness Rate (TRIR)
and Days Away, Transfer, and Restricted Case Rate (DART) for this year to date and the previous
three years, as defined by the Federal OSHA reporting requirements. Attach a copy of your OSHA
24
300 Logs and OSHA 300A Summary sheets. Submit a letter of explanation for the cause and
corrective action implemented if the average rates are above national average and/or upward trends
in injury/illness rates.
Year
Current
20 ___
20 ___
20 ___
Average
TRIR
DART
Total Work
Company
State Rate Company State Rate
Hours
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
3. Regulatory Government Agency Citations (RGAC): List the number of upheld RGACs (i.e.
DOSH, EPA, and DOT) received for this year to date and the previous three years. Submit
copies of all citations or fines, and a letter of explanation for the cause and corrective action
implemented for all the RGACs.
Year
DOSH
Citations
EPA
(Federal or State
Citations)
DOT
(Federal or
State Citations)
Current
20 ___
20 ___
20 ___
Total
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
_________
4. Fatality History (FH): Enter the number of work-related fatalities experienced by your firm in the
last three years. Provide a detailed description of the fatalities in a separate exhibit.
Year
Fatalities
20 ___
_________
20 ___
_________
20 ___
_________
5. Written Workplace Safety and Health Program (WSHP):
Does your company have a written Workplace Safety and Health Program?  Yes  No
If yes, submit a copy of your complete Workplace Safety and Health Program and answer the
questions specific to the program. The program’s critical elements will be evaluated as part of the prequalification process.
25
Critical WSHP Elements
Does your company have a substance abuse screening program?
Does your company conduct weekly (minimum) site safety inspections?
Does your company require crews to hold regular toolbox meetings?
Does your company conduct supervisor safety training?
Does your company investigate all accidents including near misses?
Does your company require your employees to complete OSHA 10-hour training?
Does your company hold regular weekly site safety meetings?
Are your company’s field supervisors certified in OSHA 30-hour courses?
Does your company require sub-tier contractors to have a written safety program
and monitor their workplace safety and health performance?
Does your company audit your workplace safety and health program and continuously improve it?
Do you have a return to work program with a provision of returning workers to
modified/light duty?
Does your Company have a disciplinary program in place for safety violations?
Does your company follow a system based partnership programs such as DOSH’s
Voluntary Protection Program (VPP) or Safety and Health Achievement Recognition Program (SHARP)?
Does your company has a formal construction Quality Assurance (QA) /Quality
Control (QC) program and/or a procedure manual?
Response
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
 Yes  No
6. Safety Personnel:
Who is responsible for safety at your company?
Name: _________________________________
Telephone Number: _______________________
Title: __________________________________
Email Address: __________________________
We will get back to you within two weeks after receipt of your submission. Please feel free to call our
office at <phone number> with any questions on the pre-qualification process.
26
4
SAFETY IN CONTRACTS
4.1 PURPOSE
This chapter is intended to provide information and guidelines on the requirements of safety and health
in construction contracts. The information will serve as a reference document for contract managers
and construction safety professionals when writing the safety section of the contracts, which will not
only improve worker safety performance, but will also avoid contract disputes or issues pertaining to
safety management.
Note: The guidelines provided in this chapter are not legal advice. When writing contracts, contractors
should always seek guidance from its attorneys/legal counsel or seek guidance from an employment
law specialist. It will help to ensure compliance with all applicable local, state, and federal laws.
4.2 CONTRACTS
Contracts are essential to the construction process. In the simplest of terms, a contract may be defined
as an agreement between two or more parties that is enforceable by law. Contract language that lacks
clarity includes significant errors and omissions, or contains excessive, non-essential information may
result in considerable ambiguities in the contract.
Inclusion of the safety related contractual language may not only help the contractor avoid safety
requirement disputes, but may perhaps also help meet the reasonable care standard by improving
the contractor’s safety practices, reducing the likelihood of noncompliance, and creating a graduated
system of onsite safety enforcement. Hence, the Project Owner should incorporate safety and health
requirements in the contract with the prime contractor, and should also require the contractor to
include the same requirements in their subcontracts.
Project owners include safety and health requirements in contracts since they:1 1) are motivated by their
own safety culture to expect safe operations by others they have some control over, 2) are encouraged
to mandate safety practices because of the contingent liability they assume, and 3) are driven by a
desire to avoid adverse public relations resulting from the aftermath of lapses in safety practices. The
general contractor group, on the other hand, is responsible for establishing and administering not only
their own safety management programs but often that of the subcontractor group as well.
1 Rajendran, S., Clarke, B., and Whelan, M. (2013). “Contract Issues: Improving Construction Safety Management.” Professional Safety,
Journal of the American Society of Safety Engineers (ASSE), 58(9), 56-61.
27
4.3 CONTRACT FORMAT
The format of the contract requirements document varies from company to company, however, it
is typical for project owners and construction firms to create a separate document that exclusively
focuses on the safety and health contract requirements such as, “Project Safety Requirements,” or
“Environmental, Health, and Safety (EHS) Requirements.” This document will be either be included
in the contract as a separate article or maintained as a stand-alone document with a reference in the
overall contract.
4.4 CONTRACT REQUIREMENTS
The contract whether between the project owner and the general contractor (or) between the general
contractor and their tiers, should clearly specify the safety and health requirements to avoid disputes
during construction and also ensure all the parties utilize consistent safety standards. Furthermore,
it allows contractors to account for the safety-related expenses in the project budget. Some of the
most important safety and health requirements that are recommended to be included in contracts are
discussed in this chapter. It should be noted that there might be other project specific safety and health
challenges that should be adequately addressed in the contract to avoid surprises.
4.4.1 Prequalification
It is important to include verbiage requiring all contractors and subcontractors to pre-qualify sub-,
and sub-tier contractors such as “….the contractor shall develop appropriate pre-qualification criteria
for the selection of subcontractors. All such pre-qualification criteria shall be subject to the prior written
approval of <Company Name>.”
4.4.2 Laws and Regulations
Construction contracts, at a minimum, should include verbiage such as “…the contractor shall develop
and implement, and be responsible for, a comprehensive safety program that complies with all applicable
(environmental, health, and safety) international, national, state, county, local, contractor, and owner
requirements while performing work on the project or facility.” This blanket statement communicates the
message that the contractors shall abide by all applicable laws and regulations, and also are required to
comply with project-specific owner and contractor safety guidelines. The word “shall” is intended to
convey the “mandatory” nature of the requirements.
4.4.3 Project Specific Safety Plan
The contract should require all contractors and their tiers to submit a site-specific safety plan prior to
commencement of any construction work or with any significant change in activity. It should clearly
state the contractors cannot commence until the safety plan is approved.
4.4.4 Safety Hazard Assessment
Job Hazard Analysis (JHA), Pre-task Plans (PTP), and safety inspections/surveys are some of the
standard safety planning tools used for site hazard assessment and control. It is recommended to add
these requirements in the contract such as frequency of pre-task plan meetings (e.g., daily), frequency
of inspections (e.g., weekly), type of inspections (e.g., superintendent), timeline for fixing hazards,
documentation requirements, etc. Since these hazard assessment tools costs money, stating them in
precise terms will allow contractors to account for these costs in their bids.
28
4.4.5 Subcontractor Management
The construction contract should require not only the “direct” contractor to comply with the contract
requirements but also all tiers by adding verbiage in the contract such as “the contractor and the tiers
shall comply with the project contract requirement.” The contract should also include verbiage that
allows the company to take action when their contractors fail to comply with the contract safety
requirements.
4.4.6 Safety Staffing
Staffing of the safety function normally depends on the project size and complexity. The contract should
identify the minimum level of safety staffing expected to manage the safety program. The contract
should include when (defined in terms of trade headcount) the project will require a “dedicated” safety
professional onsite and when it is acceptable to staff a “designated” safety representative with an
assignment of a “floater” safety professional to assist the project.
A dedicated safety professional shall not hold other duties while a designated safety representative
might hold other duties but present at the site full-time (e.g., Superintendent). A floater is a qualified
safety professional to oversee several projects, when it is not financially feasible to assign a full-time
on-site professional to a single job or due to the nature of the job in terms of complexity.
The contract should also specify the minimum qualifications of both the designated and dedicated
safety professionals. For example, “When the contractor’s trade headcount reaches 30, employ one on-site,
full-time dedicated safety professional. The contractor shall also commit one on-site, full-time dedicated
safety professional for every additional 50 trade headcount. The dedicated safety professional must hold
a safety degree and have a minimum of three years professional safety experience in construction. The
designated safety representative must hold an OSHA 30-hour Construction Certification and have a
minimum of ten year’s construction field experience.” Another requirement that can be added is the
professional certification such as Certified Safety Professional (CSP) or Construction Health and
Safety Technician (CHST).
4.4.7 Safety Meetings
Safety meetings is one of the best ways to share jobsite progress, lessons learned from incidents, safety
statistics (incident rates, citations, etc), new safety products, issue safety awards, and much more. Since
safety meetings cost a lot of worker time, at a minimum the contract should specify the required
safety meetings and their frequency. For example, “…the contractor shall hold a weekly project-wide
safety meeting (also known as “mass safety meetings”) and daily tool box meetings. The contractor shall
mandate attendance for all persons performing work on the project.”
4.4.8 Site Specific Safety Orientation Training
The contract shall require the contractors to provide new employee orientation safety training to all
workers before they are allowed access to their worksite. It should state the duration of the training.
The contract should also require contractors to provide a proof of training completion in the form of
a badge or a hard hat decal. The new employee orientation safety training must include information
regarding all applicable laws and government regulatory requirements, in addition to project-specific
safety requirements.
29
4.4.9 Safety Training
The contract should require that the contractors should train their workers on all applicable federal,
state, local, and project-specific owner mandated training. The project-specific training that are above
and beyond regulatory compliance (e.g. OSHA 10-hour) should be spelled out in the contract. This
would be a good place to ensure that the contractors maintain clear training documentation readily
accessible in case of an audit by owner or regulatory agencies.
4.4.10 Substance Abuse Program
The contract should specify your firm’s substance abuse testing requirements such as (1) who will
be tested (e.g., all office and field personnel), (2) when will they be tested (e.g., pre-employment,
probable cause or suspicion, and post-accident), and (3) what are they being tested (e.g., alcohol,
etc.). It is always a good idea to refer to your company’s substance abuse policy for more details.
When developing programs, policies, or procedures relating to substance abuse programs, contractors
should always seek guidance from its attorneys/legal counsel or seek guidance from an employment
law specialist. This helps to ensure compliance with all applicable local, state, and federal laws. For
example, contractors can use language such as, “Subcontractor, Subcontractor’s sub-tier subcontractors
and their respective employees, shall take all reasonable and necessary safety precautions pertaining to
work and the conduct thereof, including, but not limited to, compliance with all applicable laws, ordinances,
rules, regulations and orders issued by public authority, whether federal, state, local, DOSH or other state
or federal regulatory agency, and any safety measure requested in good faith by contractor, including, but
not limited to, substance abuse testing, and all laws or regulations that incorporate ASME standards and
definitions relating to crane operations.”
4.4.11 Accident Reporting and Investigation
The contract shall require all contractors and their tiers to report and investigate all incidents regardless
of severity, which resulted in personal injury or illness to workers and general public, and property
damage. Contract managers should consider specifying the following items when writing this section:
(1) timeline for reporting accidents (e.g., DOSH requirements), (2) personnel to be notified of accident,
(3) who should conduct the investigation, (4) who should attend accident review meetings (e.g., should
owner representative be invited?), (5) when should the investigation be completed (e.g., within 24 hours
of accident occurrence), (6) what kind of accident documentation is needed in terms of report and
corrective actions and where should it be submitted, and (7) what happens with the lessons learned
report (e.g., lessons learned should be shared throughout the company).
4.4.12 Emergency Plan
The contract should require the contractor to develop and implement a site-specific emergency action
plan that should specify plan contents, posting and communication requirements, frequency of drills,
procurement of equipment (e.g., AED) or services (e.g., on-site nurse station), and collaboration with
local emergency personnel (e.g., local fire department or on-site emergency personnel).
4.4.13 Pre-Bid and Pre-Construction Meetings
The contract should require all contractors and their tiers to hold pre-bid meetings. The contractor
should present an overview of the project safety contract requirements and unique challenges associated
with the project. The information presented at this meeting will allow contractors to include resources
30
in their bids to meet the contract requirements. In addition, the contractors and their tiers should
be required to participate in a pre-construction meeting to ensure they understand the project safety
requirements prior to commencement of work. The contract should clearly state who should attend
the meeting. At a minimum, the contract should state “…pre-bid and pre-construction meetings should
be attended by the contractor project management, field management, and safety personnel.”
4.4.14 Special Provisions
New safety requirements such as the use of 3D modeling such as Building Information Modeling
(BIM) for safety planning, design for safety reviews to eliminate or minimize hazards during
design phase, and use of smartphone Apps for inspections, etc, are relatively new to the industry.
If such requirements are part of the project, contract managers should ensure they are clearly
specified in the contract.
4.4.15 Progressive Disciplinary and Incentive Programs
Even though disciplinary and incentive programs are common in most safety programs, it is
recommended to include these requirements as part of the contract. Some firms contractually require
contractors not to reward workers based on lagging indicators.
4.5 Contract Issues Related to Safety Management and Remedial Measures2
Contracts if not clear can result in issues that can result in wasted time and money to resolve them. A
list of common trade-specific contract issues related to construction safety management is presented
in Exhibit 4-1. Even though not exhaustive, the list of issues generated with input from numerous
contractors is formatted as a checklist that will help contract managers and safety professionals
remember to include appropriate items in the final contract. Using this list may reduce disputes with
respect to safety issues during construction operations.
4.6 Example Contract Requirements
An example project safety requirements in contracts document from a large construction firm is
presented as Exhibit 4-2. Please note this exhibit is only provided as an example and may not be suitable
to use it “as is” by the reader. Contractors should develop their own contract requirements based on
their organization’s policies, procedures, and regulatory requirements that affect their jobsites.
4.7 Construction Safety Professionals
In addition to the checklist presented in Exhibit 4-1, there are a number of ways that construction safety
professionals could be used to greatly reduce the number of contract issues occurring in construction
contracts. Some of the primary strategies are.3
Safety professionals should be involved with marketing departments early in the process to
avoid the commitment of unrealistic or unnecessary safety resource levels in an attempt to
receive the award of the project.
2 Rajendran, S., Clarke, B., and Whelan, M. (2013). “Contract Issues: Improving Construction Safety Management.” Professional Safety,
Journal of the American Society of Safety Engineers (ASSE), 58(9), 56-61.
3 Rajendran, S., Clarke, B., and Whelan, M. (2013). “Contract Issues: Improving Construction Safety Management.” Professional Safety,
Journal of the American Society of Safety Engineers (ASSE), 58(9), 56-61.
31
Project Owners should clearly communicate their safety expectations for the project, so
contractors can allocate resources appropriately in the bid. Construction safety professionals
should make an effort to clearly understand the owner’s EHS processes as well as their own.
Safety professionals should become an active participant in the project procurement process as
early as possible, preferably as early as the Request for Proposal (RFP)/Invitation to Bid stage.
Safety professionals should take an active role in the pre-bid meetings and communications
that take place. They should continue their involvement in the early stages of the project by
actively participating in pre-award/construction meetings.
Safety professionals should ensure that appropriate contractual requirements and responsibility
assignment clauses are included in the final contract as detailed in the first part of this chapter.
Review of basic DOSH or other applicable codes and requirements, as well as an explanation
of project-specific requirements, should be included in the craft orientation to the project.
As a part of the ongoing project safety program, safety issues unique to High Hazard, LowFrequency activities and site specific protocols should be an active part of the pre-task planning
effort.
A safety checklist, such as the one presented in this chapter, would be one of the technique to
identify unique safety issues to be considered for inclusion in the contract.
Safety issues included specifically in the contract should focus on those issues that are in addition
to basic DOSH or other applicable requirements. Basic DOSH requirements are generally well
covered with existing reference specifications.
Identification of safety issues that are particularly troublesome and unique to construction
should be researched further to better define the checklist.
Construction Safety Professionals should be involved during the project proposal phase, contract
management phase, pre-award & pre-mobilization meetings; to ensure safety management
expectations are clearly identified and communicated to help reduce the possibility of safety
management related claims.
Additional Resources, Reading, and References
American Industrial Hygiene Association (AIHA). Health and Safety Requirements in
Construction Contract Documents.
Rajendran, S., Clarke, B., and Whelan, M. (2013). “Contract Issues: Improving Construction
Safety Management.” Professional Safety, Journal of the American Society of Safety Engineers
(ASSE), 58(9), 56-61.
32
Exhibit 4-1: Trade Specific Contract Issues to be Included in Construction Contracts/Subcontracts4
Date: ________________________________ Location:______________________________
Project Name/Location: _______________________________________________________
CHECKLIST ITEMS: Requirements specified? Responsibility identified?
Status
DEMOLITION
Dust control.
o Yes o No o NA
Demolition lighting erection & maintenance.
o Yes o No o NA
Cleanup and disposal of demolition debris.
o Yes o No o NA
Salvaged materials handling procedures.
o Yes o No o NA
Mandated materials salvage.
o Yes o No o NA
Comprehensive demolition process safety plan.
o Yes o No o NA
Testing of suspected or known hazardous materials.
o Yes o No o NA
Open hole barricades &/or covers.
o Yes o No o NA
Third party protection during demolition.
o Yes o No o NA
Termination & capping or safe-off of electrical, water, gas, & other utilities. o Yes o No o NA
SITEWORK
Barricades & guardrails around excavation work beyond basic applicable
regulatory requirements.
o Yes o No o NA
Safety procedures around heavy equipment beyond basic applicable
regulatory requirements.
o Yes o No o NA
Barricades around trenches regardless of depth.
o Yes o No o NA
Notification & follow-up verification of the implementation of utility
location service(s).
o Yes o No o NA
Utility potholing (physical verification of utility locations).
o Yes o No o NA
Street cleanup of spilled material due to rock & soil hauling activities.
o Yes o No o NA
Federal Aviation Authority (FAA) permits for tall equipment near airports. o Yes o No o NA
Wheel wash provisions at the site entrance/exit points.
o Yes o No o NA
Development of traffic control plan.
o Yes o No o NA
Implementation & maintenance of traffic control plan.
o Yes o No o NA
Pavement protection near excavations during construction.
o Yes o No o NA
STRUCTURAL COMPONENTS
Concrete pump/truck safety procedures.
o Yes o No o NA
Guardrail erection & maintenance during footing construction.
o Yes o No o NA
Isolation block out protection at the column - SOG intersections.
o Yes o No o NA
Installation & maintenance of access to work areas used by multiple trades. o Yes o No o NA
4 Rajendran, S., Clarke, B., and Whelan, M. (2013). “Contract Issues: Improving Construction Safety Management.” Professional Safety,
Journal of the American Society of Safety Engineers (ASSE), 58(9), 56-61.
33
Crane safety requirements in excess of basic applicable regulatory
requirements.
Dry cutting of concrete specifications.
Temporary bracing design, installation, & maintenance for masonry walls.
Protection from overhead masonry operations.
Protection from overhead welding operations.
Decking debris netting installation & maintenance.
Decking cutoff debris cleanup.
Perimeter cable installation & maintenance.
Rebar cap installation & maintenance.
MECHANICAL
Machine guarding beyond basic applicable regulatory requirements.
Rolling stock (pipes, conduit, etc.) material storage & cut-off cleanup.
Tie-off points for overhead work & tasks near deck edges.
Removal of waste materials left by multiple trades.
Removal, Cleanup, & patching of spray-on structural steel fire-proofing.
Installation & maintenance of access to work areas used by multiple trades.
Protection from welding operations.
Spotters for scissor lift work.
Pressure testing procedures & requirements.
Accessibility to trenches for work purposes.
ELECTRICAL
Electrical safety procedures beyond applicable regulatory requirements?
Small diameter conduit & ground wire impalement protection.
Weather protection of electrical components.
Temporary lighting installation & maintenance.
Theft security provisions for both installed & stored cuprous materials.
Allowance & procedures for electrical hot work onsite.
Electrical work training & experience in excess of basic applicable
regulatory requirements established.
Accessibility to trenches for work purposes.
GENERAL
Installation & maintenance of access to roof work areas used by multiple
trades.
Roof protection after completion.
Perimeter falling objects projection.
Additional safety procedures for stilts used in ceiling work.
34
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o Yes o No o NA
o Yes o No o NA
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o NA
o NA
o NA
o NA
The maximum response time for permits (confined space, hot work,
lockout/tag out, etc.) specified.
Coordination of cranes & critical lift procedures.
Erection & maintenance of task & general lighting.
Material storage areas onsite.
Theft security provisions for both installed & stored materials.
Removal of waste materials left by multiple trades.
Multi-trade scaffold erection, inspection, & maintenance.
Onsite fire protection for the project.
Provisions for onsite safety professionals.
Creation, implementation, & maintenance of traffic control plan.
Safety Management Requirements:
Employee Site Access and Orientation
Safety Training
Safety Meetings
Safety Inspections
Pre-qualification
Pre-bid and Pre-Construction Meetings
Disciplinary Action/Recognition
Pre-task Planning and Job Hazard Analysis
Site Specific Safety Plan
Reporting and Recordkeeping
Solid Waste and Hazardous Waste
Emergency Response Plan
Design for Safety Provisions
Technology Use (e.g., Building Information Modeling (BIM))
35
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
Exhibit 4-2: Example Contract Project Safety Requirements
(Used by Permission from SNC-Lavalin)
Note: This best practice tool is only included as an example, and the users should be aware that the
contractor may reference safety regulations depending on their jurisdictions. It is the user’s responsibility
to ensure that they adapt the best practices provided in this handbook for their jurisdiction and comply
with all applicable local, state, and federal regulations affecting their workplace.
SECTION 01 35 23
PROJECT SAFETY REQUIREMENTS
ARTICLE 1 – CONFIRMATION OF PROJECT HEALTH AND SAFETY GUIDELINES
1.01 1.02 It is the goal of the Construction Manager to ensure that employees and the general public are provided with
an environment free of hazards during construction activities. This program does not relieve Trade Contractor
of responsibility for the health and safety of Trade Contractor’s employees, the employees of subcontractors,
protection of the general public and the preservation of property.
The Construction Manager is committed that all construction workers have the best possible working
environment while working on this project. It shall be the responsibility of each Trade Contractor/
Subcontractor to abide by MOSH and OSHA health and safety laws and regulations.
ARTICLE 2 – HEALTH AND SAFETY STATEMENT
2.01 Trade Contractor shall develop a written site-specific health and safety plans for the Project. At a minimum, the
health and safety plan shall meet the requirements of all applicable OSHA health and safety laws and regulations,
and the requirements established in these Project Safety Requirements. Trade Contractor is responsible for
protecting the safety of its employees and the employees of each subcontractor while ensuring they have a safe
and healthful place to work.
2.02 The health and safety Requirements of these guidelines are a supplementary document to all Government rules,
codes and regulations. It does not negate, abrogate, alter or otherwise change any provisions of these rules, codes
and/or regulations, and is intended to supplement and enforce the individual program of each contractor and the
overall health and safety effort.
2.03 In the event of a conflict between the provisions of these guidelines and applicable local, state, or federal health
and safety laws, regulations and/or standards, contract documents or the Construction Manager’s health and
safety Plan, the more stringent shall apply.
2.04 By reading these guidelines, each individual confirms the understanding of the contents and shall conform to the
standards of health and safety outlined in these Guidelines and the Project health and safety program.
ARTICLE 3 – SECTION SPECIFIC DEFINITIONS
Guidelines – Statements or outlines of procedures or policies that shall be followed and enforced.
Critical Lift – Any lifts:
•
•
•
•
•
•
involving two or more cranes
within the vicinity of power lines
over operating facilities/equipment
where the crane or lifting equipment is 80 percent or above of its rated capacity at the working radius and crane
configuration
that is at or above 50,000 pounds (25 tons)
Involving special equipment or rigging or nonstandard crane configurations (e.g., multi-level rigging, gin-poles,
the use of more than three spreader bars, cargo nets, etc.)
36
•
•
involving hoisting of personnel
of loads that represents significant cost, require significant lead-time to order, are critical to the project, or are
replaceable
The General Public – All persons not employed by or under contract, subcontract or sub-subcontract to the Project
Hazardous Material – Any material that, because of its quantity, concentration, or physical or chemical characteristics,
may pose a real hazard to human health or the environment.
Government – The body that has the authority to make, amend, administer, and repeal laws, regulations and policies, and
has the authority to enforce them.
ARTICLE 4 – RESPONSIBILITIES
4.01 Each participant involved in the construction of the Project is individually responsible for conducting his/her
activities to ensure compliance with all applicable health and safety requirements. Construction activities of Trade
Contractors and Subcontractors will be monitored for compliance with Federal, State and local health and safety
regulations and contract health and safety requirements.
4.02 Trade Contractor shall establish, and submit for review, a written health and safety plan that includes details
commensurate with the work to be performed. Trade Contractor’s health and safety plan shall clearly describe
Trade Contractor’s commitments for meeting its obligations to provide a safe and healthful work environment
for its employees and Subcontractor employees, to protect vendors, visitors, and members of the general public.
Trade Contractor’s health and safety plan shall reference Federal or State standards, and local environmental laws,
and any other rules or regulations applicable to construction activities.
4.03 Trade Contractor shall designate an on-site health and safety representative who is charged with the responsibility
of on-site health and safety management and will be the point of contact for health and safety matters. If Trade
Contractor employees 25 or more employees, Trade Contractor will designate a health and safety representative
whose only duty shall be health and safety management. When Trade Contractor’s manpower on the project reaches
100, an additional acceptable safety supervisor shall be onsite. Additional acceptable safety supervisor(s) shall
be provided for each increase in 100 workers at no additional cost to Construction Manager. Trade Contractor’s
health and safety representative shall be accredited by applicable OSHA requirements as a competent site Safety
Supervisor and have heavy construction health and safety experience. A resume shall be provided that outlines
such items as: work experience, education, training completed and professional organizations, etc. The health and
safety Representative shall remain on the Project until Substantial Completion.
4.04 Trade Contractor shall be responsible for advising all Trade Contractor employees and Subcontractor employees
of the projects health and safety goals, policies, requirements, and procedures during Trade Contractor orientation
session.
4.05 Trade Contractor shall attend a pre-mobilization safety meeting after contract award and prior to Trade
Contractor commencing work on the project. Trade Contractor shall conduct and include Construction Manager
Construction Manager and EHS manager in pre-mobilization meetings with all Subcontractors.
4.06 Trade Contractor shall participate in Construction Manager’s safety interaction process which includes daily
interactions for Trade Contractor field supervision.
4.07 Trade Contractors shall submit to Construction Manager:
 A site-specific health and safety plan within fifteen (15) days after receipt of notice to proceed and prior to
start of any construction activities. The site-specific health and safety plan is to include an overview of the job
hazards expected to be encountered in the performance of their work activities.
 The name and qualifications (resume) of designated on-site health and safety representative;
 An immediate copy of all citations and/or warning of health and safety violations received from any State or
Federal jurisdiction, agency, insurance company, or by any of its Subcontractors.
 A list of any hazardous materials that may be necessary to bring to the project and how each will be handled
to prevent contamination of the site and exposure of employees.
4.08 The Contractor shall:
 Investigate, with Construction Manager, all accidents and incidents that result in personal injury or illness to
workers, damage to buildings or equipment, impacts to on- and off-site environments, and any incident with
the general public.
37
 Participate in weekly health and safety management meetings and monthly project safety committee meetings.
 Conduct daily job inspections, generate daily Team StepBack utilizing Construction Manager’s Team
StepBack form, identify unsafe conditions or work practices and assure they are corrected, and maintain
documentation.
 Conduct weekly, documented, health and safety meetings with supervisory personnel.
 Assure that employees acting in a supervisory capacity understand and enforce all safe work practices.
 Assure a competent person is provided at work locations where required by law.
 Assure that all personal protective equipment (PPE) is available and being properly used as required.
 Assure all construction equipment and motor vehicles certification, inspection, repair and controls are in
compliance with the health and safety requirements of the project and OSHA requirements. All required
equipment inspection certification shall be available for review by Construction Manager.
 Assure detailed lift plans are submitted prior to making Critical Lift,
 Assure that all work areas are kept clear of debris and trash and that adequate trash barrels are placed
throughout the work area and emptied frequently. Waste streams will be segregated as directed by project
requirements.
 Assure Trade Contractor emergency response team is properly trained and provided with adequate supplies.
 Assure that one hundred percent fall protection equipment is provided and used. Inspections of this equipment
shall be documented and on file for review by Construction Manager.
 Assure that all perimeter cables, barricades, or any other safety related items are installed correctly and
maintained. If a safety item must be removed, coordinate this activity with the Construction Manager or
trade contractor who installed the device and other workers who may be exposed. The party that removes
safety devices shall replace safety devices. Warning signs, tags, or barricades shall be installed if other safety
devices are removed.
 Assure that all hazardous materials are properly stored. Storage areas shall be designed to be properly
ventilated and to prevent releases to the environment and contact with precipitation.
 Supply all materials for the control of hazardous energy including locks, lock boxes, chains, and tags bearing
workers name and contact number.
 Assure all monthly inspections include color-coding according to the following table. This shall include,
but not limited to, electrical cords, power tools and equipment, portable fire extinguishers, fall protection
equipment, and rigging. Wherever possible GFCI is a much safer option and always recommended.
4.09 Month/ Quarter
Quarterly Colors
Monthly Colors
January
White
White
February
White
White and Yellow
March
White
White and Blue
April
Green
Green
May
Green
Green and Yellow
June
Green
Green and Blue
July
Red
Red
August
Red
Red and Yellow
September
Red
Red and Blue
October
Orange
November
Orange
Orange
Orange and Yellow
December
Orange
Orange and Blue
Workplace Substance Abuse Policy
Trade Contractor shall comply with Section 01 35 34 Drug & Alcohol Policy
38
ARTICLE 5 – INSTRUCTION AND TRAINING
5.01 Health and Safety Orientation Program
All personnel working on the Project shall receive an orientation regarding the general health, and safety rules
and regulations as well as the site-specific policies and hazards prior to starting work on the construction site. All
Trade Contractor personnel shall attend Construction Manager’s health and safety orientation. Trade Contractor
shall be responsible to ensure that its employees and those Subcontractors attend both Construction Manager’s
and Trade Contractor’s orientation. Documentation of this orientation shall be maintained on file for review by
Construction Manager.
5.02 Risk Competency Training
All Trade Contractor and Subcontractor field supervisory staff shall attend Construction Manager’s 4-hour risk
competency training.
ARTICLE 6 – PROTECTION OF THE PUBLIC
6.01 All necessary precautions to prevent injury to the General Public or damage to property of others shall be taken.
Installation of temporary barriers and/or fencing designated to protect the General Public shall be reviewed and
approved by Construction Manager.
6.02 Work shall not be performed in any area occupied by the General Public unless specifically permitted according to
the terms of the Agreement or in writing.
6.03 Site Visitors:
A.
It is particularly important that a high degree of protection be afforded to all visitors to the Project.
B.
All visitors entering the construction area shall attend a brief safety orientation.
C.
All visitors entering the construction area shall be accompanied by individuals knowledgeable of site
health and safety until such time that the visitor has been trained or is knowledgeable of all requirements.
D.
Visitors shall wear high visibility green hard hats, with the word “visitor” in two inch block letters on the
hard had. Visitors shall also wear high visibility green vests.
ARTICLE 7 – REPORTING, ACCIDENT INVESTIGATION, AND RECORDKEEPING
7.01 Reporting:
A.
All accidents and incidents resulting in employee injury, property and equipment damage, releases to the
environment, or involving the general public shall be reported immediately to Construction Manager’s
health and safety department and project construction manager. This shall include high potential near
miss incidents that could have resulted in significant injury or damage.
B.
Trade Contractor and its Subcontractors shall complete a Supervisor’s Incident Report Form and submit
the report to Construction Manager’s health and safety supervisor for all job-related accidents involving
any of the following:
1.
Any employee injury of Trade Contractor or its Subcontractor.
2.
Any injury and/or incident with the general public (including any alleged injuries reported by a
member of the general public).
3.
Equipment
4.
Property
5.
Releases of hazardous materials
7.02 All accident/incidents shall be investigated by Construction Manager’s health and safety representative and Trade
Contractor’s and/or its Subcontractor’s health and safety designee, if applicable. A written accident investigation
report and first report of injury shall be submitted to the Project health and safety representative, within twentyfour (24) hours of the occurrence.
7.03 Pertinent facts that are not available within the above time shall be submitted as soon as available in a supplemental
report.
7.04 A drug and alcohol test may be administered to all injured employee(s) that require medical treatment beyond first
aid including any employee(s) who contributed to the accident.. Employee(s) involved in an accident that results
in damage to equipment or property in excess of $1,500 may also be administered a drug and alcohol test.
7.05 Trade Contractor and Subcontractors shall maintain a master or central file for health and safety related
documentation on the jobsite. Files shall be maintained in such a manner that distinguishes Trade Contractor
from its Subcontractors.
39
Annual Crane Inspection
Chemical Inventory
Contractor Weekly Inspection
Critical Lift Checklist
First Report of Injury
Incident Investigation Using ICAM Methodology
Safety Data Sheets
Injury and Illiness log
Regulatory Agency Inspections
H&S Observations
Team Stepback Job Hazard Analysis
Job Safety Analysis (JSA)
Risk Register with weekly updates
H&S Statistics
H&S Training
Supervisor Interaction Reports
Substance Abuse Policy
Toolbox Safety Meetings
Daily Equipment / Vehicle Inspections
Hazardous Material Storage Area Inspections
Lifting Equipment
Fall Protection
Mobile Elevated Work Platform
SNC Lavalin Safety Audits
Imminent Danger Records Reports
X
X
X
X
X
X
X
X
EQ
UE
ST
PE
RR
UR
AN
C
X
X
X
X
X
X
X
X
X
X
X
X
X
X
PE
RO
CC
HL
Y
M
ON
T
QU
AR
TE
RL
Y
AN
N
UA
L
E
A.
Trade Contractor shall submit to Construction Manager and have available on site the reports shown
in Table 8.02 – Reporting Requirements. Reports shall be submitted on the following schedule: Daily - Daily
inspections are required on all equipment / vehicles
B.
Weekly - Weekly reports are due the following Tuesday morning
C.
Monthly - Monthly reports are due by the 2nd of the following month
Construction Manager shall have the right to review all health and safety documentation at any time upon request. Trade
Contractor shall give full cooperation during these reviews.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Table 8.02 - REPORTING REQUIREMENTS
ARTICLE 8 – WORK PRACTICE CONTROLS
8.01 In order to provide Trade Contractor employees with a safe workplace, a Job Safety Analysis (JSA) shall be
prepared for pre-planning the overall scope of work to be performed. The Trade Contractor shall also prepare a
JSA upon request by Construction Manager.
8.02
A Team StepBack shall be required for each task to determine if the process, equipment or procedure indicates
potential for serious injury and/or property damage.
ARTICLE 9 – SPECIFIC PROJECT HEALTH AND SAFETY REQUIREMENTS
9.01 Working at Heights
A.
One-hundred percent continuous fall protection, for fall hazards at or greater than six (6) feet, shall
be implemented on this Project. This shall include, but not be limited to, steel erection and scaffold
use, erection and dismantling. Harnesses shall be worn at all times when working at heights even when
permanent facility guardrails are installed and completed unless posted signs indicate otherwise.
B.
Lifelines shall be tagged to indicate that they have been designed and approved by a competent person.
Engineered drawings and inspection schedules are required for all horizontal lifelines prior to use.
C.
A written rescue plan must be developed in advance of work that involves the use of a fall arrest system.
D.
No person shall work alone while working at heights.
40
E.
9.02 9.03 Trade Contractor shall prepare a written auditable training program for all personnel and supervisors to
ensure that each employee who might be exposed to fall hazards is knowledgeable of the fall protection
plan requirements.
F.
Records of all training provided shall be kept on file at the job site and available for review.
G.
Personnel who have been trained and violate the established fall protection plan/regulations shall be
removed from the project.
H.
A Construction Manager Permit shall be required for guardrail and grating removal.
Scaffolds, Stair Towers and Work Platforms:
A.
The Project requires one-hundred percent continuous fall protection during the erection and dismantling
of scaffolds where employees may be exposed to a fall at or greater than six (6) feet. A competent person
must be present during erection, dismantling or moving of scaffolds. Trade Contractor shall develop and
use a scaffold tagging system similar to the following:
1.A tagging system shall be in place that indicates the scaffold is safe for use by designated, trained
personnel. Each tag must be made of weatherproof material and have at least the following information
and be visible by all employees:
 Date tag was placed and date of the last inspection.
 Name of inspecting person. All tags must be weather resistant.
A GREEN tag means the scaffold complies with manufacturer’s and safety requirements and can
be used by any authorized person.
A YELLOW tag indicates the scaffold is complete but does not meet all specifications. This tag
will be used only in special circumstances. Special precautions, such as using a safety harness will
be required because an accessory, such as a handrail, could not be installed due to the location
of the scaffold.
A RED tag shall be placed on a scaffold that is being erected, dismantled, damaged and/or
defective. No employees, except members of the qualified erection/dismantling crew, shall work
from a red-tagged scaffold.
B.
Employees will be instructed to read tags before using scaffolds. If a tag is not attached to the scaffold, the
scaffold shall not be used until inspected by a competent person and the proper tag attached.
C.
Scaffolds shall be inspected daily by Trade Contractor’s designated qualified competent person.
D.
All scaffolds, which are more than twice the height of the base width, shall be secured to a fixed structure
or employ outriggers to prevent tipping.
E.
Scaffolds will be inspected by the competent person prior to use on each shift and as required throughout
the work shift to safely maintain the scaffold.
F.
Scaffolds must be thoroughly cleaned prior to dismantling.
G.
Scaffolding shall be grounded when in close proximity to, or there is a possibility of contact, with energized
high-voltage electrical equipment.
H.
Scaffolding must be sufficiently protected (i.e., jersey barriers) when there is a possibility of contact with
vehicles or equipment.
I.
Stamped engineered drawings shall be available at the worksite during installation, disassembly and use,
for outrigger scaffolds, when pole scaffolding is 60’ or higher, when supported scaffolding is 125’ or higher
and where brackets are used to support cantilevered loads.
J.
Exterior vertical ladders shall not be used on scaffolding over 45 feet (15.72 meters) high
K.
An opening in the railing or perimeter barrier must be provided with a swing gate at each access point, if
feasible.
L.
End frames shall not be used for access use even when designed as ladder rungs.
M.
Guardrail systems or other fall protection methods shall be used on all rolling scaffolds.
Walking and Working Surfaces:
A.
Temporary guardrails shall be erected in all elevated work areas as quickly as possible. Tie-off points in
lieu of guardrails are not acceptable where normal work activities are taking place.
41
9.04 9.05 9.06 9.07 9.08 9.09 9.10 Barrier Identification Tape:
A.
Barrier identification tape is strictly prohibited from being used for any form of personnel fall protection.
Barricade tape around excavations can be used for short term (24-hours), after this period physical
barriers are required.
B.
YELLOW barricade tape shall be used for CAUTION/WARNING
C.
RED barricade tape shall not be used. Red rope, issued by Construction Manager, will be used for
DANGER, DO NOT ENTER. A Construction Manager red rope permit shall be required.
Note: Once the area barricaded is free of the hazard(s) for which it was erected, the tape or rope will be
removed and properly discarded.
D.
An assessment of the possibility of falling objects must be completed and appropriate controls must be
put into place. Controls may include – but are not limited to – barricades, warning signs, tethering tools,
debris nets, snow fences and overhead canopies.
Mobile Elevated Work Platforms:
A.
The following controls are required:
1. A signaler/ground guide is utilized while travelling in congested areas.
2. An exclusion zone is set up around the machine to deter unauthorized entry.
3. A harness and lanyard is attached to the manufacturer-installed anchor point at all times when a
worker is inside the basket.
4. A spotter shall be provided any time a MEWP is moved to ensure safe movement, identifying
potential pinch points, and to lower the platform in the event of an emergency. The Team StepBack
shall evaluate and determine if a full-time dedicated spotter is required.
Confined Space Entry:
A.
Construction Manager’s confined space permit shall be required prior to any excavation activities.
B.
All spaces shall be considered permit-required confined spaces. Trade Contractor shall train all personnel
who will enter the confined space. No one shall enter a confined space area until properly instructed.
Employee Ground Transportation:
A.
Trade Contractor is responsible for assuring that all personnel follow the requirements of this section and
prohibit improper transportation of employees and visitors. Transporting employees in cargo beds of
pick-ups, etc. is prohibited.
B.
Mobile cranes, forklifts, winch trucks, front-end loaders, tractors and other materials handling equipment
are not permitted to transport passengers.
C.
Vehicles must be designed to accommodate passenger transportation or the vehicle shall not be used for
that purpose.
Housekeeping:
A.
Trade Contractors shall monitor its work areas daily, or more frequently if needed, to assure that all
debris are removed to minimize hazards.
Project Electrical Requirements:
A.
Trade Contractor shall implement an Electrical Safety Program. This program shall include safe installation,
work practices, maintenance, and special equipment considerations. All electrical installations, either
temporary or permanent, shall be in conformance with the OSHA Electrical Code, NFPA-70, ANSI-C1,
and low and high voltage electrical safety orders per OSHA health and safety requirements
Cranes and Hoisting Equipment:
A.
Cranes and hoists shall have a current annual certificate of examination and testing issued by an accredited
crane examiner. Annual inspection certificates and operators manual shall be in the cab of each crane
prior to crane operation.
B.
Only qualified and designated personnel shall operate cranes or hoisting equipment. Crane operators
shall be NCCO certified for class of crane operated.
C.
Outrigger cribbing shall be used for all crane operations. All cranes shall have have boom angle indicators
and anti-two block devices installed and operating properly.
D.
Load cells, moment indicators and external rated capacity lighting shall be available in accordance with
the table below.
42
Crane Type
Load Moment
Indicator
Load
Cell
External
Rated
Capacity
Lighting
Mobile Rough Terrain
Shall
Shall
Shall
Mobile Truck Mounted
Shall
Shall
Shall
Crawler
Shall
Shall
Shall
Pedestal and Tower
Shall
Shall
Should
Electric Overhead Traveling
Not Applicable
Should
Should
Mobile Pick and Carry >10 Tons
Should
Should
Should
Vehicle Loading Crane/Boom Truck
Shall
Shall
Shall
Portal
Not Applicable
Should
Should
E.
9.11 9.12 The swing radius shall be barricaded or other positive means shall be taken to prevent personnel from
entering the area between the counter weight/swing radius and any stationary and/or outside obstructions.
F.
A lift evaluation form shall be completed and submitted at least 5 days prior to any Critical Lift activity
A detailed lift study shall be completed and shall be reviewed by a registered professional engineer for
all Critical Lifts involving two or more cranes, lifts at or above 200,000 pounds (100 tons), lifts where the
crane or lifting equipment is 90 percent or more of its rated capacity at the working radius and crane
configuration, loads that represents significant cost, require significant lead-time to order, are critical to
the project or are irreplaceable, or, lift where additional controls are wanted or necessary. All other lifts
shall be documented on the Daily Crane Operation Log.
G.
All Critical Lifts shall be under the direct supervision of a master/lead rigger.
H.
All rigging used in critical lifts shall be inspected for compliance with all requirements by the master/lead
rigger.
I.
Notification shall be made to the Commissioner of Labor and Industry forty-eight hours prior to the
commencement of any lift involving multiple cranes
J.
Taglines shall be used to control all loads
K.
All rigging operations shall be planned and supervised by competent personnel to ensure that the best
methods and most suitable equipment and tackle are employed.
Vehicles and Mobile Equipment:
A.
All vehicles and mobile equipment shall be maintained in safe working condition and shall be appropriate
and adequate for the intended use.
B.
Only authorized personnel shall operate equipment. Operators of equipment, machinery or vehicles
shall be certified for the operation involved. Equipment shall be operated in a manner that reduces dust
emissions.
C.
Vehicles and mobile equipment shall be moved with the assistance of a flag person (spotter) in areas
with poor visibility, for oversized loads, when operating in tight areas or other high-risk situations. This
includes the movement of mobile elevated work platforms in congested areas.
D.
Equipment shall not be operated unless all required safety devices are in place and functioning properly.
E.
All equipment including forklifts, dozers, front end-loaders, etc. shall have a reverse signal/back-up alarm
audible above surrounding background noise.
F.
Mobile equipment shall not be left unattended unless parked securely to prevent movement, with all
ground engaging tools lowered to the ground, brakes set and the engine off.
G.
When fueling equipment or vehicles the engine shall be shut down.
Welding & Cutting:
A.
Flash arrestors shall be installed in both oxygen and acetylene hoses at the regulator connection.
B.
Welders shall wear approved eye and head protection when welding. Personnel assisting the welder shall
also wear approved eye and head protection.
C.
Welding screens and welding fume extractors shall be used when other workers are in the vicinity of the
welding activities.
43
D.
9.13 9.14 Prior to welding or cutting a 20 lb ABC rated fire extinguisher shall be within easy reach of the worker.
A fire watch shall be stationed at all locations where sparks and/or flames may fall to a lower floor/work
area or to another side of a wall.
E.
Oxygen and acetylene cylinders shall not be stored inside buildings.
Personal Protective Equipment (PPE):
A.
All employees shall wear safety glasses while on the construction site. Minimum eye protection shall
include approved safety glasses with side shields that meet the standards specified in ANSI Z87.1-2003
B.
Additional eye and face protection in combination shall be worn when required.
C.
All construction workers shall wear hard hats that meet ANSI Z89.1-1997, while on the construction site.
Cowboy style hard hats are not allowed.
D.
Gloves shall be carried by personnel at all times and maintained in good condition. Gloves shall be worn
when handling material, performing jobs the present hazards to the hands, moving between elevations,
where indicated on the StepBack job hazard analysis, or entering areas where gloves are specifically
required PPE.
E.
Appropriate hearing protection shall be worn in work areas where noise levels are at 85 dBA or greater.
F.
Trade Contractor shall establish and implement a respiratory protection program when work activity
warrant that employees wear respiratory protection. The program shall meet the requirements set forth
in NIOSH/MSHA recommendations.
G.
All personnel on the construction site shall wear sturdy leather, hard-soled work boots. Boots shall measure
at least 6” from heal to top of ankle support. No one is permitted to wear sneakers (including ANSI
approved), tennis shoes, or athletic shoes of any type, sandals, high heels or thongs on the construction
site. Safety toe footwear is required for workers exposed to a crush hazard.
H.
Suitable clothing for construction shall be worn on the construction site. Shirts with sleeves (at least 3 in
length) and full-length pants, or full coveralls, shall be required. Shorts, sweat pants, or tank tops are not
allowed.
I.
High-visibility vest or high-visibility clothing meeting the requirements of ANSI Type II or Type III
(CSA or EN equivalent) depending on the activity performed.
Excavations:
A.
Construction Manager’s excavation permit shall be required prior to any excavation activities.
B.
Spotter personnel shall be used whenever mechanical excavation work comes within three (3) feet of a
buried utility. The spotter shall make certain by manually excavating or hydro-vacuuming that continuation
of mechanical excavation will not contact the buried utility. This requirement shall remain until utility is
adequately exposed and mechanical excavation can continue without risk to the utility.
C.
All open trenches and excavations greater than three (3) feet (.91 meter) shall be shall be protected by
a complete guardrail system or safety fencing (snow fencing). The system shall be erected around the
complete perimeter of the excavation.
END OF SECTION 01 35 23
44
5
PRE-BID AND PRE-CONSTRUCTION MEETINGS
5.1 PURPOSE
This chapter is intended to provide information and guidelines for conducting the safety portion of
the pre-bid and pre-construction meetings. Inclusion and discussion of safety and health in the early
stages of a construction project through pre-bid and pre-construction safety meetings will result in
better project safety performance.
5.2 PRE-BID MEETINGS
Pre-bid meetings are usually held by the Project Manager or the Contract Manager, in response to a
solicitation or request for proposal (RFP). If the company has a safety pre-qualification process in
place, the meeting should only be attended by safety pre-qualified bidders. The pre-bid meeting provides
an opportunity to the bidders to learn more about the unique challenges or hazards associated with
the project and ensure they have a clear understanding of the scope of work requirements including
expectations for safety and health performance. The pre-bid meeting will also help clarify any bidder
concerns or questions. In order to hold a successful pre-bid meeting the following items should be
considered:
Accept bids only from safety pre-qualified bidders.
Develop and communicate the meeting agenda, date, time, and the location to the bidders at
least a week in advance.
Coordinate a construction site walk-through, which will help the bidders familiarize themselves
with the existing project conditions that may have an impact on project safety performance
(e.g., Overhead power line runs across the project site).
Hold the pre-bid meeting at least two weeks in advance of the contract award which will give
the bidders enough time to react to any changes or new information provided at the pre-bid
meeting.
Require mandatory pre-bid meeting as a prerequisite for submitting a bid. Document the
meeting attendance with the help of a sign-up sheet.
Assign either the project manager or contract manager as the chairperson to run the meeting.
Require at a minimum the bidder’s project manager and a safety representative to be in
attendance.
Develop and use a pre-bid meeting safety checklist to review project safety goals and requirements
with all prospective bidders. A sample safety requirements checklist template is provided in this
chapter as Exhibit 5-1 that covers the key safety topics that should be discussed during the prebid meeting.
45
Allow sufficient meeting time to ensure all critical items are covered during the meeting. It is
important to know whether there will be a construction site walk-through since it will impact
the overall meeting duration.
Maintain, and publish written pre-bid meeting minutes to all bidders.
5.3 PRE-CONSTRUCTION MEETINGS
Pre-construction meetings provide an opportunity to begin communication about project safety
requirements between the contracting parties (e.g., Owner versus General Contractor, General
Contractor versus Subcontractors), and address project-specific challenges and hazards. This meeting
will provide “detailed” safety direction and guidance to the contractor. The pre-construction meeting
is highly recommended for large or complex projects, but will also be beneficial to hold such meetings
for smaller projects as well.
The Project Superintendent typically runs the pre-construction meetings, after the contract is
awarded, and before the contractor begins work. This meeting is typically included as part of the
project mobilization meeting. Consider the following items when planning the pre-construction safety
meetings:
Hold the meeting only after the receipt and review of the contractor’s written safety program.
Be prepared to discuss your concerns with the contractor’s safety program and suggest
recommended corrective actions.
Hold the meeting at the project site and be prepared for a construction site walk-through.
Strongly encourage attendance by a majority of the contractor representatives from both
the project management (project manager, cost engineer, and schedule manager) and field
management (project superintendent, field superintendent, and General Foreman) including
safety.
Start the meeting by communicating the project’s commitment to worker safety and health.
Define safety responsibilities.
Require the contractor to submit all the required safety submittals before mobilizing on site.
Address all the unique challenges associated with the project and necessary control measures
and all the project specific safety requirements.
Use a pre-construction safety meeting checklist or agenda, to document the safety portion of
this meeting as presented in this section as Exhibit 5-2 which covers the key Environmental,
Safety, and Health topics to be discussed during the pre-construction meeting. In addition, a
best practice example pre-construction/mobilization form from a large construction firm is also
presented as Exhibit 5-3.
Obtain the site safety point of contact and emergency action plan information.
Receive acknowledgment and commitment to project-specific safety requirements from the
contractor by signing the checklist, before commencing work.
Note: The template forms and checklists are long and detailed, but readers are reminded that these
are just examples. Contractors can choose to use shorter versions of these forms that can still be very
effective.
46
Exhibit 5-1: PRE-BID MEETING SAFETY CHECKLIST
***Note typically site safety will be one of the several items discussed during the pre-bid meeting***
Date: ________________________________ Location:_____________________________
Project Name/Location: _______________________________________________________
Contract Package (e.g., Excavation): ____________________________________________
Introductions
Route Sign-up Sheet
Project Description & Scope of Work
Staging, Access, Parking, and Use of Facilities
Lunch Tent/Sanitary Facilities
Site Work Hours (start time/end time)
Cleanup and Environmental Considerations
Substance Abuse Program
Required Safety Submittals
Safety Personnel Contact
Written Safety Program
Corrective Action Plan (CAP) (if required)
Insurance Coverage Proof
Unique Project Safety Challenges and Hazards
Dig Permit
Air Quality (Odors, Fumes, Noise, Dust, etc.)
Fire Alarm System and Bypass Requirements
Lead and Asbestos Abatement/Training
Public Protection
PPE requirements
Questions?
Construction Site Walk through
47
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o Yes
o Yes
o Yes
o Yes
o Yes
o Yes
o No
o No
o No
o No
o No
o No
o NA
o NA
o NA
o NA
o NA
o NA
o Yes o No o NA
Exhibit 5-2: PRE-CONSTRUCTION MEETING SAFETY CHECKLIST
***Note typically site safety will be one of the several items discussed during
the pre-construction meeting***
Date: ________________________________ Location:______________________________
Project Name/Location: _______________________________________________________
Subcontractor Name: _________________________________________________________
The following items were reviewed with the contractor
Introductions
o Yes o No
Sign-up Sheet
o Yes o No
Project Description & Scope of Work
o Yes o No
Project Safety Goals and Commitment
o Yes o No
Duties and Responsibilities of Contractors
o Yes o No
Staging Area and Job Site Use
o Yes o No
Trailer or Connex Placement Request
o Yes o No
Site Access – Keys, Passes, hard hat stickers, Badges
o Yes o No
Parking (Company vs. personal vehicle)
o Yes o No
Deliveries
o Yes o No
Material and/or debris storage and disposal
o Yes o No
Lunch Tent/Sanitary Facilities
o Yes o No
Site Security and Temporary Fencing/Gate Locations
o Yes o No
Typical Site Work Hours Limit (start time/end time)
o Yes o No
After Hour Work Permission Requirements
o Yes o No
Project Supervision Requirements and Notification
o Yes o No
Visitor Restrictions/Sign-in Log
o Yes o No
Dig Permit
o Yes o No
Air Quality (Odors, Fumes, Noise, Dust, etc.)
o Yes o No
Fire Alarm System and Bypass Requirements
o Yes o No
Camera Pass
o Yes o No
Medical
Drug & Alcohol Testing Requirements
o Yes o No
Occupational Clinic Locations/Map/Phone
o Yes o No
Emergency Plan posted in trailer (muster points, contact lists)
o Yes o No
AED Equipment/First Aid Kit Locations
o Yes o No
Medical Services Requirements
o Yes o No
Commitment to Light Duty /Return to Work Program
o Yes o No
48
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
o NA
Safety & Health Management
o Yes o No o NA
Compliance with DOSH requirements
o Yes o No o NA
Project Safety Staffing
o Yes o No o NA
Accident Reporting, Investigation, and Documentation
o Yes o No o NA
Approved Written Site-Specific Safety Plan
o Yes o No o NA
Project Disciplinary/Inventive Procedures
o Yes o No o NA
Job Hazard Analysis
o Yes o No o NA
Contractor Safety Representative
o Yes o No o NA
New Employee Orientation
o Yes o No o NA
Proper Personal Protective Equipment
o Yes o No o NA
Safety Meetings (type, schedule, & documentation)
o Yes o No o NA
Safety Training & Certification Verification
o Yes o No o NA
Safety Inspections (type, schedule, & documentation)
o Yes o No o NA
Required Weekly Safety Documentation
o Yes o No o NA
Identify DOSH Competent/Qualified Site Supervisor
o Yes o No o NA
Daily Housekeeping/Composite Debris Policy
o Yes o No o NA
Steel Erection Planning
o Yes o No o NA
Crane Inspection/Operator Certification
o Yes o No o NA
English Language /Non-English
o Yes o No o NA
Stretch and Flex
o Yes o No o NA
Environmental Hazards
o Yes o No o NA
Runoff Protection
o Yes o No o NA
Hazardous or chemical spill procedures
o Yes o No o NA
Proper cleaning and fueling of equipment onsite
o Yes o No o NA
Concrete Washout Area
o Yes o No o NA
Asbestos, Mold, PCB or lead – Suspected procedures
o Yes o No o NA
Contaminated Soil – Suspected procedures
o Yes o No o NA
Unique Project Safety Challenges and Hazards
o Yes o No o NA
Questions
Construction Site Walk through
Additional Notes/Comments:
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
49
PRE-CONSTRUCTION SAFETY MEETING ACKNOWLEDGEMENT
We have discussed and understand the Environmental, Safety, and Health requirements of this
project.
Contractor agrees to comply fully with all the Environmental, Safety, and Health laws, rules, regulations,
and procedures in effect on the site. Contractor agrees to communicate these requirements to any subtier contractor(s) brought onsite to complete its scope of work.
______________________________________
Contractor Management (Name)
______________________________________
<Company Name> Management (Name)
______________________________________
Contractor Management (Signature)
______________________________________
<Company Name> Management (Signature)
50
Exhibit 5-3: Example Contractor Pre-Construction/Mobilization Form
(Used with Permission from SNC-Lavalin)
Note: This best practice tool is only included as an example, and the users should be aware that the
contractor may reference safety regulations depending on their jurisdictions. It is the user’s responsibility
to ensure that they adapt the best practices provided in this handbook for their jurisdiction and comply
with all applicable local, state, and federal regulations affecting their workplace.
We have discussed and understand the Health & Safety requirements of SNC-Lavalin.
_________________________________________________________________________
Company Name
Date
_________________________________________________________________________
Subcontractor Representative (Name)
Subcontractor Representative (Signature)
1
2
A. MOBILIZATION STRATEGY
Meetings “We Care”/Safety
Daily Tool Box Meetings (all attendees must sign in)
3
Complete JSA’s as appropriate
4
5
6
7
8
9
10
11
12
13
a.
StepBack (team and personal) conducted (all members
must sign in and copies retained)
Weekly safety meetings to be held
Daily work plans to be submitted including type of work
planned, manpower, equipment and tools used
Develop a site-specific risk register
Develop a site-specific H&S manual
Dedicated H&S Coordinator(s) appointed
Transportation in / out of site (air / buses) arranged
Identification of company employees (e.g. hard hat sticker, badges, etc.)
Security access card system
First Aid Personnel (number qualified)
All supervisors must be qualified
Workers qualified per legislation (e.g. Alberta OHS
Code part 11)
14 First Aid Facility and Supplies
Any injured employee must be seen by the medical
a.
facilities
b.
51
YES / NO /N/A
COMMENTS
b.
c.
d.
e.
15
a.
b.
c.
d.
e.
16
a.
b.
c.
d.
e.
f.
g.
17
a.
b.
c.
d.
e.
18
a.
b.
c.
d.
e.
19
a.
b.
c.
d.
e.
A. MOBILIZATION STRATEGY
Immediately reported verbally
Preliminary report completed within 24 hours
Investigation report completed within seven days
Imminent danger and near misses reported
Vehicles – Proper Safety Equipment and Inspections
20 lb. ABC fire extinguisher
First-aid kit
Back-up alarm (vehicles 1 ton and over)
Company logo visible on both sides of vehicle (minimum 2” height)
Vehicle numbers on the rear window
Vehicles – Registration and Insurance
Proof of registration
Minimum $3 million liability insurance for each vehicle
All drivers to have valid a driver’s license
Seat belt mandatory
Gasoline storage and handling
Vehicle pass program
Roll over protection (if applicable)
Site Evacuation
Contractor has adequate transportation for full site
evacuation of employees
Emergency procedures established and known to all
Muster point
Updated contact lists
Alarm type and procedures
Training
Orientation
ID badges, returned for terminated employees
Site training requirements
Employee training log submitted
SNC-Lavalin orientation video shown
Permit Programs in Place
LOTO/Isolation
Excavations and earth works
Hot work
Work at height
Confined space
52
YES / NO /N/A
COMMENTS
A. MOBILIZATION STRATEGY
YES / NO /N/A
COMMENTS
20 Positive Incentive Program
a.
Requirements
b.
Ratios and budget
c.
Participation
21 Safety Interactions
22 Audits
a.
Internal (self-audit)
b.
External (corporate and regulatory audits)
B. SAFETY EQUIPMENT TO BE MOBILIZED/PROVIDED BY THE CONTRACTOR
1
Safety signage
a.
Caution
b.
Working above
c.
Caution construction area
d.
Danger open excavation
No smoking
e.
f.
Yellow / red flagging
g.
Confined space
h.
Danger
i.
Power lines
X-ray
j.
k
Welding in progress
l.
Other
2 Breathing Apparatus and Fit Testing
a.
SABA
b.
SCBA
3 Fire Fighting Equipment
a.
Extinguishers – quantity of 20 lb ABC
b.
Extinguishers – quantity / size of CO2
c.
Water trucks
d.
Water management / dewatering logs
4 Safety Harnesses / Shock Absorbing Lanyards
a.
Inspection program
b.
Training
c.
Storage
5 Personal Protective Equipment (as per 6845.3.2.1-EN minimum requirements)
a.
Hard hats/helmets, high visibility reflective striping
b.
Safety glasses w/side shields
c.
Safety footwear
53
d.
e.
f.
g.
6
a.
b.
c.
7
a.
b.
8
a.
b.
9
10
a.
b.
11
a.
b.
c.
d.
12
13
14
15
16
B. SAFETY EQUIPMENT TO BE MOBILIZED/PROVIDED BY THE CONTRACTOR
High visibility attire (Class I, II, or III)
Hand protection
Hearing protection
Long pants and 4” shirt sleeve
Scaffolding including Tag System and Tags
Inspection
Color coding
Certifications
Lockout System in place including Tagging/Sign-out Log Book
Procedures
Training
Ladders
Procedures
Training
Lunchroom Facilities
Toilets (i.e. Alberta OHS Code, Part 24 and Schedule 7)
One toilet for 10 persons as a general guide
Additional toilets for women
List of Tools and Equipment, Inspected on a quarterly basis (color code example)
Yellow  January – March
Green  April – June
Red  July – September
Blue  October – December
Log for disposal of any Hazardous and Non- Hazardous Material
Duplicate copy of the MSDS manual
Radio, cell phone access
Camera passes required on site
Other safety equipment (specify)
We have discussed and understand the Health & Safety requirements of SNC-Lavalin. We will be in
full compliance to the SNC-Lavalin Critical Risk Control Protocols at all times unless an Approval
for Alternate Controls has been completed and approved where necessary.
Subcontractor agrees to identify minimum training requirements and retain records for the duration
of the project for all company workers and contractors.
Subcontractor agrees to provide and ensure the proper use thereof, of all required safety equipment
including that specified on this checklist.
54
____________________________________________________________________________
Subcontractor Management (Name)
Subcontractor Management (Signature)
_____________________________________________________________________________
SNC-Lavalin Management (Name)
SNC-Lavalin Management (Signature)
_____________________________________________________________________________
Project Management (Name)
Project Management (Signature)
55
56
6
PROJECT SAFETY STAFFING
6.1 PURPOSE
This chapter is intended to provide guidelines to identify quantities, qualifications, and responsibilities
of the project safety staff to support the project. The guidelines provided in this chapter are just a
roadmap that contractors can use all or in part that fits their company process, culture, size, and
financial resources.
6.2 PROJECT SAFETY STAFFING
The project safety staffing varies from project to project depending on the company staffing policy,
project budget, owner contract requirements, project complexity, perceived risk level, size, industry
segment, and a project’s geographic location. Unfortunately, there is no such thing as construction
“industry norm” as it pertains to project safety staffing. Hence, before deciding on project safety
staffing, the contractors should consider these following key questions.
What safety staff requirements were specifically included in the owner’s construction contract?
o Does the safety professional have to be full-time or part-time?
o Does the safety professional have to be designated or dedicated?
o Can the safety professional have any responsibility on other projects?
o What are the minimum qualifications for the safety staff in terms of education, work
experience, and professional certifications?
o Do the contracts call for services of specialists such as industrial hygienists,
ergonomists, security managers, and environmental compliance managers?
Did the owner allow or allocate any specific amount of funds for project safety staffing?
How intensive is the project’s training, inspection, and reporting and recordkeeping
requirements?
What is the total estimated cost of construction of the project?
What is the level of complexity of the project defined in terms of anticipated and recognized
high hazards expected on the project?
How many subcontracts will be awarded on the project?
What percentage of the subcontractors were awarded contracts on a probationary status and
will be performing work with a corrective action plan (i.e. their safety performance was below
an acceptable level during the pre-qualification process)?
o Identify those subcontractors to see if you need safety staffing, and/or will you require
them to add safety staff.
How many total workers are expected on the project?
How many workers are expected on site during peak time?
How many worker-hours will be expended on this project?
57
Is the project undertaken under an owner-controlled insurance program (OCIP) or
Contractor Controlled Insurance Program (CCIP)?
Will the project owner assign an owner safety representative to this project?
It is apparent that there is no one-size-fits-all solution as it comes to project safety staffing. However,
contractors should consider all the pertinent factors and come up with a staffing level that will
improve the project safety performance.
6.3 DESIGNATED SAFETY REPRESENTATIVE
A designated project safety representative is an individual who may hold non-safety related duties but
is present at the site full-time (e.g., Superintendent). Some staffing guidelines about a designated safety
representative are presented in this section.
6.3.1 Quantity
Each contractor on the project should be required to “designate” an individual to be responsible
for the project safety activities when the crew size is less than “X” employees (e.g., 20 employees),
including all tiered subcontractor employees (or) the contract value is below $X million in labor only
(e.g., $500,000). The benchmarked number should be based on the contractor risk level and past safety
performance.
6.3.2 Site Presence and Coverage
Each contractor should provide safety coverage during all off-shift work, e.g., a three a.m. concrete
pour. It is recommended to state clearly that the designated safety representative should be required
to be on-site at all times when workers are on the jobsite. It is recommended that no subcontractor
labor be allowed on a jobsite without, at least, one designated safety representative, for the general
contractor, onsite at all times.
6.3.3 Qualifications
It is recommended that the highest level of supervision (i.e., Superintendent or General Foreman) on
the site to be selected as the designated safety representative. Depending on the project risk level, the
qualifications of the designated safety representative should be clearly defined in terms of construction
industry experience and professional development safety training or certifications. It is recommended
that the minimum qualification for the designated safety representative should include at least five
years of appropriate construction specialty experience and OSHA 30-hour outreach training.
Recently, the Board of Certified Safety Professionals (BCSP)1 has introduced a certification called “Safety
Trained Supervisor (STS)®. The STS certification provides a means for employers to verify safety and
health knowledge of first-line supervisors, managers, and any other person with safety responsibilities. The
program requires applicants to meet minimum education and experience requirements and demonstrate
knowledge of basic safety and health standards and practices. The STS program is nationally accredited
by the National Commission for Certifying Agencies (NCCA). Contractors may also choose to
1 Board of Certified Safety Professionals (BCSP). Certifications. www.bcsp.com (Accessed January 3, 2015)
58
require that designated safety representatives at a minimum to hold this certification. However, this is
a relatively new certification and not many supervisors currently hold this designation.
6.3.4 Documentation and Approval
All proposed designated safety representatives should be approved by the contractor prior to award of
the contract or at the pre-construction meeting to ensure that the person meets the project expectations
and has the necessary qualifications to support the applicable project scope.
6.4 DEDICATED SAFETY PROFESSIONAL
A dedicated safety professional is an individual who shall not hold other non-safety duties and is
present at the site full-time. The dedicated safety professional should be responsible for developing,
managing, implementing, and enforcing the contractor’s written safety and health program and may
include input from others. Some staffing guidelines about a dedicated safety professional are presented
in this section.
6.4.1 Responsibilities
Responsibilities of the project safety professional should be explicitly stated during the approval
process and communicated to the prospective professionals. An example of project safety staffing
policy and responsibilities is presented as Exhibit 6-1.
6.4.2 Quantity
Each contractor on the project may be required to provide a dedicated on-site full-time qualified safety
professional when:
•
•
•
•
Actual or expected crew size reaches “X” employees (e.g., 20 employees)
Required by the contractor’s corrective action plan as part of the pre-qualification process
The contract value exceeds $X million in labor only (e.g., $5 million), or
Hazardous activities are predetermined to be present
Furthermore, the contractor may also define when the project requires additional on-site full-time
qualified safety professional. For example, an additional safety professional may be required for each
crew size increment of fifty employees or increments of $10 million in labor only thereafter. This
requirement must be defined in all contracts to each, separate, contractor.
6.4.3 Site Presence and Coverage
Each contractor should provide safety coverage during all off-shift work, e.g., a three a.m. concrete
pour. It is recommended to state clearly that the dedicated safety professional should be required to
be on-site at all times when workers are on the jobsite. It is recommended that no subcontractor labor
be allowed on a jobsite without a designated competent person on site for each subcontractor and as
supervision for the general contractor.
59
6.4.4 Qualifications
Depending on the project risk level, the qualifications of the dedicated safety professional should
be clearly defined in terms of education, appropriate construction industry safety experience, and/or
professional certifications.
6.4.5 Experience
The more complex and riskier the project the more stringent the qualifications. For example, when
requiring a dedicated safety professional for a crane and rigging subcontractor, the individual should
have adequate experience in that discipline.
6.4.6 Education
A 2011 report prepared for the National Institute for Occupational Safety and Health (NIOSH)
titled “National Assessment of the Occupational Safety and Health Workforce,” reported that the
majority of the safety professional employers are looking for professionals with bachelor’s degreelevel.2 On projects that will include numerous site safety professionals, it is typical to assign a Project
Safety Manager who will be the lead on the site. Some contractors and Owners prefer college educated
construction safety professionals to take on the role of Project Safety Manager to manage construction
safety programs including the safety staff at the project level. Here is an example requirement, “The
safety manager must hold a safety engineering or equivalent qualification and have a minimum of seven
years’ experience in construction safety and five years of management experience.”
Readers should understand that not all contractors, especially smaller contractors will not hire or
be able to hire a safety professional with a college degree. Under those circumstances contractors
are recommended to hire safety professionals with certain field safety experience and minimum
certifications such as:
o
o
o
o
o
o
OSHA 30 and/or OSHA Outreach Trainer
Certified or trained Rigging/Signal Person
Scaffold Competent Person
Fall Protection Competent Person
Confined Space Competent Person
Certified Flagger
These professionals should be backed up by corporate safety professionals who have the 4-year safety
degree and applicable professional certifications.
6.4.7 Certifications
Some Owners and few Contractors have also started to require professional certifications such as the
Board of Certified Safety Professional’s (BCSP) Construction Health and Safety Technician (CHST)®
and Certified Safety Professional (CSP)® for their safety staff.
2 National Assessment of the Occupational Safety and Health ... (n.d.). Retrieved from http://www.cdc.gov/niosh/oshworkforce/_br
60
The Construction Health and Safety Technician (CHST) certification is designed for individuals who
demonstrate competency and work part-time or full-time in health and safety activities devoted to the
prevention of construction illnesses and injuries. The CHST certification meets national standards
for certifications. Candidates for the CHST certification are typically employed as safety and health
specialists on construction job sites, serving in either full-time or part-time positions. Typical individuals
are responsible for safety and health on one or more significant construction projects or job sites. They
may work for an owner, general contractor, subcontractor, or firm involved in the construction or
construction safety.3
A CSP (Certified Safety Professional), awarded by BCSP, is certified in the comprehensive practice
of OSH. Certified Safety Professionals (CSP) are persons who perform at least 50% of professional
level safety duties including; are making worksite assessments to determine risks, potential hazards
and controls, evaluating risks and hazard control measures, investigating incidents, maintaining and
evaluating incident and loss records, and preparing emergency response plans. Other duties could
include; hazard recognition, fire protection, regulatory compliance, health hazard control, ergonomics,
hazardous materials management, environmental protection, training, accident and incident,
investigations, advising management, record keeping, emergency response, managing safety programs,
product safety and/or security.4
More information about the certifications is available at www.bcsp.com. Please note according to the
American Society of Safety Engineers (ASSE), certifications should be from a professional safety
organization accredited by the National Commission of Certifying Agencies (NCCA) or the Council
of Engineering and Scientific Specialty Boards (CESB), or a nationally recognized accrediting body
that uses certification criteria equal to or greater than that of the NCCA or CESB, certification is an
independent third-party indicator of achievement.5
6.4.8 Specialists
Even though it is not common, depending on specific project needs, certain large projects (for example
projects over $1 billion in construction cost) will include specialists such as Ergonomists, Industrial
Hygienists, Security Managers, and Environmental Compliance Manager Full-time on-site. However,
for small to medium sized projects, it is typical practice to employ these specialists on an as-needed
basis. For example, the project might need to employ an industrial hygienist for only a week, when
excavating, transporting, and disposing of contaminated soil or to perform a noise study to analyze
project impacts on the neighborhood residential community. Selected certifications are listed below:
o CIH (Certified Industrial Hygienist) has an emphasis on evaluating and controlling physical,
chemical, ergonomic and biological hazards. www.abih.org/certified
o CFPS (Certified Fire Protection Specialist) has responsibilities regarding the application of
technologies in fire safety, fire protection, prevention, and suppression. www.nfpa.org
3 Board of Certified Safety Professionals (BCSP). Certifications. www.bcsp.com (Accessed January 3, 2015)
4 Board of Certified Safety Professionals (BCSP). Certifications. www.bcsp.com (Accessed January 3, 2015)
5 Board of Certified Safety Professionals (BCSP). Certifications. www.bcsp.com (Accessed January 3, 2015)
61
o CHMM (Certified Hazardous Materials Manager) is involved in environmental protection,
waste management, dangerous goods transportation, safety, and materials handling. www.
ihmm.org
6.4.9 Documentation and Approval
Documentation of qualifications should be submitted to the Contractor prior to the award of any
resultant contract. All proposed dedicated safety professional should be approved in advance by the
Contractor prior to award of the contract or at the pre-construction meeting to ensure the person
meets the project expectations and has the necessary qualifications to support the applicable project
scope.
6.5 COMPETENT PERSON
The constructor and subcontractors should assign a competent person who is capable of identifying
existing and predictable hazards in the work environment, which are hazardous or dangerous, and has
the authority to stop work or take corrective actions to eliminate the conditions. A list of all major
activities in the project should be created and whether or not a competent person would be required at
the start of the project. In addition to the DOSH-required competent person mandate, the competent
personnel should be required for various other activities if possible.
6.6 FUTURE CONSTRUCTION SAFETY PROFESSIONALS
The demand for qualified safety professionals has increased tremendously in recent years. It has been
anticipated there will be a shortage of skilled Occupational Safety & Health (OS&H) in the near
future. One of the best ways to overcome the shortage of trained Construction OS&H professionals is
starting a construction safety internship program.
It was previously indicated that more and more employers are leaning towards college educated
construction safety professionals.6 It is critical that contractors set a goal to recruit and retain the best
and brightest of these entry-level safety professionals. One of the best ways to achieve this goal is to
start an internship or cooperative education program with universities that houses occupational safety
and health management programs.
Safety internship programs are very common in the general industry but are gaining popularity in
the construction industry. The internship program will expose college students through a 3-month
summer employment, to all aspects of the construction industry and provide valuable job experience
to complement their academic curriculum. As an intern, they will be typically paired with a Project
Safety Manager and be involved in the overall implementation and enforcement of the site safety
program. It gives the companies an opportunity to test a potential full-time employee and also train
the future safety professionals. See example internship description and responsibilities in Exhibit 6-3
that can be used by companies looking to start an internship program. Organizations can visit www.
asse.org/academicdirectory for the OSH College and University Directory to find out the colleges and
universities near them that offer a safety degree.
6 National Assessment of the Occupational Safety and Health ... (n.d.). Retrieved from http://www.cdc.gov/niosh/oshworkforce/_br
62
6.7 ADDITIONAL RESOURCES, READINGS, AND REFERENCES
Hiring Guide: The American Society of Safety Engineers (ASSE) recently published “The
ASSE Guide to Hiring the Right Occupational Safety & Health Professional” available at
http://www.asse.org/assets/1/7/Hiring_right_OSH_Professional.pdf. It provides guidelines to
employers and companies looking to build their safety team. The guide provides essential hiring
tips for various safety positions at different levels of expertise. This breakdown helps users
focus on important aspects of a potential candidate’s skill sets and goals.
63
Exhibit 6-1: Example Project Safety Staffing Policy
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
Policy Statement
Full time, project safety staff is required on all projects with a contract value in excess of $25 million
dollars. It is recommended that the safety staff be assigned prior to the beginning of work, as with
other site staff. Additional safety staff may be required when project size is greater than 75 million
dollars or risk management plan dictates a need.
Roles and Responsibilities
This safety staff person should perform the following functions prior to and during the life of
the project:
Assist the Business Unit Safety Director (BUSD) in creating the site-specific safety program
Setup and implement substance abuse testing
Create and implement a project safety orientation
Create and implement a project incentive program
Attend pre-bid meetings to inform subcontractors of specific project safety requirements
Establish safety pre-planning meetings with all subcontractors and assist the Project Staff in
placing meeting times in the project schedule
Meet with and coordinate response from local EMS officials
Conduct project safety audits using the Predictive Solutions SafetyNet Reporting System
Conduct toolbox safety meetings for Turner employees
Establish and maintain site record keeping files
Establish and encourage Project Staff safety auditing requirements
Ensure that all precautions / requirements found in the environmental site assessment are
complied with
Other safety requirements as deemed necessary by the BUSD and / or Project Staff
64
Exhibit 6-2: Example Project Site Safety Manager Job Description
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
Position Description: The Project Safety and Loss Control Coordinator shall report to the Business Unit
Safety and Loss Control Manager. He/she will provide support to the General Manager, Operations
Manager, and the Business Unit Staff in an effort to enforce corporate safety and health policies and
procedures. In addition to their Business Unit responsibilities, they shall participate in and complete
all tasks designated to them by the Business Unit Safety and Loss Control Manager.
Essential Duties and Responsibilities:
Assist in the development of the project safety program.
Establish and conduct jobsite orientation for every new employee for the project and administer
and record their participation in the orientation program and issue identification to those
employees completing the orientation program.
Attend all initial meetings with the Project Staff and Subcontractor representatives to clearly
define their role within the confines of the Project Safety Program.
Conduct and document pre-planning safety meetings with each subcontractor safety
representatives and/or foremen to establish safety procedures prior to subcontractor’s activity
on the site.
Establish and conduct regular (weekly) safety meetings with subcontractor representatives
and issue minutes of meeting and interface with Project Staff and each Subcontractor Safety
Representatives relating to safety regulations to ensure proper compliance.
Ensure that Subcontractors are conducting the proper training requirements as per the DOSH,
standards. If necessary, facilitate training for site personnel for compliance with Federal and
State standards.
Ensure and maintain a log of each subcontractor’s toolbox safety meetings held with their
employees.
Review each Subcontractors Safety Program and ensure that it meets or exceeds the Project
Safety Program requirements.
Ensure that each Subcontractor designates a Safety Representative that is properly trained in
the DOSH, standards and that person is considered by DOSH, standards, competent for the
Subcontractors scope of work and has the proper authority to correct safety issues and hazards
relating to their safety compliance. Receive the names of their competent person(s) for their
specific work in writing and file
Conduct regular (daily) jobsite and work area inspections. Conduct formal weekly jobsite
inspections and complete the safety checklist noting safety violations and corrective actions.
Record, notify and prepare written report of any violations or unsafe practices to Subcontractors
for immediate correction actions.
Stop at once any violation or unsafe practice.
Assist Project Superintendent in establishing and implementing proper fire prevention,
evacuation and fire control procedures.
65
Investigate all incidents and generate proper reports.
Establish and maintain all required job safety records.
Conduct a monthly overview safety meeting.
Assist the Claims Coordinator in the management of claims.
Attend Project Staff Meetings to brief the staff on safety issues on the project and coming from
the company and to keep informed of the progress of the job.
Qualifications: A four year degree in Safety and Health or equivalent is preferred with at least two
(2) years of safety experience or combination of education/multiple years’ experience in building
construction, with a working knowledge of safety/environmental principles and techniques. Capable
of identifying known/potential exposures and recommending corrective actions. Computer skills and
familiarity with Microsoft Office suite programs. Strong management, leadership and interpersonal
skills with the ability to communicate well both verbally and in writing.
Physical Demands and Work Environment: Performance of the required duties will require physical
ability to climb permanent and temporary stairs, passenger use of construction personnel hoists,
ability to climb ladders and negotiate work areas under construction. Specific vision abilities required
by this job include close vision, peripheral vision, depth perception, and the ability to adjust focus.
Performing this job requires the use of hands to finger, handle, or feel objects, tools or controls, sit,
talk and hear, stand, climb, balance, stoop, kneel, crouch or crawl. The employee must occasionally
lift and/or move up to 75 pounds. While performing the duties of this job, the employee will work
on-site at the construction work site where the employee is exposed to moving mechanical parts; high
precarious places; fumes or airborne particles; outside weather conditions and risk of electrical shock.
The noise in these work environments is usually moderate to very loud. TURNER IS AN EQUAL
OPPORTUNITY EMPLOYER.
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
66
Exhibit 6-3: Example Construction Safety Intern Job Description
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
Position Description: The purpose of the internship is to provide the student with supervised practice
at the work site and in the continuing daily work of the safety professional. Interns will assist the
Project Safety Manager, Superintendent, PM, PX, and BUSD in adhering to company safety and loss
control policies. Works on construction projects or in the office to assist in the day-to-day activities
associated with safety and loss control. The safety intern shall be supervised by a manager of safety.
Essential Duties and Responsibilities:
Assists Project Safety Manager, BUSD, PX, PM, and Superintendent in administering and
adhering to company safety, health, and environmental policies such as:
Assist in implementation of the project safety program under the direction of the Project
Safety Manager or Superintendent
Stopping at once and reporting immediately to the Project Superintendent and Business
Unit Director of Safety any violation or unsafe practice where there is an imminent danger
to life or property.
Safety coordination duties in such areas as safety committees, preplanning meetings, and
tool box meetings.
Participate in training at safety meetings, tool box meetings, and orientations.
Assist in a review of subcontractor safety programs for completeness and compliance with
Turner’s policies.
Assist in promoting safe work practices and safe working conditions in accordance with all
State, Federal, Local regulations, and owner/contractual requirements.
Participate in administration of a drug screening program (pre-employment, post-accident
random and cause) that is consistent with Turner’s or Owner’s requirements.
Assist Project Safety Manager and Superintendent in preconstruction meetings and
conducting research as needed. Document those meetings under the direction of supervision.
Assist in conducting jobsite and work area inspections with the Project Safety Manager
or Superintendent. Review with the superintendent for distribution to subcontractors and
Business Unit Safety Director.
Assist in maintaining safety records, including training records, tool box meetings,
maintenance of the OSHA 300 log, maintenance of the MSDS and chemical inventory
sheets, incident investigations, and metrics. Assist in conducting an effective worker orientation program for every new employee and
administer and record their participation.
Gather pre-task planning and JHA programs for all project contractors based on contractual
requirements and log accordingly.
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Qualifications: Working toward a four-year degree in Safety and Health or equivalent is preferred
with at least two (2) years of education, and a basic knowledge of safety/environmental principles and
techniques. Capable of identifying known potential exposures and recommending corrective actions. Computer skills and familiarity with Microsoft Office suite programs. Strong management, leadership
and interpersonal skills with the ability to communicate well both verbally and in writing.
Physical Demands and Work Environment: Performance of the required duties will require physical
ability to climb permanent and temporary stairs, passenger use of construction personnel hoists, ability
to climb ladders and negotiate work areas under construction. Specific vision abilities required by this
job include close vision, peripheral vision, depth perception, and the ability to adjust focus. Performing
this job requires use of hands to finger, handle, or feel objects, tools or controls, sit, talk and hear,
stand, climb, balance, stoop, kneel, crouch, or crawl. Intern must occasionally lift and/or move up to
75 pounds. While performing the duties of this job, the intern can work in an office or on-site at the
construction work site where the intern is exposed to moving mechanical parts; high precarious places;
fumes or airborne particles; outside weather conditions and risk of electrical shock. The noise in these
work environments is usually moderate to very loud.
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
68
7
DESIGNING FOR CONSTRUCTION WORKER SAFETY
7.1 PURPOSE
According to the hazard control hierarchy, the best strategy for achieving an injury and illness free
construction work environment is by designing out hazards during the early stages of the project
design. Construction site hazards can be designed out by implementing an innovative process called
Prevention through Design (PtD), also known as designing for construction safety (DfCS). DfCS is
the consideration of construction site safety in the design of a construction project. DfCS includes
modifications to the permanent features of the construction project and to the preparation of plans
and specifications for construction in such a way that construction site safety is considered.1 DfCS
presents multiple challenges for it to be successfully implemented in practice. The DfCS process requires
collaboration and frequent interaction between the owner, designer, and the contractors. Hence, DfCS
can be “effectively” implemented on projects delivered through design-build contracts and when there
is an opportunity for upstream contractor involvement. This chapter offers guidance to project teams
interested in the planning, development, and implementation of a DfCS process. The guidelines should
be used as a roadmap that contractors can use as a reference by using all or parts of it to fit their needs.
7.2 DFCS PROGRAM – IMPLEMENTATION GUIDELINES
7.2.1 Gain support from the project owner
The greater the support that DfCS has from the owner, the greater its chance of success when
implemented on a project. However, the DfCS process is new and requires additional funds to
implement it. Currently, there is no scientific evidence showing its positive return on investment. Then
why should the owner spend the money on DfCS? A good DfCS process will not only eliminate or
minimize risks associated with construction but also the final facility. The buy-in from the owner can
also be obtained by communicating to the owner the benefits of DfCS due to the reduced safety risks
throughout the project lifecycle. Benefits can include lower claims, reduced workers compensation
premiums, reduced costs,2 fewer delays, enhanced designer-constructor collaboration, better employee
morale, and increased productivity.
1 Hinze, J. and Gambatese, J. (1996).
Research Report 101-11.
“Addressing Construction Worker Safety in the Project Design.” Construction Industry Institute, Austin, Texas,
2 Occupational Safety and Health Administration (OSHA). Injury and Illness Prevention Programs – White Paper.
www.osha.gov/dsg/InjuryIllnessPreventionProgramsWhitePaper.html (Accessed December 15, 2014)
69
7.2.2 Develop a formal DfCS process
Similar to other elements that are part of the project safety program, a formal written DfCS program
supported by the project owner will yield greater benefits. The DfCS should be distinguishable from
other construction management activities and should be an essential ingredient of the project safety
program. Also, the process should commence in project planning and design, and include input from
those knowledgeable about construction activities and safety hazards. The program can be simple: lists
of regular and predictable hazards that should be reviewed with designers and building owners.
7.2.3 Identify the goals of the DfCS process
The owner should define and communicate the DfCS process goals with the project stakeholders
during the request for proposal (RFP) process with both designers and contractors. For example, one
goal could be to “eliminate construction, maintenance, and operations related accidents and incidents
attributable to the design of the project.” The goals should be specific and measurable.
7.2.4 Select Designers in part based on experience, knowledge, and willingness to incorporate worker
safety and health in the project design
One of the biggest barriers to the DfCS process is the reluctance of designers to change designs to
accommodate worker safety. Their hesitance can be attributed to liability concerns, lack of experience,
or even the perception that construction worker safety is the constructor’s responsibility. A committed
owner should include DfCS requirements in the owner’s request for proposal (RFP) for design services.3
Designer selection should include: checking past records on designer experience, knowledge of safety
and health in design concepts, and personal interviews/knowledge.
7.2.5 Include DfCS requirements in the contract with the designer and the Construction Manager /General
Contractor (CM/GC)
Depending on the complexity of the design, it may be difficult to predict the amount of time required
to perform a comprehensive DfCS review. Hence, owners may consider signing a Cost-Plus with a
guaranteed maximum price (GMP) contract rather than a traditional fixed fee contract, 4 with both
the designer and the CM/GC (and tiers). This will allow for more effective participation in the DfCS
process from the designers and contractors.
7.2.6 Designate a DfCS coordinator to oversee the DfCS process
Once both the A/E and the CM/GC team are onboard and under contract, establish a team to oversee
the DfCS process. Prior to the start of design efforts, the owner should designate a DfCS coordinator,
who will oversee the DfCS process. It is typical that the project designer will be the DfCS coordinator
who is responsible for the DfCS process for interface with other project players.
3 Design for Safety. PtD Program Guidelines. http://www.designforconstructionsafety.org/Documents/PtD%20Guidelines.docx
(Accessed December 15, 2014)
4 Design for Safety. PtD Program Guidelines. http://www.designforconstructionsafety.org/Documents/PtD%20Guidelines.docx
(Accessed December 15, 2014)
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7.2.7 Define Roles and Responsibilities of project stakeholders
In order for the DfCS process to be effective, the roles and responsibilities of all project players should
be clearly defined and executed at the start of the design process. A few examples of responsibilities of
the key players are:
Designer (A/E) – Provide technical expertise (codes) with design alternates that focus on
risk elimination.
Owner Representatives – Provide design input that will eliminate or minimize safety risks
associated with construction, operation, accessibility, and maintenance issues.
Construction Manager/General Contractor (CM/GC) – Provide design input to improve
the constructability of the design, and any design suggestions that will eliminate or
minimize safety risks during construction.
Subcontractors – Provide design input to improve the constructability of the design, and
any design suggestions that will eliminate or minimize safety risks during construction
that impact their scope of work.
7.2.8 Develop a DfCS Review process
A systematic DfCS process should be developed and administrated. Here are some questions that will
help the project team to develop an effective DfCS review process.
When will the project team perform the DfCS review? The owner should establish a DfCS process
timeline defined in terms of the stages of design. Typically on commercial and industrial
construction projects in the United States, design reviews by the owner occur during four stages:
Concept, 30 percent, 60 percent, and 90 percent.5 These design review stages can be used as
milestones to provide DfCS comments. Deliverables from each review should be clearly defined.
How are the risks and associated controls (design suggestions) obtained from the DfCS reviews
tracked for closure?
How will the owner decide on which design change to implement? Does the owner require
a formal risk impact assessment to prioritize all risks identified during the DfCS process to
establish a most to least critical importance ranking?
Should the ranking and prioritization include the costs associated with the risk control options
(elimination versus minimization)? For example, elimination of a confined space versus
minimization of the associated risk by providing pre-installed rescue and ventilation system.
What is the timeline for the owner to make a decision on suggested design changes?
How will the lessons learned from this project be transferred to future owner projects? Who will
create and maintain the lessons learned database?
7.2.9 Develop and deliver DfCS process training to all DfCS participants
The training should enhance DfCS participant knowledge of the DfCS concept, construction safety
requirements, and the construction processes. The training should ensure the team understands the
significance of DfCS in creating an injury-free work environment, the goals of DfCS, DfCS team’s
roles and responsibilities, DfCS process, and deliverables.
5 American Society of Safety Engineers (ASSE). Construction Safety Management and Engineering. Second Edition. Editor: Darryl Hill, CSP.
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7.2.10 Provide DfCS tools and resources for designers, contractors, and owner representatives to identify
safety hazards
Create a DfCS review log to be used by the review team to document inputs from the design review
process. Create a DfCS review checklist that includes common items to look at during the DfCS review
from experience (see sample checklist in Exhibit 7-1). The checklist should not be intended to be
prescriptive, but rather a memory aid to ensure that all the participants consider the key safety areas
during the design process. It is not an exhaustive list that covers all potential safety items that will need
consideration during the project. The checklist should include key areas for scrutiny by the reviewers
including:
Accessibility
Confined space
Ergonomics
Fall Protection/Prevention
Maintenance
Operation
Physical hazards
Emergency Planning and Preparedness
The readers are recommended to use this checklist and other tools provided in the resources section as
a starting point and add to the list as new items are discovered during the DfCS review process. Also,
provide technological resources, such as Building Information Modeling (BIM), to aid in the design
review process. BIM provides a visual representation of building features for the reviewers and makes
the review process easier. However, the cost associated with BIM (both software and hardware) should
be considered before using BIM. Figures 7-1 through 7-4 shows the use of BIM during design review
and eliminating clash. See Chapter 8 for more information about using BIM for DfCS.
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Figure 7-1: Embedded fall protection anchor traps clash with HVAC systems detected using BIM
(Picture Courtesy Balfour Beatty Construction)
Figure 7-2: Embedded fall protection anchor traps clash elimination with HVAC systems using BIM
(Picture Courtesy Balfour Beatty Construction)
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Figure 7-3: Perimeter cable guardrail clash with exterior wall skin detected using BIM (Picture
Courtesy Balfour Beatty Construction)
Figure 7-4: Perimeter cable guardrail clash with exterior wall skin removed using BIM (Picture
Courtesy Balfour Beatty Construction)
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Additional DfCS Resources, Readings, and References
ƒƒ Construction Industry Institute (CII) – www.construction-institute.org
ƒƒ RR101-11 – Addressing Construction Worker Safety in the Project Design by Dr. Jimmie
Hinze and Dr. John Gambatese provides a list of 400 design suggestions that reflect all
types of design disciplines, job site hazards, and construction components and systems.
ƒƒ Design for Construction Safety - www.designforconstructionsafety.org
ƒƒ This website is number one resource for DfCS resources. It has numerous helpful DfCS
tools including checklist, training programs, and guidelines.
ƒƒ National Institute of Occupational Safety and Health’s (NIOSH) Prevention Through Design
Webpage – www.cdc.gov/niosh/topics/ptd
ƒƒ American National Standards Institute (ANSI)/American Society of Safety Engineers (ASSE)
Z590.3-2011, Prevention Through Design (PtD): Guidelines for Addressing Occupational Risks
in Design and Redesign
ƒƒ Design Best Practices - http://www.dbp.org.uk/welcome.htm
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Exhibit 7-1: Example Design for Construction Worker Safety (DfCS) Checklist
Note: This best practice tool is only included as an example, and the users should be aware that the
checklist may reference safety regulations depending on the company’s regulatory jurisdictions. It
is the user’s responsibility to ensure that they adapt the best practices provided in this checklist for
their jurisdiction and comply with all applicable local, state, and federal regulations affecting their
workplace.
Accessibility
Accessibility
Accessibility
Accessibility
Accessibility
Accessibility
Accessibility
Accessibility
Accessibility
Accessibility
Confined Space
Confined Space
Confined Space
Confined Space
Emergency
Emergency
Emergency
Emergency
Will there be adequate headroom for accessing racks, filters, viewports, sight
glasses?
Will there be adequate access to elevated areas when construction is complete?
Will routing zones discipline be enforced?
Will there be adequate access to depressed areas such below raised floors (RMF),
chemical trenches area when construction is complete?
Will there be adequate access to the tops of tanks and equipment when construction is complete?
Will there be adequate access to cable trays when construction is complete?
Will there be adequate access to valves when construction is complete?
Will there be adequate access to dampers when construction is complete?
Will there be adequate access to electrical controls, switches and relays when construction is complete?
Where access is needed for elevated areas utilize the fall protection hierarchy of
controls i.e. in order; eliminate elevated work, provide a platform and guardrail,
provide tie-off points last, etc.
Are tanks designed to minimize the need for access during construction or maintenance?
Have at least two tank access ports been provided to aid in egress/ventilation?
Will anchorage points for retrieval be located next to each confined space access
point when construction is complete?
Have the gasses being used in the Confined Space been considered as a Suffocation Hazard? If yes, note in further action how this is to be mitigated.
Are emergency relief devices (breather vents, relief valves, rupture disks, liquid
seals) vented outside the building or to a safe discharge location?
What is the most severe credible incident i.e. the worst conceivable combination
of reasonable malfunctions, which can occur? Does design address mitigation of
this type of incident?
What needs are there for emergency relief devices (breather vents, relief valves,
rupture disks, liquid seals)? Are they documented in the design?
Have you indicated the location of known shut-off valves and switches for existing utilities? Are contact names and phone numbers for local utilities indicated
on the drawings? Are these devices readily accessible?
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Emergency
Emergency
Emergency
Emergency
Emergency
Emergency
Emergency
Ergonomics
Ergonomics
Ergonomics
Ergonomics
Fall
Fall
Fall
Fall
Fall
Fall
Fall
Fall
Fall
Fall
Do drawings show pipe flow direction so the first valve upstream or downstream
of an emergency can be located?
Does design address provisions for rapid disposal of reactants if required by plant
emergency?
Does the design indicate necessary fire emergency equipment and allow for adequate execution of fire emergency procedures?
Does the design provide provisions for operation or safe shutdown during power
failures?
Does the design address proper containment and disposal of gas and liquid paths
if leakage occurs and primary containment fails?
Have adequate Emergency Off (EMO’s) been provided and are they in the correct
location?
Have adequate EW/SSH’s been provided and are they in the correct location?
Does the design eliminate the need for heavy manual material handling?
Did the design consider the height (from working surface) of all valves and controls that require viewing or operation?
Is the elevation of valves and sight glasses at an ergonomic level (between 36” and
44” above walking surface)?
Will there be adequate lighting for maintenance activities provided after construction is completed?
Are the hierarchy of controls considered for fall protection i.e. in order; eliminate
elevated work, provide a platform and guardrail, provide tie-off points last, etc.
Will rooftop equipment have a 42” parapet at every elevation change?
Has the worker tied off points been included in the design?
Stairs vs. ladders: consider access frequency and what a person will be carrying.
Does the design provide safe stair and ladder design for intended purpose?
Do the systems select minimize significant labor in an elevated position (e.g., masonry walls vs. tilt-up concrete)
Does the design allow for maximizing work on the ground?
Building offsets of varying size and shape create a falling hazard for construction
workers. Does the design minimize offsets where possible, and are necessary offsets safely constructible?
Do exterior stairs and ramps run parallel to and immediately adjacent to the
structure?
Consider how openings through floors will be protected during construction.
Does design group openings together where possible? Does the design locate
openings away from the edge of the structure where possible?
Is rooftop equipment located away from the edge of the structure?
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Fall
Fall
Fall
Layout
Layout
Layout
Layout
Layout
Layout
Layout
Layout
Maintenance
Maintenance
Maintenance
Maintenance
Maintenance
Maintenance
Maintenance
Operation
Operation
Operation
Operation
Operation
Operation
When designing openings remember 42” requirement. A window located 42”
above the floor provides a built-in guard rail. A parapet 42” tall does the same. Is
this accommodated in the design?
Are adequate craft anchor points for fall protection during construction provided
in the design?
Are adequate sustaining personnel tie offs for maintenance activities provided in
the design?
Is there adequate space to permit the installation and maintenance of equipment?
Are there access and egress clearances for normal traffic and maintenance?
Are there access and egress clearances for firefighting?
Can people and equipment be moved through the building safely during construction and sustaining operations?
When doing underground work, consider the potential for existing utilities and
impact that will have on the construction technique. Has the design addressed
this?
Have you considered construction safety when laying out the project? An obvious
example is the location of power lines. What about high-pressure piping lines and
combustible gasses? A vehicle vs. Pedestrian traffic flow?
Are spacing and clearances furnished for normal traffic maintenance and firefighting?
When placing underground lines, consider the work that follows behind and potential future work in the area. Has the design addressed this?
Can you access instruments for calibration?
Can valves be accessed readily for the operation?
Are pumps and controllers readily accessible for maintenance?
Will the area have adequate lighting to support maintenance operations?
Are special devices required to maintain this equipment?
Does the design package include allowances or clearances for maintenance?
Is signage required for maintenance clearances?
Are systems routed between buildings analyzed for differential movement in an
earthquake?
Does one set of switches control the lighting and ventilation in a mechanical
room, solvent room or confined space?
If instruments fail simultaneously, is a collective operation still fail-safe? Conduct
“what if ” analysis.
Are piping systems analyzed for stresses and movements due to thermal expansion?
Design ventilating and light fixtures in a mechanical room, or confined space to
be operated by the same switch.
Is there a safe way to load liquids into and to withdraw them from tanks?
78
Operation
Operation
Operation
Physical Hazards
Physical Hazards
Physical Hazards
Sequence
Sequence
Sequence
Sequence
Sequence
Other
Other
Other
Other
Other
Other
Other
Does the design locate electric panels within sight of the equipment that they
affect?
Does design designate protective insulation for “hot surfaces”?
Does the design provide non-conductive flooring at electrical boxes?
Have trip hazards been mitigated?
Have head knockers been mitigated?
Does design address Noise?
Does the design consider how design may affect work staging and safety?
Have you considered how design releases can impact construction scheduling and
safety? For example - if sidewalks are issued early, they can be constructed and
provide a more stable base for perimeter wall scaffolding.
Can existing systems (corridors, stairs, handrails) be staged for early construction
completion?
Has the design considered how design can affect construction sequencing to allow
energizing electrical panels at the latest possible time without impacting construction schedule?
Are fire prevention devices (firewater systems, etc.) designed early so they can be
installed for construction safety?
Has the design accommodated for the effects of extremes of atmospheric humidity and temperature? Corrosion?
Have flammable or combustible materials of construction been eliminated or minimized?
Has the use of primers, sealers, coatings, etc. containing hazardous materials been
eliminated or minimized?
Are materials of construction compatible with the process chemicals involved?
Does the design consider specification limits on “lift” heights? For example, tall
structures can easily collapse during erection if not adequately supported.
Does the design specify testing procedures for complicated designs?
What items need to be added? Please Explain on Back
79
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8
USE OF MODERN TECHNOLOGY IN CONSTRUCTION
SAFETY MANAGEMENT
8.1 PURPOSE
Modern technology is absolutely changing the way construction safety is managed on construction
sites. Currently, several construction companies are using modern technology such as 3-dimension
(3-D) modeling, computer software, and mobile technologies including smartphone and IPad Applications (Apps), to affect worker safety positively. This chapter will provide information to construction
firms to identify “technologies” and “safety management apps” that can be used to improve construction worker safety.
Note: The authors has no financial interest in the products listed in this section. The inclusion is based
on the author’s experience and their research on industry best practices.
8.2 BUILDING INFORMATION MODELING (BIM)1
The term “BIM” is used to refer to two different things: the process of building information modeling and the resultant model (the building information model). BIM is the development and use of
a computer software model to simulate the construction and operation of the facility. The resulting
model, a Building Information Model, is a data-rich, object-oriented, intelligent and parametric digital representation of the facility, from which views and data appropriate to various users’ needs can be
extracted and analyzed to generate information that can be used to make decisions and improve the
process of delivering the facility.2 Simply put, imagine walking into a building, walking through the
lobby, removing the ceiling tiles and looking at the utilities in the ceiling space—before the building is
even built. BIM can help construction professionals do that.
Currently, several construction companies are using BIM as part of their project development process.
Only recently, the construction industry has started to look at BIM as a tool to improve worker safety.
Given the newness of BIM to the industry, each project or company should designate a construction
safety professional (or project engineer) as a champion to help to facilitate the use of BIM for safety.
As BIM becomes more commonplace, construction safety professionals should continuously examine
how it can improve worker safety on each project. Safety professionals need not be experts in the model creation or its technical aspects; they simply need a basic understanding of BIM, which is essentially
a 3-D computer-aided design drawing. What are the benefits and uses of BIM with respect to the construction worker safety? Consider these areas in which BIM can positively affect the safety.
1 Rajendran, S. and Clarke, B. (2011). “Building Information Modeling - Construction Safety Benefits and Opportunities.” Professional Safety,
Journal of the American Society of Safety Engineers (ASSE), 56(10), 44-51.
2 The associated General Contractors of America (AGC) 2010. The Contractors Guide to BIM. Retrieved Oct 19, 2010, from
http://www.agcnebuilders.com/documents/BIMGuide.pdf
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8.2.1 Capture Pre-existing Site Conditions
Typically, a preliminary pre-construction property third-party survey is highly recommended to document existing conditions of adjacent structures and surrounding areas prior to commencement of construction. The survey is performed mostly to protect against third party liability exposures. Three-dimensional laser scanning can be used to capture the baseline existing model. BIM with information
obtained using 3D laser scanning can capture pre-existing conditions accurately that can be built into
the model.
8.2.2 Constructability Reviews
BIM can be used to conduct constructability reviews due to its ability to visualize what is being constructed in a simulated environment. It helps identify potential errors and omissions and reduces
change orders, which improves the quality and can prevent rework. Less rework means better safety
performance and higher efficiency.
8.2.3 BIM Enabled Prefabrication
A fully coordinated BIM model can isolate, analyze, and construct any area of the building with a
higher reliability. Hence, BIM enables more items to be prefabricated off-site (e.g., pipe assembly),
transported to the site, and installed rapidly. Prefabrication minimizes field work and on-site labor and
construction, which reduces worker exposure to unsafe conditions (e.g., working at heights, working in
inclement weather, etc.). Less exposure means better safety performance. For example, in one project
several heating/cooling pipes were assembled off-site in a controlled environment, trucked to the site,
and installed quickly and safely. It helped alleviate issues with access, fall protection, and ergonomic
concerns.
8.2.4 Designing for Construction Worker Safety (DfCS)
DfCS requires one to consider construction site safety during project design. BIM provides an excellent visualization of the project design; hence construction safety professionals can use BIM to identify where DfCS suggestions can be incorporated. For example, in one project, fall protection anchor
points were determined using BIM. BIM review revealed many areas where workers would be exposed
to fall hazards, but no anchor points were present. The project team identified several hundred locations where concrete embedded straps could be installed for anchors. BIM helped identify potential
conflicts with overhead or under-slab utilities. Chapter 7 of this handbook has a checklist that identifies, by discipline, some safety specifics that can be considered using a BIM.
8.2.5 Construction Site Logistics and Emergency Planning
BIM enables contractors to study existing and future site conditions and hazards before breaking
ground, such as traffic considerations, site access, utility concerns, crane radius, and lay down areas.
For example, BIM can be used to simulate crane operations in relation to the overhead power lines.
It can enable communication with neighbors and subcontractors (see Figure 8-1). For example, in
one project BIM was used to map on-site equipment flow. The project required extensive use of dump
trucks to transport materials from the excavation pits. A gravel ramp was the best solution for the
trucks to enter and exit the excavation area. Locating the ramp correctly, in relation to other construction activities, is critical to proper truck access and avoids congestion and trade stacking. BIM helped
simulate the ramp to confirm that no conflicts existed with other construction activities.
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Figure 8-1: BIM-enabled Site Logistics and Emergency Planning (Photo courtesy of BNBuilders)
8.2.6 Safety Training and New Employee Orientation
Craftspeople new to the jobsite are at a higher risk of injuries until they understand the site’s working environment. BIM can help them more fully and quickly understand the environment. Figure 8-2
shows the site layout derived from BIM identifying emergency access, safety bulletin board, site office,
fire extinguishers location, etc.
Figure 8-2: Site Safety Plan Integrated with BIM (Photo courtesy of BNBuilders)
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8.2.7 Site Specific Safety Plan (SSSP)
The SSSP can be integrated into the BIM model to identify and control a project’s potential hazards.
For example, risks posed by site utilities and their proximity to the overhead power line can be analyzed and controlled adequately prior to commencement of work. BIM would be perfect to develop
emergency access and evacuation route plans.
8.2.8 Job Hazard Analysis (JHA) & Pre-task Planning (PTP)
Pre-task planning offers the most opportunities to use BIM for construction safety. By virtually looking at the elements to be built, employees can better identify the hazards and control measures so the
task could be completed faster and more safely (see Figure 8-3). BIM can be used to evaluate construction sequencing of high-hazard tasks such as steel erection, construction hoists installation, and tower
crane erection. The evaluation can eliminate a variety of conflicts with other work in that area before
activities commence.
Figure 8-3: Pre-task Planning & BIM: Model vs. Actual As-Built (Photo courtesy of BNBuilders)
8.2.9 Utility Access
BIM allows better understanding of service access to above ceiling devices such as terminal units, fan
coils, and electrical junction boxes. If these areas have limited access, they can pose a safety issue to
start up, service and maintain.
8.2.10 Accident Investigation
BIM can be used during an accident or incident investigation to recreate event sequence and the incident scene. In one case, a worker was injured when he fell off a leading edge. The project had not used
BIM, but during the incident investigation, laser scanning was used to identify existing conditions at
the scene, such as location of pipes and HVAC ducts; location of stored equipment; materials storage;
and worker position. With these data, an existing condition BIM was created, which captured the incident scene. This model eliminated hundreds of pictures and answered numerous questions related to
the scene. It seems logical that BIM can be used during legal proceedings to save resources.
BIM has the potential to improve construction project safety performance. Safety professionals in
the construction industry should view building information modeling (BIM) as a tool to improve
worker safety and health. BIM can be used in worker safety training and education, design for safety, safety planning (job hazard analysis and pre-task planning), accident investigation, and facility
and maintenance phase safety. SH&E professionals should encourage other construction disciplines
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to review safety issues while performing design or constructability reviews. BIM is a tool that can
facilitate this process.
8.3 MOBILE APPLICATION SOFTWARE (APPS)
Most of the construction site’s dedicated safety professionals and designated safety representatives
(foreman, general foreman, and superintendents) typically spend more than eighty percent of their
time in the field. Most of these professionals carry at least one or sometimes two portable electronic
devices with them – a smartphone and a tablet computer with Mobile-based operating systems (OS).
Most of these devices have a touch screen interface with pop-up keyboards, are equipped with a camera, microphone, audio recording features, and Wi-Fi capability. There are several operating systems
for tablets with the most common ones include Apple iOS, Google’s Android, and Microsoft Windows
8. These portable electronic devices have helped the safety professionals increase their work efficiency
while in the field by serving as a:
Communication tool – send and receive emails and texts
Reference tool – quick reference to DOSH standards, emergency site plan, emergency contacts,
SSSP, JHAs, PTPs, and other safety-related resources
Hazard Identification and Evaluation tool – perform inspections, audits, record site conditions
using pictures and videos, and perform job site exposure assessment
The use of mobile application software (Apps), computer programs that run on these portable devices
have increased several folds over the last five years. These Apps are produced by various entities and
are available for free or sale from commercial outlets such as Apple’s App Store, Amazon’s Appstore,
Blackberry World, Windows Phone Store, and Google Play. Some common Apps readers must be familiar with including Facebook, YouTube, and Google Play. Mobile Apps can provide several benefits
with respect to the construction worker safety. There are hundreds of safety-related Apps available in
these App stores. Selected Apps that may be used by field safety professionals to help with construction
site safety are discussed in this section.
8.3.1 Safety Support Functions Apps
These Apps are not technical in nature, but it will be very helpful to the construction field professionals
to make their job more efficient. Please note some apps are available for iPhone, iPad, Blackberry, and
Android; some apps might be limited to only one of these devices. Some apps are free while some apps
can be purchased for a fee. Readers are encouraged to visit these app websites by clicking on the link
provided to understand these limitations.
Camera Apps – The Apps listed below will be useful to take job site progress pictures, picture
evidence for accident investigations, safety inspections, audits, and documentation of pre-existing site conditions.
οο DMD Panorama by Dermandar & 360 Panorama by Occipital – Both these Apps allows
a user to take panoramic photos (360°)
οο Night Camera by Sudobility – Construction work takes place even during odd hours
ranging from an early morning concrete pour to late night painting. Standard cameras
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on these devices might not prevent the night time blur. The Night Camera App will create clearer photos at night and under low light conditions.
οο MagicPlan by Sensopia – By taking a picture, this App will help measure rooms and
draw floor plans, which can be useful to measure room dimensions to calculate ventilation requirements, identify correct ladder size, etc.
Records Management Apps
οο CamCard by IntSig – Depending on the project size and complexity, a construction
safety professional will meet numerous personnel on the site, and exchange business
cards. This App scans and reads business cards, and uploads the contact information
into your phone contacts. Less time is spent on typing contact information and more
time on field supervision.
οο CamScanner by IntSig – Have you ever wanted to share safety resources on a paper document with others quickly? This App allows you to scan and share a document. Safety
professionals can scan a document and readily share with subcontractors. It also provides edit and annotation features, which makes this a very handy App.
οο Microsoft Office for iOS by Microsoft Corporation – This Apps allows viewing, editing,
and content creation that includes MS Word, Excel, and PowerPoint.
οο Adobe Ideas by Adobe – This app provides a way for users to write on pictures, which
can be useful during accident investigation when marking evidence locations. This can
also be used to share safety information regarding audit findings and safety spot checks.
And can be used to create photo-based Toolbox Safety Talks.
οο UIG Safe Work Apps – This APP has a completely paperless safety meeting minutes
manager, has built in topics and built in systems for auto-generation/ email of meeting
minutes to attendees, company designees, and outside sources.
Communication Apps – These Apps assists with safety communication to non-English speaking
workers.
οο Translate by Google – This App allows you to translate words, sentences, even an entire
document.
οο Vocre Translate – Want to talk to non-English speaking worker regarding safety? This
translation App is used to make multi-language conversations possible in real time. This
App uses the same technology that powers Siri, the Apple’s voice assistant.
8.3.2 Technical Safety Reference Apps
These Apps provide valuable technical safety reference for site supervision on the go.
EHS Pocket Guide by Dakota Software Corporation – This App contains OSHA, EPA, and
DOT regulations, which allows the user to search and view applicable documents.
NIOSH Pocket Guide by Dangerous Decisions LLC – This App provides immediate access to
the most current safety guidelines regarding hazardous chemicals.
ERG Pro by Creative Custom Applications - A useful tool for hazardous material responders.
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MSDS Mobile by KHA, Online-MSDS – This App allows users to search Safety Data Sheets
(SDS) using the keyword, view them, and even send them as an attachment via email.
iOSHA 3151 Personal Protective Equipment (PPE) by 4CYTE, LLC – This App contains
OSHA PPE requirements.
National Fire Protection Association (NFPA) Apps – NFPA publications including Codes and
standards are available via these Apps.
Crane Operator Hand Signals by Special Carriers and Rigging Association – A simple app that
provides information on crane operator hand signals.
Sling Calculator by Crosby – This app allows the user to compute load weight, sling tensions,
and load’s center of gravity. There is both a free version (limited calculators) and purchase with
more options.
Pocket First Aid & CPR from the American Heart Association – Provide simple first aid and
CPR instructions.
Electrical Pro by Multieducator Inc – Assists users with many calculations and information
regarding electrical safety.
OSHA Safety by William Howard - This OSHA Safety App includes the full text of the OSHA
regulations for General Industry and Business. These OSHA 1910 Regulations cover most
workplaces, including manufacturing, service industries, warehouses and distribution centers,
and the medical / dental fields.
Recalls by Urban Apps – Recalls™ is an application that keeps you updated on all the most recent product recalls. See product images, descriptions, company information and other important details to track and learn about the recalled products. In one place, you can track recalls
from 5 U.S. Government Agencies.
8.3.3 Workplace Exposure Measurement Apps
These Apps allows users to evaluate workplace exposure.
Heat Safety Tool by OSHA - The App allows workers and supervisors to calculate the heat
index for their worksite, and, based on the heat index, displays a risk level to outdoor workers.
The App also provides guidance on preventive measures.
NIOSH Lift Calculator by Humantech – Makes the use of NIOSH lifting equation easier.
LuxMeter Pro by AM PowerSoftware – This App allows the user to measure light intensity.
Decibel 10th by Skypaw Co. Ltd – This App and many similar Apps lets users measure the
sound level at the workplace. However, there is always a question of how accurate are these
smart device sound measurement apps. Based on field testing, users should use this app to do a
quick “temporary” analysis to determine noise levels, but should follow-up with “calibrated”
sound level meter.
8.3.4 Safety Planning and Audit Apps
Helps users to conduct safety audits and inspections, with a feature to take pictures and add them to
the report, and email a copy of the full audit report (see Figure 8-4).
iAuditor by SafetyCulture Pty Ltd
Safety Audit Pro by Iain Munro
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Inspect Safety, Quality, and Environment by Nimonik
Job Safety Analysis (JSA) by BreakThrough Application Pty Ltd
iSAFE- observation based audit tool- University of Washington
Figure 8-4: Safety Audit Using Smartphone Apps on an iPad (Photo courtesy of
Hensel Phelps Construction)
8.3.5 Custom-made Apps
There are many firms that can build custom apps for company-specific forms and checklists. Apps
can be built for other functions such as tracking incidents and accidents, for safe worker observation,
safety training, and education, and for many other safety functions. Construction professionals should
keep abreast with these innovative technologies and make use of them to improve not only worker
safety, but also work efficiency.
8.4 Safety while using mobile technology on site
While these mobile technologies present fantastic benefits, construction companies should be cautious
about the negative impact these might have on worker safety through distractions while using these
portable devices on site. Companies should develop and implement proper mobile technology use
policy on job sites.
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8.5 Other Technology Use
8.5.1 Zonar Electronic Fleet Monitoring System
Contractors with a large equipment and vehicle fleet can consider using Zonar’s Electronic Vehicle
Inspection Report (EVIR®). Traditional vehicle inspections were conducted manually that were less
efficient. This system involves placing a radio-frequency identification (RFID) tags on the vehicle in
critical inspection zones, which can be read by Zonar’s 2010 inspection tool, and the information is
transmitted to a database that can be accessing using web-browser. Zonar enables contractors to monitor their fleet such as daily operator inspection, missed operator inspection, generate speed reports
when the equipment exceed specified speeds, and issue alerts when an operator feels the equipment
is unsafe. This system helps an operator identify potential equipment hazards before they become a
serious safety issue.
8.5.2 Drones
Many construction employers are employing the use of Drones (a remote-controlled pilotless aircraft)
for site surveying, promotional videography, as well as safety observations. While these drones give an
excellent “birds eye view” of the construction operation, they cannot yet replace the value of a jobsite
walk through. These drones can, however, help in observing traffic flow patterns and other critical activities from the comfort and safety of the ground. While this emerging technology is becoming more
prevalent in the construction industry, it is not without hazards. Employers should consider a drone
safety policy and in-depth operator training/ testing before allowing their use on the job.
8.5.3 Personal Active Safety Systems (PASS)
Personal Active Safety Systems (PASS) are systems worn by individuals to improve their safety while
working in high-risk environments. These systems actively alert the wearer or those around him or her
of a potentially hazardous situation. Examples include alerting an individual of an imminent danger
to their person, notifying a supervisor that someone has possibly fallen on the job, signaling a vehicle
operator of an individual in a blind spot, or delineating to civilian traffic the personnel in an approaching work zone.
Two examples of PASS products are The Halo Light from ILLUMAGEAR (see Figure 8-5) and the
Safetemp Sensor from Coolshirt Systems. The Halo Light attaches to any hard hat and produces a
360-degree ring of light around the wearer, actively illuminating him or her and making him visible
up to a quarter mile away in all directions. It also illuminates the wearer’s task area out to the visual
periphery, making it easier to see obstacles that could result in slips, trips, and falls. The Safetemp Sensor is placed on the wearer’s neck. It monitors an individual’s core body temperature and provides an
audible alert when the wearer is at risk of heat exhaustion or heat stroke. PASS products such as these
are working to change what it means to be safe on the job.
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Figure 8-5: Halo Light – An example of Personal Active Safety Systems (PASS)
(Photo courtesy of ILLUMAGEAR)
Additional Resources, Readings, and References
Rajendran, S. and Clarke, B. (2011). “Building Information Modeling - Construction Safety Benefits and Opportunities.” Professional Safety, Journal of the American Society of Safety Engineers (ASSE), 56(10), 44-51.
BIM Forum - http://bimforum.org/
Georgia Institute of Technology RAPIDS Laboratory - http://www.rapids.gatech.edu/
Associated General Contractors (AGC), BIM Education - http://www.agc.org/cs/building_information_modeling_education_program
WBDG BIM Resource Page - http://www.wbdg.org/bim/bim.php
NIBS National BIM Standard Committee website - http://www.facilityinformationcouncil.org/
bim/index.php
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9
PROJECT SAFETY STARTUP GUIDE
9.1 PURPOSE
This chapter provides a toolbox for contractors to aid in the proper start-up of a construction project
from a safety “logistics” standpoint. To be successful, the project should have several items in place
before the commencement of any activity on the jobsite. The project superintendent or safety manager
should be responsible for ensuring that the following items are in place or completed prior to the start
of the project.
9.2 PROJECT SAFETY START-UP KIT
It is best practice for construction companies to develop a “project safety start-up kit” that contains
the following at a minimum:
Occupational Safety and Health Administration (OSHA) 300 log and 300A summary logs
All applicable local, state, and federal employment and safety posters
All applicable local, state, federal regulations (e.g., DOSH manuals, MUTCD manuals, etc.)
Company crisis management plan with all relevant corporate contacts
Safety resource guides (e.g., rigging guide, crane handbook, etc.)
Corporate safety manual
Site-specific safety plan
Site orientation checklists along with any training videos
Employee Handbooks
Drug and alcohol testing-related forms
Worker compensation related forms
Accident investigation packages (i.e. forms, cameras, tape measure, etc.)
Visitor log/liability release form
Site safety signage (i.e. sidewalk closed, PPE required, Danger, Warning, etc.)
See Exhibit 9-1 for an example project startup checklist that contractors can use as a model to develop
their checklist based on applicable local, state, and federal regulatory requirements that impact their
workplace.
9.3 SAFETY BULLETIN BOARD
Safety bulletin board is an excellent way to communicate project safety information to the crafts,
which in turn helps to improve employee safety awareness. The board should include safety bulletins,
safety newsletters, safety posters, accident statistics, safety-related educational materials, government
regulatory agency citations, OSHA 300A summary logs, and safety awards. Depending on the project
location, bilingual posters may be required to be posted.
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The safety bulletin board should be installed in a prominent location where all workers will see it. It
could be at the jobsite trailer entrance, site orientation area, or in the lunch tent. Each location has its
benefits; however, the important thing is that the employees should have access to this board to review
safety related information.
Projects should ensure compliance with DOSH safety bulletin board requirements (WAC 296-80019005), and all other applicable local, state, and federal posting requirements. According to WAC
296-155-115, “there shall be installed and maintained in every fixed establishment (the place where
employees regularly report to work) employing eight or more persons, a safety bulletin board sufficient
in size to display and post safety bulletins, newsletters, posters, accident statistics and other safety
educational material.” Common materials that should be posted on the bulletin board include:
Federal Employment/Safety Posters
οο Federal Minimum Wage
οο Employee Rights – Employee Polygraph Protection Act
οο Unemployment Benefits
οο Federal Employee Rights Under the Fair Labor Standards Act
οο Your Rights Under USERRA – The Uniformed Services Employment
οο Americans with Disabilities Act (ADA) Poster
οο Employment Rights on Government Contracts
οο Equal Employment Opportunity
οο Employee Rights and Responsibilities Under the Family and Medical Leave Act
οο DOSH Citations and notices (if received)
οο OSHA 300A summary form during February 1st to April 30th
State-Specific Employment/Safety Posters
οο Washington State Minimum Wage
οο Your Rights as a Worker in Washington State
οο WISHA poster
οο Notice to Employees—If a job injury occurs
οο Your rights as a nonagricultural worker
οο Washington State Self-insurance poster
Recommended Safety Program Information
οο Company Safety Policy or Mission Statement
οο Site Specific Emergency Procedure Plan
οο Emergency Contact Information – site contact, fire, hospital, DOSH, EPA, and other
regulating agencies.
οο Names and Contacts of First Aid/CPR or EMT Certified Employees
οο Key Site Supervision after-hours contact information
οο Designated Medical Provider Information/maps to clinic
οο Safety meeting minutes including accident information and lessons learned
οο Weekly activity information
οο Safety Award/Recognition Information
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οο Names of safety committee members and work phone numbers
οο Notices for upcoming meetings, training, or other safety-related events
Some projects will last several years, and it is important to ensure that the information on the board
is up-to-date. It is important to receive safety/employment posters from reliable organizations such
as trusted vendors, AGC, which can be trusted to notify you when new posters are developed with
updated information.
Figure 9-1: Example Safety Bulletin Board (Picture Courtesy BNBuilders)
9.4 SITE SIGNAGE AND FENCING
One of the first things to do before the start of actual construction activities is the installation of a
temporary construction security fence to delineate the construction area. Sites where it is not possible
other types of barriers should be considered. It should be followed by ordering and posting the
following signs on the site fence, as needed:
DANGER Construction Area – Keep out
Construction Site - No Trespassing Signs
NOTICE Authorized Personnel Only
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Hard Hat Area
NOTICE – All Visitors Must Report to Site Office
All activities monitored by video camera
Safety Rules Signage
Safety Warning Signage
Note: Depending on the project location, bilingual warning signs may be required to be posted.
9.5 SAFETY EQUIPMENT AND FIRST AID SUPPLIES
Construction projects get busy once you break ground. It is important that the project team ensure
that adequate and ample safety equipment and supplies are available at the project before the need
arise. A lockable storage cabinet or Knaack box should be used to store extra First-aid supplies and
safety equipment. The readers should ensure the project complies with all DOSH first-aid supplies
requirements (296-155 WAC and 296-800 WAC) and PPE requirements (296-155 WAC).
Recommended Basic Personal Protective Equipment
οο Hard hats
οο Gloves
οο Safety glasses and side shields
οο Hearing protection
οο Respiratory protection and related supplies
οο Safety vests
οο Sturdy work boots
Recommended Safety Equipment and Supplies
οο Automated external defibrillator (AED)
οο First Aid Kits in ample numbers for the job site
οο Eye wash liquids
οο Fire extinguishers in ample numbers for the job site
οο Warning signs/Safety Sings – for example, “NOTICE – Report all accidents and
injuries no matter how small, to your supervisor at once.”
οο Lockout/tag out supplies
οο Barricade
Caution Tape, Custom Caution Signs, and yellow ropes
Danger Tape, Custom Danger Signs, and red ropes
Traffic Control Candle Sticks
οο Snow Fence and fence T-posts
οο Traffic Control Signage
οο Fall protection/prevention equipment
οο HAZMAT spill kits
Emergency Equipment and Supplies (see Chapter 17 Construction Site Emergency
Management)
Communication Equipment (see Chapter 17 Construction Site Emergency Management)
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Figure 9-2: Example Safety Station/Bulletin Board with weather protection
(Picture Courtesy BNBuilders)
Figure 9-3 Example of Safety PPE Cabinet (Picture Courtesy of Korsmo Construction)
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Figure 9-4 Project Safety Kiosk (Picture Courtesy of Hensel Phelps Construction)
9.6 PROJECT SAFETY OFFICE
Having a dedicated space available for safety related activities and storing safety equipment and supplies
is critical to the successful implementation of the project. Large-scale construction sites, depending on
budget and space, can provide a dedicated small job trailer as the safety office. Small-scale project sites
should at the least designate a small office within a trailer as the safety area. The safety office should:
Be secure with a door and a lock – all project-related safety records will be typically stored in
this office including extremely sensitive employee records.
Have a first-aid kit and a sink with running water – could be used to provide first aid for
crafts.
Have several storage cabinets to store all the safety equipment, and supplies discussed above.
Be equipped with a computer with internet, printer, phone, and fax – it could be used to
receive confidential employee records. The room can also be used when employees are
communicated with drug and alcohol test results or disciplinary action.
Have a conference/training room near or within the safety office area to conduct site
orientations, if possible. If so, the room should also be equipped with audio-visual
equipment, enough space for seating and tables, and ample office supplies.
Note: On projects where the safety office does not have enough space, it is recommended to use a
Connex storage container to store all safety equipment or find an adequate area for conducting the
site orientation.
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9.7 PREPLANNING FOR EMERGENCY
Prior to the start of the project, jobsite supervision should meet with all local emergency response
organizations and perform a review of the construction site. These organizations include but not
limited to:
Local law enforcement agencies
Local fire department
Local medical facilities
Utility Companies
Government agencies – city, county, DOSH, etc.
Some things to share and discuss with them include:
What is your project schedule/hours of operations?
Will the agencies visit the project as conditions change? For example, can they visit and tour
the site every three months?
Share the site emergency plan with the emergency response organizations
Are there multiple project gates? Which gate should they enter in case of emergency?
Will there be a pilot vehicle within the project escorting the responders?
Will there be a lead person from the project who will lead emergency response efforts?
What is the site evacuation procedures?
Where are the flammable storage areas?
Are their special situations such as a tower crane operator rescue, confined space rescue, etc.?
Are the local response agencies equipped to respond to these emergencies?
Note: See Chapter 17 Construction Site Emergency Management for more information on emergency
planning and preparedness.
9.8 SETTING UP OCCUPATIONAL NON-EMERGENCY MEDICAL FACILITY/DRUG
TESTING FACILITY
One of the critical aspects of safety logistics should be setting up an occupational medical facility. In
most cases, these occupational clinics will also offer drug and alcohol testing services. Many companies
will have made a prior agreement with occupational clinic chains. Note depending on the state, you
cannot force a worker to go to a particular clinic. There are several factors that should be considered
when “designating” a project occupational clinic for non-emergency medical treatment and drug/
alcohol testing:
Will they be open during the project’s working hours? Is the clinic open during the weekend?
If not, what is the alternate clinic?
What type of services are offered by the clinic? Does it have x-ray facilities in-house? Should
the project designate a separate clinic for eye injuries or burn injuries?
What are the qualifications of the physicians? Do they understand work-related injuries? Are
they aware of return-to-work programs?
What is the distance of the clinic from the project? What is the average wait time for injured
employees to see the physician?
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Do they perform drug and alcohol testing? What are the various types of drug and alcohol
testing available? What is the average wait time for employees to complete drug and alcohol
testing? Do they provide a mobile drug and alcohol testing service?
Do they have an in-house pharmacy?
Does your insurance provider have any selection criteria?
Can they implement custom protocols for treatment and care to meet your company’s specific
needs?
Only after careful considerations of all these factors, a clinic should be selected. Once selected the
following items should be completed.
Create and post the direction map to the clinic along with name, address, and phone number.
Have several copies available to give to supervisors accompanying injured workers.
Supervisors should drive to the clinic from the project to get used to the route.
Provide all company specific drug and alcohol testing protocols and consent forms.
Through your insurance provider meet with the physicians, if possible, to explain your
company’s “return-to-work” program options.
Share the information with all your subcontractors during pre-construction meetings.
Share the information with your employees during site orientation.
Figure 9-5: Example Occupational Clinic Directions Map Posted on a Jobsite
(Picture Courtesy GLY Construction)
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9.9 OTHER CONSIDERATIONS
Communicate with the local community and project neighbors about the project schedule and potential
impacts such as noise, vibration, dust, etc. For example, if the project is next to operating hospital,
how early can the project start? Are there certain times of the day activities creating vibrations are not
allowed? Nominate a project liaison to work with the adjacent properties to minimize impacts.
Survey and record the pre-existing conditions using a video camera and pictures. It will help in case of
a claim from adjacent property owners for damages.
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Exhibit 9-1: Example Safety and Health Startup Checklist
(Used by permission from BNBuilders)
Note: This best practice tool is only included as an example, and the users should be aware that the
checklist may reference safety regulations depending on the company’s regulatory jurisdiction. It is
the user’s responsibility to ensure that they adapt the best practices provided in this checklist for their
jurisdiction and comply with all applicable local, state, and federal regulations affecting their workplace.
1. The following manuals must be on site, reviewed, understood and complied with at all times.
A. Freedom from Danger Training Manual
B. Site Specific Safety Manual
C. Mobile Crane Safety Manual
D. Crisis Management Plan
Refer to your Site Specific Safety Manual for specific items to address when work begins on the
project. (i.e. fall protection, respiratory protection, PPE, housekeeping, confined spaces, etc.)
2. All subcontractors shall submit copies of their Site Specific Safety Plans for review prior to
starting work on the project.
3. A safety filing system shall be established. Where needed, blank copies of the required documents
shall be obtained for use if needed.
4. Do all our employees, and that of our subcontractors know what to do in emergencies? Establish
and post “Emergency Response Procedures” at locations (typically stairs and exit pathways)
throughout the jobsite.
5. Contact Local Workers Comp Claims Representative:
A. Explain the nature of project.
B. Obtain names of clinics and physicians to treat various types of potential injuries.
C. Obtain a supply of reporting forms for physicians and hospitals to report claims.
6. Contact Physicians / Clinics:
A. Give them our workman’s compensation insurance information. Advise them that we
will require the use of a medical treatment authorization form (See attached example).
Discuss our policy on light duty.
B. Give them a copy of worker job analysis for use in determining light duty work.
C. If they will be providing screening for respirator usage, provide them with a copy of
the projects respiratory protection plan.
7. Contact Hospitals with your Director of Safety and Health:
A. May require issuing our workman’s compensation insurance information.
B. Advise them that in emergency case we may require their services.
C. Give them a copy of project info and contact information for their future reference.
8. Contact Occupational Clinic to establish a collection location for substance abuse screenings.
9. Contact Ambulance Service:
A. Give them good directions to your jobsite (will need a map).
B. Describe your job and advise them of the types of accidents to expect.
10.Contact Fire Department:
A. Give them good directions to your jobsite (will need a map).
B. Advise them of any particularly flammable or caustic substances that may be on your
project or any other unique features of your project.
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C. See if they have a rescue or paramedic unit in their department.
11.Contact Sheriff’s Department or Police Department:
A. Give them good directions to your jobsite will need a map).
B. Explain your project to them and advise them of the duration and the proposed
working hours.
C. Solicit their assistance and advice in handling traffic, moving equipment and
protecting your project from theft and vandalism.
12.Go through the Safety Bulletin Board Checklist (attached) and post all the enclosed forms on
your bulletin board. Make sure the posters are protected from water damage or sun fading.
13.Establish, post and maintain a Hazcom / Right-To-Know station on the jobsite. (See Project
Start-Up Package)
14.Fill out and post the Emergency Phone Number Poster (found in the Project Start-up Package) at
all phone locations on your project.
15.Injury and illness records must be kept as required by OSHA 300 Log, “Employer’s First Report
of Occupational Injury and Illness”, and First-Aid Injury Report.
16.The OSHA annual summary of workplace injuries and illnesses (part of the OSHA Log 300)
must maintained at all times and must be posted by February 1st and must remain posted until
May 1st
17.Each accident and near miss must be thoroughly investigated using the Accident Investigation
Report? Is an action taken to prevent reoccurrence formulated?
18.Each new employee is receiving a thorough safety orientation before they are allowed to begin
work, and it is to be documented in writing?
19.Establish a jobsite safety committee or group to regularly meet and report in writing, its
activities?
20.All our subcontractors are required to hold weekly safety meetings and report them to you in
writing.
21.Assure that the Weekly Toolbox Safety Meetings are effectively conducted and that all employees
attend these? It is required by DOSH at the start of the job and weekly thereafter including
documented walk around.
22.You and your supervisory staff must be conducting and documenting jobsite safety walk through
inspections using the Site Safety Audit forms found in the Project Start-Up Package.
23.Ground Fault Circuit Interrupters must be installed on all the temporary power circuits that
energize all portable electric tools and appliances. A qualified person shall test GFCI at least
once a month and document these tests.
24.Are all exits marked, visible, and unobstructed?
25.Have you taken special precautions to protect the public from the hazards of our construction
work?
26.Portable fire extinguishers must be provided in adequate number and type. Fire extinguishers
shall be inspected monthly for general condition and operability and noted on the inspection tag
and our fire extinguisher inspection log.
27.Are “No Smoking” signs prominently posted for areas, containing combustibles and flammables?
28.Have provisions been made to dispose of rubbish and litter daily?
29.Only UL approved safety cans, or other acceptable containers shall be and used for handling and
dispensing flammable liquids.
30.Are all flammable liquids that are kept inside buildings stored in proper storage containers or
cabinets?
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31.Are only trained personnel allowed to operate cranes and forklifts? DOSH requires that all
forklift operators be trained for the specific equipment being used. This training must be
documented and maintained on the jobsite. Operators must also follow the requirements in
chapter 296-863 WAC, Forklifts and other powered industrial trucks. All crane operators and
riggers should comply with the “Cranes, Rigging, and Personnel Lifting” standard of 296-155
WAC.
32.Is a copy of the Standard Hand Signals for cranes posted conspicuously at the jobsite and on the
side of each crane?
33.Are your first-aid supplies adequate for you workplace:
A. Are you documenting monthly inspections of the First Aid Kits?
B. Have arrangements been made either with Company – owned vehicles and ambulance
service for the transportation of the injured to the hospital or clinic
34.Hard hats and safety glasses shall be provided and worn while at all times in the workplace.
35.When lunches are eaten on the premises, are they eaten in areas where there is no exposure to
toxic materials, and not near a toilet facility?
36.Is the protection against the affects of occupational noise exposure provided? (A good rule of
thumb to use in determining if hearing protection is needed: If you have to shout to be heard
over the noise, then hearing protection is needed and must be required).
37.A competent person must be making daily inspections of all excavations? (If evidence of possible
cave-ins or slides is apparent, all work in the excavation shall cease until the necessary precautions
have been taken).
38.Does each over-the-road company owned vehicle contain in the glove box an accident reporting
kit describing what needs to be done and the forms filled out in the event of an accident?
(Additional lists can be obtained from the Safety Department). Report all Company vehicle
accidents to the Safety Dept and the local St. Paul Insurance Office.
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Exhibit 9-2: Example Safety Bulletin Board Checklist
(Used by permission from BNBuilders)
Note: This best practice tool is only included as an example, and the users should be aware that the
checklist may reference safety regulations depending on the company’s regulatory jurisdiction. It is
the user’s responsibility to ensure that they adapt the best practices provided in this checklist for their
jurisdiction and comply with all applicable local, state, and federal regulations affecting their workplace.
Put up a Safety Bulletin Board. The Safety Bulletin Board is to be located in an area where it will be
readily available to all personnel and near a phone. During the month of February through April, the
OSHA 300A Log is to be posted on this board. The same board can be used to post required EEO
posters. Use the board to promote safety, and do not let it deteriorate to a junk board.
ITEMS TO POST:
POSTED INITIAL
Emergency Phone Numbers:
_________ _________
Federal 5-in-1 Labor Law Poster(Now includes Family Leave Poster)
(English & Spanish)
_________ _________
DOSH, Worker’s Comp, Minimum
Wage and all other required State Posters
(English & Spanish)
_________ _________
Notification of Insurance Company
(St.Paul posters – English & Spanish)
_________ _________
Safety and Health Policy Statement
(Found in Project Startup Package)
_________ _________
Substance Abuse Policy & Procedures
_________ _________
Substance Abuse Hotline Poster
_________ _________
Safety Incentive Poster
_________ _________
Federal Projects:
Notice to all employees working on Federal or Federally Finance
Construction Projects and Notice to Employees Working On
Government Contracts.
_________ _________
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Exhibit 9-3: Example Required Safety Equipment for Project Start-up Checklist
(Used by permission from NOVA GROUP Inc.)
Note: This best practice tool is only included as an example, and the users should be aware that the
checklist may reference safety regulations depending on the company’s regulatory jurisdiction. It is
the user’s responsibility to ensure that they adapt the best practices provided in this checklist for their
jurisdiction and comply with all applicable local, state, and federal regulations affecting their workplace.
The below equipment is the minimum required for start-up on all Projects. The required equipment is
shown with the required quantity for a single activity and quantities needed per activity if needed. If
you need assistance locating or purchasing the below equipment, contact the Safety Director for further
information or assistance.
EQUIPMENT DESCRIPTION
Project Signage
Safety and Health Bulletin Board
Visitor PPE and sign-in sheet
Grab “N” Go Packets (Accident/
DOSH)
Recognize Eliminate Discuss “RED”
Books (Mini AHA)
Jobsite SDS’s
First Aid Kits (Station) 25 person
First Aid Kit (Mobile) ten person
Fire Extinguisher, ABC 2.5lb.
Fire Extinguisher, ABC 10lb.
Fire Extinguisher, ABC 20lb
Eye Wash Station or two 32-ounce
bottles filled with saline solution.
Barricade Tape, Yellow “Caution.”
Barricade Tape, Plastic, Red “Danger.”
Delineators, 42” safety warning yellow
or red
Multi Gas 4-Gas Monitor
# Required
Unit measure Or activity measure
As needed “Authorized Personnel Only,” “PPE required
/Strong Man Banner,” “ALL Visitors must
check with Jobsite Office,” “Zurich Stretch &
Flex Banner”etc….. Follow Project Specs
1
In a commonly accessed area and covered
As needed Site personnel should maintain a stock of
common PPE, such as hard hats, eye protection, ear plugs, and reflective vests for use by
visitors
1/ea
Location should be on office wall near the
exit.
20
Red books should be kept onsite and signed
by all
1
Located on thumb-drive and hung on the wall
1
Per 25 employees
1
Each mobile equipment
1
2
Each vehicle
Each Office trailer
Needed for Hot Work requirements. Also
should be mounted on portable fuel tanks.
1
Per 25 employees
1
Standard Rolls
1
Standard Rolls
As needed Sufficient amount to protect open holes or
trenches.
1
O2, CO2, H2S, and explosive limits LEL
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PID (Photo Ionization Device)
Absorbent Spill Kit
Fall Protection
LOTO Station
Bottled water
PPE
Quanta Provided AED
1
Needed if there is a possibility of contaminated soils.
1
55-gallon spill kit
Harness, Lanyard, Relief steps, and an SRL.
1
1
Isolate hazardous energy
As needed Adequate amount for personnel on jobsite.
As needed Adequate amount for personnel on jobsite.
1
Readily accessible for all
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10
CONSTRUCTION SITE PUBLIC PROTECTION
10.1 PURPOSE
A brick mason’s perimeter scaffold collapsed resulting in a severe injury to a pedestrian. A section of
a temporary construction fence tipped over during a heavy wind and injured a pedestrian. Can the
concerned contractors be held liable for these losses? The answer is a “yes.”
Any construction site carries risks associated with its activities that can cause injury/illness to the
members of the public and damage to their properties. Construction contractors can be held liable for
injury, death, or property damage to the members of the public arising from actions of their employees
or subcontractors. This liability is commonly known as a public liability or third-party claims.
The cost of dealing with such lawsuits and claims can be significant. In addition, public liability claims
can create adverse publicity to the contracting firm. It is important that contractors understand, in
addition to their workers, they also have a duty to protect the members of the public and their property
during a construction project. Hence, public protection should be an integral part of the contractor’s
site-specific safety plan (SSSP). This chapter will provide some guidance to contractors to identify
construction site exposures and industry’s best practice controls to minimize or eliminate injuries and
property damage to the public.
For the purpose of this chapter, “public” will include project visitors, tour groups, homes and businesses
within or adjacent to construction sites, guest, delivery drivers, commercial visitors, and the general
public. In other words, all persons not employed by or not under contract with the contractors working
on a construction site.
10.2 RESPONSIBILITY AND CONTRACTS
With a few exceptions, the general contractor (GC) will have the ultimate responsibility for control of
the project site, and to make sure all subcontractors take appropriate measures to protect the public.
This responsibility should be included in the contract between the GC and the subcontractors and
their tiers.
10.3 SAFETY/ EMERGENCY PLANNING
Prior to starting construction operations, the GC should consider and address all potential risks
associated with the project activities that may lead to public injury or property damage. Public protection
should be an integral part of every construction activity. Hence, all project-related job hazard analysis
(JHA) and pre-task plans (PTP) should consider public protection. In addition, the project should
develop an emergency action plan, which is in compliance with DOSH and other applicable regulatory
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requirements. See Section 17 for detailed information about the emergency management. The plan
should address at a minimum the following emergencies:
•
•
•
•
•
•
•
•
Flood, hurricane, tornado, serious inclement weather
Fire
Electrical outage
Chemical leak or spill
Medical emergency, fatality, multiple injury accidents
Catastrophe or collapse
Crime against property on the jobsite
Crime against persons on the jobsite
Instruct personnel on the job site about the emergency procedures. A specific plan to address public
contempt or protest that deals with members of the public who purposely place themselves or others
at risk by failing to observe or heed warnings or other directives or safety precautions. For example,
the plan may require notification to agencies with authority to control public activities, e.g., the police
or fire department, and cessation of all construction activities that may cause a hazard until the public
is controlled. A specific plan for handling threats or other violence as follows:
Bomb or arson threats
Threats of violence to the construction site employees
Suicide attempts/threats
Others
The plan should include immediate notification to and interface with appropriate authorities.
10.4 INSURANCE
GCs should ensure that they have adequate insurance coverage to protect them against claims made
by members of the public who suffers injury or property damage in connection with the project. GCs
should also require subcontractors to include them as additional insured under their general liability
policies. Contractors should also consider risks associated with vendors and suppliers, and ways to
manage those risks.
10.5 TRAINING
Public protection should be one of the main topics covered during the new employee site-specific
orientation. Workers and supervisors should be trained in the various site-specific public risks, and the
mitigation measures. The training should also include incident reporting procedures and emergency
response procedures.
10.6 PUBLIC COMMUNICATION
GCs should take a proactive approach when it comes to communicating construction impacts
with the neighboring homes and businesses. Property owners do not like surprises. Hence, proper
communication about the project scope and schedule will build good relationships with the neighbors.
Create a project telephone hotline or email to receive project-related inquiries. Some contractors,
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depending on the project size and public risks, have created a position or designated a team member
as the project’s minimum impact coordinator (MIC) to manage third-party risks and communications.
On many projects, this role is assigned to the project safety manager. The project should share MIC’s
contact information with the neighboring property owners, and let them know to contact the project
in case of an issue or concern. Some of the important tasks of the MIC should include:
Act as a public liaison, by serving as the main point of contact and respond to public inquiries
and complaints on matters of public interest and concern.
Coordinate, attend, and present to business, community, and neighborhood group meetings
regarding the project, its impacts, and intended mitigations. Focus on how the project will deal
with noise issues, traffic disruptions, dust issues, etc.
Monitor project’s hotline voicemail and maintains a log of incoming inquiries and response.
Create and distribute project-related public education materials, and be available to attend
community events and meetings.
Prepare and distribute advertisement materials to the neighbors.
Investigate any accidents related to the public and implement corrective actions.
10.7 PRIVACY
Sometimes construction will take place in proximity to neighboring properties. On one project, a
hospital close to the project had patient rooms facing the building site where construction workers can
easily see through the patient rooms. These privacy issues should be identified and mitigated prior to
starting construction.
10.8 PUBLIC PROTECTION RISKS AND CONTROLS
Some of the most common public risks associated with construction projects, and best practices to
control them are discussed in the following sections.
10.8.1 Site Security
What safety and site security measures should the project have in place? The magnitude of site security
measures varies from project to project. Several factors determine the level of security needed for the
project such as location (rural vs. urban), type of structure (building vs. roadways), size, duration, level
of attractive nuisance exposures (e.g., close to school), level of crime in the area and a few others. Some
things to consider:
a) Designate a person responsible for security to monitor site security including periodic inspection
of fencing and signage. The person should also review site security measures on a regular basis
since conditions change on the site frequently. Contractors have hired off-duty police officers
or retired police officers to serve as site security managers.
b) Where appropriate, the project sites should have adequate perimeter control with the help of
a temporary fencing. The main objective of the fence is to avoid unauthorized or inadvertent
access to the project site. The fence should be strong enough and high enough, and properly
secured and anchored to prevent tipping. There have been many incidents where pedestrians
were struck by the falling fence, which resulted in lawsuits against contractors claiming negligent
erection and maintenance of construction fencing.
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c) The perimeter fence gates should have locks, which should be locked at the end of shift and
proper access controls during and after hours of operations. Site gates should be closed when
not in use and opened only when required for special deliveries or other authorized entries.
d) Post appropriate warnings and signs conspicuously on the fence, gates, and any other site
entrances such as “no trespassing and keep out – construction area,” to warn the public.
e) Establish a system in place to control vehicle access in and out of the site. Only authorized
vehicles should be allowed on the site. This is critical when working near hospitals when patients
or elderly people might get easily confused and enter job sites by mistake.
f) Set up an approval system in place to remove or alter fencing. During the course of the project,
contractors remove or alter the fence to carry out their scope of work. This practice should be
strongly discouraged or should only be allowed after consultation with the project supervision.
g) Issue gate keys only to authorized supervisors and establish a system in place to control the key
issuance.
h) When site access control with a fence is not possible or not appropriate, discourage site access
using physical barricades, warning ropes, and signage.
i) Taking pictures at the end of the shift of the safe and secure site conditions is the best practice
to protect against lawsuits.
j) Inform local law enforcement agencies of your work schedule and security measures, and
request them to patrol the site after working hours.
k) Other site security measures that have been successfully used by contractors in conjunction
with fencing include but not limited to:
οο Security guard service during non-work hours both weekdays and weekends
οο Live security camera surveillance with motion sensors
οο Site under surveillance signage
οο Intrusion alarm systems or tracking devices tied to a monitoring service
Figure 10-1: Example of Properly Installed Construction Site Security Fence (Picture Courtesy of
Sellen Construction)
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Figure 10-2: Example of Properly Installed Site Fence with Appropriate Warning Signage (Picture
Courtesy of Hoffman Construction Company of Oregon).
Figure 10-3: Workers Installing Project Perimeter Privacy Barricade (Courtesy of Hensel Phelps
Construction)
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10.8.2 Attractive Nuisance
All construction sites are an attractive nuisance, which can attract people to the project to explore
it. With its fleet of heavy equipment, tower cranes, mobile cranes, trucks, hiding places, dirt piles;
construction sites, in particular, are very attractive to children and teenagers. If they are hurt a while,
on the site, contractors can be held liable for their injury. Consequently, the project should take all
due-diligence (standard of care) and good faith efforts to safeguard the project. Hence, if site access
control fails (fence or other barriers), in order to avoid liability, the following precautions should be
taken to prevent injuries:
Secure storage areas containing hazardous materials and waste.
Protect open holes and leading edges including manholes and excavations by cordoning the
area off with ropes or even physical barriers.
Ensure the stability of material storage areas.
Employ tools and equipment controls.
Restrict access to tower crane towers, electrical rooms, etc.
Remove keys from the heavy equipment such as excavators, pile drivers, lifts, etc.
Protect entry into confined spaces.
Protect and prevent access to unfinished stairways, scaffolds, etc., with physical barriers.
Remove unattended ladders that can provide access to unprotected areas.
10.8.3 Visitor Controls
How can the project avoid or reduce potential liability associated with visitors? The project should
create a visitor access policy. The project should:
Install signs at the project entrance and gates that instruct all visitors to report to the project
office.
Maintain a visitor log; all visitors should sign-in and out at the project office.
Require all visitors to sign a “hold-harmless” agreement holding the contractors/owners
harmless in case of injury or damage.
Develop and deliver a modified site orientation and document the orientation. The orientation
should, at a minimum, cover the high hazard areas, designated walkways, site Attire and
Personal Protective Equipment (PPE) requirements.
All visitors must wear the required PPE while on the project site. If the visitor fails to comply
with the requirements, deny site access.
Never allow visitors to tour the site by themselves, always provide an escort who is familiar with
the site.
Develop a visitor badge or visitor pass system for ease of identification of the visitor. Some
contractors have even used a special hard hat for visitors (e.g., red hard hats).
Sometimes school children or college students tour sites for educational purposes. Tour groups
can be complicated compared to individual visitors; extreme precaution must be taken. Establish
some age limit for tours. For example, children under the age of 12 will not be permitted to
accompany tours or visit the site. Also in case of children, ensure an adult sign the hold-harmless
agreement, preferably a parent or teacher.
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Figure 10-4: Example of visitor signage at the project entrance that instructs all visitors to report to the
project office (Picture Courtesy of Lydig Construction)
10.8.4 Traffic Control
Failure to identify and control exposures related to traffic control can lead to significant losses in
the form of injuries and public liability to both heavy civil contractors (i.e. highway work zone) and
building contractors (i.e. city streets adjacent to jobsites). Some common exposures include pedestrians
walking by or near the project and motorists driving by the project. Some of the best practices to
follow to avoid losses related to traffic are:
Implement approved traffic control plans for compliance with applicable local standards. It is
best practice to create both an onsite and offsite traffic control plans.
Use of certified flaggers to control traffic when working in highway work zones, and for directing
vehicles in and out of jobsites.
Proper segregation between traffic and pedestrian routes.
Backup alarms use on trucks and construction equipment.
Good use of clean and clear signs and barricades in compliance with applicable local standards.
Daily inspection of traffic control devices - many times traffic control devices that are blown
onto vehicles have led to public injuries. When responding to lawsuits involving a highway work
zone accident, attorneys will check to see if proper control was in place.
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Daily inspection to ensure the roads are free of “ground hazards” created by construction
work such as potholes, gravel, steel trench plates, and other debris. Install concrete wash-out
and tire wash areas to prevent from mud and rocks migrating to the streets. There have been
numerous incidents involving bicyclists slipping on rocks from construction sites on the streets
or a broken windshield due to these rocks.
Figure 10-5: Example of Traffic Control around Construction Sites (Picture Courtesy of Korsmo
Construction)
10.8.5 Property Protection
What are the various properties that should be considered? How to protect against property damage?
Property adjacent to construction sites can be damaged, and its occupants can be put at risk. The
property can include:
Adjacent buildings or structures (neighboring homes and business, city-owned sidewalks, city
streets, etc.)
Adjacent lands
Vehicles of others (cars driving by the site, cars parked near the site)
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Tools and equipment of others
Business interruption related losses
The project team should consider all potential sources that can cause property damage. The construction
activities that can cause the most exposure include:
Crane and rigging work can cause loads to shift and damage adjacent properties.
Compressed gases, flammable and combustible liquids stored on site can cause an explosion.
Open flame hot work can cause site fire or smoke damage.
Demolition activities can cause dust, vibration, flying objects, and noise issues.
Vibrations can result from activities such as demolition, blasting, pile driving, drilling, tunneling
can cause adjacent property collapse or damage.
Painting activities, concrete pours, etc., can cause material escape from the site and cause
damages to passing traffic, pedestrians, and adjacent properties.
The ground movement caused by excavation, compaction, dewatering, undermining, tunneling,
shoring, etc., can cause adjacent property settlement or damage.
Some example incidents,
οο An excavation contractor’s backfill and subsequent compaction caused adjacent
property settlement.
οο A painting contractor’s overspray caused a parked black car turn into an orange car.
οο An overspray from a concrete hose from a high-rise damaged the windshield of a car
driving by on the city street below.
οο A crane load struck a vehicle driven by a member of public close to the job site.
Even though, construction activities can sometimes lead adjacent property owners suddenly to notice
cracks in walls and foundations, many of these, however, could be pre-existing. A preliminary preconstruction property third-party survey is highly recommended to document existing conditions of
adjacent structures and surrounding areas prior to commencement of construction. The conditions
should be continuously monitored as construction progresses. Photographs, videos, physical
measurements, etc., should be taken to establish pre-existing conditions clearly. It is highly recommended
to conduct a similar post-construction survey to compare with the pre-existing conditions. If the
construction activity did cause some damage, it might be beneficial to fix it. Ensure there are physical
and fire separation and protection measures for adjacent properties.
A pre-task plan of all activities should consider any potential public property damage and provide
control measures is in place. For example, an excavation contractor digging a trench in an area known
to have a city water line. The water line supplies water to the entire neighborhood. What precautions
should be taken? Any underground or overhead utility service strike can lead to injury or death, and
will affect the business and residents. The contractor should identify the existing water line using
the “know what’s below – CALL before you dig.” In addition, the contractor can also use “vacuum
excavation” to get a visual on the line before starting to dig with an excavator to avoid utility strike
that will affect the residents. For crane and rigging tasks, develop and implement good hoisting and
material handling programs.
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Any open flame hot work or smoking that could cause a fire damage to adjacent properties the
contractor should develop and implement a good fire prevention and protection program.
10.8.6 Pedestrians
Areas around a construction site pose several hazards to the pedestrians. Some of the common
pedestrian hazards include but not limited to uneven or slippery surfaces, steep surfaces, unprotected
holes and edges, overhead obstructions, poor pedestrian routes, inadequate lighting and many others.
It is best practice to close sidewalks adjacent to projects when necessary with proper directional signage
to channel the pedestrians safely around the construction site per applicable local standards. Certain
states and cities have specific requirements when closing sidewalks.
Maintain the pedestrian walkways free of slip, trip, and fall hazards. Ensure the walkways are kept
clean at all times by removing any debris and warn pedestrians about any change in elevation of
the walking surfaces. Provide adequate lighting for the walkways. When appropriate use overhead
protection with the help of covered walkways. Temporary sidewalks, ramps or stairs should be provided
with guardrails on both sides.
Where it is necessary to provide alternative or restricted pedestrian routes, make sure you address the
needs of persons who are blind or partially sighted, use wheelchairs or have other mobility difficulties.
Temporary pedestrian walkways should have uniform surfaces, with access ramps, handrails if
necessary, good lighting and a suitable surface like smooth non-slip/trip concrete. Clear signs should
be provided to direct people to the correct pedestrian route, particularly if the destination building has
been obscured by the construction site. Clearly define the walkway by a continuous barrier and ensure
the walkway is kept free of debris and clutter.
Figure 10-6: Example of Pedestrian pathway around construction sites (Picture Courtesy of Korsmo
Construction)
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Figure 10-7: Example of Sidewalk Closed Signage and Barricade (Picture Courtesy of Hensel Phelps
Construction)
10.8.7 Other hazards
This section lists other common hazards that could cause personal injuries.
Falling Objects
Many construction activities creates a potential hazard of falling objects such as material handling
work along the building perimeter, concrete pours, construction debris that can get wind-borne such
as loose plywood or cut metal decks, that can cause serious injury or death to members of the public.
Is the area subject to strong winds? These hazards can be controlled by protection systems such as:
Safe and proper material handling procedures so as, not to interfere with any adjacent
structures
Adequate overhead protection
Adequate edge protection
Physical separation of the site from the public
Crane safety procedures during heavy winds
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Figure 10-8: Example of Pedestrian Pathway and Falling Object Protection around construction sites
(Picture Courtesy of GLY Construction)
Slips, trips, and falls
Properly maintained surfaces
Well protected holes and edges
Adequate provision of safe pedestrian routes
Adequate site lighting on pedestrian routes
Slip-free surfaces
Radiation
Control of radiation risks is impacting public. For example, how to protect public from
welding UV light?
Installation of proper signage
Noise
Compliance with local noise ordinance
Coordinate start time and schedule of high noise activities with adjacent property owners
to minimize impacts. For example, concrete pour at three a.m., can generate a lot of noise
concrete truck back-up alarms, light towers might shine at the neighbors window, etc
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Fire
Good fire prevention and protection program
Smoking controls
Environmental Hazards
Maintain a clean work area with adequate debris removal
Develop and implement an airborne contaminant management plan to prevent the escape of
a hazardous substance to escape from the site such as silica, asbestos, etc
Approved erosion and sediment control plan
Approved hazardous materials and waste management plan
Daily inspection of the site to contain the environmental hazards
Additional Resources, Readings, and References
ANSI/ASSE A10.34-2001 (R2012) – Protection of the Public on or Adjacent to Construction
Sites - One of the key element of the standard is a public hazard control plan (PHCP). The
PHCP is a guideline to aid the contractor in identifying, evaluating, preventing or minimizing
their exposures as identified in the standard.
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11
CONSTRUCTION SITE EMPLOYEE WELLNESS PROGRAM
11.1 PURPOSE
The readers might wonder why a construction site wellness program is part of a construction project
safety best practices handbook. Construction contractors are always looking for new ideas that will
help improve their company’s safety performance. One such idea is the implementation of worker
wellness program as part of the contractor’s site safety program.
11.2 NEED
In 2010, 71% of construction workers were either overweight or obese, 30% had hypertension, and
8% had diabetes. Among those aged 55 years and older, 56% had hypertension, 18% had diabetes, and
15% had heart disease.1 The construction workforce in the United States is aging. The average age of
construction workers was 41.5, and the proportion of workers aged 45 to 64 years was 38.7% in 2010.2
Will unhealthy employees (pre-existing health conditions) have extra and more severe workers’
compensation claims? Can an employee wellness program improve workplace safety? The answer to
both these questions is “yes.” A Duke University Medical Center analysis found that obese workers
filed twice the number of workers’ compensation claims, had seven times higher medical costs from
those claims and lost 13 times more days of work from work-related injury or work-related illness than
did nonobese workers.3 Another study by the University of Michigan Health Management Research
Center found employees with individual health risks (e.g., smoking, physical inactivity, etc.) had high
workers’ compensation costs.4
Construction operations are physically demanding. In order to physically perform safe and productive
work; it is crucial that crafts are physically and mentally fit. Implementing a construction site employee
wellness program will develop healthier crafts.
11.3 WELLNESS PROGRAM CONSIDERATIONS
Similar to the construction site safety program, the successful implementation of the project site
wellness program depends on the combined efforts of project owners, general contractors (GC), and
subcontractors. Each of these parties may already have an in-place corporate wellness program and
1 The Center for Construction Research and Training (CPWR). The Construction Chart Book, 5th Edition.
http://www.cpwr.com/sites/default/files/publications/5th%20Edition%20Chart%20Book%20Final.pdf (Accessed December 2, 2014)
2 The Center for Construction Research and Training (CPWR). The Construction Chart Book, 5th Edition.
2 http://www.cpwr.com/sites/default/files/publications/5th%20Edition%20Chart%20Book%20Final.pdf (Accessed December 2, 2014)
3 Duke Medicine News and Communications. http://corporate.dukemedicine.org/news_and_publications/news_office/news/10044
(Accessed November 18, 2014)
4 Musich, S., Napier, D., and Edington, D.W. (2001). The Association of Health Risks with Workers’ Compensation Costs.
Journal of Occupational and Environmental Medicine. 43(6): 534-541.
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might address wellness on each of its projects. The other case would be a contractor who does not
have a corporate program in place but is required by the owner (in case of GC) or GC (in case of
subcontractors) to participate in a project-level wellness program as part of the contract. Either way,
contractors might find the program guidelines provided in this section to be useful to help develop and
implement an effective workplace wellness program. Remember wellness programs are not required by
any government regulatory agencies, it is a voluntary program to promote healthy behaviors.
11.3.1 Obtain project owner support
Like workplace safety, the project owner has a significant role in the implementation of a project-level
wellness program. Some questions to consider:
Does top management of all project stakeholders buy-in to the idea of the jobsite wellness?
Do they understand the financial benefits of implementing a jobsite wellness program?
Does the project budget allow implementation of a wellness program?
Projects insured under Owner Controlled Insurance Program (OCIP) or Contractor Controlled
Insurance Program (OCIP) have a huge incentive to implement project-level wellness program.
Contractors who are self-insured even for their health insurance plans will benefit from this program.
The support should include establishing a project budget for the wellness program. If the owner refuses
to support a wellness program financially, will the project still be committed to implementing this
program?
11.3.2 Consult legal counsel
There could be legal issues associated with implementing a wellness program including the Americans
with Disabilities Act (ADA), the Health Insurance Portability and Accountability Act (HIPAA), tax
laws for incentives, and the Genetic Information Non- Discrimination Act (GINA). Please consult
your legal counsel to avoid legal issues.
11.3.3 Try to integrate wellness and worker safety
The project should aim to integrate wellness and safety since both the program’s goal is employee wellbeing. Since there are many parallels between these programs; it would be very efficient to integrate
them. For example, safety incentives vs. wellness incentive, safety newsletter vs. wellness newsletter,
safety committee vs. wellness committee, etc.
11.3.4 Develop a policy statement
The owner should issue a policy statement that outlines the site wellness program goals and show
a commitment to employee wellness. A well-written policy statement will show the employees that
the management cares and is committed to creating a healthier workforce. The policy should be
communicated to employees during new employee orientation. If possible, instead of a separate policy
statement, including wellness in the site safety policy statement would be beneficial.
11.3.5 Receive a commitment from subcontractors
Include wellness program requirements in the construction contracts. Specify the commitment required
such as the cost associated with the “time” commitment required by their employees to participate in
site wellness initiatives, which allows contractors to include it in their project budget. For example,
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does the project require a daily morning 15-minute stretch and flex program? It can cost a specialty
firm employing 100 workers ($55/hour billing rate) more than $ 30,000 a month by requiring them to
participate in a stretching session every day for 15 minutes.
11.3.6 Establish a jobsite wellness committee
Depending on the project size, a jobsite wellness committee can be established to lead the wellness
efforts. Since most jobsites are required to have a safety committee, the project can just charge the
safety committee to oversee the site wellness initiatives. This would be a better idea on smaller and
short-term projects. The use of a multi-discipline (e.g., electrician, plumbers, etc.) wellness team is
essential in a project-level wellness program. Some firms have included workers who lead a sedentary
lifestyle or who currently smoke and are committed to change their way of life.
11.3.7 Assess the needs and interests of the workers
Before the committee can create and implement wellness initiatives, it is important to determine the
needs and interests of the workers. Construction is different; generic wellness initiatives might not
work and will result in very low participation. Never assume construction workers will participate
because it is good for them. Identify some initiatives that will be feasible to implement at a projectlevel, considering the jobsite constraints, and then survey the crafts.
The survey should be simple with less than ten questions and can be administrated during weekly site
safety meetings. Remind the employees that the wellness program is not mandatory. Some of the items
to include in the survey:
Gauge interest – Are they interested in participating? Determine what percentage of workers
are interested in participating in the program.
Activity type – What are the different types of wellness activities they will most likely
participate (e.g., weight-loss, stress management, smoking cessation, etc.)?
How would they like to receive wellness training and education? (e.g., paycheck stuffer,
stand-alone trainings, messages on safety bulletin board, the project newsletter, etc.)
What will motivate them to participate? (e.g., types of incentives)
11.3.8 Offer free biometric screenings
The project should provide a free biometric screening to establish a health baseline, and encourage
employees to take advantage of this free screening. The administration of the program can be modeled
similarly to other site programs such as drug and alcohol testing programs. The project can make
arrangements so that employees can take their biometric screenings at the same clinic where they do
their drug and alcohol testing to improve participation and make it efficient.
11.3.9 Select and implement “simple” wellness initiatives
Remember, traditional wellness initiatives will not work well on construction sites since most crafts are
on the jobsite only for a short-term. Even when they are on the site, they are “on-the-go” all the time.
They do not have the time to maintain a food journal or fill out an activity log. Provide them with tools
such as a pedometer or an activity tracker or even buy them mobile apps that will make it easier for
them to track progress while on the go.
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In addition, it might be challenging to benchmark health data to set long-term goals to reduce atrisk behavior at a project-level. Also, the project duration can vary from few months to several years.
Hence, the project team should aim for simple initiatives that could be a “starting point” for workers
to make lifestyle changes – every little bit helps. A few examples of wellness initiatives that can be
implemented on a construction jobsite include:
Locate craft parking lot a little farther away from the site to promote walking
Require daily stretch and flex exercises
Replace junk foods in the site vending machine with fruits and vegetables
Provide healthy food and snacks at safety lunches and meetings
Conduct team weight loss competitions, erect “number of pounds lost” signage similar to
safety signs “a number of days without injuries”
Provide discounts for the gym membership near the project with a minimum attendance
requirement
Conduct project-specific runs
Offer educational seminars on the impact of health risks and workplace safety
Support wellness programs such as smoking cessation, stress management, and substance
abuse program
Supply free or discounted nicotine-replacement products
Include health tips in their pay stub envelopes
Post health tips/flyers on the project safety bulletin board
Leave health magazines in the lunch tent and rest areas
Create a “wow board” where employees can share their success
Provide water coolers at several locations to encourage workers to hydrate
Figure 11.1: Example of Employee Wellness Program - A Workplace Fitness Center (Picture Courtesy
of Exxel Pacific General Contractors)
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11.3.10 Provide incentives
Implement a wellness incentive program in conjunction with safety incentives to increase program
participation with simple rewards such as a $20 gift card for:
Completing a health risk assessment
Participate in a biometric and other health-related screening
Lead site stretch and flex exercises
Meet some activity-based goals such as perform stretch and flex exercises every day, walk
a certain number of steps, etc.
Note: Keep incentives simple and available to all employees for participation. Does the wellness
programs incentives violate the Americans with Disabilities Act (ADA)? A final ruling was scheduled
in early 2015 “to address numerous inquiries the U.S. Equal Employment Opportunity Commission
(EEOC) has received about whether an employer that complies with regulations implementing the
final Health Insurance Portability and Accountability Act (HIPAA) rules concerning wellness
program incentives, as amended by the Affordable Care Act (ACA), will be in compliance with the
ADA.” Employers should consult their legal counsel and frequently review their wellness programs for
compliance with all appropriate regulations.
11.3.11 Maintain a hygienic jobsite
Employee morale is crucial to a good jobsite safety performance and a wellness performance. One
cannot promote wellness on a project with poor housekeeping issues. The project should ensure
superior cleanliness of site toilet facilities, lunch areas, sleeping quarters, changing rooms, drinking
water, washing facilities and general site housekeeping, and proper vermin control.
11.3.12 Involve worker family in wellness & safety program
The program should make every effort to include a worker’s family members. Over the years, construction
companies have involved family members in promoting safe worker behavior by creating safety
calendars, construction safety activity books, family/home safety books and few others successfully.
Similarly, an employee’s lifestyle can be changed by including their family members. For example,
some companies like PCL Construction Services, Inc., headquartered in Denver, Colo., publish “PCL
Family Safety” handbook. Its contents include safety topics such as skating safety, lawn and garden
safety, winter safety tips, etc. In addition, the book includes wellness topics such as stress management,
healthy eating, and physical activity tips. This is an excellent way to show that the company cares about
not only a safe and healthy work environment, but it also cares about their employees and families’
well-being.
11.3.13 Evaluate program effectiveness and document lessons learned
Wellness programs should be continually assessed for performance effectiveness. Listen to concerns
and feedback from management and employees that will help improve the program. Prepare “lesson
learned” list on an ongoing basis, which can be applied in future project wellness programs.
Even though there are unique challenges associated with implementing a wellness program on a fastpaced, short-term, and ever-changing jobsites, it is possible.
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Additional Resources, Readings, and References
NIOSH has prepared a Research Compendium: The NIOSH Total Worker Health™
Program: Seminal Research Papers 2012 – An overview of the relationship between wellness
programs and workplace safety: www.cdc.gov/niosh/docs/2012-146/
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12
DEVELOPMENT OF SITE SPECIFIC SAFETY PLAN (SSSP)
12.1 PURPOSE
The Site Specific Safety Plan (SSSP) is a safety planning tool that outlines project safety and health
requirements and guidelines to help protect site personnel, visitors, the public, and the environment
from exposure to potential safety and health hazards. The SSSP should address all anticipated hazards
that will be encountered on the project. The SSSP should evaluate both field and office activities to
identify hazards and provide control measures. This chapter presents guidelines intended to help the
project team develop an effective SSSP.
12.2 SSSP REQUIREMENT
It is typical for a construction project to have multiple SSSPs. The general contractor should develop
and implement an overall project SSSP. The plan should require all subcontractors and their sub-tier
subcontractors to complete an SSSP for their scope of work. For example, a mechanical subcontractor
will develop an SSSP for their scope but will also require an SSSP for their sub-tier insulation subcontractor. At a minimum, the subcontractor SSSP must meet the requirements of the project SSSP and
all applicable regulations in relation to the project’s jurisdictions.
12.3 REVIEW AND APPROVAL
The general contractor’s overall SSSP should be reviewed and approved by the Project Superintendent
and the Project Manager. Some companies even send their SSSP to their corporate office for review
and approval by their upper management. On certain projects, the project owner might contractually
require GCs to submit the overall SSSP for the owner’s approval. The general contractor should require every subcontractor and their sub-tier subcontractors to submit their SSSP for review and approval by the Project Superintendent or designee, and the Project Safety Manager, at least two weeks
before commencement of work. The review should ensure that the SSSP meets the project safety requirements. The subcontractor should not be allowed to commence work prior to their SSSP approval.
An example Subcontractor Safety Plan Evaluation Form is presented in this section as Exhibit 12-1.
12.4 SPECIFICITY
It is common to contractors just to refer/submit their corporate safety manual in place of an SSSP. All
SSSP’s must be project specific. Do not accept their corporate safety manual. Require each contractor
to submit an SSSP.
12.5 REVISIONS
It is common that the site conditions change due to several factors including change in scope of work.
The SSSP should be updated when conditions change and should be submitted for approval. All
changes should be communicated to the site personnel impacted by the change.
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12.6 PHASED SCOPE
Some projects will have multiple contract packages or even multiple structures. For example, one project might have three different types of buildings. In those situations, it is recommended to develop a
separate SSSP for each package.
12.7 SSSP PREPARATION AND CONTENT
The project SSSP should be prepared in collaboration with the safety department and the project management. It is recommended to hold a pre-job safety planning meeting to discuss the SSSP contents
that shall include: company policies, owner safety requirements, all applicable laws, project-specific
issues that will impact the safety performance of the project. The SSSP, whether it is for the overall
project or a specific subcontractor, it shall include safety procedures as they pertain to their scope of
work. If the scope does not have the exposure, the corresponding safety element is not required. The
following content and safety work procedures, as applicable, should be part of the project SSSP.
12.7.1 Project Safety Policy
The project should establish a documented safety policy as the core of the project safety program. At
a minimum, the policy should include a commitment to worker protection, worker involvement, and
compliance with company and all appropriate regulations.
12.7.2 Scope of work
This section should include a brief description of the scope of work, details of the structure, detail any
unusual site conditions and exposures, and it should also include an overview of activities that will be
performed by the subcontractors.
12.7.3 Responsibilities
The SSSP should identify the responsibilities of the project team that should include: project manager,
project superintendent, general foreman/foreman, safety department, and the crafts.
12.7.4 Site Logistic Plan
Include a site-specific logistics plan that includes:
Pedestrian walkways
Job trailer park
Connex & Lay-down areas
Delivery entrance
Site security fence line (gate location, site lighting, security services)
Concrete washout
Tire washing area
Evacuation muster points
Craft parking
Site orientation trailers
Toilet Trailers
Lunch tent
Material staging and hoisting area
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12.7.5 Safety and Emergency Contacts
Include the name and contact information for project safety and field management personnel. Also,
create a list of other contacts such as:
Company legal counsel
Project spokesperson
Government agencies/offices (DOSH, OSHA, MSHA, EPA)
Grievance counselors
Red Cross
Transportation services
Utility companies
12.7.6 First Aid and Emergency Medical Services
Create an information sheet that includes information about the closest urgent care clinics, occupational clinics, eye clinics, and hospitals that will provide medical treatment to workers injured on the job.
The project emergency contact information sheet should include the name of the facility, route map, phone
number, and hours of operations. If the project has an on-site nurse station, ensure it is communicated to
the employees during orientation and safety meetings.
12.7.7 Owner Requirements or Impacts
Address any site specific rules when working in or around operating facility. For example, adding a new
building next to a large airport runway. Ensure appropriate rules are in place to minimize impacts to
owner facility or operations. Many owners require special permits such as a dig permit, odor permit,
dust permit, etc, when working in or close to their operating facilities.
12.7.8 Safety Administration Programs
The SSSP should include the following safety administration/management level elements.
Senior management policy statement
Job site postings
Workplace Substance Abuse Programs
Subcontractor Site Specific Safety Plan
Safety Trainings
Safety Meetings
New Employee Orientation
Safety Inspections
Pre-task Planning and Job-Hazard Analysis
Accident and investigation reporting procedures
Return to work programs
Crisis Management Plan
Disciplinary procedures
Safety Staffing
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12.7.9 Technical Areas
The following elements, if applicable, should be key components of the SSSP. Ensure detailed procedures are in place to address all high hazard operations.
Site Environment (existing utilities)
Public Protection (covered walkways, road closures, sidewalks)
Industrial Hygiene (mold, dust, noise, lead, PCS, asbestos, lead, mercury, silica)
Traffic Control Plan
Trenching and Excavation
Fall Protection
Housekeeping
Ladder and Scaffold Safety
Lockout/Tagout
Hazard Communication (HAZCOM)
Confined space
Electrical
Bloodborne pathogens
Traffic control plan
Fire prevention and protection
Hot work program
Personal Protective Equipment (PPE)
Respiratory Protection
Hearing conservation program
Welding and cutting
Motorized Vehicles and Equipment
Crane, rigging, and hoisting
Material handling
Environmental (Heat or Cold Stress Programs)
Any Special Hazards that are not included above
The level of formality or details associated with an SSSP will vary depending on the project’s anticipated risk level, which depends on the type, complexity, and size of the project. A large high-rise project
might pose a lower risk compared to a small airport project. It can also depend on government requirements. An example is when working on an Army base you would have to follow the Army Corps
of Engineers standards vs. regular OSHA standards, even though, the base is a federal facility. Hence,
the project team should identify significant hazards and develop control measures by developing an
excellent SSSP.
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Exhibit 12-1: Example Subcontractor SSSP Evaluation Form
(Used by permission from Exxel Pacific General Contractors)
Note: This best practice tool is only included as an example, and the users should be aware that the checklist may reference safety regulations depending on the company’s regulatory jurisdiction. It is the user’s
responsibility to ensure that they adapt the best practices provided in this checklist for their jurisdiction
and comply with all applicable local, state, and federal regulations affecting their workplace.
Submitted in Plan?
Plan submitted by (Contractor Name):___________________________ Yes
No
Required Safety Program Elements
Company Safety Policy
Designated Site Safety Representative
First Aid and Emergency Procedures
Procedure for Reporting Injury or Illness on the Job
Weekly Safety Meetings
Weekly Walk-around Safety Inspections
General Safety Rules
Personal Protective Equipment
Fire Prevention and Protection
Hazard Communication Program
Material Safety Data Sheets and Chemical Inventory
Fall Protection Policy
Job Hazard Analysis
Disciplinary Action Policy
Heat-Related Illness Program
If Contractor’s scope includes any of the following elements, they
Required?
Submitted?
must submit additional information as detailed in the Appendix to this
Yes No Yes
No
Evaluation Sheet Sections 1 through 20
1. Work at a height greater than 10 feet?
2. Work from Ladders
3. Work from Scaffold
4. Work from Scissors Lift or Boom Lifts
5. Trenching/Excavation
6. Cranes and Rigging
7. Steel Erection
8. Demolition
9. Disturbance of Lead-Containing Substances
10.Asbestos Abatement
11.Use of Powder Actuated Tools
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12.Use of Fork Lifts
13.Entry to Confined Spaces
14.Removal of contaminated soils considered hazardous waste
15.Traffic Control
16.Work on energized conductors
17.Concrete and Masonry Work
18.Use of electrical equipment, including plug and cord tools
19.Noise Exposure above 85 dBA
20.Exposure to Respiratory Hazards, including:
Concrete grinding, chipping, cutting
Application of spray-on material, including paint
Application of adhesives or sealant
Welding/Torch Cutting
Sanding Drywall
Use of combustion engines indoors
Other Hazardous Chemicals?
Included in Plan?
YES
NO
1. Work at height greater than 10 feet
Contractor must provide Fall Protection Work Plan, which includes provisions
for:
Identifying all fall hazards in the work area.
Identifying the method of fall arrest or fall restraint to be provided.
Specifying the correct procedures for the assembly, maintenance, inspection, and disassembly of the fall protection system to be used.
Specifying the correct procedures for the handling, storage, and securing of tools and materials.
Identifying the method of providing overhead protection for the workers who may be in, or pass through the area below the work site.
Specifying the method for prompt, safe removal of injured workers.
Ensuring that employees are trained and instructed in the items described in the fall protection work plan.
The use of a Fall Protection Monitor System is not permitted on Exxel
Pacific projects.
Included in Plan?
YES
NO
2. Work from Ladders
Contractor safety plan must address:
Ladder inspection, condition, and repair
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Ladder storage and transport
Ladder set-up and use
Employee training
Included in Plan?
YES
NO
3. Work From Scaffolding
Contractor Safety Plan must include provisions for:
Design of scaffold by named qualified person(s)
Erection of scaffolding under the supervision of qualified, competent
person(s)
Inspection of scaffold
Use of scaffolding by trained personnel
Training
Access to scaffolds
Fall Protection considerations during assembly/disassembly and use of
scaffolding
Use of toe boards or other falling object protection
Included in Plan?
YES
NO
4. Work from Scissors Lifts or Boom Lifts
Contractor Safety Plan must include provisions for:
Inspection, testing and maintenance of equipment
Operator training and authorization requirements
Pre-use operator survey for area hazards such as loose terrain, dropoffs, ditches, overhead obstructions, etc.
Fall Protection
Included in Plan?
YES
NO
5. Trenching / Excavation
Contractor Safety Plan must include provisions for:
Avoiding underground installations
Providing means of access and egress from excavations
Protection of employees from cave-ins
Protection from falling objects or surface encumbrances
Daily inspection of excavations by a competent person
Maintaining the stability of adjacent structures (if present)
Included in Plan?
YES
NO
6. Cranes and Rigging
Contractor Safety Plan must include provisions for:
Operating within load ratings
Control of overhead loads and use of tag lines
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Crane certifications and inspections
Protecting swing radius
Avoiding overhead utilities and obstructions
Operator qualifications
Rigging Inspections
Rigging use and rigger qualifications
Included in Plan?
YES
NO
7. Steel Erection
Contractor Safety Plan must include provisions for:
Development of erection plan
Rigging of loads
Maintaining structural stability during erection
Landing metal decking and other loads
Fall protection -The use of a Fall Protection Monitor System is not
permitted on Exxel Pacific projects.
Falling object protection
Training for erectors
Included in Plan?
YES
NO
8. Demolition
Contractor Safety Plan must include provisions for:
Demolition survey conducted by named competent person
Copy of the survey report to be maintained on site
Evaluating site for the presence of asbestos and other hazardous materials or chemicals
Control of utilities during demolition
Protection from falling materials
Dust control
Respiratory hazard evaluation and protection
Included in Plan?
YES
NO
9. Disturbance Abatement for Lead
Contractor Safety Plan must include provisions for:
Conducting Initial Exposure Assessments
Protecting employees during Initial Exposure Assessments
Evaluating Initial Exposure Assessment to determine the need for developing a Worker Lead Protection Plan
* For assistance reviewing Worker Lead Protection Plan, contact Exxel
Pacific Safety Director.
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Included in Plan?
YES
NO
10.Asbestos Abatement
Contractor Safety Plan must include provisions for:
Abatement to be performed by Licensed Asbestos Contractor
Asbestos Worker Training and Certification
Asbestos Supervisor training and certification
Providing written notification to L&I of abatement project
Exposure assessments and monitoring
Communication of asbestos hazards to other persons on site
Establishing regulated areas
Establishing work practices and engineering control methods, including
wetting, HEPA vacuuming, glove bagging, local exhaust ventilation,
and negative pressure enclosures
Respiratory protection
Collection and disposal of asbestos containing material
Included in Plan?
YES
NO
11.Powder Actuated Tools
Contractor Safety Plan must include provisions for:
Operator training and qualifications
Personal Protective Equipment
Care and custody of powder actuated tools and loads
Posting of hazard warning signs
Avoiding use of soft, thin or easily penetrated materials
Included in Plan?
YES
NO
12.Use of Fork Lifts
Contractor Safety Plan must include provisions for:
Inspection, testing and maintenance of equipment
Operator training and authorization requirements
Pre-use operator survey for area hazards such as loose terrain, drop-offs,
ditches, overhead obstructions, etc.
Included in Plan?
YES
NO
13.Entry to Confined Spaces
Contractor Safety Plan must include provisions for:
Identifying and controlling confined spaces
Permit entry procedures
Employee training
* For assistance reviewing permit required confined space entry program, contact Exxel Pacific Safety Director
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14.Removal of Contaminated Soils considered hazardous waste
Included in Plan?
YES
NO
Contractor Safety Plan must include provisions for:
Conducting preliminary site evaluation to assess hazards
Developing a written HASP (Health and Safety Plan) for hazardous
waste operations
* For assistance reviewing the HASP, contact Exxel Pacific Safety Director
Included in Plan?
YES
NO
15.Traffic Control
Contractor Safety Plan must include provisions for:
Developing temporary traffic control plans
Orientation of traffic personnel and flaggers to traffic control plan
Use of certified flaggers
Use of warning signs and barriers
Included in Plan?
YES
NO
16.Work on Energized Conductors
Contractor Safety Plan must include provisions for:
Lockout / tag out policy
Specific lockout / tag out procedures
Employee training
Included in Plan?
YES
NO
17.Concrete and Masonry Work
Contractor Safety Plan must include provisions for:
Protection from impalement hazards
Safety considerations specific to the concrete delivery method (concrete
pump, bucket)
Personal protective equipment and first aid supplies to protect from
caustic burns
Post-tensioning operation
Respiratory protection for concrete finishers
Establishing limited access zones for masonry wall construction
Bracing of masonry walls
18.Use of electrical equipment, including plug and cord tools
Contractor Safety Plan must include provisions for:
Inspection of cords, cables and connectors
Ground fault protection
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Included in Plan?
YES
NO
Grounding
Protecting cords from damage
Included in Plan?
YES
NO
19.Exposure to noise above 85 dBA
Contractor Safety Plan must include provisions for:
Identifying and controlling noise sources
Noise monitoring
Hearing Protection
Employee Training
Included in Plan?
YES
NO
20.Exposure to Respiratory Hazards
Contractor Safety Plan must include provisions for:
Identifying and evaluating respiratory hazards
Material Safety Data Sheets for chemical products
Methods for controlling employee exposure
Methods for controlling fugitive emissions
Written Respirator Program
* For assistance evaluating written respiratory protection program, contact the Exxel Pacific Safety Director
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13
JOB HAZARD ANALYSIS & PRE-TASK PLANNING
13.1 INTRODUCTION
Many construction accidents and injuries happen because construction crafts are not trained in proper
job safety procedures. One of the best ways to prevent construction accidents and injuries is to develop
and implement Job Hazard Analysis (JHA) and Pre-task Planning (PTP) programs as part of a company’s overall project safety and health program. The JHAs/PTPs helps prevent accidents and injuries,
by identifying workplace hazards associated with a job or task, and the effective controls (eliminate or
minimize) for the hazards. The purpose of this chapter is to provide guidance to construction contractors to develop a new or improve their existing JHAs/PTPs programs based on industry best practices.
13.2 DIFFERENCES BETWEEN JHAs AND PTPs
Even though both JHAs and PTPs are safety planning and communication tools, there are some
subtle differences between them as listed in Table 13-1.
Table 13-1: Major Differences between JHAs and PTPs
Job Hazard Analysis (JHA)
Pre-task Planning (PTP)
JHA is used to analyze a “job,” normally a larger PTP, on the other hand, involves the analysis of a
scope of work that involves more than one task. single “task,” which is a specific section of work
done within the broader scope of work.
Overall project JHAs are typically completed by PTPs are completed by the general contractor (for
the general contractor’s project supervision with the self-performed scope) or subcontractor crew
input from the safety department before the start led by their foreman, for every task daily, at the
of the project. Subcontractors and their sub-tier start of each work shift or whenever the crew’s
subcontractors will be responsible for developing task or work conditions changes. This increased
their JHAs before mobilization on the site.
involvement of crews in the safety process is one
of the major benefits of the PTP processes.
The JHA evaluates hazards associated with a This on-site assessment tool evaluates hazards asparticular broader job scope to determine the as- sociated with a particular task to identify methsociated project safety requirements and methods ods to control potential exposures. The PTP typto control potential exposures.
ically includes hazards and safety precautions
identified in the JHA.
JHAs are normally submitted along with the PTPs are submitted to the project supervision or
site-specific safety plan for review and approval the project safety personnel, on the day of the
by the upper tier contractor.
task.
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Example - A JHA will be required for overall Example - A PTP will be required to complete a
concrete pours on slab-on-metal deck for a high- small section of the concrete pours on a slab-onrise office building.
metal deck for a section of the deck on just one
floor, which will be completed on a particular day.
JHAs serves as a reference document during the PTPs also serves as a reference document during
accident investigation process.
the accident investigation process.
Even though the basic concept is the same, com- Even though the underlying concept is the same,
panies have different names for JHAs such as companies have different names for PTPs such as
Job Safety Analysis (JSA), Job Task Assignment Task Hazard Analysis (THA), Task Safety Anal(JTA), and Total Safety Task Instructions (TSTI). ysis (TSA), Pre-job Safety Instruction (PSI), Pretask Briefing (PTB), etc.
13.3 JOB HAZARD ANALYSIS (JHA) PROGRAM BEST PRACTICES
The purpose of this section is to provide guidance to construction contractors to develop a new or
improve their existing JHAs programs based on industry best practices.
Determine the jobs within your company to be analyzed. JHAs should be first developed for jobs
with the highest risk. Risk is defined as the product of “severity” and “probability” of accidents
and injuries (see Table 13-1). High risk or hazard jobs include crane and rigging, demolition, confined space, public protection, etc. Other jobs to consider include any new job scope, jobs involving
new equipment (e.g., a new model of crane or excavator), jobs infrequently performed, and routine
jobs that require deviation from documented procedures.
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Table 13-1: Example of a Risk Assessment Code (RAC)
(Used by permission from NOVA Group Inc.)
Severity
Catastrophic
Critical
Marginal
Negligible
Probability
Frequent Likely
E
E
E
H
H
M
M
L
Occasional
H
H
M
L
Seldom
H
M
L
L
Unlikely
M
L
L
L
Step 1: Review each “Hazard” with identified safety “Controls” and determine RAC (See above)
“Probability” is the likelihood to cause an incident, near
miss, or accident and identified as Frequent, Likely, Occasional, Seldom or Unlikely.
“Severity” is the outcome/degree if an incident, near miss,
or accident did occur and identified as Catastrophic, Critical, Marginal, or Negligible
H = High Risk
Step 2: Identify the RAC (Probability/Severity) as E, H,
M, or L for each “Hazard” on JHA. Annotate the overall
highest RAC at the top of AHA.
L = Low Risk
141
RAC Chart
E = Extremely High Risk
M = Moderate Risk
Table 13-2: Example of Hazard Analysis for General Safety for weather exposure using RAC
(Used by permission from NOVA Group Inc.)
Job Steps
Hazards
General Safety
Exposure to Cold or
Requirements all Steps Hot Weather
Controls
RAC
Minimum Personal Protective Equipment L
Dress:
• Long Pants
• Shirts with Sleeves
• Hardhat
• Covered Shoes (Steel Toe Preferred)
• Safety Glasses (Potential Eye Hazard
Areas)
Weather:
• Wear appropriate clothing for the
hot or cold weather.
(List specific clothing or refer to Company quick sheet, SOPs, plan, etc. for
specific details)
• Sun block
• Lip balm
Dehydration:
• Drink at least ½ liter of water an
hour.
Dehydration
• Refer to Company quick sheet,
SOPs, plan, etc. for specific details on
heat stress signs and symptoms.
The JHA is typically documented with a JHA worksheet. The worksheet usually consists of three
columns:
1. Break down the job sequence of individual steps,
2. Identify the hazards associated with each step, and
3. Develop control measures for each hazards including applicable regulatory, and project-specific safety and health requirements associated with each hazard.
142
Job Sequence: Select an individual who is experienced and knowledgeable about the job to ensure “all” the steps involved with the job is identified. For example, when developing a JHA for
tower-crane operations, choose an experienced tower crane operator and rigger who can provide
valuable input to the entire process. There is no scientific data on what is the optimum number of
“steps” for each JHA, but limiting it to ten steps would make it efficient.
Hazards: During the hazard identification phase it is critical to identify all actual and potential
hazards, which by itself or interaction with other factors can cause harm. It is best practice to
receive feedback from superintendents, general foreman, foreman, employees, safety professionals
within the company (and outside the company), and trade associations. Review of your company
accident data, industry accident data for that particular job or the trade that performs the job,
insurance claims frequency and severity data for that industry classification, can also shed some
light into hazard identification. For example, the National Institute of Occupational Safety and
Health (NIOSH)’s Fatality Assessment and Control Evaluation (FACE) program identifies various
“factors” that contribute to fatal injuries and also provides comprehensive “recommendations” for
preventing similar deaths. What are some of the most common hazards encountered on construction
sites?
Inadequate Access
Caught In/Between
Inhalation Hazard
Chemical Burns
Ladders
Chemical Spill
Compressed Gases
Lockout/Tagout
Manual Lifting
Confined Spaces
Mobile Equipment
Crane
Particles in Eyes
Electrical Shock
Poor Housekeeping
Elevated Work
Radiations
Explosion
Rigging
Falls from Elevations/Same level
Fire
Scaffolding
Sharp Objects
Hazardous Chemicals
Struck By
Heat Stress
High Noise Levels
Thermal Burns
Controls: Similar to the hazard identification phase it will be beneficial to receive feedback from
different stakeholders to identify control measures. As with any hazard, the first control that should
be considered is engineering controls followed by administrative controls and Personal Protective
Equipment (PPE) being the last option.
o Engineering controls involves, to the extent feasible, to redesign the work environment
and the job itself to eliminate hazards or reduce exposure to hazards. Engineering controls should be the first option in dealing with any hazards. The following principles as
recommended by the Occupational Safety and Health Administration (OSHA) should be
followed: (a) if feasible, design the facility, equipment, or process to remove the hazard or
substitute something that is not hazardous, (b) if removal is not feasible, enclose the hazard
to prevent exposure in normal operations, and (c) where complete enclosure is not feasible,
143
establish barriers or local ventilation to reduce exposure to the hazard in normal operations.
o Administrative controls involve altering the way work is performed such as job rotations,
etc.
o PPE introduces a barrier between the worker and the hazard, should be the last control
method.
In addition, determine if there are other options available to perform the job. For example, make
changes to concrete block cutting procedures so that they are cutting using wet methods that eliminate silica dust versus using dry cutting methods that generate dust and the use of respirators.
Continuous Improvement: After successful development and implementation of the JHAs, in order
to be effective, the JHAs should be reviewed periodically and updated as needed as part of the
program’s continuous improvement process based on: (1) lessons learned from new accidents and
injuries that requires revision of JHA, (2) feedback from workers and supervisors on particular job
procedures, hazards, and control measures.
Training and Communication: How will the current and new workers get trained on the JHAs? How
will changes to JHAs be communicated to the workers? How and who will the workers provide
feedback with regards to the JHAs?
Example JHA: An example JHA form is presented in Exhibit 13-1. Contractors can use this as a
template to develop their own JHA form that suits their company’s needs.
13.4 PRE-TASK PLAN (PTP) PROGRAM BEST PRACTICES
The purpose of this section is to provide guidance to construction contractors to develop a new or
improve their existing PTPs programs based on industry best practices.
A written policy in place regarding the PTP procedures to involve construction workers in this
important safety process.
The PTP meeting should be conducted, at a minimum, prior to the start of each workday, prior
to any new work activity or whenever the current task or work conditions change. Even though
a crew might perform the same task every day, due to the changing nature of construction
activities or crew membership, it is still necessary to complete a new PTP at the beginning of
each day.
The crew foreman should lead a PTP session. The crew foreman will typically identify the task
and the crew as a team develops a plan.
The PTP meeting should be held at the location where the task is to be performed. See Figure
13-1, which shows a crew performing PTP.
144
Figure 13-1: Construction crew performing PTP (Picture Courtesy Guy F. Atkinson Construction)
All crew members should participate in pre-task planning and should sign the completed PTP
(see Figure 13-2).
The critical steps involved in a PTP process: (1) work area assessment, (2) breakdown of tasks
into separate steps, (3) identification of hazards associated with each step, (4) identification of
control measures to minimize or eliminate the hazard, and (5) crew sign-off. Ensure the crew
has the applicable JHA for the task. The PTP should include hazards and precautions identified in applicable JHA.
145
Figure 13-2 Safety Task Assignment before work (Picture Courtesy Hensel Phelps Construction)
All project personnel should be trained on how to prepare an effective PTP. This training can
be part of the new employee orientation or a stand-alone PTP training. The crew foreman
should receive additional training on how to conduct an effective PTP session, and also how
to document the PTP. Consideration should be given to non-English speaking workers when
not only delivering the training but also during the PTP process itself. It can include providing
training and related documentation in another language or providing interpreters.
It is common to use pre-task planning forms that document the results of the meetings.
οο Pocket card vs. Regular A4 sheet: The format of the form varies from company to company. Some companies have used a trifold PTP that will fit in a safety vest pocket while
some firms have used a PTP printed on an A4 sheet.
οο Open-ended vs. Close-ended: A typical PTP worksheet consists of crew demographics
(project, work description, location, supervisors, date, contractor name, and crew signoff) and an open-ended three columns (steps, hazards with each steps, and controls
for each hazards). Some companies have developed PTPs with a combination of both
open-ended like above and have included close-ended questions to serve a reminder for
the crew such as, “Is air monitoring required?” “Are there any special permits required
to complete this task?”, etc.
146
A copy of the completed PTP should be readily available near the work area where crew members have the knowledge of its location. The original PTP should be submitted to the project
supervision for review and feedback.
A PTP program should also include a formal audit process in place to confirm the quality of
hazard recognition. All PTPs should be reviewed by the Project Superintendent or designee,
and provide feedback regarding the PTP contents. The review and following field audits should
identify potential inadequacies:
οο
οο
οο
οο
οο
οο
οο
Failure to identify all the steps that are needed to complete the task,
Failure to identify the potential hazards associated with each step,
Failure to identify the control measures for each hazard,
Failure to review the PTP with crew members (missing signatures),
Failure to post PTP in the work area,
Failure to follow the PTP, and
Failure to stop work when there is a change of conditions and make appropriate changes to the PTP.
As part of a continuous improvement process and to capture lessons learned, a good pre-task
plan should include a post-task comment section. The post-comment section will provide the
foreman and his crew a place to include lessons learned from the task such as new hazards encountered, things that went well, etc.
Exhibit 13-3 through 13.5 presents a few examples of PTP worksheet. Contractors can use this
as a template to develop their own PTP form that suits their company’s needs.
Note: The example PTPs and JHAs provided in the exhibits are only included as an example, and the
users should be aware that they may reference safety regulations depending on the company’s regulatory
jurisdiction. It is the user’s responsibility to ensure that they adapt the best practices for their jurisdiction
and comply with all applicable local, state, and federal regulations affecting their workplace.
147
Exhibit 13-1: Example Job Hazard Analysis
(Used by permission from GLY Construction)
JOB HAZARD ANALYSIS | JOB # XXXXXX
GLY CONSTRUCTION
Job #:
Write-up Date:
Task Date:
Company:
Area of Work:
Page x of x
Author:
Task to be Accomplished:
Start Date:
End Date:
Crew Size:
WORK EVALUATION
CIRCLE ANY THAT ARE
REQUIRED
CIRCLE ONE
Does this task require special training?
Yes
No
Eye/Face PPE
Signage
Should Project superintendent be involved in this planning?
Yes
No
Hand/Arm PPE
Open Flame
Do you need to review an MSDS to proceed?
Yes
No
Hearing PPE
Extinguishers
Will weather conditions effect the safe completion of the task?
Yes
No
Fall Pro. PPE
Specialized Tools
Are enough workers assigned to this task to complete it safely?
Yes
No
Respirator
Rescue System
Does this task require special permits / procedures?
Yes
No
Barricades
Ladders
Does this task require disassembly of systems or equipment?
Yes
No
Forklift
Man Lift Required
Are there shop drawings needed to do the work?
Yes
No
Other:
Are materials & tools to do the job on hand?
Yes
No
Other:
Has the planning of the work involved walking the location of
the work?
Yes
No
Other:
Are there overhead hazards?
Yes
No
Other:
Are any employees new to the work involved?
Yes
No
Other:
Are barricading required?
Yes
No
Has the JHA been reviewed with the crew doing the work?
Yes
No
SEQUENCE OF ACTITIVES
HAZARDS IDENTIFIED
HAZARD PRECAUTIONS
148
Exhibit 13-1: Example Job Hazard Analysis Contd.
(Used by permission from GLY Construction)
SEQUENCE OF ACTIVITIES
HAZARDS IDENTIFIED
HAZARD PRECAUTIONS
HAZARDS IDENTIFIED
HAZARD PRECAUTIONS
LIST OF TOOLS REQUIRED:
Foreman’s Signature
Phone
Crew Signatures:
1
6
2
7
3
8
4
9
5
10
IF WORK CONDITIONS CHANGE, STOP WORK. A NEW JHA SHOULD BE FILLED OUT.
149
Exhibit 13-2: Example Completed Demolition Work Job Hazard Analysis
(Used by permission from Exxel Pacific)
Note: This best practice tool is only included as an example, and the users should be aware that the it may
reference safety regulations depending on the company’s regulatory jurisdiction. It is the user’s responsibility to ensure that they adapt the best practices provided in this example JHA for their jurisdiction and
comply with all applicable local, state, and federal regulations affecting their workplace.
Construction Phase: Demolition
Contractor
Project:
Location:
Contractor Number:
Estimated Start Date:
Operation:
Hazard:
1. Selective Interior Demolition 1.1 Construction employees
and non-job related employees
entering removal area
1.2 Contact with existing
utilities
1.3 Dust Inhalation
1. Interior Selective Demolition 1.4 Electrocution
(Cont.)
150
Action to be taken:
1.1.2 Flag and post perimeter
with “danger” signs and
“Danger” tape
1.2.1 Owner, General
Contractor, and Electrical Sub
will review existing construction
plans to locate existing utilities
and their control points
1.2.2 Electrical Subcontractor
to lock, tag and try out control
points
1.2.3 Foreman will review
with all employees existing
hazardous chemicals and
systems that must remain
operational and the process
and care to be used to prevent
damaging any existing system.
1.3.1 Employees performing
this GWB demo will wear a
dust mask
1.4.1 Utilize an assured
grounding or ground fault
circuit interrupter program
1.4.2 All electrical tools and
cords used in this operation will
be inspected daily prior to use
Operation:
Hazard:
1.5 Flying debris/Contact with
power tools/Hearing Loss
1.6 Back injuries
1.7 Ladders
Action to be taken:
1.4.3 Cords will be kept clear
of falling debris and debris cart
paths
1.4.4 Electrical tools will not
be lowered down from ladders
or scaffolding by the cord
1.5.1 Employees will wear hard
hats, ear plugs, safety glasses,
face shields, gloves, and work
boots while performing this
operation
1.6.1 Employees will be
instructed in proper body
mechanics: A. Keep back
Straight B. Bend with your
knees (Not Your Back) C. Lift
with your legs (Not Your Back)
D. When twisting, pivot your
feet
1.6.2 Demo debris will be
cut into pieces small enough
for two people to load into
dumpster
1.6.3 When loading debris into
dumpster use the buddy system
for the large pieces
1.7.1 Inspect ladder for defects
before each use
1.7.2 Never use a ladder in a
horizontal position as a walkplank or scaffold
1.7.3 If a ladder is too short,
get a taller ladder
1.7.4 Hold side rails with both
hands when going up or down
a ladder. Material or equipment
will be raised or lowered with a
rope
1. Interior Selective Demolition
(Cont.)
151
Operation:
Hazard:
1. Selective Interior Demolition 1.7 Ladders (Cont.)
(Cont.)
152
Action to be taken:
1.7.5 Face the ladder when
climbing up or down and never
slide down a ladder
1.7.6 Never climb higher than
the second step from the top of
stepladders
1.7.7 Observe all warning signs
on ladders
1.7.8 Ladders will be
maintained free of oil, grease
and other slipping hazards
1.7.9 Ladders will not be
loaded beyond the maximum
intended load for which they
were built, or beyond their
manufacturer’s rated capacity
1.7.10 The area around the top
and bottom of the ladders will
be kept clear
1.7.11 Ladders placed in
any location where they
can be struck by workplace
activities or traffic, such as
in passageways, doorways, or
driveways, will have “Caution “
tape across the opening to keep
the activities or traffic on the
other side, or use a spotter
1.7.12 While working on
ladders they will not be moved
or shifted
1.7.13 Cross bracing on the
rear section of stepladders will
not be used for climbing unless
the ladders are designed and
provided with steps for climbing
on both front and rear sections
1.7.14 Employees will not
climb ladders while carrying
tools or materials
Operation:
Hazard:
1.8 Scaffolding
Action to be taken:
1.7.15 Step ladders will be fully
extended with the spreader bars
locked in place before climbing
1.8.1 No scaffold will be erected, moved, dismantled, or
altered except under the supervision of the project competent
person.
1.8.2 The Scaffold Competent
person will inspect the scaffold
daily before use.
1.8.3 Guardrails and toe boards
will be installed on all open
sides and ends of platforms
more than 4’ above the ground
or floor.
1.8.4 Debris will be removed
off the scaffold platform as it
accumulates
1.8.5 An access ladder or equivalent safe access will be provided.
1.8.6 Slippery conditions on
scaffolds will be eliminated as
soon as they occur.
1.8.7 Employees will not ride
on scaffolding while it is being
moved
1.9.1 Competent person will
enter all fall hazard areas onto
company fall protection work
plan such as: Scaffolding, leading edges, steel erection.
1. Interior Selective Demolition 1.9 Falls
(Cont)
153
Operation:
Hazard:
1.10 House Keeping
154
Action to be taken:
1.9.2 Competent person will
enter means of protection from
fall hazards onto company fall
protection work plan such as:
Standard Guardrails and toe
boards, catenary line secured to
the structure, full body harness
and lanyard.
1.9.3 Competent person will
train all employees to the fall
protection work plan and the
means of protection. Employees are required to sign-off on
the training.
1.10.1 Debris will be kept out
of walking paths
1.10.2 Debris will be thrown
away daily
Exhibit 13-3: Example Pre-task Plan/Job Hazard Analysis (Used by permission from Andgar Corporation)
155
156
Exhibit 13-3: Example Pre-task Plan/Job Hazard Analysis Contd.
(Used by permission from Andgar Corporation)
Exhibit 13-4: Example Pre-task Plan
(Used by permission from Balfour Beatty Construction)
157
Exhibit 13-5: Example Pre-Job Safety Instruction Form
(Used by permission from PCL Construction Services, Inc.)
158
Exhibit 13-5: Example Pre-Job Safety Instruction Form Contd.
(Used by permission from PCL Construction Services, Inc.)
159
160
14
SAFETY TRAINING
14.1 INTRODUCTION
How many times have we heard the lack of “common sense” as a reason for accidents? There is no
“common-sense” in safety, either workers have the knowledge and skill to succeed or they do not.
An effective safety training will increase worker competence and knowledge to identify and control
hazards, resulting in fewer job site accidents. Safety training should be an integral part of every Site
Specific Safety Plan (SSSP). This chapter provides guidelines for developing a new or improving an
existing site-specific training program.
14.2 IDENTIFICATION OF TRAINING NEEDS
The project supervision and a representative from the safety department should review the following
information, and develop a site-specific training matrix. A training matrix is a tool that lists the training requirements for all site personnel including workers, supervisors, and managers.
Regulatory training programs (required by federal, state, or local laws such as DOSH, federal
OSHA, fire department, EPA, DOT, etc.)
Project-specific contract requirements (e.g., U.S. Army Corps of Engineers EMS 385)
Site-specific hazards (e.g., tunnel safety, boring machine safety)
Company’s accident, audit, and inspections history from similar projects
Manufacturer requirements for equipment and tools use
For example, the Washington State Department of Labor & Industries has summarized the various
rules requiring training on their website.1
14.3 TRAINING REQUIREMENTS IN CONTRACTS
The general contractor should contractually require each subcontractor and tiers to document hazard-specific safety training requirements by job classification, and include it in their SSSP. For example,
develop a matrix for different tradespeople like plumbers, fitters, etc. In addition, require written training records available for audit on the site. Use the contracts to remind and require the subcontractors
to provide bilingual supervisors who must be on site any time non-english speakers are on the jobsite.
1 Washington State Department of Labor and Industries, Division of Occupational Safety and Health (DOSH). Rules Requiring Training.
http://www.lni.wa.gov/SAFETY/TRAININGPREVENTION/PROGRAMS/REQUIREDTRAINING.ASP. (Accessed January 31, 2015).
161
14.4 TRAINING DEVELOPMENT AND DELIVERY BEST PRACTICES
A general review of training “best practices,” reveals four characteristics that sound training programs
have in common. The best training programs are accurate, credible, clear and practical.2 OSHA has developed voluntary training guidelines for employers to provide effective training to employees. OSHA’s
training guidelines follow a model that consists of:3
Determining if training is needed
Identifying training needs
Identifying goals and objectives
Developing learning activities
Conducting the training
Evaluating program effectiveness
Improving the program
More guidance on training development best practices can be found in American National Standards
Institute (ANSI)/ American Society of Safety Engineers (ASSE) Criteria for Accepted Practices in
Safety, Health, and Environmental Training, ANSI/ASSE Z490.1-2009. This standard establishes criteria for safety, health and environmental training programs, including development, delivery, evaluation and program management.4
Safety trainers should understand the adult learning process. OSHA provides one of the best guidance
on adult learning techniques. The following are the basic principles of how adults learn, which is directly applicable to safety and health training programs:5
Adults are voluntary learners – Most adults learn because they want to. They learn best when
they have decided they need to learn for a particular reason.
Adults learn needed the information quickly – Adults need to see that the subject matter and
the methods are relevant to their lives and to what they want to learn. They have a right to know
why the information is important to them.
Adults come with a good deal of life experience that needs to be acknowledged – They should
be encouraged to share their experiences and knowledge.
Adults need to be treated with respect – They resent an instructor who talks down to them or
ignores their ideas and concerns.
Adults learn more when they participate in the learning process – Adult need to be involved and
actively participating in class.
2 Occupational Safety and Health Administration (OSHA). Best Practices for the Development, Delivery, and Evaluation of Susan Harwood Training
Grants. https://www.osha.gov/dte/sharwood/best-practices.html. (Accessed January 31, 2015)
3 Occupational Safety and Health Administration (OSHA). Training Requirements in OSHA Standards and Training Guidelines.
www.osha.gov/Publications/2254.html. (Accessed January 31, 2015)
4 American Society of Safety Engineers (ASSE). ANSI/ASSE Z490.1-2009 Criteria for Accepted Practices in Safety, Health, & Environmental
Training. www.asse.org.
5 Occupational Safety and Health Administration (OSHA). Best Practices for the Development, Delivery, and Evaluation of Susan Harwood Training
5 Grants. https://www.osha.gov/dte/sharwood/best-practices.html. (Accessed January 31, 2015)
162
Adults learn best by doing – Adults need to “try-on” and practice what they are learning. They
will retain more information when they use and practice their knowledge and skills in class.
Adults need to know where they are heading – Learners need “route maps” with clear objectives. Each new piece of information needs to build logically on the last.
Adults learn best when new information is reinforced and repeated – Adults need to hear the
concepts more than once. They need time to master new knowledge, skills, and attitudes. They
need to have this mastery reinforced at every opportunity.
Adults learn better when information is presented in different ways – They will learn better
when an instructor uses a variety of teaching techniques.
14.5 TRAINING MATRIX
Each subcontractor should be required to maintain an employee training matrix by reviewing their
training needs based on project requirements. A matrix is a tool that will allow employers to ensure
their employee training is current. Table 14-1 shows an example of an employee training matrix. The
project should designate an individual whose job is to ensure employee training and safety meeting
attendance records are complete at the end of each session. This individual should also be in charge
of updating the training matrix to reflect current qualifications and training (also see Exhibit 14-1, for
example, project-specific training matrix).
Table 14-1: Example Employee Training Matrix by Contractors showing employee name role, training
type, and date of last training*
Supervisor (S)/
Employee Name
NEO** First Aid Leadership OSHA-10 OSHA-30
Worker (W)
A
W
12/12/14 10/12/14
NA
12/12/14
NA
B
S
12/14/14 10/14/14
12/14/14
NA
01/12/14
C
W
12/14/14 10/14/14
NA
12/12/14
NA
D
W
12/15/14 10/15/14
NA
12/12/14
NA
E
W
12/15/14 10/15/14
NA
12/12/14
NA
F
S
12/15/14 10/15/14
12/15/14
NA
02/12/14
* For some certifications that have time limits either state the due date or its time limit from last training to remind that they are not expired. First Aid
is two years; Forklift is three years, etc.
**New Employee Orientation (NEO)
14.6 IMPLEMENT IDENTIFIED TRAINING
The following sections provides common training delivered by construction contractors and its associated best practices.
14.6.1 New Employee Orientation (NEO)
Workers new to the jobsite, regardless of their work experience, are at higher levels of risk of injuries
and fatalities. Hence, the NEO is the most critical element of the site training program. Some best
practices for NEO include:
163
Identify who should attend the NEO – Does the owner, visitors, vendors, and suppliers require
NEO? NEO training should be administered to all new employees prior to their initial work
assignment. New workers and workers returning to the site after a significant absence, should
be oriented by their trainer for the site logistics and the new job hazards.
Management participation in NEOs – The NEO is the first opportunity to show the employee
that the project is committed to worker safety and well-being. Hence, the project manager or
owner representative should attend the NEO for a few minutes to personally welcome the workers to the site and deliver their safety policy. For example, in a pharmaceutical manufacturing
facility project that will produce life-saving cancer treatment drugs, the owner representative
participated in all NEOs and communicated the purpose of the facility. The message increased
worker motivation by making them realize that they are part of a special project.
Use of NEO checklists – The project should use an NEO checklist as an aid to ensure all site-specific safety policies has been presented to the employee. The checklist should have an NEO acknowledgment section that should be signed by all the employees who completed the NEO. The
NEO checklist should be archived as part of the project safety records (see Exhibit 14-2 for an
example checklist).
Address site-specific topics – Work activities and site conditions and associated hazards vary
from site to site. In addition, each contractor has certain policies that are above and beyond
OSHA standards and regulations. Make sure majority of the NEO focuses on site-specific issues such as start time, break time, lunch time, smoking policies, toilet locations, parking, and
any restrictions. For example:
οο Are workers allowed to carry their food or beverage into the building?
οο What special training is needed since the site is close to a light rail track?
οο What are the challenges associated with working on a university campus, hospital campus, etc.?
Change the content periodically – How many contractors use the same NEO video from the 90s?
Some workers, for example, fire caulking contractors work on more than ten sites any given
month.
Since large contractors have multiple job sites in the same geographical location, these workers
are listening to or watching the same video every time. Try to be fluent with the training tools
so that the training does not lose its effectiveness.
Construction high hazard tasks6 – In Washington State, several employees die each month from
injuries or illnesses related to their work. Many others are hospitalized, sometimes with injuries
or illnesses that will persist for a lifetime. The L&I website publishes information regarding
these fatalities and injuries, and their causes. Spend more time on serious exposures on that site
that could lead to fatalities or serious injuries.
6 Washington State Department of Labor and Industries, Division of Occupational Safety and Health (DOSH).
http://www.lni.wa.gov/Safety/TrainingPrevention/FatalitiesInjuries/fatalities.asp. (Accessed January 31, 2015).
164
Fatalities and Injuries.
Walking Tour – Some companies have used a walking tour of the site to point out hazards.
Use Modern Tools – Use of tools such as Building Information Modeling (BIM) to communicate site-specific hazards can help workers understand the environment better and faster.
Questions – Provide an opportunity to ask questions concerning the site safety and assigned
work.
Assess the employee knowledge – Administer a test at the end of the orientation, and follow-up
with remedial training if needed.
Obtain employee commitment – In addition to the acknowledgment slip, designating a wall
space in the trailer as an area to express worker commitment is another best practice. The wall
should state the project safety commitment and goals while asking the workers to join the efforts by signing at the bottom of the wall.
Issue identification to verify NEO completion – Establish a means to identify employees who
have completed the NEO in the form of a badge or hard hat sticker.
Provide trade-specific training – In addition, to the general site orientation general contractors should require subcontractors to deliver a short, but adequate supplemental trade-specific
training to their workers. This training should be documented in writing and filed on the site.
Assign a mentor or buddy – Require subcontractors to create a “buddy” system for “new”
employees, and assign them to work with a journeyman as a work partner. Some companies
have used a special colored hard hat for identification of new employees for at least a 6-month
period.
165
Figure 14-1: New Employee Orientation (Picture Courtesy of Turner Construction Company)
14.6.2 Pre-task safety planning (PTP) & Stretch and Flex (SF) meetings
The foreman typically conducts the daily pre-task safety planning along with stretch and flex during
their meetings. The meeting is normally held at the start of the work shift to discuss safety and work
tasks for that day. If required by the project, SF exercises should also be conducted during these meetings. It is used as a daily “safety training” to ensure the workers are set up for success. These meetings
are considered the “first line of defense” against accidents. It allows the foreman to ensure all crew
members have been trained in safe work practices and procedures for their assigned tasks. If a worker
is not trained, the foreman should train the employee before assigning the task. More information on
PTP is provided in Chapter 13 of this handbook.
166
Figure 14-2: Stretch and Flex Meeting (Picture Courtesy BNBuilders)
14.6.3 Toolbox talks or Tailgate Talks
The weekly toolbox talk is also conducted by the foreman (one crew) or general foreman (multiple
crews) at the start of the work week, usually Monday mornings. Contractors should ensure they comply with the requirements of WAC 296-155-110-5 through 296-155-110-9. On large projects, there may
be several toolbox talks taking place at the same time. Weekly Toolbox talks are a golden opportunity
for the management staff to show its commitment. It is best practice to require project office personnel
such as cost managers, engineers, schedulers, etc., to participate in these toolbox talks.
These meetings are 5-10 minutes long and focus on industry-specific safety topics related to the current
work activities and circumstances. For example, would it be appropriate if the foreman chooses to discuss cold weather hazards in the middle of summer. The toolbox talks can also be used to alert workers
about any site accidents or major safety infractions. Keep the toolbox talk group to 20 or less. Ensure
the meeting is documented using a sign-in sheet (see Exhibit 14-3 for the template). There are a number
of free resources available to contractors who need help finding a construction toolbox talks topic:
The Center for Construction Research and Training (CPWR) maintains a collection of 52
toolbox talks, one for each week of the year – www.cpwr.com/publications/handouts-toolbox-talks
The Washington Department of Labor & Industries has created a year’s worth of the construction toolbox talks and guidance to foreman on how to select a topic – http://www.lni.
wa.gov/safety/topics/atoz/toolboxtalks/PDFs/ToolBoxTalksComplete.pdf
The Occupational Safety and Health Administration (OSHA) has numerous QuickCardsTM –
https://www.osha.gov/pls/publications/publication.athruz?pType=Types&pID=6
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Figure 14-3: Toolbox Talks (Picture Courtesy Guy F. Atkinson)
Many general contractors require a site-wide safety meeting attended by all site personnel including
workers, supervisors, managers, and even owner representatives. Some contractors hold this meeting
weekly while some bi-weekly. This meeting should be conducted by the project superintendent, preferably Monday morning before work begins. This meeting will allow workers to ask questions, offer
suggestions, and report concerns regarding safety on the project. While this meeting does not include
a pre-selected topic, it should include at a minimum:
Lessons learned from accidents and incidents
Safety inspection findings and corrective actions
Communication of major project activities and associated hazards
Communication of access change, emergency action plan change, etc.
Safety suggestions by workers and response by management
Reports on any environmental changes that may affect the site i.e. weather.
Issuance of rewards to employees (e.g., best pre-task plan award)
Some projects have used a Microsoft PowerPoint software as a visual aid during these meetings to
communicate safety issues and site changes.
168
Figure 14-4: Toolbox Talks (Picture Courtesy Hensel Phelps Construction)
Figure 14-5: Site-wide Safety Meeting (Picture Courtesy BNBuilders)
169
Figure 14-6: Site-wide Daily Huddle (Picture Courtesy Turner Construction Company)
14.6.4 Safety Committee Meetings
Many job sites form a safety committee that is comprised of workers from major subcontractors on
site. The Project Superintendent will appoint the chairperson for this committee. The committee is
charged with conducting bi-weekly safety committee meetings and bi-weekly safety inspections. The
committee will typically report the safety issues to the project superintendent to resolve them, and
get back to the workers on corrective actions implemented. Findings of this committee are presented
during weekly site safety meetings.
14.6.5 Safety Leadership Committee
Some sites have a leadership safety committee comprised of project managers from each major subcontractors and is led by the general contractor’s Project Manager (PM). Since the members of this
committee are primarily accountable for project safety, they engage in strategic planning for the project
that will maintain an injury-free culture. This committee usually meets once a month.
14.6.6 Special Craft Training Programs
In addition to the NEO training and other training discussed above, every contractor should be aware
of special training required before workers are allowed to perform a task or use equipment. Special
training may involve the following topics, but not limited to:
Aerial Lifts
170
Asbestos / Lead Awareness
Bloodborne Pathogens
Confined Space
Crane Operator
Fall Protection
First Aid/CPR
Flagging
Forklift Operation
HAZWOPER
Ladders
Lockout / Tagout
Personal Protective Equipment
Respiratory Protection
Rigging
Scaffolding
Use of Specialty Equipment
14.6.7 Foreman Training
Many contractors make the crew foreman responsible and accountable for their crew’s safety. Before
giving the foreman the responsibility for the safety of their crew, they should be trained in leadership
skills. In addition to training required by applicable laws, contractors should consider following training for their foreman:
Leadership
o Injury Free Work Culture - Safety culture training that includes the concept of injury
free work environment and ways to develop it. Training that helps foremen develop
skills to train and motivate their crew members.
o Foreman responsibility and accountability
Administration
o Project administration requirements
o How to conduct a pre-task planning meeting?
o How to conduct a thorough accident investigation?
o How to hold a weekly toolbox talks are meeting?
Technical
o OSHA 30-hour Construction hazard recognition and control training
o First Aid, CPR, and AED
o Applicable competent person training
o Ergonomic Risk Factor
o How to lead a stretch and flex session?
o Site Emergency Procedures
o Process safety management (on industrial sites)
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14.6.8 Management Training
Management refers to project managers, engineers, and superintendents, from all contractors on site.
Typically the management personnel is held accountable for the project’s safety. Hence, it is critical to
their success to be properly trained. The following training is recommended for management personnel:
Leadership
o Leadership Training/Injury Free Work Culture - Safety culture training that includes
the concept of injury free work environment and ways to develop it. Training that helps
foremen develops the skills to train and motivate their crew members.
o Management responsibility and accountability
Administration
o Project administration requirements
o Corporate safety manual orientation
o Substance abuse testing & reasonable suspicion training
o Hazard recognition and control strategies
o Job hazard analysis and how to conduct them.
o Accident investigation
o How to conduct a thorough accident investigation?
o Site environmental management
o Construction liability related training (e.g., public protection)
o Development, measurement, and reporting of safety performance metrics
Technical
o OSHA 30-hour Construction hazard recognition and control training
o First Aid, CPR, and AED
o Process Safety Management (on industrial sites)
o Site Environmental Management
Monthly Supervisors Forum – Many contractors hold this monthly company-wide supervisor
training at a neutral location, to share best practices and lessons learned from their projects.
These meetings are preferably held as an early morning meeting with breakfast.
14.7 SALARIED EMPLOYEES TRAINING
All other salaried employees (i.e., clerical staff, human resources) are typically issued a copy of the
company’s corporate safety manual and SSSP, and they should be trained in general safety matters by
the project safety manager/manager. In addition, the following training is recommended:
Office Ergonomics
Project Safety Record keeping
Equal Employment Opportunity/Harassment
Additional Resources, Readings, and References
The Occupational Safety and Health Administration (OSHA) Training and Reference Materials
Library - https://www.osha.gov/dte/library/materials_library.html
The Center for Construction Research and Training (CPWR) has developed and maintains the
Electronic Library of Construction Occupational Safety and Health (eLCOSH.org) was developed
172
to provide accurate, user-friendly information about safety and health for construction workers,
employers, researchers and others interested in construction safety and health from a wide range
of sources worldwide - http://www.elcosh.org/index.php
The Washington Department of Labor & Industries provides a variety of training materials –
http://www.lni.wa.gov/Safety/TrainingPrevention/Materials/default.asp
173
174
1. Use Microsoft Excel to create this matrix.
2. Use an X mark to indicate completion of training.
3. Using the “comment” function or by creating a separate column include the training date or the expiration date.
Notes:
Name
Exhibit 14-1: Example Project Training Matrix
Job Title
Project Safety Orientation
Subcontractor Orientation
Reporting Procedure
Evacuation
Substance Abuse
Buddy System
HazCom/ GHS Awareness
Pre-Task Planning
PPE
Fall Protection
Ladder Safety
Confined Space
Energized Electrical Work
LOTO
MEWP
Scaffolds
Barricading
Insp. Of Tools
Lifting Procedures
Ergo
NFPA 70 E (awareness)
Powder Actuated Tools
OSHA 30
OSHA 10
CPR FIRST AID
All Terrain Forklift
Inside Forklift
Scissor Lift
Aerial Boom Lift
Certified Rigger
Site Emergency Procedures
Exhibit 14-2: Example Project New Orientation Form
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
Note: This best practice tool is only included as an example, and the users should be aware that the checklist may reference safety regulations depending on the company’s regulatory jurisdiction. It is the user’s
responsibility to ensure that they adapt the best practices provided in this checklist for their jurisdiction
and comply with all applicable local, state, and federal regulations affecting their workplace.
Hardhat #: ______________________
Badge #: ____________________________
PROJECT SAFE AND SUSTAINABLE ORIENTATION
The signatures below document that the appropriate elements have been discussed to the satisfaction of parties, and
that both supervisor and employee accept responsibility for maintaining a safe and healthful work environment.
Print Name:
_____________________________________________
Sign Name:
_____________________________________________
Company Name / Date:
_____________________________________________
Supervisor Acknowledgement:
_____________________________________________
Emergency Contact Name and Number:
_____________________________________________
General
Initials
1. No one under the age of 18 is allowed to work on the Project property / construction site.
2. Drug testing is mandatory
A. Your employer must provide the results to Turner in order to receive badge or attend
orientation.
B. Pre-employment/prior to badging
C. Post Incident
D. Test for cause – suspicion
E. If tested positive or refuse to test, will not be allowed on site
3. Badging / orientation sticker
All employees on site for more than one (1) day must obtain a badge / attend orientation
/ drug screen
4. All OSHA regulations will be strictly enforced.
A. Disciplinary Procedures – 3 strikes, you’re out
1. Verbal = Orientation
2. Written
3. Termination
4. Turner retains the right to have you removed from site, based on the nature
of the violation, without the 3 strikes (i.e., ZERO TOLERANCE).
5. Fall Protection – ZERO TOLERANCE Policy in effect
6. Every crew member must complete and participate in a Pre-Task Plan (PTP) meeting each day
before starting work.
7. No headphones, IPods, radios, etc. are permitted on the job.
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Incident
Reporting
Initials
1. Any injuries / illnesses / near misses on site must report to their supervisor immediately after
the event, if physically possible.
2. You and your employer shall cooperate with the incident investigation.
3. A “First Report of Injury” form must be filed with Turner Safety Office within eight (8)
hours after an accident.
4. If sent to a doctor for treatment all follow-up appointments must be kept.
5. A Temporary Modified Duty policy is in place.
6. The worker must strictly follow any and all work restrictions issued by doctor.
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100% 6-Foot
Fall Protection
(Regardless of
Trade)
Initials
1.
2.
3.
4.
100% FALL PROTECTION 6-foot and above ( Includes all Trades)
ZERO TOLERANCE – For Fall Violations
Full body harnesses and double lanyards with double locking snap hook
Gear to be inspected prior to every use. Contact your supervisor immediately if gear is damaged.
DO NOT USE DAMAGED GEAR.
5. No knots or rigging can be used for fall protection.
6. Warning lines are to be a min. of 15 feet back from the edge. (see criteria in Turner Safety Manual)
7. Tie off point must hold 5,000 LBS or 2x SF as engineered anchorage point.
8. 100% tie off when working from extensible / articulating boom aerial lift.
9. Employees must be trained on the use of fall protection.
10. Vertical or horizontal rebar or other impalement hazards shall be protected.
11. Any hole 2” or larger must be covered, secured, labeled (supporting 2X max the indented load)
12. Scaffolds
A. Must be built under supervision of competent person who has necessary certifications
(w/ 100% Fall Protection while erecting)
B. Proper ladder access is required. Cross bracing cannot be used as a ladder or for a
guardrail.
C. Scaffold must be inspected before each shift by the Subcontractors competent person
and tagged/dated as safe. If you climb onto a scaffold not tagged and dated as safe,
you may be removed from the jobsite.
D. 100% tie off when working from all types of lifts that have a manufactured tie off point.
Dual action controls require that there be two separate actions to activate the lift. If it
arrives on site and does not have dual action controls, then it must remain inoperable
until a Dual action control is installed.
E. All mobile scaffolds must have rails at all heights & the wheels locked when in use.
13. Standard Railing
A. Top edge height of top rail must be 42” + 3” above the walking/working level and all
systems must include a toe board and midrail.
B. Guardrails will not be used as a horizontal anchorage for personal fall arrest equipment.
1. Do not tie off to guardrails
C. Guardrails must be provided at floor openings and open sides, or personal fall protection must be used.
D. Wood rail supports shall not be more than 8 foot on center.
E. Wire rope guardrails – min 3/8 inch cable, flagged every 6 feet, cannot have more than 3
inches of deflection, 3 clips are required at each termination, no open turnbuckles
14. Ladders
A. No aluminum or wood ladders are permitted on the site, only platform ladders are permitted
B. Ladders cannot be used onsite unless a ladder permit has been filled out & approved by
the Turner Superintendent. Use lifts or scaffolds as the first option.
C. Please inspect all ladders before each use
D. Never use a folding ladder as a straight ladder
E. Never use the top two (2) steps or the top of the ladder
F. Never store material or tools on the steps of a ladder
G. Employees shall be trained on ladder use/safety
H. Use the 3-point rule: 2 hands and a foot or vice versa to be in contact with ladder at
all times. Keep belt buckle between side rails.
If three point contact is not possible 100% fall protection using a retractable devices is
required.
Turner will approve perimeter access points for material handling. Personal fall protection must be
put in place before cables or rails are taken down, or holes uncovered. Barricade the area, place sign,
and leave a spotter.
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Safety
Enforcement
Initials
Emergency
Procedures
Initials
Personal
Protective
Equipment
Initials
1. All personnel are encouraged to ask questions and report actual and perceived hazardous conditions to site supervision. Perceived hazardous conditions may need further clarification and
hazard assessment. . If you have any questions or concerns, please ask for assistance.
2. There is a “Safety Enforcement” Fine System in place on this project.
A. You are ACCOUNTABLE for your actions on this project.
B. Monetary fines imposed upon your EMPLOYER for your inability to work in safe manner or complacency w/ regard to “MINIMUM” safety rules
C. $250.00 - $5,000.00 – depending upon severity of violation.
D. You will be physically removed from job for serious and/or repeat violations.
3. ALL personnel are empowered and encouraged to stop unsafe acts, identify unsafe conditions, &
stop non- construction personnel and escort them out of the work areas. Please care for your
project teammates.
1. In the event of an emergency
A. Notify job foreman immediately
B. Give the exact nature of the emergency (i.e. broken leg, fire, etc.)
C. Give the exact location by area column or other easily recognizable terms
D. Stay on the phone until Safety has confirmed that you have provided accurate information
E. If an evacuation is not required, stay on the scene to brief emergency personnel upon
their arrival.
2. Evacuation Procedures
A. 3 horn blasts will indicate site is to be evacuated
B. Proceed in a calm, orderly manner to the designated safety zone.
1. PRIMARY MUSTER POINTS ARE TBD
2. Report to your designated foreman/superintendent in designated area for head
count.
C. DO NOT LEAVE SAFETY ZONE OR GO HOME UNTIL INSTRUCTED BY
YOUR SUPERINTENDENT
D. ALL DANGEROUS AND/OR EMERGENCY SITUATIONS MUST BE REPORTED TO TURNER ON SITE STAFF within 15 minutes of the event if feasible.
E. Turner to call 911 for ambulance as necessary.
F. Where is the location of your first aid kit and fire extinguishers? Keep this in mind while
working.
1. Basics:
A. 100% Hardhat Protection, Non Metallic, REQUIRED AT ALL TIMES. ANSI approved
B. 100% Eye Protection (ANSI Z87.1) REQUIRED AT ALL TIMES.
C. Hard sole work boots are required, no sneakers or soft shoes are allowed, ANSI Z41.1.
Steel toed boots/metatarsals must be worn as dictated by the hazard assessment.
D. Long pants in good condition, no shorts allowed
E. Shirts must have sleeves at least 4” long
F. Cut resistant gloves are required when using knives or handling sharp material/objects.
Additional hand protection may be required depending on the hazard assessment.
G. Ear protection as required when exposed to noise above 85 DBA
H. Face-shields or goggles required when cutting / grinding / chipping / etc.
I. No loose clothing or jewelry
J. High visibility vest is required when working around machinery.
K. Any contractors requiring the use of dust masks and/or respirators must submit a written respiratory protection program Turner. This program must address medical surveillance, fit testing, etc. Voluntary usage of dust mask type respirators used by employees
must also be included in the respiratory protection program and shall meet or exceed
OSHA standards.
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Electrical /
LOTO
Initials
Equipment
Initials
Cranes
Initials
Barricade Tape
Initials
Training
Requirements
Initials
1. Industrial heavy weight cords (14 gauge or heavier) with proper grounds are to be used at all
times.
2. 100% Ground Fault Circuit Interrupter (GFCI) Protection.
3. Inspect all cords and welding leads before each use
A. Damaged items must be repaired or removed from the job site
B. All cords and leads are to be elevated above all main walkways.
4. ALL Electrical and mechanical systems are to be considered LIVE.
5. All boxes containing live wires must have a cover.
6. NEVER work on live electrical panels without prior approval from Turner.
7. LO/TO – Single lock keys (cannot have multiple keys)
1.
2.
3.
4.
5.
6.
7.
Proper training and certification is required prior to operating any equipment.
All stops must be observed at intersections. Complete stops must be observed.
Speed limit on site is 5 mph or a safe operating speed whichever is slower.
A spotter is mandatory when view is obstructed by load.
Backup alarms must be present on all required vehicles.
Horns and lights are recommended for all equipment.
Always follow the manufacturer’s operating instructions for all equipment and tools used on this
project.
8. Seatbelts must be worn at all times.
9. The use of cell phones is prohibited while the machine or vehicle is in motion.
10. The forks of a forklift cannot be used for free rigging.
1.
2.
3.
4.
5.
Awareness of overhead loads – listen for horns.
NEVER stand or walk under an elevated load.
Awareness of crane swing radius (should be flagged off).
Cannot operate a crane within 20’ of any power line.
Rigging must be inspected before each use by a qualified rigger. Damaged rigging must be removed from service.
6. Crane operator must submit operator certifications
7. Employees cannot signal a crane unless trained.
8. Each rigger & signal person must be qualified & proof of training given to Turner Construction
1. Types of Tape
A. Red – Imminent Danger exists. Only authorized personnel performing actual work are to be
allowed in this barricade tape area. The only exception for entry into a red area is with prior
permission of those authorized to work within the area
B. Yellow – a hazard exists that would warrant Caution. A yellow area can be accessed by
anyone who is authorized to be on the job site, and who stops to observe the existing hazard
and takes the proper precautions prior to entering the tape barricade area.
1. Must be trained / certified to operate forklifts, aerial lifts, scaffolding, cranes, etc.
2. Contractors are required to provide workers that are trained as required by OSHA standards
and site policies.
3. All workers are to be trained by their employer for the task at hand – ladders, scaffolds, excavations, etc.
4. No worker may lift more than 50 pounds, unassisted. Use mechanical means first.
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Housekeeping
Initials
Hand & Power
Tools
Initials
Hot Work
Initials
Excavations
Initials
1. All trash/debris is to be placed immediately upon creation into rolling trash bins or hoppers that
do not require workers to lift or carry. This includes lunch/break trash. Housekeeping is a CONDITION OF EMPLOYMENT.
2. Sweeping compound is a requirement of the Indoor Air Quality (IAQ) Management Plan.
3. Dust creating activities will take place only in accordance with the IAQ Management Plan. Any
alterations in the finished areas will require either temporary dust protection or a vacuum with
HEPA filter to collect dust generated.
4. Strict compliance with the Construction Waste Management Plan is required. Recycled materials
include but are not limited to wood, scrap metal, concrete, cardboard, and drywall. Construction
waste shall only be placed in the appropriately labeled dumpster.
5. Zero use of tobacco policy. No tolerance policy for smoking in building during construction.
6. Extension cords, hoses, welding leads, etc., must be run 8’ overhead in all stairs, aisles, and exit
areas.
7. When using stilts, the floor must be broom swept with not trip hazards. (Cords, material, and
trash)
8. No glass containers are permitted onsite.
9. Storage of material must not be within 6 feet of any interior opening or 10 feet to the exterior
without protection.
1. All drills, grinders, etc. that are designed with guards and/or control bars must have them in
place when the tool is in use. The grinding wheels must be rated per the specifications of the
grinder.
2. Work stations are to be elevated. Chop saws & other work activities.
3. Powder Actuated Tools - No lead based shot is permitted onsite
4. Tools are to be used the way the manufacturer intended. Do not modify any tool.
1. The contractor performing hot work will be required to have a charged and inspected 20 pound
ABC dry chemical fire extinguisher present in the work area.
2. Appropriate permit procedures, shields, and blankets shall be used when developing site specific
fire prevention programs.
3. Subcontractor is required to implement a fire watch during all burning operation for a minimum
of 30 minutes following completion.
4. Hard Hats are required while welding.
5. Safety glasses are required under the shield when chipping or grinding
6. Cylinder Storage must be stored upright and properly secured. When not in use, disconnect hose/
gauge assemblies and cap the cylinder. Stored cylinders must have a ½ hour fire rated barrier 5
feet tall or be stored 20 feet apart. Propane tanks cannot be stored in any building. (Turner must
be notified prior to propane used onsite) All torch carts are to have a fire rated barrier between
the cylinders.
7. Anti-flash devices are to be located at the torch head & at the cylinders
8. Hot Work activities must be pre-approved by Turner (Permit to be issued)
1. Any excavation greater than 4’ must be sloped, shielded or benched properly
2. The bottom of the trench box must be within 2 feet of the bottom of the trench. The top of the
trench box must sick up 18 inch above the slope or the bench. The box cannot be moved while
workers are inside.
3. Access must be provided by a ramp or a ladder. Travel distance to ladder must not exceed 25 feet.
4. Any excavation must be barricaded off with orange fence or equivalent, regardless of depth.
5. You cannot bench Type C soil.
6. Before you dig, Miss Utility must be notified days in advance
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Hazard
1. This employee, by his initials in this section acknowledges that he/she has been trained by their
Communication
employer.
/ GHS
2. Turner will coordinate the sharing of Safety Data Sheets (SDS) between contractors.
3. The SDS’s are available at the project.
Initials
Construction
Waste
Management
Initials
Indoor Air
Quality
Initials
1. All waste leaving this project is tracked on Turner’s Online Waste Tracking (OWT) system. Strict
compliance with the project Construction Waste Management Plan (CWMP) is required. The recycling goal is _____%. The construction and demolition dumpsters on this project are (co-mingled) (site-sorted). Materials recycled include, at a minimum:
A. Wood: pallets, wood-framed boxes, temporary lumber, etc.
B. Concrete: concrete, block, brick, asphalt
C. Metal: scrap metal, metal studs, metal pipe, etc.
D. Cardboard, paper
E. Drywall: drywall, mold board, (NO Dens Glass)
F. Construction Trash: food waste, sweepings, non-recyclable waste, etc.
2. Collect and sort your construction waste throughout the workday and transport the waste to the
appropriate dumpster at the time established by your Foreman or Project Manager.
3. All Subcontractors are required to recycle to the maximum extent possible as a part of their
Contracts using Turner’s OWT tool. In cases of non-compliance, only the Subcontractor(s) responsible for contaminating dumpsters (placing waste in the wrong dumpster) will be responsible
for fines, additional tipping fees, or other penalties as may apply.
1. Strict compliance with the project Indoor Air Quality (IAQ) Management Plan is required.
2. Safety Data Sheets (SDS), along with VOC content, of all adhesives, sealants, coatings, paints,
carpets, composite woods, etc. must be submitted for review and approval prior to these products
being brought on site.
3. Stored material shall be covered, stored off of the deck, and kept in a dry environment. Quantities should be limited to what can be installed in a reasonable time (e.g. two weeks or less).
4. This project is Tobacco-Free. Zero tolerance for smoking in the building during construction.
5. Changes in finished areas should be treated as renovations.
6. For large changes, install temporary dust protection to separate the work area from the finished
space. The work area should be kept negative and a HEPA filter should be used to filter the air
prior to it leaving the space. The temporary protection and filter system should be approved by
a Turner superintendent before beginning work. Once the work is complete, the area should be
thoroughly cleaned and the temporary protection should be removed.
7. For small changes, a vacuum with a HEPA filter should be used to collect any dust that is generated and the areas should be thoroughly cleaned after the work is complete.
8. Daily clean-up of all work areas is required by each subcontract.
9. All subcontractors will be required to use sweeping compound.
10. All cleaning products used on the project must comply with Green Seal Standard GS - 37 for
Industrial and Institutional Cleaners.
11. Mold and moisture control is a key to proper indoor air quality. If possible, drywall activities
should not begin until the building is watertight. If drywall must start before the building is
watertight, moisture resistance board should be used.
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Site
Management
Initials
Stormwater
Management
Initials
1. Strict compliance with the project Construction Activity Pollution Prevention Plan (CAPPP)
and Erosion and Sedimentation Control (ESC) Plan.
2. Use and maintain earth dikes, silt fence, sediment traps, and/or catch basin filters to trap and
separate silt.
3. Cover all stockpiles with plastic sheeting on a daily basis.
4. Do not leave spoils piled on site for extended periods. If possible excavate, install utilities, backfill
and grade each day. Sequence the work to minimize exposure.
5. Maintain existing hardscapes/landscapes (asphalt, concrete, grass, plantings) as long as possible.
6. Provide and use wheel washing facilities or maintain rip rap entries and exits.
7. Use Eco pans for concrete truck clean-up if available. If not make sure slurry is contained and
does not infiltrate catch basins or waterways.
8. Secure all materials and stockpiles and check site prior to storm events.
9. Use only designated areas for equipment maintenance and wash down.
10. Minimize the generation of dust and the tracking of sediment to off-site paved areas.
11. Minimize site disturbance during construction activity.
12. Comply with all applicable noise mitigation activity.
13. Comply with all applicable vehicle emissions requirements.
1. Stormwater Pollution Prevention Plan (SWPPP) requirements were reviewed for subcontractor
employees involved in ground disturbing activities.
2. The SWPPP requirements including Best Management Practices (BMP’s) were reviewed and will
be followed as required by the SWPPP.
3. The SWPPP drawings, project sequence and how sequencing will affect BMP locations were
reviewed.
4. Notify Turner of any disturbances of the Best Management Practices (BMP’s) including silt
fences, vehicle mud removal areas, vegetative cover, other sediment and erosion controls.
5. Ensure all concrete/cement washout is performed at designated locations and into designated
containers, notify Turner personnel immediately if washout is not adequately containing wash
water and stop washout activity.
6. All site dewatering must be performed in a manner compliant with the SWPPP and all pump
discharge locations must be previously approved by Turner.
7. Inspect all equipment and chemical storage containers for leaks as well as excess grease/grim/
oil/fuel, if any of the above are discovered ensure that mechanics are notified (if necessary) and
equipment/containers are wiped clean and containments disposed of properly.
8. Ensure parked equipment and chemical storage containers are parked/stored in locations previously approved by Turner and are identified on the SWPPP map.
9. Know where the SWPPP map is located and identify the spill kit location on it, notify Turner
personnel immediately if a spill occurs.
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Nothing Hits
the Ground
Initials
FABRICATION:
1. All material fabrication shall be performed at a work station between 30 and 39 inches off the
floor.
2. Work station shall be mobile and include a fire stop directly behind all chop saws.
3. Rubbish containers shall be mobile and located directly adjacent to the work station.
4. Mobile rubbish containers must be made available for subcontractors work.
HOUSEKEEPING:
1. All rubbish shall be disposed of as it is generated and be immediately place in a mobile rubbish
container provided by the subcontractor.
2. Cordless power tools are required unless the subcontractor can demonstrate a hardship or need
to use tools with power cords.
3. The subcontractor is required to elevate off the ground all power cords in order to minimize
tripping hazards on walking/working surfaces.
4. Debris is not allowed to be consolidated on the floor.
MATERIAL HANDLING/ STORAGE:
1. Material may not be stored within 10 feet of the building perimeter or adjacent to shafts or
stairwells.
2. All material laydown areas must be coordinated and designated by Turner.
3. Material must be stored to promote mobility of material. Pipes, conduits, metal fabrications and
steel framing are to be stored on rolling racks or similar means of conveyance. Bulk material
should be palletized to allow for easy mobility using a pallet jack.
4. Just in Time” delivery required to minimize clutter. Nothing should be stored on a floor that
cannot be installed within one week.
5. Heavy material such as glass and drywall must be loaded so as not to overload the structure. The
subcontractor is required to do a floor loading analysis for submission to Turner for review and
approval.
(Used with permission of Turner Construction Company. The opinions and guidance expressed in this
handbook are those of the author and not necessarily those of Turner Construction Company)
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Exhibit 14-3: Example Weekly Safety Meeting Attendance Sheet Template
Date: ________________________________
Location: _____________________________
Topic: ________________________________
Meeting Facilitator: ____________________
Start Time: ______ End Time: ______
Meeting Agenda attached: Yes No
Number of Attendees: ________
Total workers onsite: ________
EMPLOYEE NAME*
COMPANY NAME
SIGNATURE
*Use additional sign-in sheets if necessary
Safety Suggestions / Recommendations to improve site safety
Actions Taken
Distribution: Original to Project Safety File
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Supervisor Signature / Date
Completed
15
WORKPLACE SUBSTANCE ABUSE PROGRAM
15.1 INTRODUCTION
Construction is a hazardous industry, and most jobs associated with the industry carry a higher risk
level of accidents and injuries. A recent study found that occupations involved in the construction industry have the highest prevalence of illicit drug use and heavy alcohol use.1 Eliminating or minimizing
construction worker substance abuse can help construction companies not only to reduce workplace
injuries, but it will increase productivity and improve work quality. One of the best ways to address
substance abuse on construction sites is to implement a comprehensive substance abuse program.
The primary intent of this chapter is to offer guidance based on industry best practices to develop a
workplace substance abuse program that may help eliminate or minimize accidents or injuries related
to substance abuse.
The first step when a company has decided to implement a substance program is to consider these two
questions:
• Are drug and alcohol testing legal in your state?
• Are there any restrictions on any aspects of the testing (e.g., random testing)?
Note: When developing programs, policies, or procedures relating to substance abuse programs, contractors should always seek guidance from its attorneys/legal counsel or seek guidance from an employment law specialist. This helps to ensure compliance with all applicable local, state, and federal
laws.
15.2 DEPARTMENT OF LABOR (DOL) RECOMMENDATIONS
One of the best resources available to develop a substance abuse program was developed by the Department of Labor (DOL). The DOL recommends that a company’s formal substance abuse program
should contain at least the following components:2
1.
2.
3.
4.
5.
Written substance abuse policy
Supervisor training
Employee education
Employee assistance program
Drug and alcohol testing
1 Substance Abuse and Mental Health Services Administration, Office of Applied Studies. Worker substance use and workplace policies and programs.
Available at: http://www.oas.samhsa.gov/work2k7/work.htm#High. (Accessed November 17, 2014)
2 Occupational Safety and Health Administration (OSHA). Drug-Free Workplace Policy Builder
http://www.dol.gov/elaws/asp/drugfree/drugs/screen1.asp (Accessed November 17, 2014)
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15.3 BEST PRACTICES
In addition to the DOL recommendations, consider the following questions when developing a substance abuse policy for your company. Please note on some projects the project owner might have
stringent or additional requirements on their substance abuse program. It is important to identify and
comply with those owner or project-specific requirements.
15.3.1 Why should your company care about workplace substance abuse? What are the effects of substance abuse on the construction worker safety and health performance?
A recent study found that occupations involved in the construction industry have the highest prevalence of illicit drug use and heavy alcohol use.3 Eliminating or minimizing construction worker substance abuse can help construction companies not only to reduce workplace injuries, but it will increase
productivity and improve work quality.
15.3.2 What is your company’s policy or position on workplace drug and alcohol use?
Contractors should seek and gain full support and cooperation from their workers when developing
their substance abuse policy. As with any safety policy, employee involvement is critical to the success
of the program. It is recommended to find a way to receive and incorporate employee feedback in
the policy. By educating the workforce that employees under the influence of drugs, alcohol, or other
controlled substances on the jobsite pose serious safety and health risk not only to themselves, but to
their coworkers and the public. It is a best practice to obtain employee consent and to indicate clearly
drug and alcohol testing is a requirement for employment with the company or the jobsite. The policy
should state the benefits of drug and alcohol testing within the construction industry such as improved
workplace safety performance, better performance, better quality of living, and decreased rates of
employee absenteeism.4 For example, the company policy can state, “Company ABC will not tolerate
drug or alcohol use on its premises and projects.” See Exhibit 15-1 for a sample drug and alcohol prevention program.
15.3.3 What are the prohibited substances, articles and conduct not tolerated by the company? What are
their cut-off levels?
Prohibited substances can include alcohol, drugs, selected prescription drugs, illegal drugs, and contraband. The company policy should clearly list each of these substances to avoid confusion. Employees
who are taking prescription drugs, for which there is a potential unsafe side effect, should be required
to report to their supervisor. The company should clearly list the controlled substance and its cutoff
level in its policy. For example, ethanol alcohol the cutoff is 0.03 g/dl.
15.3.4 Which employees will be tested?
Companies cannot be discriminatory, hence, “all” company employees should be tested. On a construction project, general contractors should require all subcontractor and sub-tier subcontractor employees to undergo drug and alcohol testing. General contractors should also consider project owner
representatives and other personnel who will be present on the jobsite. Will they be tested as part of
the project drug and alcohol testing policy? What about the vendors and suppliers?
3 Substance Abuse and Mental Health Services Administration, Office of Applied Studies. Worker substance use and workplace policies and programs.
Available at: http://www.oas.samhsa.gov/work2k7/work.htm#High. (Accessed November 17, 2014)
4 Substance Abuse and Mental Health Services Administration, Office of Applied Studies. Worker substance use and workplace policies and
programs. Available at: http://www.oas.samhsa.gov/work2k7/work.htm#High. (Accessed November 17, 2014)
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15.3.5 Who covers the cost of testing?
It is recommended that the employer cover the cost of testing regardless of test results. Some contractors require the employees to pay for return-to-work testing after a verified positive test result. The
policy should also indicate who covers the cost for the time an employee spends testing. On a typical
project, the testing cost might be built into the project budget that is ultimately paid by the owner. In
some cases, when it involves union workers, collective bargaining agreement might address the payment issues related to drug and alcohol testing.
15.3.6 When (what circumstances) will the tests be conducted?
At a minimum, industry best practices recommend that the employees should be tested under the following circumstances:
o
o
o
o
o
o
Pre-employment/Pre-hire
Jobsite or project transfer
Return-to-work testing
Reasonable Suspicion/Probable cause
Random
Post-Accident
15.3.7 What is the policy for employees who refuse to submit to the test?
The best practice should be to consider refusal to test as a positive result (the employee failed the test),
and the employee should not be considered for employment by the company.
15.3.8 What are the testing procedures and protocols?
Before initiating any drug and alcohol testing for employees, it is critical to establishing effective drug
and alcohol testing policies and procedures. It should be reminded that the company should consult with their attorney. The Department of Health and Human Services (DHHS) and the Substance
Abuse and Mental Health Services Administration (SAMHSA) has published standards and guidelines regarding testing protocols. Contractors should refer to these guidelines when developing their
testing procedures or protocols.
15.3.9 Who is allowed to access the results of a drug and alcohol test? How will the company ensure confidentiality of the test results?
Test results are extremely sensitive since it involves employee privacy. All information regarding the
tests should be treated in a confidential manner in accordance with applicable laws unless otherwise
permitted upon the written consent of the employee.
15.3.10 How will the company select a licensed/certified laboratory? Does the lab meet all applicable
state and federal licensing requirements? Does the lab have properly written testing protocol
including a clear chain-of-custody? Does the lab have a protocol in place to prevent adulteration
or substitution of specimens in the case of urinalysis?
The Substance Abuse and Mental Health Services Administration (SAMHSA) maintains an archive
of monthly certified lab lists as recorded in the Federal Register, which can be accessed at http://www.
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samhsa.gov/workplace/lab-list. Use of HHS/SAMSHA approved laboratories, and medical facilities
are recommended. In some cases, mobile testing laboratories are also used, mostly for post-accident
testing, when the hospital does not have testing facilities. The company should ensure any use of mobile testing facilities should follow all applicable local, state, and federal requirements.
15.3.11 Is there any Employee Assistance Programs (EAP) available to the workers?
The policy should state the employee responsibilities to seek treatment through the company’s EAP
program if any.
15.3.12 Is your company subject to state and certain Federal regulations, such as the U.S. Department
of Transportation’s (DOT) drug testing rules? Is the company substance abuse policy compliant
with these requirements?
Employees who operate commercial motor vehicles should be tested in accordance with the Federal
Department of Transportation (DOT) regulations and other applicable state DOT regulations.
15.3.13 How will the workers and their supervisors be trained on the company’s substance abuse program? What are the topics that these training should cover?
Employee education and supervisor training should be an important component of a workplace substance abuse program. Employee training should address:
οο
οο
οο
οο
The importance of training
Dangers of substance abuse in the workplace
Company policy
The penalties due to non-compliance, and information about employee assistance programs,
substance counseling programs and services, and substance abuse rehabilitation programs
All company supervisors and management should also be trained to assist in identifying and addressing workplace substance abuse such as:
οο
οο
οο
οο
Supervisor roles and responsibilities with the program implementation and enforcement
Signs and symptoms of use of drugs and alcohol
Procedure to handle a non-compliant employee
Resources regarding employee assistance programs
All employee and supervisor training should be documented (agenda, training content, attendee signup sheet) to verify understanding of the company substance abuse program.
15.3.14 If your company provides a general contracting service, will the company accept drug and alcohol testing conducted by your subcontractors or unions through their substance abuse program?
This should also be considered as part of your policy. For example, some labor unions have their drug
and alcohol testing program and issue proof of testing in the form of cards. These cards are valid for
six months.
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15.4 PROJECT LEVEL CONSIDERATIONS
Include project drug and alcohol testing requirements in the contracts so that all contractors are
aware of the requirements.
Testing facility considerations:
οο Identify the closest certified drug and alcohol testing facility to the project. The closer, the
better since it saves a lot of travel time for the workers.
οο Develop a billing mechanism for a particular project. Typically general contractors will
create a “project identification number (PID),” and will share it with their workers and
subcontractor workers. When workers visit the testing facility, they will inform the facility
about the project they are associated with, and the testing facility will charge the project
accordingly.
οο The workers usually fill out a consent form and a chain of custody form at the facility in the
presence of the collector. Ensure the testing facility has plenty of your company’s consent
forms. The forms should be 3 or 4 part forms so that the worker, your company, and the
project receives a copy of the consent form.
οο Project supervision should talk to workers about the quality of service provided by the testing facilities, the time taken to complete testing, etc., as part of the continuous improvement
process. If the company is not satisfied, it might be a good idea to meet with the facility to
rectify the deficiencies or change the facility.
Create an information sheet that includes a facility name, contact information, and directions from
the project, and PID. After completion of the new employee orientation, workers can go to the
testing facility with the information sheet and complete the testing return to the jobsite.
When workers return to the jobsite verify the consent form, make sure there are no modifications
made on the consent form.
Ensure the project has good secure storage cabinets to store all documentation related to the project. These documents should also be archived as part of your project record retention policy. Drug
and alcohol testing documentation can include:
οο Consent forms
οο Chain of custody copies
οο Test results
οο Copies of disciplinary actions related to testing
οο Reasonable suspicion forms
Ensure the project has at least a secure room (conference room) which can be used to communicate test results to workers or to deal with anything related to drug and alcohol testing. Due to the
sensitive nature of the information, each contractor on the jobsite should come up with a plan on
how to communicate the test results, and how to remove workers from the project for positive test
results.
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Additional Resources, Readings, and References
For more information about substance abuse program best practices and guidelines, please refer to the
following resources.
Department of Labor’s (DOL) online Drug-Free Workplace Advisor helps employers develop
customized drug-free workplace policies (that may or may not including drug testing) by reviewing the different components of a comprehensive policy and then generating a written policy
statement based on the user’s responses to pre-set questions and statements. The Advisor can be
accessed at http://www.dol.gov/elaws/asp/drugfree/drugs/screen1.asp.
The Substance Abuse and Mental Health Services Administration (SAMHSA) has numerous resources on this topic such as:
οο Drug-Free Workplace Toolkit: http://www.samhsa.gov/sites/default/files/workplace-kit.pdf
οο Model Plan for a Comprehensive Drug-Free Workplace Program:
http://www.samhsa.gov/sites/default/files/workplace/ModelPlan508.pdf
The U.S. Department of Transportation (DOT) also has many resources on this topic that can be
accessed at http://www.dot.gov/odapc
National Institute on Drug Abuse - www.drugabuse.gov
Nationwide Medical Review - www.drugfreeworkplace.com
National Business Group on Health Publication -An Employer’s Guide to Workplace Substance
Abuse: Strategies and Treatment Recommendations:
http://www.businessgrouphealth.org/pub/f3151957-2354-d714-5191-c11a80a07294
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Exhibit 15-1: Sample Prevention of Drug and Alcohol Abuse Plan
Note: This Drug and Alcohol Abuse Plan is only included as an example, and the users should be aware
that the plan may reference laws and regulations depending on the company’s jurisdictions. It is the user’s
responsibility to ensure that they adapt the information provided in this plan for their jurisdiction and
comply with all applicable local, state, and federal regulations affecting their workplace.
Introduction
Employees are the most valuable resource of “Construction Company”, and because of that the health
and safety of these employees is of paramount importance.
To ensure the continued health and safety of its employees “Construction Company” will implement
the following policy regarding drug/alcohol/substance abuse in the workplace and on “Construction
Company” business. The purpose of this policy is to support and further ABC’s existing safety programs and to eliminate drug and alcohol related work performance problems by ensuring, if at all
possible, a workplace that is drug and alcohol free.
“Construction Company” has the right, both under the law and under general industrial practices, to
implement reasonable work rules governing the conduct of employees on “Construction Company”
property, “Construction Company” jobsites, and/or “Construction Company” business while off of
“Construction Company” property or jobsites. Under the Drug Free Workplace Act of 1988, “Construction Company” has a legal duty to comply with all the requirements of the act.
While “Construction Company” employees are necessarily free to select their own life-styles, “Construction Company” need not and will not accept the risks that drug and/or alcohol use by employees
will cause in the form of accidents, injuries, and other job performance problems.
Policy
Employees are expected, and must, report for work without illegal drugs in their bodies or in their
possession and not under the influence of alcohol. Compliance with this requirement is a mandatory
job qualification.
ANY PERSON ACCEPTING OR CONTINUING EMPLOYMENT WITH THE “CONSTRUCTION COMPANY” GIVES HIS/HER CONSENT TO THE TESTS AND EXAMINATIONS SET
FORTH IN THIS POLICY.
1. There will be no alcohol consumption on or off Company property during working hours.
2. Employees who are under the influence of alcohol and/or who possess or consume alcohol on the
job have the great and real potential for interfering with job performance by themselves and other
employees and endangering themselves and other persons and employees. Should such interference
and/or endangerment occur as the result of alcohol consumption, and/or possession, administrative action up to and including termination of employment, depending upon the particular situation, the nature of the interference and/or endangerment, the employee’s present job assignment,
the employee’s record with “Construction Company” and other relevant factors, may result.
191
3. The illegal use, sale or possession of narcotics, drugs, or other controlled substances while on the
job or on “Construction Company” property is a dischargeable offense. Any illegal substances will
be disposed of lawfully and appropriately.
4. Drugs which are illegal or controlled under Federal, State, and/or local laws include, but are not
limited to, marijuana, heroin, hashish, cocaine, hallucinogens, depressants and stimulants NOT
prescribed for CURRENT personal medical treatment by an accredited physician. While the use
of prescribed drugs as part of a personal medical treatment program is not in and of itself grounds
for disciplinary action, should such use adversely affect an employee’s job performance or behavior, administrative action up to and including termination of employment, depending upon the
particular situation, may result.
5. Off-the-job drug use which could adversely affect the employee’s job performance and/or the health
and safety of other employees, the public, “Construction Company” property and/or equipment
may result in administrative action up to and including termination of employment, depending
upon the particular situation, the nature of the interference and/or endangerment, the employee’s
present job assignment, the employee’s record with “Construction Company” and other relevant
factors.
6. Employees reasonably suspected of being under the influence of alcohol, narcotics, illegal and/or
dangerous drugs as evidenced by job impairment, high absenteeism or other such manifestations,
shall submit to a physical examination, including a medically validated chemical analysis of blood
and/or urine sample by a recognized hospital, clinic or laboratory.
Reasonable suspicion shall include, but not be limited to, any employee involvement in any accident resulting in any medical treatment, including first aid, being administered by an accredited
physician, resulting in any property damage in excess of five hundred dollars ($500), and employee
involvement in any physical altercation in the work place. All employees involved in the said accident, property damage, and/or altercation shall be subject to the foregoing. If the involved employee(s) refuses to submit to testing or examination, he/she will be immediately suspended from work
without pay, pending results of the investigation as more fully explained hereafter.
As soon as reasonably possible after the suspension, the suspended employee will be given a hearing by a “Construction Company” personnel panel to present evidence why such employee should
not be required to undergo testing or examination or should not be discharged for refusal to submit to testing or examination. Should such employee refuse to participate in the hearing or fail to
present good and sufficient reasons or evidence justifying such refusal, termination of employment
may be taken.
Employees found by such tests and/or examinations to have illegal drugs in their systems while
at work are considered to be “under the influence” of such drugs and in violation of this policy,
even if impairment of functions may not be present. Because unauthorized drug use is illegal and
because of the potentially serious safety consequences, “Construction Company” will not accept
even the slightest risk employees with illegal drugs in their systems may cause, or contribute to, an
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accident. For the protection of “CONSTRUCTION COMPANY”, other employees and persons,
these employees with illegal drugs in their systems will be immediately suspended from work without pay as follows:
If the initial test results are negative, the employee shall immediately be returned to work with back
pay; if the initial test results are positive, the suspension without pay shall continue until the test is
confirmed by gas chromatography, gas chromatography-mass spectroscopy or another comparably
reliable method by a duly licensed laboratory. If the results of the confirming test are negative, the
employee shall immediately be returned to work with back pay. If the results of the confirming test
are positive, the suspension without pay shall continue until such time as the subject employee has
enrolled in or completed an assistance program acceptable to “Construction Company” and the
employee’s medical tests and examinations demonstrate no evidence of such drugs. The subject
employee may be allowed to return to work subject to such follow-up tests and/or examinations as
“CONSTRUCTION COMPANY”, in conjunction with accredited assistance program personnel
and/or accredited physicians, may determine. “Construction Company” will assist in referring such
employees to appropriate treatment or assistance programs.
These suspensions are intended to allow time for drugs to be totally eliminated from an employee’s
system and to allow the employee to enroll in (and complete, if so necessary) an appropriate substance abuse assistance program. An employee will be permitted only one (1) suspension for this
reason. Any recurrence of drug abuse shall constitute grounds for immediate termination without
eligibility of rehire.
7. Any employee who, while on the job, suffers, causes, and/or is involved in a personal injury requiring medical treatment, (including first aid), by an accredited physician, shall undergo a test and/or
examination for drug/alcohol/substance abuse. Testing will be done at medical facilities assigned by
“CONSTRUCTION COMPANY”. Any employee found with a positive level of illegal drugs and/
or alcohol in his/her system could be ineligible for workman’s compensation benefits or payment
of medical expenses incurred based upon results of further investigation. Any employee involved
in an accident which involves damage to “CONSTRUCTION COMPANY”’s property or to the
property of others in excess of five hundred dollars ($500) shall also be subject to drug/alcohol/
substance abuse screening, and further subject to those specific consequences listed above. If the
employee refuses to submit to testing or examination, the employee will be immediately suspended
from work without pay. As soon as reasonably possible after the suspension, the suspended employee will be given a hearing by a “Construction Company” personnel panel to present evidence
why he/she should not be required to undergo testing or examination or should not be discharged
for refusal to submit to testing or examination.
Any employee involved in an accident which involves damage to “CONSTRUCTION COMPANY”’s property or to the property of others in excess of three hundred dollars ($300) and who is
found by any such confirmatory tests and examinations to have illegal drugs and/or alcohol in their
systems shall be required to reimburse “Construction Company” for the property damage to the
full extent allowed by law.
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Any prescription drugs being taken by the employee will and should be noted at the time of testing.
A positive result will automatically require the employee to consult with “Construction Company”
management for follow-up procedures.
8. Employees must report ALL injuries immediately to their supervisor whether the injury requires
medical treatment or first aid only.
9. From time to time, “Construction Company” reserves the right to perform periodic urine tests of
employees who occupy the following safety-sensitive positions:
All employees whose conduct on the job may affect their own safety or that of others, or whose
work is at any time subject to government regulatory requirements, which include, among others, the following assignments and activities:
Welding and cutting
Power transmission and electrical distribution
Scaffolding
Hazardous energy control (lockout and tagout)
Cranes, derricks, rigging
Excavations
Marine operations, diving
Floating plant and marine activities
Confined space operations
Pressurized equipment and systems
Steel erectionsWork platforms
Compressed air
Underground construction
Hazardous, toxic and radioactive Demolition waste activities
Contract diving operations
Cofferdams
HoistsMechanized equipment
Elevators and conveyors Caissons
Motor vehicle operation Blasting and use of explosives
Managers and supervisors of the any of the above assignments or activities. Employees subject to the
periodic testing program will be advised of the time and place of such tests.
Rehabilitation
Employees who test positive for any prohibited substance will be required to undergo a drug and alcohol evaluation performed through a “Construction Company”., health plan, Employee Assistance
Program (EAP), or other company specified professional organization. Following that evaluation, the
affected employee will be required to satisfactorily complete any recommended rehabilitation and/or
detoxification program. “Construction Company” will refer employees to local mental health agencies
and substance abuse counselors.
Following an employee’s return to duty after testing positive for a prohibited substance, the employee
will be required to undergo periodic urine testing and take part in any professionally recommended
substance abuse counseling for one year. Failure to participate in any such reasonably recommended
counseling or rehabilitation program, or failure to remain drug-free during the one year period following return to duty after a positive drug test will result in discipline up to and including termination.
194
Participation in an EAP is confidential, except as provided in this paragraph. The EAP will maintain
strict confidentiality concerning the fact and nature of the counseling or treatment, except when an
employee has been referred to the EAP by a manager or supervisor because of poor or deteriorating
job performance, or the supervisor’s concern over possible substance abuse problems. In the case of
such a supervisory EAP referral, the EAP may advise the manager or supervisor of the following information: the employee’s level of cooperation, progress in treatment, or need for job accommodation
during the course of counseling or treatment. In the case of an employee referred to the EAP because
of a positive drug test, the EAP may report to “Construction Company” whether the employee has
satisfactorily completed all recommended counseling or treatment. The fact that (prior to any positive
substance abuse test) an employee voluntarily has sought or obtained EAP counseling or treatment
for a substance abuse will not jeopardize employment or advancement, and, consistent with safety, “Construction Company” will take appropriate steps to accommodate the employee’s counseling,
treatment, and work needs. However, participation in an approved counseling or treatment program
will not insulate employees from any appropriate disciplinary action for pre-existing or continued unacceptable performance or “Construction Company” rules violations.
Required Cooperation and Compliance with Policy
As a condition of employment with “CONSTRUCTION COMPANY”, all employees must submit to,
and comply with, required drug testing procedures. All employees are expected to fully comply with instructions issued pursuant to this program. Failure to do so can result in discipline up to and including
termination, and employees refusing to submit to urine or blood testing as required will be considered
in violation of this policy, and will be subject to disciplinary action up to and including termination.
An employee who tests positive a second time following his or her return to work after completing a
required rehabilitation program will be subject to discipline up to and including termination.
Collection and Testing Procedure
The initial drug screening shall be performed on-site utilizing the Multi - Panel Drug Test by Rapid
Response. Should the initial drug screening results be positive using the Multi - Panel Drug Test by
Rapid Response, the specimen shall be forwarded to and performed by a laboratory accredited under
the National Laboratory Accreditation Program supervised by the National Institute on Drug Abuse.
The substances to be tested are those established by NIDA and the Department of Health and Human
Services (DHSS); the testing methodology shall be those employed by NIDA and DHSS; and the levels
of each drug and/or alcohol to be reported as positive are those adopted by NIDA and DHSS.
The costs of collection of the specimen and analysis of the specimen will be borne by “Construction
Company”.
Conclusion
Employee compliance with and adherence to this policy and program is a strict condition of employment. All employees are expected to comply fully and promptly with all instruction issued under the
authority of or by virtue of this policy and program. An employee’s failure to so comply may result in
administrative action up to and including termination of employment, depending upon the particular
situation, the employee’s present job assignment, the employee’s record with “Construction Company”
and other relevant factors.
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This policy and all conditions of it shall apply to all employees on any “Construction Company” property and/or jobsite. This policy will be posted at all “Construction Company” jobsites.
NOTWITHSTANDING ANY OF THE ABOVE, THIS MEMO IS NOT A CONTRACT OF EMPLOYMENT AND EMPLOYMENT BY “CONSTRUCTION COMPANY”IS STRICTLY “AT
WILL.” “CONSTRUCTION COMPANY”AND/OR THE EMPLOYEE MAY TERMINATE THE
EMPLOYMENT RELATIONSHIP AT ANY TIME.
________________________________
John Doe Dated: June 25, 2013
President and COO
“Construction Company”
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16
ACCIDENT INVESTIGATION
16.1 INTRODUCTION
Accident prevention is the number one goal of any organization. However, when an accident happens, proper investigation will help discover the accident causes, and implement corrective actions to
eliminate the deficiencies (causes) in the safety program to prevent future accidents. This chapter will
provide guidance based on industry best practices to:
• Develop an accident investigation program
• Prepare for an accident investigation
• Perform an accident investigation
For the purpose of this chapter, incidents are used to refer close calls or near misses, and accidents are
used to indicate unplanned events that result in fatal and non-fatal injuries, and property damage.
16.2 MAJOR COMPONENTS OF AN ACCIDENT INVESTIGATION (AI) PROGRAM
Every construction company should have a formal accident investigation program with procedures in
place for reporting all accidents and incidents involving their employees and the general public. At a
minimum, the AI program should include:
1.
2.
3.
4.
5.
6.
Purpose of the program
Emergency response
Reporting procedures
AI Kit
AI procedures
Periodic review of AI program to keep it up to date
16.3 PURPOSE
The AI program should clearly state the reasons for performing an investigation. The purpose of an
AI program is to:
Demonstrate management commitment to safety
Examine the facts and determine accident causes, and not to place blame on workers
Educate employees and management about the deficiencies that caused the accident
Take corrective actions that emerged from the investigation to prevent reoccurrence
Make changes to the safety program as part of a continuous improvement process
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16.4 EMERGENCY RESPONSE
Each project should develop an emergency action plan (EAP) before commencement of work. Contractors should ensure they comply with all applicable regulations pertaining to EAPs. According to
WAC 296-24-567, the following elements, at a minimum, shall be included in the plan:
ƒƒ Emergency escape procedures and emergency escape route assignments
ƒƒ Procedures to be followed by employees who remain to operate critical plant operations before they evacuate
ƒƒ Procedures to account for all employees after emergency evacuation has been completed
ƒƒ Rescue and medical duties for those employees who are to perform them;
ƒƒ The preferred means of reporting fires and other emergencies; and
ƒƒ Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.
Chapter 17 of this Handbook provides more detailed information about jobsite emergency response
and preparedness.
16.5 REPORTING PROCEDURES
What is the procedure to report accidents and incidents? Unreported accidents or incidents cannot be
investigated. Employees sometimes do not report accidents due to fear of punishment, peer-pressure,
etc. It is crucial that the project management take actions to promote good reporting from day one.
When employees report accidents no matter how small, give positive reactions, respond promptly and
get back to them with the actions taken. Furthermore, reporting accidents in case of an employee injury will help expedite medical care and any related workers’ compensation. Hence, accident reporting is
one of the most critical aspects of an AI program. Accident reporting typically comprises of internal
reporting and external reporting.
16.5.1 External Reporting
Government regulatory agencies such as L&I’s Division of Occupational Safety and Health (DOSH)
requires employers to report certain accidents to them within a set timeframe. In addition, other government agencies such as environmental or transportation agencies will have similar requirements.
Contractors should ensure they identify and comply with applicable regulatory reporting requirements.
It is best practice to ensure the program explicitly states “who” will make that phone call to these government agencies. Will it be the company safety director, project superintendent, or the project safety
manager? In addition, insurance companies would like to be notified about certain injuries that will
most likely trigger a worker’s compensation claim. In some cases, it is best practice to report an accident or incident to the company’s legal counsel or attorney if there is a potential for a lawsuit.
16.5.2 Internal Reporting
The AI program should clearly state project reporting requirements and communicate the requirements to the employees through site orientation and information signage at the site. The training
should include the benefits of AI, reporting requirements, preserving the accident scene, and emergency response. Ensure reporting requirements are identified for both the company and project level.
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Questions to consider:
ƒƒ What accidents and incidents (severity) should be reported (first aid, first-aid with offsite medical treatment, OSHA recordable, property damage, near misses, the general public related incidents and accidents)?
ƒƒ Who should be notified (project vs. corporate, company CEO, the project owner, etc.)?
ƒƒ What is the notification timeframe?
Note: The OSHA law prohibits employers from retaliating or discriminating against a worker for reporting an injury or illness.
It is best practice to require employees to report all accidents and incidents, no matter how minor, to
their immediate supervisor (typically a foreman) immediately. Employee injuries that will or may need
medical attention should be reported to the project superintendent immediately. Certain firms have
also required the project to report to their corporate office or even their Chief Executive Officer (CEO)
in case of OSHA recordable and lost-time injuries. Project owners sometimes contractually require
contractors to report OSHA recordable injuries and any significant incidents or property damage to
them within a set timeframe. Companies have found that making the project management report to the
owner or CEO has positive impacts on injury prevention.
16.6 ACCIDENT INVESTIGATION (AI) KIT
What is an Accident Investigation (AI) kit? What are the items that should be part of an AI kit?
When an accident happens, in most cases it is too late to prepare for an investigation. As part of the
project start-up procedures, it is best practice to assemble an AI kit also known as “grab-and-go” kit.
Ensure at least 2 or 3 kits are strategically placed on the jobsite. When an investigator receives a call
about an accident, s/he should be able to grab the AI kit and go to the accident scene immediately.
An AI kit will contain items an investigator needs to secure the accident scene, collect evidence, and
other relevant information. One can fill the kit with so many items, but some of the essential items that
should be part of this kit include:
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
ƒƒ
Accident Investigation Forms
Flashlights with extra batteries
Traffic candlestick and high visibility “accident scene” barrier tape to cordon off the area
Still Camera with fresh batteries
100 ft. tape measure
Clipboard with writing pad, pens, and pencils
Sturdy gloves
First aid kit
Digital voice recorder to dictate notes
Bottled water
Site emergency plan with contact numbers
Identification tags to mark evidence
Bio-Hazard Clean-up Kit
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16.7 ACCIDENT INVESTIGATION PROCEDURES
What is the accident investigation procedure? When developing your company’s AI procedure, the
following questions should be considered.
16.7.1 Investigator
Who should conduct the investigation? Obviously, this decision should be made before an accident
occurs. The project superintendent along with the project safety manager should conduct the investigation since they will be most familiar with site construction operations and will most likely implement
and follow-up on corrective actions. Depending on the severity of the accident additional members
might be part of the AI team. For example, if an accident involves an electrical circuit breaker, it is
best practice to engage the site electrical supervisor or contractor since s/he will be the subject matter
expert. No matter who is responsible the potential investigators should be trained in the following:
First aid/CPR
Emergency response
Reporting requirements
Secure the scene to avoid contamination
Collect evidence and facts including witness statements, pictures, measurements, etc.
Remember for serious accidents involving a notification to a regulatory agency, representatives from
the concerned agency will be onsite to conduct an independent investigation as well.
16.7.2 What accidents should be investigated?
Some companies will have different magnitude of investigations depending on the accident type. For
example, a minor first-aid accident might not need a full-fledged AI. It is best practice, however, to
investigate all accidents at some level and follow-up with corrective actions
16.7.3 AI Major Steps
What are the major steps involved in an effective AI? The following 8-step accident investigation process is recommended. ALL AI’S ARE FACT FINDING MISSIONS NOT FAULT FINDING.
1. Secure the accident scene
• Prevent additional accidents from occurring by ensuring there are no hazards in the scene.
• Care for the injured worker by providing first aid and medical treatment. Notify emergency
responders if needed.
• Secure the accident scene to prevent evidence contamination; unaltered accident scene will
help identify the accident cause correctly.
2. Collect evidence
• With the accident scene secure, the investigator should start gathering evidence immediately. In some cases, it is best practice to report an accident or incident to the company’s legal
counsel or attorney if there is a potential for a lawsuit. The attorney might provide some
advice on how to collect and save evidence belonging to subcontractors using chain of custody forms.
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• There are typically four sources of evidence:
Photograph evidence – take a picture of the entire scene, take pictures from all angles,
and take several shots of the scene in close range along with photos of all physical
evidence involved.
Paper evidence - collect all paper records associated with the accident:
οο Pre-task plan
οο Job hazard analysis
οο Training records of the associated employee
οο Inspection, maintenance records and operators manual for the associated
equipment
οο Safety Data Sheets of any chemicals involved
οο Site safety meeting minutes for two weeks before and after the accident
οο Disciplinary records of employees involved
οο Incident report
οο Witness forms
οο Accident scene sketch showing the location of the injured employee, witnesses, equipment, etc.
οο Police reports
οο Fire department reports
οο OSHA investigation records
οο Jobsite daily work record
People evidence – interview and record witness statements from everyone who saw
and were involved with the accident. In addition, interview everyone who were in the
vicinity of the accident before, during, and after the accident. Furthermore, project
superintendent, crew foreman, etc., should also be interviewed. Witnesses should be
separated prior to starting the interview process, and witness interviews should be
conducted with one witness at a time.
Physical evidence – review and collect equipment, tools, materials, and PPE, which
were being used at the time of the accident. All evidence collected should be labeled
accurately.
• Gathering evidence/facts from multiple sources will help the investigator re-create the accident sequence and determine why the accident occurred. Just collect the facts and do not
analyze or arrive at any conclusion during this step of the investigation.
3. Develop the sequence of events based on the evidence collected
4. Analyze the evidence
• The investigator should now begin to examine the evidence to answer the questions:
Why did the accident occur?
How did the accident occur?
What unsafe act(s) or unsafe condition(s) contributed to the accident?
• At the end of this step, the investigator should be able to identify the causes of the accident.
Most accidents have more than one cause.
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5. Develop and implement corrective actions – what does the investigator recommend to be done to
prevent reoccurrence?
• Develop individual corrective action for each cause identified in the accident investigation
• Ensure that the recommendations are very specific – what should be done to avoid reoccurrence of the accident.
• Identify who is responsible for assuring timely implementation and completion of corrective actions. For example, if a subcontractor’s employee was injured and the faulty process
that caused the accident is under the contractor control, the responsibility to change the
process to eliminate the accident cause should be placed on the subcontractor’s lead supervisor on site.
6. Complete AI report
• Prepare an AI summary report that should include the following information:
Accident description – when and where the accident occurred; who was involved;
what was involved, accident type and sequence of events.
Causes
Corrective actions and responsible parties
• Submit a report to the people who have the greatest control over the work involved. Typically it is best practice to set a deadline for this report. For example, the report shall be
completed and submitted to project management within five working days from the day of
the accident.
• Make sure all information in this report are accurate and are supported by facts and evidence, since when responding to lawsuits this report will be a major piece of proof used by
the plaintiff attorney.
7. Share lessons learned
• Review the corrective actions at the weekly safety meeting with all site employees.
• Develop a summary of the accident and share it across the company since other projects
within the company might have similar situations.
8. Follow-up on the corrective actions implemented
• It is critical to follow-up on the recommendations. Anecdotal evidence suggests, in construction, follow-up actions are not implemented properly.
• Has each of the corrective actions has been implemented correctly and completely?
• Do all the corrective actions are working? Do they address the need to prevent an accident
from happening again?
16.8 AI DOCUMENTATION
AI involves a lot of reporting forms. It is best practice to consider the Five Ls when creating accident
report forms,1 consider the five Ls (see sample near miss report form in Exhibit 16-1):
1 Williamsen, M. (2013). “Near-Miss Reporting – A Missing Link in Safety Culture.” Professional Safety. P 46-40. May 2013
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•
•
•
•
•
Literacy. Are forms easy to read and understand?
Language. Does the company provide forms in multiple languages if necessary?
Length. Are the forms short and to the point?
Location. Are they easily accessible to workers?
Logistics. Do they enable solutions?
What are the typical forms used as part of the AI process?
• Employee accident report or Supervisor Statement – This form is used to collect information
about the incident and is usually filled out by the injured employee’s immediate supervisor.
• Witness Statement Form – This form is used to record written statements from the witnesses.
• Accident Investigation Form or Incident Review Form – This form is typically utilized by the
investigator to perform a systematic review of the accident, identify causes, and recommend
corrective actions.
• Medical Care Provider Return to Work (RTW) Recommendation Form – This form is used
by employers to communicate to the medical provider that they have a formal return to
work program in place and will work within the restrictions recommended by the medical
care provider.
• Some companies have developed and used forms such as:
Injured worker’s statement
Near miss report
First-aid injury report
Property damage report
Vehicle accident report
Theft/vandalism report
16.9 AI PROGRAM REVIEW
Why should a company periodically review its AI program to keep it up to date? An accident investigation program is critical to the success of any construction safety program. As part of a continuous
improvement process, the AI program should be continuously reviewed and changed to address any
inefficiencies in the process or to include new industry best practices. At a minimum, a review of the
AI program is recommended every two years.
Additional Resources, Readings, and References
Division of Occupational Safety and Health (DOSH). L&I offers free workshops including Accident Investigation Basics. http://www.lni.wa.gov/Main/WorkshopsTraining/ (Accessed January
2015).
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Exhibit 16-1: Near Miss Incident Report Template
A near miss or a close call is an incident that has not resulted in any injury or illnesses. It is every
worker’s responsibility to report near misses. Please complete this report near miss incidents.
Project Name: ________________________
Employee Name: ______________________
Project ID: ______________________
Company Name: _________________
Date: ________________________________
Time: _____________ am / pm
Incident Location: _____________________________________________________________
Description of near-miss incident:
Immediate Action Taken:
Suggestions to prevent reoccurrence:
NEAR MISS INVESTIGATION:
Causes:
Corrective Actions Recommended:
1.
2.
3.
File original in project safety records
Date Completed
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Signature
Exhibit 16-2: Accident Report Template
Project Name:
Occupation:
Project ID:
Injured Employee’s Name:
Company Name:
Accident Date:
Date Employee Reported:
Injury Time:
am / pm
Accident Location:
Witnesses of Accident (written statements must be attached):
Witnesses Name
Phone#
Company
1
2
3
Description of the Accident (include all details is possible, use additional sheets if necessary)
Description of the specific nature of the injury (include specify body part(s) and type of injury)
Was there property damage involved?  No  Yes [If yes, describe damage]
OSHA Notified?  Yes  No  Not Required
Was Transportation to a medical facility for medical treatment required? o Yes o No
Transported by Ambulance/Paramedics
Transported or Self Transported to Clinic
Others ___________________________
Did the Injured employee return to work?  Yes  No What date and time?
What is the current work status of the worker?
 Released to Full Duty
 Lost Time
 Modified Duty
 Hospitalized
 Unknown
Describe the work restrictions?
Supervisor Signature:
Date:
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Exhibit 16-3: Witness Statement Template
Project ID:
Project Name:
Injured Employee’s Name:
Phone#:
Witness Name:
Company Name:
Witness Occupation:
Accident Date:
Date Employee Reported:
Injury Time:
Accident Location:
Did you witness the event?  Yes  No
What activity were you performing prior to the accident?
Were any other workers in the immediate area at the time of the accident?  Yes  No
am / pm
If yes, who?
Where were you located when the accident occurred?
Describe fully how the accident occurred:
Describe bodily injury sustained (be specific about body part(s) affected:
What happened immediately after the accident?
I am submitting this statement of my own free will. I have not been coerced or threatened in any
way to submit this statement. To the best of my knowledge, all information in this statement is true.
_____ (Initial)
Witness signature
Date
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Exhibit 16-4: Example Accident Investigation Form (1-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (2-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (3-17)
(Used by Permission from PCL Construction Services, Inc.)
209
Exhibit 16-4: Example Accident Investigation Form (4-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (5-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (6-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (7-17)
(Used by Permission from PCL Construction Services, Inc.)
213
Exhibit 16-4: Example Accident Investigation Form (8-17)
(Used by Permission from PCL Construction Services, Inc.)
214
Exhibit 16-4: Example Accident Investigation Form (9-17)
(Used by Permission from PCL Construction Services, Inc.)
215
Exhibit 16-4: Example Accident Investigation Form (10-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (11-17)
(Used by Permission from PCL Construction Services, Inc.)
217
Exhibit 16-4: Example Accident Investigation Form (12-17)
(Used by Permission from PCL Construction Services, Inc.)
218
Exhibit 16-4: Example Accident Investigation Form (13-17)
(Used by Permission from PCL Construction Services, Inc.)
219
Exhibit 16-4: Example Accident Investigation Form (14-17)
(Used by Permission from PCL Construction Services, Inc.)
220
Exhibit 16-4: Example Accident Investigation Form (15-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (16-17)
(Used by Permission from PCL Construction Services, Inc.)
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Exhibit 16-4: Example Accident Investigation Form (17-17)
(Used by Permission from PCL Construction Services, Inc.)
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17
CONSTRUCTION SITE EMERGENCY MANAGEMENT
17.1 INTRODUCTION
In spite of proper jobsite safety pre-planning, construction sites face the possibility of numerous jobsite emergencies. Examples of events that can cause jobsite emergencies can include:
Workplace fatalities (work-related, worker suicide, heart attack)
Severe multiple injury accidents
Workplace violence
Structural collapses
Bomb threats
Fire and explosions
Hazardous chemical releases
Inclement weather/natural disaster scenarios (e.g., earthquakes, floods, hurricanes, tornadoes)
17.2 EMERGENCY ACTION PLAN (EAP)
Contractors should ensure they comply with all applicable regulations pertaining to EAPs. According
to WAC 296-24-567, the following elements, at a minimum, shall be included in the plan:
Emergency escape procedures and emergency escape route assignments
Procedures to be followed by employees who remain to operate critical plant operations before they evacuate
Procedures to account for all employees after emergency evacuation has been completed
Rescue and medical duties for those employees who are to perform them
The preferred means of reporting fires and other emergencies
Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan
17.3 EMERGENCY MANAGEMENT BEST PRACTICES
The primary objective of this section is to help employers prepare for the emergencies their jobsites are
most likely to encounter, using industry best practices. Contractors should ensure they comply with all
applicable regulations pertaining to EAPs.
17.3.1 Assign EAP Responsibility
The EAP should be developed, overseen, frequently reviewed and updated by the controlling contractor. The EAP should be comprehensive in nature to deal with all types of emergencies that can be
expected. The controlling contractor should include emergency response related requirements in their
contract with their subcontractors. The contract should call out the provision of emergency response
equipment, identification of qualified first aid personnel, and participation in EAP training/drills. The
EAP should be reviewed at the pre-construction meetings with the subcontractors and their tiers.
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17.3.2 Designated Site Emergency Coordinator (SEC)
The project should establish a chain of command to minimize confusion during emergencies. Prior to
the start of construction operations, the controlling contractor should designate a Site Emergency Coordinator (SEC), who has the authority for making decisions during emergencies. Typically the Project
Superintendent will be designated as the primary SEC. However, it is impossible for the primary SEC
be onsite at all times. Hence, it is recommended to select and train a sufficient number of secondary
SECs. At any given time when work is taking place on the site, one of the SEC should be available on
site. The SEC should be responsible for all pre-emergency planning tasks before the commencement
of any work on the site. The SEC should be responsible for developing, frequently review, and update
the site’s EAP. The SEC should review changing site conditions in relation to the EAP and update it
if needed after completion of:
Substructure (e.g., concrete slab on grade is completed)
Superstructure (e.g., building top-out)
Exterior skin
Interior finishes
Access/egress changes
Some of the other SEC responsibilities are addressed in each of the sections below.
17.3.3 Identify the various types of potential Site Emergencies
The SEC in collaboration with the site supervision, and the owner or client in an existing facility
should first determine the anticipated types of site emergencies. Emergencies can vary from project to
project based on various factors such a location, project type, etc. For example, a contractor building
a 50-story building with a tower crane should plan for medical emergencies situations involving the
tower crane operator (heart attack) or a potential tower crane failure. Similarly, a contractor working
in the Midwestern Untied States should plan for tornados. A few examples of emergencies that can be
triggered by specific construction operations can include:
Trench collapse
Formwork collapse
Confined space-related incidents
Electrical shocks or burns
Power line contact
Crafts suspended from fall arrest systems
Incidents involving the general public
17.3.4 Develop a Construction Site Logistics Map (CSLM)
A CSLM is typically required for large or complex construction sites, with the primary objective to
assist with site logistics, but it will also be a great communication and planning tool during emergency situations. Using the sitemap, include the following key components in the CSLM:
Site address
Internal and external traffic flow (truck routes, pedestrian path, etc.)
Construction vehicle and craft parking
Site fencing
Access gates
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Temporary project-related facilities including job trailers, garbage dumpsters, recycling bins,
lunch tent, and sanitary facilities
Staging/lay down areas
Material storage area including flammable/combustible materials and compressed gas cylinder
storage
Material handling equipment including cranes and their swing radius, construction hoists,
and concrete pump truck locations
Emergency phone location
Main power supply disconnect location
Emergency vehicle access
Emergency evacuation routes
Emergency assembly areas
Emergency meeting point, where the responders will meet the site SEC or designee
Location of emergency equipment and supplies including first aid kit, fire extinguisher, eyewash, emergency shower, Automatic External Defibrillator (AED) equipment, potable water,
and blood-borne pathogen kit.
Major utility lines (underground and overhead)
Firefighting equipment including standpipes and hydrants
Emergency shelters for events such as a tornado, high wind, etc.
Figure 17-1 Example Construction Site Logistics Plan (Picture Courtesy BNBuilders)
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17.3.5 Train the workers on the EAP and CSLM
The CSLM along with the site EAP should be reviewed with the workers during site orientation, or
even posted at the orientation location. The EAP should be reviewed with the workers whenever the
site conditions change in relation to the EAP. The weekly site safety meetings and daily tool box meetings can be used for this training.
17.3.6 Identify Emergency Assembly Area
Emergency assembly area is a predetermined location or locations, where site personnel will gather
in case of an emergency. The assembly area should be determined and identified in the EAP and the
CSLM. All employees should be advised of these emergency assembly points at their new employee
safety orientation, and again when any change in location is made. Assembly areas may include parking lots, staging areas, etc. The emergency assembly area should:
Be equipped with an “emergency assembly area” signage
Be located away from the site entrance/egress points
Be sufficiently illuminated
Be kept clear of debris, materials, and equipment
Not be a parking space for equipment or staging for materials
Be frequently inspected by the SEC to ensure it is clear
17.3.7 Procure and Maintain Emergency Equipment and Supplies
The SEC should ensure the following emergency equipment and supplies are available on the site and
are in good working condition. The equipment and supplies should be strategically placed across
the site as the project progresses. The SEC should be responsible for inspecting and maintaining this
equipment per manufacturer recommendations and regulatory requirements. For example, a monthly
and annual inspection of fire extinguishers is required. Many times workers use fire extinguishers to
put out minor fires but never report it to their supervision. A discharged fire extinguisher will be of no
help during emergencies. Also, some supplies come with an expiration date. The site emergency equipment and supplies should include at a minimum:
Specialized personal protective equipment
Rescue equipment
Flashlights
Emergency notification alarm systems such as air horns
Eyewash stations
Emergency shower
Sufficient number of First Aid kits
Adequate number of Bloodborne pathogen kit
Fire Extinguishers – in sufficient quantities and classes (A, B, C, D, K) depending on the site
hazards
Portable Automatic External Defibrillator (AED)
Fuel-powered generators
Food and water (shelter in place)
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17.3.8 Procure and Maintain Communication Equipment
One of the critical components of an EAP is having the appropriate communication equipment on
site. The SEC should determine what communication equipment is needed and have them available
on site such as weatherproof two-way radio, cell phones, and air horns. The SEC should also consider
the potential failure of these equipment during an emergency. How will the project communicate if
the phone lines are down? What are the different offsite communication equipment available such as
nearest landline telephone, cell phone, etc.? These communication equipment are essential during
emergencies to communicate to the site workers, and also with external agencies such as corporate
office, police, Red Cross, ambulance, and fire department.
17.3.9 Establish Emergency Escape Procedures and Routes
The SEC should identify escape procedures (for all anticipated site emergencies) and escape routes
of evacuation. In the case of renovation work taking place within a building, emergency exits must
be adequately marked, kept clear, and doors should be unlocked. It might be essential to collaborate
with the owner or client while working on existing operating facilities such as hospitals, manufacturing
facilities, airports, etc., to ensure everyone is on the same page with emergency escape procedures. In
addition to the structure being built, job site trailers should also be included in the EAP. Post exit signs
above exit doors and keep exit areas clear.
17.3.10 Establish Warning (Alarm) Systems
A good job site emergency alarm system should be established that is distinctive and recognizable as
a medical emergency signal, an evacuation signal or to perform actions as designated in the EAP. An
alarm should be audible above normal construction site noise. Examples of alarm systems used by
construction companies:
Three short blasts of the air horn are used for medical injuries
One long blast of the air horn is used for other evaluations such as fire, etc.
Use existing owner/client alarm system
17.3.11 Establish Evacuation Procedures
The EAP should include evacuation plans for the various types of emergencies expected on the project. The evacuation plans should include special procedures that the employees should follow before
evacuation such as shutting down utilities or securing equipment that can pose a hazard to emergency
responders, or create further damage to people and property. When in doubt workers should be trained
to evacuate.
17.3.12 Develop Emergency Reporting and Response Procedures
The SEC should include proper reporting procedures for various emergency procedures in the EAP.
The reporting procedures might vary depending on the emergency. For an onsite serious medical emergency (life threatening injuries), the reporting procedure for your workers will be something similar to
below:
Call 911 immediately – All workers should be prepared to share the following information
with the dispatcher:
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οο
οο
οο
οο
Site address
Emergency meeting point
Caller name and phone number
Location of the incident within the site - On large projects it is best practice to number
each floor, stairtowers, elevators, hoists, etc., so workers can share a precise location with
the dispatcher.
οο Incident type
Notify your immediate supervisor right away either by phone or radio who will notify the
SEC or his designee
Make sure the area is safe, if unsafe leave the area immediately – do not risk your safety
Render first aid as necessary to the victim
Train the employees during site orientation on how to distinguish between routine first aid cases and
when emergency (911) calls are to be made. Ensure, alternate phone numbers, are identified in case
the 911 system is inoperable or overwhelmed.
17.3.13 Establish a Procedure to Account for Employees After Evacuation
All site personnel should stop work, secure their work area/equipment, and congregate at the emergency assembly upon hearing the emergency alarm for evacuation. Instruct the workers, not to leave the
assembly until directed by the SEC. It is important that all site personnel have been accounted for after
an evacuation. It is a challenging task on construction sites because of the number of subcontractors
performing work at any given time. A procedure should be developed in advance for accounting site
personnel during the evacuation. It is best practice to ensure all the subcontractors on the site keep a
daily personnel list using their daily work record or job diary. This list can be used by the contractors
to check names against workers gathered in an emergency assembly area. After which, the subcontractor representative should report to the SEC/general contractor with the names and the expected locations of the missing personnel. Ensure the site have employees with multilingual skills or sign language
to help with translation in an emergency.
For security, legal, and public relations needs, consider the following guidelines for employee conduct
during an evacuation or emergency:
•
•
•
•
No cell phone use except for company business
No cameras or other recording mediums to be used
Only a designated company spokesperson will engage outside interests (i.e. media)
Only leave the evacuation area upon direction of the SEC
The SEC or designee should remain on the site after the site has been evacuated (if deemed safe) to
assist emergency responders. The SEC or designee will advise them of the nature and location of the
emergency, and explain any ongoing or potential hazards. In the event of a medical emergency, the
project should identify an individual in advance, and train that person to meet and direct emergency
service vehicle to the emergency scene.
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17.3.14 Identify and train personnel with rescue and medical duties
The project should try to create an emergency response team if possible, comprised of the primary and
secondary SECs. It is best practice to pick one member from each subcontractor on site with varying
expertise (e.g., electrical, crane, etc.). Select members who are physically capable of performing emergency response duties. These members should be trained in the use of fire extinguishers, first aid and
CPR, AED, evacuation procedures, emergency equipment shutdown procedures, and other rescue
equipment. Each subcontractor on the site should have at least one person designated as their first aid
responder. Readers are encouraged to review the “Best Practices Guide – Fundamentals of a Workplace First-Aid Program” developed by OSHA1. It is a best practice that at least the site supervision,
Foreman and above are trained in first aid, CPR and the use of AED.
17.3.15 Publish Emergency Contact Information
As part of the EAP, the site should create an Emergency Contact List that shall be kept current.
The emergency contact list should be posted throughout the job site in prominent locations.
The list should include the following information and contacts:
1. Site Contacts
o General Contractor Site Supervision and Safety
o Subcontractor Lead Supervisors and Safety
o Site Emergency Coordinator (SEC) and backup
o Site Emergency Response Team (if applicable)
o Site Nurse (if applicable)
o Project Owner Representatives
2. Fire
3. Police
4. Medical
o Ambulance
o Occupational Medical Clinic
o Hospital
o Urgent Care Clinics
o Poison Information Center
The following information can be developed and maintained at the job site that can be used during
the crisis.
5. Corporate office contacts
o IT personnel
o Yard/warehouse personnel
o Corporate/Legal Counsel
o Corporate Spokesperson
1 Occupational Safety and Health Administration (OSHA). Best Practices Guide: Fundamentals of
a Workplace First-Aid Program. https://www.osha.gov/Publications/OSHA3317first-aid.pdf
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6. Employee Assistance
o Grief Counseling
7. Utility Companies – electric, gas, phone, water, sewage, traffic signal repair
8. 24-hr Security firms
9. American Red Cross
10.Government agencies
o DOSH
o OSHA
o EPA
o DOT
o MSHA
o HazMat
11.Regular transportation
12.Medical transportation services
17.3.16 Share the site EAP with local responder
Once the EAP is complete, the SEC should contact the local police, fire, and ambulance service to
set up a pre-planning meeting with them at the job site. Share the Construction Site Logistics Map
(CSLM) with them. Ensure that the responders become familiar with your job site including:
Access routes
Project work hours, schedule, and main contacts
Evacuation procedures
Anticipated types of site emergencies
Rescue type (confined space, tower crane, trench collapse)
Hazardous materials storage area
Closest hospital locations
Remember not all fire stations are equipped with equipment and expertise to respond to all types of
rescues. It is better safe than sorry to plan these high-level rescues, such as tower crane rescue and
identify how long will it take for trained rescue personnel to reach your site.
17.3.17 Conduct Emergency Drills
The site EAP should be rehearsed before construction operations begin. An emergency drill should
take place to ensure the plan is working and fixing any inefficiencies. Construction site changes every
day and its activities are fast-paced; hence an emergency drill is recommended at least twice a year
when there is a major change in conditions in relation to the EAP.
17.3.18 Maintain good housekeeping
One of the best preparation for emergency response is to maintain an organized job site including
good housekeeping and proper access/egress (not obstructed) to work areas – at all times. During an
emergency response, these two factors matter a lot for a timely response to the injured worker.
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17.3.19 Be Ready to address the media
It is critical to plan to address the media during a crisis. The site should designate a spokesperson to
coordinate all contact with the media and other external entities that might be interested about the
emergency. Ensure the designated spokesperson is trained on how to communicate with the media.
Make sure there are adequate backup spokesperson readily available to address the media if needed.
Additional Resources, Readings, and References
OSHA’s Principal Emergency Response and Preparedness Requirements and Guidance - www.osha.gov/Publications/osha3122.pdf
OSHA’s Emergency Action Plan Expert System - www.osha.gov/SLTC/etools/evacuation/expertsystem/default.htm
Best Practices Guide – Fundamentals of a Workplace First-Aid Program developed by OSHA www.osha.gov/Publications/OSHA3317first-aid.pdf
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18
EMPLOYEE RECOGNITION PROGRAM
18.1 INTRODUCTION
This chapter provides guidance to contractors on how to implement a successful employee recognition
program to improve project safety performance. Typically the two things that come to mind when discussing employee recognition are progressive discipline and incentives.
18.2 CREATING A DISCIPLINE POLICY IN CONSTRUCTION
Construction firms have used a progressive disciplinary procedure as a safety performance improvement tool for years. Employees who violate any applicable federal, state, or local safety regulations,
company policies, and owner requirements may be subjected to progressive discipline. Within traditional company’s discipline policies, the word “discipline” is often interpreted in the employee’s mind
as a form of punishment for violating a safety rule and the resulting consequences ranges from a verbal
warning to immediate termination from the project. Typically a three-step progressive disciplinary process is used for all employees violating safety rules and regulations pertaining to the project:
First Violation = Verbal Warnings. Usually, a verbal warning involves an informal discussion
between a supervisor and the employee about the unsafe behavior. This discussion provides a
teaching opportunity for the supervisor, and also a good chance for the employee to correct the
behavior. The supervisor typically gets assurances from the employee that it will not happen
again. A verbal warning should be documented in the project daily work record or a separate
form.
Second Violation = Up to three-day suspension from project and supervisor receives verbal
warning. A second violation involves the issuance of a written safety violation notice to the
employee with specifics about the unacceptable behavior or safety policies violated. It may
also include the employee’s direct supervisor receiving a verbal warning. Some companies set
some timeline such as,“a second violation within six months of the first violation will result in
an automatic 3-day suspension without pay.” The written notice documents the fact that crafts
were given the opportunity to correct their behavior, if not additional actions might be taken
including termination.
Third Violation = Termination of employment or removal from the project for subcontractor
employee. It may also include the employee’s direct supervisor receiving a three-day suspension.
Sometimes a contractor’s direct employee or subcontractor employee might be terminated with
a “permanent ban” (ineligibility for future employment on all Projects) for serious violations.
This also involves the issuance of a written safety violation notice to the employee with specifics
about the unacceptable behavior or safety policies violated.
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Zero Tolerance. Most companies have a list of zero tolerance violations where the employee is
terminated from the project and/or employer immediately. Zero tolerance items involve unsafe
behavior or condition that could lead to serious injuries, death, property damage, or major
business interruptions. Examples of zero tolerance items include but is not limited to:
1. Fall Protection
2. Confined Space
3. Trenching and Shoring
4. Energized Electrical Work (EEW)
5. Employees willfully creating a hazardous condition
6. Employees purposely causing an injury to another person
7. Employees failing to report incidents
8. Possession of firearms, unless allowed by the jurisdictional authority
9. Bomb threats
10.Unauthorized access/modification to a red flagged (Danger) area
11.Violation of the Lock Out/Tag Out procedures
12.Operating equipment without proper authority or qualifications
13.Failure to utilize proper sanitary facilities
A sample progressive disciplinary action matrix is provided as an Exhibit in 18-1. Other items to consider as part of a progressive disciplinary policy are:
The company should create a written progressive disciplinary policy. Poorly written policy can
lead to confusion and potentially lawsuits for violating employee rights. Allow some flexibility
in the policy so employers can have some discretion in enforcing this policy.
Train all employees on the policy during project site orientation. Include the policy in the employee handbook or similar documents, since it makes it easier for employees and supervisors
to refer them.
Train all supervisors in the means and methods to enforce the policy. The supervisor training
should include ways to confront the violator, how to be consistent in the judgment, how to retrain/teach them, and documentation procedures.
A disciplinary action should take place immediately after all the facts are known.
Document all disciplinary measures (see Exhibit 18-2 and 18-3 for example form and log).
Re-train all employees receiving a disciplinary action.
Maintain the worker’s information anonymous, discuss the violation in the weekly safety
meeting.
Even though companies use the progressive disciplinary program, human factors in behavioral science
suggest that to have a truly effective safety culture, a paradigm shift is needed. The shift needed comes
with using a synonym definition of the same word, and that is “teach.” Following this thought then,
as project management, the supervision role coincides with the root word of discipline - “disciples”,
further defined as “teacher.”
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18.3 DISCIPLINE (TEACHING) PARADIGM SHIFT
In deferring back to discipline under the “teacher” thought process, when it is required due to a serious or imminent danger safety infraction, following the best practices listed below will help make the
process more effective.1
Make sure the teaching opportunity occurs Soon after the incident. Waiting until the end of
the shift lessons the impact of the teaching moment and employees may not learn from their
actions.
Make sure the teaching opportunity is Certain – The employee needs to understand what specific behavior resulted in the consequence. Discipline is not effective when administered for
“poor attitudes,” or lack of “common sense.” Be specific!
Make sure the teaching opportunity is Significant – Consequences do not change behaviors
unless the employee perceives them as important. The significance of a consequence is determined by the receiver (verbal warning, a mug or hat, being sent home).
Make sure the teaching opportunity is Sincere – Appropriate motives for administering discipline an awarding positive recognition are important to the effectiveness of a consequence. Be
fair to all employees and be consistent. You should not reprimand one person and ignore others for an action that is done by many. On the same note, you should not discipline someone
for an action on Monday and walk past it on Friday.
Again, improving the recognition program in the workplace is one of the easiest ways to reduce losses.
The process is simple, especially once you’ve made recognition a habit.
18.4 EMPLOYEE RECOGNITION
On the other end of the spectrum is a positive recognition policy. Coinciding with this shift in traditional thought, employee recognition becomes a critical component to the point where discipline, as
it is known today, may become nearly unnecessary. It is simple, when workers are made aware of their
expectations and spontaneously recognized in a positive way by project management, there becomes
a direct correlation to reductions in traditional discipline - coinciding with overall reduction in injury
rates. After all, isn’t that the main goal in the first place?
When asked the question “What’s the most common supervisor response to good or safe work?”
The typical action is to ignore it simply!2
How many times do we walk by someone doing something the correct way without saying a word?3
1 Stoll, L (2013). Discipline and Recognition. Risk Management Blog. http://mysafetynews.com/discipline-and-recognition/
(Accessed December 4, 2014).
2 Stoll, L (2013). Discipline and Recognition. Risk Management Blog. http://mysafetynews.com/discipline-and-recognition/
(Accessed December 4, 2014).
3 Stoll, L (2013). Discipline and Recognition. Risk Management Blog. http://mysafetynews.com/discipline-and-recognition/
(Accessed December 4, 2014).
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By simply changing our daily interactions with people and starting to focus on the good rather than
the bad, we can reduce unsafe behaviors thereby improving productivity, profit and people’s attitudes
that reduces both the need for discipline and again, gives the incentive to perform work safe – thus
reducing the opportunity for injury. This is not to suggest teaching opportunities will never exist, but
creating a culture where employees are recognized in a way that fosters willingness on the employee’s
part toward positive recognition – whatever that looks like, reduces the likelihood discipline will be
needed.
“We are all motivated in different ways – some by internal rewards such as a sense of accomplishment,
helping others or doing a good job whereas others through external rewards such as receiving a monetary
or non-monetary (i.e. recognition by co-worker). Rewarding employees does not have to be time-consuming or expensive. Often, the simplest acts of rewarding go a long way to improving supervisor-employee
relations. Below are some examples of how rewarding can be easy and effective:4
Name posted on bulletin board, written up in the newsletter
“Safety Hero” certificate for complying
An entry into employee’s file (performance appraisal)
Safety bucks. When you catch someone doing something right
Formal recognition by the owner (not mid-level manager)
A simple “Thank-you” as you walk past!”

Construction companies should also consider the following best practices when developing their recognition/incentive programs:
Never tie your recognition to lagging indicators such as the number of days without a recordable or lost time injury. It can lead to underreporting and could lead to many accidents going
uninvestigated. This could lead to major incidents in the future.
Provide an incentive or recognize employees using leading indicators such as:
οο Crew recognition of the good development and implementation of their pre-task plan.
οο Crew recognition for their good housekeeping practices identified using management
inspections.
οο Crew recognition for “zero” unsafe acts or conditions associated with the crew.
οο Individual recognition for development and implementation of innovative safety practices or procedures.
As with discipline, recognize your employees promptly.
Recognize employees with an appreciation lunch rather than tying lunches to milestones such
as days without injuries, which again can lead to underreporting.
4 Stoll, L (2013). Discipline and Recognition. Risk Management Blog. http://mysafetynews.com/discipline-and-recognition/
(Accessed December 4, 2014).
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18.5 REGULARLY RECOGNIZE AND REWARD AND YOU’LL RARELY HAVE TO
REPRIMAND5
Combining these two schools of thoughts (recognition and discipline) into a Best Management Practice (BMP) can perhaps be better described through the “Carrots or Sticks” scenario.
The expression “carrot or sticks” refers to a system of recognition and discipline that will result in desired behaviors. The expression is best known for the example of a farmer dangling a “carrot” from a
stick in front of a donkey so the donkey will move forward and pull a cart. Dangling the carrot from
the stick motivates the donkey to work. Sticks, in the traditional sense, can be used to discipline the
donkey by swatting it if the carrot no longer serves as a motivator to perform; however, in the paradigm shift model, discipline is now used as a teaching and learning opportunity.
5 Stoll, L (2013). Discipline and Recognition. Risk Management Blog. http://mysafetynews.com/discipline-and-recognition/
(Accessed December 4, 2014).
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Focus Point /
Incident
Worker
Worker’s Direct
Foremen
Worker’s Direct
Superintendent
Prime
Contractor’s
Superintendent
Exhibit 18-1: Example Progressive Disciplinary Action Matrix
1st Violation
2nd Viola3rd Violation
Note
tion
Verbal &
3 Days
Removed From Projects For
Written Notice Off
One Year
Written Notice Written
3 Days Off
3 Worker Layoffs
Notice
= Removal from
Projects for one
year
Written Notice Written
Written Notice to Sub/Prime
3 Worker Layoffs
Notice
Superintendent and President = Days Off for
Superintendent
of Subcontractor/Company
Written Notice Written
Written Notice to President of 3 Worker Layoffs
Notice
Prime Contractor Company
= Days Off for
Superintendent
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Exhibit 18-2: Example Written Safety Violation Form Template
Project Name: ______________________________ Project ID: ______________________________
Project Location: ____________________________________________________________________
Employee Name: ___________________________________________ Last 4 of SSN: ___________
Did employee go through new employee orientation? Yes No When? ________________
Employer: __________________________________________________________________
Employee’s Direct Supervisor: __________________________________________________
Details of Safety Violation (include location of infraction, policy violated, date, time):
Previous History (describe of earlier verbal warning if applicable):
Type of Violation:
First Written Warning Violation
First Written Warning Violation with ____ days ineligible to work on this project
Second Written Warning Violation (termination from this project)
Permanent Termination or Permanent Debarment from all company projects.
Warning Issued By: __________________________
Title: ________________________
Employee Signature:________________________
Date: ________________________
CC: Employee
Employee’s Director Supervisor
Company Safety Department
241
242
Exhibit 18-3: Worker Verbal/Written Warning Log
PROJECT NAME:
PROJECT NUMBER:
THIS LOG IS CONFIDENTIAL. IT SHALL BE SECURED AND ONLY UTILIZED FOR PROJECT MANAGEMENT
DATE
TIME
WORKER’S
COMPANY
DESCRIPTION OF VIOLATION
WARNING BY
NAME
19
RETURN TO WORK PROGRAM MANAGEMENT
19.1 INTRODUCTION
Returning injured workers back on the jobsite, even in a limited capacity, carries significant benefits
for the affected employee and the employer. The employee benefits include higher morale and minimal income loss, and return to regular duty faster, and the company benefits include lower workers
compensation claim costs, and reinforces commitment to worker’s well-being. A win-win situation for
everyone. Many employers, especially smaller contractors, are unprepared to deal with returning their
employees to the jobsite. This chapter provides step-by-step best practices to implement an effective
RTW program.
1. Create a written RTW policy that shows employer’s commitment to return an injured worker to
work as soon as possible and offer light-duty or transitional jobs during the injured worker’s recovery process.
2. Designate an RTW coordinator within the company (or project) to oversee the program. In most
cases, this task will be managed either by the safety manager or claims manager.
3. Identify the roles and responsibilities of all parties who will be involved in the RTW process, including workers, supervisors, medical providers, and insurance carriers.
4. Develop regular job functions for each trade that the company employs, ahead of time. It should
include the specific routine job functions, physical demands of the tasks, and the approximate time
spent on each task per day. For example, a structural concrete contractor should have regular job
description/functions for laborers, finishers, and carpenters. It is also a best practice to establish
“modifications” for various job categories to allow injured workers to return to work while recovering.
5. Consult with the company legal counsel before finalizing your RTW policy. The Americans with
Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA) may impact RTW policies,
and it could vary from state to state. Most contractors perform work in multiple states. Hence, this
is an important step, to ensure the company complies with all applicable state and federal disability
laws while dealing with disabled workers.
6. Communicate the company’s RTW policy to the workers using the site orientation training. Explain
the benefits of returning to work early and the opportunities available to them during recovery.
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7. Train site supervisors and managers (foreman and above) about the company RTW policy and how
to return their workers to the job as soon as possible. Obtain a commitment from Project Managers
and Project Superintendents about the RTW program.
8. Establish an injury reporting system for the jobsite. Encourage workers to report all injuries immediately no matter how minor, even if the injury did not require offsite medical attention. In most
cases the earlier the employer, medical provider, and the insurance carrier, starts working with the
affected employee, the earlier the worker can recover and return to work.
9. Set up a medical facility near the project. Choose a medical provider who understands the construction industry, the diverse trades involved, their tasks and the physical demands required to
complete the tasks and the post-injury management process. Meet with the provider in advance
and educate them about the company’s RTW options for an injured worker. Note in some states
employers cannot direct employees to the medical facility of their choice; beware of these employee
rights. See chapter 9 of this handbook for more information.
10.Set up the jobsite for an efficient accident response. Accident response includes providing immediate assistance to the affected worker and transporting the worker offsite for medical treatment.
11.Assemble an accident response packet that includes accident investigation forms, RTW forms, regular job function description, and insurance information that the worker can take to the medical
provider.
12.Start the accident investigation to find out what happened, why it happened, and what should be
done to make sure the accident does not reoccur. Refer to Chapter 16 of this handbook for more
information on how to conduct an accident investigation.
13.Transport the worker to the medical facility, in most cases, the workers’ immediate supervisor or
project safety manager will accompany the worker. Inform the injured worker’s family members to
keep them in the loop. It can be used as an opportunity to reinforce the company’s commitment to
the employee.
14.Notify the company’s workers compensation insurance company as soon as possible. Some companies have an internal claims manager, in that case, notify that person. A timely notification will
allow the insurance carrier to assist both the affected employee and the employer.
15.Provide the worker’s regular job functions to the treating physician and discuss your company’s
RTW policy (see Exhibit 19-1 for example).
16.Obtain a work release from the medical provider before the employee returns to work, that clearly
specifies the information about restrictions on the job and at home. Remind the employee to comply with the limitations. The restrictions may limit certain activities (e.g., no lifting anything over 20
pounds, cannot stand more than 3 hours in a day, etc.). It might also sometimes limit the number
of hours a worker can work on the site. Sometimes the restrictions might require the employee to
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be transferred to the corporate office setting or a warehouse. For example, Labor and Industries
uses an activity prescription form (APF), as a best practice in occupational medicine. The form
communicates an injured worker’s physical restrictions and ability to work as well as the provider’s
treatment plans (see Exhibit 19-2 for example).
17.Maintain contact with the injured employee to ensure proper recovery. Follow up with your injured
employee within 24 hours of the injury. Assure him or her of your company’s commitment to their
well-being. Assess the worker’s understanding of the treatment he or she received, and respond
quickly and appropriately to questions about future treatment plans or other general questions.
Always be considerate of the employee’s rights to privacy and confidentiality. Ensure the worker is
going to the doctor for a follow-up appointment. Most jobsite injuries will result in worker released
to restricted work immediately. Research and evaluate possible transitional duty.
18.Understand the challenges of the construction sites. Many projects last less than a year, with many
crews only onsite for a few weeks to few months. For example, an excavation crew might only be on
site for a few weeks. What happens if one of the workers get hurt, and by the time the employee is
ready to return to work, the project is completed, and the contractor does not have any meaningful
work for the worker? The contractor should consider alternate employment options for cases where
an on-site RTW option is not feasible.
19.Develop an RTW plan based on the worker’s medical restrictions and make an offer to work. It is
best practice to involve the worker in creating the RTW plan. Check with the worker’s trade union,
if applicable, to ensure the company complies with the collective bargaining agreement (see Exhibit
19-3).
20.Return the worker to the jobsite after the worker accepts the offer and document the offer. Support
the worker’s return to the site. It is critical that the worker adhere to the medical restrictions so that
the worker does not aggravate the injury. Construction sites are hazardous and present many challenges to even healthy workers. Hence, workers on transitional duties should be very careful. Try
to return the employee to the same crew the worker was part of before the injury. Always maintain
contact with the worker until released to full duty.
Additional Resources, Readings, and References
Washington State Department of Labor and Industries, “Help Your Employee Return to
Work” - http://www.lni.wa.gov/ClaimsIns/Insurance/Injury/LightDuty/
See the sample claims management program from BNBuilders presented in Exhibit 19-4, which
provides sample letters.
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Exhibit 19-1: Example Physical Demands Job Analysis for Laborer
(Used by permission from BNBuilders)
Job Title: Union Laborer
Client: John Doe
DOI: 1/24/15
Claim #: AU xxxxx
Company: BNBuilders
Phone: (206) xxx-xxxx
Supervisor:
Contact: Pete Campbell
DESCRIPTION OF ESSENTIAL TASKS: Laborer maintains jobsite in clean condition. Sweeps
areas and picks up loose materials. Hauls garbage cans to dumpster. Uses shovel to grade dirt after
backhoe digs trenches. Chips concrete with chipping gun. Drills holes in concrete with Roto-hammer.
Places concrete with a pump hose. Position will be inside building or entrance to the site. Receives
deliveries and organizes site materials. Picks up materials, when needed. Flags trucks entering site and
provides security for closing and locking gates. Rigs materials and signals crane.
PHYSICAL DEMANDS
Based on an 8 Hour Work Day
Overall, this job is classified as:
- Not Applicable
- Occasional (10 – 30% of the time)
- Constant (Over 70% of the time)
TASK
FREQUENCY
Sitting
Occasional
Standing
Occasional
Walking
Occasional
Driving
Occasional
Lifting
Occasional
Carrying
Occasional
Pushing/Pulling
Occasional
Climbing
Occasional
Stairs
Twice
Ladders
Occasional
Working at heights
Occasional
Balancing
N/A
Bending at waist
Occasional
Twisting at waist
N/A
Crouching
N/A
Kneeling/Squatting
Occasional
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- Seldom (1 - 10% of the time)
- Frequent (30 - 70% of the time)
* Denotes Estimates
COMMENTS
Up to 50 lbs.
20 lbs. tools and garbage cans
Up to 10 lbs. max force.
Access upper floors
Up to 2 times a day. Upper floors
Reaching –below knees
--above shoulder
Repetitive hand movement
Repetitive arm movement
Handling/grasping
Power pinch
Pinch grasp
Fine finger manipulation
Foot controls
Talking
Hearing
Seeing
Occasional
Occasional
Occasional
Seldom
Occasional
Frequent
Occasional
Frequent
To drive car and forklift
Within normal limits
Within normal limits
Within normal limits
ENVIRONMENTAL FACTORS
Whole body vibration: On forklift
Upper extremity vibration:
Above or below normal temperatures as part of the job: Outdoors
Percentage of time spent each day: 50% Indoors; 50% Outdoors
Types of vehicles/equipment, machinery, or tools used on the job:
Safety Equipment: Radio, telephone, computer, fire extinguisher, Air horn, traffic flag, broom.
We are willing to modify this position, on a temporary transitional basis, by eliminating and/or adjusting physical demands to accommodate this individual’s needs. In order to do this, we are willing to
provide more breaks, and provide shorter hours until the claimant can return to full-time employment.
PHYSICIAN’S RELEASE FOR WORK
FOR PHYSICIAN’S USE ONLY
_____
_____
_____
_____
I agree that the above named injured worker can perform the physical activities
described in the job analysis and can return to work on____________________.
I agree that the above named injured worker can perform the physical activities described in the job analysis on a part-time basis for ____ hours per day. The worker
can be expected to progress to regular duties in ____ weeks/months.
I agree the injured worker can perform the described job but only with modifications noted below. Please note modifications in Comments section below if claimant
is not capable of functioning at maximum levels listed in the Job Analysis.
I disagree that the injured worker can perform the physical activities described in
the job analysis based on the following physical limitations.
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COMMENTS:
Physician’s Signature
Date
Physician’s Name
Number
248
Exhibit 19-2: Example Activity Prescription Form (APF)
249
Exhibit 19-3: Sample employee/Supervisor Job assignment agreement
(Used by permission from BNBuilders)
I understand that Dr. ____________________ has released me to return to work, provided that I do
not exceed the following physical limitations: (Write in limitations established by the treating physician. Attach dated copy of physician’s restrictions JHA)
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
Worker:
I agree to work within these restrictions. In the event that I am given an assignment
that falls outside these restrictions or that is causing any difficulty in the performance
of these duties or given an assignment beyond these restrictions, I will notify my supervisor immediately. I will not violate the restrictions, as I understand them. I will work
cooperatively with my supervisor(s) to prevent re-injury or aggravation of my present
physical condition.
Supervisor: I agree to assign only work within physician’s restrictions noted above. If the worker is
observed doing any job task that falls outside these restrictions, I will immediately talk
with the worker to resolve these problems. I will not violate the restrictions as understood. I will work cooperatively with the worker to prevent re-injury or aggravation of
the worker’s present physical condition.
We agree to notify the appropriate company contact if further assistance is needed.
___________________________________
_____________________________
Employee SignatureSupervisor Signature
___________________________________
_____________________________
Effective DateReview Date
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1. Policy Statement
Exhibit 19-4: Example Claims Management Plan
(Used by Permission from BNBuilders)
BNBuilders values the safety, health, and well-being of all our employees. Our company policy is to
provide safe and healthful working conditions for all operations and to follow the laws and regulations
associated with the safety and health of our employees.
If you become injured on the job while in the course of your employment with BNBuilders and need
medical attention, we will be directly involved with assisting you in getting what you need from the
moment of your injury or illness. Your supervisor will take you, or assign a staff member to take you
to the doctor or hospital; assist you with filing a company incident report; filing an Industrial Injury
Claim, if needed; and be involved in the subsequent accident investigation to identify and eliminate
any hazards which may have been associated with your injury or illness. In the event of a claim, we will
maintain close contact with you, your doctor, and the Department of Labor & Industries until your
Industrial Insurance claim is closed.
No one knows their jobs better than our employees do. Therefore, it is our expectation that when an
employee experiences a work-related injury, that employee will fully participate in the recovery, rehabilitation, and return to work process as a full partner in this effort.
As a condition of employment, I understand and agree to adhere to the above company policy. I also
agree to report all injuries and unsafe or hazardous conditions to my supervisor immediately.
*(A copy of this policy can be signed by the employee on the date of hire and placed in the employee’s
personal file along with the completed orientation checklist)
Employee’s SignatureDate
Company Representative’s SignatureDate
2. Modified Work Overview
• Modified return to work following an Industrial Insurance injury is an important component
of our Claims Management Plan and is a priority to BNBuilders. The benefits of this program
are rapid return to work for our employees and reduced Industrial Insurance injury claim costs
for the employee as well as the company as a whole.
• If for any reason you are unable to do your regular job because of a work-related accident or
illness, we will require a release from your doctor for you to return to any type of work. We
have a job description of your job of injury, which your doctor can use as a preliminary tool to
release you back to work.
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• All employees are encouraged to participate in the process of identifying tasks that could be
integrated into a temporary work assignment for injured employees. If you notice the work that
needs to be done but seems get put on the shelf for a later time, please let your supervisor know
about it. Additionally, if you have ideas about how you could do your regular job with temporary modifications, please talk to your supervisor.
• Modified work begins the date the doctor releases you to it. Once your doctor has approved
modified work, a meeting will be scheduled for you to meet with company representatives to
clearly outline the specific jobs you are released to do. A “Return to Work” agreement outlining
the details of your modified work will be completed and signed by all parties. Modified work
plans will last for two weeks and be re-assessed at two-week intervals to adjust your work duties
as approved by your doctor. If you have any difficulties during this transitional work period, we
encourage you to talk to your supervisor immediately. Our goal is to assist you in returning to
your regular job as soon as your doctor deems it is medically suitable for you.
We consider our employees to be our most valuable asset at BNBuilders. We will do everything possible to assist you in your return to your regular work activities.
3. Management Responsibilities:
• As a top priority, management is committed to, supports, and enforces a strong safety program
and through action, words and role modeling maintains a company culture of safety first.
• Management will support and enable supervisors, company representatives, and injured employees to take the action required to fulfill the program steps developed and to assist in a positive manner with the return to work process.
4. Supervisor Responsibilities:
• Supervisors will act as the communication link between management and injured employees.
• Supervisors will encourage and support all their employees to think and act safely on the job
and to participate in all activities involving safety. Supervisors will regularly communicate
with all their respective employees regarding their responsibility to keep themselves and their
co-workers safe.
• Supervisors will report near misses (incidents not resulting in injury) and incidents resulting
in injury/illness with or without a claim filed by completing the company’s internal incident
report. Supervisors will encourage and support their respective employees to do the same.
• In the event of a work-related accident/injury, supervisors are responsible for taking their injured employees to the medical provider of their choice. If for some reason a supervisor is unable to do this, the supervisor is responsible for designating someone to take the employee to
the doctor/hospital.
• The supervisor or their designee is responsible for assisting the injured employee with completing the accident report provided at the doctor’s office/hospital, and obtaining the claim number
to report back to the company representative who is managing the claim.
• Supervisors are expected to be thoroughly informed about their employee’s medical condition
following a work-related injury/illness and are expected to be knowledgeable about their employee’s medical status throughout the recovery process. Supervisors will work collaboratively
with the employee and other key company personnel to identify and coordinate the details of
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the employee’s return to work on a modified/transitional basis until such time that the employee
is medically able to return to their job of injury.
• In collaboration with other key company personnel, supervisors will participate actively in the
accident investigation process for any incidents involving their direct reports.
• Supervisors will work in concert with their direct reports to identify temporary work assignments that could result in good opportunities for a modified return to work.
5. Employee Responsibilities:
• All work-related injuries must be reported immediately to supervisors whether or not medical
attention or wage replacement options are involved.
• An internal company incident report will be provided to injured employees and must be completed as soon as possible following an accident/illness and returned to the immediate supervisor. The company will then conduct an accident investigation in order to identify and correct
any existing safety and health hazards resulting.
• If an injured employee should experience problems with their recovery, be dissatisfied with
medical treatment providers, or need help understanding the Industrial Insurance system,
Kim McKay, Claims Consultant for BNBuilders is available to provide written information,
assistance and/or support.
• Injured employees are asked to honor management requests to seek second opinions prior to
surgery or when treatment does not appear to be effective.
• Employees are expected to fully participate in the process of identifying and/or developing an
appropriate return to work options that are considered to be medically suitable by the employee’s doctor.
• Employees are expected to accept temporary, modified, and/or transitional work once the
specified duties have been approved by their doctor.
6. Claims Management Procedure:
Steps to follow the 1st day of an inquiry or as soon as possible!
1. The employee’s supervisor will go with or will designate someone to take our injured employee
to the designated clinic.
2. We will give the doctor a letter from our company, which states BNBuilders intent to assist
our employee in returning to work. Along with the letter, we will include a job description of the
job of injury to help the doctor to identify temporary job restrictions, if applicable, and return to
work status.
3. At the time of first medical treatment, we will get the claim number from the Report of Accident form. We will need this claim number on all documentation from here on out. If the employee for some reason has to go to the first doctor’s appointment unaccompanied, it will be the
employee’s responsibility to call the employer immediately following the medical appointment to
report the Industrial Insurance claim number assigned to his/her new claim.
4. Complete Employer’s portion of the Report of Accident form electronically at the L&I Claims &
Account Center.
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5. Our company will establish an individual claim file to keep copies of ALL paperwork relating
to the claim.
6. The company claims representative will organize a “1st Day Packet” to send to the Dept. of Labor & Industries, which will include the following items:
-Job description for job of injury (preferably signed by doctor, but send without doctor’s
signature if not available)
-Employee’s work history (i.e. copy of original job application)
-Current payroll records (including wages)
-Copy of company’s internal incident report
-Copy of company’s accident investigation report, if available
-Claim number will be written on the upper right corner of EACH PAGE
7. The company will mail copies of the above documentation to:
Department of Labor & Industries, Claims Section, P.O. Box 44291, Olympia, WA 985044291
And to:
AGC Retro, Kim McKay, Claims Consultant for, PO Box 12629, Olympia, WA 985082629
*A copy of every page we send to L&I will be retained in our company’s working claim file for
our employee.
8. If the doctor does not approve the job description, revisions will be made to the job better to
accommodate our employee’s physical restrictions in a temporary job for our employee during
their recovery period.
The company will monitor the progress and status of the claim via the L&I Claims & Account
Center, paying special attention to the employee’s most recent medical documentation, especially
as it affects the employee’s return to work status. If updated medical documentation is needed,
the company will request it via secure access message to the claim manager for the claim.
9. The company will maintain regular contact with the injured employee (at least once a week by
phone).
10.THIS PROCESS WILL BE REPEATED until we determine whether or not our employee
can return to the job of injury or needs further services. We will keep the claim moving and be
proactive at every opportunity!
11.The company will investigate the industrial accident within 24 hours of the incident to identify
potential hazards and revise safety procedures if necessary.
12.The company will send a FORMAL JOB OFFER LETTER to the employee after the doctor
approves return to work on any level.
13.The company will review and improve our claims management plan and make changes we feel
may be needed and/or appropriate to our company. This review process will take place on an
annual basis or more often as needed.
14.The company will contact Bob LeMay (206) 515-2832, a Risk Management Consultant at the
Dept. of Labor & Industries to discuss the claim and return to work issues as needed.
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“Dear Doctor” Letter
BNBuilders
Date:2601 4th Ave #350
Seattle, WA 98121
Doctor’s Name:
Address:
City, State, Zip Code
RE:
Worker’s Name Claim # Dear Dr. :
BNBuilders is committed to assisting our injured employees in returning to work as soon as possible.
Attached is a job description for the position of . This position
is for (restricted/light duty, transitional work, job of injury job, modified version job of injury, new job,
etc.).
Please review and respond to the job description, outlining any needed modifications. If our employee is not able to work, please indicate what physical restrictions prevent return to work at this time.
This position is currently available and we are waiting for your approval.
We would appreciate your faxing the job description to us at (206) 382-3440 at your earliest opportunity. If you have questions or concerns, please call me at (206) 382-3443. Thank you for your assistance with our employee’s return to work.
Sincerely,
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Formal Job Offer Letter
Date:
BNBuilders
2601 4th Ave #350
Seattle, WA 98121
Date:
Doctor’s Name:
Address:
City, State, Zip Code
RE:
Worker’s Name Claim # Dear :
Your doctor has released you for modified work, which he/she feels you are able to do until you can return to your regular job. Therefore, we would like to offer you the temporary, modified
duty job of . Attached is a copy of the job description approved by your doctor.
Please report to your immediate supervisor for your modified duty job on (insert date) at (insert
time). Your pay will be $
per (hour/month). Loss of Earning Power (LEP) benefits may apply if your restricted duty wage is less than your regular wage.
As you improve, the physical demands of the job may change, as approved by your doctor. Usually, a
modified duty assignment lasts anywhere from a few days to several weeks, depending on your medical condition.
Your signature below indicates that you have reviewed this offer. Please return this signed job offer
agreement to me by (insert date – 10 to 14 days from date of letter). A self-addressed, stamped envelope is enclosed for your convenience.
Should you have any questions about this job offer, please contact me at insert phone number.
Sincerely,
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Page 2
Job Offer Letter
Employee’s Name
Date of Letter
CHECK ONE:
I accept this job offer: I do not accept this job offer:
Employee SignatureDate
Enclosures: Approved Job Description
Employee’s Claim File
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Job Assignment Agreement
“Return to Work Agreement”
Employee: Claim #: Start Date: End Date: Per our modified return to work process, this agreement marks the beginning of Insert Employee’s name
modified work assignment.
The job description approved by the doctor is attached. It is very important that only those approved
tasks be performed. ___________ is authorized only to do the tasks specifically identified as approved
by the doctor. You are requested to bring an updated Return to Work form with you after every doctors
visit.
Welcome back to work. We are excited that we can provide this benefit to your and want to make your
recovery as comfortable as possible. If you have any difficulties during this assignment period, please
talk to your supervisor immediately.
We will plan to meet on the periodically to discuss treatment, progress and the next steps associated
with your return to work.
Employee: Date:
Supervisor:Date:
BNB Company Representative:Date:
Enclosures: Job description approved by a doctor
Job offer letter
CC:
Company claim file
Doctor’s Name
L&I Claims Manager
Employee’s Name
Supervisor’s Name
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Pre-existing Condition Records request
2601 4th Ave #350
Seattle, WA 98121
Date:
L&I Claims Manager
Dept. of Labor and Industries
PO Box 44291
Olympia, WA 98504-4291
RE:
Worker’s Name Claim # Dear Claim Manager. :
The doctor indicated there was a pre-existing medical condition; please obtain a medical release from
the injured worker in order to procure the prior treatment records from the appropriate physicians.
Once you receive the prior medical treatment records, please send them to the attending physician on
this claim and ask the doctor to identify when the worker has reached pre-industrial injury status.
Once pre-injury status has been reached, please ask the physician to segregate any permanent impairment as pre-injury and post–injury.
Thank you for your cooperation and assistance.
Sincerely,
Pete Campbell BNBuilders CHSO
Cc: AGC Retro
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20
CONSTRUCTION WORK-RELATED MUSCULOSKELETAL
DISORDERS (WMSDS)
20.1 INTRODUCTION
ƒƒ A construction laborer was using a rotary hammer, after a period his wrist began to hurt and
reported to his supervisor (sprained wrist).
ƒƒ Two reinforcement bar workers lifted a pallet with concrete dobies when one of them felt a
sharp pain in his lower back (back strain).
ƒƒ A drywall carpenter was installing 5/8” standard (4’ by 8’) drywall sheeting for an entire day.
Close towards the end of the day, his back began to get stiff and sore, but he continued to the
point of not being able to lift (back sprain).
ƒƒ The worker was installing an HVAC ductwork, twisted his back wrong and felt a sharp pain
(cervical strain).
ƒƒ A concrete finisher was finishing a concrete slab with a hand trowel when he experienced pain
in his right forearm (forearm injury).
ƒƒ An electrical worker experience numbness and pain on both his hands. He went to the doctor
for a checkup (carpal tunnel syndrome both hands).
What do these injuries have in common? These injuries are examples of Work-related Musculoskeletal
Disorders (WMSDs). A WMSD, commonly referred as soft tissue injury, is an injury that affects the
muscles, tendons, nerves, or ligaments. WMSDs are caused suddenly or can be aggravated by repeated
exposure over a long period, of a combination of job site risk factors that include, but not restricted to:
1.
2.
3.
4.
5.
Repetitive motions (frequency of tasks)
Force (push/pull/lift)
Awkward positioning (overhead work/ kneeling/squatting)
Exposure to vibration
Contact stress (contact stress happens due to prolonged contact, with sharp edges and hard
surfaces such sharp edges of tools, equipment, etc.)
6. Cold temperature
What else do these injuries have in common? They are all preventable through the use of appropriate
equipment, work methods, and training.
WMSDs are a tremendous concern to the U.S. construction industry, which accounts for the highest
frequency of all non-fatal occupational injury claims. A recent report by Washington Labor and In261
dustry’s Safety and Health Assessment and Research for Prevention (SHARP) Program, analyzed the
Washington State Workers’ Compensation (WC) claims from 2002 to 2010. Overall, there were 409,711
compensable claims and 176,033 of them (43%) were for work-related non-traumatic musculoskeletal
disorders of the back, upper extremity (shoulder, elbow, hand/wrist) and knee (WMSDs) in Washington State. The report states that overall, the construction industry continues to be a high-risk industry
for WMSDs in workers in Washington State.1
WMSDs prevention does not get much attention from employers compared to other physical hazards
(e.g., fall prevention). Why? How many times have you seen WMSD risk factors identified during
safety audits? Is it because there is no construction safety standard requiring construction employers
to implement WMSD controls? Companies should understand the WMSDs are hurting their bottom
line through injury claims and also decreased productivity from workers who continue to work while
being in pain. In addition, the construction workforce is aging, every construction employer must take
precautions to minimize the risks to protect their #1 resource, the workers. It can be achieved with the
implementation of an effective site WMSDs prevention program.
20.2 PURPOSE
The objective of this chapter is to provide general management best practices guide for construction
contractors on how to eliminate or minimize the risks associated with work-related musculoskeletal
disorders in construction sites. A majority of the information outlined in this document should be
part of the employer’s Accident Prevention Program (APP). The employer should at least refer to their
WMSD prevention program in their APP if they have it as a separate program.
20.3 SUPPORT
Obtain project owner and general contractor/construction manager (CM/GC) management commitment to implement an effective project-level WMSD prevention program. An effective program requires that the project management including site supervision is committed to the process. They should
demonstrate their commitment by allocating necessary resources to ensure the success of the program
(e.g., training, support for corrective actions, etc.).
20.4 CONTRACTS
Include site WMSD program requirements in the contracts. All pre-construction or pre-award meetings should include a review of the program requirements which will provide a more complete and
accurate bid-basis for subcontractors.
20.5 HISTORICAL DATA REVIEW
Review subcontractor injury and illness data (OSHA 300 log and insurance claims) as part of the
safety pre-qualification to identify WMSD risks associated with each subcontractor. Require them to
develop a Corrective Action Plan (CAP) to prevent reoccurrence of those injuries before commencement of work on the site. Set concrete goals.
1Work-Related Musculoskeletal Disorders of the Back, Upper Extremity, and Knee in Washington State, 2002-2010 (Summary).
http://www.lni.wa.gov/Safety/Research/WhatsNewSharp/Default.asp#WMSD (Accessed July 10, 2015)
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20.6 RISK ASSESSMENT
Establish a system for analyzing construction tasks to identify WMSD risk factors and controls during
(1) pre-construction, (2) during construction, and post-construction.
a. Pre-construction – Use Job Hazard Analysis (JHA) and Site Specific Safety Plan (SSSP) to
perform pre-construction WMSD risk assessment and control. Ensure a WMSD prevention plan is an important component of the SSSP.
b. During Construction – Observe and assess site operations using site safety survey (inspections), pre-task planning, and the craft feedback, to identify risk factors and eliminate or
control them as early as possible. Remember most times WMSDs does not get much attention during inspections and in pre-task plans. Hence, some companies perform a standalone WMSD risk factor survey that involves:
i. Review of pre-task plans to ensure all WMSDs risk factors and controls are identified
ii. Simple observations of the tasks to recognize risk factors not identified during
pre-construction assessment
iii. Ensure effective implementation of the risk controls identified in pre-task plans
It is also recommended to have a just-in-time review of work plans as conditions change,
such as moving from one phase of the project to another, or when weather conditions create
additional risks.
c. Post-construction – Record (using pictures) any best practices or lessons learned from the
project into a database, so that it can be transferred to future jobs or current jobs within
your company.
20.7 SUBCONTRACTOR MANAGEMENT
Require subcontractors (contractually) to examine “all” their tasks, tools used, work procedures,
workstations, and equipment operation, and carry out WMSD risk factor assessment and mitigation
before commencement of work. The risk factor evaluation and mitigation measures should be incorporated into the JHA that is specific for that scope of work. Subcontractors should submit their JHAs
prior to commencement of work. Emphasize the importance of WMSDs risk factor control during
the pre-mobilization meetings. Review all JHAs/SSSPs to ensure it has adequately identified the risk
factors and associated control measures.
20.8 CONTROLS
WMSD risks should be mitigated using the following controls in this order with engineering being the
most effective and PPE is the least effective control.
a. Engineering Controls to implement physical change to eliminate or reduce hazards (e.g.,
reduce the size of chain link fence rolls to reduce the weight to limit force exertion).
b. Administrative Controls to establish efficient procedures or processes such as job rotation,
work pacing, and work breaks. (e.g., some activities to consider for rotational work are
hammering nails while building forms, troweling concrete, etc., to limit exposure time)
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c. Personal Protective Equipment to protect against WMSD risks (e.g., a knee pad for workers
whose activities involve prolonged kneeling on hard surfaces such as concrete).
20.9 TRAINING
Train all site personnel, including supervisors and managers that should include at a minimum:
•
•
•
•
Recognition of WMSD risk factor using Pre-task Plans (PTPs)
Control of WMSD risk factors (proper use of control measures)
Recognition of signs and symptoms of WMSDs & proper procedures for reporting
Procedures to get involved with the program
20.10 PROGRAMMATIC BEST PRACTICES
Consider the following list of programmatic best practices developed based upon the experience of
major construction contractors. Depending on company and/or project size, adoption of one or more
of these practices that are feasible should help minimize WMSD risk factors.
a. Development and delivery of trade-specific ergonomics training program based on a formalized review of the company’s WMSD-related claims, with the help of ergonomics consultants. This training should be in addition to project-specific orientations.
b. Formation of an ergonomics committee at both the company- and project-level, comprised
of trade-diverse members trained on how to identify WMSDs risks and control them.
c. The addition of a full-time ergonomics coordinator position to identify and correct WMSD
risk.
d. Involvement of crafts in the WMSD prevention program. Construction crafts involvement
is critical to the success of the WMSD prevention program mainly when recommending
WMSD mitigation measures. They know the work better than anyone else, they are in a
better position to provide solutions. Furthermore, it will improve the craft acceptance of
the mitigation measures. One project implemented an ergonomic improvement suggestion
program to record employee suggestions and award gift certificates to workers whose recommendations resulted in innovative solutions.
e. Establishment of a trade-specific customized stretching and strengthening program. Seek
the guidance of an expert in this field such as an occupational therapist or physical therapist. Please note that many ergonomists do not have the training necessary to develop a
stretch and flex program. A consultant will visit your workplace and observe your crafts
and analyze the company’s claims history to develop custom programs. For example, a
concrete company will have different disciplines such as laborers, carpenters, finishers, and
office workers. Based on this, the consultant will develop customized stretches. Stretching
sessions, is typically 10-15 minutes, are recommended at the start of the shift and before performing any strenuous tasks. Remember stretching should never be a stand-alone program,
but a part of the comprehensive WMSD prevention program. Stretching sessions, has other
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benefits as well such as team building, communication, increased worker morale, and safety
planning. In addition, supervisors can use stretching sessions to identify any workers who
are in pain, exhibiting signs and symptoms of WMSDs (see Exhibit 20-1).
Figure 20-1 Workers Performing Stretching Exercises (Courtesy Hensel Phelps Construction)
f. Implementation of WMSDs related medical management program for each project. Seek
the assistance from your insurance provider to select a physician or a clinic near the project
to help with early diagnosis and treatment. Construction workers do not report WMSDs
because they think the minor muscle aches will go away after a while. As discussed earlier
in this section, train the workers and supervisors so they can recognize WMSD symptoms
early and report them. The project should encourage workers to receive employee reports
of WMSD symptoms that should result in a medical evaluation. This can help reduce the
severity of the injury (and claims) and minimize the likelihood of permanent disability or
damage.
g. Establishment of a workplace wellness program. Certain physiological and even mental
conditions that can be a confounding factor for soft tissue injuries such as diabetes, obesity,
smoking, physical conditioning, age, stress, etc. For example, a Duke University Medical
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Center analysis found that obese workers filed twice the number of workers’ compensation
claims, had seven times higher medical costs from those claims and lost 13 times more days
of work from work injury or work illness than did nonobese workers.2 Hence, a workplace
wellness program will develop healthier crafts and reduce the chances of WMSDs.
20.11 TOOLS
Provide employees, supervisors, and safety/ergonomic committee with reference tools for increasing
their knowledge of WMSD risk assessment and mitigation measures. Some resources are listed below:
 Alliance Program Construction Roundtable: Prevention of Strains, Sprains and Material
Handling Injuries in Construction.
 National Institute of Occupational Safety and Health (NIOSH): Simple Solutions: Ergonomics for Construction Workers – provides practical ideas to help reduce the risk of repetitive
stress injury in common construction tasks.
 Laborer’s Health & Safety Fund of North America: Ergonomics and Construction – The
Smart Move - Provides general information about ergonomics and construction.
 The Construction Solutions web – Designed for owners, contractors, & workers, Construction
Solutions, is a database of work hazards, & practical control measures to reduce or eliminate
hazards.
 Washington State Department of Labor and Industries Ideas Bank – A searchable collection
of ideas that may help you reduce exposure to awkward postures, high hand force, repetitive
motions, lifting, vibration and other risk factors for work-related musculoskeletal disorders
(WMSDs) in your workplace.
20.12 CONTINUOUS IMPROVEMENT
Conduct follow-up assessment and WMSD prevention program evaluation. After implementation of
the WMSD prevention program, it is important to conduct periodic assessments including feedback
from crafts to ensure the potential risk level was reduced to an acceptable level. The evaluation should
also focus on the effectiveness of the program’s education, training, etc. Any shortcomings should be
corrected as part of a continuous improvement process.
An effective WMSD prevention program will result in a safe work environment with an improved work
quality, productivity, and worker morale; and an enormous reduction in injury-related costs.
Additional Resources, Readings, and References
SHIP Grant Project, “Stretch & Flex: A Multimedia Intervention to Reduce Work-Related Musculoskeletal Injuries in the Construction Industry.” Integrity Safety Services, Inc.; Performance
Ergonomics, LLC. AGC of Washington. The project resulted in the following great tools that
contractors can use.
1. Stretch & Flex Video
2 Duke Medicine News and Communications. http://corporate.dukemedicine.org/news_and_publications/news_office/news/10044
(Accessed November 18, 2014)
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2. Stretch and Flex Poster
3. Quick Reference Card
4. Stretch and Flex Training Presentation
Washington State Department of Labor and Industries Ergonomists – Employers may request
an ergonomics consultation at their work site in Washington State. A consultation can help you
identify hazards for musculoskeletal disorders and means to reduce them. http://www.lni.wa.gov/safety/SprainsStrains/gethelp/default.asp
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Exhibit 20-1 Example Stretch and Flex Program_Page_1
(Used by Permission from Gary Merlino Construction Inc.)
268
Exhibit 20-1 Example Stretch and Flex Program_Page_2
(Used by Permission from Gary Merlino Construction Inc.)
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21
SAFETY INSPECTIONS
21.1 PURPOSE
Safety inspections are a significant hazard identification tool on a construction site, which will help
prevent accidents by correcting those hazards. This chapter is intended to provide step-by-step best
practice guidance to contractors to develop a new or improve an existing site-specific inspection program.
The following are the objectives of the safety inspection program:
Reduce the risk of injury or loss to project personnel, property or the quality of work products
through the identification and elimination of safety and health deficiencies.
Provide an ongoing, systematic monitoring mechanism to measure compliance with relevant
regulatory or contract standards.
Involve the project team members in safety and health inspection and surveillance.
Identify areas of potential risk and loss.
Identify opportunities for safety and health education and training.
Check and audit past training and skill development.
Identify and develop positive attitudes to safety and health.
21.2 DEFINE PROGRAM PURPOSE
Define and communicate the purpose of the site’s safety inspection program to all workers through site
orientation. The workers should realize and be confident that inspections are not to “get them,” but is
a proactive accident prevention measure. The primary goal of safety inspections should be to identify
and correct (a) unsafe conditions, (b) unsafe acts, and (c) deficiencies in the Site Specific Safety Plan
(SSSP). Include safety inspections as one of the major elements of the Site Specific Safety Plan (SSSP).
See chapter 12 of this handbook for more information about the development of an SSSP.
21.3 IDENTIFY INSPECTION NEEDS
The SSSP should identify the project-specific inspection needs by reviewing:
Project contract requirements (e.g., Does the owner require special inspections?)
Applicable regulatory requirements (e.g., DOSH competent person scaffold inspection)
Company’s accident history from similar projects (e.g., WMSD risk factors inspection)
Manufacturer recommendations for all equipment and tools on the site (e.g. Annual crane inspections)
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21.4 DEVELOP INSPECTION RECORDING TOOLS
Develop safety inspection tools such as checklists and forms to record the inspection findings (see Exhibit 21-1 for example). Checklists are typically created by making a list of site-specific hazards (unsafe
acts/conditions). It is an excellent tool for inspection of specific items such as:
Construction equipment inspections (e.g., scissor lift, concrete pump truck, crane)
Emergency equipment and supplies (e.g., fire extinguisher, first aid kit)
Personal Protective Equipment (e.g., Full-body harness)
Trade- or task-specific inspection (e.g., excavation inspection or landscape contractor)
Health hazards measurement and testing (e.g., measurement of noise exposure)
Inspection checklist or form focusing on fall, struck by, caught in or between and electrocution
hazards
Beware, since checklists consist of pre-determined hazards or items to inspect, there is a potential that
inspectors could miss “unrecognized” hazards not listed on the list. Also, since these checklists are
generic, ensure you modify these checklists to fit your specific jobsites. Use open-form inspections for
general site-wide inspections (see Exhibit 21-2 for example). Contact entities such as your company’s
workers’ compensation insurance carrier, industry associations (e.g., AGC), labor unions, DOSH; who
can provide free pre-made safety inspection checklists for construction.
21.5 PLAN FOR INSPECTION
Identify individuals who will conduct safety inspections, the frequency of inspections, and level of formality of these inspections. Ensure that those identified to conduct inspections are adequately trained
to recognize hazards. Safety inspections can be classified into formal and informal inspections.
Informal – Inspections that are conducted by all site personnel including craftsmen as part of
their job responsibilities throughout the day. Typically, informal inspections do not involve
documentation such as forms or checklists. However, they do play a crucial part of an SSSP by
helping to identify safety issues on a daily basis.
Formal – Inspections that are conducted by certain individuals or entities, which are scheduled
at regular intervals. It typically involves the use of inspection tools for recording inspection
findings. The frequency of formal inspections can vary from weekly to annually, depending on
the potential for injury or damage, (or) regulatory requirements associated with the jobsite, a
specific task, or equipment. For example, electrical hot work might require frequent inspections
of the work area.
Based on industry best practices, depending on project-specific factors, the following inspections and
timeline is recommended for “general” site inspections (see Table 21-1).
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Table 21-1: Safety Inspection Frequency and Level of Formality
Who should conduct inspections?
Workers & field supervisors (e.g., superintendents, foreman)
Project management (e.g., project managers (PM)
Owner representative (e.g., owner PM, safety)
Contractor(s) top management
Site Safety Committee
Site safety professionals
Site safety professionals
DOSH consultation walks
Insurance loss control experts (random)
DOSH compliance audits
Regulatory agency mandated inspections
Manufacturer or underwriter mandated inspections
Tools and Equipment
Frequency?
Daily
Monthly
Monthly
Quarterly
Bi-weekly
Weekly
Daily
As-needed
Quarterly
*
**
***
Before use
Formality?
Informal
Formal
Formal
Formal
Formal
Formal
Informal
Formal
Formal
Formal
Formal
Formal
In/formal
*Depends on imminent danger, fatality/catastrophe, complaints/referrals, and programmed
**Refer all applicable standards and regulations
***Refer operators manual
Note: The site inspection requirements should be communicated to all subcontractors through pre-bid
and pre-construction meetings and the contracts.
21.6 ASSEMBLE INSPECTION KIT
Safety inspectors should be set up for success with an inspection kit. The kit may include, depending
on the project, clipboards, inspection checklists, forms, pens, flashlights, camera, tape measure, electrical testing equipment, and monitoring/sampling devices (i.e. sound level meter, light meter). However,
paper-based inspections might become history in a few years. Many companies are using a software
called “apps” installed on portable electronic devices such as smartphone or tablet computers to conduct safety audits and inspections (see Figure 21-1). These safety inspection apps even come with a
feature to take pictures during the inspection and add them to the report and email a copy of the full
report to selected subcontractors. Some apps can measure sound and light levels, and also provides a
quick reference of standards and regulations on your fingertips – making inspections more efficient.
Refer Section 8 of this handbook for more information on smartphone apps application in safety
management.
21.7 TRAIN THE INSPECTORS
New supervisors or safety committee members, may have never conducted an inspection. Hence, it is
important to train the inspectors on the following topics:
Proper inspection techniques – proper preparation, conducting the inspection and follow-up
for corrective actions
273
Addressing workers performing unsafe acts
Common site hazards and controls
Familiarity with applicable standards and regulations
Familiarity with company/site policies including the requirements of the SSSP
21.8 CONDUCT THE INSPECTIONS AND RECOMMEND CORRECTIVE ACTIONS
The inspector should take adequate time to conduct a thorough review of the entire jobsite. Depending on the jobsite, it might take an hour to 4 hours to complete an effective inspection. Most safety
issues can be fixed during the inspection by working with the foreman in charge of the work area or
workers associated with the issue. Try to correct the cause of the unsafe condition or act, to prevent
reoccurrence. Some items might require disciplining workers, which will trigger the site’s progressive
discipline program. Hence, safety issues that were not or cannot be fixed during the inspection (e.g.,
worker operating scissor lift without training), should be noted on the inspection form along with other details (i.e. work location, concerned subcontractor).
At the end of the inspection make a separate list of safety issues with your proposed solutions and attach a deadline for each corrective action. Distribute the “action list” to the concerned subcontractor’s
key supervisors as soon as possible, and require them to fix it before the deadline. Note activities or
tasks that are posing imminent danger conditions should be stopped, and the safety issue should be
fixed immediately.
Figure 21-1: Safety Professional Performing Scaffold Inspections using I-pad (Courtesy Hensel Phelps
Construction)
274
21.9 FOLLOW-UP FOR CORRECTIVE ACTION
Did the proposed solutions were implemented? Inspections are useless if the safety issues identified
are not fixed. The inspector should periodically check to see the progress towards the corrective action
until the safety issues are resolved.
21.10 FILE THE INSPECTION FORMS
Once all safety issues are resolved, make a note on the form that should include (a) what corrective
action was taken and (b) when and who completed the action. Keep a copy in the jobsite file. It is
called closing the loop. It is a very important step, especially when responding to a lawsuit related to
that jobsite. It will demonstrate the company’s due diligence in maintaining a safe and healthy work
environment, and compliance with its safety program.
21.11 IDENTIFY TRENDS
Inspections are one of the most common safety leading indicator that can predict accidents by showing “trends” in unsafe acts and conditions. For example:
80% of the workers observed were not wearing appropriate gloves. Is there a problem with the
project’s glove policy?
60% of the scissor lifts operating on site did not have a spotter. Is there an enforcement issue
with spotter requirements?
Reviewing the inspection reports for trends and addressing them promptly will prevent accidents.
21.12 SHARE LESSONS LEARNED WITH ALL SITE PERSONNEL
Hazard trends identified during inspections offer an excellent training opportunity. Communicate the
inspection results and trends to the workers at all-hands or mass safety meetings. Review inspection
results at the safety committee meeting as well. Encourage site supervisors to share them during their
pre-task plan meetings. It will allow workers to watch for these hazards and unsafe work practices, and
report them immediately to their immediate supervisor.
21.13 RECORD AND SHARE BEST PRACTICES
The number of contractors on a jobsite will vary from 1 to more than 100 depending on the size of a
project, each implementing various safety inspection best practices. On certain projects workers might
suggest innovative inspection practices, if they were successful, make sure it is carried over to another
project. Consider the following list of programmatic best practices developed based on the experience
of major construction contractors.
21.13.1 Worker Safe Behavior Observation (WSBO) Program
The WSBO is a leading indicator metric that generates a weekly WSBO project score (0-100), with the
help of the following steps:
1. Observe worker behaviors who are part of the crew or work area for a short period. Make a
minimum of 30 observations per week to get a meaningful sample.
275
2. Calculate a WSBO score, which is the ratio of workers with safe behavior to the total number
of employees observed (e.g., 80% of crew members were safe). Set project goal, for example, the
average WSBO score goal for the project is 95.
3. Record and tabulate the “frequency” of the nature of unsafe behavior (e.g., no safety glass)
from all observations for that week.
4. Analyze trends and implement corrective actions.
5. Continue the process to check the effectiveness of the corrective actions and identify new trends,
if any.
21.13.2 Monthly Management Inspection (M2I) Program
The M2I is another leading indicator metric that generates a weekly M2I project score for each subcontractor or the project as a whole, with the help of the following steps:
1. Create a standard safety inspection form.
2. Require a monthly audit by the project manager to ensure compliance with project safety requirements and applicable regulations. In addition to a job walk, the audit should include a
review of accident reports, safety inspections, site recordkeeping, etc.
3. Start the Audit with a score of 100. Deduct points for each non-compliance items. Add points
(extra credit) for items that are above and beyond requirements.
4. Compute the net score.
5. Use the M2I score to reward subcontractors with superior performance and require subcontractors with an inferior score to provide corrective actions.
6. Track and make efforts to improve M2I score.
21.13.3 Safety Management by Walking Around (SMBWA)
The SMBWA is a management inspection technique that involves the project managers of the owner,
general contractor and subcontractors walking around on the jobsite, directly observing the site operations. Management should engage their workers in conversations, and receive feedback about the effectiveness of the site safety program, and try to resolve any deficiencies promptly. During these walks,
the managers should “recognize safe behaviors” and coach to “modify unsafe behavior.” The SMBWA
technique shows management commitment to worker safety and builds employee morale.
Additional Resources, Readings, and References
Oregon OSHA Sample Inspection Checklists: http://www.orosha.org/standards/checklists.html
Texas Department of Insurance Sample Construction Safety Inspection Checklist: Construction
Safety Inspection Checklist: http://www.tdi.texas.gov/pubs/videoresource/cklgenconstru.pdf
276
Exhibit 21-1: Example Project Safety Inspection Closed Form
(Used by Permission from GLY Construction)
Superintendent:
Foreman:
# GLY Employees:
# Sub Employees:
Date:
Job Name:
Job #:
Project Mgr:
COMPLIANCE
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
CONTRACTOR
JOB OFFICE REQUIREMENTS
Substance Abuse Testing
Posting Requirements
Signage
MSDS Manual
Safety Training (Hire-in Booklet)
Tool Box Meetings
Daily Logs
Job Hazard Analysis
Flex & Stretch
LEED Recycle Log
TOOLS
Power Tools, Wiring & Grounding
Protective Equipment
Safety Devices
PERSONAL PROTECTIVE
EQUIPMENT
Personal Clothing
Goggles or Face Shield
Hard Hats
Protective Clothing
Body Harness & Lanyard
COMPANY POLICY
Hard Hats
Eye Protection
FIRE PROTECTION
Extinguishers on Site
Fire Watch or Extinguishers
Tested & Inspected Extinguishers
MATERIAL HANDLING
EQUIPMENT
Ladders
277
COMMENTS
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Scaffolding
Man Lifts
Fork Lifts
Equipment Checklist
HOUSEKEEPING
Aisles & Stairs
Floors
Storage & Piling of Material
Lighting & Ventilation
SAFE PRACTICES
Hazardous Material Containment
Working under Suspended Loads
Removing Machine Tool Guards
Handrails & Guardrails
Floor Openings Covered & Marked
Access & Ramps
FIRST AID/CPR
Certified Provider on site
First Aid Kits
First Responder Kit
Injuries & Illness Reported
EXCAVATION
Preconstruction Meeting & Plan
Slopes & Depths
Protection
Ladders & Egress
CRANES
Engineering
Crane Certifications
Secured Access
Qualified Operators
Inspections
FALL PROTECTION
Precon Meeting & Plan
Leading Edge
Openings
Rails & Toe Boards
Perimeters
278
Yes
No
SUBCONTRACTORS
Safety Manuals
Fall Protection Plan
Violation History
Safety Manager/Safety Specialist Signature:
Site Supervisor Signature:
COMMENTS:
Copy to:
Project Superintendent; GLY Safety Department
279
280
Job Name:
Job Number:
Inspection Conducted by:
Submitted to:
5
4
3
2
Note: Ensure all identified safety concerns are addressed appropriately promptly depending on the severity of the concern.
No
Location Safety Concern
Recommended Corrective Action
Responsible Contractor Due Date Status
1
Date:
Project Superintendent:
Exhibit 21-2: Example Safety Inspection Open Form
22
SAFETY PERFORMANCE MEASUREMENT
22.1 PURPOSE
The purpose of this chapter is to provide a list of standard safety performance measures that can be
used to measure and improve contractor safety performance. The chapter also provides some guidelines for implementing two leading indicator metrics.
22.2 SAFETY PERFORMANCE INDICATORS
Construction companies are always implementing new risk control strategies to improve their company’s safety performance. However, many do not have an adequate process in place to measure the
effectiveness of its risk control strategies. Are these strategies helping improve its safety performance?
Are there any deficiencies that need to be corrected to prevent accidents and injuries? Safety programs
cannot be successful if it does not have a continuous improvement process in place to periodically
“check” its effectiveness and recommend solutions to make it even better.
Safety performance indicators will help contractors to check whether their hazard / risk control strategies are working. There are two common types of safety performance indicators used by the construction companies: (a) lagging indicators and (b) leading indicators. Proper selection of lagging and
leading indicators to measure their safety performance is critical to the success of the contractor’s
safety program. Effective performance measurement should be capable of measuring compliance and
safe/unsafe acts and behaviors.
22.3 LAGGING INDICATORS
Lagging indicators are reactive safety performance measurements that are made after an accident, injury, or illness. They are also called downstream or trailing indicators.1 Lagging indicators are the most
common performance metrics used by construction companies to determine their risks and assess the
effectiveness of their company’s safety programs. Even though, lagging indicators does help identify
some program deficiencies since the contractor has already suffered a loss, the use of lagging indicators
to help improve safety programs has been questioned lately. Example lagging indicators that contractors can consider measuring their past safety performance include:
OSHA Total Recordable Incident Rate (TRIR)
OSHA Days Away, Restricted or Transferred Incident Rate (DART)
Number of days lost per lost time injury
First Aid Injury Rate (FA)
Workers’ Compensation Experience Modification Rate (EMR)
1 Hinze, J. (2005) “A Paradigm Shift: Leading To Safety” 4th Triennial International Conference, Rethinking and Revitalizing Construction Safety,
Health, Environment and Quality. Port Elizabeth – South Africa.
281
Average cost per indemnity claim
DOSH citations or inspections with findings
22.4 LEADING INDICATORS
Leading indicators are proactive safety performance measurements that demonstrate the effectiveness
of existing safety management systems before an accident, injury, or illness. They are also called upstream indicators.2 It will help predict future performance by identifying weaknesses or deficiencies in
the contractor’s program. Leading indicators are useful tools to assess construction site risks associated with current activities and implement corrective actions immediately before the accident; injury or
illness can occur.
Examples of leading indicators, listed under various categories, that contractors can consider using to
measure safety performance include:
Accidents Related
o Percentage of near misses investigated and documented
o Percentage of incidents reported late
o Percentage of JHAs changed as a result of accident investigation corrective actions
Safety Meetings Related
o Percentage of pre-bid meeting conducted and documented
o Percentage of pre-construction meeting conducted and documented
o Percentage of weekly mass safety meeting conducted and documented
o Percentage of safety committee meeting conducted and documented
o Percentage of workers on site attending the mass safety meeting
Safety Planning Related
o Percentage of daily pre-task planning meetings completed and documented
o Quality of the pre-task plans completed
o Percentage of daily job hazard analysis completed and documented
o Quality of the job hazard analysis completed
o Percentage of site-specific safety plan completed
o Quality of site-specific safety plan
o Safety considered during safety look-ahead schedule
o Additional pre-planning for high-risk evolutions
Safety Inspections Related
o Number of the job site safety inspections completed with ZERO violations
o Number of the job site audits performed with performance and documentation in compliance
o Subjective evaluation of the quality of the job site housekeeping
2 Hinze, J. (2005) “A Paradigm Shift: Leading To Safety” 4th Triennial International Conference, Rethinking and Revitalizing Construction Safety,
Health, Environment and Quality. Port Elizabeth – South Africa.
282
o
o
o
o
Percentage of unsafe behaviors observed
Percentage of Personal Protective Equipment (PPE) compliance
Number of unsafe conditions observed
Percentage of safety violations corrected within a day of identification
Safety Training Related Compliance
o Percentage of workers who completed new employee orientation
o Number of orientations with contractor or owner management participation
o Percentage of workers with OSHA 10-hr certification
o Percentage of supervisors with OSHA 30-hr certification
o Percentage of supervisors with First Aid/CPR certification
Employee Involvement
o Worker Safety Perception Survey measuring safety culture
o Percentage of worker safety suggestions addressed within a week of reporting
o Number of management project site walks focusing exclusively on safety performance
Safety Performance Evaluation
o General contractors evaluated and recognized based on leading indicators (incentive
contracts)
o Subcontractors evaluated and recognized based on leading indicators (incentive contracts)
o Supervisors evaluated and recognized based on leading indicators
o Workers evaluated and recognized based on leading indicators
22.5 SELECTION AND IMPLEMENTATION
Incorporating lagging and leading indicators into a contractor safety program should include the following critical steps:
Educate management at all levels about the importance of safety performance measurement.
Obtain their commitment and support to implement a safety performance measurement program at both company and project levels.
Secure all necessary resources to implement the program: funding, personnel, equipment, and
other materials.
Establish scope and purpose of the program.
Identify roles and responsibilities – who will champion this program at the company level? Who
will be responsible at the project level?
Hold those responsible for driving the program accountable.
Select the different types of indicators that your company will measure. It is recommended to
have a balance of both lagging and leading indicators.
Develop an implementation plan that addresses the need, timeline, and tools for measurement.
Ensure all indicators are measurable, quantifiable, accurate and reliable.
Train and educate all personnel involved.
Set benchmarks to the measure of success for each indicator.
283
Develop a distribution or reporting system to share and communicate the progress of the program with the management.
Develop a plan to test the effectiveness of these indicators in measuring company/project safety
performance, and whether it meets your company threshold or goal.
Implement corrective actions if thresholds are not met.
A sample safety performance measure for the project along with goals is presented in Table 22-1. The
project team can use similar reporting tool every month or quarter and come up with corrective actions accordingly.
Table 22-1: Example Leading & Lagging Indicators Project Comparison for AB Company
Leading Indicators
Goal/
Science Goal Met Corrective Actions?
Threshold Building (Y/N)
Unsafe Conditions: % of safety violations
corrected within a day of identification)
Pre-task Plan (PTPs): % of crews completing
PTPs
90%
95%
Y
100%
75%
N
Orientation: Percentage of workers who
completed new employee orientation
Training: Percentage of supervisors with
OSHA 30-hr certification
Behavior: % of unsafe behaviors
Lagging Indicators
100%
90%
N
50%
60%
Y
0%
10%
N
OSHA Total Recordable Incident Rate
(TRIR)
OSHA Days Away, Restricted or Transferred
Incident Rate (DART)
4.0
5.2
N
1.0
0.5
Y
First Aid Injury Rate (FA)
8.0
12.0
N
22.6 SAMPLE PROGRAM DEVELOPMENT GUIDELINES
Two example checklists presented in the Exhibits 22-1 and 22-2 provides guidance for contractors
interested in implementing a Worker Safety Behavior Observation (WSBO), and Pre-Task Plan (PTP)
review leading indicator program.3
Additional Resources, Readings, and References
Construction Industry Institute (CII)
o Leading Indicators for Safety: https://www.construction-institute.org/scriptcontent/
more/284_1_v1-1_more.cfm
o Project Health Indicator Tool: https://www.construction-institute.org/scriptcontent/
more/ir220_2_more.cfm
3 Rajendran, S. (2013). “Enhancing Construction Worker Safety Performance Using Leading Indicators.” Periodical on Structural Design and
Construction, ASCE, 18 (1), 45-51.
284
United Kingdom (UK) Health and Safety Executive (HSE)
o Developing process safety indicators. Available on HSE website for free download
http://www.hse.gov.uk/pubns/priced/hsg254.pdf
The Center for Construction Research and Training (CPWR)
o Performance Metrics: http://www.cpwr.com/research/performance-metrics
285
Exhibit 22-1: Worker Safe Behavior Observation (WSBO) Leading Indicator Program Development Checklist4
Checklist Item
Yes No
The contractor has a need to implement a WSBO leading indicator program.
The upper contractor management, including executive’s support has been secured.
All necessary resources to implement the WSBO program have been secured: funding,
personnel, equipment, and other materials.
The purpose and scope of the program have been established.
The WSBO program will be reviewed during Contractor and subcontractor new employee orientation.
A written WSBO program has been developed and were readily available to employee
review upon request.
The program outlines the roles and responsibilities of upper management, program
owner, observers, and subcontractor management.
The program outlines the observer training requirements that also defines the competence needed for WSBO observers (The observers should, at a minimum possess the
knowledge of contractor safety program and all applicable OSHA guidelines and the
ability to correct unsafe behaviors).
The trainers are competent to train observers. The trainer competence should be defined
in the written program. The training is provided in language trainees will understand.
The program outlines guidelines for the design and development of the WSBO measurement tool – a WSBO card or form. The measurement tool contains the following as a
minimum: (1) date and time, (2) observer name and company, (3) location, (4) number
of workers’ part of the crew being observed, (5) number of workers with safe behavior,
(6) number of workers with unsafe behavior, (7) the nature or type of unsafe or safe
behavior, and (8) corrective action taken by the observer. Unsafe acts listed on the card/
form are tailored to the contractors’ line of work or industry.
The program outlines the observation procedures. Observers should make an observation only for a brief moment (approximately 10 seconds) to verify whether the crew
members are performing safe or unsafe behavior (Observers should not stand and stare
at the workers, since it might make workers nervous about being watched and portrays
observers as safety cops). For example, Figure 1 shows a picture of a worker with improper fall protection.
A minimum of 30 observations is made every week (varies based on the project site).
The WSBO output is quantified by using a “score” for each observation and “frequency” measurement for the nature of the unsafe behavior. The WSBO score is the ratio of
workers with safe behavior to the total number of workers observed, multiplied by 100.
4 Rajendran, S. (2013). “Enhancing Construction Worker Safety Performance Using Leading Indicators.” Periodical on Structural Design and
Construction, ASCE, 18 (1), 45-51.
286
The WSBO score is used to assess the severity of the worker behavior on various projects. For trend analysis, the scores are plotted using line graphs weekly or monthly to
evaluate safety performance. A sample WSBO score trend analysis is presented in Figure
2 for a hypothetical contractor on three different projects, overall company performance,
and the contractor’s goal.
The frequencies of the various unsafe behaviors are plotted on a bar graph weekly or
monthly to evaluate trends. A sample WSBO unsafe behavior frequency analysis is presented in Figure 3. In this example, the contractor should focus its intervention efforts
on hearing protection.
The WSBO program outlines a requirement to set quantified WSBO score objectives.
For example, ABC contractor’s goal is to maintain a WSBO score of 90 or above. These
objectives should be set, reviewed and modified at appropriate intervals to reflect efforts
to achieve continual improvement.
The program outlines the process to introduce safety performance improvement and risk
reduction based on “frequency” trends of unsafe behaviors. For example, on ABC contractor’s job sites 35% of workers were not compliant with eye protection. The objective
should be set to improve this situation and assign resources to achieve established objectives.
The program outlines the process of communicating WSBO results to the contractor
and subcontractor management and all employees. Communication forums include site
safety meetings, newsletters, subcontractor coordination meetings, safety committee
meetings, and management meetings.
On multi-employer worksites, the contractor has a process in place to communicate individual company WSBO results to appropriate subcontractors.
The program outlines a requirement of corrective action plans for subcontractors with
WSBO scores < 50.
A process is in place to incorporate the program requirements in subcontractor contracts to help them budget resources for the WSBO program.
The program outlines data entry and recordkeeping requirements for the measurement
tools.
The program outlines incentives to subcontractors or projects with superior WSBO
scores.
The program outlines process to review and evaluate the WSBO program every year.
287
Exhibit 22-2: Pre-task Plan (PTP) Quality Leading Indicator Program Development Checklist5
Checklist Item
Yes No
The contractor has a need to implement a PTP review leading indicator program.
The upper contractor management, including executive’s support has been secured.
All necessary resources to implement the PTP quality review program have been secured:
funding, personnel, equipment, and other materials.
The purpose and scope of the program have been established.
The purpose and scope of the PTP quality review program are reviewed during Contractor site orientation for all workers. The goal of the PTP review leading indicator
program is to prevent injuries/incidents by ensuring that all tasks are planned and implemented per the plan. This helps identify any trends in deficiency and implement suitable
intervention methods.
A written PTP quality review program has been developed and is readily available for
employee review upon request.
The program outlines the roles and responsibilities of upper management, program
owner, reviewers, and subcontractor management.
The program outlines the reviewer training requirements that also define the competence
needed for PTP reviewers. The reviewers should, at a minimum possess the knowledge of
contractor safety program and all applicable OSHA guidelines. The reviewer should also
have the ability to identify hazards and recommend control measures based on work
tasks.
The trainers are competent to train reviewers. The trainer competence should be defined
in the written program. The training is provided in language trainees will understand.
The program outlines guidelines for the design and development of the PTP review
measurement tool – a PTP review card or form. The measurement tool contains the
following as a minimum: (1) date and time of review, (2) location, (3) task name or description, (4) PTP adequate or inadequate, and (5) the nature deficiency if the PTP was
inadequate.
The program outlines the review procedures. Reviewers should randomly select a PTP
from the work site and thoroughly review the plan for adequacy. Reviewers should provide constructive criticism and not blame workers for a poor PTP. This should be considered an educational opportunity.
The PTP review is quantified by using a “score” for each review and “frequency” measurement for the nature of PTP deficiency. Adequate PTPs should receive a score of 100,
and inadequate PTPs will receive zero. For trend analysis, the scores can be plotted using
line graphs weekly or monthly to evaluate progress.
5 Rajendran, S. (2013). “Enhancing Construction Worker Safety Performance Using Leading Indicators.” Periodical on Structural Design and
Construction, ASCE, 18 (1), 45-51.
288
The various PTP inadequacies should also be quantified by listing the critical steps for a
good PTP in the review card or form: (1) perform the PTP at the work area, (2) identify
tasks to be performed in a sequential order, (3) identify the potential hazards associated with each task, (4) identify the control measures for each hazard, (5) review the PTP
with crew members, (6) crew members signs the PTP, (7) post PTP in the work area, (8)
follow the plan, (9) stop work if there is a change of conditions and make appropriate
changes to the PTP, and (10) discuss all changes with the crew members. Figure 4 shows
an example of an inadequate pre-task plan. This plan was prepared for lifting equipment
off the truck bed and set it inside a building. The plan does not address the essential
steps, hazards, and its control measures. The frequency of these deficiencies can be plotted on a bar graph weekly, or monthly to evaluate trends (see Figure 5, for example).
The program outlines the process to retrain crews with inadequate PTPs.
The program outlines a requirement to set quantified PTP score objectives. For example, ABC contractor’s goal is to maintain a PTP score of 95 or above. These objectives
should be set, reviewed and modified at appropriate intervals to reflect efforts to achieve
continual improvement.
The program outlines the process of communicating PTP review results to the contractor and subcontractor management and all employees. Communication forums include
site safety meetings, newsletters, subcontractor coordination meetings, safety committee
meetings, and management meetings.
On multi-employer worksites, the contractor has a process in place to communicate individual company PTP results to appropriate subcontractors.
The program outlines a requirement of corrective action plans for subcontractors with
PTP scores of less than 75.
A process is in place to incorporate the program requirements in subcontractor contracts to help them budget resources for the PTP program.
The program outlines recordkeeping requirements for the measurement tools.
The program outlines incentives to subcontractor or projects with superior PTP scores.
For example, the crew or subcontractor with the best PTP will be rewarded at the safety
meeting.
The program outlines the process to review and evaluate the WSBO program every year.
289
290
23
CONSTRUCTION SITE ENVIRONMENTAL MANAGEMENT
23.1 PURPOSE
Construction site operations have a high potential for impacting the environment. Contractors who fail
to control site-related environmental exposures can cause harm to the environment and public health.
To protect the environment and the public, there are many environmental standards and regulations
that impact construction operations at the federal, state, and local levels. Failure to comply with these
requirements can result in enforcement action by regulatory agencies and can also cause employee and
public injuries. Furthermore, contractors can be held liable for pollution-related damages resulting in
third-party bodily injury and property damage, which can damage their reputation and public image.
Therefore, the identification and control of the construction-related environmental risks should start
as early as the design phase.
This chapter provides construction contractors some tips to identify and control construction site
environmental exposures. Note, simply being unaware of your environmental regulations does not relieve
you of your environmental liability.
23.2 PROJECT ENVIRONMENTAL POLICY
Develop a project environmental policy to show a commitment to protect the environment. Most
projects integrate it with worker safety and health, to create a “Site Environmental, Safety, and Health
Policy.” Ensure this policy is communicated to all site personnel through site orientation and posting
it on the safety bulletin board.
23.3 ENVIRONMENTAL COORDINATOR
Designate an Environmental Coordinator (EO) for the project that will help achieve regulatory compliance for the project, and ensure all mitigation measures are properly implemented. The project
safety manager assumes this role on medium-scale projects. On large and environmentally complex
projects, a full-time environmental manager can be included as part of the project staffing. The project
superintendent or project engineer should be the designated environmental representative on small
projects. Subcontractors must also provide a designated representative for dealing with environmental
issues. At a minimum, the EO should have the knowledge of the site-specific construction activities
and associated environmental exposures.
23.4 PRE-CONSTRUCTION SURVEY
Perform an environmental risk assessment and identify all potential environmental exposures and
its impacts related to the site’s pre-existing conditions. Consider the following items when evaluating
pre-existing site conditions:
291
Identify any environmental contaminants, pollutants, or hazardous waste onsite
Look for existing underground tanks or pipelines with the potential to cause environmental
damage
Evaluate features of adjacent properties that could pose environmental risks to the contractor
Test soil and water for contamination
Check if the site is environmentally contaminated (brownfield). If so, will the project scope
include remediation?
Check for the presence of toxic mold onsite if work involves the renovation of existing
buildings
See Exhibit 23-1 for an example project environmental checklist from PCL Construction Services, Inc.
This is one of the most comprehensive environmental checklists and would be a great tool for smaller
contractors to use as a starting point.
23.5 RISK ASSESSMENT
Perform a detailed environmental risk assessment and identify all potential environmental exposures
and its impacts associated with all construction operations including vendors, suppliers, and visitor
activities, which will arise at some point during the life of the project. The assessment should consider
any adjacent property within or near the work area that could be vulnerable to environmental damage.
Some of the common sources of environmental risks associated with construction site operations (including subcontractor activities) include but not limited to:
Disturbance to vegetation
Rupture of underground tanks or pipelines
Discovery of contaminated soil
Spills and leaks of contaminants, pollutants, or wastes from on site operations (e.g., Hydraulic line damage of an excavation equipment)
Spills and leaks of contaminants, pollutants, or wastes during transportation (e.g., Release
of hazardous waste due to road accident)
Air emissions and chemical releases from chemicals and HVAC systems
Toxic mold
Construction noise
Disturbance of lead or asbestos-containing materials
Dust (asbestos, silica, etc.)
All disposal risks such as improper disposal of both hazardous and non-hazardous waste
at jobsites
Contaminated waste (e.g., disposing of pressurized aerosol cans in the garbage dumpster)
23.6 INSURANCE
Examine and identify any coverage gaps in your insurance policies (commercial general liability, business auto, and other related insurance policies) as far as providing protection against the pollution-related liability. All subcontractors and their tiers should be required to carry adequate coverage for risks
associated with their operations and require them to add the GC as additional insured.
292
23.7 DESIGNING FOR THE ENVIRONMENT
Review the environmental risks identified in step 23.4 and try to eliminate or minimize them through
project design by specifying environmentally friendly materials. For example, choose less hazardous
and more environmentally friendly products.
23.8 SITE ENVIRONMENTAL MANAGEMENT PLAN (SEMP)
Develop an SEMP integrated into the Site Specific Safety Plan (SSSP) to prevent or minimize any
construction effects on the environment. The SEMP should identify all environmental risks, detailed
mitigation measures, and procedures to implement them. The SEMP should include at a minimum the
following elements:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
Site Environmental Policy
Roles and Responsibilities
Permitting Requirements
Applicable Regulatory and Owner requirements (federal, state, local, and site-specific requirements called in owner contracts)
Site Specific Risks and Controls
Erosion and Sedimentation Controls – to prevent environmental impacts caused by soil
erosion and sedimentation.
Solid Waste Management Plan – to manage solid wastes associated with onsite construction activities (e.g., concrete, wood, scrap metal, glass, drywall, general trash, etc.).
Implement a procedure in place to classify solid waste as hazardous or non-hazardous.
Hazardous Material Controls – to establish procedures for the procurement and management of hazardous materials (e.g., adhesives, paints and thinners, solvents, lead, pesticides, refrigerants coolants such as Freon, etc.). Set up an approval process for any hazardous materials to be brought onsite, and have a policy in place to limit the inventory
of materials to the time frame (e.g., one week).
Hazardous Waste Management Plan – to manage the generation, transport, storage or
disposal of any regulated hazardous waste such as used oil, spent solvents, PCBs, asbestos, paint wastes, thinners, etc.
Air Pollution Controls – to prevent or minimize air pollution associated with construction activities.
Waste Water Management – to manage all construction related wastewater such as truck
wheel wash, concrete washout, equipment cleaning, dewatering, cleaning of painting
equipment, etc.
Spill Prevention and Response Plan – response plan to spills of chemical, fuels, and other
substances.
Environmental Performance Metrics
Environmental Training
Inspection Requirements
Environmental Incident Reporting and Investigation
Emergency Responses
Continuous Improvement
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23.9 REGULATORY AGENCY RELATIONS
Schedule an onsite meeting with local environmental regulatory agency representatives and go over the
project scope and share the SEMP. Apply and obtain “applicable” environmental permits and licenses
for the site (e.g., general stormwater permit, the Joint Aquatic Resources Permit Application (JARPA),
etc.).
23.10 SUBCONTRACTOR SELECTION
Include environmental performance factors as part of the subcontractor safety pre-qualification process. Refer to chapter 3 of this handbook for more information about subcontractor selection.
23.11 CONTRACTS
Share the SEMP and communicate site environmental requirements for the project with potential bidders through a request for proposals (RFP) and pre-bid meetings, so contractors can allocate resources appropriately in the bid. The EO should be involved during the project proposal phase, contract
management phase, pre-award and pre-mobilization meetings to ensure that the site environmental
expectations are clearly defined and communicated to help the project avoid enforcement action. Include site environmental requirements in the contracts. All pre-construction or pre-award meetings
should include a review of all environmental standards and regulations, as well as an explanation of
project-specific requirements that are above and beyond compliance. Subcontractors should be contractually required to examine their activities and carry out an environment risk assessment before
commencement of work.
23.12 ENVIRONMENTAL CONTRACTORS
Select a hazardous waste transporter, treatment or disposal contractor. Ensure they have the appropriate permits, licenses, and necessary insurance coverage.
23.13 ENVIRONMENTAL EQUIPMENT
Procure all environmental control related equipment and supplies such as spill response kits, hazardous
waste storage shacks/containers, emergency response equipment, and personal protective equipment.
23.14 TRAINING AND EDUCATION
Train workers and supervisors on the general site environmental risk factors and associated mitigation
measures, as part of the site’s new employee orientation. Identify and conduct any special training
required as part of the project environmental requirements (e.g., hazardous waste operations). Ensure
all training records are maintained on site and are readily accessible. The training should also include
proper environmental incident reporting procedures and emergency action plan.
21.15 IMPLEMENTATION OF SEMP
Implement the Site Environmental Management Plan (SEMP). Advise all supervisors to consider “environmental risks” as part of their daily pre-task planning.
23.16 ENVIRONMENTAL PERFORMANCE MONITORING
Develop environmental performance metrics (objectives) similar to worker safety, to improve project
environmental performance. The site can measure environmental performance using total points ob294
tained in a weekly site environmental inspection. For example, the inspection results can be a score
from 0 to 100 to reflect the environmental compliance of the construction site. Each inspection starts
with a score of 100. One point is deducted for a minor non-compliance item (e.g., gap in silt fence),
and two points should be deducted for a major violation (e.g., missing catch basin filter). At the end of
each inspection, the net scores should be computed and recorded. The project can set a goal to a score
of 90 every week. Any deficiencies identified during the inspection should be fixed right away. The inspection should focus on the effectiveness and condition of the following environmental controls, but
not limited to:
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
General project housekeeping
Construction site entrance cleanliness (e.g., dirt on the road)
Dust suppression
Erosion control blankets
Filter strips
Mulching
Silt fencing
Sediment traps
Condition of concrete washout areas
Concrete batch plant
Equipment fueling area controls (designated area) and containment systems (e.g., berms
and dikes)
Equipment cleaning area
Equipment maintenance (condition of hydraulic lines and emission control systems)
Visual inspection of dumpsters to check for waste contamination
Spill kits
Hazardous waste containment and cleanup
Bulk storage area
Material use and recycling
23.17 INCIDENT REPORTING AND INVESTIGATION
All personnel should be required to report any and all spills or incidents that occur on site immediately
to the site EO or their immediate supervisor. All environmental incidents should be documented and
investigated to determine the cause and prevent reoccurrence. See Exhibit 23-2 for an example spill incident form. Ensure the project has the contact numbers of relevant jurisdictional environmental agencies for reporting of environmental incidents. Please refer to the contents of an emergency response in
chapter 17 of this handbook.
23.18 PROGRAM REVIEW
Require the project management to perform a quarterly audit to review the overall effectiveness of the
site SEMP, identify and correct any deficiencies.
23.19 RECORDS RETENTION
Retain all records, reports, permits, self-inspection forms, as part of the project archive.
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Additional Resources, Readings, and References
U.S. Environmental Protection Agency (EPA) – Managing Your Environmental Responsibilities:
A Planning Guide for Construction and Development - http://www.epa.gov/compliance/resources/
publications/assistance/sectors/constructmyer/myerguide.pdf
Zurich® - Construction Environmental Best Practices - http://www.zurichna.com/internet/zna/sitecollectiondocuments/en/knowledge%20center/whitepapers/construction/construction_env_best_practices.pdf#page=1
U.S. Environmental Protection Agency (EPA). Green Buildings. http://www.epa.gov/greenbuilding/index.htm
Construction Industry Compliance Assistance (CICA). http://www.cicacenter.org/. CICA is your
source for plain language explanations of environmental rules for the construction industry. This
information is provided free of charge by the National Center for Manufacturing Sciences in partnership with The Associated General Contractors of America (AGC). Funding for this project has
been provided by the U.S. Environmental Protection Agency and AGC.
296
Exhibit 23-1 Example Project Environmental Planning Checklist (page 1)
(Used by permission from PCL Construction Services Inc.)
297
Exhibit 23-1 Example Project Environmental Planning Checklist (page 2)
(Used by permission from PCL Construction Services Inc.)
298
Exhibit 23-1 Example Project Environmental Planning Checklist (page 3)
(Used by permission from PCL Construction Services Inc.)
299
Exhibit 23-1 Example Project Environmental Planning Checklist (page 4)
(Used by permission from PCL Construction Services Inc.)
300
Exhibit 23-1 Example Project Environmental Planning Checklist (page 5)
(Used by permission from PCL Construction Services Inc.)
301
Exhibit 23-1 Example Project Environmental Planning Checklist (page 6)
(Used by permission from PCL Construction Services Inc.)
302
Exhibit 23-1 Example Project Environmental Planning Checklist (page 7)
(Used by permission from PCL Construction Services Inc.)
303
Exhibit 23-1 Example Project Environmental Planning Checklist (page 8)
(Used by permission from PCL Construction Services Inc.)
304
Exhibit 23-1 Example Project Environmental Planning Checklist (page 9)
(Used by permission from PCL Construction Services Inc.)
305
Exhibit 23-1 Example Project Environmental Planning Checklist (page 10)
(Used by permission from PCL Construction Services Inc.)
306
Exhibit 23-1 Example Project Environmental Planning Checklist (page 11)
(Used by permission from PCL Construction Services Inc.)
307
Exhibit 23-1 Example Project Environmental Planning Checklist (page 12)
(Used by permission from PCL Construction Services Inc.)
308
Exhibit 23-1 Example Project Environmental Planning Checklist (page 13)
(Used by permission from PCL Construction Services Inc.)
309
Exhibit 23-2 Example Environmental Spill Report
(Used by Permission from PCL Construction Services Inc.)
310
24
PROJECT COMMISSIONING AND TURNOVER
24.1 PURPOSE
Commissioning, closeout, and turnover is the last phase of the construction project life cycle. Commissioning is done to ensure the building systems, equipment, and the overall facility functions correctly.
Many construction workers may be assisting with the system startups while some engaged in final
clean-up for turnover, and the rest fixing final punch list items. This overlap between the construction
and commissioning phase can introduce unique safety challenges to the contractors. The safety of all
personnel and the protection of newly installed equipment and systems from damage should be an
important consideration during this final phase.
Contractors should ensure that the exposures during this stage are addressed in the Site Specific Safety Plan (SSSP). Below, is a non-exhaustive list of items that the project team should consider during
commissioning, closeout, and the final turnover process.
24.2 PROTECTION OF FINISHED PRODUCTS
Most owners expect their final product to be high quality with zero defects and are pushing for zero
punch list items. Why should a contractor focus quality in an SSSP? Anecdotal evidence suggests contractors who produce the highest construction quality are also some of the safest contractors. Defective construction work can result in:
Rework that results in workers performing work in tight or confined places, working on or
near live systems, increasing their risks of injuries.
Products and equipment that could later fail and cause severe injuries and/or property damage.
Increased construction cost and delays.
Hence, contractors should develop a plan to emphasize quality and a way to protect finished product
such as:
Preventing roof damage with proper roof access and work protocol.
Protect floors and walls by limiting equipment such as scissor lifts that can cause damage or
by putting down plywood or plastic.
Clean all surfaces so construction dust cannot impede sensitive functions of the vital equipment.
Emphasize quality during site orientation.
311
24.3 PROTECTION OF OWNER’S LIVE SYSTEMS
On many projects, especially industrial facilities, the owner will require the contractor to turn over
individual equipment or part of the facility to its control before substantial completion. At this time,
construction workers are performing work on or near potentially live systems. This is common in renovation or retrofit work inside existing facilities. How do contractors prevent or minimize impacts to
owner’s operating facility, services, operations, and personnel? One method is to implement a process
called SimOps {Review of Simultaneous Operations}. Simply put, this is a process of hazard analysis
identifying a risk when one or more and separate operations are operating or exist in one geographical
area within a facility or site. The hazard analysis will identify hazardous scenarios, consequences, hazard controls and responsibilities to ensure operations are conducted and achieved in accordance with
the risk factors as low as reasonably practicable.
Each facility presents its unique risks; the contractor should work closely with the client to ensure
proper coordination and communication between them to minimize exposure to live energy. A LockOut-Tag-Out (LOTO) plan shall be in place and followed to ensure no one is exposed to any live
energy including steam, sewer, mechanical, high pressure, electrical, etc. Contractors should develop
and implement industry best practices such as “Construction Incident Prevention Plan (CIPP)” or
“Facility Incident Prevention Plan (FIPP)” for any work that might pose a potential risk to the owner’s
personnel and systems.
The CIPP/FIPPs is a communications tool that ensures that all appropriate information has been
presented to the owner, and necessary approval has been obtained from the facility’s system owners.
It helps prevent or minimize incidents and business interruptions. See Exhibit 24-1 for a sample FIPP
form. Some examples include:
Interim Life Safety Measures & Infection Control during Construction in hospitals
Any work (e.g., excavation) near or around utilities that feed a live operating facility
Crane work over occupied owner areas
LOTO plan establishing the competent person
Any work involving utilities (e.g., electrical) which feeds a live operating facility
Concrete coring or saw cutting
Odor producing activities
24.4 OVERLAPPING SAFETY PROGRAMS
Typically the owner will implement a separate facility safety program in place after either full or part
of the facility is turned over. Some of the following questions should be considered at this point:
How will the contractor and the owner manage overlapping safety programs?
Will owner’s staff and commissioning contractors (contracted with the owner) working in
contractor controlled areas go through contractor orientation?
What about owner’s staff or building occupants working on or near a system that is still
under the contractor’s control?
How will the programs such as hot work permits, energized hot work permits, confined
space permits, lockout / tag out permits be managed?
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Will the construction personnel be required to go through owner’s facility orientation?
What about the PPE requirements in the owner and contractor controlled areas?
24.5 CONCURRENT WORKFORCE
Commissioning and other owner personnel must make themselves familiar with contractor safety procedures when working within contractor controlled areas, and the contractors should be familiar with
the owner managed areas. The project team’s primary goal should be to assess and control the potential risks to the facility’s employees from contractors’ activities, and to the contractors’ employees from
the facility activities.
24.6 WARRANTY WORK
A typical warranty period lasts approximately 12-months from project turnover, and the same safety
procedures must be followed when construction workers show up to conduct warranty work. The hazards of the warranty work can be similar to those during construction, commissioning, and turnover.
313
Exhibit 24-1: Example Facility Incident Prevention Plan Template
Date submitted:
Company:
Requester:
Phone:
Supervisor:
Phone:
Safety contact:
Phone:
Owner contact:
Phone:
Location of work (include drawings with grid lines and levels):
Start date:
Start time:
Scope of work:
Finish date:
Finish time:
List all facility systems potentially impacted by the scope of work (Electrical, fire alarms, natural gas,
etc.):
Detailed Job Hazard Analysis performed and attached?
All special permits required have been obtained?
All impacted system owners notified and received approval to proceed?
All issues regarding overlapping safety programs resolved?
OWNER APPROVAL
System Name:
Owner Name
Sign
System Name:
Owner Name
Sign
Approved Date
From:
To:
314
o Yes o No
o Yes o No
o Yes o No
o Yes o No
Date
Date
25
PROJECT SAFETY RECORDS MANAGEMENT
25.1 PURPOSE
Every construction company should establish a written record retention policy that should be applied
consistently to the records of their projects. Safety records should be an integral component of this
policy. Failure to maintain records required by law could subject a firm to penalties and fines, or other
legal consequences. Some companies might be concerned that site records might be used against them
when responding to lawsuits. However, proper record retention practices can also protect them from
lawsuits brought against them, by helping prove that they did their due diligence to protect their workers and the members of the public.
Note: Construction companies should consult their attorneys, and review all local, state, and federal
government record retention requirements before finalizing their safety record retention procedures.
This chapter offers site safety records retention guidance for construction firms. The guidance provided in this section is not a legal advice.
25.2 RECORDS RETENTION POLICY
When developing a record retention policy, the following questions should be considered.
1.
2.
3.
4.
5.
What records should be retained?
How long the records should be retained?
Should the record retention requirements be included in the construction contracts?
In what form should the records be stored?
How will the records generated by each project archived? Who will be in charge to oversee the
archiving process? Where will it be stored?
6. Is the company storage facility secure?
7. How will the records be disposed of at the end of required retention time?
25.3 TYPES OF RECORDS
At a minimum, the project safety records should include the following materials (depending upon the
terms of the contract other project safety records may be necessary). Remember any of these records
could be read in courts in a lawsuit situation, so contractors have to make sure the records are accurate and credible with only “facts.”
25.3.1 Employee Records
These records will help when responding to lawsuits relating to workplace injuries and discrimination/
harassment lawsuits.
315
o
o
o
o
o
o
o
New employee orientation checklist
Drug and alcohol testing-related forms
Employee training records
Employee injury records
Employee disciplinary records
Employment records (timesheet / payroll records)
Exposure records – Division of Occupational Safety and Health (DOSH) required workplace health exposure records and medical records, retained for the duration required by
DOSH.
o Medical records – if employees underwent any medical treatment at the onsite medical
facility (e.g., nurse station).
25.3.2 Government-Records
Many government regulatory agencies require employers to maintain certain records for a specified
period. For example, OSHA’s Recordkeeping regulation requires employers to prepare and maintain
records of serious occupational injuries and illnesses, using the OSHA 300 Log. Similarly, DOSH requires employers to maintain medical evaluation records for the duration of employment plus thirty
years. Hence, construction employers should review all regulatory requirements they are subject and
comply with their recordkeeping and retention requirements.
o
o
o
o
o
o
DOSH/WAC codes (version during the project duration)
OSHA 300 Log and OSHA 300A summary page
DOSH consultation reports if any
DOSH inspection records
DOSH citations and notices
Other government agency inspection records and any resultant citations
25.3.3 Accident Investigation Package
Accident-related records for all injuries, incidents, and illnesses, involving employees, visitors, and the
public. The package should include incident reports, witness statements, pictures, handwritten notes
used by the investigators, recommendations, and any follow-up on the recommendations. All evidence
(paper, photos, pictures, and physical) collected as part of the investigation process should be properly
archived.
25.3.4 Safety Meetings
All safety meeting related records such as agenda, meeting minutes, and sign-up sheets. A few examples of safety meetings include:
o Project overall mass-safety meetings
o Safety personnel meetings
o Toolbox meetings
25.3.5 Safety Inspections
Records related to site safety inspections performed by insurance consultants, project owners, subcontractors; equipment related inspections, tool inspections (ladders, slings, fall protection, etc.), en316
vironmental inspections and reports, etc. Ensure all safety hazards and issues identified during these
inspections were fixed and documented accordingly.
25.3.6 Meeting Minutes
Most site meetings discuss safety issues/updates as the first agenda item. Hence, it is critical to store
all meeting minutes including:
o Subcontractor weekly coordination meetings
o Daily foremen meetings
o Pre-bid meetings
o Pre-award meetings
o Pre-construction meetings
o Any other meetings where safety was discussed
25.3.7 Safety Planning Related Documents
General Contractor’s Site Specific Safety Plan (SSSP) & all documents generated as a result of the
SSSP requirements. For example, the SSSP might require hot work permits, confined space permits,
crane critical lift plans, etc. All these documents should be retained.
o SSSPs of all Subcontractors and its tiers
o All project Job Hazard Analysis (JHA)
o All project Pre-task Plan (PTP)
o Air / noise monitoring results
o Hazardous waste manifests
o Hazard communication program / SDS for each job
25.3.8 Project Safety Correspondence
All safety related correspondence (E-mails, memos, letters, notes of telephone conversations, etc.) between the general contractor and owner, general contractor and architect/engineer (A/E), general contractor and subcontractors, etc.
25.3.9 Contract Documents
o Safety pre-qualification documents
o Contract drawings
o Contract Specifications
o Contracts between owner and general contractor
o Contracts between the general contractor and subcontractors
o Documentation of any changes to your contract
25.3.10 Daily Work Record (DWR) / Job Diaries
A DWR documents the contractor name, work description, work location, equipment involved, crafts
names and hours worked, visitor information, any construction related issues, safety meetings attended or inspections participated, accidents on the project and any other information pertinent to the
work. All contractors performing work on the job site should complete a DWR. The DWRs has provided valuable evidence during contractual disputes and legal actions.
317
25.4 RECORD RETENTION DURATION
The minimum retention period for project-related safety records will be governed by:
o Regulatory requirements specified by government agencies such as DOSH, Mine Safety and
Health Administration (MSHA), Environmental Protection Agency (EPA), Department of
Transportation (DOT) recordkeeping requirements, and also by other applicable legal (law)
requirements.
o Terms of the contractual requirements.
o The Statute of Repose/Statute of Limitations in the state where the project was completed. For
example in Washington State, the statute of limitations for filing a personal injury lawsuit is
three years, and it is two years in Oregon. The firm should consider these factors when deciding
how long to store their records.
25.5 RECORD RETENTION IN CONTRACTS
All contracts generated as part of the project (contracts between the owner and general contractor,
and contracts between general contractor and subcontractors) should clearly state the documents to
be archived/retained as part of the project.
25.6 STORAGE
Construction projects generate both electronic and paper records. Some companies are incorporating modern technologies such as smartphone apps to perform safety inspections, site exposure assessments and conduct pre-task planning meetings. They also use learning management systems to
manage training and store related records. However, construction projects still generate lots of paper
records, and contractors should plan on storing both paper and electronic records. Separate policies
should be developed to addresses both these formats.
25.7 ARCHIVE
Every project typically has an office manager who is designated as the keeper of the records. At the
end of the project, the office manager should work with all major disciplines within the project such as
payroll, cost, schedule, contract, safety, etc., to archive records generated in each area. Usually, each
discipline should be coded, and records are stored in boxes and transported to a remote storage facility. For example, safety might be coded as “1” and safety-related documents might be archived in boxes
1-1, 1-2, 1-3, etc. See example project safety filing system provided in Exhibit 25-1.
It is critical to protect the paper records from risks such as water damage, fire damage, vandalism or
theft. Some firms have built or rented a storage warehouse with a rack system, and use large archive
boxes to store paper documents. These buildings are secured and are protected against fire and water
damages.
All project-related electronic records should be stored online in a secure manner in multiple locations.
The company’s Information Technology (IT) professionals should able to assist with the safe and secure (password protection) storage of electronic records. All electronic mails (E-mail) should be saved
either in hard copy or downloaded as a computer file. In addition, some companies convert paper
records into electronic format using scanning, so they are stored forever.
318
Individual employee records are governed by privacy laws such as HIPPA. These include OSHA 300
logs, drug and alcohol testing records, and medical records. These records should not be accessible to
unauthorized personnel.
25.8 DISPOSAL
A large high-rise building project, depending on specific requirements, might generate thousands of
documents. These documents take up a lot of storage space. Hence, it is critical to determine the life
of each document and come up with ways to dispose of them at the end-of-life. Before destroying any
project-related documents, it is advisable to seek legal counsel.
319
Exhibit 25-1: Example Safety and Health Filing System
(Used by permission from BNBuilders)
Administration
A. Warning / Dismissal Notices
• Project Health & Safety Committee Meeting Minutes
• Health & Safety Correspondence
• Incident Reports Log
• Corporate Health & Safety Committee Memos
• Operating Group Safety Committee Memos
• Visitor Sign-In Sheets
BNBuilders Manuals
B. Zero Injury Training Manual
• Mobile Crane Training Manual
• Crisis Management Manual
• Site Specific Safety Manual
• Hazard Communications Manual
• SDS’s
• Safety Supplies Catalog
• Substance Abuse Policy Booklets
• Project Incentive Program
• Safety Orientation Booklet
• Disruption Avoidance Plans (If Applicable)
Subcontractor Manuals
C. Subcontractor Site Specific Safety Manual
D. Subcontractor SDS’s
• Workers Comp. / Insurance
• DWC Form 1 (Blank)
• W/C Reporting Forms (Blank)
• First Incident Reports (Blank)
• Incident Investigation Forms (Blank)
• Completed Incident Reports (Shall include completed copies of all forms noted above and
subsequent documents relating to the incident.)
E. DOSH
• OSHA 300 Logs
• Consultation Visits
• Inspections / Citations
• Construction / Excavation / Scaffold Permits
• Tower Crane Submittal and Permit to Operate
• Man/Material Hoist Permit and Inspections Records
320
F. Training
• Orientation Records
• Safety Meetings
• Subcontractor Safety Meetings
• Employee Training Records
• Re-Training Records
G. Loss Control
• Jobsite Audits
• Insurance Co. Audits
• PAHA’s
• Pre-Task Planning Cards
• Pre-Construction Meeting Minutes
• Scaffold Inspections (If Applicable)
• Confined Space Permits (If Applicable)
• Excavation Inspections (If Applicable)
• Equipment and Scaffold Waivers
H. Medical
• Medical Provider / Clinic Information
• Chain of Custody Forms
• Prescription Eyewear Program
• Respirator Physical
• Respirator Fit Test Records
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