Pam Susi CPWR – Center for Construction Research and Training What is a focused inspection? When
a general construction contractor has implemented a safety and health
program — with worker involvement — that appears to be effective, an
OSHA inspector may choose to conduct only a partial inspection of a
worksite, focusing on the hazards known to cause the most deaths.
The focused inspections look at these types of hazards:
The focused approach assumes that:
Why does OSHA use focused inspections? OSHA's focused inspection program is intended to direct limited inspection and enforcement resources where they are most needed in the construction industry. A focused inspection takes about one-fourth to one-third the time of a full inspection. An inspector thus can inspect more projects, especially those lacking safety and health programs.Injuries kill more than 1,000 construction workers each year in the United States — more than in any other industry. Nearly 200,000 workers are seriously injured each year. Roughly three-fourths of the deaths in construction are linked to the four hazards:
What happens during a focused inspection? To quality for a focused inspection, a site must have:
As in other inspections, worker representatives are invited to go with the OSHA compliance officers to assist in the inspection. The reps should be chosen by the union(s) or workers on site. In a focused inspection, the OSHA inspector does five things: 1. Finds out if there is a comprehensive safety and health program covering all employers on the project and a designated competent person (s). The inspector asks officials of the "controlling" or overall/ general contractor, for a paper copy of the program. If there isn't a document, the inspector asks the competent person on site about the program and how it is used by all contractors on the site. The program must assure compliance with OSHA regulations. (OSHA also has guidelines about good programs.) If there seems to be no coordination among contractors, a full inspection will normally take place. 2. Asks questions to ensure the program works. The inspector looks for evidence the program works. OSHA 300 logs are checked. Inspectors talk to workers, foremen, superintendents, and safety reps about how the program is run and by whom, the most important safety hazards on the project, how quickly identified hazards are corrected, and how workers are trained. Workers are expected to have participated in setting up and implementing the program; this usually means a joint safety and health committee with worker representatives from all trades on site, elected by the workers or union(s). The inspector looks for such things as evidence of a fall protection system, compliance with excavation procedures, safety railings, wash-up facilities, and effective housekeeping. Workers must be trained about possible hazards and how to avoid them. Topics range from general safety and health hazard awareness to specific knowledge of chemicals (such as, asbestos and lead). Other topics workers should be trained on include fall protection, underground construction, ladders, ground-fault protection, and compressed air. (These rules are all in 29 CFR Part 1926, the OSHA construction standard.) 3. Concentrate on the four major hazards during the inspection. If the site qualifies for a focused inspection, the inspection is limited to the four high-risk hazards. This means the inspector:
An inspector is not to cite (write up) problems considered "other than serious,"** if they are fixed as the inspector watches.However, serious legal infractions and other-thanserious violations that are not fixed right away must be cited. Finding serious problems does not automatically change an inspection from focused to comprehensive, although an inspector usually will decide to expand an inspection. If citations are issued, contractors who qualify for a focused inspection will normally get a 25% reduction in the assessed monetary penalty because of their "good faith" in having a safety and health program. 5. Justifies why a focused or comprehensive inspection is done. All contractors and employee reps on a site are told what type of inspection is being done and why. This can be done in person or on an OSHA form, which the inspector can give to the contractor to post at the site. Making focused inspections work for you Here are suggestions about how to take advantage of focused inspections as an employer, worker, or worker rep. These approaches can save money (in compensation costs, fines, and liability) and lives.General contractors/employers
For more information: OSHA
Documents on the OSHA Internet web site (http://www.osha.gov)
Contact your local area office or your state plan office or call 1-800 321-OSHA and you will be put in touch with the OSHA office nearest you. Ask for the construction coordinator at each regional office: Region I (Boston) 617-565-9860 Region II (New York) 212-337-2378 Region III (Philadelphia) 215-861-4900 Region IV (Atlanta) 404-562-2300 Region V (Chicago) 312-353-2220 Region VI (Dallas) 214-767-4731 Region VII (Kansas City) 816-426-5861 Region VIII (Denver) 303-844-1600 Region IX (San Francisco) 415-975-4310 Region X (Seattle) 206-553-5930 These are phone numbers for OSHA state plans: Alaska, 907-465-4839 Arizona, 602-542-5795 California, 415-703-5070 Hawaii, 808-586-9116 Indiana, 317-232-2378 Iowa, 515-242-5870 Kentucky, 502-564-3070 Maryland, 410-767-2213 Michigan, 517-322-1814 Minnesota, 651-284-5372 Nevada, 702-687-5240 New Mexico, 505-827-4230 North Carolina, 919-807-2861 Oregon, 503-378-3272 Puerto Rico, 787-756-1100 South Carolina, 803-734-9606 Tennessee, 615-741-2793 Utah, 801-530-6898 Vermont, 802-828-2765 Virgin Islands, 340-772-1315 Virginia, 804-371-2327 Washington, 360-902-5495 Wyoming, 307-777-7786 Related standards
Some Building Trades Contacts BCTDBuilding and Construction Trades Department 1155 15th St., NW, 4th Floor Washington DC 20005 Tel: 202-347-1461 Fax: 202-628-0724 www.bctd.org BCTD Research Arm CPWR – Center for Construction Research and Training 8484 Georgia Ave., # 1000 Silver Spring, MD 20910 Tel: 301-578-8500 Fax: 301-578-8572 www.cpwr.com BCTD Affiliates International Association of Heat and Frost Insulators and Asbestos Workers 9602 Martin Luther King Hwy. Lanham, MD 20706 Tel: 301-731-9101 / Fax: 301-731-5058 www.insulators.org International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers and Helpers 753 State Ave. Kansas City, KS 66101 Tel: 913-371-2640 / Fax: 913-281-8101 www.boilermakers.org International Union of Bricklayers and Allied Craftworkers 1776 Eye St. NW Washington, DC 20006 Tel: 202-783-3788 / Fax: 202-393-0219 www.bacweb.org United Brotherhood of Carpenters and Joiners of America 101 Constitution Ave., NW Washington DC 20001 Tel: 202-546-6206 / Fax: 202-543-5724 www.carpenters.org International Brotherhood of Electrical Workers 1125 15th Street, NW Washington DC 20005 Tel: 202-833-7000 / Fax: 202-728-6099 www.ibew.org International Union of Elevator Constructors 7154 Columbia Gateway Dr. Columbia, MD 21046 Tel: 410-953-6150 / Fax: 410-953-6169 www.iuec.org International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers 1750 New York Ave., NW, #400 Washington DC 20006 Tel: 202-383-4800 / Fax: 202-638-4856 www.ironworkers.org Laborers International Union of North America 905 16th Street, NW Washington DC 20006 Tel: 202-737-8320 / Fax: 202-737-2754 www.liuna.org International Union of Operating Engineers 1125 17th St., NW Washington DC 20036 Tel: 202-429-9100 / Fax: 202-778-2619 www.iuoe.org Operative Plasterers and Cement Masons International Association of the United States and Canada 14405 Laurel Pl., Suite 300 Laurel, MD 20707 Tel: 301-470-4200 / Fax: 301-470-2502 www.opcmia.org International Union of Painters and Allied Trades 1750 New York Ave., NW Washington DC 20006 Tel: 202-637-0700 / Fax: 202-637-0771 www.iupat.org United Union of Roofers, Waterproofers and Allied Workers 1660 L St., NW, Suite 800 Washington DC 20036-5603 Tel: 202-463-7663 / Fax: 202-463-6906 www.unionroofers.org Sheet Metal Workers International Association 1750 New York Ave., NW Washington DC 20006 Tel: 202-783-5880 / Fax: 202-662-0894 www.smwia.org International Brotherhood of Teamsters 25 Louisiana Ave., NW Washington DC 20001 Tel: 202-624-6800 / Fax: 202-624-8102 www.teamsters.org United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of the United States and Canada 901 Massachusetts Ave., NW Washington DC 20001 Tel: 202-628-5823 / Fax: 202-347-4938 www.ua.org Definitions Citation - The notice OSHA sends to employers and to local unions describing a hazard, the OSHA standard or section applicable to the hazard, the date for abatement, and the penalties. Citations are alleged for 15 working days after the employer receives them. During this 15-day period, the employer and employee representatives can ask for an informal meeting with the office that issued the citations. The employer can ask for a deletion of a citation or penalty. The employer or employee representative can ask for a change in the abatement date. Proof of abatement is required under 1903.19. Competent person - Someone who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees and who has authorization to take prompt, corrective measures to eliminate them. Inspections Comprehensive - The OSHA Field Inspection Reference Manual (1994) says this is a "substantially complete" inspection of areas that may have a fair number of hazards. It does not mean that all possible hazards are inspected. Partial - The OSHA Field Inspection Reference Manual says this type of inspection is focused on certain areas, operations, conditions, or practices that may be hazardous. During an inspection, it may become obvious that a focused inspection is not enough. In such a case, the inspector can use "professional judgment" to expand the inspection. Safety and health program - A safety and health program usually starts with a written plan that spells out the goals of having a safe and healthy workplace. The rest of the document explains how the safety and health laws and regulations are to be obeyed, in plain language — with an analysis of stages or activities that require special safety inspection or supervision. Among other topics, the plan should include procedures regularly inspecting for and correcting potential hazards, where material safety data sheets are kept, supervisor and worker safety training, toolbox meetings, and procedures for injury reports. Safety and health committee - A committee that can be set up in a union or union local to investigate safety and health problems, train union members, or represent members' interests in dealings with government, employers, or other unions. Site-based joint labor-management committees are required in Washington state and some Canadian provinces, such as Ontario. Even if not required, a committee can be set up by contract or agreement with the employer — and is an excellent way to demonstrate employee involvement in safety and health programs. Construction site committees are usually multi-union, with at least half the committee members representing unions on the job. Violation - A citation from OSHA indicating that a specific part of the OSHA law or regulation was not obeyed or used. Serious - OSHA believes it is likely that a worker could die or be seriously injured by the situation. Other-than serious - Death or serious physical harm is not the most likely result from a hazardous situation. However, the problem does have a direct and immediate relationship to a worker's health or safety. *OSHA defines a competent person as one who can identify existing and predictable hazards and is authorized to act promptly to correct them. ** "Other than serious" violations have a direct and immediate relationship to a worker's health or safety, but are not likely to result in death or serious physical harm. |