Do you want the next OSHA inspection of your construction sites to go smoothly and quickly? Then make sure you have a solid program in place to address the top four leading causes of construction industry deaths: falls from elevations (floors, platforms and roofs), struck bys (falling objects and vehicles), caught ins or caught betweens (cave-ins, unguarded machinery and equipment), and electrical shock (overhead power lines, power tools and cords, outlets and temporary wiring).
Focusing on these four hazards does not mean you can ignore other safety and health matters at your sites. Still, giving the top four attention can shorten your OSHA inspection time, let alone go a long way toward making your sites safer places to work.
When you add up the top four hazards, you get the causes of 90 percent of deaths at construction sites. Falls alone account for a third.
It was through this recognition, as well as the realization that inspection resources were limited, that OSHA unveiled its Focused Inspections Initiative in Construction 6 1/2 years ago. "The focused inspection was designed so we wouldn't spend a lot of time on work sites that were really fairly safe work sites," explains H. Berrien Zettler, deputy director for the Directorate of Construction at OSHA.
In short, focused inspections allow responsible contractors to avoid lengthy inspections as long as they meet certain qualifications. They must have a written safety program and a designated person to implement it, and must comply with safety measures addressing the top four hazards.
If all is in order, an OSHA compliance officer inspecting the site can leave. To the heart of the matter, that means more time for OSHA to spend at unsafe work sites, where the agency feels it can do more good.
Focused inspections are a significant departure from the early 1990s and before, when all contractors visited by OSHA got a full inspection, no matter what. "A lot of contractors, especially the ones that [made] an honest effort and devoted resources, were having OSHA just walk on their jobs for weeks until they found something," recalls Jim Lapping, vice president of EEI Holding of Springfield, Ill. Lapping was with OSHA from 1994 to 1998 and helped develop the focused inspections policy. The mandatory full inspections were "giving OSHA a bad reputation and disrupting the work place," he explains.
According to OSHA, the number of focused inspections has increased slightly over the years, from 1,789 in 1996 to 1,822 in 2000. As a percentage of total construction inspections, the rates have actually decreased from 15.7 percent to 9.3 percent over the same time period.
"From our point of view, I wouldn't say we're getting to more construction sites. I would say we're getting to more hazardous sites," Zettler says. "We're able to focus more on those sites where we are finding violations and less time on the sites that are safe."
Response to the Program
Today, many people in the industry speak favorably of focused inspections. "Focused inspections have been effective," says Steve Cloutier, manager of special projects for Environmental, Safety and Health Services at Bechtel Corp., headquartered in San Francisco. Through focused inspections, OSHA provides "better utilization of the OSHA compliance officers' time and effort."
But Larry Edginton, director of safety and health for the International Union of Operating Engineers (IUOE), cautions that focused inspections are not the "be all, end all." "One should not assume that, just because you get a clean bill of health on those four major hazards, there are not other hazards on the job," he says.
By the same token, Rick Kaletsky, a Connecticut-based consultant and author of OSHA Inspections: Preparation and Response (updated for 2001), wants contractors to remember to focus on all worksite hazards, not just the top four. "I like you to put your efforts everywhere," he says.
Keys to Success
Among the many challenges in keeping a construction site safe are the number and variety of subcontractors working alongside each other -- inside and outside the project -- and continual changes in tasks being performed. "A construction site is a very fluid, dynamic process," Cloutier notes. "Things change daily, sometimes by the minute."
According to Cloutier, one of the keys to a top-notch construction safety program is having support throughout the organization. "You have to have senior management's complete support and buy-in," he says. Further, you "need to communicate the organization's expectations to all your workers -- not only direct hires, but subcontractors, as well -- and let them know they're an integral part of the process."
"Contractors certainly have to utilize the value of employee participation," Kaletsky says. He lists several questions to ask to ensure worker involvement: Are your employees aware of the safety program? Do they accept it? Do they buy into it? Do they get involved in the program? "Their input and cooperation are essential," he adds.
Effective training is another basic key. "The best way to communicate your expectations and increase the safety awareness through all workers is through training," Cloutier says.
Edginton stresses the importance of training workers not only in the hazards of their jobs, but in the broader range of hazards associated with the construction site. "If you don't have a knowledge of what [other craftsmen are] doing, it can put you at risk."
Making safety information available to non-English-speaking workers also has to be addressed. John Johnson, manager of safety and health for Black & Veatch's Infrastructure Division in Kansas City, Mo., says his company provides training manuals, handbooks and work rules in English and Spanish. Plus, interpreters are on hand during safety meetings.
"We don't let the language barrier divide our projects," Johnson says. "It takes time and effort, but it's well worth any of the costs or effort, because then your workers know what's expected related to safety and health, and they're more a part of the overall team."
Johnson also points to the importance of a company enforcing its safety program. "If there are problems out on the jobsite where deficiencies are found, enforcement has to take place. If not, your program will fail."
Consider a Bechtel behavior-based safety program. Under this program, a random group of employees from different trades, usually two to a team, assess a work process. Their task is to note safe and unsafe measures, then communicate that information to the entire work force. "We've found this to be extremely successful," Cloutier says. "It's successful because it's peer to peer, carpenter to carpenter, pipe fitter to pipe fitter."
Industry experts say you're not trying hard enough if you can't find the safety information you need. Toward that end, another key to a successful safety program is taking advantage of resources.
"There aren't any situations that there are not answers for out there," says EEI's Lapping. But you will not find them if you do not look. "Some contractors just want to hurry and get it done and move on."
IUOE's Edginton has encountered the same problem. "Small contractors say, 'We're small and don't have the ability or the resources to have a professional safety and health staff.' I understand that, but the fact of the matter is, if you want the information, the information is available."
Unions and trade associations, such as Associated General Contractors of America, can provide valuable information. Those resources usually can be tapped through the Internet. "I can go [online] and say I'm having trouble with a fall protection issue, and it goes out to all [AGC] members. Hundreds of other safety directors come back giving me eight or 10 ways to solve the problem," Lapping says.
Although often overlooked in this regard, OSHA is more than willing to help contractors with safety and health issues. Yet, there continues to be a hesitation on the part of industry to call the agency for help. "Part of the problem there is trying to get employers to understand that if you call OSHA for help, that doesn't mean you're going to get an inspection," Edginton says.
"I think that's one of the agency's challenges," OSHA's Zettler agrees. "OSHA does not schedule [inspections] off of the people who call in. People just don't believe it."
If you're hesitant to talk with OSHA directly, however, consider taking a look at its Web site, which Black & Veatch's Johnson calls an "excellent source" to find standards, look up letters of interpretation and, if you're willing, ask questions of OSHA. "I don't think it's tapped as much as it could be in the construction industry."
Johnson says he uses OSHA's Web site every day, not only to look up standards and letters of interpretation, but to pre-qualify contractors. He uses the site to check against what contractors put on their job pre-qualification questionnaires. The OSHA site keeps track of how many federal inspections contractors have gone through and lists any penalties. "If they have a bad history with OSHA, we disqualify them."
Better Targeting in Store?
Zettler says he'd like to eliminate focused inspections by going to something better. A better program, he explains, would target unsafe construction sites up front -- something the agency has been unable to do and in which it is often criticized.
Currently, OSHA inspects cites randomly. "The defect is that there's not any way for anybody to distinguish between the safe and the unsafe up front," Zettler says. "Usually, the only way we know is when we are on site. When we're on site, we don't want to spend any more time at the safe places than we have to."
Zettler hopes to have additional money in his budget this year to tackle the targeting problem. Talks are under way to find a way to distinguish between contractors or work sites likely to have hazardous conditions on site as opposed to those that have hazards controlled. "It's a tough nut for us to crack."
Sandy Moretz is a freelance writer based in Atlanta. She is a former associate editor of Occupational Hazards.