Safety and Health Programs: Recommended Practices in Construction (OSHA 3886)

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   Construction

   • Occupational Safety
   • and Health Administration www.osha.gov
   • OSHA 3886
   • October 2016
   • Recommended Practices for
   • Safety & Health Programs
   • in
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   DISCLAIMER

   • These practices for safety and health programs for construction worksites are recommendations only. Employers in construction work must have a program that includes measures to detect and correct workplace hazards. However, their program may not contain all of the practices recommended in this document. Employers will not be cited if their safety and health program does not comply with this document.
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   FOREWORD

   • FOREWORD
   • Establishing a safety and health program at your job site is one of the most effective ways of protecting your most valuable asset: your workers. Losing workers to injury or illness, even for a short time, can cause significant disruption and cost—to you as well as the workers and their families. It can also damage workplace morale, productivity, turnover, and reputation.
   • Resources and Tools to Support
   • Implementation of These
   • Recommended Practices
   • OSHA has created a dedicated Web page to support the implementation of these practices at www.osha.gov/safetymanagement. The page includes a link to these recommended practices as well as the following:
   • …
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   • FOREWORD
   • ii
   • Increased temporary and contract employment means that traditional relationships between workers and employers are shifting, and changes in safety programs and policies will be required to ensure the safety and health of all workers at worksites characterized by these newer and more fluid relationships.
   • These practices also reflect what we have learned from best-in-class programs and what makes them effective. In particular, these recommended practices place greater emphasis on involving workers, and include a more robust program evaluation element to help drive continuous improvement. These practices also stress the need for communication and coordination on worksites involving more than one employer.
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   CONTENTS

   • INTRODUCTION … 2
   • MANAGEMENT LEADERSHIP … 9
   • WORKER PARTICIPATION … 11
   • HAZARD IDENTIFICATION AND ASSESSMENT … 15
   • HAZARD PREVENTION AND CONTROL … 20
   • EDUCATION AND TRAINING … 24
   • PROGRAM EVALUATION AND IMPROVEMENT … 27
   • COMMUNICATION AND COORDINATION FOR EMPLOYERS
   • ON MULTIEMPLOYER WORKSITES … 30
   • LIST OF ABBREVIATIONS … 34
   • GLOSSARY OF TERMS … 34
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   INTRODUCTION

   • THESE RECOMMENDED PRACTICES provide responsible employers, workers, and worker representatives 1 with a sound, flexible framework for addressing safety and health issues on diverse construction job sites. They may be used by any construction company or job site, but they will be particularly helpful to small and medium-sized contractors. They also include guidance specifically aimed at general contractor employment, staffing agency employment, and multiemployer work situations. These recommended practices have been developed solely for the construction industry. Separate recommended practices are available for all other industries.
   • The recommended practices emphasize a proactive approach to managing occupational safety and…
   • …
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   THE BENEFITS OF IMPLEMENTING THESE RECOMMENDED PRACTICES

   • INTRODUCTION
   • These best practices present principles and approaches to implementing and maintaining a safety and health program for the entire construction company. OSHA recognizes that a wide variety of small and large construction job sites exist. Some are short-duration, while others may take years to complete; some sites are characterized by frequently changing conditions, while other sites’ conditions may change less often. An effective program emphasizes top-level ownership, participation by employees, and a “find and fix” approach to workplace hazards.
   • The “find and fix” approach to workplace hazards refers to the “Hazard Identification” and “Hazard Prevention and Control” core…
   • …
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   IMPLEMENTING

   • INTRODUCTION
   • a safety & health program can help employers avoid the INDIRECT
   • COSTS
   • that result from
   • WORKPLACE
   • INCIDENTS
   • such as
   • TIME LOST
   • due to work stoppages and investigations, training and other costs associated with REPLACING
   • INJURED
   • WORKERS
   • LOSS OR and DAMAGE to material, machinery and property.
   • These INDIRECT have been estimated
   • 2.7
   • to be at least times the
   • COSTS
   • DIRECT
   • COSTS
   • Source: Leigh, J.P. (2011), Economic Burden of Occupational Injury and Illness in the United States. Milbank Quarterly, 89:728-772. 2
   • HOW TO USE THE RECOMMENDED
   • PRACTICES
   • Each section of the recommended practices describes a core program element (see page 7), followed by several action items. …
   • …
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   One size does not fit all

   • INTRODUCTION
   • (and likely will) affect actions needed under one or more other elements. For example, workers must be trained in reporting procedures and hazard identification techniques in order to be effective participants. Thus, the “Education and Training” core element supports the “Worker
   • Participation” core element. Similarly, setting goals (as described under “Management
   • Leadership”) will be more effective if you routinely evaluate your progress in meeting those goals
   • (see “Program Evaluation and Improvement”).
   • Progress in each core element is important to achieve maximum benefit from the program.
   • While the action items under each core element are specific, they are not prescriptive. …
   • …
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    NINE EASY THINGS TO GET YOUR PROGRAM STARTED

    • INTRODUCTION
    • If these recommended practices appear challenging, here are some simple steps you can take to get started. Completing these steps will give you a solid base from which to take on some of the more structured actions presented in the recommended practices.
    • 1. ALWAYS SET SAFETY AND HEALTH AS THE TOP PRIORITY
    • 5. CONDUCT INSPECTIONS
    • Inspect the job site with workers and ask them to
    • Tell your workers that making sure they finish the identify any activity, piece of equipment, or material day and go home safely is the way you do business.
    • that concerns them. Use checklists and other
    • Assure them that you will work with them to find and resources, such as OSHA’s Construction Industry fix any…
    • …
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    CORE ELEMENTS OF THE RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION

    • INTRODUCTION
    • MANAGEMENT LEADERSHIP
    • Top management demonstrates its commitment to eliminating hazards and to continuously improving workplace safety and health, communicates that commitment to workers, and sets program expectations and responsibilities.
    • Managers at all levels make safety and health a core organizational value, establish safety and health goals and objectives, provide adequate resources and support for the program, and set a good example.
    • Workers and their representatives are involved in all aspects of the program—including setting goals, identifying and reporting hazards, investigating incidents, and tracking progress.
    • WORKER
    • …
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    FOR MORE INFORMATION

    • INTRODUCTION
    • For more information about these recommended practices, tools to help you implement them, and related topics, see the recommended practices Web page. This page includes links to many tools and resources developed by OSHA and others that can help employers and workers implement these recommended practices. OSHA will continue to update and add to this resource list.
    • OSHA’s On-site Consultation Program offers free and confidential occupational safety and health services to small and medium-sized businesses in all states across the country and in several territories, with priority given to high-hazard worksites.
    • On-site Consultation Program services are separate from enforcement and do not result in penalties or…
    • …
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    MANAGEMENT LEADERSHIP

    • MANAGEMENT PROVIDES the leadership, vision, and resources needed to implement an effective safety and health program.
    • Management leadership means that business owners, managers, and supervisors:
    • Make worker safety and health a core organizational value.
    • Are fully committed to eliminating hazards, protecting workers, and continuously improving safety and health on job sites.
    • Provide sufficient resources to implement and maintain the safety and health program.
    • Visibly demonstrate and communicate their safety and health commitment to workers and others.
    • Set an example through their own actions.
    • Action item 1: Communicate your commitment to a safety and health program
    • …
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    Action item 2: Define program goals

    • MANAGEMENT LEADERSHIP
    • By establishing specific goals and objectives, management sets expectations for managers, supervisors, and workers, and for the program overall. The goals and objectives should focus on specific actions that will improve worker safety and health.
    • How to accomplish it
    • Establish realistic, measurable goals for improving safety and health.
    • Develop plans to achieve the goals by assigning tasks and responsibilities to particular people, setting timeframes, and determining resource needs.
    • Action item 3: Allocate resources
    • Management provides the resources needed to implement the safety and health program, pursue program goals, and address program shortcomings when they are identified.
    • …
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    WORKER PARTICIPATION

    • TO BE EFFECTIVE, any safety and health program needs the meaningful participation of workers and their representatives. Workers have much to gain from a successful program, and the most to lose if the program fails. They also often know the most about potential hazards associated with their jobs. Successful programs tap into this knowledge base.
    • Worker participation means participation in establishing, operating, evaluating, and improving the safety and health program. All workers at a worksite should participate, including those employed by subcontractors and temporary staffing agencies (see
    • “Coordination and Communication on Multi-employer Worksites”).
    • IN AN EFFECTIVE safety and health program, all workers:
    • …
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    Action item 1: Encourage workers to participate in the program

    • WORKER PARTICIPATION
    • By encouraging workers to participate in the program, management signals that it values their input into safety and health decisions.
    • How to accomplish it
    • Give workers the necessary time and resources to participate in the program.
    • Acknowledge and provide positive reinforcement to those who participate in the program.
    • Maintain an open door policy that invites workers to talk to managers about safety and health and to make suggestions.
    • Action item 2: Encourage workers to report safety and health concerns
    • Workers are often best positioned to identify safety and health concerns and program shortcomings, such as emerging job site hazards, unsafe conditions, close…
    • …
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    Action item 3: Give workers access to safety and health information

    • WORKER PARTICIPATION
    • Sharing relevant safety and health information with workers fosters trust and helps organizations make more informed safety and health decisions.
    • How to accomplish it
    • Give workers the information they need to understand safety and health hazards and control measures on the job site. Some OSHA standards require employers to make specific types of information available to workers, such as:
    • Other useful information for workers to review can include:
    • — Chemical and equipment manufacturer safety recommendations
    • — Job site equipment and vehicle inspection reports
    • — Safety Data Sheets (SDSs)
    • …
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    Action item 5: Remove barriers to participation

    • WORKER PARTICIPATION
    • To participate meaningfully in the program, workers must feel that their input is welcome, their voices will be heard, and they can access reporting mechanisms. Participation will be suppressed if language, education, or skill levels on the job site are not considered, or if workers fear retaliation or discrimination for speaking up (for example, if investigations focus on blaming individuals rather than the underlying conditions that led to the incident, or if reporting an incident or concern could jeopardize the award of incentive-based prizes, rewards, or bonuses).
    • How to accomplish it
    • Ensure that workers from all levels of the organization can participate regardless of…
    • …
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    HAZARD IDENTIFICATION AND ASSESSMENT

    • IN CONSTRUCTION, unanticipated hazards can arise due to changes in project timelines, sequence of events, and the fast pace of some construction projects. Hazard identification and assessment is a crucial part of an effective safety and health program.
    • One of the “root causes” of construction injuries, illnesses, and incidents is the failure to identify or recognize hazards that are present, or that could have been anticipated. A critical element of any effective safety and health program is a proactive, ongoing process to identify and assess such hazards.
    • TO IDENTIFY AND ASSESS hazards, employers and workers:
    • Consider hazards associated with emergency or nonroutine situations.
    • …
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    • HAZARD IDENTIFICATION AND ASSESSMENT in construction, respiratory protection, process safety management, PPE, etc.).
    • Information available may include:
    • — Equipment and machinery operating manuals.
    • — Input from workers, including surveys or minutes from safety and health committee meetings.
    • — SDSs provided by chemical manufacturers.
    • — Self-inspection reports and inspection reports from insurance carriers, government agencies, and consultants.
    • — Records of previous injuries and illnesses, such as OSHA 300 and 301 logs and reports of incident investigations.
    • — Results of job hazard analyses (also known as job safety analyses).
    • Information about hazards may be available from outside sources, such as:
    • …
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    HAZARD IDENTIFICATION AND ASSESSMENT

    • Regularly inspect both mobile construction equipment (e.g., forklifts, bulldozers, aerial lifts and cranes) and transportation vehicles (e.g., cars, trucks).
    • Create material delivery areas and internal traffic control plans for the construction site and laydown areas.
    • Use checklists that highlight things to look for. Typical hazards fall into several major categories, such as those listed below; each workplace will have its own list:
    • — Slip, trip, and fall hazards
    • — Work practices
    • — Electrical hazards
    • — Ergonomic problems
    • — General housekeeping
    • — Equipment operation
    • — Equipment maintenance
    • — Lack of emergency procedures
    • — Fire protection
    • …
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    Action item 4: Conduct incident investigations

    • HAZARD IDENTIFICATION AND ASSESSMENT
    • Identify biological hazards—determine whether workers may be exposed to sources of infectious diseases, molds, toxic or poisonous plants, or animal materials (fur or scat) capable of causing allergic reactions or occupational asthma.
    • Identify ergonomic risk factors—examine work activities that require heavy lifting, work above shoulder height, repetitive motions, or tasks with significant vibration.
    • Conduct quantitative exposure assessments, when possible, using air sampling or direct reading instruments.
    • Review OSHA 300 logs to help identify health hazards associated with job site exposures.
    • …
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    Action item 5: Identify hazards associated with emergency and nonroutine situations

    • HAZARD IDENTIFICATION AND ASSESSMENT
    • Emergencies present hazards that need to be recognized and understood. Nonroutine or infrequent tasks, including mobilization and demobilization of the site, critical lifts with cranes, concrete pours, or setting critical structural members, also present potential hazards. Plans and procedures need to be developed for responding appropriately and safely to hazards associated with foreseeable emergency scenarios and nonroutine situations.
    • How to accomplish it
    • Identify foreseeable emergency scenarios and nonroutine tasks, taking into account the types of material and equipment in use and the location at the worksite. …
    • …
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    HAZARD PREVENTION AND CONTROL

    • EFFECTIVE CONTROLS protect workers from hazards; help avoid injuries, illnesses, and incidents; minimize or eliminate safety and health risks; and help employers provide workers with safe and healthful working conditions. The processes described in this section will help employers prevent and control hazards identified in the previous section.
    • TO EFFECTIVELY CONTROL and prevent hazards, employers should:
    • Involve workers, who often have the best understanding of the conditions that create hazards and insights into how they can be controlled.
    • Identify and evaluate options for controlling hazards, using a “hierarchy of controls.”
    • Use a hazard control plan to guide the selection and implementation of controls, and…
    • …
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    Action item 2: Select controls

    • HAZARD PREVENTION AND CONTROL
    • For complex hazards, consult with safety and health experts, including OSHA’s On-site
    • Consultation Program.
    • Plan the sequencing of various trades to reduce overlap where possible and to avoid exposing other trades to hazards.
    • Most effective
    • Hierarchy of Controls
    • Employers should select the controls that are the most feasible, effective, and permanent.
    • Elimination
    • How to accomplish it
    • Eliminate or control all serious hazards (hazards that are causing or are likely to cause death or serious physical harm) immediately.
    • Use interim controls while you develop and implement longer-term solutions.
    • Select controls according to a hierarchy that emphasizes engineering solutions (including…
    • …
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    Action item 4: Select controls to protect workers during nonroutine tasks and emergencies

    • HAZARD PREVENTION AND CONTROL
    • A hazard control plan includes provisions to protect workers during nonroutine tasks and foreseeable emergencies, such as falls, cave-ins, fires and explosions, chemical releases, hazardous material spills, infrequent activities, natural and weather disasters, workplace violence, terrorist or criminal attacks, disease outbreaks (e.g., pandemic influenza), and medical emergencies. Nonroutine tasks, or tasks workers don’t normally do, should be approached with particular caution. …
    • …
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    Action item 6: Follow up to confirm that controls are effective

    • HAZARD PREVENTION AND CONTROL
    • To ensure that control measures are and remain effective, employers should track progress in implementing controls, inspect and evaluate controls once they are installed, and follow routine preventive maintenance practices.
    • How to accomplish it
    • Track progress and verify implementation by asking the following questions:
    • — Have all control measures been implemented according to the hazard control plan?
    • Conduct regular inspections (and industrial hygiene monitoring, if indicated) to confirm that engineering controls are operating as designed.
    • Evaluate control measures to determine if they are effective or need to be modified.
    • …
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    EDUCATION AND TRAINING

    • EDUCATION AND TRAINING are important tools for informing workers and managers about hazards and controls so they can work more safely and be more productive. Another role of education and training, however, is to provide workers and managers with a greater understanding of the safety and health program itself, so that they can contribute to its development and implementation.
    • EDUCATION AND TRAINING provides employers (owners and executives), managers, supervisors, and workers with:
    • Knowledge and skills needed to do their work safely and avoid creating hazards that could place themselves or others at risk.
    • Awareness and understanding of hazards and how to identify, report, and control them.
    • …
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    EDUCATION AND TRAINING

    • — Whom to contact with questions or concerns about the program (including contact information)
    • — How to report hazards, injuries, illnesses, and close calls/near misses
    • — What to do in an emergency
    • — The employer’s responsibilities under the program
    • — Workers’ rights under the OSH Act
    • Provide information on the safety and health hazards of the job site and the controls for those hazards.
    • Ensure that training is provided in the language(s) and at a literacy level that all workers can understand.
    • Emphasize that the program can only work when everyone is involved and feels comfortable discussing concerns; making suggestions; and reporting injuries, incidents, and hazards.
    • …
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    Action item 3: Train workers on their specific roles in the safety and health program

    • EDUCATION AND TRAINING
    • Additional training may be needed to ensure that workers can incorporate safety and health responsibilities into their daily routines and activities.
    • How to accomplish it
    • Instruct workers on how to report injuries, illnesses, incidents, and concerns. If a computerized reporting system is used, ensure that all employees have the basic computer skills and computer access sufficient to submit an effective report.
    • Instruct workers assigned specific roles within the safety and health program on how they should carry out those responsibilities, including:
    • — Participation in incident investigations
    • — Program evaluation and improvement
    • …
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    PROGRAM EVALUATION AND IMPROVEMENT

    • ONCE A SAFETY and health program is established, it should be evaluated initially to verify that it is being implemented as intended. After that, employers should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals. Whenever these assessments identify opportunities to improve the program, employers, managers, and supervisors—in coordination with workers—should make adjustments and monitor how well the program
    • PROGRAM EVALUATION and improvement includes:
    • Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress.
    • …
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    PROGRAM EVALUATION AND IMPROVEMENT

    • — Track leading indicators, such as:
    • Timely completion of corrective actions after a job site hazard is identified or an incident occurs
    • Level of worker participation in program activities
    • Timely completion of planned preventive maintenance activities
    • Number of employee safety suggestions
    • Worker opinions about program effectiveness obtained from a safety climate or safety opinion survey
    • Number of hazards, near misses, and first aid cases reported
    • Amount of time taken to respond to reports
    • Analyze performance indicators and evaluate progress over time.
    • Number and frequency of management walkthroughs
    • Share results with workers and invite their input on how to further improve performance.
    • …
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    Action item 3: Correct program shortcomings and identify opportunities to improve

    • PROGRAM EVALUATION AND IMPROVEMENT
    • — Collecting and reporting any data needed to monitor progress and performance
    • Review the results of any compliance audits to confirm that any program shortcomings are being identified. Verify that actions are being taken that will prevent recurrence.
    • Whenever a problem is identified in any part of the safety and health program, employers—in coordination with supervisors, managers, and workers—need to take prompt action to correct the problem and prevent its recurrence.
    • How to accomplish it
    • If you discover program shortcomings, take actions needed to correct them.
    • …
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    COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES

    • CONSTRUCTION JOB SITES typically have workers who are employed by a general contractor and other workers who are employed by a contractor or subcontractor, or workers from other sources.
    • In these circumstances, it is important that each employer and contractor consider how its work and safety activities can affect the safety of other workers at the job site. Examples include
    • IN TODAY’S ECONOMY, an increasing number of workers are assigned by staffing agencies to work at specific “host” worksites under the direction and control of the host employer. Examples include unskilled laborers or skilled trade workers from a staffing agency who may be placed in either short- or…
    • …
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    COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES

    • Effective communication and coordination among such employers means that:
    • General contractors and their workers are aware of:
    • — The types of hazards that may arise from the work being done on site by workers employed by contractors, subcontractors, or staffing agencies.
    • — The procedures or measures needed to avoid or control exposure to these hazards.
    • — How to contact the contractor, subcontractor, or staffing agency if they have a safety concern.
    • Before coming on site, contractors, subcontractors, and staffing agencies and their workers are aware of:
    • — The previous work done and the types of hazards that may already be present at the job site.
    • …
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    Action item 1: Establish effective communication

    • COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES
    • Each general contractor establishes and implements a procedure to ensure the exchange of information about hazards present on site and the hazard control measures in place. Thus, all workers on the site are aware of worksite hazards, and the methods and procedures needed to control exposures to them.
    • How to accomplish it
    • The general contractor communicates with contractors, subcontractors, and staffing agencies to determine which among them will implement and maintain the various parts of the safety and health program, to ensure protection of all on-site workers before work begins. …
    • …
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    Action item 2: Establish effective coordination

    • COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES
    • General contractors, contractors, subcontractors, and staffing agencies coordinate on work planning, scheduling, and resolving program differences to identify and work out any concerns or conflicts that could impact safety or health.
    • How to accomplish it
    • — Ensure that joint-employed workers are adequately trained and equipped before arriving on the worksite.
    • General contractors:
    • — Include in contracts and bid documents any safety-related specifications and pre-qualifications and ensure that contractors, subcontractors, and staffing agencies selected for the work meet those requirements.
    • …
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    LIST OF ABBREVIATIONS

    • CDC
    • Centers for Disease Control and Prevention
    • NIOSH
    • National Institute for Occupational Safety and Health
    • OSHA
    • Occupational Safety and Health Administration
    • PPE
    • personal protective equipment
    • PtD
    • Prevention through Design
    • SDS
    • Safety Data Sheet
    • SHARP
    • Safety and Health Achievement Recognition Program
    • VPP
    • Voluntary Protection Programs
    • GLOSSARY OF TERMS
    • close call/near miss:
    • An incident that could have, but did not, result in death, injury, or illness. They signal that hazards are not being adequately controlled or that new hazards have arisen.
    • contractor:
    • An individual or firm that agrees to furnish materials or perform services at a specified price.
    • elimination:
    • …
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    • GLOSSARY OF TERMS
    • host employer:
    • An employer who has general supervisory authority over the worksite, including controlling the means and manner of work performed and having the power to correct safety and health hazards or require others to correct them.
    • industrial hygiene:
    • The science of protecting and enhancing the health and safety of people at work and in their communities.
    • job hazard analysis:
    • A technique that focuses on job tasks as a way to identify hazards before they occur. It focuses on the relationships among the worker, the task, the tools, and the work environment.
    • joint-employed worker:
    • A worker hired and paid by a staffing agency and assigned to work for a host employer, whether or not the job is actually temporary.
    • …
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    GLOSSARY OF TERMS

    • Safety and Health Achievement
    • Recognition Program:
    • An OSHA program that recognizes small business employers who have used OSHA’s On-site Consultation Program services and operate an exemplary injury and illness prevention program.
    • safety data sheet:
    • Written or printed material used to communicate the hazards of substances and chemical products to employees prepared in accordance with paragraph (g) of OSHA’s Hazard Communication standard.
    • serious hazards:
    • Hazards that are causing or are likely to cause death or serious physical harm. See OSHA’s Field Operations Manual, Chapter 4.
    • shortcoming:
    • A fault, deficiency, or gap that results in a failure to meet program design criteria.
    • staffing agency:
    • …