16

C H A P T E R

Safety

INTRODUCTION
The safety of employees is a paramount concern for all employers. This is espe-
cially true in the construction industry that continuously boasts one of the high-
est job injury rates of all professions. Construction employs 7.9 million people,
5.4% of the workforce, yet accounts for over 20% of fatalities and over 12% of
the injuries in the workforce according to the 2005 Bureau of Labor and Statis-
tics reports.
Safety on the jobsite is the responsibility of everyone on the site, but as the
construction manager, your examples set the tone for the jobsite. If your attitude
toward safety is carefree, your employees will exemplify that attitude. On the
other hand, if safety is a priority to you and the company and clearly displayed,
employees will be inclined to follow that example. To a construction manager,
safety is a component of any project that is as important as estimating, schedul-
ing, and equipment maintenance. It should be treated with the same concern and
attention to detail that weekly job cost reports receive. It is not something that
should be treated as an added responsibility to an employee’s job. This means
that everyone is responsible for the safety and well-being of all employees on
the jobsite. It is up to the manager to plan this into the project and adapt it as part
of the day-to-day culture on the jobsite.
Safety is the part of a project that has to take the front stage of the planning
process and continue through all the way to the daily project operations. Safety
is an investment, and a good safety program is part of a successful portfolio. The
financial well-being of a company can be tied to the safety performance dis-
played by the company. While rates of return of $4 for every $1 spent on safety
are quoted, the safety manager knows that this is not hard cash that is added into
the bottom line of the company. A strong safety record benefits companies in

520

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 C h a p t e r 16 Safety 521

several intangible and tangible ways. The most easily quantified is the experi-
ence modification rate (EMR).
The EMR is an excellent measure of how your loss prevention and control
practices compare to others in the construction industry. The EMR compares
your worker’s compensation claims experience to other employers of similar
size operating in the same type of construction business. Your EMR is calcu-
lated by the National Council on Compensation Insurance or in some states an
independent agency. To calculate the EMR, each year your insurance company
will report your payrolls and losses for the last 5 years. To complete the calcula-
tions, 3 complete years of data ending 1 year prior to the effective date of the
rating period are used. For example, a rating in 2009 would not normally use
2008 data, but would include 2007, 2006, and 2005. The formula compares your
specific payrolls and losses to industry averages. So, if your EMR is 1.0, you
are at the industry average. If you are 25% better than the industry average, your
EMR is 0.75, or if you are 25% worse, your EMR would be 1.25. Table 16.1
highlights how the EMR affects insurance premiums.
The backbone of a safety program is the written plan. Throughout this chap-
ter we will highlight essentials of an effective safety program, providing exam-
ples that will help make your life easier as a project manager. The chapter will
also highlight the regulatory component of safety on the job and the costs of
accidents, and provide tips for you to practice on a daily basis. Safety is more
than a slogan and it must be treated that way for it to be successful.

TECHNICAL INFORMATION
How much are accidents costing the construction industry on average each
year? The construction industry boasts the highest spending on worker's
compensation—$5.17 billion. It is a high risk industry so the premiums are
higher. In addition to higher insurance expenditures, accident costs include lost
wages, medical expenses, insurance administration, property damage, and indi-
rect costs. The greatest impacts associated with accidents are the effect upon
worksite morale, loss of productivity, and lawsuits.
A construction manager needs to be knowledgeable about programs and
policies relating to daily jobsite operations that aim to protect employers and

TABLE 16.1 EMR example.

ABC contractors XYZ contractors

Payroll $1,200,000 $1,200,000
Rate per $100 $10.25 $10.25
Premium $123,000 $123,000
EMR 0.75 1.25
EMR dollars ($30,750) $30,750
Modified Premium $92,250 $153,750

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 522 PA R T 2 Construction Practice

their employees. Worker’s compensation is an insurance program whose objec-

tive is to provide employers with immunity from lawsuits in exchange for pay-
ment to the affected worker, the replacement of income for injured employees,
and rehabilitation of the injured employee. The program varies from state to
state. Accident prevention plan strategies have been employed in the construc-
tion industry to reduce the high cost of worker’s compensation rates. These
include cultivating job satisfaction among employees, making safety a part of
the company culture, and involving employees at all levels in the safety program
and recognizing them for their efforts. While these efforts may ultimately lower
the cost of worker’s compensation, an effective safety program must be devel-
oped at the highest level within the company.
While providing a safe working environment is the right thing to do, it is
also the law. To assure safe and healthful working conditions for employees, the
Williams-Steiger Act Williams-Steiger Occupational Safety and Health Act (OSH Act) was signed
Known as the in 1970. The act authorized enforcement of the currently developed health and
Occupational Safety safety standards while assisting and encouraging States in their efforts to assure
and Health Act. Passed safe and healthful working conditions. The act also provides for research, infor-
in 1970. mation, education, and training in the field of occupational safety and health.
Of the numerous standards promulgated by OSHA, the regulations that pertain
specifically to the construction industry are contained within 29 CFR 1926.
The General Duty Clause of the OSHA regulations establishes the basic
fundamental responsibilities of employers. The clause states,

Each employer shall furnish to each of their employees employment

and a place of employment which are free from recognized hazards that
are causing or are likely to cause death or serious physical harm to their
employees and shall comply with occupational safety and health stan-
dards promulgated under this Act.

Individual states are encouraged to develop and operate their own job safety
and health programs. States must develop a plan that is as least as stringent as the
federal standards, but they have the option to develop and promulgate standards
that address hazards not covered within the federal standards. For example, Cal-
ifornia requires more stringent ergonomic standards, Nevada has different reg-
ulations regarding fatalities, Kentucky has a different way to report accidents,
South Carolina revised the definition of a competent person, and Oregon has a
revised method for hazard determination. Be certain to investigate the regula-
tions that are pertinent to the state within which you are completing work.

FEDERAL OSHA REPORTING

REQUIREMENTS
There are OSHA reporting requirements with which the construction manager
must comply. You are required to keep records and reports of OSHA-recordable
injuries and illnesses and submit this information to OSHA every year. These
reports include a log of work-related injuries and illnesses (OSHA Form 300),

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 C h a p t e r 16 Safety 523

an injury and illness incident report that includes data about how an injury or
illness occurred (OSHA Form 301), and a summary of work-related injuries
and illnesses (OSHA Form 300A). These forms and instructions for their com-
pletion can be downloaded from OSHA at the following link: www.osha.gov/
recordkeeping/RKforms.html. At the end of each year, the OSHA 300 form must
be reviewed to verify that the entries are complete and accurate, and a summary
of the injuries and illnesses recorded on the OSHA 300 must be created and
certified. This summary must be posted in a conspicuous place or placed where
notices to employees are customarily posted. The summary must be posted no
later than February 1 of the year following the year covered by the records and
be kept in place until April 30. Additionally, you must save the OSHA 300 Log,
the annual summary, and the OSHA 301 Incident Report forms for 5 years fol-
lowing the end of the calendar year that these records cover.
The OSHA 300 form requires each employer to keep records of fatalities,
injuries and illnesses that are work related, or result in death, days away from
work, restricted work or transfer to another job, medical treatment beyond first
aid, or loss of consciousness. A work-related injury is an event or exposure in
the work environment that caused or contributed to the resulting condition. All
work-related incidents resulting in a fatality or the in-patient hospitalization of
three or more employees must be reported to OSHA within 8 hours.
A question frequently asked of safety personnel is, what is normal first aid?
For the purposes of OSHA, “first aid” means the following:
■ Using a nonprescription medication
■ Administering a tetanus shot
■ Cleaning, flushing, or soaking wounds on the surface of the skin
■ Using wound coverings such as bandages or Band-Aids
■ Drilling of a fingernail or toenail to relieve pressure, or draining fluid from
a blister
■ Removing foreign bodies from the eye using only irrigation or a cotton
swab
■ Removing splinters or foreign material from areas other than the eye by
irrigation, tweezers, cotton swabs, or other simple means
■ Drinking fluids for relief of heat stress
If you are still having trouble deciding if an injury or illness is reportable, the deci-
sion tree illustrated in Fig. 16.1, adapted from OSHA for recording work-related
injuries and illnesses, shows the steps involved in making this determination.
According to OSHA, record keeping is a critical part of an employer’s safety
and health efforts for several reasons:
■ Keeping track of work-related injuries and illnesses can help prevent them
in the future.
■ Using injury and illness data helps identify problem areas. The more you
know, the better you can identify and correct hazardous workplace
conditions.

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 524 PA R T 2 Construction Practice

Did the employee experience an

injury or illness?
NO

YES

Is the injury or illness work

related?
NO

YES

Update the previously

NO
Is the illness or injury a recorded injury or illness
new case? entry if necessary

YES

NO YES
Does the injury or illness meet the
general recording criteria?

Do not record the Record the injury or

injury or illness illness

FIGURE 16.1 OSHA recordable injury decision tree.

■ The recording process leads to improved administration of company safety

and health programs with accurate records.
■ As employee awareness about injuries, illnesses, and hazards in the
workplace improves, workers are more likely to follow safe work practices
and report workplace hazards.

OSHA JOBSITE VISITS

OSHA has the right of entry to any site of work performance to investigate or
inspect the level of compliance with the safety and health standards. Knowing
what to expect when an OSHA official visits your jobsite will help you better

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 C h a p t e r 16 Safety 525

respond to the visit and ensure that your company is prepared in the event of
a visit.
OSHA will inspect a jobsite for several reasons, but the order of priority for
inspections is as follows: reports of imminent danger to employees; a fatality or
catastrophe investigation; response to a complaint or referral; a planned inspec-
tion. A planned inspection may include a follow-up or monitoring visit due
to a previous citation that required remediation. Inspections are unannounced
because many investigation conditions can be easily and quickly altered if an
employer knows investigators are coming. In fact, in Section 8(a) of the OSH
Act, it prohibits unauthorized advance notice, except in special circumstances.

The Inspection
Inspections are made during regular working hours so working conditions may
be observed. The first phase of the inspection is the opening conference. Upon
arrival, the OSHA inspector will locate the general contractor and present his
or her credentials. The inspector will note the conditions of the worksite upon
arrival as well as any changes that may occur during the opening conference.
So, fixing things during the opening conference is not a strategy to employ. Be
certain that you have the necessary people present at the opening conference. If
you would like an owner’s representative present or another official from your
company, for example the company safety officer, you may delay the inspection
for no longer than 1 hour to await the arrival of the necessary party.
The inspector will alert you to the reason for inspecting the jobsite, to
include the scope of the inspection and the rationale. If the inspection is due
to a report of imminent danger, the inspector must provide a description of the
alleged imminent danger situation, the date received, and the source of the infor-
mation. If the inspection is being conducted as a result of a complaint, a copy
of the complaint is to be furnished to the general contractor and any affected
subcontractors. If the visit is a follow-up or monitoring visit, the inspector must
provide the date of the initial inspection and detail the reasons for the follow-up
or monitoring based upon prior employer agreement.
As part of the opening conference, the inspector will review the injury and
illness records to the extent necessary to determine compliance and identify
trends. Other OSHA programs, such as the Hazardous Communication Plan and
the Fall Protection Plan, and records will be reviewed at the inspector’s pro-
fessional discretion. The inspector may also determine whether the employees
of any other employers are working on the jobsite. If these employers may be
affected by the inspection, the scope may be expanded to include others or a
referral made at the discretion of the inspector. At multiemployer sites, copies
of complaint(s), if applicable, shall be provided to all employers affected by the
alleged hazard(s), and to the general contractor.

Walk-around Inspection
The main purpose of the walk-around inspection is to identify potential safety
and health hazards in the workplace and to determine employer compliance.

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 526 PA R T 2 Construction Practice

Inspectors assess the employee and employer knowledge of any hazards on the
jobsite through interviews and evaluate the good-faith efforts of the employer’s
safety and health program. The inspector will bring to your attention any appar-
ent violations at the time they are documented. They will take photographs and
measurements and may collect samples, such as air samples or surface samples.
Be certain to take the same photographs as the inspector for your own records. A
good rule of thumb is, if the inspector is taking photos, so should you.

Closing Conference
Upon completion of the inspection process, the inspector will meet with the gen-
eral contractors and all appropriate subcontractors or their representatives and
advise each of the apparent violations disclosed by the inspection. Employee
representatives participating in the inspection shall also be invited to participate
in the closing conference(s). The inspector will describe the apparent violations
found during the inspection and other pertinent issues. The inspector will inform
you of your rights regarding the citations, contesting procedures, abatement
times, and a possible schedule for follow-up visits. Awareness of the OSHA site
visit process, procedures, and policies is important knowledge for any construc-
tion manager.

Citation Types
OSHA inspectors can issue citations of the following types: serious, willful,
repeated, and nonserious. A serious violation is a condition that has substantial
probability to cause death or serious physical harm. The maximum fine for a
serious violation is $7,000. A willful violation is issued when an employer com-
mits an intentional and knowing violation of the OSH Act. The maximum fine
for such a violation is $70,000. Repeated violations are issued for a hazardous
condition that is substantially similar to a previously cited condition and must
be issued within 3 years of the previous citation. Other than serious violations
or nonserious violations are also possible, which net a maximum fine of $7,000.
A failure to abate violation is issued if a noted violation is not corrected within
the agreed upon period of time. This violation incurs a maximum fine of $7,000
per day for every day that the violation is not corrected. It is important to correct
violations quickly and disseminate the information broadly to avoid this type of
problem in the future on the site or on other projects.

Most-Violated Construction Standards

According to the 2006 data, the most violated OSHA standards in the con-
struction industry center around a few main topics and include scaffolding, fall
protection, ladders, excavations, hazard communication, personal protection,
and general training requirements. Table 16.2 highlights the top 10 most cited
standards for the reporting period from October 2005 through September 2006,
based upon OSHA reporting information. For that period, there were a total of

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 C h a p t e r 16 Safety 527

TABLE 16.2 Top 10 most violated OSHA standards in construction.

Number of Dollars
Standard Subsection citations fined Description
1926.451 L – Scaffolding 9,706 10,306,196 General requirements
1926.501 M – Fall Protection 6,820 8,242,454 Duty to have fall protection
1926.1053 X – Ladders 2,514 1,298,126 Ladders
1926.651 P – Excavations 2,078 2,500,316 Specific excavation requirements
1926.020 A – General 2,008 1,073,362 General safety and health
provisions
1926.503 M – Fall Protection 2,002 966,063 Training requirements
1926.100 E – Personal Protection 1,709 867,654 Head protection
Equipment
1910.1200 HAZCOM 1,652 219,434 Hazard communication
(1926.59)
1926.453 L – Scaffolding 1,489 1,325,076 Aerial lifts
1926.652 P – Excavations 1,466 4,167,996 Requirements for protective
systems

FIGURE 16.2 Questionable scaffolding—no toeboards.

51,749 citations for a total of $46,526,993 in penalties in the construction indus-

try. Figures 16.2 and 16.3 illustrate scaffolding and fall protection violations
respectively.

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 528 PA R T 2 Practice

FIGURE 16.3 Hole in safety fencing.

It is suggested that during the planning stages of any project the construction
manager assess the project with these frequently cited standards in mind. This is
a good starting point for jobsite safety planning.

WORKING WITH OSHA

As a construction manager, you may wish to investigate the opportunities that
are available to assist you in the development of a site safety program or help in
the identification and abatement of hazards. OSHA supports several programs
that offer help and collaboration to employers to improve the health and safety
of their jobsites. Examples include the Voluntary Protection Programs, alliances,
and participation in a consultation program. The free health and safety consulta-
tion program is targeted to improve safety on the site level, and for a new con-
struction manager, it is a recommended program to investigate.

CONSULTATION PROGRAM
This confidential program is completely separate from the OSHA compliance
section and no citations are issued as a result of a consultation visit. The only
obligation is committing to correcting serious job safety and health hazards in a
timely manner.
The program provides a consultant to work with you and your employees
to examine the conditions of your jobsite. The key piece to the consultation is
the jobsite walkthrough. During the walkthrough, the consultant will work with
you and your employees to identify and judge the nature and extent of specific

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 C h a p t e r 16 Safety 529

hazards. This is another meaningful way that employees can be involved in the
safety process.
A comprehensive consultation includes:
■ An appraisal of all mechanical and environmental hazards and physical
work practices
■ An appraisal of the present job safety and health program or the
establishment of one
■ A conference with management on findings from the consultation
■ A written report of recommendations and agreements
■ Training and assistance with implementing recommendations
Overall, the program will improve your knowledge of workplace hazards and
ways to eliminate them. This is a proactive step toward establishing a vital health
and safety program. Additional information about the consultation program and
other OSHA sponsored safety programs can be found on the OSHA website.
The site also contains several success stories. Reading and researching these
programs are excellent ways to gain information about different approaches to
safety and health that may be applicable to your jobsite. Figs. 16.4 and 16.5
are examples of worksite housekeeping issues that may be identified during a
consultation visit. These sites can be cleaned up and easily organized to meet
OSHA standards.

FIGURE 16.4 Poor housekeeping.

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 530 PA R T 2 Construction Practice

FIGURE 16.5 Improper material storage.

SAFETY PROGRAM DEVELOPMENT

For a safety program to be successful, it must be a systematic, orderly, all-
inclusive management process that reaches beyond the minimum regulatory
requirements providing the utmost safety and health protection for employees.
In construction, safety programs must include industry-specific hazards. Con-
struction work has the potential to be hazardous and occurs in several phases to
include preplanning, planning, design, construction, and operation and mainte-
nance. Safety needs to be considered at all stages of work on a project to ensure
seamless functioning throughout a company and project.
Development of a safety program requires the input from all involved.
Active involvement by both management and employees in implementation is
critical to the success and support of a safety program. Creating a companywide
atmosphere that safety is everyone’s job ensures active involvement and owner-
ship at every level and phase.
As a construction manager, your leadership provides the motivating force
and the resources for organizing and controlling safety within the organization.
Safety must be regarded as a fundamental and valuable activity within the orga-
nization. The emphasis placed upon safety should parallel the resources dedi-
cated to scheduling, estimating, and cost control. Safety must be included as
a fundamental operating principle of the company. This emphasis will send a
strong message to all employees about the importance placed upon worker’s
health and well-being.
A commitment must be made to developing a company safety policy with
goals and objectives that will be maintained, evaluated, and assessed on a recur-

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 C h a p t e r 16 Safety 531

FIGURE 16.6 Appropriate use of scaffolding signage.

ring basis. Included in this policy shall be a requirement for site-specific health
and safety plans. While many owners require a project-specific safety plan as
part of the contract, it should be an established company practice, as the hazards,
demands, environment, and employees vary among all jobs. Unique plans that
are founded upon the fundamental company policies are critical to sustaining
a vibrant safety culture. The written plans should include all necessary aspects
appropriate for the project undertaken. For example, personal protection equip-
ment requirements may vary from project to project. Certain jobsites may be
using building materials that can easily fray, fragment, or splinter. On these
sites, safety gloves may be mandatory at all times. Figs. 16.6 and 16.7 illustrate
simple, yet effective signage that emphasizes appropriate safety precautions that
must be taken in specific areas.
As a manager, you must create an environment of trust and establish a clear
line of communication with your employees. They should feel comfortable rais-
ing safety issues to any level within the company. In this role, you must actively
demonstrate your commitment to their safety and health. This includes ensur-
ing that all employees have access to the required safety equipment and that
they know how to properly utilize that equipment. They also must have adequate
training and knowledge of the dangers that are present on the jobsite.
While safety is everyone’s responsibility, written clear definition of the
responsibilities of all individuals on the site is necessary. Safety responsi-
bilities should be clearly assigned. At all levels, each employee has his or her

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 532 PA R T 2 Construction Practice

FIGURE 16.7 Effective safety signage.

individual and assigned functional safety and health related activities. Employ-
ees are required to know their specific duties, be trained in how to perform them,
and have the authority to act upon their relevant requirements. The ability to act
when a situation is deemed unsafe is critical. For example, if the scaffolding
superintendent notices that the crew trained in scaffolding erection is not wear-
ing the appropriate personal protection equipment, he or she can stop the work
and prevent the crew from continuing their work until the appropriate equipment
is in place. The situation pictured in Fig. 16.8 is an excellent example of when
an employee should be wearing fall protection equipment and is not. Anyone
on the jobsite should have the authority to stop him and require him to wear the
appropriate equipment.
Enforcement of safety policy is key to success. Employees must be held
accountable for their actions and that accountability should be from top manage-
ment, to field supervisors, to site employees. Employee performance should be
tracked. Reward or recognize it when it is done well and correct it when it is not.
Everyone is accountable for meeting their responsibilities for completing a job
safely.
Company safety and health policy must be communicated to and understood
by your employees. Safety should be integrated into the day-to-day management
system within the company and on the jobsite. Employees understand the prior-
ity placed upon safety—they live it day to day and nothing interferes with it as
their top priority. If this is the case, then enforcement of the policy will become
easier over time.
Involving employees in the safety planning at all phases of a construction
project not only is a smart decision, but also will help to increase the success
of your program. Employees develop and express a commitment to safety and
health protection for themselves and their fellow workers. They develop a sense

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 C h a p t e r 16 Safety 533

FIGURE 16.8 Unsafe worker—no fall protection.

of ownership for the success of the program because they were involved in the
planning and in decisions that affect their safety and health. Their participa-
tion in the program must be meaningful and their input valued. Some exam-
ples of where employee participation should be sought include analyzing job
or process hazards, participating in accident or incident investigations, and the
documentation of near misses. Consideration should also be given to the develop-
ment of an employee-suggestion program for safety improvements or initiatives.
One company initiated a contest soliciting safety slogans from employees. The
winning slogans were printed on banners and posted on the jobsite (Fig. 16.9).

FIGURE 16.9 Employee safety slogan sign.

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 534 PA R T 2 Construction Practice

Last, consider engaging employees in training other employees. They possess

intimate knowledge of the jobs they perform and may be better equipped to edu-
cate others who will be completing the same work.
Another aspect that is important for construction managers is the presence
of subcontractors on the site. Be certain to have a system in place for subcon-
tractors when they come onto the jobsite. Prequalify your subcontractors and
make sure they have a safety plan or better yet, require a written safety plan
prior to award of the contract. It should be a requirement that they develop and
operate an effective safety program. Be certain that the plan is job specific and
not a generic plan. Their plan must be equal to or better than the plan in place by
the general contractor.
To quantify the success of a safety program requires the implementation
of a self-evaluation protocol. The protocol should examine the overall pro-
gram and evaluate strengths, weaknesses, areas in need of improvements, and
achievements. Determining where you are meeting your goals will help you
to refocus your efforts and energies for the next year or project. The evalua-
tion process must include interviewing employees at all levels for knowledge,
awareness, and perceptions of the program. These people can help provide
workable solutions to improving areas of weaknesses. The assessment should
also review site conditions and, where hazards are found, determine the weak-
nesses that allowed the hazards to occur. Be certain to conduct evaluations
immediately upon completing a project. This will provide valuable informa-
tion that can be used for improvement in the future and be more competitive in
the next bid.

JOB HAZARD ANALYSIS

A major component of a project-specific safety plan is the analysis of the work
site for hazards that may impact safety and health. A job-hazard analysis should
be conducted prior to even bidding a project or at the latest before completion
of a task. Comprehending the hazards ahead of time may lead to prevention or
elimination of any accidents or injuries. It should be the first step in completing
a site-specific safety program.
To begin, identify and document common hazards associated with the proj-
ect and the site. This should be accomplished for all phases of the construction
project and the processes associated with each of the phases. Use OSHA regula-
tions, building codes, industry standards, and equipment manufacturer recom-
mendations as guidelines. Establish procedures to identify hazards and their
prevention and control. Be certain to analyze routine jobs, tasks, and processes
and identify uncontrolled hazards. Document the process by which the analysis
takes place and how these will lead to hazard elimination or control.
In addition to completing a preliminary job hazard analysis for the entire
project, individual procedures should be developed for specific task hazard anal-
ysis. The procedure should describe the process to identify uncontrolled haz-
ards prior to an activity and detail the precautionary measures for the day-to-day

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 C h a p t e r 16 Safety 535

operations. These should be developed for all areas of the project, but should
focus upon areas that are considered high risk for the project.
In construction operations, employees are exposed to potential hazards as
part of their daily work. Operations that may require additional attention for
identifying hazards include scaffolding erection, work that could involve a fall
from height, trench excavation, electrical work, or other areas that have a history
of high accidents or injuries. In 2006, OSHA recorded 13,267 citations for vio-
lations of scaffolding regulations. These citations resulted in fines totaling over
$13 million. Establishing a method for identifying and analyzing safety hazards
for routine and nonroutine processes will help you to avoid being one of these
statistics. Fig. 16.10 illustrates a simple but highly effective way to document
and communicate daily hazards to employees. This simple message board con-
veys the dangers and increases employee awareness.

SELF-INSPECTIONS
As part of a vigilant safety program, jobsite inspections should be conducted
on a regular basis, at least weekly during the project. Development of a system-
atic approach with checklists will help streamline the inspections and ensure a

FIGURE 16.10 Daily risk signage.

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 536 PA R T 2 Construction Practice

consistent process. The inspection guidelines should include what will be

inspected, who is responsible for conducting the inspection, what the schedule is for
inspections, and also include a system that tracks any required actions to com-
pletion. A verification system to ensure that the inspection took place should
also be implemented. This documentation will help to determine trends and pos-
sibly aid in correction of such issues.

ACCIDENT/INCIDENT INVESTIGATIONS
Investigating the root cause of an accident is critical to the success of a health
and safety program. As part of the written program, the development of pro-
cedures that detail the process by which an investigation will take place is
required. This procedure should outline the type of incident that is investigated.
Is it for reportable incidences and fatalities only? Or will there be an investiga-
tion for near-misses, first-aid cases, and other incidents? Who is authorized to
conduct the investigation? What are the criteria for an investigation and what is
the appropriate level of investigation? How will the findings be represented? It
is ideal to have written findings that aim to identify all contributing factors and
corrective actions required, tracking actions to completion with a summation of
what action was taken to prevent similar events in the future.
Why are these investigations so important to a safety and health program? It
is all in how the data collected is utilized. A system should be in place to analyze
injury, illness, and related data that include investigation results. The goal of the
investigation is to identify common causes and accident trends over a year or for
the duration of a project and enact corrections in the appropriate systems, equip-
ment, or programs. For example, if there is a high rate of nail gun injuries to
employees during the first 3 weeks of employment, it may indicate the need for
more training on the equipment or possibly investigation of the use of another
manufacturer’s nail gun. Awareness of this issue can save a project time and
money and improve the safety of the employee.

WRITTEN EMERGENCY RESPONSE PLAN

When it comes to safety in construction, most energy is spent on prevention.
Safety programs focus upon the elimination of hazards and reducing injuries
and illnesses. However, do the employees on your jobsite know what to do if an
accident occurs? A written emergency response plan is another vital aspect of a
safety program, but many jobsites do not have a detailed plan. Why? A possible
reason may be due to the lack of federal standards. The standards merely men-
tion a rescue component and do not define what is meant by a “prompt rescue.”
In the ANSI standards, Section A.10, which details the safety requirements for
Construction and Demolition Operations, section A.10.26 Emergency Proce-
dures for Construction Sites, address the NEED for emergency procedures on

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 C h a p t e r 16 Safety 537

construction sites, but go no further. Without regulations requiring these types of

plans, not much effort is placed upon preparedness.
When developing a plan, begin with the end in mind, and that is decreas-
ing the number of fatalities, injuries, and illnesses that may result if an accident
occurs. The plan must include training for employees in rescue procedures and
be site specific. Key elements of the plan include knowing when and how to
rescue workers, making sure that the necessary life-saving tools are available,
understanding the roles of various emergency responders, and effective coordi-
nation with local authorities.
The plan should detail the local resources available to the jobsite, to include
emergency response teams, HAZMAT teams, and disaster relief specialty teams. It
should set procedures with preplanned objectives to include defining the “golden
hour.” This is the longest amount of time that should pass between trauma and
treatment. In addition to having the right tools and equipment available, employ-
ees must be trained in how to use them. One of the hardest things to train and plan
for is the human emotional responses to the incident. Brief your employees on
what they may expect. Advanced planning with local officials can greatly improve
the effectiveness of the plan. At a minimum, the local officials should be familiar
with the jobsite location, know who is part of the rescue team, and have detailed
contact information for all company representatives and related personnel.
Rescue planning and training is critical. As mentioned earlier, falls account
for a large number of fatalities and injuries each year as do trenching acci-
dents. In 2005, 394 construction personnel lost their lives as a result of falls and
39 fatalities were recorded due to trench and excavation cave-ins. When analyz-
ing falls, if an employee is wearing a safety harness, it will do its job. The rescue
is the vital component. To ensure a successful rescue, training and timing are
critical. The training program must include a briefing that covers hazards daily
and daily inspection of related equipment. Time is of the essence in a rescue,
because the harness restricts blood flow and brain damage can occur in as little
as 3–4 minutes after loss of consciousness and stoppage of breathing.
Also, coworkers should remain calm, so as not to cause any further trauma
to the injured worker. Rescues from trenches are no less difficult. Most deaths in
trenches are caused by medical asphyxia, due to the immense weight of the soil
crushing the ribs, or compartment syndrome, where blood is cut off from the
muscles and tissue necrosis can occur in as little as 10 minutes. Once a trench
has collapsed, certain precautions must be taken to prevent another collapse.
These include turning off equipment, halting traffic near the trench, and keep-
ing people back at least 50 feet. The last precaution may be the most difficult to
enforce, as most coworkers want to help. However, coworkers can do very little
and statistics show that 75% of would-be rescuers become victims themselves.
The trench shown in Fig. 16.11 is correctly shored and has a readily accessible
method of egress—the ladder.
The success of an emergency response plan involves the amount of prepara-
tion and how effective communication is during a crisis. A highly coordinated

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 538 PA R T 2 Construction Practice

FIGURE 16.11 Example trench bracing.

management and communications strategy is the foundation for an emergency

response plan, and training is the cornerstone.

SAFETY AND HEALTH TRAINING

While a majority of the OSHA regulations focus on the creation of safe work
environments, some regulations concentrate on the responsibility of manage-
ment to maintain safe worksites by ensuring that appropriate safety training is
received by employees. Subsection 1926.21, entitled “Safety Training and Edu-
cation,” outlines the requirements of employers to provide employee training,
but does not describe the details of how to meet these requirements. At a mini-
mum, the training programs must meet the guidelines and regulations promul-
gated by OSHA. These requirements are that all employees in the construction
industry are to be trained in the recognition, avoidance, and prevention of unsafe
conditions.
Despite the fact that training is a requirement, in the period from October
2005 to September 2006, there were 1,105 citations relating to the education
and training standard that resulted in 1,066 investigations by OSHA officials.
Of these incidences, the fines assessed for violation of §1926.21 were over
$950,000.

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 C h a p t e r 16 Safety 539

QUANTIFY TRAINING NEEDS

On each jobsite, employees will be conducting different types of work requir-
ing various levels of safety training to meet regulatory guidelines. The first step
in development of an effective company training program is to determine the
regulatory requirements. §1926.21 outlines these training and education require-
ments in general terms. Other subsections address specific training requirements
for the safe operation of various equipment and tools.
The most extensive section regarding training and education of employ-
ees in the OSHA standards can be found in §1926.59, Hazard communication.
There was a time when employees had no legal means to force their employers
to provide them with information about the hazardous substances they used at
work. They demanded a “Right-to-Know” or the right to have access to such
information. The federal OSHA standards detailed within 29 CFR 1910.12 and
1926.59, better known as the “hazard communications” or “right-to-know” stan-
dards, require employers to do just that. This section of the standards requires
employers to develop and implement employee training programs that inform
them of the hazards of chemicals used in the workplace and the appropriate pro-
tective measures available for hazard avoidance.
When identifying the needs of a program, determine the type of work to be
performed and then review the applicable OSHA standards. Different types of
work and the use of equipment associated with that work have specific train-
ing requirements according to the OSHA regulations. The education of your
employees regarding these standards is required by law, so be sure these topics
are included within the training program.
In addition to the regulatory and specific jobsite requirements, a determi-
nation must be made regarding the solution of a safety problem via training.
Do safety problems currently exist? Will training solve the unsafe practices of
employees or are there other actions that must be taken? Not every problem may
be solved through training, such as shoddy equipment or unavailability of mate-
rials. Problems that can be addressed effectively by training include:
■ lack of knowledge of a work process
■ unfamiliarity with equipment
■ incorrect execution of a task
In determining what training is needed, you must identify the work the employee
is expected to complete and if the employee’s performance is deficient. To obtain
this information, an analysis of what an employee needs to know in order to per-
form a job in a safe manner must be conducted. With this information, specific
training requirements will be identified.
When defining the general goals of your program, consider the following
areas where adequate training and education can really affect the bottom line.
■ Regulatory or performance based goals (i.e., meet OSHA standards)
■ Reduction in accidents, injuries, and illnesses

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 540 PA R T 2 Construction Practice

■ Reduction in lost workdays, hours, etc.

■ Improved EMR rating
■ Strong safety records
In addition to overreaching company goals and improvement of the bottom line,
goals should be set that involve the level of training, the frequency of training,
and the quality of training. Consider goals such as:
■ Corporate managers and top executives will receive annual safety training.
■ Supervisors, project managers, and superintendents will receive project-
specific training.
■ Every employee receives initial company safety orientation within
1–3 days of starting work.
■ Every employee receives refresher training at regular intervals.
■ Every employee is instructed in safe practices and the hazards associated
with the activity prior to the commencement of that activity.
In order to effectively administer a safety training program, guidelines and
objectives must be determined for the training. The goal of instructional objec-
tives is to clearly state what you want your employees to do, to do better, or to
stop doing as a result of the training. These objectives must be definitive and
measurable, precisely indicating the skills or knowledge that must be demon-
strated by an employee upon completion of the training. The learning objectives
should also state the conditions for acceptable employee performance and the
level of competency required to satisfactorily complete training.
The critical elements of a training program are the content of the program,
the people delivering the training, and the employees receiving the training. After
development of safety goals and the objectives of the training program, employ-
ers can begin to define the elements of the program. The content of the program
should be outlined with precise activities that the employee will take part in
during training. These activities should simulate the actual job environment as
closely as possible to best ensure that the employee will transfer the skills learned
in training to the job. By arranging the course material to mimic the sequence of
events that would be used on-site, a specific safe practice can be developed.
For example, if an employee is learning the process of safe operation of a
power tool, the sequence might be:
1. Ensure that the power source cord is free of defects.
2. Check that the power source is connected.
3. Identify and acknowledge that safety devices are in place and operating.
4. Understand the manufacturer's recommendations for safe operation.
5. Identify the power switch and its operation.
6. Determine and use the appropriate personal protective equipment, etc.
When determining the actual content of the training program, examine the needs
that were previously identified.

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 C h a p t e r 16 Safety 541

TABLE 16.3 Top five training standard violations.

Number of Dollars
Standard Subsection citations fined Description
1926.503 M – Fall Protection 2,002 966,063 Training requirements
1926.454 L – Scaffolding 1,281 1,073,088 Training requirements
1926.21 C – General 1,105 954,189 Safety training and
Requirements education
1926.1060 X – Ladders 455 113,738 Training requirements
1926.761 R – Steel Erection 122 101,916 Training

Each of these areas has specific requirements with respect to training that
can be cited. In the period from October 2005 to September 2006, there were
1,281 citations and 1,140 investigations leading to over $1,073,000 in fines for
violation of the scaffolding training requirements outlined in §1926.454. Falls
are one of the leading causes of death on construction sites. During the same
time period, there were 2,002 citations and 1,881 investigations for failure to
comply with §1926.503, fall protection training. These citations yielded over
$966,000 in fines. Table 16.3 highlights the top five most violated OSHA train-
ing standards. Is it just a coincidence that falls from heights are the leading cause
of death in the construction industry and that the most violated OSHA standard
is §1926.451—General Requirements for All Types of Scaffolding? Based upon
the above facts, every safety training program should begin the development of
its content by focusing on those standards.

KEY COMPONENTS TO A SUCCESSFUL

PROGRAM—BEYOND REGULATORY
REQUIREMENTS
In addition to the regulatory requirements that you must meet in relation to train-
ing programs, other important components contribute to the success of a training
program. Research completed on safe workplaces indicates that certain actions
can influence the overall success or failure of a safety program. These compo-
nents are easy to implement, most only take time and planning prior to comple-
tion of work. However, what makes implementation difficult is that these steps
are attempting to change individual attitudes and habits. Although the steps are
tangible methods that can be outlined on paper, the real effect and delivery is
somewhat intangible. The focus of these components is making the shift from
written policy to action at all levels.

ESTABLISHING THE SAFETY FOUNDATION

Safety demands a constant effort from all parties involved. The degree of success
of any training program is contingent upon field implementation of the knowl-
edge acquired during the instruction. Practicing the guidelines detailed within

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 542 PA R T 2 Construction Practice

the training on a daily basis must be expected from all employees. When estab-
lishing a strong safety foundation, a message must be sent to employees indicat-
ing not only that they are expected to follow the safety regulations, but also that
they should immediately take care of any safety problems that they encounter. If
they are unable to correct the problem by themselves, they should contact their
immediate supervisor to get the appropriate help.
All employees need to know that they are empowered to correct any unsafe
conditions on a site and that they can stop working if they feel they are in an
unsafe environment. With this concept in mind and knowing that it is supported
by the employer, employees will begin to act safely. Employees must see that
compliance with safe work practices is for their benefit and that violation of
these practices will not be tolerated. To enforce that belief, it must be clear that
noncompliance with the safety regulations will result in immediate action. For
example, some employers have adopted a three-strikes system that deals with
safety violations in stages. The employee is issued a warning regarding his or
her unsafe behavior for the first infraction. Next, the employee is given time off
without pay. Finally, if behavior fails to improve, the employee is terminated.
This system, if followed consistently, will send a clear message regarding the
company’s policy toward safety compliance.

IMPROVING THE OVERALL ATTITUDE

In order to increase the success of a training program, the attitude of the worker
must be changed and apathetic behavior must be modified. People can be
trained so that acting safely and performing work in a safe manner is second
nature. The atmosphere that needs to be created is one where unsafe acts are
not tolerated, and that atmosphere needs to permeate every level of employ-
ment. Regardless of the level of employment, whether top management, project
managers, field personnel, or office administrative staff, the environment cre-
ated must be one where unsafe practices do not exist. If the environment exists
where safety is the first consideration given to every task by every employee,
then the “safety first” sign at the project entrance is more than just a sign—it
has real significance.
The attitude toward safety is even more important during the actual training
sessions. The focus of the training should be positive. Safety should not be viewed
as something that has to be done to avoid a punishment. It should be addressed
in a favorable light, with enthusiasm and a positive attitude. Training must also
possess a level of seriousness since the goal of the program is to ultimately save
lives and reduce injuries. Make sure employees understand what could happen if
the practices are not followed. Part of a safety training program should include
images of what has happened as a result of unsafe practices. Although some-
times graphic, these images will leave a lasting impression. Additionally, OSHA
publishes documents easily accessible on its website that highlight fatal acci-
dents. Employees can learn from others’ mistakes. Employees need to know that
the company cares about their safety and well-being. Safety training should take

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 C h a p t e r 16 Safety 543

center stage regularly throughout the month. It should be viewed as an invest-

ment and not as an expenditure. As the old saying goes, “People don’t care how
much you know, until they know how much you care.” Keep that phrase in mind
as training is conducted. Focus on issues that are important to workers and listen
to their feedback. Try something novel with a safety twist, such as a safety essay
or poster contest for employee’s children. This is an easy and fun way to involve
employees. Last, remember during training that the attitude of trainees is often a
reflection of the trainer’s attitude.

PROMOTION OF THE SAFETY CULTURE

Safe people develop a mindset and when they work with other people of the
same mind set, a new safety culture is achieved. Employees need to be an active
and integral part of the safety team. To help promote this sense of inclusion and
responsibility, have your employees sign a personal commitment to safety and
positive interaction. This document is a powerful tool that noted safety profes-
sional Art Fettig developed several years ago. People need to learn to interact
with each other in positive ways to promote safe work environments and prac-
tices. Part of the training program must address this issue. On many jobsites
where accidents occur, you hear coworkers say, “I knew they were going to hurt
themselves or someone, they were always taking chances.” Why don’t cowork-
ers get involved? A positive interaction program can work only if you first have
the participant’s signed permission. It should state that they give their permis-
sion for other employees to point out to them when they are acting unsafely.
Workers need to admit that they are human and that they do make mistakes.
Injuries and accidents most often occur when individuals become complacent
with their work and let their guards down. If part of the training program empha-
sizes that everyone is an equal player in the game of workplace safety, everyone
will benefit.

OTHER SAFETY RESOURCES

There are several resources available to the construction manager to help in
developing a safety program and navigating the complex issues surrounding
safety. The Construction Industry Institute (CII) as well as the National Safety
Council and other local organizations provide safety training programs. Addi-
tionally, trade and professional organizations have actively participated in
improving safety education and practice. Consider involvement or contacting
these agencies before you begin developing a program.

SUMMARY
Comprehending the impact of safety on your bottom line, what is required by
law, what to expect during an OSHA jobsite visit, and the development of a
safety program are either directly or indirectly part of your responsibilities as a

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 544 PA R T 2 Construction Practice

construction manager. Effective planning for safety at all phases of a project will
help you to provide a safe and healthy jobsite for all of your employees. Safety
is a combination of education, training, and enforcement, but do not forget the
human element. Leading by example and providing a positive attitude toward
safety will help establish you as a safety leader.

REVIEW QUESTIONS
16.1 What is the purpose of an Experience Modification Rate?
16.2 When calculating the Experience Modification Rate for a company in
2009, what years of data would be included?
16.3 What act created federal OSHA?
16.4 What are the record keeping requirements for OSHA?
16.5 How long do you have to keep OSHA logs of injuries and illnesses?
16.6 What is the leading cause of fatalities in the construction industry?
16.7 Why do you need to have worker’s compensation insurance?
16.8 Summarize the OSHA site inspection process.
16.9 What makes an injury reportable according to OSHA standards?
16.10 Describe the consultancy program supported by OSHA.
16.11 Identify three tasks that are commonly performed on a jobsite and
perform a job hazard analysis on each.
16.12 Develop a mitigation plan for the tasks identified in problem 16.11.
16.13 Write an emergency response plan for a fall from heights.
16.14 Outline the key components of a safety plan for a residential and
highway construction project. How do they differ?
16.15 Develop a list of emergency contacts for jobsite rescue and emergency
response teams in your local area.

REFERENCES
1. Diether, J., and G. Loos. (2002). “Advancing Safety and Health Training,”
Occupational Health and Safety, 69: 28–34.
2. Fettig, A. (1998). Winning the Safety Commitment. Growth Unlimited Inc.,
Battle Creek, MI.
3. Hinze, J. W. (2003). “Safety Plus: Making Zero Accidents a Reality,”
Construction Industry Institute Research Report 160-11.
4. Occupational Safety and Health Administration (OSHA). (2007). OSHA
Standards for the Construction Industry, 29 CFR 1926. U.S. Department
of Labor, Washington, DC.

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 C h a p t e r 16 Safety 545

WEBSITE RESOURCES
1. www.osha.gov/recordkeeping/RKforms.html
2. www.osha.gov

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