Session No.

503

Standards for Safety in Construction and Demolition Operations

A10 Series: Engaging the Process

Jerry E. Rivera, MEng

Power Design Inc.
St. Petersburg, FL

Thomas Trauger, MBA, MSIH, ARM, CRIS

Winchester Homes
Bethesda MD

Introduction
In 2011 the American Society of Safety Engineers (ASSE) celebrated 100 years of service to the
environmental, health and safety profession. Certainly, many aspect of the EHS practice has evolved
demanding that practitioners quickly adapt to professional needs. Today’s EHS practitioners face increase
pressure of demonstrating higher levels of competence at all levels of the professional practice. The
knowledge fundamentals demand skill levels in business continuity, hazard analysis techniques, risk
management, law and industry standards.

According to data provided in NIST Special Publication 806, Standards Activities of

Organizations in the United States (1996 Edition; edited by Robert B. Toth), there are more than 93,000
standards produced and nearly 700 organizations that cited standards development as an area of activity.
Of these, the federal government is the largest single creator and user of standards (more than 44,000 of
them); the private sector in America collectively has about 49,000 standards. 1

Many of the standards in circulation today claim to address safety in one form or another.
Whether it’s in the area of product safety or workplace safety it can easily become a discouraging task for
EHS practitioners to adopt consensus standards in the workplace. More alarming is that while there are
about 49,000 private sector standards throughout the US today, few EHS practitioners are part of the
standard development process. EHS practitioners are expected to know how to interpret, implement and
comply with applicable standards that impact their industry. The lack of participation of EHS
practitioners in the standard development process puts the practice and constituents represented at a
serious disadvantage.
This paper will explore how practitioner in the construction industry can engage the standard
development process with the purpose of crafting out the future of the EHS practice. The paper will focus
on the ANSI/ASSE 10 Standards with an overview of the ANSI process.

1
American National Standards Institute (ANSI) 1996. Domestic Programs (American National Standards) Overview
(retrieved February 17, 2014)
(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3).
About ANSI
From the very first American National Standard (ANS) on pipe threads, to work that is underway today to
meet emerging needs and priorities, ANSI-approved standards have provide tremendous benefit to society
and the global economy. Their work spans a broad spectrum of industries: from nanotechnology and
energy efficiency to telecommunications and the rapidly expanding service sector, the reach and influence
of the standards community is pervasive. Participation by a standards developer in the ANS process
signifies a commitment to the creation of high-quality, market-driven standards in an open environment
characterized by due process and ANSI’s neutral third party oversight. ANS set benchmarks for quality
and performance that help to protect the public interest and foster commerce by influencing the design,
manufacture, marketing, distribution, and safe use of products and processes worldwide. 2

ANSI Process
(ANS) is a document that has been sponsored by an ANSI-Accredited Standards Developer, achieved
consensus, met ANSI’s Essential Requirements, and been approved by the Institute.
The hallmarks of this process ensure that American National Standards are developed in a manner that is
equitable, accessible, and responsive: 3

1. Participation is open to all interested stakeholders

2. Balance of interests shall be sought
3. Consensus must be reached by representatives from materially affected and interested parties in an
environment that is free from dominance by any party
4. Standards are required to undergo public reviews during which any member of the public may
comment
5. Comments from the consensus body and public review period must be responded to in writing
6. All unresolved objections, attempts at resolution, and substantive changes to text are provided to the
ANS consensus body for review prior to final vote
7. An appeals process through the standards developer to address procedural concerns is required

Periodic maintenance is defined as the maintenance of a standard by review of the entire

document and action to revise or reaffirm it on a schedule not to exceed five years from the date of its
approval as an American National Standard. The standards developer may request an extension of time to
reaffirm or revise the standard.

No extension of time beyond ten years from the date of approval is granted for action on a
standard. In no case shall a standard maintained.

2
American National Standards Institute (ANSI) 2012. Value of the ANS designation (retrieved February 17, 2014)
(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3)
3
American National Standards Institute (ANSI) 2012. Value of the ANS designation (retrieved February 17, 2014)
(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3)
Figure 1. A10 Members voting on a proposed issue.

Once a standard is developed by the subcommittee it is put to a vote to the committee membership. This
is done by email. Prior to the vote the members have the opportunity to comment on the standard. A
comment tracking matrix with all comments is then circulated to all members for review. The
subcommittee reviews the comments and may incorporate the recommended changes. In many instances
they may not be incorporated. The disposition of the comment is tracked on the matrix. In many instances
there are comments that may take longer to resolve. The head of the subcommittee makes the final
decision in consultation with the subcommittee members on rejecting and including comments. Once this
decision is made if a member of the committee is not satisfied with the decision he/she can follow the
appeals process.

Assuming all comments are resolved the final draft standard is put to a vote and each member of
the committee completes a ballot, voting yes, no or abstain. This ballot is submitted to the secretary.

A10 Committee
The A10 Committee writes and interprets voluntary national consensus standards regarding workplace
hazards that provide guidance as well as technical information to Environmental, Health and Safety
Professionals. 4

The A10 Committee is responsible for:

4
American Society of Safety Engineers (ASSE) 2009. Procedures A10 ASC
 1. Developing proposed American National Standards within the scope of the committee
2. Voting on approval of proposed American National Standards within its scope
3. Maintaining the standards developed by the Committee
4. Review each standard within its scope at least every five years and determine the appropriate
recommendations for (a) reaffirmation, (b) revision, or (c) withdrawal
5. Adopting Committee policy and procedures for interpretations of the standard(s) developed by
the Committee
6. Coordinating and responding to requests for interpretations of the standard(s) developed by the
Committee
7. Adopting committee procedures and revisions thereof
8. Considering and acting on proposals for termination of the Committee
9. Other matters requiring Committee action as provided in these procedures

The Secretariat of the American Society of Safety Engineers (ASSE) shall:

1. Organize the Committee (see Section 2)

2. Apply for committee accreditation by ANSI and maintain accreditation in accordance with ANSI
requirements, including submission of the Committee Roster
3. Oversee the Committee's compliance with these procedures
4. Maintain a roster of the Committee and a list of standards for which the Committee is responsible
5. Provide a Committee secretary to perform administrative work, including secretarial services;
meeting notices and arrangements; preparation and distribution of meeting agendas, minutes,
ballots and draft standards; and maintenance of adequate records
6. Submit candidate standards approved by the Committee, with supporting documentation, for
ANSI review and approval as American National Standards
7. Publish or arrange with ANSI for publication of its standards, revisions and addenda
8. Perform other administrative functions as required by these procedures

The committee consists of a chairman and a vice-chairman appointed by the secretariat from the
individual members or representatives of the Committees, subject to approval by majority vote of the
Committee. Each will serve until a successor is selected and ready to serve. The vice-chairman shall
carry out the chairman duties if the chairman is temporarily unable to do so. The secretary is appointed by
the secretariat.

The chairman and vice-chairman serve a three-year term, beginning with the election at the first
meeting of the Committee in the calendar year.
Figure 2. A member of the committee conducting a presentation.

Membership
Members of the Committee consist of organizations (preferably national in scope), companies,
government agencies, individuals, users, etc., having an interest in the activities of the Committee.
The addition or termination of members is subject to approval by vote of the Committee after
the application has been processed in accordance with Committee Procedures or the membership
reviewed. There shall not be any more than seventy-five voting members on the committee

Application
A request for membership is addressed to the secretariat, indicating the applicant's interest in the
Committee's work and qualifications and willingness to participate actively, and, if the applicant is an
organization, company or government agency, identify itself as (a) a representative, (b) an alternate(s), if
desired, and (c) an information contact at the organization headquarters.

In recommending appropriate action to the Committee on applications for membership, the

Secretariat considers the:

1. Need for active participation by each interest

2. Potential for dominance by a single interest category
3. Extent of interest expressed by the applicant and the applicant's willingness to participate actively
4. The representative identified by the applicant organization, company, or government agency.
Membership Requirements
Continuing membership on the Committee is based on active participation in Committee activities. All
Committee members are required to complete the following three participation requirements for
continued A10 Committee membership.

1. accept appointment to at least one ASC A10 Committee Subgroup

2. respond to at least 75% of letter ballots
3. attend at least one of the two annual ASC A10 Committee meetings

Subgroups Created by the Committee

When the secretariat, the chairman, or the Committee determines a need to create one or more
standing subgroups (subcommittees, technical subcommittees) to expedite the work of the
Committee, their formation (and later disbandment) requires approval by a majority vote of the
Committee, and appropriate public notice. The scope and duties delegated to the subgroups are approved
at the time it is formed, and subsequent changes in scope or duties also require approval. The charge to
the subgroups clearly state whether:

1. The subgroup is responsible for the definitive content of one or more standards and for
responding to views and objections thereon. Such subgroups need to meet the requirements
established for committees as applied to voting on the standard(s), or
2. The subgroup is responsible for assisting the Committee (e.g., drafting all or a portion of a
standard, drafting responses to comments, drafting positions on international standards, or other
advisory functions).

The secretariat, at times, may determine a need to establish a subgroup or steering committee on
an ad hoc basis to assist the Committee or a subcommittee. Its formation (and disbandment) is at the
discretion of the secretariat.

Subcommittees for standards that are being updated or are new typically hold meetings the day
before the A10 committee meeting. There are several organizations in the Washington D.C. area that have
facilities where subcommittee meetings can be conducted. The meetings are typically conducted in the
afternoon. Sub committees may have meetings during the year at other locations or conduct conference
calls. You do not need to be a member of the A10 Committee to lead a subcommittee. Any safety
professional with expert knowledge in the standard being developed can volunteer to head the
subcommittee. However, they may not vote on it.
Figure 3. Members of the A10.49 Health Hazards Subcommittee reviewing the proposed
standard.

Open Meetings
Meetings of the Committee shall be open to all members and others having an interest. When
possible, at least four weeks' notice of regularly scheduled meetings shall be given by the secretariat in
ANSI's "Standards Action;" or in other media designed to reach affected interests; or in both. The notice
shall describe the purpose of the meeting and shall identify a readily available source for further
information. An agenda and schedule is distributed in advance of the meeting to members and to others
expressing interest.

Meetings are held twice a year in January and July. For the past several years they have been
conducted at the International Brotherhood of Electrical Workers in Washington D.C. A large conference
room is used and has been provided by the IBEW which is on the committee. There are several other
organizations that are part of the committee that have facilities in the Washington DC area that can hold
the meetings. In the past one meeting was conducted at the National Association of Homebuilders.
Meetings start at 12:30 pm and end at 4 pm. However meetings may continue longer depending on issues
being discussed.

Public Review
Proposals for new American National Standards or reaffirmation, revision or withdrawal of existing
American National Standards shall be transmitted to ANSI for listing in "Standards Action" for comment.
 Views and objections resulting from the above are dealt with in accordance with Committee
guidelines. Any substantive change made in the proposed American National Standard is typically listed
for a limited public review of the changes.

Prompt consideration is given to the timely written views and objections of all participants,
including those commenting on either the PINS announcement or public comment listing in
Standards Action. Comments generated from PINS notification need to be addressed in accordance with
ANSI Essential Requirements.

Appeals
Directly and materially affected interests who believe they have been or will be adversely affected by a
standard within the Committee's jurisdiction, or by the lack thereof, have the right to appeal substantive or
procedural actions or inactions of the Committee or the secretariat.

ANSI/ASSE A10 Standards

The ANSI Accredited A10 Committee (ASC) is one of the longest existing voluntary national consensus
standards committee in the United States. Founded originally in 1944, the A10 ASC writes and interprets
voluntary national consensus standards relating to the protection of employees and the public from
hazards arising out of, or associated with, construction and demolition operations. 5

SH&E professionals working in the construction industry have significant interest in these
standards due to the fact that they are recognized in both the public and private sectors. Specifically, the
A10 Standards have extensive recognition in the standards of the U.S. Department of Labor Occupational
Safety and Health Administration and by a series of other national and state government agencies. At the
private sector level A10 Standards are widely cited and required in different contracts and work
agreements

The full A10 ASC is made-up of seventy-four national organizations from the private and public
sector. In addition, there are forty-eight (48) accredited standards and projects under the A10 banner. A
subgroup is created and approved by the committee, which is responsible for putting together draft
documents for review by the A10 ASC. The subgroups are not responsible for the definitive content of the
standard and instead serve to assist the committee in putting the documents together and serving as a
technical resource.

A10.1-200X (Planning For Construction and Demolition Operations).

A10.2-20XX (Safety, Health and Environmental Training).
A10.3-1995 (Powder Actuated Fastening Systems Schofield).
A10.4-2004 (Personnel Hoists).
A10.5-2005 (Material Hoists).
A10.6-1989 (R1998) (Demolition Operations).
A10.7-1998 (R2005) (Blasting).
A10.8-2001 (Scaffolding).
A10.9-2004 (Concrete & Masonry Construction).
A10.10-2004 (Space Heating Devices).
A10.11-1989 (R1998) (Safety Nets).
A10.12-1998 (R2005) (Excavation).

5
American Society of Safety Engineers (ASSE) 2008. A10 Information Sheet
A10.13-2001 (Steel Erection).
A10.14-Withdrawn (Fall Protection Systems for Construction and Demolitions).
A10.15-1995 (R2005) (Marine Dredging).
A10.16-1995 (R2001) (Tunnels, Shafts and Caissons).
A10.17-2006 (Asphalt/Pavement Construction).
A10.18-2006 (Temporary Floor and Wall Openings, Railings, and Toeboards).
A10.19-200X (Pile Installation & Extraction Operations).
A10.20-2005 (Ceramic tile, Terrazzo and Marble Work).
A10.21-200X (Control of Health Hazards in Construction)
A10.22-1990 (R1998) (Rope Guided and Nonguided Hoists).
A10.23-200X (Reserved for future use)
A10.24-2006 (Roofing).
A10.25-200X (Sanitation in Construction).
A10.26-200X (Emergency Medical and Rescue Procedures for Construction Sites).
A10.27-1998 (R2005) (Asphalt Mixing Plants).
A10.28-1998 (Crane or Derrick Suspended Work-Platform Platforms).
A10.29-200X (Safe Use of Aerial Lifts in Construction).
A10.30-200X (Construction Workplace Security).
A10.31-1995 (Digger-Derricks.
A10.32 (Fall Protection System for Construction Industry Users).
A10.33-1998 (R2004) (Safety and Health Program).
A10.34-2001 (R2005) (Public Protection).
A10.35-200X (High Pressure Hydro Blasting).
A10.36-200X (Railroad Safety).
A10.37-1996 (Debris Nets).
A10.38-2000 (Safety Program Elements).
A10.39-1996 (R2005) (Safety Audits).
A10.40-2007 (Ergonomics in Construction).
A10.41-200X (Equipment Operator/ Supervisor Qualifications and Responsibilities).
A10.42-2000 (Rigging Supervisor, Signalmen Qualifications and Responsibilities).
A10.43-200X (Confined Spaces in Construction).
A10.44-2006 (Lock/Out Tag/Out)
A10.45-200X (Reserved for future use)
A10.46-2007 (Hearing Loss Prevention).
A10.47-200X (Highway Construction Safety).
A10.48-200X (Tower Erection).

Regulatory Impact on EHS Profession

OMB CIRCULAR A-119, First Published in 1980
This Circular establishes policies to improve the internal management of the Executive Branch.
Consistent with Section 12(d) of P.L. 104-113, the "National Technology Transfer and Advancement Act
of 1995" (hereinafter "the Act"), this Circular directs agencies to use voluntary consensus standards in
lieu of government-unique standards except where inconsistent with law or otherwise impractical. It also
provides guidance for agencies participating in voluntary consensus standards bodies and describes
procedures for satisfying the reporting requirements in the Act. The policies in this Circular are intended
to reduce to a minimum the reliance by agencies on government-unique standards. 6

6
Silcox, Clark “Incorporation by Reference: “Inclusion of Consensus by Public Law and Coping with a Moving
Target” November 18, 2011.
 For purposes of this policy, "voluntary consensus standards" are standards developed or adopted
by voluntary consensus standards bodies, both domestic and international. These standards include
provisions requiring that owners of relevant intellectual property have
agreed to make that intellectual property available on a nondiscriminatory, royalty-free or reasonable
royalty basis to all interested parties. For purposes of this Circular, "technical standards that are developed
or adopted by voluntary consensus standard bodies" is an
equivalent term. 7

"Voluntary consensus standards bodies" are domestic or international organizations which plan,
develop, establish, or coordinate voluntary consensus standards using agreed upon procedures. For the
purpose of this Circular, "voluntary, private sector, consensus standards bodies," as cited in Act, is an
equivalent term. The Act and the Circular encourage the participation of federal representatives in these
bodies to increase the likelihood that the standards they develop will meet both public and private sector
needs. A voluntary consensus standards body is defined by the following attributes:

1. Openness
2. Balance of interest
3. Due process
4. An appeal process

Consensus, which is defined as general agreement, but not necessarily unanimity, and
includes a process for attempting to resolve objections by interested parties, as long as all
comments have been fairly considered, each objector is advised of the disposition of his or
her objection(s) and the reasons why, and the consensus body members are given an
opportunity to change their votes after reviewing the comments. 8

National level draws most attention because of OSHA’s Impact on EHS Professionals
Laws / Guidelines require agency to review voluntary consensus standards during proposed rulemaking.

If not, the agency is expected to work with the private sector to develop the needed standard.

Legal Implication and the EHS Profession

In tort litigation actions arising from workplace accidents, the presence or absence of a recognized and
substantive safety and health management program can be critical in controlling financial liability. Thus,
the extent to which OSHA and MSHA reference Z10 in future publications or rulemaking activities will
increase its judicial recognition and create a guideline against which employer programs will be
benchmarked. 9

OSHA Reform
ASSE encourages support of OSHA reforms that foster the use of consensus standards in
enforcement when a standard does not exist, is inadequate, or is obsolete/dated. For safety

7
Silcox, Clark “Incorporation by Reference: “Inclusion of Consensus by Public Law and Coping with a Moving
Target,” November 18, 2011.
8
Silcox, Clark “Incorporation by Reference: “Inclusion of Consensus by Public Law and Coping with a Moving
Target,” November 18, 2011.
9
Abrams, Adele L., “Legal Perspective: ANSI Z10 2005 Standard Occupational Health and Safety Management
Systems. July 2005
professionals/practitioners to realize greater opportunities to apply their professional skill and
judgment, consensus standards must, in some sense, be authoritative. Without such authority,
safety and health professionals may not have sufficient influence and resources to properly do
their jobs. For consensus standards to be authoritative, OSHA must be able to routinely rely on
provisions of consensus standards in enforcement. 10

Conclusion
In the previous pages we briefly reviewed the importance of the development of ANSI standards for the
construction industry. A review of the A10 committee and the process it follows to develop and approve
consensus standards. Safety and health practitioners need to be part of the process and should learn the
skills needed for standard development. Through the development of consensus standards, the practice of
safety will experience continuous improvement and address issues that the regulations do not. While it is
important for government, labor and private sector organizations to be involved, it is a duty of safety and
health practitioners to get engaged in the process and help define the future of the safety and health
practice.

The ANSI/A10 Committee needs involvement from safety professional at all levels.
While organizations currently hold seats at the committee there are multiple ways that safety practitioners
can get involved without having to be part of the Committee. This can be done through the submittal of
comments or the active participation in a subgroup.
The safety practitioners should interpret this paper as a call to action. Engage the process!

Bibliography
Abrams, Adele L. “Legal Perspective: ANSI Z10 2005 Standard Occupational Health and Safety
Management Systems.” The Compass 3-5. July 2005.

American National Standards Institute (ANSI). 1997. Media Tips and Case Studies Standards Overview:
Avoiding Surprises - Some Thoughts on Standard. (retrieved on February 28, 2014)
(http://www.ansi.org/news_publications/media_tips/standards_overview_cont.aspx?menuid=7)

American National Standards Institute (ANSI), 2012. Value of the ANS designation (retrieved February
17, 2014)
(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3)

American Society of Safety Engineers (ASSE). 2003. Position Statement on the Role of Consensus
Standards and Governmental Regulations in Occupational Safety and Health (retrieved on
February 28, 2014).
(http://www.asse.org/publications/standards/docs/PositionStatementonConsensusStandards.pdf)

Federal Register. 2012. Federal Participation in the Development and Use of Voluntary Consensus
Standards and in Conformity Assessment Activities (retrieved on February 28, 2014)
(https://www.federalregister.gov/articles/2012/03/30/2012-7602/federal-participation-in-the-
development-and-use-of-voluntary-consensus-standards-and-in-conformity)

10
American Society of Safety Engineers (ASSE). 2003 Position Statement on the Role of Consensus Standards and
Government Regulations in Occupational Safety and Health Des Plains, IL American Society of Safety Engineers.
National Institute of Standards and Technology (NIST). 2010. Thirteenth Annual Report on Federal
Agency Use of Voluntary Consensus Standards and Conformity Assessment (retrieved in
February, 28, 2013) (https://standards.gov/nttaa/resources/nttaa_ar_2009.pdf)

Occupational Safety and Health Administration (OSHA). 2004. 29 CFR 1910, Updating OSHA Standards
Based on National Consensus Standards (retrieved February 28, 2014)
(https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&
p_id=18260)

Silcox, Clark. 2011. “Incorporation by Reference: Inclusion of Consensus by Public Law and Coping
with a Moving Target.” Small Business Administration Safety and Health Round Table.
Washington, DC.

The Society for Standards Professionals (SES). 2010. “Frequently Asked Questions” (retrieved on
February 28, 2014) (http://www.ses-standards.org/displaycommon.cfm?an=1&subarticlenbr=58)