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Most Frequently Cited OSHA
Construction Standards
Federal OSHA – FY 2012
John A Newquist
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#1 1926.501 (b)(13)
• Most the falls are
those with no fall
arrest
• Workers can slip on
shingle or felt to start
slipping
• Most are roof falls in
residential
No fall arrest protection
used
Part 1 Directive
• Effective June 16, 2011
• OSHA has issued a directive rescinding the Interim Fall Protection
Compliance Guidelines for Residential Construction (STD 03-00-
001)
• OSHA Extends Residential enforcement. Note: OSHA's policy does
NOT give builders a reprieve from new, more stringent fall
protection regulations.
• First, the regulation hasn't changed; the old 1994 regulation is just
being enforced. Second, there is no reprieve. Those requirements
have been in effect for over a year. Penalties are lower and more
compliance assistance is offered, but builders and roofers are
required to comply with the new requirements.
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEW
What is Residential?
• The end-use is to have
people live in as their
home, i.e., a
dwelling/apartment
AND
• The structure being built
must be constructed
using traditional wood
frame construction
materials and methods.
– Metal Studs
– Masonry
Residential? NO! (most instances)
• Churches
• Nursing Homes
• Banks
• Hotels
Nursing Homes
Hotels
Banks
Fall Protection Plan
• 1926.502(k)
• See Appendix E in
OSHA Subpart M
• ANSI Z359.2 –
Minimum
Requirements for a
Comprehensive
Managed Fall
Protection Program
Fall Protection Program
• Written Plan showing fall arrest is not
feasible
• Plan must be specific to the site it is used
on
• Can be used for repetitive use for a
particular style/model house if ALL issues
related to fall protection are addressed
#2 1926.503(a)(1)
• No fall protection
training program
• This is a program
requirement to train
workers in the
hazards of falls.
• Many use job safety
analysis to determine
potential hazards
faced in construction.
#3 1926.501(b)(1)
• Open-sided floors
over six feet without
fall protection.
• No guardrails on this
commercial building.
• Found quite a bit at
elevator shafts, and
stairwells also.
#4 1926.1053(b)(1)
• Ladder not extending
over the edge 3 feet
#5 1926.102(a)(1)
• 1926.102(a)(1) –
eye/face protection
• Grinding, Chemicals,
Sparks, and any other
flying object hazard
#6 1926.100(a)
• No Hard Hats
• When working around
the bucket of a back
hoe, hard hats should
be worn.
#7 1926.501(b)(10)
• Fall protection not used
on low sloped roofs
• Guardrails and Fall arrest
can be put on roofs.
• 1926.501(b)(10) permits
the use of warning lines
and safety monitoring
systems during the
performance of roofing
work on low-sloped roofs
(least desirable option).
#8 1926.451 (g)(1)
• No guard rails on
scaffolds.
• Often ends are not
protected.
• The cross bracing
may serve as ONE of
the rails only if it
meets certain height
criteria.
#9 1926.20(b)(2)
• No inspection of
worksite by a
competent person
• Workers are never
to allowed to ride
the forks of a rough
terrain forklift.
#10 1926.453(b)(2)(v)
• No Fall Protection in
aerial lifts.
• Worker in photo is
wearing a full body
harness for fall arrest.
• Nearly 400 aerial lift
deaths since 2000.
• Users need a PAL’s
card or specific hands
on user training.
Develop Safety Rules
• Follow Aerial Lift Manufacturer’s
instructions. Use ANSI A92 standards on
aerial lifts if you cannot get them.
• Follow Warning Labels.
• Only trained personnel can operate the
lifts.
• A trained person must inspect the
machine before each shift.
• And many more!
Aerial Lift Training
• Hands on training is
necessary. An aerial lift
is not a car.
• The worker should be
able to demonstrate all
predicted uses of the lift
and compliance with
manufacturers
instructions.
• Always close lift platform
chains or door. (This is
always required).
• Many fatal falls are under
six feet.
Aerial Lift Training
• The worker must know
where to attach the
snaphook for any aerial
lift that has an OSHA
rated anchorage.
• He is wearing a full body
harness for fall arrest.
• Guardrails are not meant
to be used as anchorages
on an aerial lift.
• The manufacturer’s
manual will designate the
proper anchorage points.
Aerial Lift Training
• National Training guidelines
• International Powered Access Federation
(IPAF) www.ipaf.org
• "Spot the Mistake" video
• Promotes safe and effective of product
• 15 training centers/companies in the US.
• Successful trainees are awarded the PAL
Card (Powered Access License) as proof
of training
Bubbling Under the Top Ten
• 1926.652(a)(1) – cave-in
protection
• 1926.451(e)(1) – Unsafe
scaffold access
• 1926.501(b)(11) – No fall
arrest on steep roofs
• 1926.451(b)(1) – Scaffold
needed stable footing
• 1926.20(b)(1) – no
accident prevention
program
Thanks
• To Kenny for all his help.
• My email is johnanewquist@gmail.com
• www.buildsafe.org is a nonprofit where I
teach many classes.
• Follow me on Facebook where I post
everyday on OSHA and safety.

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OSHA Most Cited Construction Standards FY12

  • 1. Most Frequently Cited OSHA Construction Standards Federal OSHA – FY 2012 John A Newquist Facebook Linked In Twitter Slideshare
  • 2. #1 1926.501 (b)(13) • Most the falls are those with no fall arrest • Workers can slip on shingle or felt to start slipping • Most are roof falls in residential No fall arrest protection used
  • 3. Part 1 Directive • Effective June 16, 2011 • OSHA has issued a directive rescinding the Interim Fall Protection Compliance Guidelines for Residential Construction (STD 03-00- 001) • OSHA Extends Residential enforcement. Note: OSHA's policy does NOT give builders a reprieve from new, more stringent fall protection regulations. • First, the regulation hasn't changed; the old 1994 regulation is just being enforced. Second, there is no reprieve. Those requirements have been in effect for over a year. Penalties are lower and more compliance assistance is offered, but builders and roofers are required to comply with the new requirements. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEW
  • 4. What is Residential? • The end-use is to have people live in as their home, i.e., a dwelling/apartment AND • The structure being built must be constructed using traditional wood frame construction materials and methods. – Metal Studs – Masonry
  • 5. Residential? NO! (most instances) • Churches • Nursing Homes • Banks • Hotels Nursing Homes Hotels Banks
  • 6. Fall Protection Plan • 1926.502(k) • See Appendix E in OSHA Subpart M • ANSI Z359.2 – Minimum Requirements for a Comprehensive Managed Fall Protection Program
  • 7. Fall Protection Program • Written Plan showing fall arrest is not feasible • Plan must be specific to the site it is used on • Can be used for repetitive use for a particular style/model house if ALL issues related to fall protection are addressed
  • 8. #2 1926.503(a)(1) • No fall protection training program • This is a program requirement to train workers in the hazards of falls. • Many use job safety analysis to determine potential hazards faced in construction.
  • 9. #3 1926.501(b)(1) • Open-sided floors over six feet without fall protection. • No guardrails on this commercial building. • Found quite a bit at elevator shafts, and stairwells also.
  • 10. #4 1926.1053(b)(1) • Ladder not extending over the edge 3 feet
  • 11. #5 1926.102(a)(1) • 1926.102(a)(1) – eye/face protection • Grinding, Chemicals, Sparks, and any other flying object hazard
  • 12. #6 1926.100(a) • No Hard Hats • When working around the bucket of a back hoe, hard hats should be worn.
  • 13. #7 1926.501(b)(10) • Fall protection not used on low sloped roofs • Guardrails and Fall arrest can be put on roofs. • 1926.501(b)(10) permits the use of warning lines and safety monitoring systems during the performance of roofing work on low-sloped roofs (least desirable option).
  • 14. #8 1926.451 (g)(1) • No guard rails on scaffolds. • Often ends are not protected. • The cross bracing may serve as ONE of the rails only if it meets certain height criteria.
  • 15. #9 1926.20(b)(2) • No inspection of worksite by a competent person • Workers are never to allowed to ride the forks of a rough terrain forklift.
  • 16. #10 1926.453(b)(2)(v) • No Fall Protection in aerial lifts. • Worker in photo is wearing a full body harness for fall arrest. • Nearly 400 aerial lift deaths since 2000. • Users need a PAL’s card or specific hands on user training.
  • 17. Develop Safety Rules • Follow Aerial Lift Manufacturer’s instructions. Use ANSI A92 standards on aerial lifts if you cannot get them. • Follow Warning Labels. • Only trained personnel can operate the lifts. • A trained person must inspect the machine before each shift. • And many more!
  • 18. Aerial Lift Training • Hands on training is necessary. An aerial lift is not a car. • The worker should be able to demonstrate all predicted uses of the lift and compliance with manufacturers instructions. • Always close lift platform chains or door. (This is always required). • Many fatal falls are under six feet.
  • 19. Aerial Lift Training • The worker must know where to attach the snaphook for any aerial lift that has an OSHA rated anchorage. • He is wearing a full body harness for fall arrest. • Guardrails are not meant to be used as anchorages on an aerial lift. • The manufacturer’s manual will designate the proper anchorage points.
  • 20. Aerial Lift Training • National Training guidelines • International Powered Access Federation (IPAF) www.ipaf.org • "Spot the Mistake" video • Promotes safe and effective of product • 15 training centers/companies in the US. • Successful trainees are awarded the PAL Card (Powered Access License) as proof of training
  • 21. Bubbling Under the Top Ten • 1926.652(a)(1) – cave-in protection • 1926.451(e)(1) – Unsafe scaffold access • 1926.501(b)(11) – No fall arrest on steep roofs • 1926.451(b)(1) – Scaffold needed stable footing • 1926.20(b)(1) – no accident prevention program
  • 22. Thanks • To Kenny for all his help. • My email is johnanewquist@gmail.com • www.buildsafe.org is a nonprofit where I teach many classes. • Follow me on Facebook where I post everyday on OSHA and safety.