This document summarizes the 10 most frequently cited OSHA construction standards from fiscal year 2012. It provides details about each standard, including photographs showing violations. Standard #1 concerns fall protection on roofs. Standard #2 involves fall protection training. Standard #3 addresses guardrails for open-sided floors. The remaining standards cover issues such as ladders, eye/face protection, scaffolds, aerial lifts, inspections, and cave-in protection. The document also discusses OSHA requirements for residential construction, fall protection plans, aerial lift training programs, and additional standards that were frequently cited.
1. Most Frequently Cited OSHA
Construction Standards
Federal OSHA – FY 2012
John A Newquist
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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.
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.