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 The 100 Most Frequently Cited OSHA Construction Standards in 1991: A Guide for the Abatement of the Top 25 Associated Physical Hazards
U.S. Department of Labor Occupational Safety and Health Administration March 1995 (Reprinted)  OSHA's 100 Most Frequently Cited Standards: The information contained in this document was correct at the time of publication in 1991. Several standards have changed since that time. The current standards may be viewed by selecting this hyperlink: http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1&p_part_number=1926 There have been technological advances in safety equipment, and some of the acceptable abatement methods indicated are no longer the safest means to protect the worker. The current standards (link to standards) and Interpretations (http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=0&p_keyvalue=) will assist you in determining the best examples to use for your training. Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission of the Federal Government. Source credit is requested but not required. The information contained in this publication is not considered a substitute for any provisions of the Occupational Safety and Health Act of 1970 or for any standards issued by OSHA. This report was written by Michael L. Marshall, Civil Engineer Charles Handesty, Construction Safety Specialist This information will be made available to sensory impaired individuals upon, request. Voice phone: (202)219-8644; TDD message referral phone: 1-800-326-2577 The 100 Most Frequently Cited OSHAConstruction Standards in1991: A Guidefor the Abatement of the Top 25Associated Physical Hazards U.S. Department of Labor Robert B. Reich, Secretary Occupational Safety and Health Administration Joseph A. Dear, Assistant Secretary Office of Construction and Engineering Bruce Swanson, Director March 1995 (Reprinted) For sale by the U.S. Government Printing Office Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328 ISBN 0-16-048011-6 TABLE OF CONTENTS
ACKNOWLEDGEMENT ABSTRACT SIMPLIFIED FLOW CHARTS OF CONTENTS OF REPORT 1.0 INTRODUCTION 2.0 THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS 3.0 100 MOST CITED PHYSICAL LIST 4.0 FORMAT AND USE OF GUIDE 4.1 USE OF GUIDE 4.2 FORMAT 5.0 GUIDE FOR THE ABATEMENT OF TH E TOP 25 MOST CITED PHYSICAL HAZARDS 5.1 THE TOP 25 GUIDE SHEETS 5.2 CONSTRUCTION SPECIFICATIONS FOR GUARDRAILS AND TOEBOARDS 5.3 REFERENCES INDEX LIST OF FIGURES AND TABLES
FIGURE 1-1 EMPLOYER'S SAFETY AND HEALTH PROGRAM TABLE 2-1 100 MOST CITED CONSTRUCTION STANDARDS IN AND THEIR RELATIVE RANKING TO 1991 TABLE 2-2 THE MOST CITED CONSTRUCTION STANDARDS IN 1991 BY PERCENTAGE OF TOTAL VIOLATIONS FIGURE 2-1 FREQUENCY OF PROGRAMMATIC VS. PHYSICAL VIOLATIONS: 100 MOST CITED VIOLATIONS IN 1991 FIGURE 2-2 DISTRIBUTION OF THE 100 MOSWT FREQUENTLY CITED STANDARDS BY SUBPART TABLE 3-1 LIST OF THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS RELATED TO PHYSICAL HAZRDS IN 1991 TABLE 3-2 GROUPING BY SUBMECT OF 100 MOST CITED PHYSICAL STANDARDS TABLE 3-3 COMBINED STANDARDS BY SUBJECT MATTER FROM THE LIST OF 100 PHYSICAL STANDARDS IN 1991 TABLE 5.2-1 MINIMUM SPECIFICATIONS FOR GUARDRAIL SYSTEMS TABLE 5.2-2 MINIMUM SPECIFICATIONS FOR TOEBOARDS ACKNOWLEDGEMENTS
Staff from the OSHA National Office provided assistance in preparing this report. The following directors and their staffs provided information, review and comments for the report: Roy Gurnham from the Office of Construction and Maritime Compliance Assistance; Gerald Reidy from the Office of Construction and Civil Engineering Safety Standards; and Joseph Pipkin from the Office of Electrical and Electronic Engineering Safety Standards. The Office of Information and Consumer Affairs, Jim Foster, Director, Jim Blackmon and Sue Fleming provided editorial review and production assistance. Charles Culver, Director and Fred Anderson, Deputy Director from the Office of Construction and Engineering (OCE) provided direction and input for the report. Eugene Simms, Cooperative Education Student (OCE) spent considerable amount of time and effort tabulating data and developing computer graphic charts and tables. Cathleen Cronin of the OSHA Training Institute provided direction and access to photographs, slides and documents which were used in this report. Manny Ypsilantes and Donovan Grentz provided information, photographs, review and comments for the report. The following OSHA field personnel provided information, review and comments for the report: William Burke, Assistant Area Director, Region VI - Dallas, TX Area Office; Robert Holmes, Area Director and Mike Partin, Assistant Area Director, Region VI - Baton Rouge, LA, Area Office; Mirth A. Deshler, Safety Specialist, Region VIII - Denver, CO, Area Office; Brian Hennessy and Bob Chadwick, Safety Specialists, Region IV- Tampa, FL, Area Office. The following individuals and organizations provided photographs for the report: Larry Falk, Area Director, OSHA, Tampa, FL, Area Office; Anthony Solano, Administrator, Construction and General Laborers, District Council of Chicago and Vicinity Training Facility, Carol Stream, IL; Carl Jones, Apprenticeship Director, Florida West Coast Carpenters (J.A.T.C.), Tampa, FL; Safeway Steel Products; and the Scaffolding, Shoring and Forming Institute. ABSTRACT
This report is intended to help employers and employees identify and correct hazards related to the most frequently cited OSHA standards found on construction sites throughout the United States. The report also is designed as a resource document for OSHA field personnel. The 100 most cited construction standards for 1991 are presented in the report. The standards cited were checked against similar citations for the years 1987 thru 1990. The relative rankings of the standards cited are similar, affected mostly as a result of the incorporation of new standards. The list was compiled from the OSHA Integrated Management Information System (IMIS). It includes citations by Federal OSHA in the 27 Federal Plan States for employers engaged in construction activities defined by Standard Industrial Classifications (SIC) 15, 16, 17. Citations issued by states operating OSHA approved state plans are not included. A listing of the 100 most cited construction standards related to physical conditions on job sites also is included. This second list does not include citations for so called"paperwork" requirements such as the hazard communications standard ([29 CFR] 1926.59) and safety training and education (1926.21) but does include citations for standards such as hard hats (1926.100), guards for open sided floors (1926.500), etc. The report also examines in detail the top 25 construction hazards relating to physical conditions. Information on the 25 standards includes, among other things: 1) citation and text of the standards; 2) intent and application of the standard; 3) hazards associated with the standard; 4) example case histories related to the standard; 5) suggested abatement of hazardous conditions related to the standard; and 6) additional source materials including interpretation, compliance directives, industry standards, etc., which may aid in the compliance with a given standard. Keywords: 100 Most Cited; OSHA Standards; Cited Standards; Physical Hazards; Hazard Abatement; Most Cited Construction Standards  1.0 INTRODUCTION Fatalities and injuries due to accidents continue to beseige the construction industry. In an effort to help employers, employees and OSHA compliance personnel (CSHO's) identify hazards that are causing accidents, OSHA has compiled listings in this report of the 100 Most Cited Standards in the construction industry. The purposes of the report are to: 1) identify the hazards causing accidents that are associated with the most frequently cited OSHA construction standards; 2) educate the employer, employee and CSHO on hazards found on construction sites and to offer suggestions for eliminating, controlling or mitigating the hazards; 3) notify employers of the types of violations on construction sites that OSHA personnel find most frequently; and 4) provide information in a format that would be readily useable for safety talks, tool box meetings, etc. The first part of this report contains two lists: The first list includes the 100 most frequently cited construction standards. The second list of 100 covers only those citations for standards related to physical conditions on a job site. This list does not include citations for so called "paperwork" requirements such as the hazard communications standard (Code of Federal Regulations - Title 29 [CFR 29], 1926.59)and safety training and education (1926.21) but does include citations for standards such as hard hats (1926.100), guards for open sided floors (1926.500), etc. The report refers to the first list as the 100 Most Cited List and the second list as the 100 Most Cited Physical List. The second part of this report (Chapters 4 and 5) focuses on the top 25 construction hazards from the 100 Most Cited Physical List and serves as a guide to the elimination, control and or mitigation of the physical hazards addressed by the standards cited. The most cited lists were compiled from the OSHA Integrated Management Information System (IMIS). The IMIS system contains, among other information, a record of all the citations that were issued for each inspection conducted. The lists were generated using 1991 calendar year data for citations issued to employers in the Standard Industrial Classification (SIC) 15, 16, and 17, for construction. Data also are presented for a five-year period that show that the most cited standards tend to be consistent over a period of years with the rankings altered mostly by the addition of new standards. The data used in this report were drawn from the 27 Federal plan states. Data for states operating OSHA approved state plans are not included. The 100 Most Cited List contains standards related to both physical and programmatic requirements. For this report a programmatic standard means a standard that could not be identified as the primary physical cause of an accident, but had the programmatic elements been in place and fully implemented might have precluded the hazardous condition(s) that led to the accident from ever existing. Programmatic standards are usually educational or information based such as Hazard Communication standards, recordkeeping requirements, OSHA poster, general safety/health training requirements, or written programs such as respirator, fire prevention plans, etc. Although this report emphasizes physical hazards and hazard abatement, it cannot be emphasized strongly enough, however, that a complete and effective safety and health program must contain all the programmatic elements as well as the elements which address physical hazards. The elements of a thorough and effective jobsite safety program are listed in FIGURE 1-1 (see page 4). If hazards addressed by the 100 Most Cited Lists do not exist on a particular site one should not conclude that there are no other hazardous conditions that might contribute to an accident. To the contrary, OSHA recognizes that a large percentage of accidents occur due to hazardous conditions that are not covered by specific standards. OSHA standards are only minimum requirements to run a safe and healthful construction site. Therefore, all parties involved with a site must continually identify all hazardous conditions, whether addressed by OSHA standards or not, to achieve a safe and healthful work site. The 100 Most Cited Physical List ranks the most frequently cited standards that constitute actual physical hazards. This list consists of 78 standards included in the 100 Most Cited List (22 standards from the 100 Most Cited List were programmatic) and 22 other identified physical hazards. Much of the emphasis in this report is placed on controlling physical hazards. A physical hazard is defined in this document as a hazard that can be eliminated, controlled and/or mitigated by: 1) using some type of hardware, i.e. guard rails to prevent falls, body belt/harness-lanyard-lifeline to mitigate the effects of a fall, flash arrestors in safety cans to prevent a fire/explosion, a fire extinguisher to control or mitigate the effects of an incipient stage fire; or 2) a specific inspection protocol designed to identify defects which can lead to accidents such as the monthly inspections of critical items of crawler, locomotive and truck cranes prescribed by 29 CFR 1926.550(b)(2). A physical hazard can directly cause an accident; conversely, a programmaticviolation would not have a direct physical linkage to the direct or primary cause of an accident. The GUIDEin the second part of the report provides detailed information for the first 25 standards on the 100 Most Cited Physical List. The GUIDE's format lends itself to safety meetings, tool box talks, etc. Chapter 4 (see page 27) describes the GUIDE,its format and use. The GUIDE itself can be found in Chapter 5 (see page 31). Twenty-five physical standards were chosen for the GUIDE because all other individual standards were cited less than 0.5 percent of the total number (approximately 62,000) of citations issued to construction contractors in 1991. Citations associated with the 25th Most Cited Physical Standard, for example, account for only one-half of one percent of all construction violations. FIGURE 1-1
EMPLOYER'S SAFETY AND HEALTH PROGRAM 1291
2.0 THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS The following section lists the construction standards most frequently cited in 1991. The information is presented in list form which will be referred to as the 100 Most Cited List. Table 2-1 (see page 7) list the 100 Most Cited Construction Standards in 1991. This table also ranks these standards relative to 1991 for the years 1987 thru 1990. The 100 Most Cited List gives a ranking from the first most frequently cited construction standard to the 100th most cited and provides the standard number, a brief description and its ranking for 1991 relative to the years 1987-1990. The 100 Most Cited list contains standards that are related to both physical and programmatic requirements. A programmatic requirement, for this list, means a standard that could not be identified as the primary physical cause of an accident. Programmatic elements supplement physical hazard standards and if they are fully implemented, may prevent hazardous condition(s) that lead to accidents. Programmatic standards are usually educational or information based and cover injury and illness recordkeeping requirements, Hazard Communication requirements, etc. No in-depth analysis was conducted to determine the reason(s) for any changes in a standard's rankings in the earlier years. However, the biggest factor for change appears to be the implementation of new standards. For example, the Hazard Communication Standard was not enforced in construction because of legal proceedings until March 1989. The immediate result was that three provisions of the Hazard Communication Standard were ranked #1, #2 & #3 in the 100 Most Cited List starting in 1989. This pattern is consistent for other implemented standards during this period. Generally, except for the new standards previously mentioned, the ranking of the individual standards did not significantly change during the five-year period. Another list related to the 100 Most Cited List is presented in Table 2-2 (see page 12), which lists the percentage of the total number of (approximately 62,000 violations) cited under each of these standards in 1991. A chart illustrates the number of PHYSICAL standards vs. the number of PROGRAMMATIC standards cited in the 100 Most Cited List, (see Figure 2-1, page 14). The relatively high number o programmatic violations (22%) might be an indicator of several things such as: 1) a higher degree of noncompliance with the programmatic requirements that are mostly performance oriented; 2) a larger emphasis by CSHO's on programmatic violations; or 3) a higher degree of compliance with specification standards that are mostly addressed by the physical standards. Consequently, the potential number of specification type violations might be fewer on jobsites. Another chart illustrates from which Subpart, i.e. Subpart N, O, X, etc. each of the standards from the 100 Most Cited List originates, (see Figure 2-2, page 15). This chart directs and assists those who know which Subparts of the standards are the most applicable to his/her operation. With the specific Subparts, the numbers listed for the Subparts of interest can be cross-referenced with the 100 Most Cited List to find the requirements that relate to the operation. TABLE 2-1
100 MOST CITED CONSTRUCTION STANDARDS AND THEIR RELATIVE RANKING TO 1991
(2) Trenching/Excavation Standard became effective on March 5, 1990. (3) Ladder/Stairway Standard became effective January, 1991. (4) Standard first included in Concrete/Masonry Standard- effective August 15, 1988. (5) Particular standard was not one of the 100 most frequently cited in the reference year. (6) Standard was part of old Ladder & Stairway Standards and was effectively discontinued January 1991. TABLE 2-2
THE MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS IN 1991 BY PERCENTAGE OF TOTAL VIOLATIONS
 
3.0 100 MOST CITED PHYSICAL LIST The next section presents the 100 Most Cited Physical List. A physical hazard can be the actual cause(s) of an accident. A physical hazard as defined by his report is: 1) one that can be abated (eliminated, controlled and/or mitigated) by using some type of hardware i.e., guard rails to prevent falls; or 2) following a specific inspection protocol designed to identify defects that can lead to accidents such as the monthly inspections of critical items of crawler, locomotive and truck cranes which are prescribed by 1926.550(b)(2). The 100 Most Cited Physical List presented in Table 3-1 (see page 18) ranks the most frequently cited physical standard from #1 to #100, describes the major activity related to the standard, profiles the standard and gives the standard number. Other lists help identify which of the 100 standards are related to major subjects and subdivisions of each i.e., major subject - ELECTRICAL; subdivisions - GROUND FAULT PROTECTION, CORD SPECIFICATIONS., etc., see Table 3-2 (page 22) & Table 3-3 (page 23). TABLE 3-1
LIST OF THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS RELATED TO PHYSICAL HAZARDS IN 1991
TABLE 3-2
GROUPING BY SUBJECT OF 100 MOST CITED PHYSICAL STANDARDS
(2) PERCENT Sum of individual standards per subject divided by 100 TABLE 3-3
COMBINED STANDARDS BY SUBJECT MATTER FROM THE LIST 100 PHYSICAL STANDARDS IN 1991
(1) Refers to the ranking number of individual standards listed in TABLE 3-1, i.e. "Electrical - #13 Ground Fault Circuit Interrupters". 4.0 FORMAT AND USE OF GUIDE The following chapter describes the GUIDE. The format discusses the headings for each particular GUIDE Sheet. 4.1 USE OF GUIDE The GUIDE consist of 25 user-friendly data sheets covering the first 25 standards from the 100 Most Cited Physical List. Each two page GUIDE is accompanied by photographs or illustrations depicting acceptable and unacceptable conditions related to the standard. Captions describe the photograph or illustration and identify an acceptable or unacceptable condition. The following key specifies an acceptable or unacceptable condition:  Note: The photographs and illustrations may identify other conditions than those addressed by the particular GUIDE. The caption, however, only mentions the situation germane to that GUIDE. These GUIDE are intended to be usable information or a training source for safety talks, tool box meetings, etc. Much of the information contained in the GUIDE SHEETS is taken from OSHA field personnel with many years of field experience. The GUIDE, therefore, gives the contractor some insight into the types of conditions the OSHA CSHO observes on the Job-site. Statistical dales presented in the individual GUIDE related to fatalities were taken from an OSHA report (see Section 5.3 REFERENCES - [10]) developed from OSHA accident investigation data. Data presented related to injuries came from an OSHA report (see Section 5.3 REFERENCES [6]) which was based on the Bureau of Labor Statistics - Supplementary Data System (SDS). 4.2 FORMAT This section identifies information and sources, where applicable, that are found in each the sub-headings in the individual GUIDE in Chapter 5. Heading 5.0 GUIDE FOR THE ABATEMENT CF THE TOP 25 MOST CITED PHYSICAL HAZARDS The GUIDE consists of the following: 1) Section 5.1 contains the top 25 most frequently cited physical standards or hazards from the 100 Physical List presented in TABLE 3-1 (see page 18), each GUIDE is presented as an individual information/data source for each standard; 2) Section 5.2 consists of two tables related to construction specifications for guardrails and toeboards that are common for eve of the individual GUIDE Sheets; and 3) Section 5.8 contains a list of additional sources of further OSHA and industry information. 5.1 THE TOP 25 GUIDE SHEETS The following section presents individual GUIDE Sheets to help employers, employees and OSHA personnel identify and abate the 25 most frequently cited physical hazards on construction sites.
INTENT: Falls from elevations are the leading cause of fatalities in the construction industry. From 1985-1989, 33% of all construction fatalities [10] resulted from a fall from an elevation. One hundred-seventeen fatalities occurred when employees fell from open sided doors and through floor openings. This standard specifies that guarding must be provided for all open-sided floors and platforms 6 feet or more in height. It also specifies minimum requirement for the type of guarding. Paragraph (f) of the same section species the requirement of a standard guardrail system. TABLE 5.2-1 lists guardrail specifications for various materials. Where there is an open-sided floor/platform and there is a potential for a person to pass or a hazard is presented by machinery, toeboards are required. The intent is to contain any materials near the edge from inadvertently getting pushed over the edge where they may strike persons or machinery below. TABLE 5.2-2 lists specifications for toeboards. HAZARDS:
An employee taking measurements was killed when he fell backwards from an unguarded balcony to the concrete 9'6" below. COMMENTS:
[1] Section 500 & Steel Erection - 750 & 752(k); [11]; [12]; [13]; [26] Part - 701(f)(2) - Concrete and Masonry Const. OSHA COMPLIANCE LETTER Date 5/22/84; From-Directorate of Field Operations to Regional Administrators; Synopsis - Clarification of 1926.750(b)(1)(iii) stating that ˝ " wire rope or equivalent safety railing must be used around temporary planked or temporary metal-decked doom during steel erection operation. Raging also must be provided at leading edge if spreading stops for any significant time period. ˝ " synthetic or fiber rope would not be acceptable as a required safety railing for steel erection operations. OSHA COMPLIANCE LETTER Date 1/13/81; From-Assistant Secretary to Int. Union of Bricklayers & Allied Craftsmen; Synopses - Standards 1926.28, 1926.104, 1926.105 & 1926.500(d)(1) do not apply to overhand bricklaying operations. OSHA COMPLIANCE LETTER Date 2/13/86; From-Directorate of Field Operations to Individual Company; Synopses - When structural steel assembly including decking has been completed and other trades are working on the deck while concrete is being poured on the deck, the door must be guarded in accordance with 1926.500(d)(1). PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS
INTENT Thousands of head injuries each year occur in the construction industry. This standard requires employees to wear "hard hats" to mitigate or lessen the effects of being struck by an object, accidentally striking their head against an objects or making contact with an energized electrical line. It needs to be emphasized that the standard is not just for employees that work at sites where there is a possibility of falling objects striking them in the bead, in workers on lower levels of a mufti-story budding project which are exposed to falling materials such as hand tool, bolts, nuts, etc. But it is also intended for employees who work in the vicinity of an operation that is found on a construction site. These type of energy releases are common to almost all construction operation and are not predictable. Almost all construction operations involve the potential of falling and flying objects, and, therefore, employees must wear head protection. Additionally many impact hazards exist. For instance, iron workers are constantly exposed to striking their heads on structural steel during erection, carpenters strike their heads on temporary framing lumber as they move through a building, etc. Employees that work in the vicinity of electrical conductors are exposed to potential shocks and burns to the head should they contact an uninsulated conductor. HAZARDS Struck by: injuries ranging from death to major concussion or trauma to minor abrasions; electrocution. (AMONG OTHER) SUGGESTED ABATEMENT(S):
1. OSHA [6] found that in a four year period from 1985 to 1988, 3.2% (11,685) of all construction lost time accidents in 10 states were related to head injuries. 2. All lost-time accidents involving head injuries do not result from being struck by falling and flying objects. OSHA [6] found that the head was the "Part of Body" injured in 9% (7125) of the "Struck By" (falling and flying object) type injuries. This compared to 5% (1440) for "Struck Against", (impact) type injuries; in other words, impacts are the cause of about 17% of all lost time head injuries. 3. This standard was cited in 142 fatality/catastrophe inspections by OSHA in a five year period. ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE [l] Section 100 (b)& (c); [7]*; [8]*; [9], [25]. *- Referenced in 29 CFR 1926- Construction Standards OSHA CLARIFIICATION LETTER Date 8/23/83 Synopsis The employer must determine which employees face possible head injuries and must wear appropriate head protection. OSHA has no exhaustive guidelines for determining when head protection must be worn. A case-by-case analysis must be performed by the employer. OSHA CLARIFICATION LETTER Date 7/22/92; From Directorate of Compliance to IBEW Business Manager Synopsis Wearing of hard hats with bill to the rear would not meet 1926.100(a) & (b) unless manufacturer certifies that this practice meets ANSI Z89.1-1969. ANSI test and certifies hard hats with bills facing forward. PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS
INTENT: Due to the dynamic, rugged nature of a typical construction site, electrical equipment, especially tools and extension cords are much more susceptible to deterioration due to "normal" use and sometimes abuse. When the deterioration occurs, sometimes insulation cracks or breaks exposing bare energized conductors, stress and strain may cause terminal screws to loosen resulting in one conductor short-circuiting another, etc The result can be that fault current is generated which may be directed through an employee's body to ground. Wet conditions often found at construction sites, greatly increase this hazard. This standard offers the employer two additional methods beyond the required equipment grounding conductor, to reduce and/or eliminate fault current which might be generated in any electrical system or tool during use. One means is to provide ground fault circuit interrupters (GFCI's) in all temporary receptacle outlets rated 120 volt single phase, 15&20 amps. This is essentially a hardware requirement. The GFCI continually monitors and compares the amount of current going to an electrical tool or piece of equipment against the amount of current returning along the "grounded neutral". If the differential in current (amount going to the tool vs. amount coming from tool) is more than 5 milliamps, the GF C1 is designed to trip in about 1/40 of a second. The other option is to establish and fully implement an Assured Equipment Grounding Conductor Program(AEGCP). This program relies on daily visual inspections and periodic (three months maximum for temporary cords and cords exposed to damage, six months for fixed cords not exposed) test inspections. Additionally, the AEGCP requires a written description, a competent person to implement the program and a record of the periodic tests. HAZARDS: Fatal electrocutions; Electrical burns ranging from critical to mirror; Fire; Explosion; Electric shock has been the initiator of other type hazards, i.e. electrical shocks have been the initiating cause of employees falling from elevated work surfaces, electrical shocks have caused employees to lose control of hand held equipment which in turn has struck and injured other employees in the immediate work area, etc. (AMONG OTHER) SUGGESTED ABATEMENTS:
A journeyman HVAC worker was installing metal duct work using a double insulated drill connected to a drop light cord. Power was supplied through two extension cords from a nearby residence. The individual's wet clothing/body contacted bare exposed conductors on one of the cords causing an electrocution. No GFCI's were used. Additionally, the ground prongs were missing from the 2 cords. COMMENTS: 1. Although it was suggested above to use double insulated tools, it does not relieve the employer from providing ground fault protection. Extension cords in use between a fixed electrical system (permanent outlet) and a tool can become worn with exposed energized conductors. Therefore, ground fault protection or an AEGCP would be required. See OSHA CLARIFICATION LETTER below. 2. According to OSHA[10] there were 48 fatalities in the years 1985 to 1989 related to 120 volt electrical systems. 3. Employers have attempted to skirt the requirements of providing ground fault protection by using 30 amp breakers in their 120 volt, single phase systems. This not only defeats the intent of the ground fault provisions it also introduces another set of hazards because the system is no longer rated fro the actual over current protection (30 amp breaker) that is in place. ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE: [1] Section 404(b); [3]; [4]; [5] 
INTENT: Many times on construction sites due to the frequency and severity of use, electrical equipment that is originally designed and provided an electrical path to ground is not capable of physically transferring "fault" current to ground became he positive physical path (a direct positive conn ection through the entire system usually terminating at a ground rod or cold water pipe) to ground, sometimes known as the "ground wire" or "equipment ground" is proved to transfer fault current to ground in the event that an exposed part of the piece of equipment were to be energized by the "hot" conductor or wire in the system, i.e. the case of an electric drill might be energized by fault current if the internal windings came in contact with the case or contact is made with an exposed conductor. The "equipment ground" would, in the case of the drilll, provide a favorable path of least resistance for the fault current to ground through the conductor. If the "equipment ground" was not continuous the path of least resistance from the drill might be through a persons body. HAZARDS: Electrical shock; Probable injuries range from death to minor burns; Fire; Explosion; Electric shock has been the initiator of other Type hazards, i.e. electrical shocks have been the initiating cause of employees falling from elevated work surfaces, WNW shocks have caused employees to lose control of hand held equipment which in turn has struck and injured other employees in the immediate work area, etc. (AMONG OTHER) SUGGESTED ABATEMENTS:
A fan connected to a 120-volt electrical system via an extension cord provided ventilation for an employee performing a chipping operation from an aluminum. stepladder. The insulation on the extension cord was cut through and exposed bare energized conductors which made contact with the ladder. The ground wire was not attached on the male end of the cord's plug. When the energized conductor made contact with the ladder, the path to ground included the employee's body resulting in death. COMMENTS 1. A large majority (estimated from many compliance staff sources) of the citations under this standard are issued because ground prongs are missing from cord and plug connected equipment or extension cords. 2. Sometimes ground prongs are intentionally removed from tools and extension cords because, "it makes them easier and quicker to plug into and remove." Statements such as these heard from employees clearly indicate that they do not understand the importance of the of the components of the equipment grounding system. 3. For five years, citations were issued to the contractor who employed the deceased employee in 93 fatality/catastrophe investigations that OSHA conducted, where the absence of a required equipment grounding conductor or lack of continuity of the conductor were listed as a factor. ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE [1] Section 404(f); [2] pg. 5; [3] pgs. 35-58; [4]; [5] Art. 250 
INTENT: Excavation accidents often result in serious injury or death. California reports a ratio of lost-time accidents to fatalities [14] for cave-ins aqua to 14:1. In contrast that same ratio for all types industry in California a 250:1. From 1985-1989 OSHA investigated 239 excavation fatalities [10]. This rule is basically a general rule and it's intent is to state that the employer will utilize some means of protection when employees are working in an excavation. This standard requires employers to protect employees from cave-ins. Later paragraphs, Paragraph (b) "Design of Sloping and Benching Systems" and Paragraph (c) "Design of Support System, Shield Systems and Other Protective Systems give specific alternatives and corresponding appendices to help the employer comply with the rule (NOTE: Appendices A - F provide valuable information for complying with the standard). The rule does not cover excavations in stable rock and excavations less the 5 feet deep - ONLY when the competent person evaluates the excavation and states there is no potential for cave-ins. HAZARDS: A cave-in is the greatest risk associated with excavation, Fatalities can be expected if a cave-in occurs. Other type hazards which are similar to confined space situations should be expected including asphyxiation due to lack of O2, inhalation of toxic materials, fire, drowning, etc. Moving machinery near the edge of the excavation can cause a surcharge (overloading) of the excavation wall that can cause collapse. Plus, the same machinery and vehicular traffic can strike employees. Many accidence occur when workers contact or sever underground utility lines. (AMONG OTHER) SUGGESTED ABATEMENTS:
1. Of all the excavation standards, this one is cited the most often because it is the appropriate standard to cite when no protection at all is provided. Unfortunately, many employers engaged in this activity, still provide no protection for their employees. 2. This standard is written in a unique manner -"Each employee ", which gives OSHA, the option to cite this particular standard for each exposed employee. 3. 'This standard was cited in 47 fatality/catastrophe inspections conducted by the Agency from March 1990 to January 1992. ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE: [141], [20] PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS
Guardrails made of lumber, not less than 2 x 4 inches(or other material providing equivalent protection), and approximately 42 inches high, with a midrail of 1 x 6 inch lumber (or other material providing equivalent protection), and toeboards, shall be installed at all open sides and ends on all scaffolds more than 10 feet above the ground or floor. Toeboards shall be a minimum of 4 inches in height. Wire mesh shall be installed in accordance with paragraph (a)(6) of this section. INTENT: OSHA investigated 214 fatalities from 1985-1989 [10] related to falls from scaffolds. The intent of this standard is to provide specifications far a fall prevention system, i.e. standard guardrails and toeboards, on tubular welded frame scaffolds. Because this is a specification standard it only applies to tubular welded frame type scaffolds. Note: This standard requires both standard guardrails and toeboards at a height of 10'. The general scaffold requirement 1926.451(a)(4) which requires guardrails between 41-10, when the minimum horizontal dimension of the scaffold is < 45', does not include tubular welded frame scaffolds, see OSHA CLARIFICATION LETTER below. Other guardrail materials which would provide equivalent protection are listed in TABLE 5.2-1. When persons must work or pass under a tubular welded scaffold, wire mesh construction is required. This includes a minimum No. 18 gauge US. Standard wire ˝-inch mesh or equivalent extending along entire opening from toeboard to top rail. If persons are not required to work or pass under the scaffold only a toeboard is necessary (see TABLE 5.2-2 for acceptable toeboard specifications). HAZARDS:
1. Many scaffolding guardrail violations are issued because no railings were provided on the ends of the scaffolds. Remember, a fall prevention system is not complete until the scaffolding is completely enclosed. Additionally, this is a specification standard, therefore, it is more easily identified and substantiated as a violation when the guarding is not provided. 2. Scaffold cross-bracing (X braces) are not acceptable alternatives for guardrails. 3. Many times scaffold guardrail are provided for tubular welded frame scaffolds where only one or two 10" planks are provided for a 60" wide scaffold end frame. This is ineffective because there is a potential for an opening 40"-50" between the edge of the "platform" and the guardrail (if in-place). Instead of falling over the edge of the scaffold, employees are exposed to falling through the scaffold. ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE: [1] Section 451(a) & (d), [17] OSHA DIRECTIVE #100-58 (STD 3-10.3) Date 10/30/78-Synopsis - Wire, chains, synthetic and fiber apes may be used as guardrails as per equivalent requirements of 1926.451 (a) (5) provided it meets the following guidelines: 1) it is secured to each support and taut at all times; 2) it a free of sharp edges; and 3) it has a maximum deflection of 3" in any direction when a 200 1b. load is applied. Note: No size requirements of the ropes are listed in directive. OSHA CLARIFICATION LETTER Date 3/11/83; From Acting Regional Administrator Region III to Area Director; Synopsis 1926.451(a)(4) General Scaffold Requirements, guarding in particular If a specific type scaffold is covered by a standard such as tubular welded frame guarding doesn't need to be provided as per 451(a)(4) from the 4' 10' level unless adjacent to dangerous equipment. NOTE: This position was reaffirmed in a letter dated August 7, 1992 from the Acting Assistant Secretary to an individual company. PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS
The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the need for using such equipment to reduce the hazards to the employees. INTENT: This rule gives the employer responsibility for insuring that employees wear appropriate PPE to reduce the exposure to hazardous conditions such as falling objects, toxic atmospheres, noise exposure, etc PPE is not only a right for the employee - it is a responsibility for the employer.This standard is part of Subpart C - General Safety and Health Provisions. Specific PPE and life saving equipment requirements are found in Subpart E, including: head protection; hearing protection; eye and face protection; respiratory protection; safety belts, lifelines, and lanyards; and safety nets. The Subpart E requirements are usually more specific than the Subpart C requirement. 1926.28(a), therefore, the standards in Subpart E are utilized more often than 1926.28(a). For example 1926.100(a) is #2 on the 100 Most Cited PhysicalLIST, conversely 1926.28(a) is #7. The Subpart E standards give specifications/guidance for selecting, use and maintenance of appropriate types and levels of PPE depending on the types of hazards employees are exposed. HAZARDS: Hazards can range from falling objects or bodies to inhalation of toxic materials. The injuries related to this standard also vary widely, inducting instant death from the inhalation of a highly toxic substance to a minor burn. (AMONG OTHER) SUGGESTED ABATEMENTS:
An employee was working with a crew setting a metal elbow duct for a bag house when he fell 50' to his death. The victim was wearing a safety belt with lanyard; however, the lanyard was not attached to any tie-off support. COMMENTS: | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
