1926 Subpart C
Construction Focused Inspections
AND HEALTH Inspections
Construction Focused Inspections Initiative
August 22, 1994 (Revision (2) 9/20/95)
Summary of the document "Guidance to Compliance Officers for Focused
CONSTRUCTION FOCUSED INSPECTIONS INITIATIVE
- General Guidelines
- The Focused Inspections Initiative that became effective October
1, 1994 is a significant departure from how OSHA has previously
conducted construction inspections. This Initiative will recognize
the efforts of responsible contractors who have implemented effective
safety and health programs/plans, and will encourage other contractors
to adopt similar programs. The number of inspections is no longer
driving the construction inspection program. The measure of success
of this new policy will be an overall improvement in construction
jobsite safety and health.
- The Focused Inspections Initiative will enable OSHA to focus on
the leading hazards that cause 90% of the injuries and deaths.
The leading hazards are:
- falls, (e.g., floors, platforms, roofs)
- struck by, (e.g., falling objects, vehicles)
- caught in/between (e.g., cave-ins, unguarded
- machinery, equipment)
- electrical (e.g., overhead power lines, power tools and cords, outlets, temporary wiring)
Under the Focused Inspection Initiative, CSHO's shall determine
whether or not there is project coordination by the general contractor,
prime contractor, or other such entity and conduct a brief review of
the project's safety and health program/plan to determine whether or
not the project qualifies for a Focused Inspection.
In order to qualify, the following conditions must be met:
If the project meets the above criteria, an abbreviated walk-around inspection shall be conducted focusing on:
- the project safety and health program/plan meets the requirements of 29 CFR 1926 Subpart C General Safety and Health Provisions, and
- there is a designated competent person responsible for and capable of implementing the program/plan.
- verification of the safety and health program/plan effectiveness by interviews and observation;
- the four leading hazards listed above, and
- other serious hazards observed by the CSHO.
The CSHO conducting a Focused Inspection is not required to inspect
the entire project. Only a representative portion of the project need
be inspected as stated in CPL 2.103, September 26, 1994, FIRM, chapter
II section A.1.b.
The CSHO shall make the determination as to whether a project's
safety and health program/plan is effective, but if conditions observed
on the project indicate otherwise, the CSHO shall immediately terminate
the Focused Inspection and conduct a comprehensive inspection. The
discovery of serious violations during a Focused Inspection need not
automatically convert the Focused Inspection into a comprehensive
inspection. These decisions will be based on the professional judgment
of the CSHO.
The Focused Inspection Initiative should be publicized to the maximum
extent possible so as to encourage contractors to establish effective
safety and health programs/plans and concentrate on the four leading
hazards prior to being inspected.
The Focused Inspection Initiative will be continuously evaluated
and modified based on experience.
- The Focused Inspections Initiative policy
applies only to construction safety inspections. Construction health
inspections will continue to be conducted in accordance with current
- A project determined not to be eligible
for a Focused Inspection shall be given a comprehensive inspection
with the necessary time and resources to identify and document violations.
- A comprehensive inspection shall be
conducted when there is no coordination by the general contractor,
prime contractor or other such entity to ensure that all employers
provide adequate protection for their employees.
- A request for a warrant will not affect
the determination as to whether a project will receive a Focused Inspection.
- On jobsites where unprogrammed inspections
(complaints, fatalities, etc.) are being conducted, the determination
as to whether to conduct a Focused Inspection shall be made only after
the complaint or fatality has first been addressed.
All contractors and employee representatives shall, at some time
during the inspection, be informed, why a focused or a comprehensive
inspection is being conducted. This may be accomplished either by
personal contact or posting the "Handout for contractors and employees"
(see attachments, per FIRM, Chapter II, section A. 3.)
- A brief justification will be included
in each case file as to why a Focused Inspection was or was not conducted.
The optional "Construction Focused Inspection Guideline" may be used
for this purpose.
- Although the walk-around inspection
shall focus on the four leading hazards, citations shall be issued
for any serious violations found during a Focused Inspection, and
for any other-than-serious violations that are not immediately abated.
Other-than-serious violations that are immediately abated shall not
normally be cited nor documented.
- Only contractors on projects that qualify
for a Focused Inspection will be eligible to receive a full "good
faith" adjustment of 25%.
- For Focused Inspections an OSHA-1 will
be completed in accordance with the multi-employer policy as stated
in the Field Inspection Reference Manual for the:
- general contractor, prime contractor or other such entity and
- each employer that is issued a citation.
FOCUSED INSPECTION GUIDELINE
This guideline is to assist the professional
judgment of the compliance officer
to determine if there is an effective project plan, to qualify for a
|PROJECT SAFETY AND HEALTH COORDINATION.
Are there procedures in place by the general contractor, prime contractor
or other such entity to ensure that all employers provide adequate
protection for their employees ?
|Is there a DESIGNATED COMPETENT
PERSON responsible for the implementation and monitoring of the project
safety and health plan who is capable of identifying existing and
predictable hazards and has authority to take prompt corrective measures?
|PROJECT SAFETY AND HEALTH PROGRAM/PLAN*
that complies with 1926 Subpart C and addresses, based upon the size
and complexity of the project, the following:
|_____ Project Safety Analysis
at initiation and at critical stages that describes the sequence,
procedures, and responsible individuals for safe construction.
_____ Identification of work/activities
requiring planning, design, inspection or supervision by an engineer,
competent person or other professional.
_____ Evaluation/monitoring of subcontractors
to determine conformance with the Project Plan. (The Project Plan
may include, or be utilized by subcontractors.)
_____ Supervisor and employee training
according to the Project Plan including recognition, reporting and
avoidance of hazards, and applicable standards.
_____ Procedures for controlling hazardous
operations such as: cranes, scaffolding, trenches, confined spaces,
hot work, explosives, hazardous materials, leading edges, etc.
_____ Documentation of: training, permits,
hazard reports, inspections, uncorrected hazards, incidents and
_____ Employee involvement in hazard:
analysis, prevention, avoidance, correction and reporting.
_____ Project emergency response plan.
* For examples, see owner and contractor
association model programs, ansi a10.33, a10.38, etc.
|The walkaround and
interviews confirmed that the Plan has been implemented, including:
_____ The four leading hazards are
addressed: falls, struck by, caught in\between, electrical.
_____ Hazards are identified and corrected
with preventative measures instituted in a timely manner.
_____ Employees and supervisors are
knowledgeable of the project safety and health plan, avoidance of
hazards, applicable standards, and their rights and responsibilities.
| THE PROJECT QUALIFIED FOR A