Focused Inspections in Construction

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Occupational Safety & Health Administration
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Construction > Construction Outreach TOC > Focused Inspections in Construction

Construction Safety and Health
Outreach Program

U.S. Department of Labor
OSHA Office of Training and Education
May 1996

Focused Inspections in Construction

INTRODUCTION

The Focused Inspections Initiative that became effective October 1, 1994 is a significant departure from how OSHA has previously conducted construction inspections. This Initiative recognizes the efforts of responsible contractors who have implemented effective safety and health programs, and encourages 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 job site safety and health.

This document provides an overview of the basic guidance OSHA has provided to its compliance safety and health officers (CSHO's) for determining which projects are eligible for focused construction inspections and how those inspections are to be conducted.

BACKGROUND

Under previous agency policy, all construction inspections were comprehensive in scope, addressing all areas of the workplace and, by inference, all classes of hazards. This guidance may have caused CSHO's to spend too much time and effort on a few projects looking for all violations and, thus, too little time overall on many projects inspecting for hazards which are most likely to cause fatalities and serious injuries to workers. Presently, a contractor was likely to be cited for hazards that were unrelated to the four leading causes of death that make up 90% of all construction fatalities (falls from elevations - 33%; struck by - 22%; caught in/between - 18%; electrical shock - 17%). Although these other conditions are important, the time and resources spent to pursue them on a few projects can be better spent pursuing conditions on many projects related to the four hazard areas most likely to cause fatalities or serious injuries. The goal of OSHA's construction inspections is to make a difference in the safety and health of employees at the work site.

To accomplish this, the CSHO's time will be more effectively spent inspecting the most hazardous workplace conditions. The CSHO will conduct comprehensive, resource intensive inspections only on those projects where there is inadequate contractor commitment to safety and health. It is this group of employers that will receive OSHA's full attention.

GENERAL GUIDELINES

The Focused Inspection Initiative will enable OSHA to focus on the leading hazards that cause 90% of the injuries and deaths.

The leading hazards are:

falls from elevations (e.g., floors, platforms, roofs)
struck by (e.g., falling objects, vehicles)
caught in/between (e.g., cave-ins, unguarded machinery, equipment)
electrical shock (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:

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.

If the project meets the above criteria, an abbreviated walk-around inspection shall be conducted focusing on:

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 OSHA Instruction CPL 2.103, September 26, 1994, Field Inspection Reference Manual (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.

SPECIFIC GUIDELINES

The Focused Inspection Initiative policy applies only to construction safety inspections. Construction health inspections will continue to be conducted in accordance with current agency procedures.

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 warrant will not effect 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" included with this discussion 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.

REFERENCES

The following resources can provide assistance in developing and evaluating safety and health programs/plans:

"Safety and Health Program Management Guidelines" published January 26, 1989 in the Federal Register (54 FR 3904).

OSHA Instruction STD 3-1.1 "Clarification of Citation Policy Regarding 29 CFR 1926.20, 29 CFR 1926.21 and Related General Safety and Health Provisions."

American National Standards Institute ANSI A10.33, Safety and Health Program Requirements for Multi-Employer Projects.

American National Standards Institute ANSI A10.38, Basic Elements of an Employer Program to Provide a Safe and Healthful Work Environment.

Owner and Contractor Association Model Safety and Health Programs.

CONSTRUCTION FOCUSED INSPECTIONS INITIATIVE

Handout for contractors and employees

The goal of Focused Inspections is to reduce injuries, illness and fatalities by concentrating OSHA enforcement on those projects that do not have effective safety and health programs/plans and limiting OSHA's time spent on projects with effective programs/plans.

To qualify for a Focused Inspection, the project safety and health program/plan will be reviewed and a walkaround will be made of the jobsite to verify that the program/plan is being implemented.

During the walkaround, the compliance officer will focus on the four leading hazards that cause 90% of deaths and injuries in construction. 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.)

The compliance officer will interview employees to determine their knowledge of the safety and health program/plan, their awareness of potential jobsite hazards, their training in hazard recognition and their understanding of applicable OSHA standards.

If the project safety and health program/plan is found to be effectively implemented, the compliance officer will terminate the inspection.

If the project does not qualify for a Focused Inspection, the compliance officer will conduct a comprehensive inspection of the entire project.

If you have any questions or concerns related to the inspection or conditions on the project, you are encouraged to bring them to the immediate attention of the compliance officer or call the area office at _________________.

________________________________ qualified as a FOCUSED PROJECT.
Project/site

_______________	__________________________________
Date	AREA DIRECTOR

This document should be distributed at the site and given to the Contractor for posting.

CONSTRUCTION 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 Focused Inspection.

		YES/NO
PROJECT SAFETY AND HEALTH COORDINATION; are there procedures in place by the general 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 near misses.
_______	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 FOCUSED INSPECTION.

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