Occupational Safety and Health Administration OSHA

1926 Subpart C

Construction Focused Inspections Initiative


Subpart C
Construction Focused Inspections Initiative

August 22, 1994 (Revision (2) 9/20/95)

Summary of the document "Guidance to Compliance Officers for Focused Inspections"


  1. General Guidelines
    1. The Focused Inspections Initiative that became effective October1, 1994 is a significant departure from how OSHA has previouslyconducted construction inspections. This Initiative will recognizethe efforts of responsible contractors who have implemented effectivesafety and health programs/plans, and will encourage other contractorsto adopt similar programs. The number of inspections is no longerdriving the construction inspection program. The measure of successof this new policy will be an overall improvement in constructionjobsite safety and health.
    2. The Focused Inspections Initiative will enable OSHA to focus onthe 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)
    3. Under the Focused Inspection Initiative, CSHO's shall determinewhether or not there is project coordination by the general contractor,prime contractor, or other such entity and conduct a brief review ofthe project's safety and health program/plan to determine whether ornot the project qualifies for a Focused Inspection. In order to qualify, the following conditions must be met:
      1. the project safety and health program/plan meets the requirements of 29 CFR 1926 Subpart C General Safety and Health Provisions, and
      2. there is a designated competent person responsible for and capable of implementing the program/plan.
    4. If the project meets the above criteria, an abbreviated walk-around inspection shall be conducted focusing on:
      1. verification of the safety and health program/plan effectiveness by interviews and observation;
      2. the four leading hazards listed above, and
      3. other serious hazards observed by the CSHO.

    5. The CSHO conducting a Focused Inspection is not required to inspectthe entire project. Only a representative portion of the project needbe inspected as stated in CPL 2.103, September 26, 1994, FIRM, chapterII section A.1.b.
    6. The CSHO shall make the determination as to whether a project'ssafety and health program/plan is effective, but if conditions observedon the project indicate otherwise, the CSHO shall immediately terminatethe Focused Inspection and conduct a comprehensive inspection. Thediscovery of serious violations during a Focused Inspection need notautomatically convert the Focused Inspection into a comprehensiveinspection. These decisions will be based on the professional judgmentof the CSHO.
    7. The Focused Inspection Initiative should be publicized to the maximumextent possible so as to encourage contractors to establish effectivesafety and health programs/plans and concentrate on the four leadinghazards prior to being inspected.
    8. The Focused Inspection Initiative will be continuously evaluatedand modified based on experience.
  2. Specific Guidelines
    1. The Focused Inspections Initiative policyapplies only to construction safety inspections. Construction healthinspections will continue to be conducted in accordance with currentagency procedures.
    2. A project determined not to be eligiblefor a Focused Inspection shall be given a comprehensive inspectionwith the necessary time and resources to identify and document violations.
    3. A comprehensive inspection shall beconducted when there is no coordination by the general contractor,prime contractor or other such entity to ensure that all employersprovide adequate protection for their employees.
    4. A request for a warrant will not affectthe determination as to whether a project will receive a Focused Inspection.
    5. On jobsites where unprogrammed inspections(complaints, fatalities, etc.) are being conducted, the determinationas to whether to conduct a Focused Inspection shall be made only afterthe 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.)
    6. A brief justification will be includedin each case file as to why a Focused Inspection was or was not conducted.The optional "Construction Focused Inspection Guideline" may be usedfor this purpose.
    7. Although the walk-around inspectionshall focus on the four leading hazards, citations shall be issuedfor any serious violations found during a Focused Inspection, andfor any other-than-serious violations that are not immediately abated.Other-than-serious violations that are immediately abated shall notnormally be cited nor documented.
    8. Only contractors on projects that qualifyfor a Focused Inspection will be eligible to receive a full "goodfaith" adjustment of 25%.
    9. For Focused Inspections an OSHA-1 willbe completed in accordance with the multi-employer policy as statedin the Field Inspection Reference Manual for the:
      1. general contractor, prime contractor or other such entity and
      2. each employer that is issued a citation.


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.

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 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.

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