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.
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OSHA Most Cited Construction Standards FY12
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.