Last week Massachusetts contractors had the opportunity to meet an OSHA employee face to face. The Contractor Coaching Partnership Inc and Safety Trainers Inc brought Boston OSHA to local lumberyards.
On 11/18/2011 National Lumber hosted the OSHA Awareness Seminar in their Mansfield, Mass location. We had 30 plus contractors ask Tim Irving from OSHA many questions about enforcement, training, safety manuals, compliance, record keeping, fines, fall protection and more. I am going to do a few posts on these OSHA Awareness Seminars over the coming weeks to share the information from OSHA.
The contractors in the group were anonymous and asked numerous questions throughout the session. The tone was civil and the questions were very direct. In this post we will talk about Fall Protection, Safety Manuals and Enforcement Initiatives for Region 1 (New England).
1. Fall Protection; there were many questions on this topic due to the recent changes by OSHA. One contractor asked what am I required to do to comply with fall protection? Others asked do I really have to wear harnesses on low sloped roofs? What is the height requirement? Tim Irving explained that the old fall protection standard is rescinded and has been replaced with a the new one in June of 2011 effective as of 9/16/2011. He stated that the top cited violations are from fall protection, ladders, scaffolding and lack of fall protection training. He said contractors have a duty to provide fall protection training and equipment for their workers. He also said the general contractor must make sure their subs are compliant as well.
Mr Irving went on to explain that there are many injuries and deaths from falls. He showed us several examples where men were killed on the south shore and cape.
He explained one man died when he fell from 15 feet into bushes. Tim explained that the man hit the bushes head first and a branch from the bush went up his nostril and penetrated his brain killing him.
Another young man with 2 kids and one on the way was painting on the Cape and he fell 8 feet through a hole, broke his neck and died. His co-worker couldn't believe he died falling from just 8 feet!
Tim explained to contractors that they are required to comply with the new fall protection standards on residential jobs where workers work 6' above lower levels. He explained contractors must have a written fall protection plan and use fall arrest systems, guard rails and/or safety nets. Contractors are required by OSHA to train their workers on the fall protection standards and then document that they were trained. He showed several examples of inspections he conducted and enforced.
2. Safety Manuals; there were several questions about does a residential contractor have to have a safety manual? Does the manual have to be on site or in the truck or can it be at the office? What needs to be in the manual?
Tim explained that all contractors are required to have a safety program and manual. He said it should be on site for workers to reference. He also said one of the most frequent violations is the failure to have a safety training program backed up with documentation that you trained your workers on OSHA Standards. He cautioned contractors that they must be careful when using a template. The manual must be relevant to the hazards presented by the contractor's type of work and hazards. There are several standards that must be in the safety manual; fall protection written plan, hazardous communication written plan, for RRP work medical monitoring and respiratory written plans and more.
3. Enforcement Initiatives for Region 1; questions asked; How many enforcement officers are there in our area? Why is OSHA focusing on residential contractors? Why are the fines so big? What kind of cars do OSHA officers drive? How often do they make their rounds? What are they looking for when they come on site?
Tim said there are approximately 80 officers in New England. They make there rounds randomly and without warning. They often do sweeps of areas like the Cape and the Islands or the South Shore. They drive cars like the Ford Focus or other basic vehicles. The fines are generally $2,000 per violation with three fines on average per contractor. When the officer drives by a site he is looking for an obvious violation. If they see something they are instructed to stop and investigate. Tim said if there is nothing obviously wrong he cannot stop by. He said OSHA officers need a reason (probable cause) to come on the job. He said if it looks like you are following the rules he will keep on driving. If guys are up on a roof without fall protection he is instructed to go onto the job site.
OSHA Local Emphasis Programs; Tim said Region 1 OSHA officers have been instructed to focus on residential construction job sites. There are two local directives in Region 1; Fall Protection and Residential Construction. Essentially in Region 1 the residential construction industry is under a specific enforcement focus until the end of 2012. This is also known as a targeted industry. Due to the high injury and death rate in residential construction in New England OSHA will be focusing on residential contractors until the rates come down.
Next post we will look at what an OSHA officer does when he audits your site, your rights and what you can expect. We will cover the concept of effective training and your responsibility to your workers. In addition we will talk about the general contractors responsibilty to ensure that his subs are working within OSHA guidelines.
See the following links for OSHA Workshops for Residential Contractors
mark the coach
"one voice for the residential cosntruction industry"