Construction Safety and The Top 10 OSHA Citations for 2006

Written By: Ray Pirnat, CSA
Manager – Technical Services
Atlantic Environmental, Inc.
Dover, NJ

Construction safety, that is, injuries and illnesses at construction sites, have been getting increased attention from OSHA Inspectors. OSHA has already compiled a Top 10 List of Citations for 2006 and half of these are from Construction Regulation violations.. (Section 1926 of OSHA regulation)

The Construction Standards apply to all types of construction; roads, high rises, demolition, housing, reclamation, public works, and renovation

The Top 10 Citations – by specific standard include the following:
1. Scaffolding (29CFR1926-451) Construction
2. Hazard Communication (29CFR1910.1200) General Industry
3. Fall Protection (29CFR1926.501) Construction
4. Respiratory Protection (29CFR1910.134) General Industry
5. Lock Out/Tag Out (29CFR1910-147) GeneraSupersexy813l Industry
6. Powered Industrial Trucks (29CFR1910.178) General Industry
7. Electrical Wiring (29CFR1910.305) General Industry
8. Machine Guarding (29CFR1926-300) Construction
9. Ladders (29CFR1926.1053) Construction
10. Electrical (29CFR1926.402) Construction

The following is a more detailed listing of common citations in each of these OSHA standards:


1. Scaffolding (1926.451 )
• Not having the scaffold deck fully floored
• Not having the scaffold level or capable of supporting its designated load with the proper use of screw jacks, footings, etc.
• Not providing safe access for each scaffold
• Not providing proper fall, or falling object, protection — guardrails, midrails, toe boards, screens and debris netting
• Not having scaffold components approved by a competent person on the job site
• Not having the scaffold inspected daily
• Coble also said access should be provided by fixed ladders.

2. Hazard Communication (1910.1200 )
• A written hazard communication program had not been developed, implemented, or maintained (29 CFR 1910.1200(e)(1)).
• Material safety data sheets were not available for each hazardous chemical used (29 CFR 1910.1200(g)(1)).
• Containers of hazardous chemicals did not identity the contents (29 CFR1910.1200(f)(5)(i)).

3.Fall Protection (1926.501)
• 1926.501(b)(1) Fall protection at 6 feet above level
• 1926.503, Training requirements

4. Respiratory Protection (1910.134)
• 1910.134(c)(1) Failure to establish written respiratory program
• 1910.134(e)(1) Failure to provide medical evaluations to determine employee ability to use a respirator
• 1910.134(a)(2) Failure to provide respirators

5.Lockout/Tagout (1910.147)
• 1910.14(c)(1) Failure to have a written lockout tagout program that complies with the standard
• Exposure of employees to energized machines or equipment during service maintenance operations.
• 1910.134 (c )(7)Failure to train employees in lockout/tagout safety procedures
• 1910.134 (c)(4) Failure to develop procedures, document6ed and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section

1. Written procedures for controlling hazardous energy releases from each piece of equipment. They should describe preparation for shutdown, actual shutdown, and equipment isolation, steps for applying and removing lockout/tagout devices, requirements for testing that hazardous energy has indeed been isolated, and notification of employees.

2. Training for: "authorized" employees who do the maintenance and servicing work and must know how to safely isolate energy sources before beginning work; "affected" employees who might be working in the vicinity of a locked-out machine and must understand the hazards of attempting a start-up; and "other" employees who might be walking through part of a plant where a machine is locked out.

3. Periodic audits, at least once a year, of the overall program. This inspection must be done by an authorized employee who is not actively involved in the energy control procedures being inspected.

The standard does not cover normal production operations, such as routine adjustments, which are covered by OSHA's machine guarding standards. Also excluded are hot tap operations involving gas, steam, water or petroleum products where shutdown is impractical and other documented procedures guarantee worker safety. Furthermore, the standard does not apply to work on equipment powered through a cord and plug when it is unplugged and the authorized employee has complete control over the plug.

6. Powered Industrial Trucks (1910.178)
• 1910.178(i)(1) Failure to provide adequate training, the employer must ensure that the employee is competent to operate a powered industrial truck, as demonstrated by successful completion of a training program and evaluation.
• 1910.178(o)(1) Failure to use only stable or safely arranged loads.

7. Electrical Wiring (1910.305)
• Misuse of Equipment: OSHA 29 CFR 1910.303 (b)(2) requires all electrical equipment to be used or installed in accordance with any instructions included in the listing or labeling

• Guarding of Live Electrical Parts: Unguarded energized conductors pose a serious electrocution hazard. OSHA 1910.303 (g)(2)(i) requires all energized conductors > 50 volts within eight (8’) feet of the floor or working surface to be guarded against accidental contact.

• Reverse Polarity: This condition occurs whenever the hot and neutral electrical wires are reversed. OSHA 1910.304 (a)(2) prohibits reverse polarity. A receptacle tester may be utilized to verify that receptacles are wired correctly.

Proper Use of Flexible Cords and Cables: 29 CFR 1910.305(g) addresses flexible cords and cables. Flexible cords and cables may not be used:

• As a substitute for the fixed wiring of a structure
• Where run through holes in walls, ceilings or floors
• Where run through doorways, windows, or similar openings
• Where attached to building surfaces, or
• Where concealed behind building walls, ceilings, or floors

Ground Fault Protection: OSHA’s Construction Standards (29 CFR 1926) requires ground fault protection on construction sites. 29 CFR OSHA 1926.404 (b) requires ground fault circuit interrupters or an assured equipment grounding conductor program on all construction sites with temporary wiring that contain 120-volt, single-phase 15 and 20 ampere receptacles

8. Machine Guarding (1926.300)
• 1926.300 (2) Failure to provide adequate guarding in equipment that can cause injury due to belts, gears, shafts, pulleys, sprockets, spindles, drums, fly wheels, chains, or other reciprocating, rotating or moving parts of equipment.

9. Ladders (1926.1053)
• 1926.1053(b)(13) The top or top step of a step ladder shall not be used as a step.
• 1926.1053(b)(1) Not having adequate tie off of ladder that extends less than 3 feet above upper landing surface to which the ladder is used to gain access to.
• 1926.1053 (b)(22) Carrying an object up a ladder that could cause the employee to loose balance and fall.

10. Electrical (1926.402 )
• Improper installation of electrical equipment used to provide electric power and light at the jobsite.

We have 28 years of experience in construction safety including program development, site inspections, training, and regulatory interpretation. Our staff includes Certified Safety Professionals and Certified Industrial Hygienists and Field Inspectors. For more information or a specific quotation e-mail us at info@atlenv.com or call Bob Sheriff at 800-344-4414.

References: National Safety Council: Safety & Health Magazine December 2006
OSHA Website: www.OSHA.gov/pls/imis/citedstandard.html

Atlantic Environmental Inc
2 East Blackwell Street
Dover, NJ 07801
(800) 344-4414
(973) 366-4660
(973) 366-3116 Fax
info@atlenv.com