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Session No. 503

Standards for Safety in Construction and Demolition OperationsA10 Series: Engaging the Process

Jerry E. Rivera, MEngPower Design Inc.St. Petersburg, FL

Thomas Trauger, MBA, MSIH, ARM, CRISWinchester Homes

Bethesda MD

Introduction

In 2011 the American Society of Safety Engineers (ASSE) celebrated 100 years of service to the

environmental, health and safety profession. Certainly, many aspect of the EHS practice has evolveddemanding that practitioners quickly adapt to professional needs. Today’s EHS practitioners face increase

pressure of demonstrating higher levels of competence at all levels of the professional practice. Theknowledge fundamentals demand skill levels in business continuity, hazard analysis techniques, riskmanagement, law and industry standards.

According to data provided in NIST Special Publication 806, Standards Activities ofOrganizations in the United States (1996 Edition; edited by Robert B. Toth), there are more than 93,000standards produced and nearly 700 organizations that cited standards development as an area of activity.Of these, the federal government is the largest single creator and user of standards (more than 44,000 of

them); the private sector in America collectively has about 49,000 standards.1

Many of the standards in circulation today claim to address safety in one form or another.Whether it’s in the area of product safety or workplace safety it can easily become a discouraging task forEHS practitioners to adopt consensus standards in the workplace. More alarming is that while there are

about 49,000 private sector standards throughout the US today, few EHS practitioners are part of thestandard development process. EHS practitioners are expected to know how to interpret, implement and

comply with applicable standards that impact their industry. The lack of participation of EHS practitioners in the standard development process puts the practice and constituents represented at a

serious disadvantage.This paper will explore how practitioner in the construction industry can engage the standarddevelopment process with the purpose of crafting out the future of the EHS practice. The paper will focus

on the ANSI/ASSE 10 Standards with an overview of the ANSI process.

1 American National Standards Institute (ANSI) 1996. Domestic Programs (American National Standards) Overview

(retrieved February 17, 2014)

(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3).


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About ANSI

From the very first American National Standard (ANS) on pipe threads, to work that is underway today tomeet emerging needs and priorities, ANSI-approved standards have provide tremendous benefit to societyand the global economy. Their work spans a broad spectrum of industries: from nanotechnology and

energy efficiency to telecommunications and the rapidly expanding service sector, the reach and influenceof the standards community is pervasive. Participation by a standards developer in the ANS process

signifies a commitment to the creation of high-quality, market-driven standards in an open environmentcharacterized by due process and ANSI’s neutral third party oversight. ANS set benchmarks for qualityand performance that help to protect the public interest and foster commerce by influencing the design,

manufacture, marketing, distribution, and safe use of products and processes worldwide.2

ANSI Process

(ANS) is a document that has been sponsored by an ANSI-Accredited Standards Developer, achievedconsensus, met ANSI’s Essential Requirements, and been approved by the Institute.

The hallmarks of this process ensure that American National Standards are developed in a manner that is

equitable, accessible, and responsive:

3

1. Participation is open to all interested stakeholders2. Balance of interests shall be sought3. Consensus must be reached by representatives from materially affected and interested parties in an

environment that is free from dominance by any party4. Standards are required to undergo public reviews during which any member of the public may

comment5. Comments from the consensus body and public review period must be responded to in writing6. All unresolved objections, attempts at resolution, and substantive changes to text are provided to the

ANS consensus body for review prior to final vote7. An appeals process through the standards developer to address procedural concerns is required

Periodic maintenance is defined as the maintenance of a standard by review of the entire

document and action to revise or reaffirm it on a schedule not to exceed five years from the date of itsapproval as an American National Standard. The standards developer may request an extension of time toreaffirm or revise the standard.

No extension of time beyond ten years from the date of approval is granted for action on a

standard. In no case shall a standard maintained.

2 American National Standards Institute (ANSI) 2012. Value of the ANS designation (retrieved February 17, 2014)

(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3)3 American National Standards Institute (ANSI) 2012. Value of the ANS designation (retrieved February 17, 2014)

(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3)


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Figure 1. A10 Members voting on a proposed issue.

Once a standard is developed by the subcommittee it is put to a vote to the committee membership. Thisis done by email. Prior to the vote the members have the opportunity to comment on the standard. A

comment tracking matrix with all comments is then circulated to all members for review. Thesubcommittee reviews the comments and may incorporate the recommended changes. In many instancesthey may not be incorporated. The disposition of the comment is tracked on the matrix. In many instancesthere are comments that may take longer to resolve. The head of the subcommittee makes the finaldecision in consultation with the subcommittee members on rejecting and including comments. Once thisdecision is made if a member of the committee is not satisfied with the decision he/she can follow the

appeals process.

Assuming all comments are resolved the final draft standard is put to a vote and each member ofthe committee completes a ballot, voting yes, no or abstain. This ballot is submitted to the secretary.

A10 CommitteeThe A10 Committee writes and interprets voluntary national consensus standards regarding workplacehazards that provide guidance as well as technical information to Environmental, Health and Safety

Professionals.4

The A10 Committee is responsible for:

4 American Society of Safety Engineers (ASSE) 2009. Procedures A10 ASC


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1. Developing proposed American National Standards within the scope of the committee2. Voting on approval of proposed American National Standards within its scope3. Maintaining the standards developed by the Committee4. Review each standard within its scope at least every five years and determine the appropriate

recommendations for (a) reaffirmation, (b) revision, or (c) withdrawal

5. Adopting Committee policy and procedures for interpretations of the standard(s) developed bythe Committee

6. Coordinating and responding to requests for interpretations of the standard(s) developed by theCommittee

7. Adopting committee procedures and revisions thereof8. Considering and acting on proposals for termination of the Committee9. Other matters requiring Committee action as provided in these procedures

The Secretariat of the American Society of Safety Engineers (ASSE) shall:

1. Organize the Committee (see Section 2)2. Apply for committee accreditation by ANSI and maintain accreditation in accordance with ANSI

requirements, including submission of the Committee Roster3. Oversee the Committee's compliance with these procedures4. Maintain a roster of the Committee and a list of standards for which the Committee is responsible5. Provide a Committee secretary to perform administrative work, including secretarial services;

meeting notices and arrangements; preparation and distribution of meeting agendas, minutes, ballots and draft standards; and maintenance of adequate records

6. Submit candidate standards approved by the Committee, with supporting documentation, forANSI review and approval as American National Standards

7. Publish or arrange with ANSI for publication of its standards, revisions and addenda8. Perform other administrative functions as required by these procedures

The committee consists of a chairman and a vice-chairman appointed by the secretariat from the

individual members or representatives of the Committees, subject to approval by majority vote of theCommittee. Each will serve until a successor is selected and ready to serve. The vice-chairman shallcarry out the chairman duties if the chairman is temporarily unable to do so. The secretary is appointed bythe secretariat.

The chairman and vice-chairman serve a three-year term, beginning with the election at the first

meeting of the Committee in the calendar year.


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Figure 2. A member of the committee conducting a presentation.

MembershipMembers of the Committee consist of organizations (preferably national in scope), companies,

government agencies, individuals, users, etc., having an interest in the activities of the Committee.The addition or termination of members is subject to approval by vote of the Committee after

the application has been processed in accordance with Committee Procedures or the membershipreviewed. There shall not be any more than seventy-five voting members on the committee

Application

A request for membership is addressed to the secretariat, indicating the applicant's interest in theCommittee's work and qualifications and willingness to participate actively, and, if the applicant is an

organization, company or government agency, identify itself as (a) a representative, (b) an alternate(s), ifdesired, and (c) an information contact at the organization headquarters.

In recommending appropriate action to the Committee on applications for membership, the

Secretariat considers the:

1. Need for active participation by each interest2. Potential for dominance by a single interest category3. Extent of interest expressed by the applicant and the applicant's willingness to participate actively4. The representative identified by the applicant organization, company, or government agency.


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Membership RequirementsContinuing membership on the Committee is based on active participation in Committee activities. AllCommittee members are required to complete the following three participation requirements forcontinued A10 Committee membership.

1. accept appointment to at least one ASC A10 Committee Subgroup

2. respond to at least 75% of letter ballots3. attend at least one of the two annual ASC A10 Committee meetings

Subgroups Created by the Committee

When the secretariat, the chairman, or the Committee determines a need to create one or morestanding subgroups (subcommittees, technical subcommittees) to expedite the work of theCommittee, their formation (and later disbandment) requires approval by a majority vote of the

Committee, and appropriate public notice. The scope and duties delegated to the subgroups are approvedat the time it is formed, and subsequent changes in scope or duties also require approval. The charge to

the subgroups clearly state whether:

1. The subgroup is responsible for the definitive content of one or more standards and for

responding to views and objections thereon. Such subgroups need to meet the requirementsestablished for committees as applied to voting on the standard(s), or

2. The subgroup is responsible for assisting the Committee (e.g., drafting all or a portion of astandard, drafting responses to comments, drafting positions on international standards, or other

advisory functions).

The secretariat, at times, may determine a need to establish a subgroup or steering committee on

an ad hoc basis to assist the Committee or a subcommittee. Its formation (and disbandment) is at thediscretion of the secretariat.

Subcommittees for standards that are being updated or are new typically hold meetings the day before the A10 committee meeting. There are several organizations in the Washington D.C. area that have

facilities where subcommittee meetings can be conducted. The meetings are typically conducted in theafternoon. Sub committees may have meetings during the year at other locations or conduct conferencecalls. You do not need to be a member of the A10 Committee to lead a subcommittee. Any safety

professional with expert knowledge in the standard being developed can volunteer to head thesubcommittee. However, they may not vote on it.


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Figure 3. Members of the A10.49 Health Hazards Subcommittee reviewing the proposedstandard.

Open Meetings

Meetings of the Committee shall be open to all members and others having an interest. When possible, at least four weeks' notice of regularly scheduled meetings shall be given by the secretariat in

ANSI's "Standards Action;" or in other media designed to reach affected interests; or in both. The noticeshall describe the purpose of the meeting and shall identify a readily available source for further

information. An agenda and schedule is distributed in advance of the meeting to members and to othersexpressing interest.

Meetings are held twice a year in January and July. For the past several years they have beenconducted at the International Brotherhood of Electrical Workers in Washington D.C. A large conferenceroom is used and has been provided by the IBEW which is on the committee. There are several otherorganizations that are part of the committee that have facilities in the Washington DC area that can holdthe meetings. In the past one meeting was conducted at the National Association of Homebuilders.

Meetings start at 12:30 pm and end at 4 pm. However meetings may continue longer depending on issues being discussed.

Public Review

Proposals for new American National Standards or reaffirmation, revision or withdrawal of existingAmerican National Standards shall be transmitted to ANSI for listing in "Standards Action" for comment.


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Views and objections resulting from the above are dealt with in accordance with Committeeguidelines. Any substantive change made in the proposed American National Standard is typically listed

for a limited public review of the changes.

Prompt consideration is given to the timely written views and objections of all participants,including those commenting on either the PINS announcement or public comment listing in

Standards Action. Comments generated from PINS notification need to be addressed in accordance withANSI Essential Requirements.

Appeals

Directly and materially affected interests who believe they have been or will be adversely affected by astandard within the Committee's jurisdiction, or by the lack thereof, have the right to appeal substantive or

procedural actions or inactions of the Committee or the secretariat.

ANSI/ASSE A10 Standards

The ANSI Accredited A10 Committee (ASC) is one of the longest existing voluntary national consensusstandards committee in the United States. Founded originally in 1944, the A10 ASC writes and interpretsvoluntary national consensus standards relating to the protection of employees and the public fromhazards arising out of, or associated with, construction and demolition operations.5

SH&E professionals working in the construction industry have significant interest in these

standards due to the fact that they are recognized in both the public and private sectors. Specifically, theA10 Standards have extensive recognition in the standards of the U.S. Department of Labor OccupationalSafety and Health Administration and by a series of other national and state government agencies. At the

private sector level A10 Standards are widely cited and required in different contracts and work

agreements

The full A10 ASC is made-up of seventy-four national organizations from the private and publicsector. In addition, there are forty-eight (48) accredited standards and projects under the A10 banner. Asubgroup is created and approved by the committee, which is responsible for putting together draft

documents for review by the A10 ASC. The subgroups are not responsible for the definitive content of thestandard and instead serve to assist the committee in putting the documents together and serving as atechnical resource.

A10.1-200X (Planning For Construction and Demolition Operations).

A10.2-20XX (Safety, Health and Environmental Training).A10.3-1995 (Powder Actuated Fastening Systems Schofield).A10.4-2004 (Personnel Hoists).

A10.5-2005 (Material Hoists).A10.6-1989 (R1998) (Demolition Operations).

A10.7-1998 (R2005) (Blasting).A10.8-2001 (Scaffolding).A10.9-2004 (Concrete & Masonry Construction).A10.10-2004 (Space Heating Devices).A10.11-1989 (R1998) (Safety Nets).

A10.12-1998 (R2005) (Excavation).

5 American Society of Safety Engineers (ASSE) 2008. A10 Information Sheet


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A10.13-2001 (Steel Erection).A10.14-Withdrawn (Fall Protection Systems for Construction and Demolitions).

A10.15-1995 (R2005) (Marine Dredging).A10.16-1995 (R2001) (Tunnels, Shafts and Caissons).

A10.17-2006 (Asphalt/Pavement Construction).A10.18-2006 (Temporary Floor and Wall Openings, Railings, and Toeboards).

A10.19-200X (Pile Installation & Extraction Operations).A10.20-2005 (Ceramic tile, Terrazzo and Marble Work).A10.21-200X (Control of Health Hazards in Construction)

A10.22-1990 (R1998) (Rope Guided and Nonguided Hoists).A10.23-200X (Reserved for future use)A10.24-2006 (Roofing).A10.25-200X (Sanitation in Construction).A10.26-200X (Emergency Medical and Rescue Procedures for Construction Sites).

A10.27-1998 (R2005) (Asphalt Mixing Plants).A10.28-1998 (Crane or Derrick Suspended Work-Platform Platforms).

A10.29-200X (Safe Use of Aerial Lifts in Construction).A10.30-200X (Construction Workplace Security).

A10.31-1995 (Digger-Derricks.A10.32 (Fall Protection System for Construction Industry Users).A10.33-1998 (R2004) (Safety and Health Program).A10.34-2001 (R2005) (Public Protection).A10.35-200X (High Pressure Hydro Blasting).A10.36-200X (Railroad Safety).

A10.37-1996 (Debris Nets).A10.38-2000 (Safety Program Elements).

A10.39-1996 (R2005) (Safety Audits).A10.40-2007 (Ergonomics in Construction).A10.41-200X (Equipment Operator/ Supervisor Qualifications and Responsibilities).A10.42-2000 (Rigging Supervisor, Signalmen Qualifications and Responsibilities).

A10.43-200X (Confined Spaces in Construction).A10.44-2006 (Lock/Out Tag/Out)A10.45-200X (Reserved for future use)A10.46-2007 (Hearing Loss Prevention).A10.47-200X (Highway Construction Safety).A10.48-200X (Tower Erection).

Regulatory Impact on EHS Profession

OMB CIRCULAR A-119, First Published in 1980This Circular establishes policies to improve the internal management of the Executive Branch.Consistent with Section 12(d) of P.L. 104-113, the "National Technology Transfer and Advancement Act

of 1995" (hereinafter "the Act"), this Circular directs agencies to use voluntary consensus standards inlieu of government-unique standards except where inconsistent with law or otherwise impractical. It also

provides guidance for agencies participating in voluntary consensus standards bodies and describes

procedures for satisfying the reporting requirements in the Act. The policies in this Circular are intendedto reduce to a minimum the reliance by agencies on government-unique standards.

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6 Silcox, Clark “Incorporation by Reference: “Inclusion of Consensus by Public Law and Coping with a Moving

Target” November 18, 2011.


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For purposes of this policy, "voluntary consensus standards" are standards developed or adopted

by voluntary consensus standards bodies, both domestic and international. These standards include provisions requiring that owners of relevant intellectual property have

agreed to make that intellectual property available on a nondiscriminatory, royalty-free or reasonableroyalty basis to all interested parties. For purposes of this Circular, "technical standards that are developed

or adopted by voluntary consensus standard bodies" is anequivalent term.

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"Voluntary consensus standards bodies" are domestic or international organizations which plan,develop, establish, or coordinate voluntary consensus standards using agreed upon procedures. For the

purpose of this Circular, "voluntary, private sector, consensus standards bodies," as cited in Act, is an

equivalent term. The Act and the Circular encourage the participation of federal representatives in these bodies to increase the likelihood that the standards they develop will meet both public and private sector

needs. A voluntary consensus standards body is defined by the following attributes:

1. Openness2. Balance of interest

3. Due process4. An appeal process

Consensus, which is defined as general agreement, but not necessarily unanimity, andincludes a process for attempting to resolve objections by interested parties, as long as allcomments have been fairly considered, each objector is advised of the disposition of his orher objection(s) and the reasons why, and the consensus body members are given anopportunity to change their votes after reviewing the comments.8

National level draws most attention because of OSHA’s Impact on EHS ProfessionalsLaws / Guidelines require agency to review voluntary consensus standards during proposed rulemaking.

If not, the agency is expected to work with the private sector to develop the needed standard.

Legal Implication and the EHS Profession

In tort litigation actions arising from workplace accidents, the presence or absence of a recognized andsubstantive safety and health management program can be critical in controlling financial liability. Thus,the extent to which OSHA and MSHA reference Z10 in future publications or rulemaking activities willincrease its jud icial recognition and create a guideline against which employer programs will be

benchmarked.9

OSHA Reform

ASSE encourages support of OSHA reforms that foster the use of consensus standards inenforcement when a standard does not exist, is inadequate, or is obsolete/dated. For safety

7 Silcox, Clark “Incorporation by Reference: “Inclusion of Consensus by Public Law and Coping with a Moving

Target,” November 18, 2011.8 Silcox, Clark “Incorporation by Reference: “Inclusion of Consensus by Public Law and Coping with a Moving

Target,” November 18, 2011.9 Abrams, Adele L., “Legal Perspective: ANSI Z10 2005 Standard Occupational Health and Safety Management

Systems. July 2005


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professionals/practitioners to realize greater opportunities to apply their professional skill and judgment, consensus standards must, in some sense, be authoritative. Without such authority,

safety and health professionals may not have sufficient influence and resources to properly dotheir jobs. For consensus standards to be authoritative, OSHA must be able to routinely rely on

provisions of consensus standards in enforcement.10

Conclusion

In the previous pages we briefly reviewed the importance of the development of ANSI standards for theconstruction industry. A review of the A10 committee and the process it follows to develop and approve

consensus standards. Safety and health practitioners need to be part of the process and should learn theskills needed for standard development. Through the development of consensus standards, the practice ofsafety will experience continuous improvement and address issues that the regulations do not. While it isimportant for government, labor and private sector organizations to be involved, it is a duty of safety andhealth practitioners to get engaged in the process and help define the future of the safety and health

practice.

The ANSI/A10 Committee needs involvement from safety professional at all levels.

While organizations currently hold seats at the committee there are multiple ways that safety practitionerscan get involved without having to be part of the Committee. This can be done through the submittal of

comments or the active participation in a subgroup.The safety practitioners should interpret this paper as a call to action. Engage the process!

Bibliography

Abrams, Adele L. “Legal Perspective: ANSI Z10 2005 Standard Occupational Health and SafetyManagement Systems.” The Compass 3-5. July 2005.

American National Standards Institute (ANSI). 1997. Media Tips and Case Studies Standards Overview: Avoiding Surprises - Some Thoughts on Standard. (retrieved on February 28, 2014)(http://www.ansi.org/news_publications/media_tips/standards_overview_cont.aspx?menuid=7 )

American National Standards Institute (ANSI), 2012. Value of the ANS designation (retrieved February17, 2014)(http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3)

American Society of Safety Engineers (ASSE). 2003. Position Statement on the Role of Consensus

Standards and Governmental Regulations in Occupational Safety and Health (retrieved onFebruary 28, 2014).(http://www.asse.org/publications/standards/docs/PositionStatementonConsensusStandards.pdf)

Federal Register. 2012. Federal Participation in the Development and Use of Voluntary Consensus

Standards and in Conformity Assessment Activities (retrieved on February 28, 2014) (https://www.federalregister.gov/articles/2012/03/30/2012-7602/federal-participation-in-the-development-and-use-of-voluntary-consensus-standards-and-in-conformity)

10 American Society of Safety Engineers (ASSE). 2003 Position Statement on the Role of Consensus Standards and

Government Regulations in Occupational Safety and HealthDes Plains, IL American Society of Safety Engineers.

http://www.ansi.org/news_publications/media_tips/standards_overview_cont.aspx?menuid=7http://www.ansi.org/news_publications/media_tips/standards_overview_cont.aspx?menuid=7http://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3http://www.asse.org/publications/standards/docs/PositionStatementonConsensusStandards.pdfhttps://www.federalregister.gov/articles/2012/03/30/2012-7602/federal-participation-in-the-development-and-use-of-voluntary-consensus-standards-and-in-conformityhttps://www.federalregister.gov/articles/2012/03/30/2012-7602/federal-participation-in-the-development-and-use-of-voluntary-consensus-standards-and-in-conformityhttps://www.federalregister.gov/articles/2012/03/30/2012-7602/federal-participation-in-the-development-and-use-of-voluntary-consensus-standards-and-in-conformityhttps://www.federalregister.gov/articles/2012/03/30/2012-7602/federal-participation-in-the-development-and-use-of-voluntary-consensus-standards-and-in-conformityhttp://www.asse.org/publications/standards/docs/PositionStatementonConsensusStandards.pdfhttp://www.ansi.org/standards_activities/domestic_programs/overview.aspx?menuid=3http://www.ansi.org/news_publications/media_tips/standards_overview_cont.aspx?menuid=7


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February, 28, 2013) (https://standards.gov/nttaa/resources/nttaa_ar_2009.pdf)

Occupational Safety and Health Administration (OSHA). 2004. 29 CFR 1910, Updating OSHA Standards Based on National Consensus Standards (retrieved February 28, 2014)

(https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER& p_id=18260)

Silcox, Clark. 2011. “Incorporation by Reference: Inclusion of Consensus by Public Law and Copingwith a Moving Target.” Small Business Administration Safety and Health Round Table.Washington, DC.

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February 28, 2014) (http://www.ses-standards.org/displaycommon.cfm?an=1&subarticlenbr=58)
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