introduction to osha subpart c 29 cfr -1926.1-1926.35

Introduction to OSHAIntroduction to OSHA

Subpart CSubpart C

29 CFR -1926.1-1926.3529 CFR -1926.1-1926.35


The William-Steiger Occupational Safety & The William-Steiger Occupational Safety & Health Act was passed by Congress in Health Act was passed by Congress in December, 1970. The act established the December, 1970. The act established the Occupational Health and Safety Administration Occupational Health and Safety Administration (OSHA).(OSHA).

April, 1971-Enforcement of regulations began.April, 1971-Enforcement of regulations began.

Purpose: To assure every employee a safe & Purpose: To assure every employee a safe & healthful work environment.healthful work environment.


Prior to OSHA, job related accidents accounted Prior to OSHA, job related accidents accounted for more than 14,000 workers deaths annually.for more than 14,000 workers deaths annually.

Currently about 6000 Americans die annually Currently about 6000 Americans die annually from workplace injuries.from workplace injuries.

In 2002, 1121 construction workers died from In 2002, 1121 construction workers died from workplace injuries.workplace injuries.

The “General Duty” ClauseThe “General Duty” Clause

OSH Act – Public Law 91-596 Dec.29. 1970 OSH Act – Public Law 91-596 Dec.29. 1970 Section 5 (a) (1):Section 5 (a) (1):

“ “Each employer shall furnish to each of his Each employer shall furnish to each of his employees, employment and a place of employees, employment and a place of employment, which are free from recognized employment, which are free from recognized hazards that are causing or are likely to cause, hazards that are causing or are likely to cause, death or serious physical harm to employees.”death or serious physical harm to employees.”

Incorporation by Incorporation by ReferenceReference

Other standards mandatory provisions have the Other standards mandatory provisions have the same force and effect of law as OSHA same force and effect of law as OSHA standards, i.e., ANSI, NEC, NFPA…standards, i.e., ANSI, NEC, NFPA…

Most Frequently Cited Serious Most Frequently Cited Serious Violations - 2003Violations - 2003

501(b)(1) Unprotected sides and edges (1652)501(b)(1) Unprotected sides and edges (1652) 451(g)(1) Scaffolds – Fall protection (1229)451(g)(1) Scaffolds – Fall protection (1229) 100(a) Head protection (1159)100(a) Head protection (1159) 501(b)(13) Fall protection – Residential @ 6’ (1090)501(b)(13) Fall protection – Residential @ 6’ (1090) 451(e)(1) Scaffolds – Access (1044)451(e)(1) Scaffolds – Access (1044) 453(b)(2)(v) Aerial lifts – Body belt & lanyard (977)453(b)(2)(v) Aerial lifts – Body belt & lanyard (977) 451(b)(1) Scaffolds – Platform construction (925)451(b)(1) Scaffolds – Platform construction (925) 652(a)(1) Excavations- Protection of employees (890)652(a)(1) Excavations- Protection of employees (890) 21(b)(2) Employee training programs (812)21(b)(2) Employee training programs (812) 503(a)(1) Fall hazards training program (774)503(a)(1) Fall hazards training program (774)

Most Frequently Cited Most Frequently Cited Subpart C - 2003Subpart C - 2003

21(b)(2) Employee training programs (812)21(b)(2) Employee training programs (812)

20(b)(2) Inspections by a competent person (542)20(b)(2) Inspections by a competent person (542)

20(b)(1) Initiate and maintain accident prevention 20(b)(1) Initiate and maintain accident prevention programs (419)programs (419)

25(a) Housekeeping (266)25(a) Housekeeping (266)

28(a) Personal protective Equipment (113)28(a) Personal protective Equipment (113)

General Requirements General Requirements Subpart CSubpart C

Employer cannot require employees to work in Employer cannot require employees to work in unsafe, hazardous, or unsanitary conditions.unsafe, hazardous, or unsanitary conditions.

Employer must have a safety program & conduct Employer must have a safety program & conduct frequent and regular inspections by competent frequent and regular inspections by competent persons.persons.

Most companies conduct written weekly inspections Most companies conduct written weekly inspections and daily informal inspections.and daily informal inspections.

General Requirements General Requirements Subpart CSubpart C

Unsafe tools, machinery, material or equipment Unsafe tools, machinery, material or equipment to be tagged or locked out of service, or to be tagged or locked out of service, or physically removed from place of operation. physically removed from place of operation.

Employer shall permit only employees qualified Employer shall permit only employees qualified by training or experience to operate machinery by training or experience to operate machinery and equipment.and equipment.

HousekeepingHousekeeping

Combustible scrap and debris must be removed at Combustible scrap and debris must be removed at regular intervals.regular intervals.

Form and scrap lumber with protruding nails and all Form and scrap lumber with protruding nails and all other debris, shall be cleared from work areas, other debris, shall be cleared from work areas, passageways, and stairs.passageways, and stairs.

Containers shall be provided for waste, trash, oily Containers shall be provided for waste, trash, oily and used rags.and used rags.

Means of EgressMeans of Egress

Free and unobstructed egress at all exits must Free and unobstructed egress at all exits must be maintained.be maintained.

Exits cannot be lockedExits cannot be locked

Exits must be marked if direction to them not Exits must be marked if direction to them not immediately visible.immediately visible.

Means of egress must be maintained free of Means of egress must be maintained free of obstructionsobstructions

Emergency Action PlansEmergency Action Plans

Must be written and cover the following at a Must be written and cover the following at a minimum:minimum:

Escape procedures and routesEscape procedures and routes Procedures for employees who remain for critical Procedures for employees who remain for critical

functionsfunctions Procedures to account for all employees after Procedures to account for all employees after

evacuationevacuation Means of reporting emergenciesMeans of reporting emergencies Rescue and medical dutiesRescue and medical duties Names or job titles of persons who can be Names or job titles of persons who can be

contacted for further informationcontacted for further information


Employer must establish an employee alarm Employer must establish an employee alarm systemsystem

Employees must be trained in plan Employees must be trained in plan requirements.requirements.

Radios, Nextels, air horns, etc. can serve this Radios, Nextels, air horns, etc. can serve this purpose.purpose.

Confined Space EntryConfined Space Entry

All employees required to enter into confined All employees required to enter into confined spaces must be trained regarding hazards, spaces must be trained regarding hazards, precautions, and use of protective and precautions, and use of protective and emergency equipment.emergency equipment.

Guidelines are covered under OSHA General Guidelines are covered under OSHA General Industry Standard 1910.146Industry Standard 1910.146

A construction standard is being developed.A construction standard is being developed.

Confined Space EntryConfined Space Entry

Confined Space:Confined Space:

… …any space having limited means of egress, any space having limited means of egress, subject to accumulation of toxic or flammable subject to accumulation of toxic or flammable contaminants or oxygen deficient atmosphere.contaminants or oxygen deficient atmosphere.

Competent PersonCompetent Person

One who is capable of identifying existing and One who is capable of identifying existing and predictable hazards in the surroundings or predictable hazards in the surroundings or working conditions that are unsanitary, working conditions that are unsanitary, hazardous, or dangerous to employees, and hazardous, or dangerous to employees, and who has who has authorityauthority to take prompt corrective to take prompt corrective measures to eliminate them.measures to eliminate them.

Qualified PersonQualified Person

One who, by having recognized degree, One who, by having recognized degree, certificate, or professional standing, or who by certificate, or professional standing, or who by extensive knowledge, training, and experience, extensive knowledge, training, and experience, has successfully demonstrated his ability to has successfully demonstrated his ability to solve or resolve problems relating to the work.solve or resolve problems relating to the work.

I.e., a Professional Engineer, experienced I.e., a Professional Engineer, experienced foreman, etc.foreman, etc.

Examples of Areas With Competent Examples of Areas With Competent Person RequirementsPerson Requirements

Fall ProtectionFall Protection ScaffoldingScaffolding Trench & ExcavationTrench & Excavation Respirator UseRespirator Use Cranes & DerricksCranes & Derricks LaddersLadders Hearing ProtectionHearing Protection Welding & CuttingWelding & Cutting

ElectricalElectrical Concrete forms & Concrete forms &

ShoringShoring DemolitionDemolition LeadLead Ionizing RadiationIonizing Radiation

Training EducationTraining Education

Employees must be trained in recognition, Employees must be trained in recognition, avoidance, and prevention of unsafe conditions avoidance, and prevention of unsafe conditions and the regulations applicable to his/her work and the regulations applicable to his/her work environment.environment.

Employees required to handle or use poisons, Employees required to handle or use poisons, caustics, toxic or flammable materials must be caustics, toxic or flammable materials must be trained in safe handling.trained in safe handling.

Training Education Training Education

OSHA recognized training programs:OSHA recognized training programs:

OSHA 500 program established to “train the OSHA 500 program established to “train the trainers”trainers”

OSHA 10 & 30 hour programs established for OSHA 10 & 30 hour programs established for employees and supervisors.employees and supervisors.

WWW.OSHA.ORGWWW.OSHA.ORG Agency home pageAgency home page

All companies OSHA history available as public record All companies OSHA history available as public record informationinformation

OSHA standards can be downloadedOSHA standards can be downloaded

Compliance directives and letters of interpretation availableCompliance directives and letters of interpretation available

Employee online complaint systemEmployee online complaint system

eTools (best practice guidelines)eTools (best practice guidelines)

Types of InspectionsTypes of Inspections

General Scheduled (random)General Scheduled (random) ComplaintComplaint Post-Incident (1 fatality or 3 injuries from 1 event)Post-Incident (1 fatality or 3 injuries from 1 event) Referral (news media, fire department, public…)Referral (news media, fire department, public…) Special Emphasis (silica, falls, trenching…)Special Emphasis (silica, falls, trenching…) Focused (4 main hazards)Focused (4 main hazards) Follow-up (post citation)Follow-up (post citation)

Focused InspectionsFocused Inspections

Allows compliance officers to spend less time Allows compliance officers to spend less time with companies that have strong safety with companies that have strong safety programs, and more time with companies that programs, and more time with companies that do not.do not.

You must have a written safety program, You must have a written safety program, implemented by a competent person, to qualify.implemented by a competent person, to qualify.

Results in shortened inspections process.Results in shortened inspections process.

Focused InspectionsFocused Inspections

Inspections Focused on: (90% of fatalities)Inspections Focused on: (90% of fatalities)

Falls (floors, work platforms, roofs) 33%Falls (floors, work platforms, roofs) 33%

Struck by (falling objects, vehicles) 22%Struck by (falling objects, vehicles) 22%

Caught in-between (cave-ins) 18%Caught in-between (cave-ins) 18%

Electrical (overhead lines, tools) 17%Electrical (overhead lines, tools) 17%

Rules of ConstructionRules of Construction

Contractors and subcontractors can make their Contractors and subcontractors can make their own arrangements regarding who will do things own arrangements regarding who will do things such as; installing guardrails or providing such as; installing guardrails or providing drinking water, however:drinking water, however:

Under no circumstance is the Prime Contractor Under no circumstance is the Prime Contractor relieved of overall responsibility for safety relieved of overall responsibility for safety (1926.16)(1926.16)

Multi-Employer Work Site Multi-Employer Work Site PolicyPolicy

Exposing EmployerExposing Employer – One whose employees – One whose employees are exposed to hazards (most often receives are exposed to hazards (most often receives citation).citation).

Creating EmployerCreating Employer – One who actually creates – One who actually creates the hazards.the hazards.

Correcting EmployerCorrecting Employer – One responsible for – One responsible for correcting the hazard.correcting the hazard.

Controlling EmployerControlling Employer – One who is responsible – One who is responsible for conditions on work site.for conditions on work site.

Inspections, Citations and Inspections, Citations and EnforcementEnforcement

Preplanning:Preplanning: OSHA will review OSHA will review

the company’s the company’s history of citationshistory of citations

May film or video May film or video from offsitefrom offsite

Work Site:Work Site: Compliance Compliance

Officer must show Officer must show credentialscredentials

Will request entry, Will request entry, and explain the and explain the purpose of the visitpurpose of the visit

Inspection Sequence:Inspection Sequence:

Inspections, Citations Inspections, Citations and Enforcementand Enforcement

Opening Conference:Opening Conference: The compliance Officer Identifies the scope & The compliance Officer Identifies the scope &

type of inspection.type of inspection.

Will review OSHA required recordkeeping.Will review OSHA required recordkeeping.

Opportunity to qualify for focused inspection.Opportunity to qualify for focused inspection.

Meet with a representative of each contractorMeet with a representative of each contractor


Inspection Process:Inspection Process:

Will tour the job/facility looking for hazards, will Will tour the job/facility looking for hazards, will interview employees, collect photos/videos, and interview employees, collect photos/videos, and samples or measurements.samples or measurements.

It is important for the employer to take the same It is important for the employer to take the same photo as OSHA from several viewpoints.photo as OSHA from several viewpoints.


Closing Conference:Closing Conference:

The Compliance Officer may point out potential The Compliance Officer may point out potential violations of the standards, and establish violations of the standards, and establish abatement dates for correction.abatement dates for correction.


Decision to Issue Citation(s):Decision to Issue Citation(s):

The Compliance Officer completes report and The Compliance Officer completes report and proposes potentials citations. This is reviewed proposes potentials citations. This is reviewed by the Area Director who has final authority to by the Area Director who has final authority to issue citations/penalties.issue citations/penalties.


Citation Issuance:Citation Issuance: Will be received by the employer via registered Will be received by the employer via registered

mail within 180 days.mail within 180 days.

The employer can ask for an informal The employer can ask for an informal conference, within 15 days.conference, within 15 days.

The employer must correct any citations within The employer must correct any citations within the abatement dates & pay penalty amount or the abatement dates & pay penalty amount or contest citations.contest citations.

Types of CitationsTypes of Citations

Other than SeriousOther than Serious – A violation that would not – A violation that would not cause death or serious injury.cause death or serious injury.

SeriousSerious – A violation where there is a high – A violation where there is a high probability of death or serious injury.probability of death or serious injury.

WillfulWillful – A violation where death or serious – A violation where death or serious injury could occur, and the employer knew, or injury could occur, and the employer knew, or should have known, the hazard existed.should have known, the hazard existed.


Criminal WillfulCriminal Willful – “Flagrant disregard for – “Flagrant disregard for safety….” Can result in 6 months jail time and safety….” Can result in 6 months jail time and $500,000 fine.$500,000 fine.


RepeatRepeat – A violation of any standard or rule – A violation of any standard or rule where upon re-inspection within 3 years, a where upon re-inspection within 3 years, a similar violation is found.similar violation is found.

Failure to AbateFailure to Abate – A violation for failure to – A violation for failure to correct a previous citation in a timely manner.correct a previous citation in a timely manner.

Citation PenaltiesCitation Penalties

Other than SeriousOther than Serious – $0 - $7000 – $0 - $7000

SeriousSerious – Up to $7000 – Up to $7000

RepeatedRepeated – – X2, X5, & X10X2, X5, & X10


WillfulWillful – Up to $70000 – Up to $70000

EgregiousEgregious – Penalty amount multiplied times – Penalty amount multiplied times the number of employees exposed. (the number of employees exposed. (At this time, At this time, OSHA cannot use the egregious policy due to OSHA cannot use the egregious policy due to court decision however, they have appealed court decision however, they have appealed this).this).

Criminal WillfulCriminal Willful – – Up to $500,000Up to $500,000


Failure to Abate – (per calendar day $7000, to Failure to Abate – (per calendar day $7000, to maximum $210,000)maximum $210,000)

Failure to report fatality – $5000Failure to report fatality – $5000

Failure to post citation – $3000Failure to post citation – $3000

Failure to post on 300 log – $1000 / caseFailure to post on 300 log – $1000 / case

What’s New Subpart CWhat’s New Subpart C

2002 Construction Fatalities – 1,1212002 Construction Fatalities – 1,121

Only 5% of the workers in constructionOnly 5% of the workers in construction

20% of the fatalities20% of the fatalities


Enhanced Enforcement Policy:Enhanced Enforcement Policy:

Announced by Secretary of Labor Chao on 3/11/03.Announced by Secretary of Labor Chao on 3/11/03.

Focuses on employers who have received high Focuses on employers who have received high gravity citations.gravity citations.

High gravity = high risk factor / high penaltyHigh gravity = high risk factor / high penalty


High Gravity Citations include:High Gravity Citations include:

High gravity willful violations.High gravity willful violations. Multiple high gravity serious violations.Multiple high gravity serious violations. High gravity repeat violations at originating High gravity repeat violations at originating

establishment.establishment. Failure to abate notices.Failure to abate notices. Serious willful or repeat violations related to a Serious willful or repeat violations related to a

fatality.fatality.


Will Result in:Will Result in:

Follow up inspectionsFollow up inspections

Issuance of press releasesIssuance of press releases

Identified companies prioritized for programmed Identified companies prioritized for programmed inspectionsinspections


Settlement Agreement:Settlement Agreement:

Requires employers to hire consultants.Requires employers to hire consultants.

Applies agreement corporate-wide.Applies agreement corporate-wide.

Requires info on other job sites.Requires info on other job sites.


Settlement Agreement:Settlement Agreement:

Requires submission of 300 logs to OSHA Requires submission of 300 logs to OSHA quarterly and consent to inspections quarterly and consent to inspections based on logs.based on logs.

Employer consents to allow OSHA entry.Employer consents to allow OSHA entry.


Post Settlement Agreement:Post Settlement Agreement:

OSHA will seek enforcement of court orders as allowed OSHA will seek enforcement of court orders as allowed under Section 11(b) OSH Act. In other words, they will under Section 11(b) OSH Act. In other words, they will more aggressively deal with employers in the courts.more aggressively deal with employers in the courts.

Federal courts have more sanctions to deal with non-Federal courts have more sanctions to deal with non-compliant employers-fines, court costs, incarceration.compliant employers-fines, court costs, incarceration.

RecordkeepingRecordkeeping

Recordkeeping StandardRecordkeeping Standard

Revised January 2002Revised January 2002

Who Must ComplyWho Must Comply

All employers with over ten employees All employers with over ten employees must maintain 300 & 301must maintain 300 & 301

Randomly selected employers must Randomly selected employers must participate in the annual survey – results in participate in the annual survey – results in BLS data.BLS data.

PenaltiesPenalties

““Whoever knowingly makes any false statement, Whoever knowingly makes any false statement, representation, or certification in any application, representation, or certification in any application, record, report, plan or other document filed or record, report, plan or other document filed or required to be maintained pursuant to this Act required to be maintained pursuant to this Act shall, upon conviction, be punished by a fine of shall, upon conviction, be punished by a fine of not more than $10,000, or by imprisonment, for not more than $10,000, or by imprisonment, for not more than 6 months, or both.”not more than 6 months, or both.”

Requirements…Requirements…

Each workplace must display an OSHA or Each workplace must display an OSHA or State poster.State poster.

The employer must report to OSHA within 8 The employer must report to OSHA within 8 hours all accidents which result in a fatality hours all accidents which result in a fatality or hospitalization of three or more or hospitalization of three or more employees. (1-800-321-OSHA)employees. (1-800-321-OSHA)

Recordkeeping FormsRecordkeeping Forms

300 Log – list of recordable injuries300 Log – list of recordable injuries

301 Supplemental Form – in some states you 301 Supplemental Form – in some states you can substitute your Employer’s First Report of can substitute your Employer’s First Report of Injury Form.Injury Form.

300A Summary (This is what is posted)300A Summary (This is what is posted)

General Recording General Recording Criteria Criteria

You must post the summary (300A) from February You must post the summary (300A) from February 1st through April 30th .1st through April 30th .

You can just post this at the corporate office You can just post this at the corporate office unless your project will last over 12 months.unless your project will last over 12 months.

The summary must be signed by a company The summary must be signed by a company executiveexecutive

General Recording General Recording Criteria Criteria

You must record the following if work related:You must record the following if work related:

DeathDeath Loss of consciousnessLoss of consciousness Lost work dayLost work day Restricted work / Job transfer Restricted work / Job transfer Medical treatmentMedical treatment Significant injury or illness diagnosed by Significant injury or illness diagnosed by

physician or licensed health care professionalphysician or licensed health care professional

Hearing LossHearing Loss

You must record work-related hearing loss.You must record work-related hearing loss.

Record 10 decibel threshold shift from initial Record 10 decibel threshold shift from initial audiogram.audiogram.

Record 25 db hearing loss from audiometric Record 25 db hearing loss from audiometric zerozero

Lost Work DaysLost Work Days

Count Calendar DaysCount Calendar Days

If the Doctor says the employee must take If the Doctor says the employee must take time off from work you must count it as lost time time off from work you must count it as lost time even if employee does not take time off.even if employee does not take time off.

Counting Cap – 180 days.Counting Cap – 180 days.

Restricted Work Restricted Work Days / Job TransferDays / Job Transfer

Count Calendar DaysCount Calendar Days

Stop counting at 180 days Stop counting at 180 days

Stop counting if permanent job transfer.Stop counting if permanent job transfer.

Medical TreatmentMedical Treatment

If the employee receives medical treatment, you If the employee receives medical treatment, you must record must record

If the employee receives only first aid treatment, If the employee receives only first aid treatment, regardless of who provides the treatment, you regardless of who provides the treatment, you do not record do not record

Medical Treatment – Medical Treatment – ExceptionsExceptions

Visits to a medical professional solely for Visits to a medical professional solely for observation are not recordableobservation are not recordable

First Aid – (see list to follow)First Aid – (see list to follow)

Diagnostic Procedures:Diagnostic Procedures:

X-rays, blood work or other tests solely for X-rays, blood work or other tests solely for diagnostic purposes are not recordablediagnostic purposes are not recordable

First Aid List – Items on this First Aid List – Items on this List are Not RecordableList are Not Recordable

Non- prescription medication Non- prescription medication Tetanus immunizations Tetanus immunizations Cleaning, flushing or soaking wounds Cleaning, flushing or soaking wounds Band- Aids, butterfly bandages, or steri-stripsBand- Aids, butterfly bandages, or steri-strips Hot or cold therapy Hot or cold therapy Splints, slings, neck collarsSplints, slings, neck collars Drilling nails to relieve pressure, drain blisterDrilling nails to relieve pressure, drain blister

First Aid List ContinuedFirst Aid List Continued

Eye patches Eye patches Removal of foreign bodies using irrigation or Removal of foreign bodies using irrigation or

cotton swabcotton swab Removal of splinters by irrigation, tweezers or Removal of splinters by irrigation, tweezers or

cotton swabcotton swab Use of finger guards Use of finger guards Massage of therapyMassage of therapy Drinking fluids for heat stressDrinking fluids for heat stress

Resources Resources

For statisticsFor statistics

www.stats.bls.gov/blshome.htmlwww.stats.bls.gov/blshome.html

For 300 log, regulations, letters of For 300 log, regulations, letters of interpretation:interpretation:

www.osha.govwww.osha.gov

Regular and online safety coursesRegular and online safety courses

www.nahb.orgwww.nahb.org

Safety & Health Safety & Health ProgramsPrograms

Is a Safety and Health Program required by Is a Safety and Health Program required by OSHA in constructionOSHA in construction??

Yes, however a written program is not Yes, however a written program is not required, but OSHA has proposed to change required, but OSHA has proposed to change thisthis..

Why Have A Safety & Why Have A Safety & Health Program?Health Program?

It is the foundation for other Safety /Health efforts.It is the foundation for other Safety /Health efforts.

Your insurance carrier wants you to have one Your insurance carrier wants you to have one

Avoid /reduce accident costs Avoid /reduce accident costs

Must have to qualify for focused inspectionMust have to qualify for focused inspection

OSHA Penalty Reductions OSHA Penalty Reductions Based On Good FaithBased On Good Faith

25% - Based on a comprehensive written and 25% - Based on a comprehensive written and implemented safety & health program.implemented safety & health program.

15% - Based on a written program with some 15% - Based on a written program with some deficiencies deficiencies

Elements Of A Safety & Elements Of A Safety & Health ProgramHealth Program

Management Commitment & Employee Management Commitment & Employee InvolvementInvolvement

Worksite AnalysisWorksite Analysis

Hazard Prevention & ControlHazard Prevention & Control

Safety & Health TrainingSafety & Health Training

Management Commitment Management Commitment & Employee Involvement& Employee Involvement

Develop a worksite safety & health policyDevelop a worksite safety & health policy

Establish & communicate safety goals.Establish & communicate safety goals.

Provide visible top management involvement & Provide visible top management involvement & support.support.

Encourage employee involvement.Encourage employee involvement.

Management Commitment & Management Commitment & Employee InvolvementEmployee Involvement

Assign and communicate program responsibilityAssign and communicate program responsibility

Provide adequate authority and resources.Provide adequate authority and resources.

Hold managers, supervisors, and employees Hold managers, supervisors, and employees accountable.accountable.

Review program operations regularly.Review program operations regularly.

Worksite Analysis Worksite Analysis Recommended ActionsRecommended Actions

Identify hazards.Identify hazards.

Provide regular inspectionsProvide regular inspections

Encourage employee notificationEncourage employee notification

Investigate accidents / near misses.Investigate accidents / near misses.

Analyze injury /illness trends.Analyze injury /illness trends.

Hazard Prevention & Control Hazard Prevention & Control Recommended Actions:Recommended Actions:

Establish hazard control procedures.Establish hazard control procedures.

Provide regular maintenanceProvide regular maintenance

Implement an emergency action plan. Implement an emergency action plan.

Establish a medical program.Establish a medical program.

Hazard Prevention & Hazard Prevention & ControlControl

Implement engineering controls.Implement engineering controls.

Utilize administrative controls.Utilize administrative controls.

Provide PPE.Provide PPE.

Establish a disciplinary system.Establish a disciplinary system.


Employee Notification (Alarm)Employee Notification (Alarm) Initial Response Procedures Initial Response Procedures Emergency Telephone NumbersEmergency Telephone Numbers Site Layouts / Evacuation Routes Site Layouts / Evacuation Routes Designated Gathering AreasDesignated Gathering Areas Accounting SystemAccounting System Employee Training / Periodic DrillsEmployee Training / Periodic Drills

Safety & Health TrainingSafety & Health Training

Employees must be trained in recognition and Employees must be trained in recognition and avoidance of unsafe conditions avoidance of unsafe conditions

Conduct both general & job specific safety Conduct both general & job specific safety training.training.

Safety & Health Training Safety & Health Training Efforts Should Be:Efforts Should Be:

Conducted with new hiresConducted with new hires

Conducted periodicallyConducted periodically

Followed up for retention / understandingFollowed up for retention / understanding

DocumentedDocumented

Question for ReviewQuestion for Review

1.1. If there is not a specific standard for a work practice, how If there is not a specific standard for a work practice, how could OSHA cite it?could OSHA cite it?

2.2. What is OSHA’s name for a person who has knowledge of What is OSHA’s name for a person who has knowledge of the standards, hazard recognition and the authority to stop the standards, hazard recognition and the authority to stop work when necessary?work when necessary?

3.3. What type of inspection should you asked for if you have a What type of inspection should you asked for if you have a safety program?safety program?

4.4. How long do you have to report a fatality to OSHA? What’s How long do you have to report a fatality to OSHA? What’s the phone number call?the phone number call?

introduction to osha subpart c 29 cfr -1926.1-1926.35

Documents

osha standards

head protection

safety administration

nfpa slide

osha subpart c

451g1 scaffolds

652a1 excavations protection

occupational health