Construction has long been recognized as a high hazard industry and is one of the industries targeted in MOSH's Five Year Strategic Plan. The State has experienced significant construction activity in recent years. Accidents relating to falls from elevations are one of the leading causes of serious injuries and fatalities. It is believed through a local emphasis program that increases awareness and accelerates enforcement activity, injuries can be reduced. It is also recognized that a tracking mechanism for these type inspections would prove beneficial in monitoring the area of fall hazards. In the past, many unprogrammed inspections have been conducted through CSHO self referrals, imminent danger complaints or through accident investigations. This LEP is designed to increase inspection activity, provide tracking, enhance expertise and formalize procedures
MOSH compliance personnel shall ensure that the procedures contained in this directive are followed when conducting this LEP. The Regional Offices will implement the procedures described in section VIII of this Instruction in response to imminent dangers or serious fall hazards that are identified on construction sites. The Regional Supervisors shall use the LEP as a basis for scheduling and conducting safety inspections of construction sites. This LEP is intended to be used on any construction site where fall hazards have been alleged and/or identified to initiate safety inspections. These inspections may be expanded to comprehensive inspections of multi employer construction sites in accordance with the guidelines established in the FOM.
A. Responsible Office: Office of the Assistant Commissioner
Procedures: This LEP will be conducted throughout the State.
A. An inspection targeting system which encompasses identification of sites at the beginning of the quarter and the random selection of sites is not practical. Hazards related to falls on construction sites are normally transient and of limited duration. This limits the practicality of targeting the site in advance. Therefore, inspections conducted under this LEP would be initiated by several means: CSHO observance, non formal complaints, and referrals from other outside sources.
B. All work sites where fall hazards are observed by compliance officers will be selected for inspection under this LEP. These sites shall include but shall not be limited to:
1. Structural steel erection sites where fall protection is not apparent and potential falls or related hazards exist;
2. Structural steel erection where fall protection for employees other than ironworkers is not apparent and potential falls or related hazards exist;
3. Structural steel erection where fall protection for ironworkers 10' or more above a lower level (in excess of 30' or two stories, whichever is less for employees working in controlled decking zones, and in excess of 30' for connectors) is not apparent and potential falls or related hazards exist;
4. Sites where fall protection for employees on scaffolds 10' or more above a lower level is not apparent;
5. Sites where fall protection for employees on walking/working surfaces 6' or more above a lower level is not apparent;
6. Other activities which constitute potential falls and no protective systems are in use such as erection of tanks, communication and broadcast towers, certain work on cranes and derricks, and activities where employees are working from elevations without fall protection.
When a job site with fall hazards is noted during travel, the CSHO will notify the supervisor with the name of the contractor (if known) and the location of the site. The supervisor will determine if the site has been inspected within the last 30 days. If the site has not been inspected within the last 30 days, permission will be given to inspect the site. If the site has been inspected within the last 30 days, an inspection will be authorized only if an imminent danger appears to be present, or at the Regional Supervisor's discretion. These inspections will normally be limited to the imminent danger situation and plain view items. The CSHO will remain at the site to observe the abatement procedures and/or to assist with abatement methods. CSHOs will record these inspections as referral inspections.
C. A large number of fall hazards are reported via referrals and complaints, both of a formal and a non formal nature. Formal complaints of fall hazards on construction sites will continue to be scheduled before programmed inspections. Non formal complaints and referrals which would normally be handled by letters will be handled in accordance with paragraph VIII.B. above. Inspection history and the scope of the inspection will be handled in the same manner.
II. Recording in IMIS. The IMIS identifier code to be used in item 25c on the OSHA-1 will be "FALL HAZARDS IN CONSTRUCTION".
Roger Campbell, Assistant Commissioner, MOSH
cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
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