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OSHA releases update to construction safety guidelines

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The U.S. Occupational Safety and Health Administration’s safety and health program management guidelines for the construction sector set out a specific set of recommended practices for employers in this industry. 

OSHA released its long-awaited update to its 1989 safety and health program management guidelines for general industry in October, but the agency decided to craft separate guidelines specifically for the construction industry based on stakeholder feedback, which was published last week.

The guidelines include seven core elements for a safety and health program in the construction sector: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication and coordination for employers on multiemployer worksites. 

“Construction is a different beast (compared) to general industry,” Dean McKenzie, director of OSHA’s Directorate of Construction, told the Advisory Committee on Construction Safety and Health in Washington last week. “We have standards that require a program, so this guidance was a little bit trickier to put out in how we treat that. But they are out and ready for use. We will have the same seven core elements. A lot of the principles are identical to the general industry set, with a few things that are slightly different. We discuss multiemployer differently.”

The document notes, for example, that construction job sites typically have workers who are employed by a general contractor and other workers who are employed by a contractor or subcontractor or workers from other sources. 

“In these circumstances, it is important that each employer and contractor consider how its work and safety activities can affect the safety of other workers at the job site,” OSHA said in the document. “Examples include electrical or mechanical contractors working for the general contractor at a building construction site.”

Each general contractor establishes and implements a procedure to ensure the exchange of information about hazards present on site and the hazard control measures in place, making all workers aware of worksite hazards and the methods and procedures needed to control exposures to them, according to the guidelines. General contractors, contractors, subcontractors and staffing agencies coordinate on work planning, scheduling, and resolving program differences to identify and work out any concerns or conflicts that could impact safety or health.

The Associated General Contractors of America was one of the stakeholders that advocated for a separate set of guidelines for the construction sector after seeing a draft of the proposed update last year, said Kevin Cannon, senior director of safety for the Arlington, Virginia-based organization. 

“It didn’t feel like it fit the dynamics of the construction industry and how the industry really works,” he said. 

While the organization has not completed its review of the recommended practices at this point, the first six elements are “pretty common elements of a robust safety program,” and communication and coordination on multiemployer sites is critical, Mr. Cannon said. 

“It doesn’t fall on one individual contractor,” he said. “Everyone shares that responsibility.”

The agency’s position that it would not use failure to follow all the core elements of the recommended practices against employers is a positive development, Mr. Cannon said. 

“OSHA made it clear this document will not be used for enforcement reasons, and employers will not be cited if their programs don’t contain all the elements,” he said.