Kevin Lindley, Safety Consultant, FRSA Self Insurer’s Fund
Construction companies expect that their field workers are doing their part to keep the company profitable, productive and upholding company values to maintain their reputation and site inspections play an integral role in making this happen. Random and frequent visits to jobsites should be made by various company individuals to ensure every aspect of a project is being performed to company standards. Those individuals selected to complete site visits should have a specific purpose, be able to make changes or recommendations while at the site, take corrective action immediately and ensure that safety measures
are being followed.
Contractors are required to complete site inspections on their workers per Section 5(a)(1) of the Occupational Safety and Health Act (aka “the General Duty Clause”), which reads, “Employment and a place of employment which are free from
recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” Site safety inspections should always be documented either with photographs or in writing or both. Following an OSHA site inspection, contractors need to submit documented proof of site inspections to OSHA during the investigative process. Written documentation is preferred: photographs sometimes communicate more than intended.
To conduct site inspections, designated company individuals are recommended. Many companies rely upon their field foreman to self-audit the site and workers, which works very well for the day-today operations. However, an inspection should be
performed by someone not actively involved in the work. All too often, employees become engaged in their scope of work and lose perspective of work areas and activities other than their own. The individual(s) who are responsible for completing the various inspections should be given guidelines and trained to complete the type of inspection(s) they are conducting.
Ensure the individual(s) have the tools necessary to perform the inspection, provide assistance or guidance to the field workers and know what steps to take when issues cannot be immediately resolved or require additional action.
There are many different types of jobsite inspections. Site superintendents or project managers often visit the job to verify the workers are on schedule, have the materials needed to complete the task or project, ensure all the workers are present and actively engaged with work-related activities. Sometimes, site safety inspections are not completed to the expectations of upper management or OSHA. Site safety inspections must be documented.
Create a checklist of safety items to be verified or corrected. Photos are very helpful to identify safety hazards existing on the site prior to the inspection and aid management should issues arise. A standardized checklist helps to maintain consistency
even when different people are conducting inspections. No jobsite is perfect all the time. Jobsites change minute by minute and there are many moving, evolving, changing conditions. It is not practical to have a perfect site. A safety issue is not as big a
concern as a repeat safety issue or an overlooked safety problem that is not corrected. A checklist needs to identify the issues and note the corrective action taken or to be taken. At minimum, a job safety inspection checklist should include the following:
■ Site: secure, organized, clean, public signs posted if needed.
■ Vehicle: tires in good condition, materials secure in bed, propane tanks secured upright, limited debris.
■ Equipment: operators are licensed as required, daily inspections completed and documented, equipment in good operational condition, fire extinguisher attached to or within 50 feet of operation, equipment operator following safety operating procedures.
■ Ladder: good operational condition, three feet above the top landing surface (measured vertically), set at a 4:1 (rise to run) ratio, secured to the structure, have clear landings at top and base.
■ Personal protective equipment: workers wearing the required PPE (safety glasses, hard hats, gloves, hearing protection, appropriate silica protection while cutting silica containing materials, work shoes, work clothing, etc.).
■ Fall protection: guardrail, personal fall arrest, warning lines, monitor adequate for slope of the roof.
■ Housekeeping on roof and work areas: orderly, clean, clear egress.
■ Gas powered equipment: exhaust clear of combustible materials or equipment, adequate distance away from the structure, shut down prior to refilling, gas container with flash guard and spring-loaded lid.
■ Fire extinguisher: present, readily available, fully charged, inspected as required.
■ Electrical: cords and equipment in good operational condition, free of defects, tagged out if necessary.
■ Tools: safety guards present, used as intended.
■ Water: adequate supply available onsite.
Many site safety concerns are minor and can be easily resolved in the field with minor adjustments. For instance, ladder set-up is the third most-cited OSHA standard. Ladders not set at a 4:1 ratio, raised three feet above the roof contact point, feet properly positioned or found not secured to the structure or the base of the ladder was not secured if needed, can be corrected in the field without much effort.
Personal protective equipment including eye and face protection is currently the ninth most-cited OSHA standard. Field workers often find themselves in a situation where they know they need to wear their personal protective equipment and have it with them on the jobsite but are not wearing it while completing a task and leave themselves and the company liable for their actions.
Fall protection is the number one most-cited OSHA standard. Many contractors train their workers on fall protection as required by OSHA for all employees exposed to fall hazards of six feet or greater and issue their employees fall protection equipment as required by OSHA standards. Many workers can identify and know when fall protection equipment is required and necessary; however, those workers are often found repeatedly working at elevations greater than six feet without the use of any type of fall protection – not only by OSHA, but also their co-workers, supervisors and the public. Roofing, sheet metal, solar and air conditioning field workers not having their personal fall arrest devices with them on a jobsite is unacceptable. Liability by the individual as well as the company is too great to allow unsafe behavior in the field to be compromised for convenience, speed or lack of care and should be dealt with accordingly.
FRSA’s Self Insurers Fund (FRSA-SIF) has professional safety consultants throughout the state who are available to provide SIF members with safety training, to conduct site, office and shop safety evaluations, provide consultation for all safety needs
and are a resource for safety documentation. Site inspections conducted through FRSA-SIF come with documentation and photo support as well as feedback to assist in identifying safety concerns and aid to abate them through conversation, training or recommendation of action to be taken by the company.
Some violations arise when issues cannot be immediately resolved in the field at the time of the inspection. When this occurs, workers need to be informed of the issues and hazards need to be isolated until they can be corrected. For example, during a
safety inspection on a jobsite, workers are found on a roof that has a ladder access that is damaged with a split ladder rail. If an alternate ladder is not present, a replacement ladder must be immediately requested and brought to the site.
There will also be times when unsafe safety actions or behavior of an individual or crew require additional action that cannot be immediately taken. Unsafe acts that require disciplinary action or retraining must follow the company disciplinary action policy standards. Should action in this manner be necessary, it should be taken and documented. Disciplinary action in the form of verbal reprimand completed at the time of the site safety inspection should be noted on the written documentation of the site safety visit.
Access to workers’ comp coverage is available to all FRSA members. To find out if you qualify for FRSA-SIF workers’ comp insurance, please contact Alexis at 800-767-3772, ext. 206 or email alexis@frsasif.com. To learn more about the FRSA Self Insurers Fund, please visit www.frsasif.com.
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