Employee involvement is important when you conduct Job Safety Analyses and Activity Hazard Analyses on a construction site. Employees should be consulted during preparation of pre-phase accident prevention plans. Safety and Health Plans should be discussed with the employees who will perform the work.
Employee involvement can take a variety of forms, including participation in the following:
- development of safety and health programs
- workplace inspections and program audits
- membership on joint labor/management committees
- making suggestions for improvement
- incident/accident investigations.
Safety and health committees with representation from both management and labor should be established. Both management and labor should participate in the worksite safety committee meetings. Employees and/or their representatives should be informed of all safety and health activities and measures taken on the construction site. Safety committees should perform in a consultative mode, writing recommendations for improvement in worksite safety and health.
Many construction companies actively encourage employee participation. It’s good business. The International Labour Organization (ILO), the Council of the European Communities (EC), the Corps of Engineers, the Department of Energy, and the ANSI standard for multi-employer work sites all stress the importance of employee involvement. However, there are no specific requirements for employee involvement in Federal OSHA’s construction standards. Some OSHA State Plans (such as Oregon) do require employee participation in safety committees.
Fitness for Duty
The employer should allow only those employees qualified by training or experience to operate equipment and machinery on the worksite. Employees must be physically, mentally, medically, and emotionally qualified to perform the duties to which they are assigned.
Preventing alcohol and drug abuse on the job should always be addressed in the Safety and Health Program. All worksite orientations should include a discussion of drug and alcohol abuse policy. Employees found to be under the influence of or consuming alcohol, drugs, etc. should be removed from the worksite immediately.
Equipment operators should be able to read and understand signs, signals, and operating instructions. Physical examinations should be required for heavy equipment operators and must be required for crane and hoisting equipment operators. Divers should be required to demonstrate driving ability in the equipment they will be operating and only qualified employees should be allowed to operate heavy equipment.
Identifying hazards begins with analyses of the specific anticipated and actual hazards expected to exist at various work sites. An analysis of all work site conditions and each employee’s job and each major phase of activity, will help identify the specific safety, health, and ergonomic hazards associated with a particular project. Analyses of the tasks performed by employees may be conducted by any or all of the following processes:
- Job Hazard Analysis (JHA) or “Job Safety Analysis”(JSA)
- Activity Hazard Analysis, (AHA)
- Preliminary Hazard Analysis (PHA)
The standards and codes of practice ANSI and other agencies require call for each contractor responsible for conducting a particular phase of work (e.g., trenching, concrete work, and masonry) to develop an operation–or phase-specific–PHA describing the hazards associated with that phase of the project, methods of reducing or eliminating them, equipment to be used and inspection requirements for equipment, and phase-specific training requirements. OSHA has no corresponding requirements.
A Preliminary Hazard Analysis (PHA) should be conducted and finalized before the start of work on a construction project. The PHA should identify:
- Anticipated construction phases
- Types of hazards associated with anticipated operations or phases of the project
- Operations or phases requiring further analysis or the design of special protective measures
An Activity Hazard Analysis (AHA) should be prepared by the contractor prior to the beginning of each major phase of work. The AHA:
- Identifies phase-specific hazards
- Includes drawings and/or documentation of any corrective measures needing to be designed by a PE or other component person
- Identifies qualifications of the competent person, or other individual, who will conduct inspection required by DOE standards or construction project documents
When warranted by the nature of the hazards of a job, a Job Hazard Analysis (JHA) should be prepared and documented. The JHA should be conducted when a construction project is first initiated and at critical stages of work, such as:
- Pre-phase Job Hazard Analysis (JHA) should be conducted for work operations performed by contractors.
- Pre-phase JHA should be developed by the contractor filed supervisory personnel who will actually be running the job that is being pre-planned.
- Under no circumstances should work be allowed to begin before the JHA has been approved by the Project Constructor.
Hazard Prevention and Control
To ensure worksite equipment is being maintained and that site conditions pose no unnecessary risks, hazard prevention and control require careful planning, analysis of the hazards associated with:
- each major phase of the project
- the design and application of the controls
- necessary to eliminate or mitigate identified hazards
- routine inspections of the work site
- enforcement of safety rules
Although 29 CFR 1926 addresses hazard preventing and controlling hazards indirectly when discussing inspections and housekeeping requirements, most of the standards directly address this requirement and were developed later by other organizations.
Any machinery, tools, materials, or equipment not in compliance with OSHA requirements should not be used on the worksite. Non-compliant machine tools, materials, or equipment should either be tagged or locked out or should be physically removed from the worksite.
Inspection reports should identify safety and health issues and deficiencies, and the actions, timetable, and responsibility for correcting those deficiencies. Conduct follow-up inspections to ensure abatement and adequate documentation of identified deficiencies. Employees should not be required or instructed to work in surroundings under conditions that are unsafe or dangerous to health.
The contractor should make sure all activities, equipment, and facilities comply with applicable standards. During the pre-construction safety meeting, contractors should discuss, in detail, measures to control hazards that might develop during all major phases of work under contract.
A system should be developed and maintained for tracking the status of all hazards for which immediate abatement is not possible or that fall outside of the project scope.
If feasible, all identified hazards should be immediately corrected or eliminated. If this is not possible:
- Interim control measures should be devised and implemented.
- Warning signs should be posted by the hazard.
- Employees should be informed of the hazard’s location and interim control measures.
- Work practices, procedures, and scheduling should be adjusted as needed.
Worksite supervisors, foremen, and construction safety and health managers should stop work that could place employees, equipment, or property in imminent danger.
Noncompliance with safety and health standards, project safety and health programs, and hazardous conditions should be formally reported to the Senior Project Supervisor. The Senior Project Supervisor should make sure all hazardous conditions are abated in compliance with the safety and health program.