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Publication Number: FHWA-RD-98-180
Safety and Health on Bridge Repair, Renovation and Demolition Projects
General Requirements for Safety and Health Programs
Table of Contents
Section 1: Management Commitment and Leadership
Section 2: Assignment of Responsibility
Section 3: Hazard Identification, Analysis and Control
Section 4: Training and Education
Section 5: Recordkeeping
Section 6: Emergency Planning
SECTION 1: MANAGEMENT COMMITMENT AND LEADERSHIP
Safety and health is a management function that requires management's leadership in planning, setting objectives, organizing, directing, and controlling the program. Management's commitment to safety and health is evidenced in every decision the company makes and every action the company takes. Therefore, the management of the company must assume primary responsibility for implementing and ensuring the effectiveness of a safety and health program. The best evidence of a company's commitment to safety and health is a policy that places the prevention of workplace injuries and illnesses equal to any of the other fundamental corporate operating policies.
Management's leadership role in implementing a safety and health policy is carried out by each member of the management team, from the CEO to the jobsite foreman. The company must provide the necessary resources and leadership to ensure the effectiveness of established safety and health programs. However, each employee's active participation in the safety and health program is also desired and necessary.
The following is an example of a generic company safety and health policy:
A. Policy Statement
To all Employees:
This company is committed to providing safe and healthful workplaces that are free from recognized hazards. The safety and health of our employees is one of the highest priorities of the company. It is the policy of this company to maintain jobsites that are free from recognized safety and health hazards and ensure that accident prevention will be given primary importance in all phases of operation and administration. Therefore, management has developed safety and health programs to reduce the injuries and illnesses that are prevalent in construction.
The effectiveness of this program depends upon the cooperation and communication of management officials, supervisors, and employees. Everyone must be capable of recognizing hazards in the workplace and each must understand their roles and assigned responsibilities. Each supervisor will make the safety and health of all employees an integral part of his/her regular management function, and supervisors will be evaluated on safety and health performance. In addition, each employee will adhere to established company safety rules and procedures. Participation of all employees is essential in order to ensure the effectiveness of this program.
Management will make every effort to provide adequate safety training to employees prior to allowing an employee to begin work. Employees in doubt about how to do a job or task safely are required to ask a qualified person for assistance. Employees must report all injuries and unsafe conditions to management as soon as possible. Corrective measures will be taken to prevent future accidents, and there will be no management retribution or retaliation against employees who report safety and health concerns.
Please read this safety and health program and follow the safe work procedures described. Safety is everyone's business, and everyone (management officials, supervisors, employees) will be held accountable for participating in this program.
Please think Safety and always work safely.
The employer’s safety and health policy should be communicated to its employees regularly. More importantly, however, employees should be able to see that the written policy is regularly reflected in the actions, decisions, and operations of the management team.
B. Company Safety Goals and Objectives
On each construction project jobsite, the project manager and site superintendent should be accountable to the CEO for achieving the company's safety and health objectives and measurable goals. Part of a manager's yearly evaluation should consider the degree to which safety and health goals were achieved on the jobsites he or she supervised.
Suggested company safety and health objectives are to:
Measurable goals to assess progress toward meeting these objectives include:
Whenever a violation of safety rules occurs, the following enforcement policy (or something similar) should be implemented:
FIRST OFFENSE - Verbal warning and proper instruction pertaining to the specific safety violation. (A notation of the violation may be made and placed in the employee's personnel file.)
SECOND OFFENSE - Written warning with a copy placed in the employee's personnel file.
THIRD OFFENSE - Receipt of two written reprimands in any 12-month period may result in suspension.
FOURTH OFFENSE - Dismissal from employment.
The company reserves the right to terminate immediately any employee who acts unsafely on its jobsites.
Note: Each State may have its own rules and regulations regarding the dismissal of employees. Please refer to the State and local labor laws in your own jurisdiction to clarify dismissal procedures in your own State.D. Drug and Alcohol Policy
Many employers establish substance abuse programs. These programs may require pre-employment testing for illegal drug use, as well as random periodic drug or alcohol testing for "safety sensitive" job functions. Testing also may be required for those involved in a workplace death or injury event, or other "for cause" reasons.
Other components of a comprehensive company drug and alcohol program include employee drug and alcohol training programs, Employee Assistance Programs, and the provision of drug and alcohol treatment programs. Any successful company drug and alcohol policy must be clearly defined and communicated to all affected employees. Furthermore, all testing, collection, and analysis procedures should adhere to the U.S. Department of Health and Human Services guidelines for Federal programs.
SECTION 2: ASSIGNMENT OF RESPONSIBILITY
To accomplish the company's safety and health objectives and goals, the participation of everyone in the company and others on the jobsite is required. The roles and responsibilities of major stakeholders in the company's safety and health structure are described below:
A. Chief Executive Officer (CEO) or President
In every organization, the CEO or president has the final authority for ensuring that the workplace is free of recognized safety and health hazards. To accomplish this function the president:
B. Safety and Health Director
The primary function of the safety and health director is to establish, communicate, and assess the effectiveness of programs necessary to implement the company's safety and health policy. These programs must address the entire scope of activities performed to effectively prevent injuries and illnesses.
This guideline is specifically designed to help safety and health directors (and others with safety and health leadership responsibilities) establish and communicate safety and health programs applicable to bridge repair, renovation, and demolition (RR&D) jobsites.
Typical functions of the safety and health director include:
In order to be effective in these functions, the safety and health director should:
C. Non-Field Personnel and Other Managers
This group of employees includes project managers, engineers, and estimators who have responsibilities for the overall direction and success of company activities, including safety and health. In order for many of the established safety and health programs to function properly during actual construction, this group of people must anticipate and incorporate applicable safety and health programs in all their planning, design, and estimating activities. This group also must select subcontractors who will perform the work safely and abide by all site safety and health requirements. And finally, these employees must ensure the ongoing success of the safety and health efforts by organizing periodic project safety meetings.
As an example of the importance of considering safety and health in pre-planning, before employees can use personal fall arrest systems, the location and configuration of suitable anchor points for safety lanyards or lifelines must be determined and may have to be fabricated or designed into structural elements. Shielding, sloping, or shoring methods must be specified for excavations below 4 ft (1.2 m) in depth, and hardware such as trench boxes must be obtained prior to work. Containment structures must be properly designed and reviewed by a professional engineer to prevent collapses from wind. Costs for implementing safety and health programs on the jobsite must also be factored into any bids by estimators. In summary, these employees:
D. Field Supervisors
The day-to-day safety and health of employees is a primary responsibility of field supervisors, including superintendents, project supervisors, and foremen. To accomplish this obligation, this group:
Safety is everyone’s responsibility, with management accountable for the establishment of a culture that enables all employees to go home in the same or better condition than they arrived in. Part of establishing this culture is effectively communicating that each employee is expected, as a condition of employment for which he/she is paid, to work in a manner that will not cause injury to themselves or to fellow workers. Each employee must understand that responsibility for his/her own safety is an integral job requirement. Each employee shall:
F. Competent/Qualified Persons
The OSHA Construction Standards (29 CFR 1926) require every employer to designate competent persons to conduct frequent and regular inspections of the jobsite, materials, and equipment. In addition, specific construction operations such as, but not limited to, lead remediation, excavation, the use of cranes and rigging, underground construction, and mechanical demolition require oversight by "competent persons."
According to OSHA, a "competent person" means "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them." A qualified person is one who, by experience or training, is familiar with the operations and equipment associated with a particular operation or activity.
On construction jobsites, a variety of persons may perform the functions of qualified or competent persons. These include the safety director, non-field management, field management, designated workers, and possibly outside vendors and consultants. In any case, the qualified and competent persons must have the necessary training, experience, and authority to control hazards on the jobsite.
Competent/qualified persons should be designated for each project and listed on the appropriate assignment form (See appendices A-1 and A-2). These forms should be completed during the preparation of the Site-specific Safety Plan (appendix M) and displayed at jobsites where activities requiring the presence of a competent/qualified person are performed. These people can then act as resources for employees who need guidance and informed advice on how to perform specific operations. The form should be updated and replaced as necessary to reflect current designated competent/qualified persons and their area of expertise and responsibility.
On bridge renovation and demolition sites, a competent person must frequently and regularly assess the effectiveness of all controls used to limit lead exposures to employees. The controls are addressed in the company's written Lead Compliance Program. These controls may include engineering measures such as local exhaust ventilation systems, containment structures and ventilation systems, wet methods, vacuum-blast systems, or other commonly used engineering controls. The competent person also inspects the adequacy of hygiene facilities, work practice controls, personal protective equipment, administrative controls (such as job rotation, if used), and respiratory protection programs.
G. Labor/Management Safety and Health Committee
A joint labor/management safety and health committee or some other employee participation structure should be established on each construction jobsite to assist with implementation of the employer’s safety and health program and the control of identified hazards. The joint safety and health committee should be composed of employees and management representatives. The committee should meet regularly, but not less than once a month. Written minutes from safety and health committee meetings should be available and posted on the project bulletin board for all employees to see.
The safety and health committee participates in periodic inspections to review the effectiveness of the safety programs and make recommendations for improvement of unsafe and unhealthy conditions. In short, the committee monitors the effectiveness of the safety and health programs.
The committee reviews safety inspection, near-miss, and accident investigation reports and complaints about unsafe or unhealthy working conditions. Where appropriate, the committee submits suggestions for further action. The committee also, upon request from OSHA, may verify abatement action taken by the company in response to safety and health citations.
The objectives of the joint project labor/management safety and health committee are to:
You may wish to consult your labor attorney before establishing labor/management safety and health committees. Forming such committees could have an impact on your business.
The selection of subcontractors should be based in part on the subcontractor's past safety and health performance. Has the subcontractor's health and safety program on previous lead projects demonstrated effectiveness? Has the subcontractor been cited for OSHA violations? What is the experience modification rate (EMR) for the subcontractor? These items of concern should be addressed in addition to a review of the subcontractor's safety and health resources such as equipment and staff.
When applicable work quality standards exist, such as the Steel Structures Painting Council (SSPC) Painting Contractors Certification Program QP 2(I), consideration should be given to subcontractors who have completed the program or similar quality assurance programs. Evidence of a comprehensive lead protection program must be required of subcontractors performing work that exposes employees to lead in order to protect their employees and other employees from lead hazards.
Each subcontractor should conduct a physical survey of the jobsite, prior to the start of work, and make a survey of the work to be performed by reviewing the drawings and conducting discussions with the owner, engineer, general contractor, and construction manager.
The general contractor's management team is responsible for informing all subcontractors of hazards present on the worksite so that the subcontractor can adequately protect his or her employees. General worksite safety programs that impact multiple employers such as lockout/tagout, right-to-know, and site emergency/evacuation procedures need to be covered with each subcontractor prior to the commencement of work. Arrangements for shared lead compliance provisions such as hygiene facilities, laundering facilities, personal protection equipment, and medical monitoring must be discussed in detail with prospective subcontractors.
SECTION 3: HAZARD IDENTIFICATION, ANALYSIS AND CONTROL
Effective hazard identification, analysis, and control strategies prevent workplace injuries and illnesses. The following activities are often used by employers to identify and control workplace hazards:
A. Site-Specific Safety Plans
A written site-specific safety plan should be developed from the outset of work to describe the construction sequence and consider safety and health programs needed as the site progresses. Preparing a site-specific safety plan also ensures that preplanning for fire, rescue, first aid, and site evacuation are considered. In addition, a site-specific safety plan helps to identify activities that will require employee training.
In general, a site-specific safety plan is developed in the following manner:
A model site-specific safety plan for a bridge RR&D site is found in appendix M.
B. Jobsite Safety Inspections and Industrial Hygiene Monitoring
Safety inspections of the jobsite need to occur regularly and frequently, and especially when jobsite conditions change or whenever a new process or procedure is implemented. These inspections should focus on the identification and correction of potential safety and health hazards. Recently, OSHA has begun a program to inspect jobsites for the four types of hazards that most often cause fatalities and serious injuries on jobsites. This program, called the "Construction Focused Inspections Initiative" focuses on falls, struck-by hazards, caught-in or between hazards, and electrical hazards. A summary of the Focused Inspections Initiative is found in appendix L; however, OSHA’s policies regarding focused inspections change frequently. The nearest OSHA Area Office should be consulted for the most current policy regarding focused inspections. Focused inspection issues are highlighted in chapter 3 of this guide, "Safety Programs, Practices, and Procedures."
Sometimes, health hazards are identified that require industrial hygiene assistance to evaluate and control the hazards, and the necessary industrial hygiene resources should be obtained. For small contractors, OSHA 7(C)(1) consultants and many workers' compensation insurance carriers can provide free or low-cost industrial hygiene services.
Qualified or competent persons conducting jobsite safety and health inspections should use the site evaluation worksheet (see appendix K). In addition, the "Safety Hazard Programs, Practices, and Procedures" in chapter 3 should be reviewed and mastered by personnel conducting safety inspections of the jobsite. Other tools that are useful in conducting inspections of worksites to determine the need for hazard control programs include job hazard analyses (see appendix P), failure mode and effect analyses (FMEA), operations hazard analyses (OHA), and fault-tree analyses.
As part of this safety and health program, the qualified/competent persons for each company jobsite:
C. Injury and Illness Records Review
Records collected on a project should be subject to a continuing analysis to detect illness and injury trends and to spot potential hazards that have not been addressed on the worksite. Examples of records that are useful in detecting injury trends and identifying workplace hazards include:
A thorough review of these records will allow for process and work practice changes to take place before an injury or illness occurs. Safety injury and illness records must be reviewed on a frequent basis.
D. Accident and Illness Investigations
All accidents and illnesses should be investigated to determine causal factors and prevent future recurrences. In addition, near misses that could have resulted in injuries and illnesses should also be investigated.
Whenever an accident is reported, the supervisor of the injured worker(s) should respond to the scene of the accident as soon as possible. After prompt medical attention has been provided to the injured, a copy of the supervisor's injury and illness report must be filled out (see appendix B). All witnesses should be interviewed privately as soon as possible after the accident. If possible, the supervisor should interview the worker(s) at the scene of the accident so that events leading up to the accident can be reconstructed. Photographs should be taken as soon as possible after the accident and include the time and date taken.
Any accident that involves a fatality or the hospitalization of three or more employees for in-patient treatment must be reported within 8 hours to the State or Federal OSHA office that has jurisdiction over the location of the jobsite.
A written report of investigation findings should be prepared by each injured employee's supervisor and submitted to management (the site superintendent) for review. Written reports for accidents resulting in fatalities or serious injuries should also be submitted to company attorneys.
An effective accident investigation report answers the questions: who, what, when, where and how:
E. Project Safety Meetings
A periodic (at least monthly) project safety and health meeting should be conducted on each construction project to provide all affected parties with relevant information concerning existing or potential jobsite hazards, corrective actions, and/or abatement. Minutes for each from these meetings should be recorded and a copy sent to the corporate safety office. Copies of the meeting minutes should also be posted on bulletin boards accessible to employees.
The following parties should attend these monthly safety meetings:
F. Hazard Correction Plans
Many employers have found it useful to incorporate into their safety and health efforts a formal plan to ensure that hazardous conditions are promptly corrected and not ignored. An example of such a plan follows:
"Unsafe or unhealthy work conditions, practices, or procedures shall be corrected in a timely manner based on the severity of the hazards. Hazards shall be corrected according to the following procedures:
SECTION 4: TRAINING AND EDUCATION
All employees, from superintendents to journeymen and apprentices, must receive safety education and training for the work they perform. The training needs to meet certification requirements where specific training requirements apply, such as for lead-in-construction and right-to-know. Any training provided to employees should be documented with dates, attendees, and an outline of topics covered. Additionally, all training must be provided by qualified instructors. Common types of safety training include:
A. New-Hire Safety Orientation
New employees or current employees who are transferred from another project should attend a project specific new-hire safety orientation prior to the start of work. This program provides each employee the basic information about the company project-specific safety and health plan, Federal and State OSHA standards, and other applicable safety rules and regulations. Employee attendance is mandatory prior to working on the construction project. To adequately document the new-hire training, a form such as the New Hire Safety Orientation Form (appendix C) should be filled out by the person providing the training. Following the training, the form should be signed by the employee, and a copy of the form provided to the employee. The original signed copy should be kept by the employer.
The project safety orientation program should introduce new employees to:
In addition to participating in the new-hire safety orientation, the employee should complete refresher training at intervals established by the employer. Any refresher training or new-skills training should also be documented as discussed above. A form similar to appendix D can be used to record and document training activities.
Additional training should be completed if workers:
C. Supervisor Training
The supervisor/foreman is responsible for the prevention of accidents for tasks under his/her direction, as well as thorough accident prevention and safety training for employees he/she supervises. Therefore, all supervisors/foremen must receive training so they have a sound theoretical and practical understanding of the following:
In addition to the training requirements described above, site superintendents should receive additional training on, but not limited to, the following topics:
Similar to training provided to employees, any training provided to supervisors should also be documented. The form in appendix D can be adapted to document supervisor training.
D. Safety Bulletin Board
A safety bulletin board should be located on each jobsite where it will be visible to all employees. The bulletin board should contain information such as:
Additional items may be posted with the site superintendent's approval.
As part of the safety bulletin board, a Safety Suggestion Box could also be mounted to solicit suggestions regarding any safety and health issues of concern to workers.
E. Toolbox Meetings
Supervisors/foremen should conduct weekly work group sessions, also known as toolbox meetings. These toolbox meetings may be held more frequently depending on the circumstances (i.e., injuries, new operations, etc.) On large jobsites with multiple crews, the supervisor/ foreman provides appropriate materials (handouts, audio/visual aids) to discussion leaders in advance of each meeting. Discussion leaders should be selected for each meeting by the supervisor/foreman and trained in the materials they will present.
These weekly meetings should be short - 15 to 30 minutes - but long enough to cover the training topic. Active employee participation and a question-and-answer session are recommended during each meeting. The content of the toolbox meetings should reinforce the basic safety and health training provided prior to the beginning of a job, and should cover topics pertinent to the nature of the ongoing work and hazards. Possible discussion and training resources for toolbox safety meetings include:
Meetings should also be scheduled whenever new operations are introduced into the workplace to ensure that all employees are familiar with the procedures and requirements for performing the job safely.Employee attendance at toolbox meetings should be recorded on the Employee Training Record Form (see appendix D) or a similar form. If discussion at the meeting identifies a suspected safety or health hazard that cannot be corrected immediately or requires expertise, a notice of the hazard must be forwarded to the site superintendent and/or safety and health committee so that steps can be taken to eliminate or manage the hazard.
SECTION 5: RECORDKEEPING
Various types of reports are necessary to meet the recordkeeping requirements of OSHA, insurance carriers, and other government regulatory agencies. Additionally, some clients may require additional site recordkeeping requirements.
The company should establish uniform recordkeeping procedures for all jobsites to measure the overall safety and health performance of each project.
A. Injury and Illness Records
OSHA requires each employer with 10 or more employees to record and maintain injury and illness records. These records are used by management to evaluate the effectiveness of the safety and health programs. The safety director or equivalent management officer shall be responsible for the following:
In accordance with OSHA requirements, medical and exposure records have to be maintained for 30 years from the time of the end of an employee's employment unless a different retention period is specified by a specific standard. These records are confidential information and should remain in the custody of the safety director or other designated individual. Information from an employee's medical record should only be disclosed to the employee, his/her designated representative with written consent from the employee, and to company officials with an occupational health need for gaining access to those records.
C. Training Records
Training records should be maintained by designated persons such as the safety coordinator or site superintendent. Exactly who maintains the records is a matter of organizational preference; however, the location of the records should be known to all. Training records should be made available for review by employees and other interested parties upon request.
D. Employee Access to Records
Each employee, or their designated representative as defined by 1926.33(c)(3), has the right to review all medical records developed in compliance with health and safety standards. These records may consist of documents such as baseline audiometric testing records and medical surveillance records such as specific tests for blood lead levels. All records are kept confidential to ensure the privacy of the worker. Employees must be given access to their medical and exposure records, but must also give reasonable time to the employer to produce these records.
All employees must be informed by posted notice of the existence, location, and availability of medical exposure records at the time of initial employment and at least annually thereafter. The name of the individual responsible for maintaining and providing access to these records must also be communicated annually.
SECTION 6: EMERGENCY PLANNING
Each construction project must have adequate procedures for contingencies such as fire, medical emergencies, communication, rescue, and evacuation. Provisions for these programs should be determined before work begins and should be outlined in the site-specific safety plan. (see appendix M)
A. Jobsite First Aid Log
First aid supplies and certified, trained personnel must be available for the treatment of personnel injured on the job. It is also imperative that all treatments are documented in the construction first aid log. Prompt medical attention should be sought for any serious injury or if there is doubt of an employee's condition. A first aid log (see appendix E for sample log) should be maintained in the site first aid facility or another designated location. This log should reflect the following information:
It should be noted that the cases noted on the first aid log are usually not entered into the OSHA 200 log unless follow-up medical treatment is provided. According to OSHA (as referenced in its April 1986 publication "Recordkeeping Guidelines for Occupational Injuries and Illnesses"), medical treatment includes "treatment (other than first aid) administered by a physician or by registered professional personnel under the standing orders of a physician." It does NOT include first aid treatment even though it is administered by a physician or registered professional personnel.
B. Emergency Procedures
Emergency Phone Numbers
At each jobsite, the emergency phone numbers of police, fire, and ambulance services should be conspicuously posted. Medical treatment facilities near the jobsite such as hospitals, walk-in emergency centers, or industrial medical centers should be identified, and their phone numbers posted. In addition, the emergency phone numbers for top company management should be available on the site.
Injury and Illness
All employees need to be told the locations of the first aid stations on each construction project. Instructions for using first aid equipment should be located in each station. In the event of an emergency, employees should contact any supervisor or individual who is trained in first aid. Supervisors and employees trained in first aid should be available, visible, and identifiable. Trained first-aiders may be identified by wearing a first aid emblem on their hard hat or jacket. First aid providers must also have the capability of requesting the immediate assistance of outside emergency medical technician and rescue personnel.
Prompt reaction to, and rapid suppression of, any fire is essential. According to OSHA’s 1926.24, the company must develop an effective fire protection and prevention program at the jobsite throughout all phases of the construction. The program should at least provide for effective firefighting equipment to be available without delay and that is designed to effectively meet incipient-stage fire hazards as they occur. In addition the fire protection program shall require that:
If necessary, a trained and equipped firefighting brigade must be established to ensure an adequate fire protection level.
Some emergencies may require company personnel to evacuate the jobsite. In the event of an emergency that requires evacuation, an alarm or other notification system must sound to alert employees to evacuate the site. All employees are required to go the area adjacent to the project that has been designated as the "safe area." It should be noted that the safe areas can change from day to day depending on wind directions and other factors. The alarm system signal and safe areas for each project must be determined and communicated to employees and subcontractors as part of the basic safety and health training covered in the project safety meetings prior to the beginning of the job and must be updated as necessary. (See appendix M).
Job-Specific Rescue Requirements
In addition to these general emergency response procedures, some construction activities may require special rescue and emergency response procedures. For example, specific rescue and response procedures apply for:
Some of these rescue activities may be accomplished by company employees who have received proper training in rescue procedures, while other types of rescue and emergency response may require outside help from the fire department or rescue squad. Prior to each job, however, special rescue and emergency response requirements must be considered in the site-specific safety plan. (See appendix M)
TRT Terms: Bridges; Maintenance; Occupational safety; Lead (Metal)