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Publication Number: FHWA-RD-98-180
Safety and Health on Bridge Repair, Renovation and Demolition Projects
Table of Contents
BACKGROUND, OBJECTIVE, AND PURPOSE OF THIS DOCUMENT
More than 5,000 bridge rehabilitation and repainting projects are performed each year that have the potential for exposing workers to lead. Laborers, ironworkers, and painters are the most severely lead-exposed worker populations associated with bridge renovation, repair, and demolition (RR&D) work. In recent years, lead exposures to some workers have increased to even greater levels than in the past as a result of their working inside containment structures that are required to reduce lead contamination to the environment.
In October 1992, Congress responded to the national lead-based paint hazard with the passage of the Residential Lead-Based Paint Hazard Reduction Act. That Act, commonly known as Title X, contains provisions specifically related to work performed on bridges and steel superstructures and to demolition. Among those provisions was the requirement that the Occupational Safety and Health Administration (OSHA) promulgate an Interim Final Standard for Lead in Construction applicable to all construction activities. On May 4, 1993, OSHA issued this interim final standard at 29 CFR Part 1926.62. That comprehensive standard applies to highway infrastructure projects activities where workers may be occupationally exposed to lead.
Work in the construction industry, including bridge repair and renovation projects, poses other safety risks to workers, including falls from elevations and being struck by vehicles. Construction work has the highest lost time injury rate of all the major economic sectors in the United States and accounts for billions of dollars of losses to workers and contractors each year.
In an effort to reduce the toll of fatalities, injuries, and illnesses in construction, increasing emphasis is being given to the creation and implementation of effective safety and health programs. The effective application of management practices in the implementation of safety and health programs is designed to benefit both employers and workers by reducing injuries and illnesses.
In a recent initiative, OSHA established a Focused Inspection Program for construction that recognizes the efforts of contractors who have implemented effective safety and health programs. Contractors with such programs will qualify for a Focused Inspection in which the OSHA compliance officer's inspection will "focus" only on the four leading causes of death and injury among construction workers (falls from elevation; struck by; caught in/between; and electrical hazards). For those contractors who do not have effective safety and health programs, the OSHA compliance officer will conduct the traditional "wall-to-wall" inspection. OSHA is also in the process of drafting a proposed regulation that would require contractors to develop comprehensive safety and health programs. With regard to construction lead, OSHA has recently instituted Special Emphasis Programs that focus specifically on its new construction lead standard, including inspections of bridge projects where lead-based coatings are being disturbed.
In an effort to help contractors develop effective safety and health programs for work on bridges involving lead paint disturbance, the Laborers' Health and Safety Fund of North America (LHSFNA) has received a grant from the Federal Highway Administration (FHWA) entitled "Health and Safety Related Aspects of Bridge Rehabilitation and Restoration" (Grant Agreement DTFH61-95-X-00004). Under this grant, the LHSFNA has prepared a written guideline document for the purpose of assisting bridge contractors in the development, improvement, and implementation of a comprehensive safety and health program for projects where lead-based coatings are to be disturbed. The guideline for establishing the safety and health program is intended to be comprehensive in that it addresses both health and safety hazards associated with work of this nature.
To prepare a guideline that addresses the specific concerns and issues affecting contractors who are engaged in this type of work, a technical workshop was held from May 31 to June 2, 1995. Workshop participants included invited safety and health experts from all the affected constituencies, including contractors, labor, government, and trade associations to prepare a consensus draft document (see Appendix O for list of attendees). This document, entitled "Safety and Health on Bridge Repair, Renovation, and Demolition Projects," is the resulting product of that technical workshop.
HOW TO USE THIS GUIDELINE
The "Safety and Health on Bridge Repair, Renovation, and Demolition Projects" guideline has been prepared for use by contractors who are engaged in work of this nature. It is designed to assist contractors in establishing, improving, and implementing a comprehensive safety and health program to address workplace hazards for workers who are employed on these projects. The overall objective is to provide guidance to contractors on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for construction workers performing activities and tasks associated with highway bridge projects.
The guideline is designed to be comprehensive in that it addresses both safety and health hazards that confront contractors and workers on the job site for work of this nature. As such, this guideline is not designed to address issues related to the impact that these projects may have on the environment nor the health and safety of the general public.
This document is, as its title states, a guidance reference for contractors to use for the establishment of and improvement in their management practices in the design and implementation of a safety and health program. It is not a "cookbook" document for contractors to "fill in the blanks" as a means to claim that a safety and health program is in effect. Rather, it is written in such a manner as to guide the bridge contractor through the elements and issues that must be considered in the establishment of their own safety and health program.
The manual is organized by chapters that move sequentially from the general requirements for essential elements in any safety and health management program (chapter 2), to safety and health programs, practices, and procedures (chapters 3 and 4), to compliance with lead-specific issues encountered in this work (chapter 5). In addition, a number of items in the Appendices are provided to further assist contractors in developing their own programs.
Because the guideline deals with workplace health and safety issues affecting employees who work on bridge maintenance and construction projects, references are made to the relevant OSHA regulations that are applicable to construction work. Where workplace conditions on a given job create or have the potential to create hazards where OSHA standards apply, employers are required to comply, as a minimum, with these OSHA requirements. Nevertheless, contractors may wish to consider implementing practices and policies that go beyond that required by OSHA if they represent sound industry practice.
The guideline attempts to comprehensively address the health and safety issues that are reasonably anticipated to occur on highway bridge work where lead paint is disturbed. All such issues will not affect all contractors nor will all hazards be present on any given job site. Those who use this guideline are advised to utilize those chapters and sections that are applicable to the work they perform on a specific project. Likewise, the guideline outlines only some elements of some of the OSHA regulations that may typically be applicable to this work. In that regard, in order to fully comply with applicable OSHA requirements, contractors must consult with the most recent publication of Federal or State construction standards for the purpose of achieving compliance. This guideline is not to be used as a substitute for those legal responsibilities of the employer.