Worker safety should be a top priority for all companies, especially in construction, where risks tend to be high and routine. The top 10 citations seldom change from year to year, and are normally released by Cal OSHA at the end of the year. 2020 has not been a typical year in many ways, however. Because of this, we are still very much looking at the 2019 list.
This does not, thus, include COVID-19 related violations, however, the most cited issue in 2019 was already issues related to the Injury & Illness Prevention Program, so it’s reasonable to assume that COVID-19 has exaggerated this trend rather than changing it. So let’s talk about the top five.
Injury & Illness Prevention Program (IIPP)
California employers are required to have an Injury & Illness Prevention Program that covers such issues as indoor air quality, hearing protection, and slip, trip, and fall protection. It’s unsurprising that most violations are related to the program as it covers the biggest workplace hazards. Many of these violations are technical or training violations. Training is key to prevention, and has been particularly hard to conduct during the pandemic; many companies are now turning to automated training programs that send information through phone apps as a substitute for classroom training. If using such a program, make sure that your IIPP is updated appropriately and that the training program you choose is up to code, as it were, as well as focusing on areas of particular concern.
You also need to make sure that you abide by AB-685, which has requirements for COVID-19 notification; this is a new law that appears complicated, but essentially says that you have a responsibility to notify employees and contractors who may have been exposed and report outbreaks to the health department.
Heat illness is also a particular problem for construction workers (as well as for agricultural workers and anyone else who works outdoors). Cal-OSHA requires that supervisors and employees who are routinely exposed to higher temperatures take an annual training course. The standards require that you provide access to shade, have employees observe each other for signs of heat illness, and take appropriate cooldown breaks. It’s vital, thus, to ensure that all employees know the risk factors for heat illness, the symptoms, and simple mitigation techniques such as drinking sufficient water.
You are also required to have a heat illness prevention plan, and this is one area where many employers fall short; the plan must be in writing and discuss provision of water, access to shade, acclimatization methods and emergency response. Heat illness can be a serious problem for those working outdoors in Southern California, and education about the symptoms as well as provision of water and shade make a huge difference.
Construction Injury and Illness
Standards specific to construction are third on the list. While all employers are required to have an injury and illness prevention program, construction falls under a specific category due to the specific risks, especially falling risks. Nationwide, slips, trips, and falls are the most common cause of personal injury in the workplace.
Appropriate fall protection is one of the most important things you can do to keep your employees safe. Depending on the circumstances, this might include harnesses, guard rails, etc. Education is also important to ensure that employees use fall protection equipment (especially active fall protection such as harnesses) consistently and appropriately. Many injuries happen when an employee fails to properly secure their harness to the line. Your plan must also address other hazards, such as protection from inhaled dust and dirt.
Control of Hazardous Energy
Hazardous energy is an issue for any worksite that uses electrically powered machines. A big issue is lockout and tagout, that is to say the procedures used to ensure that machines are properly turned off before maintenance works on them. These steps need to be laid out as a specific protocol, and citations often happen when lockout and tagout procedures are not properly documented or documented in the correct place, or when hardware used for locking out is not correctly stored or substantial enough to prevent inadvertent removal.
As with everything else, training on the procedures is essential, and employees need to be aware that ignoring tagout protocols can result in injury or death. Only authorized employees should be allowed to apply and release lockouts, so as to ensure that they are always done correctly and that employees are clear of the area before a lockout is released. Although this is generally more of a problem for production lines, the correct locking out of construction equipment is vital to prevent accidents and worse that can happen when a machine is unexpectedly energized and moves.
In this context, hazard communication refers primarily to identifying and communicating the hazards of chemical exposure. It requires that chemicals are classified and that you provide information to employees about hazardous chemicals they might be exposed to. Generally, this takes the form of safety sheets that give information such as the kind of hazard present, but it also includes training on the hazards of non-routine tasks.
In the construction industry, hazardous chemicals include solvents and paints, which can cause irritation with extended exposure. Some insulators have been associated with dioxin exposure, which can cause cancer. Hazard communication must be clear, accurate, and employees should be trained on the chemicals present and the appropriate PPE to use to reduce exposure, especially long-term chronic exposure which can cause delayed problems such as cancer or reproductive challenges.
By understanding which issues attract the most Cal-OSHA citations, companies can avoid not just citations but very real safety issues that can cause illness or injury. This can help develop plans and training that help keep your workforce safe, avoid fines and citations, and avoid downtime caused by accidents.
As a company that specializes in mitigating environmental risk during acquisitions, Essel Environmental Consulting can also help protect your workforce from environmental and other hazards. We can give you advice on how to manage risk and keep everyone safe, especially when renovating or reconstructing your new acquisitions.
Contact our Safety experts at Essel Environmental to assist you with a Free Safety Audit.