| This was
presented to the 13th Annual Construction Safety Conference:
Building a Safer Nation, February 2003, in Rosemont, Illinois,
by OSHA compliance officer Mimi Thaung of the Dallas area office. |
- Background
Information on the Case
- Scope
of Activities
- Residential
Construction
- Multi-Employer
Policy
- Language
Barrier (Non-English Speaking employees)
- OSHA Citations
Issued
- Lessons
Learned
- RESIDENTIAL
CONSTRUCTION
- Custom,
single-family home builder/owner, 700 employees
- Construction
of custom home, 4297square foot and 33 feet, 7-inch in height
- Primary
Framing Subcontractor
- Husband
and wife business
- Secondary
Framing Subcontractor
- Work
crew of six employees
- One
employee was handing a rafter from the second floor, to a
coworker, who was standing on the frame work of the attic.
Employee fell 10-foot, 3-inches through floor opening along
with the 2'x8'x20'' rafter
- Safety
Guardrail System Company
Applicable OSHA
Standards
- 29 CFR
1926.501(b)(13), Subpart M - Fall Protection
- STD 3-0.1A
Interim Fall Protection Compliance Guidelines for Residential
construction
Definition:
Working environment, materials, methods and procedures are same as
those used in building a typical single-family home or townhouse.
- Materials
- Wood
framing (not steel or concrete); wooden floor joists and roof
surfaces
- Methods
- Traditional
wood frame construction techniques
- Construction
of discrete part of a large commercial building, such as wood
frame, shingled entranceway
- Four groups
of residential construction activities:
- Fatality
Rate (in Region VI, DAO):
- 81%
from falls in construction
- Number of
non-English speaking (in Region VI, DAO):
- At least
57% in construction, more in residential construction
- General
Contractor
- Primary
Framing Subcontractor
- Secondary
Framing Subcontractor
- Creating
- Exposing
- Correcting
- Growing
number of non-English Speaking workforce in construction
- Lack of
communication regarding safety procedures and policies
- Many employers
have not tailored company safety and health policies and safety
training to adequately train non-English speaking employees
- No efficient
methods to report safety hazards and concerns to the employer
- Employers
hire employees based upon inexpensive labor, not on prior job
experience
- Most Non-English
Speaking work force has no prior knowledge of OSHA
- Non-English
speaking employees, who have never worked in this country
GENERAL CONTRACTOR
29 CFR 1926.501 (b)(13)
29 CFR 1926.1052 (c)(1)
PRIMARY FRAMING SUBCONTRACTOR
29 CFR 1926.501 (b)(13)
29 CFR 1926.1052 (c)(1)
SECONDARY FRAMING SUBCONTRACTOR
29 CFR 1926.25 (a)
29 CFR 1926.100 (a)
29 CFR 1926.501 (b)(13)
29 CFR 1926.501 (c)
29 CFR 1926.1052 (c)(1)
- GENERAL CONTRACTOR
- Insured the installation of guardrail system along stairway,
balcony and floor opening
- Assist their subcontractors with the development of a detailed
fall protection plan
- PRIMARY FRAMING SUBCONTRACTOR
- Participated in a Spanish 10-hour construction safety course
sponsored by OSHA
- SECONDARY FRAMING SUBCONTRACTOR
- Sent all of his employees to the Spanish 10-hour construction
safety course taught by bilingual OSHA compliance safety and
health officers
- Review company safety programs and policies with all subcontractors
before starting work
- Hold safety meetings with all subcontractors before the start
of each phase or on a routine basis
- Establish effective communication with non- English speaking
work crew Need to perform documented, routine safety inspections
and communicate hazards with all parties who may be exposed.
- Follow up requested safety services, in this case, from Safety
Guardrail Systems Company
- Insure safety and health measures are handled in a timely manner
and taken beginning of each construction phase.
-
Established a Task Force consisting of framing and general contractors
-
Obtained 150 % employer participation from other states to develop
a uniform fall protection plan
-
Developed a 10-hour Construction Safety and Health Training
-
Conduct the 10-hour Construction Safety and Health Training in both
Spanish and English, on a monthly basis
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