Pre-Work Start-Up Safety Checklist for Contractors

Gary Auman

Gary Auman (www.dmfdayton.com) is a Partner in the law firm of Auman, Mahan & Furry in Dayton, Ohio. He graduated with an electrical engineering degree from the University of Louisville in 1969, and a law degree from The Ohio State University in 1976. Since then, his practice has focused on defending employers in workers’ compensation and OSHA cases. In 2002, Mr. Auman was awarded the Distinguished Service to Safety Award by the National Safety Council. He has worked with OSHA in its development of safety and health standards, and he has defended OSHA cases in several federal appellate courts. Mr. Auman also represents 4 national and regional trade associations in the construction industry. He can be reached at gwa@dmfdayton.com.

October 1, 2013

Regardless of size, safety should be a key
component of every job, and contractors should make safety planning a priority
when they are creating their bids. The cost of having a safe job site should be
considered and made part of the bid; and if the contractor gets the job, it
should be treated as an integral part of the project. When contractors visit
job sites to obtain project information, they should also be evaluating safety
concerns to outline what is needed to finish the job safely and in compliance
with all applicable codes, standards, etc.

When assessing a job site, it is important to keep in mind what you need
to accomplish and anything you may need on site when you start the job. Once
you have a contract, it is time to make decisions about the things you need to
have before you begin work.

The following is a starter list of points to consider before beginning
any project (or workday):

  1. Identify
    the employees who are going to make up the project crew. Confirm that each
    employee has received the necessary safety training to
    perform the job safely. This includes the use of any personal protective
    equipment (PPE), hazard recognition, and steps to take if they perceive a
    potential hazard exposure.

  2. Confirm
    that your Safety Director, Consultant, or the individual responsible for safety
    has a site safety plan for this project. This should include a job hazard
    assessment.

  3. Confirm that if any exposure assessments are
    required, they have been or will be completed on the first day. If the exposure
    assessment is being performed on the first day, ensure that all employees are
    being protected at the level required by the Occupational Safety and Health
    Administration (OSHA) until the results of the exposure assessment are known
    .

  4. Keep
    a copy of your company safety program on the job site, along with a copy of
    your company’s hazard communication program.

  5. Ensure that sufficient PPE is on site for all
    employees.

  6. Make
    sure that all PPE on site has been inspected, is in good condition, and is safe
    to use.

  7. Whenever possible, assign a well-trained, competent
    person to work at the site. Alternatively, schedule this person to visit the
    job site several times a day to perform necessary safety walk-around
    inspections and ensure that all employees are working in compliance with all
    company safety rules. Remember that some OSHA standards have requirements
    beyond the basic guidelines for a competent person that apply to the areas
    covered by those standards.

  8. Be certain that management on the job site knows
    how to respond to a visit from a federal or state OSHA representative, how to
    conduct an accident investigation, and how to perform regular safety audits.

  9. Secure
    someone to determine the predicted heat index for the day, or—in the case of
    cold work—the projected low temperature, and arrange appropriate safeguards for
    either situation.

  10. If
    scaffolding is to be used on the project, ensure that it is designed and
    erected by qualified and competent persons.

  11. Be certain that any ladders on the job site erected
    by your employees or to be used by your employees are properly put up and tied
    off, and that the ingress and egress points to the ladders are guarded
    from displacement.

  12. Have a procedure in place to identify damaged or
    unsafe equipment, tag it, and remove it from the worksite until properly
    repaired. This procedure should include employees trained to identify damaged
    and/or unsafe equipment.

Upon arriving at the job site,
the contractor should also check safety compliance by confirming that the job
site is completely prepared for work in regard to safety standards. In addition
to following all state and federal regulations, contractors should:

  1. Address
    all fall protection issues. These include, but are not limited to, ensuring
    that warning lines or guardrails are properly erected (where appropriate),
    personal fall-arrest equipment is in place, and adequate anchors are in place
    for the personal fall-arrest equipment. It is also important to make sure that
    employees are wearing their personal fall-arrest equipment correctly.

  2. If scaffolding is going to be used, ensure that it
    is properly erected. This includes, but is not limited to, barricading areas
    under scaffolds to prevent anyone from passing or working below employees who
    are on the scaffold. Additionally, make sure all guardrails and toe boards are
    in place for any scaffold work areas more than 10 feet above the ground.

  3. Be sure that all employees are wearing proper personal
    respiratory protective equipment if an initial exposure assessment is being
    performed or if it is deemed necessary by the completed exposure assessment.

  4. Walk
    the site and ensure that all floor holes, holes in walls, and open-sided floors
    are either covered correctly or guarded.

  5. Check
    the use of electricity on the job site. Use ground fault circle interrupters
    (GFCIs) wherever necessary, and verify that all electrical cords are undamaged
    and have 3-pronged plugs in place.

  6. Properly
    label all containers of hazardous materials on site and ensure that copies of
    all safety data sheets are readily available to all employees on the site, and
    all employees have been trained to read the safety data sheets and the labels
    on all hazardous materials.

  7. Determine if any other contractor’s employees or
    the customer’s employees will be on the site; this may create hazards for your
    employees. If this is the case, take all steps necessary to protect
    your employees and other personnel from potential hazards.

  8. Provide
    sufficient cool, potable water on site for all of your employees if you will be
    working in a high-heat environment. In addition, make sure cooling-off areas
    are available and are located in relative close proximity to where your
    employees will be working.

  9. Ensure
    that any powered equipment that you may have on site has been inspected for
    safety issues before any employees are permitted to operate it, and all
    necessary safety inspection forms have been properly completed. Also, make sure
    that any employees on site who may be tasked to operate such equipment have
    been properly trained and that training documentation is on file.

  10. Confirm
    that all employees on site have been properly trained in all aspects of safety,
    including, but not limited to, hazard recognition. 

This list is not intended to
cover all points for safety consideration on every job site, but it is meant to
share basic safety guidelines. Every job site is unique and will present
different safety concerns, which is why a job safety analysis is essential to
identify all of the safety issues on each job site. Please also check state and
federal guidelines and laws, as well as with your own safety experts, to ensure
each job site is compliant and safe for your personnel.