Before You Start: Safety Checklist for Contractors
A similar article was written on this topic 11 years ago. From a safety perspective, much has remained the same, but OSHA is now more aggressive. Safety should be a key component of every job, regardless of size, and contractors should prioritize safety planning when they are developing their bids. The cost of maintaining a safe jobsite 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. Not only will this greatly reduce the potential for expensive enforcement actions by OSHA, but it will also greatly reduce the likelihood of serious and costly injuries on the job. When contractors visit jobsites to obtain project information, they should also evaluate safety concerns to outline what is needed to finish the job safely and in compliance with all applicable codes, standards, etc.
When assessing a jobsite, it is important to keep in mind what you require to accomplish the job safely, as well as the things you may need on site when you start work to ensure the safety of all employees. Once you have a contract, it is time to put into effect those things you identified during your pre-bid assessment and make decisions about what you must have before you begin work.
The following is a starter list of points to consider before beginning any project (or workday). The steps and requirements may change as the regulatory environment changes.
- 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 and that the training has been properly rendered and appropriately documented. This includes the use of any personal protective equipment (PPE), hazard recognition, and steps to take if they perceive a potential hazard exposure. This training should include their initial new-hire orientation, as well as jobsite orientation for the location where they will be working.
- Confirm that your Safety Director, Consultant, or other individual responsible for safety has a site safety plan for this project. This should include a job hazard assessment. From a workday perspective, ensure that each employee on the crew has completed a Pre-Task Plan (PTP) or received a documented safety briefing by the Site Supervisor covering the work to be performed that day.
- Be sure that the site competent person, or your site or branch Safety Representative, has surveyed the site and identified all confined spaces. Be sure that all confined spaces are correctly labeled, and that all Permit Required Confined Spaces (PRCS) are so labeled with an appropriate sign, including a “DO NOT ENTER” warning. Document this assessment and the completion of this task.
- Confirm that if any exposure assessments are required, they have been or will be completed on the first day. These assessments should be in each employee’s breathing zone. If the exposure assessment is being performed on the first day, ensure that all employees are protected at the level required by OSHA until the results of the exposure assessment are known. If the assessment indicates that personal respiratory protection needs to be worn, be sure each employee who will need to wear such protection has completed the assessment required by OSHA Standard 1910.134 (this will include completion of the required questionnaire, as well as any testing).
- Keep a copy of your company safety program on the jobsite, along with a copy of your company’s hazard communication program.
- Ensure that sufficient PPE is on site for all employees.
- Make sure that all PPE on site has been inspected, is in good condition, and is safe to use. In addition, every employee who will wear PPE should inspect it before they wear and rely on it for protection.
- Whenever possible, assign a well-trained competent person to work at the site most employers in the construction industry qualify each Site Supervisor or Foreperson as a competent person. Alternatively, schedule this person to visit the jobsite several times a day to perform the necessary safety walk-around inspections and ensure that all employees are working in compliance with all company safety rules. You should consider this a minimum requirement, and you should strive to assign a competent person to each jobsite to be there whenever work is being performed. Remember that some OSHA standards have requirements beyond the basic guidelines for a competent person that apply to the areas covered by those standards.
- Be certain that management on the jobsite 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 daily safety audits. Site safety compliance audits and inspections should be performed multiple times each day, and the results of the audits/inspections should be documented.
- Have someone on the site assigned as responsible for determining 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. The responsible person should monitor the heat index or low temperature during the entire day and take any necessary steps described in your heat illness or cold injury protection programs.
- If scaffolding is to be used on the project, ensure that it is designed by a qualified person and erected under the supervision of a competent person.
- Be certain that any ladders on the jobsite erected by your employees or to be used by your employees are properly erected and tied off, and that the ingress and egress points to the ladders are guarded from displacement. Be sure that any employees who will use ladders have been trained under and comply with your ladder safety program when erecting and/or using the ladders.
- Have a written procedure in place to identify damaged or unsafe equipment, tag it, document your inspection, and remove any such equipment from the work site until it is properly repaired. This procedure should include the methods you use to train employees to identify damaged and/or unsafe equipment.
Upon arriving at the jobsite, the contractor should also check safety compliance by confirming that the site is completely prepared for work in regard to safety standards. In addition to following all state and federal regulations, contractors should:
- Address all fall protection issues. These include, but are not limited to, ensuring that warning lines or guardrails are properly erected (where appropriate), that personal fall-arrest equipment is in place, and that 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; and, in the case of fall protection, are connected to their safety lines and anchors.
Ensure that any employee who might have ANY possibility of being exposed to a fall of more than 6 feet has been trained by a competent person, and that the person who provided the training has documented the date and time the training was performed. That person also should sign the training record as a competent person. These records should be maintained in each employees’ personnel file. - Ensure that all walking and working surfaces that may possibly be used by employees on the site, for any purpose and at any time, have been inspected, and that they have the integrity to support the weight of any employees on the site. Again, be sure this inspection has been documented. If any surface has been determined not to have the integrity to support the weight of any employee safely, be sure to take steps to improve the integrity of the surface. There are NO EXCEPTIONS to this requirement. Again, document your actions. You MAY NOT employ the use of any PPE to protect employees because you have not ensured the integrity of the walking or working surface.
- If scaffolding will 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.
- 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 a completed exposure assessment.
- Walk the site and ensure that all floor holes, holes in walls, and open-sided floors are either covered correctly or guarded.
- Check the use of electricity on the jobsite. Use ground fault circle interrupters on all extension cords or wherever else they may be necessary, and verify that all electrical cords are undamaged and have three-pronged plugs in place.
- Properly label all containers of hazardous materials on site, ensure that copies of all safety data sheets are readily available to all employees on the site, and make sure all employees have been trained to read the safety data sheets and the labels on all hazardous materials. Be sure the labels on any containers of hazardous materials are positioned so they can be read easily by all employees on the site.
- Determine if any other contractor’s employees, or the customer’s employees, will be on the site. These employees 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. Again, be sure your employees are trained to direct their full attention 100% of the time they are in the active work zone. The Site Supervisor, as well as all employees on the active site, should pay attention to employees of the customer or any other contractor(s) either on the active site or working in such a way that their activities may impact your employees.
- Provide sufficient cool, potable water on site for all 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. Be sure you have a heat illness prevention plan in place, and that it provides: 1) acclimatization procedures; 2) procedures to remind employees to hydrate, and that there is sufficient cool, potable water on the site for all employees to adequately hydrate; 3) a procedure for establishing a work/rest regimen; 4) cool rest areas in close proximity of the jobsite; and 5) training for all employees. Training should include the different types of heat illnesses and their symptoms, how to identify those symptoms in themselves and others, the first aid steps to take when they observe such symptoms, the importance of avoiding alcohol and caffeine when working in a high heat index environment, and the underlying physical and health conditions that can make a person more susceptible to heat illness than others.
- Ensure that any powered equipment you may have on site has been inspected for safety issues before any employees are permitted to operate it, and that 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 in accordance with the appropriate OSHA standard, and training documentation is on file.
- Confirm that all employees on site have been properly trained in all aspects of safety beyond those stated above—including, but not limited to, hazard recognition.
This list is not intended to cover all points for safety consideration on every jobsite, but it is meant to share basic safety guidelines. Every jobsite is unique and will present different safety concerns, which is why a job safety analysis is essential to identify all the safety issues on each jobsite. Please also check state and federal guidelines and laws, and consult with your own Safety Experts to ensure each jobsite is compliant and safe for your personnel. Remember, YOU ARE RESPONSIBLE FOR THE SAFETY OF YOUR EMPLOYEES ON ANY JOBSITE, and providing them with the appropriate PPE and training alone is not enough! You MUST have a consistent and objectively applied safety compliance/enforcement program.