Regular and frequent safety hazard inspections are required by OSHA standards. Studies have shown that inspections reduce incidents and injuries, and the business case is there for all employers to conduct and plan for inspections. A 2012 comparative study found that even random inspections decreased injuries and incidents by nearly 10%.
But the inspection process should not be limited to the identification of hazards. Rather, it should prioritize identifying hazards early and often—before a formal OSHA inspection—and implementing corrective actions to eliminate recurrence.
Regardless of OSHA’s enforcement efforts, construction companies should be conducting regular hazard identification inspections to protect workers from identified hazards and their companies from future liability. Here are three ways to ensure your in-house hazard inspections are most effective.
1. Create and maintain a regular schedule for hazard identification inspections.
OSHA does not clearly define “frequent” or “regular” within its construction standards. If we search the entire OSHA standard, we find a few references to frequent and regular.
One example is the crane standard 1926.1412(h), which loosely defines “regular use” as a three-month period. If we expand our review to the general industry standard, we find the gantry crane standard 1910.179 defines frequent inspections as “daily to monthly intervals.” Also, in the industry, the term “periodic” is used in lieu of “frequent” and is defined as one- to 12-month intervals.
Considering these varying recommendations throughout OSHA standards, inspections should be done on a regular schedule that works well for your company—whether daily, weekly, monthly or a combination. This could even be on a shift or per-use schedule. What is most important is establishing a standard that works for your business and creates a strong case for compliance in case of an OSHA inspection.
2. Involve multiple employees from various trades and levels of the business.
Your business should conduct its inspections using more than one employee to avoid accusations of bias. Typically, the onsite supervisor would conduct these inspections, but to be most effective, inspections should be done as a team, involving craft workers, supervisors and other stakeholders. Each will have a different perspective on hazards found on the job.
In the case of construction, OSHA uses the Multi-Employer Citation Policy to expand the “team approach” and put some regulatory backing to this concept. General contractors have oversight and control over subcontractors, but OSHA’s position is that GCs and subs bear the same or greater role in hazard inspections.
OSHA also encourages involving employees with different roles on the job to make it easier to identify hazards created by other trades that could affect other workers and require reporting and remediation. This policy places the responsibility for regular and accurate inspections more equally on all workers or stakeholders on a jobsite.
3. Determine a plan for correcting potential hazards in a timely and organized manner.
Simply identifying hazards is not enough. Employers need to correct potential hazards in a timely manner and track the findings.
According to the National Institute for Occupational Safety and Health’s Hierarchy of Controls, there are five tiers of response to consideration: elimination, substitution, engineering controls, administrative controls and personal protective equipment. Using this hierarchy, employers should first work towards implementing solutions that eliminate the hazards, rather than changing administrative controls or personal protective equipment practices, which do not eliminate the hazard but rather inform, limit or place a barrier between the worker and the hazard.
Tim Neubauer is president and owner of Exceed Safety in Raleigh, North Carolina. His experience spans three decades in the application of safety principles while in the field. Neubauer holds a master's in occupational safety and health and is a certified safety professional with knowledge in a wide range industries, specializing in construction health and safety. He has worked with the National Safety Council and their affiliates for more than 20 years and has facilitated Advanced Safety Certificate courses as an instructor. Neubauer was also an OSHA OTI Level 500 instructor in Region 5 and a certified National Center for Construction Education and Research instructor.