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Fall protection, ladders and trenching are routinely three of the most frequently cited Occupational Safety and Health Administration construction standards. For Fiscal Year 2019, OSHA reported that the construction industry’s Fall Protection standard (1926.501) was its most frequently cited standard, and the Ladders standard (1926.1053) as its sixth-most cited standard. While trenching was not within the top six most-cited standards, OSHA created a National Emphasis Program for trenching and excavations in 2018, and routinely cites employers under the NEP.

Given the risks associated with working from heights, on ladders and in excavations, there are common requirements for each of these areas and recommended strategies to improve employee compliance.

Fall Protection

Falls are the cause of more than one-third of construction deaths. As such, employers must be vigilant in creating, implementing and enforcing their fall-protection policies to prevent injury or even death, and to defend against potential citations. Generally, OSHA’s Construction Industry Fall Protection Standard (1926.501) requires the use of fall protection (guardrails, safety nets or personal fall arrest systems) when workers are working above 6 feet and may be exposed to holes, skylights and unprotected sides or edges. 

To prevent accidents and illnesses, employers must adequately train their employees on the proper use and care for fall protection. Many employers accomplish this through annual trainings with a third-party vendor. Regardless of who provides the training, the employer should keep records of both the training content and the attendance sheets in their file. Additionally, employers should require employees to create a fall protection plan at each job site that covers how each job task will be performed while the employee remains tied in (or while using guardrails or safety-net systems). Such an analysis will assist in identifying areas where certain types of fall protection may be infeasible or may require additional planning. 

A fall-protection program is only effective if employees follow it. To ensure employee compliance, employers must routinely inspect the site. Such inspections likely will involve periodic walkarounds by supervisors or foremen to ensure employees working at heights follow required protocols. Random audits from an Environmental Safety & Health Manager will also confirm that such inspections are routinely being performed by lower-level foremen or supervisors.

Finally, the employer must consistently enforce its policies through discipline. If one of these inspections or audits uncovers a violation, then the employer must discipline accordingly. Otherwise, such behavior remains uncorrected and OSHA will likely cite the employer for failure to enforce its fall-protection program if an accident or complaint gives rise to an inspection. 

Ladders

Ladders are yet another fall-related hazard in OSHA’s top 10 most frequently cited citations. While the construction-industry ladder standard (1926.1053) also covers the use of fixed ladders, this article will focus on the use of portable self-supporting and non-supporting ladders. Hazards focused herein are on proper load rating, setting and use of ladders.

Loads

Self-supporting ladders, such as fold-out or a-frame ladders, and portable ladders must be able to support at least four times the maximum intended load. The exception to this is extra-heavy-duty metal or plastic ladders which must be able to sustain 3.3 times the maximum-intended load.

Proper Setting and Angle

Non-self-supporting ladders should be positioned at an angle where the horizontal distance from the top support to the foot of the ladder is approximately 1/4 the working length of the ladder. For job-made wooden ladders, that angle should be approximately 1/8 of the working length of the ladder to minimize strain on ladder joints that may not be as strong as their commercial counterparts. 

Ladders should be set on a firm, level and dry surface to prevent slippage. Additionally, a spotter employee may be used to hold the base of the ladder for stability. Before setting the ladder, the user must look for and avoid overhead powerlines. When working in proximity to such power lines an insulated, non-metal ladder should be used. Employees should maintain three points of contact while ascending and using the ladder. A non-self-supporting ladder that is used to access an elevated surface must extend three feet above the point of support, and employees should never stand on the top three rungs of a straight, single or extension ladder. Employees should never stand on the top rung of any ladder.

All ladders should be kept free from oil, grease, wet paint and other slipping hazards, and employees should inspect the ladders for any damage or defects to the feet, rungs, cleats, stringers and/or locking mechanisms prior to each use. Any ladder found to have a problem should be removed from service immediately. 

Training and Discipline

 Employers should properly train their employees on ladder safety, including hands-on demonstrations, upon their hire and should continually refresh such trainings using weekly safety topics or meetings and/or toolbox talks. Employers must ensure compliance through random safety audits and inspections at worksites involving the use of ladders and must routinely and consistently discipline employees for infractions. 

Trenching

OSHA implemented a trenching NEP in 2018 citing “the continuing incidence of trench/excavation collapses and accompanying loss of life” and OSHA’s belief “that there is a potential for collapse in virtually all excavations.” Between 2011 and 2016 there were 130 fatalities related to excavating and trenching and 104 of those fatalities occurred within the private construction industry, making this an area of concern for construction employers.

OSHA’s excavation standard (1926.651) applies to open excavations and trenches. An “excavation” is defined by the standard as any “man-made cut, cavity, trench, or depression in the Earth’s surface” formed by removal of material. The major hazard of concern is a cave-in. However, some of the other potential hazards include, but are not limited to, falling loads, material, or objects, hazardous atmospheres, inadequate ingress and egress, and site inspections. 

Protection Against Cave-In or Collapse

The OSHA standard has requirements regarding sloping/benching the sides of an excavation, supporting the sides of an excavation, or placing a shield between the side of an excavation and the work area to prevent cave-ins. Designing a protective system requires consideration of many factors, including soil classification, depth of cut, water content of soil, weather and climate, and other operations in the area. Such a design typically involves the use of a trench box or shield that is approved by a registered professional engineer. 

The standard also requires support systems for structures adjacent to an excavation, such as buildings, walls, sidewalks, etc. The standard does not require a protective system when an excavation is less than five feet in depth, and when a “competent person” has examined the area and determined there is no indication of potential cave-in, or when the excavation is made entirely within stable rock. The trenching standard defines a “competent person” as someone who is capable of identifying: existing and predictable hazards; working conditions which are unsanitary, hazardous or dangerous to employees; and who is authorized to take prompt corrective measures to eliminate them.

Falling Loads, Materials and Object

Employers must protect employees in the trench or excavations from above-grade falling loads, materials and objects. For example, employers must not permit other employees – or other contractors – to work on the bench or slope of the excavation while others are in the bottom of the excavation or trench. Employees must not be permitted to work under suspended loads. Materials near the trench should be kept at least two feet from the excavation’s edge to prevent a fall-in hazard.

Hazardous Atmospheres

Atmospheric testing is required in excavations deeper than four feet and where oxygen deficiencies or hazardous atmospheres are present or could reasonably be expected. Employee exposure must be prevented by adequate ventilation or respiratory protection. Confined space or permit-required confined space measures may be required in some instances. 

Ingress and Egress

 The OSHA standard requires ladders, steps, ramps or other safe means of egress for workers in trenches deeper than 4 feet, and they must be located 25 feet or less from workers in the excavation. Any access or egress must be designed by a competent person.

Site Inspections

Competent persons are required to examine excavations, adjacent areas and protective systems. These examinations should be conducted daily and prior to starting work. Examinations should be re-performed if conditions change.

Training and Discipline

Given the excavation standard’s requirements, employers must adequately train both employees and competent persons on excavation and trenching safety. Moreover, because competent persons are required to perform daily inspections of any excavation, audits to ensure such inspections are performed are crucial to compliance with the standard. Employers should enforce any deficiencies among employees and competent persons through discipline.

These standards are detailed in Part 1926 of OSHA’s regulations. However, education and training on any standard is only one step in the process. Ensuring employee compliance with an employer’s written safety programs through audits and discipline is critical to employee safety and to the employer’s defense against OSHA citations. 

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