[KtotheJ]

I work for a residential construction company. We build both houses and condos. Almost all of our work is subcontracted out to the various trades. I've recently been charged with setting up a comprehensive safety and health program for the company to fully comply with OSHA regulations. I'm all over the OSHA and MIOSHA (I'm in Michigan) websites. I've spent the past few days reading and I have the early beginnings of a fairly generic program. I'm looking for any advice any of you may have on this topic. Anybody been through this process and have any tips to share? I'm looking to produce a nice program and am reaching for anything that I may overlook. Thanks.

Omni

 

[hatchet]

The biggest thing with a safety program is the documentation. Have a method of taking safety violations (per job) and tracking them. For example, if you have a subcontractor who has been notoriously lax in doing weekly safety meetings you need to document and follow up with a remedy. You can still be found liable for an accident this subcontractor has if you have documented the inadequate items without following up and providing a solution or remedy. Same goes for your own people.
What about near misses? How do you deal with discipline? What does your contract tie the subcontractor to? Insurance requirements? Haz Com? MSDS? Blood borne pathogens. Fall protection (big one)? Scaffolding? Ladder use? Weekly safety meetings? Immediate reactions - for example - lead carpenter walks by and sees a subcontractor using an A-frame ladder against a wall - what do you do? You need to take immediate action and resolve the situation. All these things need to be mentioned and thought about in the plan.

 

[KtotheJ]

Thanks Rich. All good food for thought. Thanks for refreshing a few ideas. I'm sure I'll have more to throw out there in the coming days (not sure if that's even enough time.)

-Kevin

 

[JustaFramer]

Don't forget cords with not ground or cracked outer insulation. Cut the cord ends off (unplug it of course). Safety glasses for anyboy using pnuematic nailers or power tools. Eye wear and hard hats are really big here in WA.

 

[PipeGuy]

I have the early beginnings of a fairly generic program. Anybody been through this process and have any tips to share? I'm looking to produce a nice program i

I think the most significant thing you can do is tailor it towards the audience you're working with. Use words, phrases, examples that they aer familiar with. Keep it simple and understandable.

FYI - Here's the Table of Contents from my safety manual. As a GC you'll have compliance enforcement issues that I don't include as a sub.

 

[hatchet]

Doesn't your current 300 log have to posted at the entrance to the jobsite?

JustaFramer - yeah we inspect cords at every use and when we do site walks you get to see some pissed off subs when we cut the ends of their cords for that. The thing most don't realize is that it's for their own good. Oh and make sure you cut the male end off not the female

 

[PipeGuy]

Doesn't your current 300 log have to posted at the entrance to the jobsite?

Every foreman has a copy 'posted' in his safety manual which is located in his truck. Never have had a problem with that. Been through a couple inspections.

 

[Teetorbilt]

Having spent most of my adult life dealing with those knuckleheads, I don't consider your position enviable.
Have you considered studying for your GC license? It's about the same amount of work and should shift you into a higher income bracket.
Justaframer only touched the tip of the iceburg. I worked at one place where I still don't understand how we made it, every month it was another $3500. even though we complied with everything from the month before.
Do you know what a tongue guard is? It's opposite from the rest on a grinding wheel, at the top. Know what the setting is? Same as the rest, less than 1/8" How do I know this? OSHA! On one big job we had to move equipment to make conforming aisles and the next month we had to paint black and yellow stripes on the floor to demark them.
IMHO go for your GC.

 

[JustaFramer]

Hatchet- I wonce cut up this painters 14 or 16 g homeowner cord up with my riggin axe in like three different places. Damn cord kept popping the breaker. Had no ground and the insulation was cracked. This guy comes out to see why he had no power. Then starts cussing in spanish. He tells his boss that start asking questions. I say I don't know what happened. Then I say I think the Sup did it. The dumass takes the cord the to the Sup and asks why did you do it. Super is like I don't know what the ******************** your talking about but If I had I would of givin you a 100 dollar fine. Because you stupid fk's never come to the weekly meeting.
Oh that was funny.

Damn Teetor sound like harassment. It got so bad here a bunch of contractors got together and filed a complaint of harassment with the state. Well it worked now they need permission to walk on property or it's trespassing. But this is WISHA guys. I don't know if it would work with the feds.

Tip of the iceberg is right. A person really needs to take a class to really know everything. I know the L&I office here has a class that will lower your hourly insurance rate for employees if you pass it.

 

[hatchet]

Every foreman has a copy 'posted' in his safety manual which is located in his truck. Never have had a problem with that. Been through a couple inspections.

Sorry PipeGuy - is more of an internal joke at work here. We have regulation upon regulation and one of them is posting the 300 log at the entrance to the site. We enclose it in a box (wrap it in plastic) and everything else and it lasts about 3 days if there is any moisture in the air.

 

[hatchet]

Imagine a commercial job JustaFramer. Walking through a 12 story office building (1 million sf) with 500 and more workers. All of them thinking they need their own cord - and most often they pulled it from the chicken coop that morning. We've come back with dozens in one day before. Usually only takes one time before they start checking their own cords.
I've taken the OSHA 10 hour class - pretty good. A friend of mine took the OSHA 30 - but he's a project safety director. 10 hours was bad enough - can't imagine 30 hours of that stuff. Safety has become a necessary part of what construction is - without some program in place (sub)contractors are going to find that it's harder and harder to get work.

 

[KtotheJ]

.... Safety has become a necessary part of what construction is - without some program in place (sub)contractors are going to find that it's harder and harder to get work.

Hatchet, Hand in hand with what you are saying is the fact that costs are going to go up. Reasonably, the same job done the 'old way' can't possibly be done under OSHA regs for the same price. Subs will lose their butts. But don't get excited. I understand this, but have ZERO control on the contracts at this point. I wonder how long it will take for the GC's to fully realize that if we're going to demand full compliance with OSHA that our own profit margins will shrink slightly.

-Kevin

 

[hatchet]

Hatchet, Hand in hand with what you are saying is the fact that costs are going to go up. Reasonably, the same job done the 'old way' can't possibly be done under OSHA regs for the same price. Subs will lose their ass. But don't get excited. I understand this, but have ZERO control on the contracts at this point. I wonder how long it will take for the GC's to fully realize that if we're going to demand full compliance with OSHA that our own profit margins will shrink slightly.

-Kevin

Very true Kevin.. but imagine what a fatal accident would cost your company indirectly. I would assume insurance would take care of the direct costs.. but extended premium costs can cripple unprepared companies. And it's not just a direct cost to the subcontractor - those extended costs should be extended right up to the GC. What (sub)contractors are going to see here in the very near future (already seeing quite a bit in the commercial market) is that anyone with an EMR greater than 1 will be unable to bid on jobs. The company I work for right now requires a subcontractor EMR less than 1.2. Along with that we expect a safety plan and yes - increased costs to administer it.

 

[PipeGuy]

What (sub)contractors are going to see here in the very near future (already seeing quite a bit in the commercial market) is that anyone with an EMR greater than 1 will be unable to bid on jobs.

How right you are. I'm seeing more and more specs like that. I, for one, welcome the increased scrutiny. An owner/GC can't demand one performance standard and pay for another.

 

[Teetorbilt]

Teetor & Teetor, Inc., Advanced Marine Systems, Inc. and Perfect Balance, Inc. have never filed any claims for any reason since inception. I'm proud to say that all but Perfect Balance have been around for +/- 20 yrs.
Perfect Balance is a recent aquirement, also without a claim for 9 yrs.

 

[hatchet]

That's an excellent record Teetor and something to be very proud of.

 

[ConcreteGuy]

Hey Omni, that's great news. The resources for safety googles my mind! Just do a little research and you will have more information than I could furnish you.

Ya'll don't forget, OSHA expects you to do more than "fuss" at people. OSHA expects, rightfully, that you take action. In other words, if you tell the OSHA officer that you repeatedly warned an employee, or an employee of a subcontractor, about safety violations without taking action, they will consider you weak and ineffectual. And it's true. If you go about complaining without taking action, you are ineffective. That is, you are a no account ineffectual sissypants. lol!

What you must do is take disciplinary action. If some butthole refuses abide you need to remove him from the job. Or give him a suspension.

My point is that OSHA expects actions rather than words.

Saying, "I told him to quit being so stupid" makes you look weak in the eyes of OSHA. They expect you to take disciplinary ACTION. Send somebody home, or tell him not to return until he can work by the rules.

Do something about it! OSHA will not accept passiveness.

 

[DoubleJ]

You might want to use this website as a good starting point. It has a sample plan from Colorado University. Good luck.

http://www.bernardino.colostate.edu/OHSS/OHSSHandouts/ohss_ConstSHProgramSB.pdf

 

[orozko]

Very true Kevin.. but imagine what a fatal accident would cost your company indirectly. I would assume insurance would take care of the direct costs.. but extended premium costs can cripple unprepared companies. And it's not just a direct cost to the subcontractor - those extended costs should be extended right up to the GC. What (sub)contractors are going to see here in the very near future (already seeing quite a bit in the commercial market) is that anyone with an EMR greater than 1 will be unable to bid on jobs. The company I work for right now requires a subcontractor EMR less than 1.2. Along with that we expect a safety plan and yes - increased costs to administer it.

OSHA FINES, INSURANCE COST=$THOUSANDS
LEGAL LAWSUITS FROM FAMILY=$MILLIONS
I work for a commercial GC in the Dallas area and the sub must have an EMR of 1.00 or better to qualify on our bid list.