Safety Articles

Personal Protective and Lifesaving Equipment (1926.95- 1926.103)

Fire Protection and Prevention (1926.150- 1926.159)

This Subpart has some regulations that apply to highway contractors. From basic compliance to fueling, heating and storage requirements, keeping an outside jobsite safe from fire and explosion hazards is important. Any DOT requirements for fire protection are not addressed here.

Section 1926.150 (a)(c) - General requirements; first of all requires the contractor to have a fire prevention program. While this program need not be lengthy, it is required to be discussed with workers as a part of their overall safety training. This written program may also be a part of your overall safety plan.

Section 1926.152 (a)(e)(g) - Flammable & combustible liquids; first and foremost need to be stored in approved containers. One of the most common violations is storing fuels in plastic or metal gas cans which don’t meet OSHA’s requirements. Approved containers for flammable and combustible liquids are metal, with an internal flame-arrester tube in the filler throat and a spring-loaded self-closing cap. Any area used for refueling of equipment of 5 gallons or more requires a 25 ft. separation from other operations. In addition, there can be no smoking in the immediate area, and a “No Smoking” sign shall be posted. Therefore, gravity-fed tanks on “farm stands” and even fuel tanks on pickup beds should have permanent “No Smoking” signs with the 25 ft. separation posted.

Section 1926.153 (h) - Liquefied petroleum gas (LP-gas); used for temporary heaters have some special requirements. LP tanks which are connected to heaters by a hose are required to be placed at least 6 ft. away from the heaters. In addition, heaters cannot be directed toward any LP tanks unless there is at least a 20 ft. separation. Another consideration is that barricading or some equivalent means is necessary to protect any LP tanks which could be struck or damaged by vehicle and equipment operations.

Section 1926.154 (a) - Temporary heating devices; do have one regulation that may affect highway contractors. Heaters shall be located at least 10 ft. away from any combustible tarpaulins, canvas, or other coverings. In addition, the adjacent coverings need to be tied down to prevent winds from upsetting the heater.

Signs, Signals, and Barricades (1926.200- 1926.202)

This Subpart, as the title implies, affects highway contractors to a great extent. Naturally, right-of-way work is subject to Federal, State, and sometimes local DOT regulations which in many cases may be more restrictive that the OSHA regulations. However, the following are highlights from this Subpart.

Section 1926.200(g) - Traffic signs; requires that “Construction areas shall be posted with legible traffic signs at points of hazard”. Additionally, worker protection signage shall be made in accordance with ANSI standards D6.1-1971 (Manual on Uniform Traffic Control Devices for Street and Highways). Again, when working in a DOT- regulated area, there are typically more stringent signage requirements.

Section 1926.201(a) - Signaling; requires flagmen (or other appropriate traffic controls) onsite when the signs, signals, or barricades being used still do not provide the necessary protection on or adjacent to a highway or street. Flagmen are required to use 18” square red flags, or paddles. When working at night, flagmen shall use red lights. At all times, flagmen shall wear red or orange warning garments, but at night, the warning garments shall have reflectorized material. Any signaling the flagmen make shall be in accordance with the same ANSI standard D6.1-1971 as above.

Section 1926.202 - Barricades; are required to conform to the same ANSI standard D6.1-1971 as above. There are no specific barricade requirements, but again the DOT standards typically apply.

The information as outlined in this article focuses primarily on the requirements for highway and roadway contractors. Please refer to these sections of the CFR (including other work activities you perform) for a more in-depth review of these regulations.

This is part two of a two-part series on Right-of Way working requirements. Read Part one of this article.

Does Your Site Meet the OSHA Safety Manual Requirements?

Omni Safety offers safety plans and safety training for construction industry leaders and contractors. Contact Us today for a custom-written safety manual for your jobsite.

OSHA regulations are grouped by work activities rather than by types of contractors.

Therefore, contractors cannot review any particular Subpart to understand the applicable OSHA regulations for their particular type of business, but rather would need to review any Subparts that cover the actual type of work they perform. However, while OSHA doesn’t address highway work separately, there are many Subparts of the Code of Federal Regulations (CFR) that apply to highway and roadway construction more than others.

In this article, I will be focusing on three Subparts that are important to roadway contractors which are: Personal Protective and Lifesaving Equipment; Fire Protection and Prevention; and Signs, Signals, and Barricades.

Personal Protective and Lifesaving Equipment (1926.95- 1926.103)

This Subpart affects virtually all contractors. However, some roadway contractors may not seriously consider personal protective equipment by the fact that their workers are outdoors, usually on grade without some of the hazards expected, for example, in building construction.

Section 1926.95 (a) - Criteria for personal protective equipment; simply states the employer’s responsibility to provide personal protective equipment to their workers whenever required by jobsite conditions. One item to note is that even if the equipment used is owned by the employee, the employer is still responsible for it’s adequacy.

Section 1926.100 (a) - Head protection; requires hardhats only when an overhead danger is present. However, a company-wide rule to wear hardhats should be considered for several reasons. First, when all workers have hardhats, it provides a feeling of both unity (much as uniforms) and of safety-mindedness. Second, while there may be no overhead danger at the time, having to consider while working “when” or “when not” to wear hardhats is time-consuming, separate and an arbitrary decision- something you the employer may not want the workers to be making. Finally, lack of hardhats may cause an OSHA inspector to involuntarily slow down and notice an otherwise safe and in-compliance jobsite. Roadway contractors are especially subject to “drive by” inspections by virtue of their jobsite location and exposure.

Section 1926.101 (a)(b)(c) - Hearing protection; is required at specific decibel/ duration levels when experienced on the jobsite. In most cases, roadway operations will require hearing protection. Hearing protection is required for as little as 90 decibels, (which is slightly higher than heavy road traffic) if constant over an eight hour period. There are basically two styles of hearing protection; earmuffs and earplugs. As with most personal protective equipment, earplugs need to be fitted or determined by a competent person. Also, cotton balls or other similar plugs are not recognized by OSHA as having any benefit.

Section 1926.102 (a) - Eye & face protection; is required when the hazard is present. There are several styles of eye and face protection including safety glasses, goggles, and face shields. For those of us who wear prescription glasses, safety or unbreakable lenses alone are not enough. Your safety lenses would need to be in a frame that is rated for safety glasses (which includes the side panels). Check with your optician for safety frame availability. Also, if you’re performing work with hazardous chemicals that could splash into your eyes (such as curing compound, form oils, or other sprays), special goggles with “hooded” ventilation would be required to be used. Face shields are especially useful for protection against particles from grinding or sawcutting concrete.

Section 1926.103 (a) - Respiratory protection; as with the other personal protective equipment, is only required when a hazard is present. Road contractors would normally require respiratory protection when grinding or sawcutting concrete. Any worker in a location where there is a high concentration of fumes or toxic gases would also require a respirator. Note that respirators are required to be form-fitted to each wearer, and need to be fitted the first time under the supervision of a competent person. The typical paper dust mask is not recognized by OSHA as having any benefit. Workers may wear paper dust masks, however they provide little to no protection, and if conditions would have required a respirator, a citation could still be cited by OSHA.

This is part one of a two-part series on Right-of Way working requirements.  Read Part two of this article.

Does Your Site Meet the OSHA Safety Manual Requirements?

Omni Safety offers safety plans and safety training for construction industry leaders and contractors.  Contact Us today for a custom-written safety manual for your jobsite.

What are the most frequently cited violations for demolition work? The following are OSHA’s top five followed by suggestions and protective measures you can use to maintain compliance with OSHA’s standard/regulations.

Not performing a written engineering survey of the structure before commencing demolition work.

An engineering survey needs to be performed to determine if there are areas where premature or inadvertent collapse may occur, including any adjacent structures that employees may be exposed to. While this survey is being done, the presence of hazardous materials (asbestos, lead, PCBs, etc.) needs to be noted. When hazardous materials are present they will need to be included and addressed in the work scheduling before the demo work can begin. This knowledge of the structure’s weak points, presence of hazardous materials, contents of equipment within the structure, fire protective measures, etc. is essential for providing a safe work environment for your employees. Employers must have in writing evidence that this survey has been performed.

Failure to provide fall protection for employees exposed to wall openings (greater than 6 feet in height).

OSHA requires the use of fall protection in certain situations where employees will be using stairs, ladders, or working near wall openings. The protective measures found in Subpart M - Fall Protection and Subpart X - Stairways and Ladders will outline the necessary action you need to take to assure employees are protected from falls.

Failure to provide shoring or bracing for walls to prevent premature collapse.

The OSHA 1926.850 regulation outlines that where employees are required to work within a structure to be demolished that has been damaged by fire, flood, explosion, etc., the walls or floor must be shored or braced to prevent premature or inadvertent collapse. Additionally, any wall sections in areas where employees will access that stand more than one story high cannot stand alone without lateral bracing, unless the wall was originally designed and constructed to stand without lateral support, and is in a condition safe enough to be self-supporting.

Failure to properly inspect and maintain stairways and ladders in a safe condition for employee use.

Employers must designate specific passageways, stairs, ladders, etc. as a means of employee access to a structure being demolished and only those designated areas may be used. Other non-designated areas must be closed off at all times. These designated areas must be periodically inspected and maintained in a clean safe condition and be provided with such items as natural or artificial lighting, overhead protection from falling objects etc.
Failure to properly test and remove hazardous materials from within the structure before performing demolition work, and not providing sidewalk shed covers to protect employee entrances to the structure.

As noted in item A), a preliminary test must be performed prior to commencing with the demo work to determine what hazardous materials are present. All hazardous materials found within the structure must be addressed first. Next, OSHA requires safe entrance to the structure to be demolished to protect employees from objects falling onto them as they enter the work area. Overhead shed and/or canopy protection needs to extend at least 8 feet out from the face of the structure and must be at least 2 feet wider than the structures entrance or opening (1 foot wider on each side is permitted). The overhead protection (shed/canopy) must be able to sustain a load of 150 pounds per square foot.

For a more in-depth review of the regulation requirements for demolition work, please refer to sections 1926.850 thru 1926.860 Subpart-T of the Code of Federal Regulations.

Does Your Site Meet the OSHA Safety Manual Requirements?

Omni Safety offers hazard communication plans and safety training for construction industry leaders and contractors.  Contact Us today for a custom-written safety manual for your jobsite.