“OSHA’s proposal for an Injury and Illness Prevention Program (I2P2) standard is getting nowhere in today’s political climate, but the idea that all employers should plan ahead to limit hazards is a good one,” says LHSFNA Management Co-Chairman Noel C. Borck.

“Fortunately,” he continues, “the American National Standards Institute (ANSI) is able to avoid much of today’s political gridlock by bringing industry, labor and OSH professionals together to construct voluntary standards based on broad consensus about best practice. The new ANSI A10.1 standard may accomplish much of what OSHA’s I2P2 proposal aimed to achieve.”

The new standard delineates responsibilities for owners, project constructors (essentially, the general contractors), contractors and subcontractors, starting before the job is even bid and running through the design phase, then pre-project and pre-task. Owners are expected to designate safety and health goals for the project and ensure that they are followed. These considerations must be included in the project design and the bid documents, and the safety performance of project constructors bidding on the project must be evaluated and reviewed to help determine who gets the job.

The project constructor has to develop a project-specific safety and health plan which identifies potential problems and provide it to contractors in pre-bid meetings. Evaluations of the contractor’s safety records must be included in the selection process. Resources needed for jobsite safety must be spelled out in these pre-bid documents. Regular, mandatory safety meetings must be held to coordinate efforts on the site.

Contractors must have their own project specific safety and health plan. They must also include safety reviews in hiring any subcontractors. Subcontractor candidates must provide the contractors with a report demonstrating their capabilities to perform safely.

Safety training is required for both workers and supervisors on the site. Equipment used on the site must be selected with safety features in mind and maintained in good working order. Contractors must perform task hazard analyses for any complex or potentially hazardous tasks and use those analyses with craft labor before work is performed. Workers must be trained and equipped for any task that they are asked to perform.

The standard includes appendices with guidelines for project and task hazard analyses.

“By moving safety upstream to the planning process, major improvements will be made in site safety,” Borck summarizes. “It makes good sense to plan ahead.”

[Scott Schneider is the LHSFNA’s Director of Occupational Safety and Health.]