“Traditionally,” LIUNA General President Terry O’Sullivan notes, “OSHA hasn’t focused its enforcement on work zones as much as on building construction. This is because work zones are often temporary and continuously changing as roadwork progresses. As a result, many OSHA inspectors do not know much about work zones or how to inspect them. We’re glad to see that OSHA is addressing this important gap in its inspection program.”
To remedy this shortcoming, OSHA published a new compliance directive (CPL 02-01-054) in October to explain to its compliance officers 1) how to safely inspect highway work zones and 2) what types of violations may be present and the OSHA standards to cite if they are found.
How to Inspect
The directive requires every OSHA Region to designate a Traffic Control Coordinator to support these investigations and all compliance safety and health officers (CSHOs) to take a work zone safety course approved by the OSHA Training Institute. CSHOs are told what type of personal protective equipment (PPE) to wear when inspecting work zones (e.g., Class 2 or 3 vests), equipment to bring and proper procedures for safely doing the inspection (e.g. doing drive-bys of the site before entering it). CSHOs must check to see if proper traffic controls are in place, find a safe place to park, use safe practices while walking in the work zone area and use safe access and egress methods. They should also coordinate with local traffic engineers, State DOTs and law enforcement.
What to Look For
OSHA does not have many standards specifically for work zones so inspectors will focus primarily on violations of the Signs, Signals and Barricades standards (1926.200, 1926.201 and 1926.202). They are looking to see if temporary traffic controls are set up in accordance with the Federal Highway Administration’s Manual on Uniform Traffic Control Devices (MUTCD) (using the 1988 or millennium MUTCD additions, even though the newest edition is 2009). The directive also encourages CSHOs to look for violations of the general construction safety requirements and training requirements (1926.20(b)(1) and 1926.21(b)(2)) as well as the General Duty Clause of the OSH Act (section(5)(a)(1)). It also mentions other potential hazards such as: noise, dust (silica), illumination, PPE, scaffolds (for bridge work), fall protection, equipment, excavations, precast/poured concrete, steel erection and cranes.
“Hopefully,” says O’Sullivan, “this new directive will help OSHA inspectors stay safe while inspecting work zones. It should also educate them on how to better inspect these complex work environments. This is an important step toward improved safety and health for Laborers and all highway workers.”
[Scott Schneider is the LHSFNA’s Director of Occupational Safety and Health.]