Division of Labor and Industry


Five Additional Steps for Construction Employers - Developing a Workplace Safety and Health Program - Maryland Occupational Safety and Health (MOSH)


An effective safety and health program for construction is extremely important. One report concluded that for construction, the savings from effective administration of safety and health protection is 3.2 times the cost of implementation (Improving Construction Safety Performance, New York, The Business Roundtable, Report A-3, January 1982, page 16).

Most of the material covered in the previous section also applies to the construction trades. However, there are some changes and additions that construction companies should consider. For example, MOSH Safety and Health Regulations for Construction, 29 CFR Part 1926, sets the following specific requirements for construction safety and health programs:

1926.20 General safety and health provisions

b.  Accident prevention responsibilities.
(1) It shall be the responsibility of the employer to initiate and maintain such programs as may be necessary to comply with this part [29 CFR 1926].
(2) Such programs shall provide for frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employers.

1926.21 Safety training and education.

b.  Employer responsibilities.
(1) The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.;

The conditions that make safety and health programs so important in the construction industry also may make these programs difficult to administer effectively:

  • The work environment is dispersed and frequently changing.
  • Often several contractors share the same worksite.
  • There is a frequent turnover in personnel.
  • A number of construction trades are highly specialized and involve hazardous operations and specialized training and equipment.

Many trade associations that service the construction industry take an active interest in safety and health and have developed materials on safety and health programs that are specific to their trade. Refer to the Appendices for further information.

Step 9: Learn the safety and health requirements of your particular trade.

Follow the suggestions in the STEPS section of this text. Remember, knowing how to perform a particular trade does not ensure that you know everything about performing it safely. Review the appropriate equipment manuals and standards. Review accident and injury records to determine where, when and how employee injuries are occurring.

Step 10: Develop a general safety and health policy, safety rules, and other operational procedures.

An effective program addresses company policies and procedures in writing to provide a document for future review and revision. Include:

A general policy on safety and health that addresses company objectives

A description of how costs associated with safety and health will be met

A discussion of how responsibility and authority will be delegated

Safety and health procedures for particular operations or job classifications. Of particular concern are confined space operations, working at elevated levels, exposure to hazardous or toxic substances, clearance of overhead electric lines, and other site specific highly hazardous tasks

Emergency procedures

Respiratory and hearing protection programs that comply with applicable standards

Medical surveillance programs, when necessary

Accident investigation procedures

A disciplinary system for enforcement of safety and health rules

Maryland "Right-to-Know" information

General worksite inspection procedures

Maryland standards for construction, including the Maryland Confined Space Standard and Maryland amendments to the federal Lead in Construction Standard.

Step 11: Train a Core of Supervisory Employees.

Most construction companies have dispersed work sites and many have a high turnover of field employees. It is particularly important that worksite supervisory employees be well trained in all safety and health programs and in hazard recognition and control. Frequently it may be necessary to rely on these supervisors to train field employees.

Supervisors should be extensively trained in each of the policies and procedures developed as a part of Step 10. They should also have a good understanding of the OSHA and MOSH construction standards and hazardous conditions that can occur on a construction site.

This training will take time. Do not try to provide it all in one session. Refer to Step 7 for training suggestions.

Ensure that supervisors are responsible for setting a good example for employees as they enforce safety and health rules. Include as part of the supervisor's evaluation the proper handling of safety and health responsibilities.

Step 12: Individual Site Preparation

Whenever possible, perform individual site safety and health planning prior to bidding on a job. Costs associated with safety, such as personal protective equipment, fall protection, and medical surveillance, may figure into the job cost. Be sure to determine whether any special hazards such as lead paint or asbestos are associated with the job.

Conduct a pre-job site survey. Determine if your employees will be exposed to any hazardous materials or conditions. Note the location of overhead electric lines. Determine the location of emergency response resources (fire, ambulance, and hospital). Determine if special personal protective equipment or safety procedures will be required.

Ensure that the appropriate safety and health program information is on-site (see Step 10). Effective program procedures include requirements for correcting hazards in a timely manner and for protecting employees until hazards are corrected. Any information necessary to describe methods of correction and protection also should be on-site. Responsibility and authority for providing on-site information may be delegated to the site supervisor or referred to another company official. Ensure that supervisors on-site are well aware of the company procedures.

Before work begins, develop emergency procedures that fit the physical location, hazards, processes, and personnel of the job site in question.

Before work begins, post emergency telephone numbers, mark exit routes, and ensure the availability of emergency equipment. Require the supervisor on the site to conduct periodic worksite safety surveys. Establish the procedures and training for these surveys before operations begin.

At the beginning of the job, the on-site supervisor must communicate to employees the safety and health requirements and procedures and how to report safety and health concerns. The supervisor must instruct them not to engage in unsafe acts, and explain disciplinary action to be taken if unsafe acts occur. The supervisor also must ensure that all other required training is completed before employees start work. A general construction site self-inspection checklist is available from the MOSH Training and Education Office for use as a guide.

Frequently Overlooked Safety Matters

Ensure that new employees receive any required medical monitoring prior to beginning work that requires the use of personal protective equipment or involves chemical exposures.

Ensure that new employees are trained prior to starting work involving any hazards. As new employees come on site or transfer to new jobs, they must be trained.

When air contaminants are a potential problem, for example when there is lead on the site, initial monitoring is required on the first day of work and periodically thereafter, or when significant changes in work procedures occur.

A material safety data sheet (MSDS) on-site is recommended for any unusual toxic material required for use on a specific site.

Certain MOSH standards require that employees be notified in writing of medical surveillance results or environmental monitoring results.

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