Occupational Safety

and Health Administration

www.osha.gov

OSHA 3886 October 2016

Recommended Practices for 

Safety & Health Programs

in Construction
DISCLAIMER

These practices for safety and health programs for 

construction worksites are recommendations only. 

Employers in construction work must have a program 

that includes measures to detect and correct workplace 

hazards. However, their program may not contain 

all of the practices recommended in this document. 

Employers will not be cited if their safety and health 

program does not comply with this document. 
FOREWORD

FOREWORD

Establishing a safety and health program at 

your job site is one of the most effective ways 

of protecting your most valuable asset: your 

workers. Losing workers to injury or illness, even 

for a short time, can cause significant disruption 

and cost—to you as well as the workers and their 

families. It can also damage workplace morale, 

productivity, turnover, and reputation.

Safety and health programs foster a proactive 

approach to “finding and fixing” job site hazards 

before they can cause injury or illness. Rather 

than reacting to an incident, management and 

workers collaborate to identify and solve issues 

before they occur. This collaboration builds trust, 

enhances communication, and often leads to 

other business improvements. Employers who 

have implemented safety and health programs, 

including many who are in OSHA’s Voluntary 

Protection Programs (VPP) or the Safety and 

Health Achievement Recognition Program 

(SHARP) for small and medium-sized businesses, 

have also found that managing for safety results 

in higher-quality product or output and higher 

profits.

These recommended practices reflect current 

conditions in the construction industry: 

• New construction techniques, materials, and

equipment have come into common use.

• Greater diversity in the construction

workforce means that people from different

backgrounds and cultures are working

alongside each other, often speaking

different languages.

Resources and Tools to Support 

Implementation of These 

Recommended Practices

OSHA has created a dedicated Web 

page to support the implementation 

of these practices at www.osha.gov/

safetymanagement. The page includes a 

link to these recommended practices as 

well as the following:

• Additional resources. Articles and

information sources related to each core

element of the recommended practices,

plus other topics discussed in the

recommended practices.

• Tools. Downloadable templates,

worksheets, and reference materials you

can use as you develop your own safety

and health program.

Please visit the recommended practices 

Web page and explore the resources 

available. OSHA will update the Web page 

and add resources and tools as they become 

available.

• An aging workforce and the rise of sedentary

lifestyle means that some workers are at

higher risk for work-related musculoskeletal

disorders.

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION i
FOREWORD

• Increased temporary and contract

employment means that traditional

relationships between workers and

employers are shifting, and changes in safety

programs and policies will be required to

ensure the safety and health of all workers at

worksites characterized by these newer and

more fluid relationships.

These practices also reflect what we have 

learned from best-in-class programs and what 

makes them effective. In particular, these 

recommended practices place greater 

emphasis on involving workers, and include a 

more robust program evaluation element to 

help drive continuous improvement. These 

practices also stress the need for 

communication and coordination on worksites 

involving more than one employer.

ii RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
INTRODUCTION................................................................................................................................................... 2

MANAGEMENT LEADERSHIP .......................................................................................................................... 9

WORKER PARTICIPATION................................................................................................................................11

HAZARD IDENTIFICATION AND ASSESSMENT........................................................................................15

HAZARD PREVENTION AND CONTROL....................................................................................................20

EDUCATION AND TRAINING.........................................................................................................................24

PROGRAM EVALUATION AND IMPROVEMENT....................................................................................... 27

COMMUNICATION AND COORDINATION FOR EMPLOYERS 

ON MULTIEMPLOYER WORKSITES..............................................................................................................30

LIST OF ABBREVIATIONS.............................................................................................................................. 34

GLOSSARY OF TERMS ................................................................................................................................... 34

CONTENTS

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 1
INTRODUCTION

THESE RECOMMENDED PRACTICES provide 

responsible employers, workers, and worker 

representatives1 with a sound, flexible framework 

for addressing safety and health issues on diverse 

construction job sites. They may be used by any 

construction company or job site, but they will be 

particularly helpful to small and medium-sized 

contractors. They also include guidance specifically 

aimed at general contractor employment, staffing 

agency employment, and multiemployer work 

situations. These recommended practices have 

been developed solely for the construction 

industry. Separate recommended practices are 

available for all other industries.

The recommended practices emphasize a 

proactive approach to managing occupational 

safety and health. Traditional approaches are 

often reactive—that is, actions are taken only 

after a worker is injured or becomes sick, a 

new standard or regulation is published, or an 

outside inspection finds a problem that must 

be fixed. Finding and fixing hazards before they 

cause injury or illness is a far more effective 

approach. Doing so avoids the direct and 

indirect costs of worker injuries and illnesses, 

and promotes a positive work environment. 

1 Worker participation is vital to the success of the program. In several places in these recommended practices, OSHA refers not just to 

workers but also to their representatives, such as labor unions or religious or community groups.
Source: Ohio Bureau of Workers’ Compensation (2011), Ohio 21(d) SHARP Program Performance Assessment.

INTRODUCTION

These best practices present principles and 

approaches to implementing and maintaining 

a safety and health program for the entire 

construction company. OSHA recognizes that a 

wide variety of small and large construction job 

sites exist. Some are short-duration, while others 

may take years to complete; some sites are 

characterized by frequently changing conditions, 

while other sites’ conditions may change less 

often. An effective program emphasizes top-level 

ownership, participation by employees, and a 

“find and fix” approach to workplace hazards.

The “find and fix” approach to workplace hazards 

refers to the “Hazard Identification” and “Hazard 

Prevention and Control” core elements. Because 

of the wide variety of site conditions, these two 

core elements should be implemented on a sitespecific basis in order to effectively detect and 

correct hazards. 

The concept of continuous improvement is 

central to these recommended practices. As 

with any journey, the first step is often the 

most challenging. The idea is to begin with a 

basic program and grow from there. By initially 

focusing on achieving modest goals, monitoring 

performance, and evaluating outcomes, you can 

help your company progress over time along the 

path to higher levels of safety and health.

THE BENEFITS OF IMPLEMENTING 

THESE RECOMMENDED PRACTICES

Responsible employers know that the main goal 

of a safety and health program is to prevent 

work-related injuries, illnesses, and deaths, as 

well as the suffering and financial hardship these 

events can cause for workers, their families, and 

their employers.

Employers may find that implementing these 

recommended practices brings other benefits 

as well. The renewed or enhanced commitment 

to safety and health and the cooperative 

atmosphere between employers and workers 

have been linked to:

• Improvements in production and quality. 

• Better employee morale.

• Improved employee recruiting and retention.

• A more favorable image and reputation 

(among customers, suppliers, and the 

community). 

(per million 

dollars of payroll)

A study of small employers in Ohio found that workers’ compensation claims fell dramatically after working 

with OSHA’s SHARP program to adopt programs similar to those described in these recommended practices.

average

number of claims cost per claim claims

52%

+

DECREASED DECREASED

80% 88%

DECREASED

average lost time per claim

87%

DECREASED

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 3
HOW TO USE THE RECOMMENDED 

PRACTICES

Each section of the recommended practices 

describes a core program element (see page 7), 

followed by several action items. Each action 

item is an example of steps that general 

contractors, subcontractors, managers, 

supervisors, and workers can take to establish, 

implement, maintain, and improve safety and 

health programs. A general self-evaluation 

tool can be found on the recommended 

practices Web page. It can be tailored to your 

construction site to track your progress and 

document how you have implemented (or will 

implement) each action item.

Seven interrelated elements

The seven core elements are interrelated and 

are best viewed as part of an integrated system. 

Actions taken under one core element can 

Source: Leigh, J.P. (2011), Economic Burden of Occupational Injury and Illness in the United States. Milbank Quarterly, 89:728-772.2

2 The 2.7 multiplier for indirect costs includes some social costs, such as workers’ compensation costs not covered by insurance.

INTRODUCTION

IMPLEMENTING

a safety & health program

can help employers avoid the 

that result

from 

due to work 

stoppages and

investigations, 

training and other 

costs associated with to material, 

machinery 

and property. 

and

such as 

TIME

LOST

REPLACING 

INJURED 

WORKERS 

LOSS OR

DAMAGE

INDIRECT

COSTS

These have been estimated

to be at least 

2.7

 times the

INDIRECT

COSTS

DIRECT

COSTS

WORKPLACE

INCIDENTS

4 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
(and likely will) affect actions needed under one 

or more other elements. For example, workers 

must be trained in reporting procedures and 

hazard identification techniques in order to be 

effective participants. Thus, the “Education and 

Training” core element supports the “Worker 

Participation” core element. Similarly, setting 

goals (as described under “Management 

Leadership”) will be more effective if you routinely 

evaluate your progress in meeting those goals 

(see “Program Evaluation and Improvement”). 

Progress in each core element is important to 

achieve maximum benefit from the program. 

One size does not fit all

While the action items under each core element 

are specific, they are not prescriptive. The 

process described in these recommended 

practices can, and should, be tailored to the 

needs of each construction company and/or job 

site. Likewise, your safety and health program 

can and should evolve. Experimentation, 

evaluation, and program modification are all part 

of the process. You may also experience setbacks 

from time to time. What is important is that you 

learn from setbacks, remain committed to finding 

out what works best for you, and continue to try 

different approaches. 

Injuries and illnesses occur in all construction 

trades. The preventive approaches described 

in these recommended practices work equally 

well for small and large organizations in the 

construction industry. Small employers may 

find that they can best accomplish the actions 

outlined in these recommended practices using 

informal communications and procedures. 

Larger employers, who have more complex work 

processes and hazards, may require a more 

formal and detailed program. They may also wish 

to integrate their safety and health program with 

other programs that they are using to manage 

production, quality control, and environmental 

protection or sustainability.

The importance of worker 

participation

Throughout these recommended practices, 

OSHA emphasizes the importance of worker 

participation in the safety and health program. 

For a program to succeed, workers (and, 

if applicable, their representatives) must 

participate in developing and implementing 

every element of the safety and health program. 

This emphasis on worker participation is 

consistent with the OSH Act, OSHA standards, 

and OSHA enforcement policies and procedures, 

which recognize the rights and roles of workers 

and their representatives in matters of workplace 

safety and health. Several action items described 

in these recommended practices rely on 

perspectives, expertise, and input that can come 

only from workers and their representatives. 

When more than one employer is 

involved

Employers and workers on “multiemployer” 

worksites should pay particular attention to 

the “Coordination and Communication for 

Employers on Multiemployer Worksites” section. 

This section describes actions that controlling 

employers such as general contractors, prime 

contractors and construction managers, 

subcontractors, and temporary staffing agencies 

(and their workers) should take to ensure 

protection of everyone on the job site.

For tools and resources to help you 

implement these recommended practices, 

visit: www.osha.gov/safetymanagement

INTRODUCTION

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 5
INTRODUCTION

NINE EASY THINGS TO GET YOUR PROGRAM STARTED

If these recommended practices appear challenging, here are some simple steps you can 

take to get started. Completing these steps will give you a solid base from which to take on 

some of the more structured actions presented in the recommended practices.

1. ALWAYS SET SAFETY AND

HEALTH AS THE TOP PRIORITY

Tell your workers that making sure they finish the

day and go home safely is the way you do business.

Assure them that you will work with them to find and

fix any hazards that could injure them or make them

sick.

2. LEAD BY EXAMPLE

Practice safe behaviors yourself and make safety part

of your daily conversations with workers.

3. IMPLEMENT A REPORTING

SYSTEM

Develop and communicate a simple procedure for

workers to report any injuries, illnesses, incidents

(including near misses/close calls), hazards, or safety

and health concerns without fear of retaliation.

Include an option for reporting hazards or concerns

anonymously.

4. PROVIDE TRAINING

Train workers on how to identify and control hazards

using, for example, OSHA’s Hazard Identification

Training Tool.

5. CONDUCT INSPECTIONS

Inspect the job site with workers and ask them to

identify any activity, piece of equipment, or material

that concerns them. Use checklists and other

resources, such as OSHA’s Construction Industry

Digest, to help identify problems.

6. COLLECT HAZARD CONTROL

IDEAS

Talk with workers about ideas on safety improvements

throughout the project.

7. IMPLEMENT HAZARD CONTROLS

Assign workers the task of choosing, implementing,

and evaluating the solutions.

8. ADDRESS EMERGENCIES

Identify foreseeable emergency scenarios and develop

instructions on what to do in each case. Meet to

discuss these procedures and post them in a visible

location at the job site.

9. MAKE IMPROVEMENTS

Set aside a regular time to discuss safety and health

issues, with the goal of identifying ways to improve

the program.

6 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
INTRODUCTION

CORE ELEMENTS OF THE RECOMMENDED PRACTICES FOR 

SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION

MANAGEMENT 

LEADERSHIP

•Top management demonstrates its commitment to eliminating hazards and to continuously 

improving workplace safety and health, communicates that commitment to workers, and sets 

program expectations and responsibilities. 

•Managers at all levels make safety and health a core organizational value, establish safety and 

health goals and objectives, provide adequate resources and support for the program, and set 

a good example.

WORKER 

PARTICIPATION

•Workers and their representatives are involved in all aspects of the program—including setting 

goals, identifying and reporting hazards, investigating incidents, and tracking progress. 

•All workers, including contractors and temporary workers, understand their roles and 

responsibilities under the program and what they need to do to effectively carry them out. 

•Workers are encouraged and have means to communicate openly with management and to 

report safety and health concerns or suggest improvements, without fear of retaliation.

•Any potential barriers or obstacles to worker participation in the program (for example, 

language, lack of information, or disincentives) are removed or addressed.

HAZARD 

IDENTIFICATION AND 

ASSESSMENT

•Procedures are put in place to continually identify workplace hazards and evaluate risks.

•Safety and health hazards from routine, nonroutine, and emergency situations are identified 

and assessed.

•An initial assessment of existing hazards, exposures, and control measures is followed by 

periodic inspections and reassessments, to identify new hazards.

•Any incidents are investigated with the goal of identifying the root causes.

• Identified hazards are prioritized for control. 

HAZARD 

PREVENTION AND 

CONTROL

•Employers and workers cooperate to identify and select methods for eliminating, preventing, 

or controlling workplace hazards. 

•Controls are selected according to a hierarchy that uses engineering solutions first, followed by 

safe work practices, administrative controls, and finally personal protective equipment (PPE).

•A plan is developed that ensures controls are implemented, interim protection is provided, 

progress is tracked, and the effectiveness of controls is verified.

EDUCATION AND 

TRAINING

•All workers are trained to understand how the program works and how to carry out the 

responsibilities assigned to them under the program. 

•Employers, managers, and supervisors receive training on safety concepts and their 

responsibility for protecting workers’ rights and responding to workers’ reports and concerns. 

•All workers are trained to recognize workplace hazards and to understand the control measures 

that have been implemented.

PROGRAM 

EVALUATION AND 

IMPROVEMENT

•Control measures are periodically evaluated for effectiveness. 

•Processes are established to monitor program performance, verify program implementation, 

and identify program shortcomings and opportunities for improvement.

•Necessary actions are taken to improve the program and overall safety and health performance.

COMMUNICATION 

AND COORDINATION 

FOR EMPLOYERS ON 

MULTIEMPLOYER 

WORKSITES

•General contractors, contractors, and staffing agencies commit to providing the same level of 

safety and health protection to all employees.

•General contractors, contractors, subcontractors, and staffing agencies commmunicate the 

hazards present at the worksite and the hazards that work of contract workers may create on site.

•General contractors establish specifications and qualifications for contractors and staffing agencies.

•Prior to beginning work, general contractors, contractors, and staffing agencies coordinate on work 

planning and scheduling to identify and resolve any conflicts that could impact safety or health. 

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 7
INTRODUCTION

FOR MORE INFORMATION

For more information about these recommended 

practices, tools to help you implement them, and 

related topics, see the recommended practices 

Web page. This page includes links to many tools 

and resources developed by OSHA and others 

that can help employers and workers implement 

these recommended practices. OSHA will 

continue to update and add to this resource list. 

OSHA’s On-site Consultation Program offers free 

and confidential occupational safety and health 

services to small and medium-sized businesses in all 

states across the country and in several territories, 

with priority given to high-hazard worksites. 

On-site Consultation Program services are separate 

from enforcement and do not result in penalties 

or citations. Consultants from state agencies 

or universities work with employers to identify 

workplace hazards, provide advice on compliance 

with OSHA standards, and help them establish and 

improve their safety and health programs. 

For free assistance, including help 

implementing your program, visit: 

www.osha.gov/dcsp/smallbusiness

or call 1-800-321-6742 (OSHA)

8 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
MANAGEMENT 

LEADERSHIP

MANAGEMENT PROVIDES the leadership, 

vision, and resources needed to implement 

an effective safety and health program. 

Management leadership means that business 

owners, managers, and supervisors:

• Make worker safety and health a core 

organizational value.

• Are fully committed to eliminating hazards, 

protecting workers, and continuously 

improving safety and health on job sites.

• Provide sufficient resources to implement 

and maintain the safety and health program.

• Visibly demonstrate and communicate their 

safety and health commitment to workers 

and others.

• Set an example through their own actions.

Action item 1: Communicate your commitment to a safety and health program

A clear, written policy helps you communicate that safety and health is a primary organizational 

value—as important as productivity, profitability, product or service quality, and customer satisfaction. 

How to accomplish it

Establish a written policy signed by top 

management describing the organization’s 

commitment to safety and health, and pledging 

to establish and maintain a safety and health 

program for all workers.

• Communicate the policy to all workers and, 

at appropriate times and places, to relevant 

parties, including: 

— Contractors, subcontractors, staffing 

agencies, and temporary workers at your 

worksite(s)

— Suppliers and vendors 

— Other businesses in a multi-tenant 

building

— Visitors

— Customers

• Reinforce management commitment by 

considering safety and health in all business 

decisions, including estimating and bidding 

on projects, subcontractor and vendor 

selection, scheduling, and implementing 

safety designs into construction processes, 

drawings, and modifications. 

• Be visible in operations and set an example by 

following the same safety and health procedures 

you expect workers to follow. Conduct weekly 

or daily toolbox talks on safety and health, 

and discuss/review safety and health indicators 

and/or open safety items on a “to do” list.

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 9
MANAGEMENT LEADERSHIP

Action item 2: Define program goals 

By establishing specific goals and objectives, management sets expectations for managers, 

supervisors, and workers, and for the program overall. The goals and objectives should focus on 

specific actions that will improve worker safety and health.

How to accomplish it

• Establish realistic, measurable goals for 

improving safety and health. 

• Develop plans to achieve the goals by 

assigning tasks and responsibilities to 

particular people, setting timeframes, and 

determining resource needs.

Action item 3: Allocate resources

Management provides the resources needed to implement the safety and health program, pursue 

program goals, and address program shortcomings when they are identified. 

How to accomplish it

• Estimate the resources needed to establish 

and implement the program. One example is 

ensuring safety equipment is included in the 

project budget.

• Allow time in workers’ schedules for them to fully 

participate in the program. Safety can be built 

into the labor rates when estimating a project. 

• Integrate safety and health into planning and 

budgeting processes, and align budgets with 

program needs. 

• Provide and direct resources to operate and 

maintain the program, meet safety and health 

commitments, and pursue program goals.

Note: Resource needs will vary depending on your organization’s size, complexity, hazard types, and program maturity and development. 

Resource needs may include capital equipment and supplies, staff time, training, access to information and tools (e.g., vendor information, Safety 

Data Sheets, injury/illness data, checklists, online databases) and access to safety and health experts, including OSHA’s free and confidential 

On-site Consultation Program (see “For More Information” in the introduction to these recommended practices).

Action item 4: Expect performance

Management leads the program effort by establishing roles and responsibilities and providing an 

open, positive environment that encourages communication about safety and health. 

How to accomplish it

• Identify a frontline person or persons who 

will lead the safety program effort, make 

plans, coordinate activities, and track 

progress. Define and regularly communicate 

responsibilities and authorities for 

implementing and maintaining the program, 

and hold people accountable for performance.

• Provide positive recognition for meeting or 

exceeding safety and health goals aimed at 

preventing injury and illness (e.g., reporting 

close calls/near misses, attending training, 

conducting inspections).

• Establish ways for management and all workers 

to communicate freely and often about safety 

and health issues, without fear of retaliation.

Note: Maintaining a positive and encouraging tone is important. Successful programs reward, rather than discipline, workers who identify problems 

or concerns, much like successful quality programs. Disciplinary measures should be reserved for situations in which an individual manager or 

worker is uncooperative or becomes an impediment to progress.

10 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
WORKER 

PARTICIPATION

TO BE EFFECTIVE, any safety and health 

program needs the meaningful participation of 

workers and their representatives. Workers have 

much to gain from a successful program, and 

the most to lose if the program fails. They also 

often know the most about potential hazards 

associated with their jobs. Successful programs 

tap into this knowledge base.

Worker participation means participation 

in establishing, operating, evaluating, and 

improving the safety and health program. 

All workers at a worksite should participate, 

including those employed by subcontractors 

and temporary staffing agencies (see 

“Coordination and Communication on Multiemployer Worksites”). 

RETALIATION AGAINST

WORKERS IS ILLEGAL

Section 11(c) of the Occupational Safety and Health 

Act of 1970 prohibits employers from retaliating 

against employees for exercising a variety of rights 

guaranteed under the OSH Act, such as filing a 

safety and health complaint with OSHA, raising a 

health and safety concern with their employers, 

participating in an OSHA inspection, or reporting 

a work-related injury or illness. OSHA vigorously 

enforces the anti-retaliation protections provided 

under 11(c) of the OSH Act and other federal statutes. 

For more information, see www.whistleblowers.gov.

IN AN EFFECTIVE safety and health program, all 

workers: 

• Are encouraged to participate in the program 

and feel comfortable providing input and 

reporting safety or health concerns.

• Have access to information they need to 

participate effectively in the program.

• Have opportunities to participate in 

all phases of program design and 

implementation.

• Do not experience retaliation when they raise 

safety and health concerns; report injuries, 

illnesses, and hazards; participate in the 

program; or exercise safety and health rights.

Note: Worker participation is vital to the success of safety and health 

programs. Where workers are represented by a union, it is important 

that worker representatives also participate in the program, consistent 

with the rights provided to worker representatives under the 

Occupational Safety and Health Act of 1970 and the National Labor 

Relations Act.

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 11
WORKER PARTICIPATION

Action item 1: Encourage workers to participate in the program

By encouraging workers to participate in the program, management signals that it values their input 

into safety and health decisions.

How to accomplish it

• Give workers the necessary time and 

resources to participate in the program.

• Acknowledge and provide positive reinforcement to those who participate in the program.

• Maintain an open door policy that invites 

workers to talk to managers about safety and 

health and to make suggestions.

Action item 2: Encourage workers to report safety and health concerns

Workers are often best positioned to identify safety and health concerns and program shortcomings, 

such as emerging job site hazards, unsafe conditions, close calls/near misses, and actual incidents. By 

encouraging reporting and following up promptly on all reports, employers can address issues before 

someone gets hurt or becomes ill.

How to accomplish it

• Establish a simple process for workers to 

report injuries, illnesses, close calls/near 

misses, hazards, and other safety and health 

concerns, and respond to reports promptly. 

Include an option for anonymous reporting to 

reduce fear of reprisal.3

• Report back to workers routinely and 

frequently about action taken in response to 

their concerns and suggestions.

• Emphasize that management will use reported 

information only to improve job site safety 

and health, and that no worker will experience 

retaliation for bringing such information to 

management’s attention (see Action item 5). 

• Empower all workers to initiate or request a 

temporary suspension or shutdown of any 

work activity or operation they believe to be 

unsafe.

• Involve workers in finding solutions to 

reported issues.

3 Under OSHA’s injury and illness recordkeeping rule (29 CFR 1904), employers are required to establish a “reasonable” procedure for 

employees to report work-related injuries and illnesses promptly and accurately. A reasonable procedure is defined as one that would 

not deter or discourage a reasonable employee from accurately reporting a workplace injury or illness.

12 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
WORKER PARTICIPATION

Action item 3: Give workers access to safety and health information

Sharing relevant safety and health information with workers fosters trust and helps organizations make 

more informed safety and health decisions.

How to accomplish it

• Give workers the information they need to understand safety and health hazards and control 

measures on the job site. Some OSHA standards require employers to make specific types 

of information available to workers, such as:

— Safety Data Sheets (SDSs)

— Injury and illness data (prevent disclosure 

of sensitive and personal information as 

required)

— Results of worker exposure monitoring 

conducted at job sites (prevent disclosure 

of sensitive and personal information as 

required)

• Other useful information for workers to 

review can include:

— Chemical and equipment manufacturer 

safety recommendations

— Job site equipment and vehicle 

inspection reports

— Incident investigation reports (prevent 

disclosure of sensitive and personal 

information as required)

— Job hazard analyses (JHAs) and/or job 

safety analyses (JSAs)

Action item 4: Involve workers in all aspects of the program

Including worker input at every step of program design and implementation improves your ability to 

identify the presence and causes of job site hazards, creates a sense of program ownership among workers, 

enhances their understanding of how the program works, and helps sustain the program over time.

How to accomplish it

• Provide opportunities for workers to 

participate in all aspects of the program, 

including, but not limited to helping:

— Develop the program and set goals to 

reduce or eliminate injuries and illnesses.

— Report hazards and develop solutions 

that improve safety and health.

— Analyze hazards in each step of routine 

and nonroutine jobs, tasks, and processes.

— Define and document safe work practices.

— Conduct site inspections, including 

equipment and vehicles.

— Develop and revise safety procedures.

— Participate in incident and close call/near 

miss investigations.

— Train current coworkers and new hires.

— Develop, implement, and evaluate 

training programs.

— Evaluate program performance and 

identify ways to improve it. 

— Take part in exposure monitoring and 

medical surveillance associated with 

health hazards.

• Conduct daily planning meetings, huddles, 

toolbox talks, or tailgate meetings to engage 

workers in the safety and health program.

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 13
WORKER PARTICIPATION

Action item 5: Remove barriers to participation

To participate meaningfully in the program, workers must feel that their input is welcome, their 

voices will be heard, and they can access reporting mechanisms. Participation will be suppressed if 

language, education, or skill levels on the job site are not considered, or if workers fear retaliation 

or discrimination for speaking up (for example, if investigations focus on blaming individuals rather 

than the underlying conditions that led to the incident, or if reporting an incident or concern could 

jeopardize the award of incentive-based prizes, rewards, or bonuses).

How to accomplish it

• Ensure that workers from all levels of the 

organization can participate regardless of 

their skill level, education, or language.

• Provide frequent and regular feedback to 

show employees that their safety and health 

concerns are being heard and addressed.

• Authorize sufficient time and resources to 

facilitate worker participation; for example, 

hold safety and health meetings during 

regular working hours.

• Ensure that the program protects workers 

from being retaliated against for reporting 

injuries, illnesses, and hazards; participating 

in the program; or exercising their safety 

and health rights. Ensure that other policies 

and programs do not discourage worker 

participation. 

• Post the Section 11(c) fact sheet (found at 

www.whistleblowers.gov) in the workplace or 

otherwise make it available for easy access 

by employees.

Note: Incentive programs (such as point systems, awards, and prizes) should be designed in a manner that does not discourage injury and 

illness reporting; otherwise, hazards may remain undetected. Although sometimes required by law or insurance providers, mandatory drug 

testing following injuries can also suppress reporting. Effective safety and health programs recognize positive safety and health activities, such 

as reporting hazardous conditions or suggesting safer work procedures. (See OSHA’s “Employer Safety Incentive and Disincentive Policies and 

Practices” memorandum, dated March 12, 2012: www.osha.gov/as/opa/whistleblowermemo.html.)

14 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
HAZARD 

IDENTIFICATION 

AND ASSESSMENT

IN CONSTRUCTION, unanticipated hazards 

can arise due to changes in project timelines, 

sequence of events, and the fast pace of some 

construction projects. Hazard identification 

and assessment is a crucial part of an effective 

safety and health program. 

One of the “root causes” of construction injuries, 

illnesses, and incidents is the failure to identify 

or recognize hazards that are present, or that 

could have been anticipated. A critical element 

of any effective safety and health program is 

a proactive, ongoing process to identify and 

assess such hazards.

TO IDENTIFY AND ASSESS hazards, employers 

and workers:

• Collect and review information about the 

hazards present or likely to be present at the 

job site.

• Conduct frequent and regular inspections of 

the job site to identify new or recurring hazards.

• Investigate injuries, illnesses, incidents, 

and close calls/near misses to identify the 

underlying hazards, their causes, and safety 

and health program shortcomings.

• Group similar incidents and identify trends in 

injuries, illnesses, and hazards reported.

• Consider hazards associated with emergency 

or nonroutine situations.

• For each hazard identified, determine the 

severity and likelihood of incidents that could 

result, and use this information to prioritize 

corrective actions.

Some hazards, such as housekeeping and tripping 

hazards, can and should be fixed as they are 

found. Fixing a hazard on the spot emphasizes 

the importance of safety and health and takes 

advantage of a safety leadership opportunity. 

Fixing other hazards identified using the 

processes described here will be addressed in the 

next section, “Hazard Prevention and Control.” 

Action item 1: Collect existing information about job site hazards

Information on job site hazards may already be available (from both internal and external sources) to 

employers and workers.

How to accomplish it

• Collect, organize, and review information with 

workers to determine what types of hazards 

may be present and which workers may be 

exposed or potentially exposed.

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 15
• Information available may include:

— Equipment and machinery operating 

manuals.

— SDSs provided by chemical manufacturers.

— Self-inspection reports and inspection 

reports from insurance carriers, 

government agencies, and consultants.

— Records of previous injuries and illnesses, 

such as OSHA 300 and 301 logs and 

reports of incident investigations.

— Workers’ compensation records and reports.

— Patterns of frequently occurring injuries 

and illnesses. 

— Exposure monitoring results, industrial 

hygiene assessments, and medical 

records (appropriately redacted to ensure 

patient/worker privacy).

— Existing safety and health programs 

(hazard communication, confined spaces 

in construction, respiratory protection, 

process safety management, PPE, etc.). 

— Input from workers, including surveys 

or minutes from safety and health 

committee meetings.

— Results of job hazard analyses (also 

known as job safety analyses).

• Information about hazards may be available 

from outside sources, such as:

— OSHA, National Institute for Occupational 

Safety and Health (NIOSH), and Centers 

for Disease Control and Prevention (CDC) 

websites, publications, and alerts.

— Trade associations.

— Labor unions, state and local 

occupational safety and health 

committees/coalitions (“COSH groups”), 

and worker advocacy groups.

— Safety and health consultants.

Action item 2: Inspect the job site for safety hazards

Hazards can be introduced over time as conditions on the job site change, for example, as the building 

goes up, equipment or tools become worn, different trades arrive at and depart from the site, and 

housekeeping practices decline. Setting aside time to frequently and regularly inspect the job site for 

hazards can help identify shortcomings so that they can be addressed before an incident occurs.

How to accomplish it

• Designate a competent person to conduct 

frequent and regular inspections of the 

job sites, materials, and equipment. Have 

workers on the inspection team, and talk to 

them about hazards that they see or report. 

• Plan ahead to anticipate the potential 

introduction of additional hazards by the next 

group of trades or sequence of construction 

activies and to address these additional 

hazards. For example, ensure that structures 

can handle any additional anticipated loads. 

• Be sure to document inspections so you 

can later verify that hazardous conditions 

have been corrected. Take photos or video 

of problem areas to facilitate on-the-job 

discussion and brainstorming about how to 

immediately control them.

• Include all areas and activities in these inspections, such as trenching and excavations, 

staging areas, layout yards, working at heights, 

materials storage, heavy equipment maintenance, and the activities of on-site contractors, 

subcontractors, and temporary workers.

HAZARD IDENTIFICATION AND ASSESSMENT

16 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
• Regularly inspect both mobile construction 

equipment (e.g., forklifts, bulldozers, aerial 

lifts and cranes) and transportation vehicles 

(e.g., cars, trucks).

• Create material delivery areas and internal 

traffic control plans for the construction site 

and laydown areas.

• Use checklists that highlight things to look 

for. Typical hazards fall into several major 

categories, such as those listed below; each 

workplace will have its own list:

— Slip, trip, and fall hazards

— Electrical hazards 

— General housekeeping

— Equipment operation

— Equipment maintenance

— Fire protection

— Work organization and process flow 

(including staffing and scheduling)

— Work practices

— Ergonomic problems

— Lack of emergency procedures

• Before changing operations, workstations, 

or workflow; making major organizational 

changes; or introducing new equipment, 

materials, or processes, seek the input of 

workers and evaluate the planned changes 

for potential hazards and related risks. 

Note: Many hazards can be identified using common knowledge and available tools. For example, you can easily identify and correct hazards 

associated with broken stair rails and frayed electrical cords. Workers can be a very useful internal resource, especially if they are trained in how to 

identify and assess risks.

Action item 3: Identify health hazards 

Identifying workers’ exposure to health hazards is typically more complex and less obvious than 

identifying physical safety hazards. For example, gases and vapors may be invisible, often have no 

odor, and may not have an immediately noticeable harmful health effect. Health hazards include 

chemical hazards (solvents, adhesives, paints, toxic dusts such as lead and silica, etc.), physical hazards 

(noise, radiation, heat, etc.), biological hazards (infectious diseases), and ergonomic risk factors (heavy 

lifting, repetitive motions, vibration from operating tools and earthmoving equipment).

How to accomplish it

• Identify chemical hazards—review SDSs and 

product labels to identify chemicals at your 

job site that have low exposure limits, are 

highly volatile, or are used in large quantities 

or in unventilated spaces. Identify activities 

that may result in skin exposure to chemicals. 

• Identify physical hazards—identify any 

exposures to excessive noise (areas where 

you must raise your voice to be heard by 

others), elevated heat (indoor and outdoor), 

or sources of radiation (radioactive materials, 

X-rays, or radiofrequency radiation).

HAZARD IDENTIFICATION AND ASSESSMENT

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 17
• Identify biological hazards—determine 

whether workers may be exposed to sources 

of infectious diseases, molds, toxic or 

poisonous plants, or animal materials (fur or 

scat) capable of causing allergic reactions or 

occupational asthma.

• Identify ergonomic risk factors—examine 

work activities that require heavy lifting, 

work above shoulder height, repetitive 

motions, or tasks with significant vibration.

• Conduct quantitative exposure assessments, 

when possible, using air sampling or direct 

reading instruments.

• Review OSHA 300 logs to help identify health 

hazards associated with job site exposures. 

Note: Identifying and assessing health hazards may require specialized knowledge. Small businesses can obtain free and confidential occupational 

safety and health advice services, including help identifying and assessing workplace hazards, through OSHA’s On-site Consultation Program (see 

www.osha.gov/dcsp/smallbusiness/consult.html).

Action item 4: Conduct incident investigations 

Incidents—including injuries, illnesses, close calls/near misses, and reports of other concerns—provide 

a clear indication of where hazards exist. By thoroughly investigating incidents and reports, you will 

identify hazards that are likely to cause future harm. The purpose of an investigation must always be 

to identify the root causes (and there is often more than one) of the incident or concern, in order to 

prevent future occurrences.

How to accomplish it

• Develop a clear plan and procedure for 

conducting incident investigations, so that an 

investigation can begin immediately when an 

incident occurs. The plan should cover items 

such as: 

— Who will be involved

— Lines of communication 

— Materials, equipment, and supplies 

needed

— Reporting forms and templates

• Train investigative teams on incident 

investigation techniques, emphasizing 

objectivity and open-mindedness throughout 

the investigation process.

• Conduct investigations with a trained 

team that includes representatives of both 

management and workers. 

• Investigate close calls/near misses.

• Identify and analyze root causes to address 

underlying program shortcomings that 

allowed the incidents to happen.

• Communicate the results of the investigation 

to managers, supervisors, and workers to 

prevent recurrence. 

Note: OSHA has special reporting requirements for work-related incidents that lead to serious injury or a fatality (29 CFR 1904.39). OSHA must be 

notified within 8 hours of a work-related fatality, and within 24 hours of an amputation, loss of an eye, or inpatient hospitalization.

Note: Effective incident investigations do not stop at identifying a single factor that triggered an incident. They ask the questions “Why?” and 

“What led to the failure?” For example, if a piece of equipment fails, a good investigation asks: “Why did it fail?” “Was it maintained properly?” 

“Was it beyond its service life?” and “How could this failure have been prevented?” Similarly, a good incident investigation does not stop when it 

concludes that a worker made an error. It asks such questions as: “Was the worker provided with appropriate tools and time to do the work?” “Was 

the worker adequately trained?” and “Was the worker properly supervised?”

HAZARD IDENTIFICATION AND ASSESSMENT

18 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
Action item 5: Identify hazards 

associated with emergency and 

nonroutine situations

Emergencies present hazards that need to 

be recognized and understood. Nonroutine 

or infrequent tasks, including mobilization 

and demobilization of the site, critical lifts 

with cranes, concrete pours, or setting critical 

structural members, also present potential 

hazards. Plans and procedures need to be 

developed for responding appropriately and 

safely to hazards associated with foreseeable 

emergency scenarios and nonroutine situations.

How to accomplish it

• Identify foreseeable emergency scenarios 

and nonroutine tasks, taking into account the 

types of material and equipment in use and 

the location at the worksite. Scenarios such 

as the following may be foreseeable:

— Structural collapse (i.e., bridges, 

buildings, trenches, and concrete forms)

— Nonroutine tasks, such as infrequently 

performed activities (i.e., critical lifts and 

concrete pours)

— Fires and explosions

— Medical emergencies

— Weather emergencies and natural 

disasters

— Hazardous material spills 

— Startups after planned or unplanned 

equipment shutdowns

Action item 6: Characterize the nature of identified hazards, identify interim 

control measures, and prioritize the hazards for control 

The next step is to assess and understand the hazards identified and the types of incidents that 

could result from worker exposure to those hazards. This information can be used to develop interim 

controls and to prioritize hazards for permanent control (see “Hazard Prevention and Control”). 

How to accomplish it

• Evaluate each hazard by considering the 

severity of potential outcomes, the likelihood 

that an event or exposure will occur, and the 

number of workers who might be exposed. 

• Use interim control measures to protect 

workers until more permanent solutions can 

be implemented.

• Prioritize the hazards so that those 

presenting the greatest risk are addressed 

first. Note, however, that employers have 

an ongoing obligation to control all serious 

recognized hazards and to protect workers.

Note: “Risk” is the product of hazard and exposure. Thus, risk can be reduced by controlling or eliminating the hazard, or by reducing workers’ exposure 

to hazards. An assessment of risk helps employers understand hazards in the context of their own workplace, and prioritize hazards for permanent control. 

HAZARD IDENTIFICATION AND ASSESSMENT

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 19
HAZARD 

PREVENTION AND 

CONTROL

EFFECTIVE CONTROLS protect workers from 

hazards; help avoid injuries, illnesses, and 

incidents; minimize or eliminate safety and 

health risks; and help employers provide 

workers with safe and healthful working 

conditions. The processes described in this 

section will help employers prevent and control 

hazards identified in the previous section. 

TO EFFECTIVELY CONTROL and prevent 

hazards, employers should:

• Involve workers, who often have the best 

understanding of the conditions that create 

hazards and insights into how they can be 

controlled.

• Identify and evaluate options for controlling 

hazards, using a “hierarchy of controls.” 

• Use a hazard control plan to guide the 

selection and implementation of controls, 

and implement controls according to the 

plan.

• Develop plans with measures to protect 

workers during emergencies and nonroutine 

activities. 

• Evaluate the effectiveness of existing controls 

to determine whether they continue to 

provide protection, or whether different 

controls may be more effective. Review new 

technologies for their potential to be more 

protective, more reliable, or less costly. 

Action item 1: Identify control options 

A wealth of information exists to help employers investigate options for controlling identified hazards. Before 

selecting any control options, it is essential to solicit workers’ input on their feasibility and effectiveness.

How to accomplish it

• Review sources such as OSHA standards 

and guidance, industry consensus standards, 

NIOSH publications, manufacturers’ literature, 

and engineering reports to identify potential 

control measures. Keep current on relevant 

information from trade or professional 

associations.

• Investigate control measures used at other 

worksites and determine whether they would 

be effective at your job sites. 

• Get input from workers who may be able 

to suggest and evaluate solutions based on 

their knowledge of the job site, equipment, 

and work processes.

20 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
• For complex hazards, consult with safety 

and health experts, including OSHA’s On-site 

Consultation Program. 

• Plan the sequencing of various trades to 

reduce overlap where possible and to avoid 

exposing other trades to hazards. 

Action item 2: Select controls

Employers should select the controls that are the 

most feasible, effective, and permanent.

How to accomplish it

• Eliminate or control all serious hazards 

(hazards that are causing or are likely to 

cause death or serious physical harm) 

immediately.

• Use interim controls while you develop and 

implement longer-term solutions.

• Select controls according to a hierarchy that 

emphasizes engineering solutions (including 

elimination or substitution) first, followed by 

safe work practices, administrative controls, 

and finally PPE. 

• Avoid selecting controls that may directly or 

indirectly introduce new hazards. Examples 

include exhausting contaminated air into 

occupied work spaces or using hearing 

protection that makes it difficult to hear 

backup alarms. 

• Review and discuss control options with 

workers to ensure that controls are feasible 

and effective.

• Use a combination of control options when 

no single method fully protects workers.

Note: Whenever possible, select equipment, machinery, and materials that are inherently safer based on the application of “Prevention through 

Design” (PtD) principles. Apply PtD when making your own job site or equipment decisions. For more information, see the link to the NIOSH PtD 

initiative on the recommended practices Web page. 

Action item 3: Develop and update a hazard control plan

A hazard control plan describes how the selected controls will be implemented. An effective plan 

will address serious hazards first. Interim controls may be necessary, but the overall goal is to ensure 

effective long-term control of hazards. Control plans at a construction site may need to be updated 

and modified often as the project develops and the site conditions and hazards change.

How to accomplish it

• List the hazards needing controls in order of 

priority.

• Assign responsibility for installing/

implementing the controls to a specific 

person or persons with the power or ability 

to implement the controls.

• Establish a target completion date.

• Plan how you will track progress toward 

completion. 

• Plan how you will verify the effectiveness 

of controls after they are installed or 

implemented.

Most Hierarchy of Controls effective

Change the way

people work

Least

effective

Physically remove

the hazard

Replace

the hazard

Isolate people

from the hazard

Protect the worker with

Personal Protective Equipment

Administrative

Controls

PPE

Engineering

Controls

Substitution

Elimination

Source: NIOSH

HAZARD PREVENTION AND CONTROL

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 21
Action item 4: Select controls to protect workers during nonroutine tasks and 

emergencies

A hazard control plan includes provisions to protect workers during nonroutine tasks and foreseeable 

emergencies, such as falls, cave-ins, fires and explosions, chemical releases, hazardous material spills, 

infrequent activities, natural and weather disasters, workplace violence, terrorist or criminal attacks, 

disease outbreaks (e.g., pandemic influenza), and medical emergencies. Nonroutine tasks, or tasks 

workers don’t normally do, should be approached with particular caution. Prior to initiating such work, 

review JSAs with the workers involved and notify others about the nature of the work, work schedule, 

and any necessary precautions. 

How to accomplish it

• Develop procedures to control hazards that 

may arise during nonroutine tasks (e.g., 

mobilization and demobilization of the site, 

critical lifts with cranes, concrete pours, or 

setting critical structural members).

• Develop or modify plans to control hazards 

that may arise in emergency situations. 

• Procure any equipment needed to control 

emergency-related hazards.

• Assign responsibilities for implementing the 

emergency plan.

• Conduct emergency drills to ensure that 

procedures and equipment provide adequate 

protection during emergency situations. 

Note: Depending on your location, type of business, and materials stored or used on site, authorities including local fire and emergency response 

departments, state agencies, the U.S. Environmental Protection Agency, the Department of Homeland Security, and OSHA may have additional 

requirements for emergency plans. Ensure that your procedures comply with these requirements. 

Action item 5: Implement selected controls on the job site

Once hazard prevention and control measures have been identified, they should be implemented 

according to the hazard control plan. 

How to accomplish it

• Implement hazard control measures 

according to the priorities established in the 

hazard control plan. 

• When resources are limited, implement 

measures on a “worst-first” basis, according 

to the hazard ranking priorities (risk) 

established during hazard identification 

and assessment. (Note, however, that 

regardless of limited resources, employers 

have an obligation to protect workers from 

recognized, serious hazards.) 

• Promptly implement any measures that 

are easy and inexpensive—such as general 

housekeeping, removal of obvious tripping 

hazards such as electrical cords, and basic 

lighting—regardless of the level of hazard 

they involve. 

HAZARD PREVENTION AND CONTROL

22 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
Action item 6: Follow up to confirm that controls are effective

To ensure that control measures are and remain effective, employers should track progress in 

implementing controls, inspect and evaluate controls once they are installed, and follow routine 

preventive maintenance practices.

How to accomplish it

• Track progress and verify implementation by 

asking the following questions:

— Have all control measures been 

implemented according to the hazard 

control plan?

— Have engineering controls been properly 

installed and tested?

— Have workers been appropriately trained 

so that they understand the controls, 

including how to operate engineering 

controls, safe work practices, and PPE 

use requirements?

— Are controls being used correctly and 

consistently? 

• Conduct regular inspections (and industrial 

hygiene monitoring, if indicated) to confirm 

that engineering controls are operating as 

designed. 

• Evaluate control measures to determine if 

they are effective or need to be modified. 

Involve workers in the evaluation of the 

controls. If controls are not effective, 

identify, select, and implement further 

control measures that will provide adequate 

protection.

• Confirm that work practices, administrative 

controls, and PPE use policies are being 

followed.

• Conduct routine preventive maintenance 

of equipment and controls to help prevent 

incidents due to equipment failure.

HAZARD PREVENTION AND CONTROL

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 23
EDUCATION AND 

TRAINING

EDUCATION AND TRAINING are important 

tools for informing workers and managers 

about hazards and controls so they can work 

more safely and be more productive. Another 

role of education and training, however, is 

to provide workers and managers with a 

greater understanding of the safety and health 

program itself, so that they can contribute to its 

development and implementation. 

EDUCATION AND TRAINING provides employers 

(owners and executives), managers, supervisors, 

and workers with: 

• Knowledge and skills needed to do their 

work safely and avoid creating hazards that 

could place themselves or others at risk.

• Awareness and understanding of hazards 

and how to identify, report, and control them.

• Specialized training, when their work involves 

unique hazards.

Additional training may be needed depending 

on the roles assigned to employers or individual 

managers, supervisors, and workers. For 

example, employers, managers, and supervisors 

may need specific training to ensure that they 

can fulfill their roles in providing leadership, 

direction, and resources for the safety and health 

program. Workers assigned specific roles in 

the program (e.g., incident investigation team 

members) may need training to ensure their full 

participation in those functions. 

Effective training and education can be provided 

outside a formal classroom setting. Peer-topeer training, on-the-job training, daily toolbox 

talks, and worksite demonstrations can be 

effective in conveying safety concepts, ensuring 

understanding of hazards and their controls, and 

promoting good work practices.

Action item 1: Provide program awareness training

Managers, supervisors, and workers all need to understand the program’s structure, plans, and 

procedures. Having this knowledge ensures that everyone can fully participate in developing and 

implementing the program.

How to accomplish it 

• Provide training to all managers; supervisors; 

workers; and contractor, subcontractor, and 

temporary agency workers on:

— Safety and health policies, goals, and 

procedures

— Functions of the safety and health program

24 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
— Whom to contact with questions or 

concerns about the program (including 

contact information)

— How to report hazards, injuries, illnesses, 

and close calls/near misses

— What to do in an emergency

— The employer’s responsibilities under the 

program

— Workers’ rights under the OSH Act

• Provide information on the safety and health 

hazards of the job site and the controls for 

those hazards. 

• Ensure that training is provided in the 

language(s) and at a literacy level that all 

workers can understand.

• Emphasize that the program can only 

work when everyone is involved and feels 

comfortable discussing concerns; making 

suggestions; and reporting injuries, incidents, 

and hazards. 

• Confirm, as part of the training, that all 

workers have the right to report injuries, 

incidents, hazards, and concerns and to fully 

participate in the program without fear of 

retaliation. 

Action item 2: Train employers, managers, and supervisors on their roles in the 

program 

Employers, managers, and supervisors are responsible for workers’ safety, yet sometimes have little 

training on safety-related concepts and techniques. They need specific training that allows them to 

fulfill their leadership roles in the program. 

How to accomplish it

• Reinforce employers, managers, 

and supervisors’ knowledge of their 

responsibilities under the OSH Act and the 

workers’ rights guaranteed by the Act.

• Train employers, managers, and supervisors 

on procedures for responding to workers’ 

reports of injuries, illnesses, and incidents, 

including ways to avoid discouraging reporting. 

• Instruct employers, managers, and 

supervisors on fundamental concepts and 

techniques for recognizing hazards and 

methods of controlling them, including the 

hierarchy of controls (see “Hazard Prevention 

and Control”). 

• Instruct employers, managers, and 

supervisors on incident investigation 

techniques, including root cause analysis. 

• As a starting point, consider providing the 

OSHA 30-hour construction safety course, or 

a similar course.

EDUCATION AND TRAINING

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 25
Action item 3: Train workers on their 

specific roles in the safety and health 

program

Additional training may be needed to ensure 

that workers can incorporate safety and health 

responsibilities into their daily routines and 

activities. 

How to accomplish it

• Instruct workers on how to report injuries, 

illnesses, incidents, and concerns. If a 

computerized reporting system is used, 

ensure that all employees have the basic 

computer skills and computer access 

sufficient to submit an effective report. 

• Instruct workers assigned specific roles within 

the safety and health program on how they 

should carry out those responsibilities, including: 

— Hazard recognition and controls (see 

Action item 4)

— Participation in incident investigations

— Program evaluation and improvement

• Provide opportunities for workers to ask 

questions and provide feedback during and 

after the training.

• As the program evolves, institute a more 

formal process for determining the training 

needs of workers responsible for developing, 

implementing, and maintaining the program.

Action item 4: Train workers on hazard identification and controls

Providing workers with an understanding of hazard recognition and control, and actively involving 

them in the process, can help to eliminate hazards before an incident occurs. Employers are required 

to instruct each employee in the recognition and avoidance of unsafe conditions and the regulations 

applicable to his or her work environment to control or eliminate any hazards or other exposure to 

illness or injury [29 C.F.R. 1926.21(b)(2)]. As a starting point, employers may consider providing the 

OSHA 10-hour course for construction or a similar course to be supplemented by orientation training 

and toolbox talks to cover hazards on each specific site.

How to accomplish it

• Train workers on techniques for identifying 

hazards, such as job hazard analysis (see 

OSHA Publication 3071).

• Train workers so they understand and can 

recognize the hazards they may encounter in 

their own jobs, as well as more general workrelated hazards.

• Instruct workers on concepts and techniques 

for controlling hazards, including the 

hierarchy of controls and its importance. 

• Train workers on the proper use of work 

practice and administrative controls.

• Train workers on when and how to wear 

required PPE.

• Provide additional training, as necessary, 

when construction progresses. Consider 

situations such as when new trades and/or 

equipment arrive at the job site to perform 

the next phase of the project.

EDUCATION AND TRAINING

26 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
PROGRAM 

EVALUATION AND 

IMPROVEMENT

ONCE A SAFETY and health program is 

established, it should be evaluated initially 

to verify that it is being implemented as 

intended. After that, employers should 

periodically, and at least annually, step back 

and assess what is working and what is not, 

and whether the program is on track to 

achieve its goals. Whenever these assessments 

identify opportunities to improve the program, 

employers, managers, and supervisors—in 

coordination with workers—should make 

adjustments and monitor how well the program 

performs as a result. Sharing the results of 

monitoring and evaluation on the job site, and 

celebrating successes, will help drive further 

improvement.

PROGRAM EVALUATION and improvement 

includes:

• Establishing, reporting, and tracking goals 

and targets that indicate whether the 

program is making progress. 

• Evaluating the program initially, and 

periodically, to identify shortcomings and 

opportunities for improvement.

• Providing ways for workers to participate in 

program evaluation and improvement.

Action item 1: Monitor performance and progress

The first step in monitoring is to define indicators that will help track performance and progress. Next, 

employers, managers, supervisors, and workers need to establish and follow procedures to collect, 

analyze, and review performance data. 

Both lagging and leading indicators should be used. Lagging indicators generally track worker exposures 

and injuries that have already occurred. Leading indicators track how well various aspects of the program 

have been implemented and reflect steps taken to prevent injuries or illnesses before they occur.

How to accomplish it

• Develop and track indicators of progress 

toward established safety and health goals.

— Track lagging indicators, such as:

 Number and severity of injuries and 

illnesses

 Results of worker exposure 

monitoring that show that exposures 

are hazardous

 Workers’ compensation data, 

including claim counts, rates, and cost

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 27
— Track leading indicators, such as: 

 Level of worker participation in 

program activities

 Number of employee safety 

suggestions

 Number of hazards, near misses, and 

first aid cases reported 

 Amount of time taken to respond to 

reports

 Number and frequency of 

management walkthroughs 

 Number and severity of hazards 

identified during inspections 

 Number of workers who have 

completed required safety and health 

training

 Timely completion of corrective 

actions after a job site hazard is 

identified or an incident occurs

 Timely completion of planned 

preventive maintenance activities

 Worker opinions about program 

effectiveness obtained from a safety 

climate or safety opinion survey

• Analyze performance indicators and evaluate 

progress over time.

• Share results with workers and invite 

their input on how to further improve 

performance.

• When opportunities arise, share your 

experience and compare your results—across 

similar construction projects within your 

company, with other companies you know, or 

through trade or business associations. 

Note: Indicators can be either quantitative or qualitative. Whenever possible, select indicators that are measurable (quantitative) and that will help 

you determine whether you have achieved your program goals. The number of reported hazards and near misses would be a quantitative indicator. 

A single worker expressing a favorable opinion about program participation would be a qualitative indicator.

Action item 2: Verify that the program is implemented and is operating

Employers need to continuously evaluate the effectiveness of the entire program and newer sitespecific programs to ensure they are operating as intended, are effective in controlling identified 

hazards, and are making progress toward established safety and health goals and objectives. The 

scope and frequency of program evaluations will vary depending on changes in OSHA standards; the 

scope, complexity, and maturity of the program; and the types of hazards it must control.

How to accomplish it

• Verify that the core elements of the program 

have been fully implemented on each of your 

job sites.

• Involve workers in all aspects of program 

evaluation, including reviewing information, 

such as incident reports and exposure 

monitoring results; establishing and tracking 

performance indicators; and identifying 

opportunities to improve the program.

• Verify that the following key processes are in 

place and operating as intended:

— Reporting injuries, illnesses, incidents, 

hazards, and concerns

— Conducting job site inspections and 

incident investigations

— Tracking progress in controlling identified 

hazards and ensuring that hazard control 

measures remain effective

PROGRAM EVALUATION AND IMPROVEMENT

28 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
— Collecting and reporting any data needed 

to monitor progress and performance

• Review the results of any compliance audits 

to confirm that any program shortcomings 

are being identified. Verify that actions are 

being taken that will prevent recurrence. 

Action item 3: Correct program shortcomings and identify opportunities to 

improve

Whenever a problem is identified in any part of the safety and health program, employers—in 

coordination with supervisors, managers, and workers—need to take prompt action to correct the 

problem and prevent its recurrence. 

How to accomplish it

• If you discover program shortcomings, take 

actions needed to correct them.

• Proactively seek input from managers, 

workers, supervisors, and other stakeholders 

on how you can improve the program. 

• Determine whether changes in equipment, 

materials, key personnel, or work practices 

trigger any need for changes in the program. 

• Determine whether your performance 

indicators and goals are still relevant and, if not, 

how you could change them to more effectively 

drive improvements in safety and health. 

Note: The scope and frequency of program evaluations will depend on the scope, complexity, and maturity of the program and on the types of 

hazards it must control. Program evaluations should be conducted periodically (and at least annually) but might also be triggered by a change in 

process or equipment, or an incident such as a serious injury, significant property damage, or an increase in safety-related complaints. 

PROGRAM EVALUATION AND IMPROVEMENT

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 29
COMMUNICATION 

AND COORDINATION 

FOR EMPLOYERS ON 

MULTIEMPLOYER 

WORKSITES

CONSTRUCTION JOB SITES typically have 

workers who are employed by a general 

contractor and other workers who are employed 

by a contractor or subcontractor, or workers 

from other sources. 

In these circumstances, it is important that each 

employer and contractor consider how its work 

and safety activities can affect the safety of 

other workers at the job site. Examples include

electrical or mechanical contractors working for 

the general contractor at a building construction 

site. Several subcontractors working together 

on a job site (such as a subcontractor tying 

rebar and another subcontractor setting 

concrete formwork at the same job site) would 

be another example. 

IN TODAY’S ECONOMY, an increasing number 

of workers are assigned by staffing agencies 

to work at specific “host” worksites under the 

direction and control of the host employer. 

Examples include unskilled laborers or skilled 

trade workers from a staffing agency who 

may be placed in either short- or long-term 

assignments with a general contractor or other 

contractor. In these situations, it is important 

for the staffing agency and the host employer 

to communicate and coordinate to provide 

and maintain a safe work environment for their 

workers. (Note: Any employer on a multiemployer worksite may be a “joint employer” 

with a staffing agency if temporary workers are 

utilized.)

In both temporary worker and multiemployer 

situations, safety is enhanced if employers 

establish mechanisms to coordinate their efforts 

and communicate effectively regarding their 

safety and health responsibilities to afford all 

workers equal protection against hazards. These 

mechanisms include measures to ensure that all 

workers on site (and their representatives) can 

participate in preventing injuries and illnesses. 

Failure to take these steps may undermine safety 

programs. For example, if the different employers 

have inconsistent policies for when and where 

to wear PPE, workers may mistakenly believe 

that the equipment is not needed, leading to 

injury. Inconsistent safety policies may also cause 

workers to question the credibility of safety and 

health programs, resulting in less meaningful 

employee engagement and participation.

30 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
Effective communication and coordination 

among such employers means that:

• General contractors and their workers are 

aware of:

— The types of hazards that may arise from 

the work being done on site by workers 

employed by contractors, subcontractors, 

or staffing agencies. 

— The procedures or measures needed 

to avoid or control exposure to these 

hazards. 

— How to contact the contractor, 

subcontractor, or staffing agency if they 

have a safety concern.

• Before coming on site, contractors, 

subcontractors, and staffing agencies and 

their workers are aware of:

— The previous work done and the types of 

hazards that may already be present at 

the job site.

— The procedures or measures they need to 

use to avoid or control their exposure to 

these hazards.

— How to contact the general contractor to 

get more information, report an injury, 

illness, or incident or if they have a safety 

concern.

COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 31
Action item 1: Establish effective communication 

Each general contractor establishes and implements a procedure to ensure the exchange of 

information about hazards present on site and the hazard control measures in place. Thus, all workers 

on the site are aware of worksite hazards, and the methods and procedures needed to control 

exposures to them. 

How to accomplish it

• The general contractor communicates with 

contractors, subcontractors, and staffing 

agencies to determine which among them 

will implement and maintain the various 

parts of the safety and health program, 

to ensure protection of all on-site workers 

before work begins. These determinations 

can be included in contract documents that 

define the relationships between the parties 

and confirmed during pre-construction 

meetings. 

• The general contractor establishes and 

implements procedures to exchange 

information with contractors, subcontractors 

and staffing agencies about hazards present 

on the job site and the measures that have 

been implemented to prevent or control such 

hazards. 

• The general contractor gathers and 

disseminates information sufficient to 

enable each employer to assess hazards 

encountered by its workers and to avoid 

creating hazards that affect workers on the 

site.

• Contractors, subcontractors, and staffing 

agencies regularly give the general 

contractor any information about injuries, 

illnesses, hazards, or concerns reported by 

their workers and the results of any tracking 

or trend analysis they perform. 

• Each contractor or subcontractor establishes 

and implements a procedure for providing 

the general contractor with information 

about the hazards and control measures 

associated with the work being done by its 

workers, and the procedures it will use to 

protect workers on the site.

• The general contractor gives contractors, 

subcontractors, and staffing agencies the 

right to conduct site visits and inspections 

and to access injury and illness records and 

other safety and health information.

• The general contractor provides contractors, 

subcontractors, and staffing agencies 

and their workers information on hazards 

that could occur as a result of nonroutine 

operations or emergencies and procedures to 

follow in emergency situations. 

• Information is communicated before on-site 

work starts and, as needed, if conditions 

change. 

COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES

32 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
Action item 2: Establish effective coordination

General contractors, contractors, subcontractors, and staffing agencies coordinate on work planning, 

scheduling, and resolving program differences to identify and work out any concerns or conflicts that 

could impact safety or health.

How to accomplish it

• General contractors:

— Include in contracts and bid documents 

any safety-related specifications and 

pre-qualifications and ensure that 

contractors, subcontractors, and staffing 

agencies selected for the work meet 

those requirements. 

— Identify issues that may arise during 

on-site work and include procedures 

to be used by the general contractor, 

contractors, subcontractors, and 

staffing agencies for resolving any 

conflicts before work starts. This may be 

accomplished through pre-construction 

meetings.

• General contractors coordinate with 

contractors, subcontractors, and staffing 

agencies to:

— Ensure that work is planned and 

scheduled to minimize impacts on safety.

— Ensure that joint-employed workers are 

adequately trained and equipped before 

arriving on the worksite.

— Harmonize their safety and health 

policies and procedures to resolve 

important differences, so that all workers 

at the site have the same protection and 

receive consistent safety information (i.e., 

conduct site-specific training).

• General contractors, contractors, 

subcontractors, and staffing agencies:

— Work together to deal with unexpected 

staffing needs by ensuring that enough 

trained and equipped workers are 

available or that adequate lead time is 

provided to train and equip workers.

— Make sure that managers with decisionmaking authority are available and 

prepared to deal with day-to-day 

coordination issues.

COMMUNICATION AND COORDINATION FOR EMPLOYERS ON MULTIEMPLOYER WORKSITES

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 33
LIST OF ABBREVIATIONS 

CDC Centers for Disease Control and Prevention

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration 

PPE personal protective equipment

PtD Prevention through Design

SDS Safety Data Sheet

SHARP Safety and Health Achievement Recognition Program

VPP Voluntary Protection Programs

GLOSSARY OF TERMS 

close call/near miss: An incident that could have, but did not, result in death, injury, 

or illness. They signal that hazards are not being adequately 

controlled or that new hazards have arisen. 

contractor: An individual or firm that agrees to furnish materials or perform 

services at a specified price.

elimination: A change in process or workplace condition that removes the 

hazard or ensures that no worker can be exposed to a hazard 

under any foreseeable circumstances. 

hierarchy of controls: A system for selecting and implementing the most effective 

control solutions for workplace hazards that includes:

• Elimination.

• Substitution.

• Engineering controls.

• Administrative controls.

• Personal protective equipment. 

This is known as the “hierarchy of controls” because they should 

be considered in the order presented. Controls at the top of the 

hierarchy are potentially more effective and more protective 

than those lower in the hierarchy.

34 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov
host employer: An employer who has general supervisory authority over the 

worksite, including controlling the means and manner of work 

performed and having the power to correct safety and health 

hazards or require others to correct them. 

industrial hygiene: The science of protecting and enhancing the health and safety 

of people at work and in their communities.

job hazard analysis: A technique that focuses on job tasks as a way to identify 

hazards before they occur. It focuses on the relationships among 

the worker, the task, the tools, and the work environment.

joint-employed worker: A worker hired and paid by a staffing agency and assigned to work 

for a host employer, whether or not the job is actually temporary. 

lagging indicators: Measures of the occurrence and frequency of events in the past 

such as the number or rate of injuries, illnesses, and fatalities. 

leading indicators: Measures intended to predict the occurrence of events in the 

future. Leading indicators are proactive, preventative, and 

predictive measures that provide information about the effective 

performance of safety and health program activities that can 

drive the control of workplace hazards. 

metrics: Measures of performance.

multiemployer worksite: Any worksite where two or more employers are present. See 

OSHA’s Multiemployer Citation Policy.

nonroutine operations: Operations that do not occur frequently or that occur as a result 

of an emergency.

peer-to-peer training: A type of on-the-job training where workers exchange information 

about hazards, controls, reporting procedures, and work 

procedures that are relevant to the safety and health program.

Prevention through Design: A NIOSH national initiative to prevent or reduce occupational 

injuries, illnesses, and fatalities through the inclusion of 

prevention considerations in all designs that impact workers. 

PtD encompasses all of the efforts to anticipate and design out 

hazards to workers in facilities, work methods and operations, 

processes, equipment, tools, products, new technologies, and 

the organization of work. 

quantitative exposure assessment: Techniques used to quantitatively measure workers’ exposure 

to hazards, particularly health hazards, such as sampling for 

chemicals, dusts, biological organisms, noise, radiation, or other 

assessments. The purpose of such assessments is to quantify 

the level of workers’ exposure to a hazard. Also known as 

exposure monitoring.

root cause analysis: A collective term that describes a wide range of approaches, 

tools, and techniques used to uncover causes of problems. 

GLOSSARY OF TERMS

www.osha.gov RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION 35
Safety and Health Achievement An OSHA program that recognizes small business employers 

Recognition Program: who have used OSHA’s On-site Consultation Program services 

and operate an exemplary injury and illness prevention program.

safety data sheet: Written or printed material used to communicate the 

hazards of substances and chemical products to employees 

prepared in accordance with paragraph (g) of OSHA’s Hazard 

Communication standard. 

serious hazards: Hazards that are causing or are likely to cause death or serious 

physical harm. See OSHA’s Field Operations Manual, Chapter 4.

shortcoming: A fault, deficiency, or gap that results in a failure to meet 

program design criteria. 

staffing agency: A firm that provides temporary workers to host employers. 

A staffing agency hires its own employees and assigns them 

to support or supplement a client’s workforce in situations 

involving employee absences, temporary skill shortages, 

seasonal workloads, and special projects.

substitution: The replacement of toxic or hazardous materials (or the 

equipment or processes used with them) with ones that are less 

harmful. 

Voluntary Protection Programs: An OSHA initiative that recognizes employers and workers in the 

private industry and federal agencies who have implemented 

effective safety and health management systems and maintain 

injury and illness rates below the U.S. Bureau of Labor Statistics 

averages for their respective industries.

work practices: A set of procedures for performing a specific work assignment 

safely.

GLOSSARY OF TERMS

36 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS IN CONSTRUCTION www.osha.gov