The 100 Most Frequently Cited OSHA 

Construction Standards in1991: A Guide 

for the Abatement of the Top 25 

Associated Physical Hazards

U.S. Department of Labor

Occupational Safety and Health Administration

March 1995 (Reprinted)
PUBLICATION DISCLAIMER 

– OSHA’s 100 Most Frequently Cited Standards: 

The information contained in this document was correct at the time of publication

in 1991. Several standards have changed since that time. The current

standards may be viewed by selecting this hyperlink:

http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1926.html

There have been technological advances in safety equipment, and some of the

acceptable abatement methods indicated are no longer the safest means to

protect the worker. The current standards (link to standards) and Interpretations

(http://www.osha-slc.gov/OshDoc/toc_interps.html) will assist you in determining

the best examples to use for your training.
Material contained in this publication is in the public domain and

may be reproduced, fully or

partially, without permission of

the Federal Government. Source

credit is requested but not

required.

The information contained in this

publication is not considered a

substitute for any provisions of

the Occupational Safety and

Health Act of 1970 or for any

standards issued by OSHA.

This report was written by

Michael L. Marshall,

Civil Engineer

Charles Handesty,

Construction Safety Specialist

This information will be made

available to sensory impaired

individuals upon, request.

Voice phone: (202)219-8644;

TDD message referral phone:

1-800-326-2577
The 100 Most Frequently Cited OSHA

Construction Standards in1991: A Guide

for the Abatement of the Top 25

Associated Physical Hazards

U.S. Department of Labor 

Robert B. Reich, Secretary 

Occupational Safety and Health Administration 

Joseph A. Dear, Assistant Secretary 

Office of Construction and Engineering 

Bruce Swanson, Director 

March 1995 (Reprinted) 

For sale by the U.S. Government Printing Office 

Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328 

ISBN 0-16-048011-6

TABLE OF CONTENTS

Page

ACKNOWLEDGEMENT....................................................................................... v

ABSTRACT....................................................................................................... vii

SIMPLIFIED FLOW CHARTS OF CONTENTS OF REPORT....................................... ix

1.0 INTRODUCTION...................................................................................... 1

2.0 THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS

............................................................................................................. 5

3.0 100 MOST CITED PHYSICAL LIST 17

4.0 FORMAT AND USE OF GUIDE 27

4.1 USE OF GUIDE 27

4.2 FORMAT 28

5.0 GUIDE FOR THE ABATEMENT OF TH E TOP 25 MOST CITED PHYSICAL 

HAZARDS................................................................................................. 31

5.1 THE TOP 25 GUIDE SHEETS 31

5.2 CONSTRUCTION SPECIFICATIONS FOR GUARDRAILS 

AND TOEBOARDS.............................................................................. 82

5.3 REFERENCES................................................................................... 84

INDEX................................................................................................................. 87

iii
CONTENTS (CONTINUED)

LIST OF FIGURES AND TABLES

Page

FIGURE 1-1 EMPLOYER’S SAFETY AND HEALTH PROGRAM 4

TABLE 2-1 100 MOST CITED CONSTRUCTION STANDARDS IN AND THEIR 

RELATIVE RANKING TO 1991 7

TABLE 2-2 THE MOST CITED CONSTRUCTION STANDARDS IN 1991 BY 

PERCENTAGE OF TOTAL VIOLATIONS 12

FIGURE 2-1 FREQUENCY OF PROGRAMMATIC VS. PHYSICAL VIOLATIONS: 100 

MOST CITED VIOLATIONS IN 1991 14

FIGURE 2-2 DISTRIBUTION OF THE 100 MOSWT FREQUENTLY CITED 

STANDARDS BY SUBPART 15

TABLE 3-1 LIST OF THE 100 MOST FREQUENTLY CITED OSHA 

CONSTRUCTION STANDARDS RELATED TO PHYSICAL HAZRDS IN 

1991 18

TABLE 3-2 GROUPING BY SUBMECT OF 100 MOST CITED PHYSICAL 

STANDARDS 22

TABLE 3-3 COMBINED STANDARDS BY SUBJECT MATTER FROM THE LIST OF 

100 PHYSICAL STANDARDS IN 1991 23

TABLE 5.2-1 MINIMUM SPECIFICATIONS FOR GUARDRAIL SYSTEMS 82

TABLE 5.2-2 MINIMUM SPECIFICATIONS FOR TOEBOARDS 83

iv
ACKNOWLEDGEMENTS

Staff from the OSHA National Office provided assistance in preparing this report. The following

directors and their staffs provided information, review and comments for the report: Roy Gurnham

from the Office of Construction and Maritime Compliance Assistance; Gerald Reidy from the

Office of Construction and Civil Engineering Safety Standards; and Joseph Pipkin from the Office

of Electrical and Electronic Engineering Safety Standards. The Office of Information and

Consumer Affairs, Jim Foster, Director, Jim Blackmon and Sue Fleming provided editorial review

and production assistance. Charles Culver, Director and Fred Anderson, Deputy Director from the

Office of Construction and Engineering (OCE) provided direction and input for the report. Eugene

Simms, Cooperative Education Student (OCE) spent considerable amount of time and effort

tabulating data and developing computer graphic charts and tables.

Cathleen Cronin of the OSHA Training Institute provided direction and access to photographs,

slides and documents which were used in this report. Manny Ypsilantes and Donovan Grentz

provided information, photographs, review and comments for the report.

The following OSHA field personnel provided information, review and comments for the report:

William Burke, Assistant Area Director, Region VI - Dallas, TX Area Office; Robert Holmes, Area

Director and Mike Partin, Assistant Area Director, Region VI - Baton Rouge, LA, Area Office;

Mirth A. Deshler, Safety Specialist, Region VIII - Denver, CO, Area Office; Brian Hennessy and

Bob Chadwick, Safety Specialists, Region IV- Tampa, FL, Area Office.

The following individuals and organizations provided photographs for the report: Larry Falk, Area

Director, OSHA, Tampa, FL, Area Office; Anthony Solano, Administrator, Construction and

General Laborers, District Council of Chicago and Vicinity Training Facility, Carol Stream, IL;

Carl Jones, Apprenticeship Director, Florida West Coast Carpenters (J.A.T.C.), Tampa, FL;

Safeway Steel Products; and the Scaffolding, Shoring and Forming Institute.

v

ABSTRACT

This report is intended to help employers and employees identify and correct hazards related to the

most frequently cited OSHA standards found on construction sites throughout the United States. The

report also is designed as a resource document for OSHA field personnel. The 100 most cited

construction standards for 1991 are presented in the report. The standards cited were checked against

similar citations for the years 1987 thru 1990. The relative rankings of the standards cited are similar,

affected mostly as a result of the incorporation of new standards. The list was compiled from the

OSHA Integrated Management Information System (IMIS). It includes citations by Federal OSHA in

the 27 Federal Plan States for employers engaged in construction activities defined by Standard

Industrial Classifications (SIC) 15, 16, 17. Citations issued by states operating OSHA approved state

plans are not included. A listing of the 100 most cited construction standards related to physical

conditions on job sites also is included. This second list does not include citations for so called

"paperwork" requirements such as the hazard communications standard ([29 CFR] 1926.59) and safety

training and education (1926.21) but does include citations for standards such as hard hats (1926.100),

guards for open sided floors (1926.500), etc. The report also examines in detail the top 25 construction

hazards relating to physical conditions. Information on the 25 standards includes, among other things:

1) citation and text of the standards; 2) intent and application of the standard; 3) hazards associated

with the standard; 4) example case histories related to the standard; 5) suggested abatement of

hazardous conditions related to the standard; and 6) additional source materials including

interpretation, compliance directives, industry standards, etc., which may aid in the compliance with a

given standard.

Keywords: 100 Most Cited; OSHA Standards; Cited Standards; Physical Hazards; Hazard Abatement;

Most Cited Construction Standards

vii



1.0 INTRODUCTION

Fatalities and injuries due to accidents continue to beseige the construction industry. In an effort to

help employers, employees and OSHA compliance personnel (CSHO's) identify hazards that are

causing accidents, OSHA has compiled listings in this report of the 100 Most Cited Standards in

the construction industry. The purposes of the report are to: 1) identify the hazards causing

accidents that are associated with the most frequently cited OSHA construction standards; 2)

educate the employer, employee and CSHO on hazards found on construction sites and to offer

suggestions for eliminating, controlling or mitigating the hazards; 3) notify employers of the types

of violations on construction sites that OSHA personnel find most frequently; and 4) provide

information in a format that would be readily useable for safety talks, tool box meetings, etc.

The first part of this report contains two lists:

The first list includes the 100 most frequently cited construction standards. The second list of 100

covers only those citations for standards related to physical conditions on a job site. This list does

not include citations for so called "paperwork" requirements such as the hazard communications

standard (Code of Federal Regulations - Title 29 [CFR 29], 1926.59) and safety training and

education (1926.21) but does include citations for standards such as hard hats (1926.100), guards for

open sided floors (1926.500), etc. The report refers to the first list as the 100 Most Cited List and

the second list as the 100 Most Cited Physical List.

The second part of this report (Chapters 4 and 5) focuses on the top 25 construction hazards from

the 100 Most Cited Physical List and serves as a guide to the elimination, control and or mitigation

of the physical hazards addressed by the standards cited.

The most cited lists were compiled from the OSHA Integrated Management Information System

(IMIS). The IMIS system contains, among other information, a record of all the citations that were

issued for each inspection conducted. The lists were generated using 1991 calendar year data for

citations issued to employers in the Standard Industrial Classification (SIC) 15, 16, and 17, for

construction. Data also are presented for a five-year period that show that the most cited standards

1
tend to be consistent over a period of years with the rankings altered mostly by the addition of new

standards. The data used in this report were drawn from the 27 Federal plan states. Data for states

operating OSHA approved state plans are not included.

The 100 Most Cited List contains standards related to both physical and programmatic

requirements. For this report a programmatic standard means a standard that could not be identified

as the primary physical cause of an accident, but had the programmatic elements been in place and

fully implemented might have precluded the hazardous condition(s) that led to the accident from

ever existing. Programmatic standards are usually educational or information based such as Hazard

Communication standards, recordkeeping requirements, OSHA poster, general safety/health

training requirements, or written programs such as respirator, fire prevention plans, etc.

Although this report emphasizes physical hazards and hazard abatement, it cannot be emphasized

strongly enough, however, that a complete and effective safety and health program must

contain all the programmatic elements as well as the elements which address physical hazards.

The elements of a thorough and effective jobsite safety program are listed in FIGURE 1-1 (see page

4).

If hazards addressed by the 100 Most Cited Lists do not exist on a particular site one should not

conclude that there are no other hazardous conditions that might contribute to an accident. To the

contrary, OSHA recognizes that a large percentage of accidents occur due to hazardous conditions

that are not covered by specific standards. OSHA standards are only minimum requirements to run

a safe and healthful construction site. Therefore, all parties involved with a site must continually

identify all hazardous conditions, whether addressed by OSHA standards or not, to achieve a safe

and healthful work site.

The 100 Most Cited Physical List ranks the most frequently cited standards that constitute actual

physical hazards. This list consists of 78 standards included in the 100 Most Cited List (22

standards from the 100 Most Cited List were programmatic) and 22 other identified physical

hazards. Much of the emphasis in this report is placed on controlling physical hazards. A physical

hazard is defined in this document as a hazard that can be eliminated, controlled and/or mitigated

2
by: 1) using some type of hardware, i.e. guard rails to prevent falls, body

belt/harness-lanyard-lifeline to mitigate the effects of a fall, flash arrestors in safety cans to prevent

a fire/explosion, a fire extinguisher to control or mitigate the effects of an incipient stage fire; or 2)

a specific inspection protocol designed to identify defects which can lead to accidents such as the

monthly inspections of critical items of crawler, locomotive and truck cranes prescribed by 29 CFR

1926.550(b)(2). A physical hazard can directly cause an accident; conversely, a programmatic

violation would not have a direct physical linkage to the direct or primary cause of an accident.

The GUIDE in the second part of the report provides detailed information for the

first 25 standards on the 100 Most Cited Physical List. The GUIDE's format lends itself to safety

meetings, tool box talks, etc. Chapter 4 (see page 27) describes the GUIDE, its format and use.

The GUIDE itself can be found in Chapter 5 (see page 31).

Twenty-five physical standards were chosen for the GUIDE because all other individual standards

were cited less than 0.5 percent of the total number (approximately 62,000) of citations issued to

construction contractors in 1991. Citations associated with the 25th Most Cited Physical Standard,

for example, account for only one-half of one percent of all construction violations.

3
FIGURE 1-1

EMPLOYER'S SAFETY AND HEALTH PROGRAM 1291

A. Management's Commitment and Leadership

1. Policy statement: goals established, issued, and communicated to employees. 

2. Program revised annually. 

3. Participation in safety meetings, inspections; agenda items in meetings. 

4. Commitment of resources is adequate. 

5. Safety rules and procedures incorporated into site operations. 

6. Management observes safety rules. 

B. Assignment of Responsibility

1. Safety designee on-site, knowledgeable and accountable. 

2. Supervisors (including foreman) safety and health responsibilities understood. 

3. Employees adhere to safety rules. 

C. Identification and Control of Hazards

1. Periodic site safety inspection program involves supervisors. 

2. Preventive controls in-place (PPE, maintenance, engineering controls). 

3. Action taken to address hazards. 

4. Safety committee, where appropriate. 

5. Technical references available. 

6. Enforcement procedures by management. 

D. Training and Education

1. Supervisors receive basic training. 

2. Specialized training taken where needed. 

3. Employee training program exists, is on-going and is effective. 

E. Recordkeeping and Hazard Analysis

1. Records maintained of employees illnesses/injuries and posted. 

2. Supervisors perform accident investigations, determine causes and propose corrective action. 

3. Injuries, near misses and illnesses are evaluated for trends, similar causes; corrective action initiated. 

F. First Aid and Medical Assistance

1. First-aid supplies and medical services available. 

2. Employees informed of medical results. 

3. Emergency procedures and training where necessary. 

4 
2.0 THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION

STANDARDS

The following section lists the construction standards most frequently cited in 1991. The

information is presented in list form which will be referred to as the 100 Most Cited List. Table 2-1

(see page 7) list the 100 Most Cited Construction Standards in 1991. This table also ranks these

standards relative to 1991 for the years 1987 thru 1990. The 100 Most Cited List gives a ranking

from the first most frequently cited construction standard to the 100th most cited and provides the

standard number, a brief description and its ranking for 1991 relative to the years 1987-1990. The

100 Most Cited list contains standards that are related to both physical and programmatic

requirements. A programmatic requirement, for this list, means a standard that could not be

identified as the primary physical cause of an accident. Programmatic elements supplement

physical hazard standards and if they are fully implemented, may prevent hazardous condition(s)

that lead to accidents. Programmatic standards are usually educational or information based and

cover injury and illness recordkeeping requirements, Hazard Communication requirements, etc.

No in-depth analysis was conducted to determine the reason(s) for any changes in a standard's

rankings in the earlier years. However, the biggest factor for change appears to be the

implementation of new standards. For example, the Hazard Communication Standard was not

enforced in construction because of legal proceedings until March 1989. The immediate result was

that three provisions of the Hazard Communication Standard were ranked #1, #2 & #3 in the 100

Most Cited List starting in 1989. This pattern is consistent for other implemented standards during

this period. Generally, except for the new standards previously mentioned, the ranking of the

individual standards did not significantly change during the five-year period.

Another list related to the 100 Most Cited List is presented in Table 2-2 (see page 12), which lists

the percentage of the total number of (approximately 62,000 violations) cited under each of these

standards in 1991.

5
A chart illustrates the number of PHYSICAL standards vs. the number of PROGRAMMATIC

standards cited in the 100 Most Cited List, (see Figure 2-1, page 14). The relatively high number of

programmatic violations (22%) might be an indicator of several things such as: 1) a higher degree of

noncompliance with the programmatic requirements that are mostly performance oriented; 2) a

larger emphasis by CSHO's on programmatic violations; or 3) a higher degree of compliance with

specification standards that are mostly addressed by the physical standards. Consequently, the

potential number of specification type violations might be fewer on jobsites.

Another chart illustrates from which Subpart, i.e. Subpart N, O, X, etc. each of the standards from

the 100 Most Cited List originates, (see Figure 2-2, page 15). This chart directs and assists those

who know which Subparts of the standards are the most applicable to his/her operation. With the

specific Subparts, the numbers listed for the Subparts of interest can be cross-referenced with the

100 Most Cited List to find the requirements that relate to the operation.

6
TABLE 2-1

100 MOST CITED CONSTRUCTION STANDARDS AND THEIR RELATIVE

RANKING TO 1991

RELATIVE RANKING TO 1991

YEARS

STANDARDS

[1926 UNLESS

NOTED]

DESCRIPTION

1991 1990 1989 1988 1987

59(e)(1) WRITTTEN HAZ. COMM.

PROGRAM 1 1 1 **(1) **

59(h) EMPLOYEE TRAINING – HAZ.

COMM.

2 2 2 **(1) **

59(g)(1) MSDS FOR HAZ. CHEMICALS 3 3 3 **(1) **

1903.2(a)(1) OSHA POSTER 44412

59(g)(8) ACCESSIBLE COPIES OF MSDS 5 5 12 **(1) **

21(b)(2) SAFETY

TRAINING/RECOGNITION OF

UNSAFE CONDITIONS

6 7 10 3 6

500(d)(1) GUARDING OPEN SIDED

FLOORS

78854

100(a) HEAD PROTECTION 8 10 7 6 5

404(b)(1)(i) GROUND FAULT PROTECTION 96521

404(f)(6) ELECTRICAL GROUNDING 10 9 6 4 3

20(b)(1) ACCIDENT PREVENTION

PROGRAM

11 11 9 7 7

652(a)(1) PROTECTIVE SYSTEMS FOR

TRENCH/EXCAV.

12 15 *(2) * *

451(d)(10) GUARDRAIL SPEC. FOR

TUBULAR WELDED

SCAFFOLDS

13 13 13 9 11

1904.2(a) OSHA 200 LOG 14 12 11 8 9

28(a) PPE USED FOR SPECIFIC

OPERATION

15 14 14 10 8

1052(c)(1) STAIR RAIL REQUIRED @ 30” 16 *(3) ***

152(a)(1) STORMING AND HANDLING

FLAMM. OR COMB. LIQUIDS

17 17 15 12 14

25(a) GENERAL HOUSEKEEPING 18 18 16 11 10

20(b)(2) ACCIDENT PREVENTION

INSPECTIONS

19 15 17 20 49

651(k)(1) INSPECT. OF PHYSICAL

COMPONENTS OF

TRENCH/PROTECT. SYSTEM

20 22 *(2) * *

7
RELATIVE RANKING TO 1991

YEARS

STANDARDS

[1926 UNLESS

NOTED]

DESCRIPTION

1991 1990 1989 1988 1987

451(a)(13) SAFE ACCESS FOR

SCAFFOLDS 21 25 25 27 33

404(b)(1)(ii) GROUND FAULT CIRCUIT

INTERUPTER

22 19 18 13 12

701(b) GUARDING PROTRUDING

STEEL REBARS

23 40 77 *(4) *

59(e)(1)(i) LIST OF HAZ. CHEMICALS 24 31 50 **(1) **

451(a)(4) SCAFFOLD GUARDING SPEC’s. 25 21 19 17 19

651(j)(2) SPOIL PILE PROTECTION 26 28 27 25 27

350(j) WELDING AS PER ANSI Z49.1-

1967

27 28 27 25 27

350(a)(9) SECURING COMPRESSED GAS

CYLINDERS

28 27 24 19 20

1910.20(g)(2) COPY OF 1910.20 STND.

AVAILABLE

29 35 20 40 96

102(a)(1) EYE/FACE PROTECTION 30 26 29 29 28

1910.20(g)(1)(i) INFORMING OF MEDICAL

ACCESS

31 62 40 *(5) *

1053(b)(1) LADDER EXTENDED 3’ ABOVE

LANDING

32 *(3) ***

500(b)(1) GUARDING FLOOR OPENING 33 23 22 16 16

651(c)(2) ACCESS/EGRESS FROM

TRENCH/EXCAV.

34 32 *(2) * *

1910.20(g)(1)(iii) RIGHT OF ACCESS TO

MEDICAL RECORDS

35 63 43 *(5) *

403(b)(2) LISTED, LABELED OR CERT.

EQUIP.

36 34 59 68 78

405(a)(2)(ii)(j) FLEXIBLE CORDS DESIGNED

FOR HARD OR EXTRA HARD

USAGE

37 33 33 22 21

1910.20(g)(l)(ii) FLEXIBLE CORDS DESIGNED FOR

HARD OR EXTRA HARD USAGE 38 69 46 *(5) *

405(g)(2)(iv) STRAIN RELEIF FOR CORDS 39 38 42 38 51

59(f)(5)(i) LABEL SPEC. – HAZ. CHEMICAL(S) 40 39 45 **(1) **

304(f) WOODWORKING TOOLS AS

PER ANSI 01-1.1967

41 43 34 23 17

105(a) SAFETY NETS ABOVE 25’ 42 52 48 43 59

300(b)(2) MACHINE GUARDING –

MOVING PARTS

43 42 39 35 29

8
RELATIVE RANKING TO 1991

YEARS

STANDARDS

[1926 UNLESS

NOTED]

DESCRIPTION

1991 1990 1989 1988 1987

59(f)(5)(ii) LABEL SPEC. – HAZ. COMM. 44 50 65 **(1) **

405(a)(2)(ii)(e) PROTECTION TEMPORARY

LIGHTING

45 48 38 26 34

500(c)(1) GUARDING WALL OPENING 46 58 57 44 41

403(i)(2)(i) ACCESS TO INSTALL. OVER

600 VOLTS

47 45 49 37 36

451(e)(10) GUARDING SPEC. FOR MOBILE

SCAFFOLDS

48 46 41 34 37

451(d)(3) BRACING OF TUBULAR

WELDED SCAFFOLD

49 55 56 48 54

5(a)(1) GENERAL DUTY CLAUSE 50 30 54 65 73

404(f)(7)(iv)(c) GROUNDING SPECIFIC TYPES

OF EQUIP.

51 53 32 30 31

59(e)(4) ACCESSIBILITY OF THE

WRITTEN HAZ.

COMMUNICATION PROGRAM

52 54 **(1) ** **

50(f) EMERGENCY NUMBERS

POSTED

53 36 26 15 13

1051(a) ACCESS BY

LADDER/STARIWAY @

CHANGE IN ELEVATION > 19”

54 *(3) ***

405(b)(2) COVERS FOR PULL BOXES,

JUNCTION BOXES, OUTLETS,

ETC.

55 61 58 54 47

416(e)(1) WORN AND FRAYED

ELECTRICAL CORDS

56 57 62 55 81

451(a)(2) LOAD DESIGN FOR

SCAFFOLDS

57 60 66 59 61

405(b)(1) UNUSED OPENING IN BOXES 58 70 74 64 64

550(b)(2) CRANES – ANSI B30.5-1968 59 65 63 50 52

451(e)(4) TIGHTLY PLANKED MOBILE

SCAFFOLD

60 51 47 42 45

404(a)(2) REVERSE POLARITY OF

CONDUCTORS

61 59 61 45 39

1053(b)(16) DEFECTIVE PORTABLE LADDER 62 *(3) ***

405(a)(2)(ii)(i) PROTECTION OF FLEXIBLE CORDS

AND CABLES 63 44 37 28 25

1060(a) TRAINING PROGRAM FOR

LADDERS

64 *(3) ***

9
RELATIVE RANKING TO 1991

YEARS

STANDARDS

[1926 UNLESS

NOTED]

DESCRIPTION

1991 1990 1989 1988 1987

602(a)(9)(i) HORNS ON BIDIRECTIONAL

EQUIP. 65 78 83 57 53

500(g)(1) FALL PROTECTION FOR LOWPITCHED ROOFS66 76 85 78 79

50(c) CERTIFIED FIRST-AID

PERSONNEL

67 80 84 73 93

500(b)(8) GUARDING FLOOR HOLES 68 79 73 60 58

451(a)(14) EXTENSION OF PLANKING –

SCAFFOLD

69 67 93 69 94

405(g)(2)(iii) ELECTRICAL CORDS LESS

THAN NO.12

70 81 78 70 67

556(b)(2)(v) BELT/LANYARD – AERIAL

LIFTS

71 73 80 74 77

150(a)(1) FIRE PROTECTION PROGRAMS 72 87 69 46 32

451(e)(8) PLUMB/SOUND BASE FOR

MOBILE SCAFFOLDS

73 68 79 72 68

50(d)(1) ACCESSIBLE FIRST-AID

SUPPLIES

74 66 52 36 30

59(e)(1)(ii) NON-ROUTINE INFORM. –

WRITING HAZ. COMM.

75 *(1) * ** **

403(b)(1) ELECT. EQUIP. FREE OF

HAZARDS

76 85 * * *

500(d)(2) GUARDING RUNWAY 77 84 72 64 *

451(e)(5) LADDER/STAIRWAY FOR

ACCESS/EGRESS

78 *(3) 99 96 99

602(a)(9)(ii) BACKUP ALARM PROVIDED 79 74 82 56 46

150(c)(1)(i) FIRE EXTINGUISHER EVER 300

FT.2 OR 100 FT. TRAVEL

80 49 44 39 38

405(a)(2)(ii)(b) BRANCH CIRCUIT

SPECIFICATIONS

81 92 94 76 75

450(a)(9) TIMPER MEMBER OF

SCAFFOLD FRAMING

82 24 23 18 18

59(f)(5) LABELING HAZ.

CHEMICALS

83 56 70 **(1) **

59(h)(1) EMPLOYEE INFORMATION 84 88 71 **(1) **

404(b)(1)(iii) ASSURED EQUIP. GROUNDING

CONDUCTOR PROGRAM

85 *(5) *(5) 81 83

500(e)(1)(iv) RAILING ON STAIRWAY 86(6) 29 28 21 22

1052(b)(1) STAIRWAY TRAVEL WITH

EMPTY PANS

87 * * * *

450(a)(10) SECURING PORTABLE

LADDERS

88(6) 20 21 14 15

10
RELATIVE RANKING TO 1991

YEARS

STANDARDS

[1926 UNLESS

NOTED]

DESCRIPTION

1991 1990 1989 1988 1987

300(b)(1) POWER OPERATED TOOL

GUARDS 89 91 81 67 65

350(a)(1) VALVE PROTECTION CAPS 90 75 68 61 66

405(a)(2)(iii) GUARDING PROTECTING

TEMP. WIRING OVER 600

VOLTS

91 *(5) *(5) *(5) *(5)

405(a)(2)ii)(f) TEMP. LIGHTS FROM ELECT.

CORDS

92 97 * 98 72

451(a)(3) SUPERVISION DURING

ERECTION,ETC.

93 *(5) *(5) *(5) *(5)

602(a)(2)(i) SEAT BELTS FOR

EARTHMOVING EQUIP.

94 *(5) *(5) 95 91

1052(c)(12) GUARDING FOR STAIRWAY

EDGES

95 *(5) *(5) *(5) *(5)

1053(b)(8) SECURING LADDERS 96 *(3) ***

59(e)(2) MULTI-EMPLOYER(S)

WORKPLACES – WRITTEN

HAZ. COMM. PROVISION

97 83 *(1) ** **

451(d)(4) FOUNDATION SPEC. FOR

TUBULAR WELDED

SCAFFOLD LEGS

98 98 95 *(5) *(5)

451(a)(10) SCAFFOLD GRADE PLANKING 99 95 *(5) *(5) *(5)

550(a)(6) ANNUAL INSPECTION OF

CRANES

100 93 88 79 76

(1) Full enforcement of Hazard Communication Standard began in March, 1989.

(2) Trenching/Excavation Standard became effective on March 5, 1990.

(3) Ladder/Stairway Standard became effective January, 1991.

(4) Standard first included in Concrete/Masonry Standard- effective August 15, 1988.

(5) Particular standard was not one of the 100 most frequently cited in the reference year.

(6) Standard was part of old Ladder & Stairway Standards and was effectively discontinued January 1991.

11
TABLE 2-2

THE MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS IN

1991 BY PERCENTAGE OF TOTAL VIOLATIONS

RANK(1) STANDARD

[1926 UNLESS

NOTED]

[PERCENT OF TOTAL] NUMBER OF

SPECIFIC STANDARD VIOLATIONS ÷ TOTAL

NUMBER CONSTRUCTION

VIOLATIONS(91,191)

CUMULATIVE

PERCENT

[%]

1 59(e)(1) 8.9 8.9

2 59(h) 6.2 15.1

3 59(g)(1) 3.7 18.8

4 1903.2(a)(1) 2.7 21.5

5 59(g)(8) 2.6 24.1

6 21(b)(2) 2.1 26.2

7 500(d)(1) 1.9 28.1

8 100(a) 1.9 30.0

9 404(b)(1)(i) 1.8 31.8

10 404(f)(6) 1.8 33.6

11 20(b)(1) 1.7 35.3

12 652(a)(1) 1.7 37.0

13 451(d)(10) 1.4 38.4

14 1904.2(a) 1.3 39.7

15 28(a) 1.2 40.9

16 1052(c)(1) 1.1 42.0

17 152(a)(1) 1.1 43.1

18 25(a) 1.1 44.2

19 20(b)(2) 1.0 45.0

20 651(k)(1) 1.0 46.0

21 451(a)(13) 0.8 46.8

22 404(b)(1)(ii) 0.8 47.6

23 701(b) 0.8 48.4

24 59(e)(I)(i) 0.7 49.1

25 451(a)(4) 0.7 49.8

26 651(j)(2) 0.7 50.5

27 350(j) 0.6 51.1

28 350(a)(9) 0.6 51.7

29 1910.20(g)(2) 0.6 52.3

12
RANK(1)

STANDARD

[1926 UNLESS

NOTED]

[PERCENT OF TOTAL] NUMBER OF

SPECIFIC STANDARD VIOLATIONS ÷ TOTAL

NUMBER CONSTRUCTION

VIOLATIONS(91,191)

CUMULATIVE

PERCENT

[%]

30 102(a)(1) 0.6 52.9

31 1910.20(g)(1)(i) 0.6 53.5

32 1053(b)(1) 0.6 54.1

33 500(b)(1) 0.6 54.7

34 651(c)(2) 0.5 55.2

35 1910.20(g)(1)(iii) 0.5 55.7

36 403(b)(2) 0.5 56.2

37 405(a)(2)(ii)(j) 0.5 56.7

38 1910.20(g)(1)(ii) 0.5 57.2

39 405(g)(2)(iv) 0.5 57.7

40 59(f)(5)(i) 0.5 58.1

41 304(f) 0.4 58.5

42 105(a) 0.4 58.9

43 300(b)(2) 0.4 59.3

44 59(f)(5)(ii) 0.4 59.7

45 405(a)(2)(ii)(e) 0.4 60.1

46 500(c)(1) 0.4 60.5

47 403(i)(2)(i) 0.3 60.9

48 451(e)(10) 0.3 61.2

49 451(d)(3) 0.3 61.5

50 5(a)(1) 0.3 61.8

51 404(f)(7)(iv)(c) 0.3 62.1

52 59(e)(4) 0.3 62.4

53 50(f) 0.3 62.7

54 1051(a) 0.3 63.0

55 405(b)(2) 0.3 63.3

56 416(e)(1) 0.3 63.6

57 451(a)(2) 0.3 63.9

58 405(b)(1) 0.3 64.2

59 550(b)(2) 0.3 64.5

60 451(e)(4) 0.3 64.8

TOTAL 64.8

(1) Includes only those standards ≥ 0.3% of the total construction violations in 1991.

13
14
15

3.0 100 MOST CITED PHYSICAL LIST

The next section presents the 100 Most Cited Physical List. A physical hazard can be the actual

cause(s) of an accident. A physical hazard as defined by his report is: 1) one that can be abated

(eliminated, controlled and/or mitigated) by using some type of hardware i.e., guard rails to prevent

falls; or 2) following a specific inspection protocol designed to identify defects that can lead to

accidents such as the monthly inspections of critical items of crawler, locomotive and truck cranes

which are prescribed by 1926.550(b)(2).

The 100 Most Cited Physical List presented in Table 3-1 (see page 18) ranks the most frequently

cited physical standard from #1 to #100, describes the major activity related to the standard, profiles

the standard and gives the standard number.

Other lists help identify which of the 100 standards are related to major subjects and subdivisions

of each i.e., major subject - ELECTRICAL; subdivisions - GROUND FAULT PROTECTION,

CORD SPECIFICATIONS., etc., see Table 3-2 (page 22) & Table 3-3 (page 23).

17
TABLE 3-1

LIST OF THE 100 MOST FREQUENTLY CITED OSHA CONSTRUCTION STANDARDS

RELATED TO PHYSICAL HAZARDS IN 1991

RANK DESCRIPTION OF STANDARD STANDARD

(1926.____)

1 Fall Protection Guarding open sided floors/platforms 500(d)(1)

2 PPE Head protection from impact, falling or flying objects 100(a)

3 Electrical Ground fault protection 404(b)(1)(i)

4 Electrical Path to ground missing or discontinuous 404(f)(6)

5 Trench/Excavation Protective Systems for trenching/excavation 652(a)(1)

6 Scaffolding Guardrail specifications for tubular welded frame scaffolds 451(d)(10)

7 PPE Appropriate PPE used for specific operation 28(a)

8 Ladders/Stairways Stair rails required @ 30” change of elevation or 4 risers 1052(c)(1)

9 Fire Protection Approved containers or tanks for storing or handling

flammable or combustable liquids.

152(a)(1)

10 General Provisions General Housekeeping 25(a)

11 Trenching/Excavation Daily inspection of physical components of trench and

protection systems

651(k)(1)

12 Scaffolds Safe access for all types of scaffolds 451(a)(13)

13 Electrical Ground fault circuit interrupters (GFCI’s) 404(b)(1)(ii)

14 Concrete/Masonry Guarding protruding steel rebars 701(b)

15 Scaffolds General requirements for guarding 451(a)(4)

16 Trench/Excavation Spoil pile protection 651(j)(2)

17 Welding/Cutting Securing compressed gas cylinders 350(a)(9)

18 Welding/Cutting Additional rules for welding as per ANSI Z49.1-1967 350(j)

19 PPE Eye/Face Protection for operations which create exposure 102(a)(1)

20 Fall Protection Guarding floor openings 500(b)(1)

21 Ladder/stairway Ladder extended 3’ above landings 1053(b)(1)

22 Trench/excavation Access/Egress from trench/excavation 651(c)(2)

23 Electrical Listed, labeled or certified equipment used in manner

prescribed

403(b)(2)

24 Electrical Flexible cords designed for hard or extra hard usage 405(a)(2)(ii)(j)

25 Electrical Strain relief for cords 405(g)(2)(iv)

26 Woodworking Tools Additional rules for woodworking tools as per ANSI

01.1-1967

304(f)

18
 RANK DESCRIPTION OF STANDARD STANDARD

(1926.____)

27 Fall Protection Safety nets above 25’ when no other means of fall

protection is practical

105(a)

28 Tools Guarding moving parts of machinery 300(b)(2)

29 Electrical Protection and grounding for temporary lamps 405(a)(2)(ii)(e)

30 Electrical Controlled access to installations operating at over 600 volts 403(i)(2)(i)

31 Fall Protection Guarding wall openings 500(c)(1)

32 Scaffolding Guarding specifications for mobile scaffolds 451(e)(10)

33 Scaffolding Bracing tubular welded frame scaffolds 451(d)(3)

34 General Duty Serious hazard not covered by specific standard 5(a)(1)

35 Electrical Specific types of equipment or operations where grounding is

required

404(f)(7)(iv)(c)

36 Health Emergency phone numbers posted 50(f)

37 Ladder/Stairway Access by means of ladder/stairway when no other means

provided and change in elevation > 19”

1051(a)

38 Electrical Covering provided for pull boxes, junction boxes, outlets, etc. 405(b)(2)

39 Electrical Worn or frayed electrical cords 416(e)(1)

40 Scaffolding Sound, rigid, and load capable footings or anchorages for

all types of scaffolds

451(a)(2)

41 Electrical Unused opening in boxes must be closed and conductors

entering boxes must be protected from abrasion.

405(b)(1)

42 Cranes/Derricks All crawler, truck, or locomotive cranes meet ANSI

B30.5-1968

550(b)(2)

43 Scaffolding Tightly planked mobile scaffolds 451(e)(4)

44 Electrical Reverse polarity of conductors 404(a)(2)

45 Ladders/Stairways Defective portable ladders tagged and taken out-of-service 1053(b)(16)

46 Electrical Protecting flexible cords and cables from damage 405(a)(2)(ii)(i)

47 Matl. Handling Equip. Horns provided on bi-directional equipment 602(a)(9)(i)

48 Health Certified first-aid trained personnel when treatment is not

readily available

50(c)

49 Fall Protection Components of a fall protection system for low-pitched

roof work

500(g)(1)

50 Fall Protection Guarding floor holes 500(b)(8)

51 Scaffolding Specifications for extension of planking beyond supports 451(a)(14)

52 Fire Provide for firefighting equipment and a fire protection

program.

150(a)(1)

53 Electrical Splicing and tapping electrical cords less than No. 12 405(g)(2)(iii)

19
 RANK DESCRIPTION OF STANDARD STANDARD

(1926.____)

54 Fall Protection Body belt and lanyard while working from aerial lift 556(b)(2)(v)

55 Scaffolding Plumb and sound base for mobile scaffold – casters locked 451(e)(8)

56 Health Accessible first-aid supplies approved by consulting physician 50(d)(1)

57 Electrical Electrical equipment is free of hazards as determined by

specifications.

403(b)(1)

58 Fall Protection Guarding runways 500(d)(2)

59 Scaffolding Ladder/stairway affixed or built-in to mobile scaffold for

access/egress

451(e)(5)

60 Matl. Handling Equip. Backup alarm or signalman provided when operating in

reverse

602(a)(9)(ii)

61 Fire Fire extinguisher for every 3000 sq. ft. of protected building

area and 1000 feet of travel

150(c)(1)(i)

62 Electrical Branch circuit specifications 405(a)(2)(ii)(b)

63 Ladders/Stairways Ladders extended 3’ above landing 450(a)(9)

64 Electrical Assured equipment grounding conductor program 404(b)(1)(iii)

65 Ladders/Stairways Stair rail and handrail specifications 500(e)(1)(iv)

66 Ladders/Stairways No travel on stairways with empty pans 1052(b)(1)

67 Ladders/Stairways Securing portable ladders 450(a)(10) 

68 Tools Power operated tool guards 300(b)(1)

69 Welding/Cutting Valve protection caps in-place and secure 350(a)(1)

70 Electrical Guarding provided for temporary wiring operating over 600

volts

405(a)(2)(iii)

71 Scaffolding Competent person supervision during erection, dismantling,

etc.

451(a)(3)

72 Electrical Temporary lights suspended from electrical conductor cords 405(a)(2)(ii)(f)

73 Matl. Handling Equip. Seat belts for all earth moving equipment 602(a)(2)(i)

74 Ladders/Stairways Guarding stairway edges and landings 1052(c)(12)

75 Ladders/Stairways Siting and securing ladders 1053(b)(8)

76 Scaffolding Scaffold grade planking or equivalent 451(a)(10)

77 Scaffolding Foundation specifications for tubular welded frame scaffold

Legs

451(d)(4)

78 Cranes/Derricks Annual inspection of cranes/derricks 550(a)(6)

79 Cranes/Derricks Barricading the swing radius of cranes/derricks 550(a)(9)

80 Fire Specifications for fire extinguisher on each floor of multi-story

Structure

150(c)(1)(iv)

20
 RANK DESCRIPTION OF STANDARD STANDARD

(1926.____)

81 Ladders/Stairways Stairrail specifications 500(e)(1)(iii)

82 Scaffolding Tie specifications for tubular welded frame scaffolds 451(d)(7)

83 Fire Inspection of fire extinguisher in accordance with NFPA

10A-1970

150(c)(1)(viii)

84 Electrical Deenergizing or guarding electrical circuits which are in

proximity of employees

416(a)(1)

85 Scaffolding Immediate replacement or repair of any damaged or defective

components of scaffolding systems

451(a)(8)

86 Trenching/Excavating High-visibility garments when exposed to vehicular traffic 651(d)

87 Health Common drinking cup 51(a)(4)

88 Fire “NO SMOKING” signs posted in service and refueling areas 152(g)(9)

89 Fire Fire extinguisher for cranes/derricks 550(a)(14)(i)

90 Ladders/Stairways Swing radius specifications for doors/gates which open on

to a stairway or landing

1052(a)(4)

91 Scaffolding Lifeline support on suspension scaffolds 451(i)(8)

92 Scaffolding Specifications for catch platform for “steep-slope” roofs 451(u)(3)

93 Matl. Handling Equip. Industrial trucks (fork lifts) meet ANSI B56.1-1969 602(c)(1)(vi)

94 Motor Vehicles Specifications for using vehicles with obstructed views to rear 601(b)(4)

95 Fire Fire extinguisher specifications for locations near

flammable/combustible materials

150(c)(1)(vi)

96 Welding/Cutting Regulators/gauges kept in proper working order 350(h)

97 Cranes/Derricks Competent person to inspect crane to identify defects

prior to use

550(a)(5)

98 Fire Periodic inspection of firefighting equipment 150(a)(4)

99 Fire Storing liquefied petroleum gases in buildings 153(j)

100 Scaffolding Locking or pinning legs to prevent uplift 451(d)(6)

21
TABLE 3-2

GROUPING BY SUBJECT OF 100 MOST CITED PHYSICAL STANDARDS

SUBJECT RELATED RANK NUMBERS FROM TABLE 3-1(1)[PERCENT(2)]

ELECTRICAL 3,4,13,23,24,25,29,30,35,38,39,41,44,46,53,57,62,64,70,72,84 [21%]

SCAFFOLDINGG 6,12,15,32,33,40,43,51,55,59,71,76,77,82,83,91,92,100 [18%]

LADDER/STAIRWAY 8,21,37,45,63,65,66,67,74,75,81,90 [12%]

FIRE 9,52,61,80,83,88,89,95,98,99, [10%]

PPE 2,7,19 [3%]

TRENCH/EXCAVATION 5,11,16,22,86 [5%]

FALL PROTECTION 1,20,27,31,49,50,54,58 [8%]

CRANES/DERRICKS 42,78,79,97 [4%]

WELDING/CUTTING 17,18,69,96 [4%]

MATERIAL HANDLING

EQUIPMENT

47,60,73,93 [4%]

HEALTH 36,48,56,87 [4%]

MISCELLANEOUS 10,14,26,28,34,68,94 [7%]

(1) Refer to the ranking of individual standards listed in TABLE 3-1, i.e. “Electrical - #13, GFCI requirement”.

(2) PERCENT – Sum of individual standards per subject divided by 100

22
TABLE 3-3

COMBINED STANDARDS BY SUBJECT MATTER FROM THE LIST 100 PHYSICAL

STANDARDS IN 1991

MAJOR SUBJECT

COMBINED STANDARD TITLE

#(1) DESCRIPTION OF EACH STANDARD FOR

COMPARISON

ELECTRICAL

GROUND FAULT PROTECTION 3

13

64

Ground fault protection

Ground fault circuit interrupters (GFCI’s)

Assured equipment grounding conductor program

CORD SPECIFICATIONS 25

24

46

Strain relief for cords

Flexible cords designed for hard or extra hard usage

Flexible cords and cables made suitable for specific

conditions

SPECIFICATIONS FOR TEMPORARY

LIGHTING

29

72

Protection and grounding for temporary lamps.

Temporary lights suspended from electrical

conductor cords

COVERED FOR BOXES, UNUSED

OPENING, ETC

38

41

Covering provided for pull boxes, junction boxes,

outlets, etc.

Unused opening in boxes must be closed and

conductors entering boxes must be protected from

abrasion.

CONTROLLED ACCESS AND

GUARDING OF EQUIPMENT

OPERATING >600 VOLTS

30

70

Controlled access to installations operating at over

600 volts.

Guarding provided for temporary wiring operating

over 600 volts.

STAND ALONE STANDARDS

4,23,35,39,44,53,57,62,84

23
MAJOR SUBJECT

COMBINED STANDARD TITLE

#(1)

DESCRIPTION OF EACH STANDARD FOR

COMPARISON

SCAFFOLDING

GUARDING SPECIFICATIONS 6

15

32

Guardrail specifications for tubular welded frame scaffolds

General requirements for guarding

Guarding specifications for mobile scaffolds

ACCESS 12

59

Safe access for all types of scaffolds

Ladder/stairway affixed or built-in to mobile scaffold for

access/egress

FOUNDATION SPECIFICATIONS 40

55

Sound, rigid, and load capable footings or anchorages for

all types of scaffolds

Plumb and sound base for mobile scaffold – casters locked

77

100

Foundation specifications for tubular welded frame scaffold

legs

Locking or pinning legs to prevent uplift

STAND ALONE STANDARDS

32,43,51,71,76,82,85,91,92

LADDER/STAIRWAY

STAIR RAIL REQUIREMENTS

DEFECTIVE LADDERS

LADDER ERECTION

8

74

45

75

21

Stair rails required @ 30” change of elevation or 4 risers

Guarding or stairway edges and landings

Defective portable ladders tagged and taken out-of-service

Siting and securing ladders

Ladders extended 3’ above landings

STAND ALONE STANDARDS

37,63,65,66,67,81,90

24
MAJOR SUBJECT

COMBINED STANDARD TITLE

#(1)

DESCRIPTION OF EACH STANDARD FOR

COMPARISON

FIRE PROTECTION

FIRE EXTINGUISHER 61

80

83

89

95

Fire extinguisher for every 3000 sq. ft. of protected building

area and 100 ft. of travel

Specifications for fire extinguisher on each floor of multistory structure

Inspection of fire extinguisher in accordance with NFPA

10A-1970

Fire extinguisher for cranes/derricks

Fire extinguisher specifications for locations near

flammable/combustible materials

STAND ALONE STANDARDS

9,52,88,98,99

PPE

SPECIFIC WEAR 2

7

19

Head protection from impact, falling or flying objects

Appropriate PPE used for specific operation

Eye/face protection for operations which create

exposure

STAND ALONE STANDARDS

NONE

TRENCHING/EXCAVATION STAND ALONE STANDARDS

5,11,16,22,86

FALL PROTECTION

SPECIFICATIONS FOR VARIOUS

WORK SURFACES

1

20

31

50

58

Guards for open sided floors/platforms

Guarding floor openings

Guarding wall openings

Guarding floor holes

Guarding runways

STAND ALONE STANDARDS

27,49,54

CRANES/DERRICKS

INSPECTION REQUIREMENTS 42

78

97

REF. ONLY – All crawler, truck, or locomotive cranes

meet ANSI B30.5-1968

Annual inspection of cranes/derricks

Competent person to inspect crane to identify defects prior

to use

STAND ALONE STANDARDS

42,79

25
MAJOR SUBJECT

COMBINED STANDARD TITLE

#(1)

DESCRIPTION OF EACH STANDARD FOR

COMPARISON

WELDING/CUTTING

CYLINDERS 17

69

Securing compressed gas cylinders

Valve protection caps in-place and secure

STAND ALONE STANDARDS

18,96

MATERIAL HANDLING EQUIPMENT

SAFE MOVEMENT 47

60

Horns provided on bidirectional equipment

Backup alarm or signalman provided when operating in

reverse

STAND ALONE STANDARDS

73,93

HEALTH

EMERGENCY RELATED 48

56

36

Certified first-aid trained personnel when treatment is not

readily available

Accessible first-aid supplies approved by consulting

physician

Emergency phone numbers posted

STAND ALONE STANDARDS

87

MISCELLANEOUS

STAND ALONE STANDARDS 10

14

26

28

34

68

94

General Housekeeping

Guarding protruding steel rebars

Additional rules for woodworking tools as per ANSI 01.1-

1967.

Guarding moving parts of machinary

General Duty

Power operated tool guards

Specifications for using vehicles with obstructed views to

rear

(1) Refers to the ranking number of individual standards listed in TABLE 3-1, i.e. “Electrical - #13

Ground Fault Circuit Interrupters”.

26
4.0 FORMAT AND USE OF GUIDE

The following chapter describes the GUIDE. The format discusses the headings for each particular

GUIDE Sheet.

4.1 USE OF GUIDE

The GUIDE consist of 25 user-friendly data sheets covering the first 25 standards from the 100

Most Cited Physical List. Each two page GUIDE is accompanied by photographs or illustrations

depicting acceptable and unacceptable conditions related to the standard. Captions describe the

photograph or illustration and identify an acceptable or unacceptable condition. The following key

specifies an acceptable or unacceptable condition:

Note: The photographs and illustrations may identify other conditions than those addressed by the

particular GUIDE.. The caption, however, only mentions the situation germane to that GUIDE.

These GUIDE are intended to be usable information or a training source for safety talks, tool box

meetings, etc.

Much of the information contained in the GUIDE SHEETS is taken from OSHA field personnel

with many years of field experience. The GUIDE, therefore, gives the contractor some insight into

the types of conditions the OSHA CSHO observes on the Job-site,

Statistical dales presented in the individual GUIDE related to fatalities were taken from an OSHA

report (see Section 5.3 REFERENCES - [10]) developed from OSHA accident investigation data.

Data presented related to injuries came from an OSHA report (see Section 5.3 REFERENCES -

[6]) which was based on the Bureau of Labor Statistics - Supplementary Data System (SDS).

27
4.2 FORMAT

This section identifies information and sources, where applicable, that are found in each the

sub-headings in the individual GUIDE in Chapter 5.

Heading

Gives the ranking of the particular standard or GUIDE on the 100 Most Cited Physical List. the standard number and a brief

key word description of the standard.

Rule

Quotes the standard.

Intent

States the intent and/or the purpose of the standard. For example. a fall prevention system may be required on a scaffold to

prevent falls from elevations. The intent of a corresponding standard might be to specify the construction of a guard rah

system. While this sub-heading specifies the requirements of the standard, it might also include information on: 1) the history

of a particular hazard related to the standard, i.e., a certain number of fatal/lost-time falls from scaffolds over a given period

of time; and 2) the theory or operation or equipment, loss prevention technique, etc. which might be associated with the

standard.

Hazards

Lists the most commonplace hazards associated with the standard. Additionally, lists common probable injuries identified

with the listed hazard. NOTE: No attempt is made to list all hazards associated with the specific standard because of the

numerous hazardous conditions and situations that each standard may cover. The employer must fist evaluate the

situation/condition and identify all the hazards. Secondly, the employer must decide which standards apply and then take the

appropriate actions required by the standard to abate the hazards.

(Among Other) Suggested Abatements

Lists at least one common and sometimes obvious abatement method to correct the hazards) associated with the particular

standard. NOTE: As above, there may be many acceptable means of abatement for hazards) related to the standard. Also, the

abatement methods listed MAY NOT cover the situation/condition at any given jobsite. Therefore, it is incumbent upon the

employer to evaluate the operation to insure the abatement is adequate to control or eliminate the hazard.

The employer must identify, control or eliminate all hazards (29 CFR 1926.20 & .21) on the jobsite through an effective and

implemented safety program. The elements of a thorough jobsite safety program are listed in FIGURE 1-1 - EMPLOYER'S

SAFETY AND HEALTH PROGRAM[29] (see page 4). The elements listed in FIGURE 1-1 apply to controlling any hazard

on any jobsite including those listed in this report. Therefore, these common abatement methods are not listed on each

GUIDE, but must be followed to achieve a safe and healthful work place.

Selected Case Histories

Lists at least one fatal/catastrophic accident where the particular standard was cited and was directly related to the causes) of

the accident. The accident cases were extracted from the OSHA IMIS System which contains accident information in an

abstract format from the OSHA-1 70 Form (codified form used by OSHA CSHO's when investigating fatal or catastrophic

accident) and from various OSHA Fatal Facts Accident Reports. This section offers a reader or employee(s) at safety

meetings/tool box talks an idea of possible consequences if the requirements of the standard are not followed.

28 
Comments

Lists at least one comment related to the standard, giving information such as the number of times the standard was cited

during OSHA accident/catastrophe investigations, common observations from OSHA field personnel related to the standard,

common conditions found in the field that do not meet the requirements of the standard, etc.

Additional Documents to Aid in Compliance

Lists other documents that are directly related to the particular standard and provides supplement information to the

employer, employee or CSHO. However, it is important to understand that other industry/operational documents may be used

to support OSHA violations. The other listed non-OSHA documents carry the same legal impact if they are incorporated by

reference fisted in the OSHA standards with a specific standard number such as ANSI 249.1 - 1967 Safety in Welding and

Cutting , which is listed as OSHA standard 1926.3500)).Other documents may be used as criterion documents to illustrate

industry practice to support a "General Duty Clause 5(a)(1)" violation.

Additionally all pertinent current and historic OSHA documents listed in the OSHA Computer Information System (OCIS)

including directives, compliance letters, individual letters of interpretation, etc. have been listed by date with a synopsis of the

associated information to help interested parties research the standard.

Bracketed numbers, i.e. [29], refer to corresponding documents listed in APPENDIX B-REFERENCES.

Photographs, Illustrations and Other Documents

This section uses photographs and/or illustrations to show some common acceptable and unacceptable situations/conditions

found at construction sites related to the standard. Additionally, some of the GUIDE Sheets include items such as checklists

and other Agency documents.

29 

5.0 GUIDE FOR THE ABATEMENT CF THE TOP 25 MOST CITED PHYSICAL 

HAZARDS 

The GUIDE consists of the following: 1) Section 5.1 contains the top 25 most frequently cited

physical standards or hazards from the 100 Physical List presented in TABLE 3-1 (see page 18),

each GUIDE is presented as an individual information/data source for each standard; 2) Section 5.2

consists of two tables related to construction specifications for guardrails and toeboards that are

common for eve of the individual GUIDE Sheets; and 3) Section 5.8 contains a list of additional

sources of further OSHA and industry information.

5.1 THE TOP 25 GUIDE SHEETS 

The following section presents individual GUIDE Sheets to help employers, employees and OSHA

personnel identify and abate the 25 most frequently cited physical hazards on construction sites.

31
RANK IN FREQUENCY CITED

#1

1926.

500(d)(1) GUARGDRAILS NOT PROVIDED

FOR OPEN-SIDED FLOORS

OR PLATFORMS

RULE: Every open-sided floor or platform 6 feet or more above adjacent floor or ground level shall be guarded

by a standard ramp, or the equivalent , as specified in paragraph (f)(1) of this section, on all open sides, except

where there Is an entrance to a ramp, stairway, or fix ladder. The railing shall be provided with a standard toeboard

wherever, beneath the open sides, persons can pass, or there is moving machinery, or there Is equipment with

which falling materials could create a hazard.

INTENT:

Falls from elevations are the leading cause of fatalities in the construction industry. From 1985-1989, 33% of all construction

fatalities [10] resulted from a fall from an elevation. One hundred-seventeen fatalities occurred when employees fell from open

sided doors and through floor openings. This standard specifies that guarding must be provided for all open-sided floors and

platforms 6 feet or more in height. It also specifies minimum requirement for the type of guarding. Paragraph (f) of the same

section species the requirement of a standard guardrail system. TABLE 5.2-1 lists guardrail specifications for various materials.

Where there is an open-sided floor/platform and there is a potential for a person to pass or a hazard is presented by machinery,

toeboards are required. The intent is to contain any materials near the edge from inadvertently getting pushed over the edge where

they may strike persons or machinery below. TABLE 5.2-2 lists specifications for toeboards.

HAZARDS:

• Falls from elevations: probable injuries range from death to fractures; Fall from lower elevations such as 4-6 feet have caused serious

lost-time accidence and occasionally have been the cause of fatalities.

• Struck by: the lack of material containment (toeboards) has caused both fatalities and lost-time accidents when falling materials have

struck employees below.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Whenever an employee must work at any elevated location, ask the questions: 1) Are they protected from a fall? and 2) What

measures must be taken to protect the employee at the elevated work location?

• Fall prevention systems such as standard guardrail systems provide more positive means of protection than fall protection systems

such a bodybelt/harness-lanyard-lifeline combination, except when workers are suspended, i.e. working on suspended scaffolds, work

platforms, etc.

• Construct/maintain all guardrail systems according to OSHA requirements.

• An acceptable method to preclude the use of toeboards, would be to determine the fall radius of materials on an open-sided

door/platform. Place positive physical barrier outside the potential fall radius to keep workers and machines outside the danger zone.

SELECTED CASE HISTORIES:

An employee taking measurements was killed when he fell backwards from an unguarded balcony to the concrete 9'6" below.

COMMENTS:

• Falls from elevations accounted for 14% of all lost-time accidents[6].

• This standard was cited in 103 fatality/catastrophe inspections conducted by OSHA over a 4 year period.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 500 & Steel Erection - 750 & 752(k); [11]; [12]; [13]; [26] Part - 701(f)(2) - Concrete and Masonry Const.

OSHA COMPLIANCE LETTER

Date 5/22/84; From-Directorate of Field Operations to Regional Administrators; Synopsis - Clarification of 1926.750(b)(1)(iii) stating

that 1⁄2 " wire rope or equivalent safety railing must be used around temporary planked or temporary metal-decked doom during steel

erection operation. Raging also must be provided at leading edge if spreading stops for any significant time period. 1⁄2 " synthetic or fiber

rope would not be acceptable as a required safety railing for steel erection operations.

OSHA COMPLIANCE LETTER

Date 1/13/81; From-Assistant Secretary to Int. Union of Bricklayers & Allied Craftsmen; Synopses - Standards 1926.28, 1926.104,

1926.105 & 1926.500(d)(1) do not apply to overhand bricklaying operations.

OSHA COMPLIANCE LETTER

Date 2/13/86; From-Directorate of Field Operations to Individual Company; Synopses - When structural steel assembly including

decking has been completed and other trades are working on the deck while concrete is being poured on the deck, the door must be

guarded in accordance with 1926.500(d)(1).

32
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

" Properly erected wire rope perimeter guardrail system. VIOLATION ! IN-COMPLIANCE

Exposure to open-sided floor

NOTE: The high visibility tape on wire rope (arrow) on

top floor makes the guardrail easier for the

employees to see.

" VIOLATION ! IN-COMPLIANCE

Too much sag in the wire

rope (arrows) guard rails

! VIOLATION " IN-COMPLIANCE

Properly erected wooden guardrail

system for platform.

NOTE: The top erection floor has a properly

erected wire rope guardrail system.

33
RANK IN FREQUENCY CITED

#2

1926.

100(a)

HEAD PROTECTION FROM

IMPACT, FALLING OR

FLYING OBJECTS AND

ELECTRICAL BURNS

RULE: Employees working in areas were there is a possible danger of head injury from impact, or from failing

or flying objects, or from electrical shock and burns shall be protected by protective helmets.

INTENT

Thousands of head injuries each year occur in the construction industry. This standard requires employees to wear "hard hats" to mitigate

or lessen the effects of being struck by an object, accidentally striking their head against an objects or making contact with an energized

electrical line. It needs to be emphasized that the standard is not just for employees that work at sites where there is a possibility of

falling objects striking them in the bead, in workers on lower levels of a mufti-story budding project which are exposed to falling

materials such as hand tool, bolts, nuts, etc. But it is also intended for employees who work in the vicinity of an operation that is found

on a construction site. These type of energy releases are common to almost all construction operation and are not predictable. Almost

all construction operations involve the potential of falling and flying objects, and, therefore, employees must wear head protection.

Additionally many impact hazards exist. For instance, iron workers are constantly exposed to striking their heads on structural steel

during erection, carpenters strike their heads on temporary framing lumber as they move through a building, etc. Employees that work in

the vicinity of electrical conductors are exposed to potential shocks and burns to the head should they contact an uninsulated conductor.

HARZARDS

Struck by: injuries ranging from death to major concussion or trauma to minor abrasions; electrocution.

(AMONG OTHER) SUGGESTED ABATEMENT(S):

• Emphasize that the wearing of hard hats is not only for those employees that are exposed to falling objects, but it is also for

employees exposed to the other types or hazards.

• Focus on the wearing of hard hats during site inspections. Check hard hats to insure their integrity is not compromised. Metal hard

hats are electrical conductors and do not meet the requirement of OSHA and ANSI.

• A formal management discipline program may need to be utilized for those employees who after repeated warnings either refuse

or "forget” to wear their hard hats where required.

SELECTED CASE HISTORIES

• An employee was standing under a suspended scaffold that was hosting a workman and 3 sections of ladder. Sections of the ladder

became unlashed and fell ≈ 5O feet striking the employee in the skull. The employee, who was not wearing any head protection died

from injuries received.

• Two employees were using a wire rope to winch a wooden tool shed onto a flat bed trailer. The wire rope broke, snapped back struck

one of the employees in the top of the head, killing him. The employee was not wearing a hard hat.

• Employees were using a 5-ton winch to pull a 10-foot section of a 600 lb. grain spout through a vent hole when the spout became

wedged. Employees were attempting to use pry bars to free the spout that was still under tension from the winch when the spout popped

free, striking an employee in the head. No head protection was provided.

COMMENTS

1. OSHA [6] found that in a four year period from 1985 to 1988, 3.2% (11,685) of all construction lost time accidents in 10 states were

related to head injuries.

2. All lost-time accidents involving head injuries do not result from being struck by falling and flying objects. OSHA [6] found that

the head was the "Part of Body" injured in 9% (7125) of the "Struck By" (falling and flying object) type injuries. This compared

to 5% (1440) for "Struck Against", (impact) type injuries; in other words, impacts are the cause of about 17% of all lost time head

injuries.

3. This standard was cited in 142 fatality/catastrophe inspections by OSHA in a five year period.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE

[l] Section 100 (b)& (c); [7]*; [8]*; [9], [25].

*- Referenced in 29 CFR 1926- Construction Standards

OSHA CLARIFIICATION LETTER

Date 8/23/83 – Synopsis – The employer must determine which employees face possible head injuries and must wear appropriate head

protection. OSHA has no exhaustive guidelines for determining when head protection must be worn. A case-by-case analysis

must be performed by the employer.

34
OSHA CLARIFICATION LETTER

Date 7/22/92; From Directorate of Compliance to IBEW Business Manager – Synopsis – Wearing of hard hats with bill to

the rear would not meet 1926.100(a) & (b) unless manufacturer certifies that this practice meets ANSI Z89.1-1969. ANSI

test and certifies hard hats with bills facing forward.

PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

Hardhat meets OSHA and ANSI Z89.1-1969, Safety

Requirements for Industrial Head Protection

" VIOLATION ! IN-COMPLIANCE

Work is in progress on top of scaffold. The workers

drilling below scaffold are exposed to being struck

by falling materials. There is a need for head

protection which is not provided by the soft hats

shown

" VIOLATION ! IN-COMPLIANCE

The inspector on the ground (arrow) is exposed to

falling materials. Therefore, head protection is

required for him. The carpenters would most likely

not be exposed to falling materials in this situation.

However, a flying material hazard may exist and

the operation must be evaluated to determine if

head protection is required. NOTE: Fall hazards do

exist at the perimeter and at the floor openings.

Also, an improperly constructed ladder is being

used.

33
RANK IN FREQUENCY CITED

#3

1926.

404(b)(1)(i)

GROUND FAULT

PROTECTION NOT

PROVIDED

RULE: General. The employer shall use either ground faun circuit Interrupters as specified in paragraph

(b)(1)(III) of this section or an assured equipment grounding conductor program as specified in paragraph

(b)(1)(III) of this section to protect employees on construction sites. These requirements are in addition to any

other requirements for equipment grounding conductors.

INTENT:

Due to the dynamic, rugged nature of a typical construction site, electrical equipment, especially tools and extension cords are much

more susceptible to deterioration due to "normal" use and sometimes abuse. When the deterioration occurs, sometimes insulation

cracks or breaks exposing bare energized conductors, stress and strain may cause terminal screws to loosen resulting in one conductor

short-circuiting another, etc.. The result can be that fault current is generated which may be directed through an employee's body to

ground. Wet conditions often found at construction sites, greatly increase this hazard. This standard offers the employer two additional

methods beyond the required equipment grounding conductor, to reduce and/or eliminate fault current which might be generated in

any electrical system or tool during use. One means is to provide ground fault circuit interrupters (GFCI’s) in all temporary receptacle

outlets rated 120 volt single phase, 15&20 amps. This is essentially a hardware requirement. The GFCI continually monitors and

compares the amount of current going to an electrical tool or piece of equipment against the amount of current returning along the

"grounded neutral". If the differential in current (amount going to the tool vs. amount coming from tool) is more than 5 milliamps, the

GF C1 is designed to trip in about 1/40 of a second. The other option is to establish and fully implement an Assured Equipment

Grounding Conductor Program (AEGCP). This program relies on daily visual inspections and periodic (three months maximum for

temporary cords and cords exposed to damage, six months for fixed cords not exposed) test inspections. Additionally, the AEGCP

requires a written description, a competent person to implement the program and a record of the periodic tests.

HAZARDS:

Fatal electrocutions; Electrical burns ranging from critical to mirror; Fire; Explosion; Electric shock has been the initiator of other

type hazards, i.e. electrical shocks have been the initiating cause of employees falling from elevated work surfaces, electrical shocks

have caused employees to lose control of hand held equipment which in turn has struck and injured other employees in the immediate

work area, etc.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Instruct employees to visually inspect all electrical equipment p prior to u-se. Any defects such as frayed cords; missing ground

prongs, cracked tool casing, etc. should be corrected by taking the tool out-of-service. Apply a warning tag to the tool and do not

allow it to be used until the problem has been corrected.

• Frequently trip GFCI’s while test tool is operating to insure GFCI is operating correctly.

• Use double insulated tools. Double insulated too1s protect the user from fault currents which might energize the case of the tool

or equipment.

SELECTED CASE HISTORIES:

A journeyman HVAC worker was installing metal duct work using a double insulated drill connected to a drop light cord. Power

was supplied through two extension cords from a nearby residence. The individual's wet clothing/body contacted bare exposed

conductors on one of the cords causing an electrocution. No GFCI’s were used. Additionally, the ground prongs were missing from

the 2 cords.

COMMENTS:

1. Although it was suggested above to use double insulated tools, it does not relieve the employer from providing ground fault

protection. Extension cords in use between a fixed electrical system (permanent outlet) and a tool can become worn with exposed

energized conductors. Therefore, ground fault protection or an AEGCP would be required. See OSHA CLARIFICATION LETTER

below.

2. According to OSHA[10] there were 48 fatalities in the years 1985 to 1989 related to 120 volt electrical systems.

3. Employers have attempted to skirt the requirements of providing ground fault protection by using 30 amp breakers in their 120

volt, single phase systems. This not only defeats the intent of the ground fault provisions it also introduces another set of hazards

because the system is no longer rated fro the actual over current protection (30 amp breaker) that is in place.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 404(b); [3]; [4]; [5]

36

RANK IN FREQUENCY CITED

#4

1926.

404(f)(6)

ELECTRICAL PATH TO

GROUND MISSING OR

DISCONTINOUS

RULE: Grounding Path. The path to ground from circuits, equipment, and enclosures shall be permanent

and continuous

INTENT:

Many times on construction sites due to the frequency and severity of use, electrical equipment that is originally designed and

provided an electrical path to ground is not capable of physically transferring “fault” current to ground became he

positive physical path (a direct positive conn ection through the entire system usually terminating at a ground rod

or cold water pipe) to ground, sometimes known as the "ground wire" or "equipment ground" is proved to transfer

fault current to ground in the event that an exposed part of the piece of equipment were to be energized by the

"hot” conductor or wire in the system, i.e. the case of an electric drill might be energized by fault current if the

internal windings came in contact with the case or contact is made with an exposed conductor. The "equipment

ground” would, in the case of the drill, provide a favorable path of least resistance for the fault current to ground through

the conductor. If the “equipment ground" was not continuous the path of least resistance from the drill might be through a

persons body.

HAZARDS:

Electrical shock; Probable injuries range from death to minor burns; Fire; Explosion; Electric shock has been the initiator of

other Type hazards, i.e. electrical shocks have been the initiating cause of employees falling from elevated work surfaces,

WNW shocks have caused employees to lose control of hand held equipment which in turn has struck and injured other

employees in the immediate work area, etc.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Instruct employees to visually inspect all electrical equipment prior to use. Any defects such as frayed cords, missing ground

prongs, cracked tool casing, etc. should be corrected by taking the tool out-of-service. Apply a warning tag to the tool and do

not allow it to be used until the problem has been corrected.

• Frequently inspect electrical systems to insure the path to ground is continuous. A volt-ohm meter rated for the proper

capacity could be used to check for ground in an electrical circuit A receptacle circuit tester can be used to check the continuity

of the grounding conductor from a 120 volt receptacle back to ifs origin at the breaker box. This type tester depending on

manufacturer usually has the ability to check for wiring configurations including correct wiring, reversed polarity, open

neutral, open hot, etc. Additionally, it is relatively inexpensive- usually less than $20 dollars and can be easily carried in a

pants pocket. A pocket pen light continuity checker is an inexpensive piece of equipment that can be used to check the

"equipment bonding" conductor of cord and plug connected equipment, i.e. drills, saws, sanders, etc.

• Use double insulated tools. Double insulated tools protect the user from fault currents which might energize the case of the

tool or equipment. If electrical equipment is double insulated it must be distinctively marked.

SELECTED CASE HISTORIES

A fan connected to a 120-volt electrical system via an extension cord provided ventilation for an employee performing a

chipping operation from an aluminum. stepladder. The insulation on the extension cord was cut through and exposed bare

energized conductors which made contact with the ladder. The ground wire was not attached on the male end of the cord's

plug. When the energized conductor made contact with the ladder, the path to ground included the employee's body resulting

in death.

COMMENTS

1. A large majority (estimated from many compliance staff sources) of the citations under this standard are issued because

ground prongs are missing from cord and plug connected equipment or extension cords.

2. Sometimes ground prongs are intentionally removed from tools and extension cords because, “it makes them easier and

quicker to plug into and remove." Statements such as these heard from employees clearly indicate that they do not understand

the importance of the of the components of the equipment grounding system.

3. For five years, citations were issued to the contractor who employed the deceased employee in 93 fatality/catastrophe

investigations that OSHA conducted, where the absence of a required equipment grounding conductor or lack of continuity of

the conductor were listed as a factor.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE

[1] Section 404(f); [2] pg. 5; [3] pgs. 35-58; [4]; [5] Art. 250

38

RANK IN FREQUENCY CITED

#5

1926.

652(a)(1) PROTECTIVE SYSTEMS FOR

TRENCHING/EXCAVATING

RULE: Each employee in an excavation shall be protected from cave-fns by an adequate protective system

designed in accordance with paragraph (b) or (c) of this section..

INTENT:

Excavation accidents often result in serious injury or death. California reports a ratio of lost-time accidents to fatalities [14] for cave-ins

aqua to 14:1. In contrast that same ratio for all types industry in California a 250:1. From 1985-1989 OSHA investigated 239

excavation fatalities [10]. This rule is basically a general rule and it's intent is to state that the employer will utilize some means of

protection when employees are working in an excavation. This standard requires employers to protect employees from cave-ins. Later

paragraphs, Paragraph (b) "Design of Sloping and Benching Systems" and Paragraph (c) "Design of Support System, Shield Systems

and Other Protective Systems give specific alternatives and corresponding appendices to help the employer comply with the rule

(NOTE: Appendices A - F provide valuable information for complying with the standard). The rule does not cover excavations in

stable rock and excavations less the 5 feet deep - ONLY when the competent person evaluates the excavation and states there is no

potential for cave-ins.

HAZARDS:

A cave-in is the greatest risk associated with excavation, Fatalities can be expected if a cave-in occurs. Other type hazards which are

similar to confined space situations should be expected including asphyxiation due to lack of O2, inhalation of toxic materials, fire,

drowning, etc. Moving machinery near the edge of the excavation can cause a surcharge (overloading) of the excavation wall that can

cause collapse. Plus, the same machinery and vehicular traffic can strike employees. Many accidence occur when workers contact or

sever underground utility lines.

(AMONG OTHER) SUGGESTED ABATEMENTS:

o Pre job planning is vitally important to this operation. The soil must be evaluated so the employer can select an appropriate

protective system. Utilities must be contacted so they can identify their underground lines, traffic control may be an issue, an attempt

to identify previous site history must be made, in. was the excavation previously backfilled?, etc.

o Construct all protective systems in accordance with the standard.

o Inspect the site daily at the start of each shift, following a rainstorm or after any other hazard increasing event.

o Keep excavations open the minimum amount of time needed to complete operations.

SELECFED CASE HISTORIES:

o Two employees were installing 6’ PVC pipe in a 40 long x 9t x 2t wide trench. No means of protection was provided in the vertical

wall trench. A cave-in occurred fatally injuring one employee and causing serious facial injuries to the second employee.

o An inadequately protected trench wall collapsed killing one employee who had just gotten into the trench to check grade for

installation of an 8N sewer line. The trench was = 201-25, deep and had been benched ≈ one bucket width (40 on each side. At the time

of collapse the backhoe was extracting soil from the trench.

o Four employees were in an excavation 9, wide x 3V long x 71 deep were boring a hole under a road. Eight foot steel plates used as

shoring were placed against the side walls of the excavation at about 30 degree angles. No horizontal bracing was used. One of the

plates tipped over crushing an employee.

COMMENTS:

1. Of all the excavation standards, this one is cited the most often because it is the appropriate standard to cite when no protection at

all is provided. Unfortunately, many employers engaged in this activity, still provide no protection for their employees.

2. This standard is written in a unique manner -"Each employee..", which gives OSHA, the option to cite this particular standard for

each exposed employee.

3. 'This standard was cited in 47 fatality/catastrophe inspections conducted by the Agency from March 1990 to January 1992.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[141, [20]

40
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

Properly constructed timber shoring and trench box (left)

NOTE: The plywood (bottom right) is not a structural

member of the shoring system. It is to be used only to

prevent the soil in the sidewalls from raveling.

" VIOLATION ! IN-COMPLIANCE

Employees in vertical wall trench with no sidewall

protection (above).

" VIOLATION ! IN-COMPLIANCE

Improper shoring including bracing is not secured (above)

" VIOLATION ! IN-COMPLIANCE

Employees is exposed (arrow) between concrete

manhole and unprotected sidewall of excavation (right).

:

41
RANK IN FREQUENCY CITED

#6

1926.

451(d)(10)

GUARDRAIL SPECIFICATIONS

FOR TUBULAR WELDED

FRAME SCAFFOLDS

RULE: Guardrails made of lumber, not less than 2 x 4 inches(or other material providing equivalent protection),

and approximately 42 inches high, with a midrail of 1 x 6 inch lumber (or other material providing equivalent

protection), and toeboards, shall be installed at all open sides and ends on all scaffolds more than 10 feet above

the ground or floor. Toeboards shall be a minimum of 4 inches in height. Wire mesh shall be installed in

accordance with paragraph (a)(6) of this section.

INTENT:

OSHA investigated 214 fatalities from 1985-1989 [10] related to falls from scaffolds. The intent of this standard is to provide

specifications far a fall prevention system, i.e. standard guardrails and toeboards, on tubular welded frame scaffolds. Because this is a

specification standard it only applies to tubular welded frame type scaffolds. Note: This standard requires both standard guardrails and

toeboards at a height of 10'. The general scaffold requirement 1926.451(a)(4) which requires guardrails between 41-10, when the

minimum horizontal dimension of the scaffold is < 45', does not include tubular welded frame scaffolds, see OSHA

CLARIFICATION LETTER below. Other guardrail materials which would provide equivalent protection are listed in TABLE 5.2-1.

When persons must work or pass under a tubular welded scaffold, wire mesh construction is required. This includes a minimum No. 18

gauge US. Standard wire 1⁄2-inch mesh or equivalent extending along entire opening from toeboard to top rail. If persons are not

required to work or pass under the scaffold only a toeboard is necessary (see TABLE 5.2-2 for acceptable toeboard specifications).

HAZARDS:

• Fall from elevation. Probable injuries range from death to severe sprains/strains.

• Struck by falling objects from scaffold platforms with insufficient material containment systems, i.e. wire mesh screen or toeboards.

Probable injuries could include death or lost-time injuries duet) head concussion, broken bones in the upper body areas, etc.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Whenever employees must work any elevated location, ask: 1) Are they protected from a fall? and 2) What measures must be taken to

protect the employee at the elevated work location?

• Fall prevention systems such as standard guardrail systems provide a more positive means of protection than fall protection systems

such as the use of a bodybelt/harness-lanyard-lifeline combination.

SELECTED CASE HISTORIES:

• An employee preparing masonry facia for removal from a building fell from the third level of a tubular welded frame scaffold. No

guarding system was provided for the scaffold. Further, the platform was coated with ice creating a slippery condition.

• A contract employee was taking measurements inside a reactor vessel from an unguarded tubular welded frame scaffold when he

either lost balance or stepped backwards and fell ≈ 14 1⁄2’, sustaining fatal injuries.

COMMENTS:

1. Many scaffolding guardrail violations are issued because no railings were provided on the ends of the scaffolds. Remember, a fall

prevention system is not complete until the scaffolding is completely enclosed. Additionally, this is a specification standard, therefore,

it is more easily identified and substantiated as a violation when the guarding is not provided.

2. Scaffold cross-bracing (X braces) are not acceptable alternatives for guardrails.

3. Many times scaffold guardrail are provided for tubular welded frame scaffolds where only one or two 10” planks are provided for a

60” wide scaffold end frame. This is ineffective because there is a potential for an opening 40”-50” between the edge of the "platform"

and the guardrail (if in-place). Instead of falling over the edge of the scaffold, employees are exposed to falling through the scaffold.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 451(a) & (d), [17]

OSHA DIRECTIVE #100-58 (STD 3-10.3)

Date 10/30/78-Synopsis - Wire, chains, synthetic and fiber apes may be used as guardrails as per equivalent requirements of 1926.451

(a) (5) provided it meets the following guidelines: 1) it is secured to each support and taut at all times; 2) it a free of sharp edges; and 3)

it has a maximum deflection of 3” in any direction when a 200 1b. load is applied.

Note: No size requirements of the ropes are listed in directive.

42
OSHA CLARIFICATION LETTER

Date 3/11/83; From Acting Regional Administrator Region III to Area Director; Synopsis – 1926.451(a)(4) – General Scaffold

Requirements, guarding in particular – If a specific type scaffold is covered by a standard such as tubular welded frame guarding

doesn’t need to be provided as per 451(a)(4) from the 4’ – 10’ level unless adjacent to dangerous equipment. NOTE: This position was

reaffirmed in a letter dated August 7, 1992 from the Acting Assistant Secretary to an individual company.

PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

A properly erected guardrail system with top rail, mid rail and

toeboard.

End frame not

guarded.

NOTE: The

hole between

the scaffold

planks is large

enough to fall

through (left).

121/2 ft. tall

scaffold (left) with

no fall protection

provided.

" VIOLATION ! IN-COMPLIANCE

(above left, left, immediately above)

4 buck high scaffold (above) with no guardrail system any

of the 4 working heights.

NOTE: The incomplete platforms and deficient erection of

the structural members.

43
RANK IN FREQUENCY CITED

#7

1926.

28(a) APPROPRIATE PPE USED

FOR SPECIFIC OPERATION

RULE: The employer is responsible for requiring the wearing of appropriate personal protective

equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the

need for using such equipment to reduce the hazards to the employees.

INTENT:

This rule gives the employer responsibility for insuring that employees wear appropriate PPE to reduce the exposure to hazardous

conditions such as falling objects, toxic atmospheres, noise exposure, etc.. PPE is not only a right for the employee - it is a

responsibility for the employer. This standard is part of Subpart C - General Safety and Health Provisions. Specific PPE and life

saving equipment requirements are found in Subpart E, including: head protection; hearing protection; eye and face protection;

respiratory protection; safety belts, lifelines, and lanyards; and safety nets. The Subpart E requirements are usually more specific than

the Subpart C requirement. 1926.28(a), therefore, the standards in Subpart E are utilized more often than 1926.28(a). For example

1926.100(a) is #2 on the 100 Most Cited Physical LIST, conversely 1926.28(a) is #7. The Subpart E standards give

specifications/guidance for selecting, use and maintenance of appropriate types and levels of PPE depending on the types of hazards

employees are exposed.

HAZARDS:

Hazards can range from falling objects or bodies to inhalation of toxic materials. The injuries related to this standard also vary widely,

inducting instant death from the inhalation of a highly toxic substance to a minor burn.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Evaluate the operations, define the hazards. When it is not feasible to design out all hazards, it may be necessary for employees to

wear PPE.

• Discipline workers who fail to wear PPE. Because PPE can be uncomfortable, cumbersome, hot etc., employees sometimes don't

wear it even though they know they may be risking injury. When an employee has been given repeated warnings about not wearing

PPE, but still does not wear it, it may be prudent for the employer to impose appropriate penalties, leading to release if the employee

persistently chooses not to follow company safety rules.

• Another system that has shown to work is to require employees, as a condition of employment, wear PPE at all needed times.

SELECTED CASE HISTORIES:

An employee was working with a crew setting a metal elbow duct for a bag house when he fell ≈ 50' to his death. The victim was

wearing a safety belt with lanyard; however, the lanyard was not attached to any tie-off support.

COMMENTS:

1. Several United States Courts of Appeals have vacated citations relying on this standard as a requirement for fall protection.

However, as can be seen by the numerous violations related to the standard the Agency was still enforcing it in 1991. In response to

the courts, OSHA developed guidelines to use 1926.28(a) & 1926.105 for fall protection. Those guidelines were set forth in STD

3-3.1. See below for a synopsis of that STD. However, STD 3-3.1 has been canceled and is no longer in effect, See OSHA NOTICE

CPL 2 below.

2. This standard was cited in 257 fatal/catastrophe inspections in 5 years by the Agency.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Sections 1926. 100, 101, 102, 103, 104, 105 & 106; [7]*, [8]*, [9], [12], [13], [15]*, [16]; [25]

*- Referenced in 29 CFR 1926- Construction Standards

OSHA. INSTRUCTION STD 3-3.1

Date 7/18/83; Synopsis - Clarifies using 1926.28(a) & 1926.105(a) as fall protection requirements. Gives guidance as to how to apply

the standards. General guidance is to provide safety belts-lanyards at heights > 10’ and < 25’. Above 25’ provide safety new or other

means of adequate fall protection. Other specific guidance is provided. Note - this STD has been canceled. OSHA Notice CPL 2 is 

currently in effect, see next page.

44 
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

OSHA Notice CPL 2

October 5, 1992

Office of Construction and

Maritime Compliance Assistance

Subject: Cancellation of OSHA Instruction STD 3-3.1

A. Purpose notice cancels an OSHA Instruction based on court decisions that make the guidance

given in the instruction inaccurate.

B. Scope. This notice applies OSHA-wide.

C. Cancellation. OSHA Instruction STD 3-3.1,July 18,1983, "Fall Protection in Construction: 29 CFR

1926.28(a) and 29 CFR 1926.105(a)," is canceled.

D. Expiration Date. This notice expires on October 30, 1992.

E. Action. Users of the OSHA Directives System shall remove from their files and discard OSHA Instruction

STD 3-3.1.

F. Background. The Review Commission has held in the LE. Meyers Company case, OSHRC Docket No.

82-1137, that the December 1972 revision to 1926.28(a) was invalid on the grounds that the change

from "and" to "or" was substantive change that could not be accomplished without notice and comment

rulemaking. This decision holds that 29 CFR 1926.28(a) may not be cited unless there is exposure to a

hazardous condition and the need for personal protective equipment is indicated elsewhere in the Part

1926/1910 Construction Industry Safety and Health Standards.

In view of this decision, use of 1926.28(a) is superfluous. If a hazard is addressed by another standard,

such as 1926.105 for a fall greater than 25 feet, the other standard should be cited. Recognized failing

hazards not covered by an existing standard shall be cited in appropriate cases under the general duty

clause as indicated in Chapter N of the Field Operations Manual.

Directorate of Compliance Programs

NOTE: Even though the use of this standard has been curtailed. It is strongly recommended by OSHA that the employer evaluate

all operations employees are involved with at a worksite to determine what hazards might exist and the appropriate

measures including PPE which can be utilized to eliminate or control the hazard. All other PPE requirements specifically

addressed by OSHA as well as industry recognized requirements for wearing PPE are still being enforced by the Agency

by utilizing specific standards or the General Duty Clause - 5(a)(1).

45
RANK IN FREQUENCY CITED

#8

1926.

1052(c)(1) STAIR RAILS REQUIRED AT

30” CHANGE OF ELEVATION

OR 4 RISERS

RULE: Stairways having four or more risers or rising more than 30 inches (76 cm), whichever is less,

shall be equipped with at least one handrail and one stairrail system along each unprotected side or edge.

However, when the top edge of a stairrail system also serves as a handrail, paragraph (c)(7).

INTENT:

OSHA estimates that 4 fatalities, 5400 impact injuries and 1900 sprain/strain injuries occur annually on stairways [18] . About 65% of

those injured required medical treatment. The intent of this standard is to require the use of stairrail systems and handrails when a set

of stagy is > 30" in height or it has ≥ 4 risers and an unprotected edge. Walls or stairrail systems (vertical barrier consisting of a

handrail, mid rails and constructed similarly to guardrail systems [See TABLE 5.2-1]) can guard an unprotected edge. Note: the top

edge of a stairrail system can serve as a handrail. The top edge of the stairrail system which is used as a handrail shall be < 37"-36"

> from the surface of the tread measured in line with the face of the riser.

HAZARDS:

Fall from elevation; can be fatal. Most likely injuries rangefrom broken bones to sprains/strains.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Identify all access points where there is a break in elevation of ≥ 19". Are all these access points provided a stairway/ladder? Does

every access/egress area have a stairway/ladder or some other equivalent safe means of access/egress? Are the stairways

constructed/maintained properly?

SELECTED CASE HISTORIES:

The OSHA IMIS system included no fatalities directly caused by failing to adhere to this standard (since January 1991 when

standard came into effect).

1. This is another of the more common situations found on construction sites which are covered by specification standards that are

easily identified and substantiated as a violation. This is probably a reason it is quite high on the list.

2. This standard became effective in January 1991. The old previous standard (1926.500(e)(1)(iii) ranked #80 on the 1991 List of

the Most Frequently Cited Physical Hazards. The two standards taken together would rank #7 on the 100 Most Cited PhysicalL List

and #13 on the 100 Most Cited List.

3. One of the most common stairway violations found on a construction site is the complete absence of stairs or no stairrails for the

risers leading into the equipment trailer [Conversations with CSHO's].

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[18], [19]

46
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

Stairrail systems which meet OSHA erection specifications.

" VIOLATION

! IN-COMPLIANCE

No guarding

provided for a

6 riser stairway.

! VIOLATION " IN-COMPLIANCE

Properly erected stairway

and stairrail system.

" VIOLATION ! IN-COMPLIANCE

Guarding not provided for the

unprotected edge

47
RANK IN FREQUENCY CITED

#9

1926.

152(a)(1)

APPROVED CONTAINERS OR

TANKS FOR STORING OR

HANDLING FLAMMABLE OR

COMBUSTIBLE LIQUIDS

RULE: Only approved containers and portable tanks shall be used for storage and handling of flammable and

combustible liquids. Approved metal safety cans shall be used for the handling and use of flammable liquids in

quantities greater than one gallon, except that this shall not apply to those flammable liquid materials viscid

(extremely hard to pour), which may be used and handled in original shipping containers. For quantities of one

gallon or less, only the original container or approved metal safety cans shall be used for storage, use, and

handling of flammable liquids.

INTENT:

The intent is to provide acceptable containers (Approved safety cans) for the handling, use and storage of flammable and combustible

liquids. Because these materials can ignite and cause fires or explosions this standard requires an "Approved Metal Safety Can". The

approved safety can may have a maximum five gallon capacity and must include a spring closing lid and spout a flame arrestor, and a

design to relieve internal pressure in a safe manner when exposed to fire. "Approved" means equipment that has been listed or approved

by a nationally recognized testing laboratory. The standard does not apply to highly viscid materials in their original shipping

containers nor to any flammable or combustible liquids in quantities 1 gallon in their original containersor in approved metal safety

cans. OSHA now recognizes approved plastic containers, see discussions below.

HAZARDS:

Fire and/or explosion; aunt likely injuries range from fatalities to 1st degree burns.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• When handling, storing or using flammable and combustible materials, follow all fire prevention rules such as no smoking. Bond and

ground all containers when transferring contents to eliminate the possibility of static charge and a potential ignition source.

• Survey your worksite to determine if flammable and combustibles are being used. Then determine if they are being used, transferred,

and stored in a safe manner as prescribed by OSHA and NFPA.

SELECTED CASE HISTORIES:

There were no fatality/catastrophes listed in BUS for the past five years directly tied to violations of this standard. However, the

inadequate use, transfer and storage of these materials has caused many serious burns.

COMMENTS:

1. Frequently gasoline I brought on site in a 21⁄2 or 5-gallon unapproved can that was purchased at a local hardware store. Because this

is a specification standard the violation is very easy to identify and substantiate (conversations with OSHA CSHOs).

2. Plastic containers can lx used as an "approved" container 11 they have been "approved" by a nationally recognized testing

laboratory. See below.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Subpart F

OSHA COMPLIANCE MEMORANDUM

Dates 7/19/89; From Directorate of Compliance Programs to Regional Administrator VI; Synopsis- Clarification stating that the term

"approved" applies to the use of plastic containers in lieu of metal safety cans when they are approved as containers for flammable

liquids over one gallon by Underwriters Laboratories (UL) or Factory Mutual (FM) (or other nationally recognized testing laboratory).

OSHA ISTRUCTION STD 3-4.1A

Date 9/16/80; From OSHA Compliance Programming; Synopses- 1926.155(l) requires a flash arrestor screen for an approved metal

safety can. FM requires flame arrestor screens in their approvals of safety cans; however, UL does not require the arrestor screens in

their safety can approval. NFPA 30 recognizes approval of both FM or UL. Therefore, any citation issued under this standard for lack

of the flame arrestor screen only is de minimis.

48
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

An approved safety can. The arros show

the self closing cover and flame arrestor

" VIOLATION ! IN-COMPLIANCE

A common can on the market for gasoline.

However, the can is not approved because

it does not include a self-closing top.

" VIOLATION ! IN-COMPLIANCE

2 plastic cans which do not meet

the criteria for self-closing tops.

49
RANK IN FREQUENCY CITED

#10

1926.

25(a) GENERAL HOUSEKEEPING

RULE: During the course of construction, alteration, or repairs, form and scrap lumber with

protruding nails, and all other debris, shall be kept cleared from work areas, passageways, and stairs, in and

around buildings or other structures.

INTENT:

Since construction sites are dynamic by nature, the work areas often times become cluttered and disorderly creating a hazard. The

array of construction debris is almost endless, including wood from old forms, broken pallets, boards with protruding nails and

material shipping container to name just a few. At any given time it would not be unexpected to find any area of a construction site

with a housekeeping problem. Housekeeping must be on-going as the job progresses.

HAZARDS:

Poor housekeeping can lead to the increased risk of trips, slips and falls. Resulting injuries range from fractures to sprains/strains.

Associated hazards include nails in boards responsible for skin punctures resulting in lockjaw. If combustibles are not controlled at the

site fires may occur.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Encourage the first line managers to make a concentrated effort to focus on housekeeping.

• On larger job sites, give laborers specific duties related to housekeeping only.

• On smaller sites, set up a system designating certain employees on an hourly basis to care for housekeeping chores.

SELECTED CASE HISTORIES:

IMIS did not contain any fatality/catastrophe inspections over the past five years, where violations of this standard were a

direct/indirect cause(s) of an accident.

COMMENTS:

1. Although identifying a housekeeping violation is a subjective call (no real specific criteria which delineate what an actual

housekeeping hazard is) these violations are rarely challenged when the CSHO has a photograph of the particular situation

(Conversations with OSHA Area Directors).

2. This standard was cited in 33 OSHA fatality/catastrophe inspections in five years.

ADDITT0NAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 25 (b) & (c)

50 
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

All six worksites below are examples of poor housekeeping.

51
RANK IN FREQUENCY CITED

#11

1926.

651(k)(1)

DAILY INSPECTION OF

PHYSICAL COMPONENTS OF

TRENCH AND PROTECTION

SYSTEM

RULE: Daily Inspections of excavations, the adjacent areas, and protective systems shall be made by

a competent person for evidence of a situation that could result in possible cave-ins, indications of failure of

protective systems, hazardous atmospheres, or other hazardous conditions. An inspection shall be conducted by

the competent person prior to the start of work and as needed throughout the shift. Inspections shall also be

made after every rainstorm or other hazard increasing occurrence. These inspections are only required when

employee exposure can be reasonably anticipated.

INTENT:

This rule gives criteria for employees to use in conducting inspections of excavations to identify signs warning of potential cave-in,

failure of a protective system, hazardous atmosphere or other hazards. The criteria include the frequency of inspections (daily prior to

each shift, throughout shift as needed, after rainstorms or other hazard-increasing occurrence) and the locations of the inspections

(excavations, adjacent areas and protective systems). The competent person is responsible for conducting these inspections. The

competent person must have specific training in, and be knowledgeable about sod analysis, the use of protective systems and the

requirements of the standard. An important provision of the competent person requirement is that he/she must have real authorization to

take prompt corrective measures to eliminate hazards.

HAZARDS:

Cave-ins are the most frequent and most dangerous hazard associated with these excavations. Fatalities can be expected if a cave-in

occurs. Other type hazards similar to those associated with confined spaces should be expected including asphyxiation due to lack of O2

inhalation of toxic materials, fire, drowning, etc. Moving machinery near the edge of the excavation can cause a surcharge (overloading)

with resulting stress cracks at/near the edge of the excavation wall which can cause collapse. Many accidents occur when employees

contact or sever underground utility lines.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Use the GUIDE FOR THE DAILY INSPECTION OF TRENCHES/EXCAVATIONS on the next page to assist in identifying the

warning signs of excavation failure and specific items to evaluate for different trench/excavation protection systems.

• Keep excavations open the minimum amount of time needed.

• RECOMMENDATION ONLY: Prior to giving authorization as competent person conduct a rigorous testing program to assure that

his/her knowledge level is functional for the duties and responsibilities of a competent person.

SELECTED CASE HISTORIES:

• An employee was in a 7’ 6” deep trench installing forms for concrete footers when the trench caved-in causing fatal injuries. The

trench was in loose sandy soil (Type C) and no inspection was conducted prior to the start of the shift/operation.

• An employee in a trench 6' deep x 32' wide was applying a waterproofing primer material containing methyl chloroform and 1,4

dioxane to

the foundation of a house. The employee was overcome and latter died of trichloroethane intoxication. Deficiencies rated to the cause

of the accident included: 1) no one had tested the atmosphere in the trench; 2) the employees were not provided with respiratory

protection; and 3) mechanical ventilation was not used.

COMMENTS:

1. The competent person must be knowledgeable and have the authority to take corrective action.

2. At times the production schedule and the duties of the competent persons conflict, If the competent person's authority, is overridden,

overtly or he/she fails to act because he/she believes the company would not support him/her, then in reality there is no true competent

person at the excavation site.

3. This standard was cited in 37 fatality inspections conducted by OSHA since March 1990.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[14], [20]

OSHA CLARIFICATION LETTER

8/5/92; From Directorate of Compliance Programs to Private Company, Synopsis - A competent person need not present at the site at

all times when trenching/excavating operations are being conducted. However, it is the competent person's responsibility to inspect the

site to identify hazardous conditions and to take the appropriate corrective action. Therefore, the individual conditions at each site will

govern the amount of time a competent person must spend at the site.

GUIDE FOR THE DAILY INSPECTION OF TRENCHES AND EXCAVATIONS[30]

See next page.

52
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

GUIDE FOR THE DAILY INSPECTION OF TRENCHES/EXCAVATIONS[30]

WARNING SIGNS OF THE FUTURE

• Tension Cracks (In Sidewalls, Slopes and Surface

adjacent to Excavation

• Ground Settlement or Subsidence

• Changes in Wall Slope or Bulge

• Increase in Strut Loads

• Bowing of Struts

• Spalling or Sloughing of Soils

• Excessive Seepage and Piping of Fine Soils

• Softening of Sidewalls

• Boiling of Trench Bottom

• Creaking or Popping Sounds

• Visual Deformation of Bracing System or Trench

SHORING/BRACING CHECKLIST

• Strict Adherence to Plans and Specifications

• Changes in Soil Condition

• Maintenance of Proper Slope Ratio

• Excessive Vibrations

• Location of Spoil Pile

• Equipment Location Relative to Excavation

• Secondary Soil/Rock Structure -

• Presence of Water Seepage and Rainfall

• Location of Trees, Boulders, Structures and Existing

Utilities

• Right-of-Way

• Signs of Distress

SLOPING/BENCING CHECKLIST

• Strict Adherence to Plans and Specifications

• Changes in Soil Conditions

• Excessive Vibration

• Location of Spoil Pile

• Equipment Location Relative to Excavation

• Excessive Wear or Damage to Equipment

• Signs of Distress

• Improper Installation Procedures

- Workers in unbraced trench

- Improper system being used

- Improper alignment of members

- Improper installation of connections

• Location of Existing Utilities and Backfill

TRENCH SHIELD (BOX) CHECKLIST

• Strict Adherence to Plans and Specifications

• Changes in Soil Conditions

• Clearance Between Shield Trench Sidewalls

• Adequate Freeboard at Top of Shield

• Proper Slope Above Shield

• Current Certification of Shield

• Excessive Wear or Damage of Shield

• Improper Use of Shield

- Workers in unshielded trench

- Improper shield being used

• Location of Existing Utilities

NOTE: These are only general warnings of failure and recommendations for daily inspections of most trenches and

excavations. Every trench/excavation must be inspected by a competent person as per 1926.651(k)(l) for the

items listed above and all other hazards which are unique to that site.

53
RANK IN FREQUENCY CITED

#12

1926.

451(a)(13) SAFE ACCESS FOR ALL

TYPES OF SCAFFOLDS

RULE: An access ladder or equivalent safe access shall be provided

INTENT:

To decrease the risk of a fall, this standard requires a ladder or other equivalent means of access for scaffolds. Too often when

ladders are not in place, workers climb the end frames of the scaffold (a common unsafe work practice in the construction

industry). This can be hazardous. Depending on the design of the end frame the structural members which are used as ladders rungs

can be narrower than the width of an average food i.e. this case requires the employee to actually stand on the side of his foot

on the "rung"" The vertical distance between "rungs" also may be excessive (2 1⁄2‘' – 3'), resulting in the employee reaching for the

next "rung". Unless the end frame is designed as a ladder access frame, it must not be used as such. The scaffold manufacturer or

dealer can assist the user in determining if a scaffold frame has a built-in ladder. Some of the common frames do not have built-in

ladders. Scaffold ladders that attach directly to the frame can be obtained from scaffold dealers. Equivalent safe access to scaffold

platforms can include access from a building floor/window directly to the platform, a portable stairway system, etc.

HAZARDS:

Fall from elevation. Probable injuries vary from death to severe sprains/strains.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Construct all scaffolds and related components (ladder access) as per scaffold manufacturers technical literature.

• Whenever possible, use a window/floor at the elevation of the platform to gain access, thereby, eliminating any hazard associated

with climbing.

SELECTED CASE HISTORIES:

While descending the end frame of a scaffold that was not designed to be a built-in ladder, an employee lost his balance, fell 13’ to

concrete and suffered fatal head injuries.

COMMENTS:

1 If the scaffold user has any questions about the scaffold, i.e. construction, use, etc. they should contact the scaffold manufacturer

or dealer. Experience has proven that they are fully cooperative and can assist with technical questions.

2. If workers use an attached ladder on the end frame of the scaffold, the scaffold must be constructed to withstand the effects of the

overturning force imparted on the scaffold due to the external loading caused by the weight of the person climbing the ladder. A

material hoist on the same side as the ladder might increase the overturning force causing collapse of the scaffold. These loading

factors must be considered in the design/construction phase.

3. A portable ladder, constructed and used as per Subpart X of 1926 is an acceptable ladder for access to scaffolding.

4. This standard was cited in 35 fatality inspections conducted by OSHA over five years.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 451; [18] Sections 1051 & 1053-1060 (Subpart X)

OSHA COMPLIANCE LETTER

Date 2/25/83; From Chief, Division of Compliance Prgms., to Individual Company; Synopsis - 1) It's not practical for employer to prove

ladder access at all times for employees assembling/dissembling scaffolding; however, other safe access must be provided; 2) end

frames designed by a scaffold manufacturer as ladder access are acceptable if they are erected in a continuous line and the maximum

spacing between rungs < 161⁄2"; 3) portable wood or metal ladders must comply with Subpart X (formerly Subpart L); 4) fixed ladder

standards do not apply to scaffolds; and 5) Subpart X does not apply to built-in scaffold ladders.

OSHA CLARIFICATION LETTER

Date 4/7/87; From Director of Directorate of Field Programs to Regional Administrator; Synopsis - The following relate to designed

and manufactured built-in scaffold access ladders: 1) allow a maximum 161⁄2 " rung spacing; 2) rungs may be spaced unevenly where

end frames join provided they do not exceed maximum rung spacing; 3) climbing over top guardrail or scaffold board overlay is not a

safe practice; and 4) guardrail systems shall be provided with removable rails, chains or gates in accordance with manufacturers'

recommendations.

54
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

The 2 photos (left) show employees accessing

scaffolds by using a hook-on scaffold. NOTE: the inward swinging gate which

allows employees to step directly from the ladder on to the platform. Also, the

scaffold (far left) has a platform which is not fully planked and creates a hazard.

! VIOLATION " IN-COMPLIANCE

The 2 photos (above & left) show employees using

the structural members of end frames as ladders.

The scaffold manufacturer did not design these

type end frames as built-in ladders. NOTE: The

platform violations

" VIOLATION !IN-COMPLIANCE

The scaffold below shows end frames

which where designed by the

manufacturer to be built-in laddders.

NOTE: The chain above the platform

gurading opening.

55

" VIOLATION

!IN-COMPLIANCE
RANK IN FREQUENCY CITED

#13

1926.

404(b)(1)(ii) GROUND FAULT CIRCUIT

INTERRUPTERS (GFCI’s)

RULE: All 120-volt, single-phase, 15-and-20-ampere receptacle outlets on construction sites, which are

not a part of the permanent wiring of the building or structure and which are in use by employees, shall have

approved ground-fault circuit Interrupters for personnel protection. Receptacles on a two-wire, single-phase

portable or vehicle-mounted generator rated not more than 5kw, where the circuit conductors of the generator are

Insulated from the generator frame and all other grounded surfaces, need not be protected with ground-fault circuit

Interrupters.

INTENT:

This standard requires the use of electrical hardware that is designed for monitoring ground fault current and is capable of stopping the

fault current in the circuit, i.e. through an employee's body. This rule states that all 120 volt 15 & 20 amp receptacles outlets on

construction sites will be protected by ground fault circuit interrupters (GFCI’s), when not part of the permanent wiring of a structure.

Because a receptacle is in effect part of the branch circuit wiring, this rule is effectively identical to 1926.404(b)(1)(1) - GROUND

FAULT PROTECTION. For more information related to the operation of GFCI’s see #3 GUIDE Sheet. This rule exempts portable or

vehicle-mounted generators that meet the following: 1) rated < 5kW; 2) system wiring is two wire, single phase; and 3) circuit conductors

are insulated from the generator frame and all other grounded surfaces. NOTE: GFCPS ARE NOT TO BE USED IN LIEU OF

EQUIPMENT GROUNDING - GFCPS ARE SUPPLEMENTAL PROTECTION AND MUST ONLY BE CONSIDERED AS A

BACKUP TO EQUIPMENT GROUNDING. GFCI's can be placed anywhere in the circuit and still be effective. They may be put in a

panel box as a breaker, at the receptacle or in-line anywhere along an extension cord up to the tool. GFCI’s are very important on

construction sites because of the likely probability of encountering wet/damp locations that greatly increase the risk of electrical shock.

HAZARDS: 

Fatal electrocutions, electrical burns ranging from critical to minor, Fire; Explosion; Electric shock has been initiator of other type

hazards, i.e. electrical shocks can cause employees to fall from elevated work surfaces, loose control hand held equipment which in turn

can strike other employees in the immediate work area, etc.

(AMONG OTHER) SUGGESTED ABATEMENTS:

o Frequently trip GFCI’s while test tool is operating to insure GFCI is operating correctly.

o Use double insulated tools. Double insulated tools can protect the user from fault currents which might energize the case of the tool or

equipment.

o GFCI’s for 220-volt circuits are available. Note: they are not required by this standard.

SELECTED CASE HISTORIES:

An employee attempted to plug an extension cord into a temporary power spider box. The employee was kneeling on the ground and held

the box in his hand. Fault current energized the case of the box and electrocuted the employee. No GFCI's were used.

COMMENTS:

1. Although double insulated tools are recommended, using them does not relieve the employer from providing ground fault protection.

Extension cords connecting a fixed electrical system (permanent outlet) and a tool can become worn with exposed energized conductors.

Therefore, ground fault protection or an AEGCP would be required. See OSHA CLARIFICATION LETTER below.

2. According to OSHA [10] there were 48 fatalities in the years 1985 to 1989 related to 120-volt electrical systems.

3. Employers have attempted to skirt the requirements of providing ground fault protection by using 30 amp breakers in their 120-volt,

single-phase systems. This not only defeats the intent of the ground fault provisions, it also introduces new hazards because the system is

no longer rated for the actual over current protection (30 amp breaker) that is in place. (Personal experience & conversations with

CSHO's).

4. Had all 3 requirements for ground fault protection been combined (1926.404(b)(1)(i) & (ii) & (iii)), they would have been ranked # 1

on the 100 Most Cited Physical Lisa t and #4 on the 100 Most Cited LIST.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 404(b); [3]; [4]; [5]

OSHA CLARIFICATION LETTER

Date 11/4/92; Directorate Compliance Programs to Private Company; Synopsis - If all extension cord sets and/or portable tool assemblies

are approved and used in such a manner that the entire lengths of all cords whether provided power from either permanent or temporary

wiring, have GFCI protection, then the employer would be in compliance. If any of the cords or tools in a series are not protected by a

GFCI, then an AEGCP would be required for all the cords and tools, including the ones already protected by a GFCI.

56 
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

The Gound-Fault-Circuit Interrupter (“GFCI”) provides an additional precaution

The GFCI is a solid-state, sensitive device which can be applied to open the circuit in

case of ground-fault leakage too small to trip the circuit breaker, (but large enough to

be dangerous to people).

HOW THE GFCI PROTECTS PEOPLE

(BY OPENING THE CIRUIT WHEN CURRENT FLOWS THRU A GROUND-FAULT

PATH.)

Note that the GFCI will open the circuit if 5 mA or more of current returns to the

service entrance by any path other than the intended white wire. If the equipmentgrounding conductor is properly installed and maintained this will happen as soon as

the faulty tool is plugged in. If by change this grounding conductor is not intact and

low-impedance, the GFCI may not trip out until a person provides the path. In this

case the person will receive a shock, but the GFCI should trip out so quickly that the

shock will not be harmful.

Where are GFCI’s required?

OSHA required GFCI’s on construction sites because of the combined special

hazards of two conditions.

a. Questionable integrity of the ground-fault path through temporary wiring.

b. Presence of wetness due to working on earth, wet concrete, etc.

! VIOLATION "IN-COMPLIANCE

The use of portable GFCI’s (arrow)

meets this requirements.

57
RANK IN FREQUENCY CITED

#14

1926.

701(b) GUARDING OF PROTRUDING

STEEL REBARS

RULE: Reinforcing steel. All protruding reinforcing steel, onto and into which employees could fall, should be guarded

to eliminate the hazard of impalement.

INTENT:

In conversations with construction personnel, they seem to all have an account of a situation where an employee has fallen and

Impaled himself on a piece of steel rebar. The accounts are some of the most gruesome stories told related to accidents in the

construction industry. This rule requires guarding for the ends of the rebar where the potential impalement could exist. The

most common guarding is specially manufactured rebar caps which fit onto the rebar and have rounded surfaces facing upward, or lumber is

used and set on top of the rebar. The theory is to dissipate the force of the fall by distributing it over a larger area than the diameter of the rebar,

i.e. less force reduces tile chance of impalement.

HAZARDS:

Impalement/puncture. Probable injuries can range from death to serious internal injuries.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Prior to installing rebar at the site, insure enough rebar caps or materials to construct caps will be available.

SELECTED CASE HISTORIES:

• An employee pulling a concrete hose along a form fell 2 stories and hit his head on steel bars which punctured his brain.

• A laborer fell through a roof opening about 8' to a patio foundation that had about 20 half-inch rebar protruding straight up.

The laborer was impaled by one of the bars and died.

COMMENTS:

1. This is another example of a specification standard which is easy to identify and substantiate (its either in-place or its not) as a violation.

Even though exposed vertical rebar would not be present at many OSHA construction inspections, this situation is being cited very

frequently as evident by its #14 ranking on the Most Cited Physical Hazard List. This might be an indicator of industry wide noncompliance.

2. This standard was cited in 12 fatality investigations.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Subpart Q, [26]; [27]

58
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

!VIOLATION "IN-COMPLIANCE

Rebar caps which are acceptable

as meeting OSHA requirements.

" VIOLATION ! IN-COMPLIANCE

The arrows show 3 rebars without protective caps which create a hazard.

59
RANK IN FREQUENCY CITED

#15

1926.

451(a)(4) GENERAL REQUIREMENTS

FOR GUARDING SCAFFOLDS

RULE: Guardrails and toeboards shall be installed on all open sides and ends of platforms more than 10

feet above the ground or floor, except needle beam scaffolds (See paragraphs (p) and (w) of this section). Scaffolds 4

feet to 10 feet in height, having a minimum horizontal dimensions in either direction of less than 45 Inches, shall have

standard guardrails installed on all open sides and ends of the platform.

INTENT:

This standard specifies when guardrail systems and toeboards are required for all types of scaffolds (General Scaffold Requirements) that are

not covered by a specific standard. The requirements for guardrails at specific heights is similar to 1926.451(d)(10). Tubular Welded Frame

Scaffolds (See #6 "Most Cited Physical Standards Sheet”), except for scaffolds which are 4’ to 10’ in height which are not covered by a

specific standard. For further explanation see OSHA CLARIFICATION LETTER date 8/7/92, below. Guardrail and toeboard construction

specifications are contained in 1926.445 (a)(5) & (6). This rule contains an exemption for needle beam scaffolds and floats (suspended

scaffolds) and directs compliance with those type scaffolds be in accordance with Paragraphs (p) & (w), respectively. Guardrail systems are

not required on these type scaffolds, OSHA requires only safety-belts and lifelines in accordance with 1926.104 for needle beam and float

scaffolds.

HAZARDS:

• Fall from elevation. Probable injuries range -from death to severe sprains/strains.

• Struck by falling objects from scaffold platform due to lack of/insufficient material containment system, i.e., wire mesh screen or

toeboards. Probable injuries include death, lost-time injuries due to head concussion, broken bones in the upper body, etc.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Whenever an employee must work at any elevated location ask the questions: 1) Are they protected from a fall? and 2) What measures

must be taken to protect the employee at the elevated work location?

• Fall prevention systems such as standard guardrail systems provide more positive means of protection than fall protection systems

such as a bodybelt/harness-lanyard-lifeline combination, except when workers are suspended, i.e., from suspended scaffolds, work

platforms, etc.

• Construct/maintain all guardrail system according to OSHA requirements.

SELECTED CASE HISTORIES:

An employee was installing overhead boards from a scaffold platform consisting of two 2"x10" boards with no guardrails. He lost his

balance and fell 7’6" to the floor sustaining fatal injuries.

COMMENTS:

1. Many scaffolding guardrail violations are issued because no railings were provided on the ends of the scaffolds. The fall prevention

system is not complete until it is completely enclosed. Additionally, because the is a specification standard it is more essay identified and

substantiated as a violation when guarding is not provided.

2. This standard was cited in 56 fatality investigations over a five year period.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 451(a) & (d), [17]

OSHA CLARIFICATION LETTER

Date 3/11/83; From Acting Regional Administrator Region III to Area Director; Synopsis - 1926.451(a)(4) - General Scaffold

Requirements, guarding in particular - If a specific type scaffold is covered by a individual standard, such as tubular welded frame,

Guarding doesn’t need to be provided as per 451(a)(4) from the 4’ –10’ level unless adjacent to dangerous equipment.

OSHA CLARIFICATION LETTER

Date 8/7/92; From - Acting Assistant Secretary to individual company; Synopsis - The interpretation listed above is correct and still in

effect. General requirements for scaffolds, 451(a), apply to all scaffolds unless specifically exempted or when the issue is specifically

addressed in a specific section for a particular type of scaffold. The requirements for guardrails on scaffolds was specified at a height of 10’

(less than 10' in height was omitted) for paragraph .451(b) through .451(y) (standards for particular type scaffolds). Therefore, the .451(a)(4)

standard does not apply to any, 451(h) through 451(y), such as proprietary or make shift type scaffolds. Also, clarification of "10’ above the

ground or floor" was given - it is the falling distance, not the vertical dimension of the scaffold that is the controlling factor.

OSHA CLARIFICATION LETTER

Date 12/88; From Director of Compliance Programs to Regional Administrator; Synopsis - Guardrails not required -for Ladder Jack

Scaffolds because they may pose additional hazards and increase risk. The OSHA proposed rule requires the use of a body harness/belt and

lanyard for fall protection on these scaffolds.

60
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

An employee using a makeshift single

plank scaffold to apply stucco

approximatetly 7’-8’ above the ground

with no fall protection.

! VIOLATION " IN-COMPLIANCE

Front and side view (above) of a make shift scaffold 4’-6’ above the ground. No

fall protection is provided. NOTE: The opening between the scaffold platforms and

the unsecured portable ladder.

61
RANK IN FREQUENCY CITED

#16

1926.

651(j)(2) SPOIL PILE PROTECTION

RULE: Employee shall be protected from excavated or other materials or equipment that could pose a

hazard by falling or rolling into excavations. Protection shall be provided by placing and keeping such materials or

equipment at least 2 feet (.61 m) from the edge of excavations, or by the use of retaining devices that are sufficient

to prevent materials or equipment from falling or rolling into excavations, or by a combination of both if necessary.

INTENT:

The intent of this standard is two-fold, by requiring excavated material (spoils) and equipment to be set back 2 feet it accomplishes the

following: 1) decreases the risk of spoils or equipment from rolling back into the excavation on top of employees; and 2) reduces

superimposed loads on the face of the excavation which possibly could contribute to a cave-in. If the superimposed load of the spoils has

been considered in the design of the protection system the spoils may be placed at the face of the excavation if they are retained by a

sufficient (strength, i.e. can resist any reasonably anticipated forces applied to it, and/or height) device/operation such as barricading or

wire mesh.

HAZARDS:

• Cave-in caused by superimposed load on face of excavation. Probable injury is death.

• Ro1ling/falling spoils or equipment; Probable injuries could be expected to range from head concussion to bruises. Extreme cases could

result in death due to suffocation.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Conduct a pre-job survey of site to insure the location is large enough to accommodate 2 foot set back for the spoil pile. If not, materials

must be obtained to provide an alternate retaining device.

• In some cases contractor may need to haul spoils to a temporary site until excavation is ready to back fill.

SELECTED CASE HISTORIES:

A spoil pile had been placed on top of a curb which formed the west face of a trench. A backhoe was spotted on top of the spoil pile. The

west face of the trench collapsed on two employees who were installing sewer pipe. One employee was killed; the other received back

injuries. The trench was 8 feet deep with vertical walls. No other protection was provided. In fact, the superimposed loads of the spoil pile

and backhoe may have initiated the collapse.

COMMENTS:

1. Many excavations/trenches dug for utility line are located in narrow right-of-ways. Often spoil piles are placed at the edge with no

retaining device. This situation can be avoided with a sound pre-job survey and plan.

2. The fatality rate for trenching/excavation work was 112% higher than the rate for construction in general [14].

3. This standard was cited in 37 fatality inspections since it became effective in March 1990.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 651(j); [14]; [20]; GUIDE FOR THE DAILY INSPECTION OF TRENCHES AND EXCAVATIONS (See pg.53)

62
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

!VIOLATION "IN-COMPLIANCE

Proper spoil pile set back (above & right).

Arrows show spoil piles.

" VIOLATION ! IN-COMPLIANCE

Two employees along pipe are exposed to the spoil pile

(arrow) which is located on the edge of the trench.

NOTE: Sloping does not meet OSHA requirements.

" VIOLATION ! IN-COMPLIANCE

Employee at end of pipe is exposed to the spoil

pile at the edge of the trench.

63
RANK IN FREQUENCY CITED

#17

1926.

350(a)(9) SECURING OF COMPRESSED

GAS CYLINDERS

RULE: Compressed gas cylinders shall be secured in an upright position at all times except, if necessary, for

 short periods of time while cylinders are actually being hoisted or carried.

INTENT:

This standard specifiesy the following: l) gas cylinders must be secured to prevent them from falling against people equipment and other

cylinders; if a cylinder strikes a person it can cause an impact type injury, if it strikes nearby equipment the consequences will vary

depending on the type of equipment if the first cylinder strikes other unsecured cylinders a domino effect may occur; an unsecured

cylinder with its valve protection cap off could fall and strike the valve, rupturing it, causing the compressed gas cylinder to take-off like a

rocket; and 2) the cylinders must be stored upright since adverse effects can result if cylinders containing some welding gases are

stored/used in a horizontal position. This standard exempts hoisting or carrying cylinders that are only intended to be moved during short

periods of time.

HAZARDS:

• Struck by facing or rocketing cylinders. injuries can range from death to contusions.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Supervisors should note all cylinders in their work area and identify if they are in use or storage. If they are in storage, are they upright,

secured and labeled? Is the valve protection cap in place? Are incompatible materials (oxygen and fuel gas) separated properly? If the

cylinders are in use, are all appropriate safeguards in place to protect the welder and other personnel in the area?

SELECTED CASE HISTORIES:

OSHA IMIS did not maintain any fatal/catastrophe inspections citing conditions related to this standard as a direct/indirect cause(s) of an

accident.

COMMENTS:

1. Welding cylinders placed in welding carts are considered to be secured.

2. Unsecured cylinders on construction sites are common. This is a specification standard which is easily identified and substantiated as a

violation as evident of its high ranking on the 100 Most Cited Physical Li.st . Therefore, the contractor must continually audit the site to

ensure compliance.

3. This standard was cited in 29 OSHA fatality inspections in 5 years.

ADDITIONAL DOCUMENTS TO AIDIN COMPLIANCE:

[1] Section 350; [22]; [23]*; [24]

*- Referenced in 29 CFR 1926 - Construction Standards

OSHA INSTRUCTION STD 3-8.2

Dated 3/11/81 - Synopsis - Clarifies that the standard does not apply to welding gas supply manufacturers or distributors prior to delivery

at construction sites. The intent of the standard is for it to apply to welding or cutting operations on construction sites.

64
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

!VIOLATION "IN-COMPLIANCE

The cylinders (above & right) are secured properly

in an upright position. NOTE: Cylinders are not

required to be secured to a cart as shown above.

This method is only a recommendation.

" VIOLATION ! IN-COMPLIANCE

The cylinders are not secured (left) and are not

secured in an upright position (above).

NOTE: Improper storage of oxygen and fuel gas

cylinders in photo on left.

65
RANK IN FREQUENCY CITED

#18

1926.

350(j) ADDITIONAL RULES FOR

WELDING/CUTTING AS PER

ANSI Z49.1 - 1967

RULE: Additional rules. For additional detail not covered in this subpart, applicable technical portions of American

National Standards Institute, Z49.1 – 1967, Safety In Welding and Cutting, shall apply.

INTENT:

This ANSI standard was incorporated by reference into the original OSHA construction standards and remains today. Its intent is to

supplement the safety, requirement for gas welding. Additional requirements cover the following: 1) installation and operation of

oxygen-fuel gas systems for welding and cutting; 2) fire prevention and protection; 3) protection of personnel; 4) health protection and

ventilation; and 5) industrial applications. Construction industry applications are further subdivided by operation, those operations include:

A) general; B) general maintenance welding and cutting operations; C) earth moving and grading equipment; D) fire protection and

prevention; E) demolition; F) concrete construction and masonry; G) tunnels, shafts and caissons; H) marine piling and marine construction;

I) batch plant and road paving; J) steel erection; K) transmission pipeline; and L) mechanical piping systems.

HARZARDS:

• Fire/explosion. Probable injuries range from death to minor burns.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• A pre-job survey to identify all potential hazards and affected areas around the operation is critical.

• All fire prevention and protection rules absolutely must be followed.

SELECTED CASE HISTORIES:

• A welder was cutting braces on a catwalk of a conveyor when the catwalk collapsed falling approximately 30' to the ground killing the

welder.

• Three employees were cutting (burning) a catwalk from the top of a 20,000 gallon ethanol storage tank which had been drained of liquid

but the vapors were not purged. Vapors emanating from a gage hatch which was not sealed were ignited and the tank exploded. The three

employees were fatally injured. The area (not designed for cutting purposes) was not properly inspected and authorized prior to the start of

the operation.

COMMENTS:

1. The most common standard cited from ANSI 249.1-1967 is 3.2.4.3, which specifies a 20 foot minimum spacing or 1⁄2 hour minimum fire

rated wall 5 feet high separating oxygen cylinders from fuel gas cylinders in storage. Other commonly cited standards include: using

acetylene at a pressure greater than 15 psig (3.1.2) and failure to inspect and authorize an operation when welding or cutting must be done in

a location not designed for such purposes (6.2.5).

2. This rule only applies to gas welding. It does not apply to arc welding, resistance welding or other non-gas welding procedures

ADDTTIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Subpart J; [24]; [281*

*- Referenced in 29 CFR 1926- Construction Standards

66
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

Oxygen and fuel gas cylinders stored together

without proper separation or barriers.

NOTE: The missing valve protection cap on the

front of the cylinder bottle.

"VIOLATION !IN-COMPLIANCE

Oxygen cylinders in storage separated from fuel

gas cylinders by a 5’ tall properly constructed and

rated fire wall (arrow).

67
RANK IN FREQUENCY CITED

#19

1926.

102(a)(1) EYE/FACE PROTECTION FOR

OPERATIONS WHICH CREATE

EXPOSURE

RULE: Employees shall be provided with eye and face protection equipment when machines or operations

present potential eye or face injury from physical, chemical, or radiation agents.

INTENT:

There were about 22,000 lost-time accidents in the construction industry in 10 states from 1985-1989 due to eye injuries [6]

. Metal items

(34.5%) and wood items (10.7%) were the most frequent sources of eye injuries. The purpose of the standard is obvious - to reduce the

number of eye injuries. The rule requires employers to provide eye/face protection when there are potential hazards to the eye/face

related to physical, chemical, or radiation agents. The key word is potential. On very few construction sites would potential for falling,

flying, moving, etc. objects not be present. Sometimes pieces of debris break off, spring, eject, etc. from objects which are usually intact.

Once airborne, potential exist to cause an eye/face injury (example - prying on a wooden box, when a splinter breaks due to the force

(energy) of the prying operation, the splinter might be thrown in the direction of the employees face). Although these types of events are

not normal, they can and should be expected because of the nature of construction work. Therefore, protection must be provided. Other

standards in this Part include 1926.102(a)(2) which specifies that eye/face PPE will meet requirements of ANSI Z87.1-1968, UT [15] and

1926.102(a)(5), which specifies that Table E-1 [I] shall be used as guidance for selecting appropriate protection for listed operations. This

is a very useful and user friendly table. All spectacle type glasses listed in TABLE E-1 require sideshields. A footnote in the table states

spectacles without sideshields are available when only frontal exposure is possible. Most construction operations would require

sideshields.

HAZARDS:

• Struck by flying objects, particles, and chemicals. Probable eye injuries can range from blindness to minor irritation caused by foreign

matter in the eye. Probable injuries to the face range from chemical burns caused by splashes to lacerations caused by flying objects.

• Radiant energy exposure from welding and laser operations. Probable injuries range from blindness to temporary eye irritation.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Instruct fast-line supervisors to continually audit employees to insure eye/face protection is worn.

• Institute a formal discipline program in workplaces where a problem exist relating to employees not wearing PPE when required.

• Make the wearing of PPE in accordance with company rules a specific condition of employment. This has proven to be an effective

tool for safety managers (Conversations with safety managers).

SELECTED CASE HISTORIES:

IMIS data did not show violations of this standard contributing to the direct cause of a fatality/catastrophe. However, numerous severe

lost-time injuries are related.

COMMENTS:

1. This rule requires employers to actually provide the eye/face protection to the employees.

2. This standard was cited in 17 fatality inspections conducted by OSHA in five years.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 102, TABLES E-1, E-2 & E-3; [15]*; [25]

*- Referenced in 29 CFR 1926- Construction Standards

68
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

Employee is wearing the proper goggles while cutting steel for stairway.

69

"VIOLATION !IN-COMPLIANCE

Types of eye and face protection that are required depending on the

operation.
RANK IN FREQUENCY CITED

#20

1926.

500(b)(1) GUARDING OF FLOOR

OPENINGS

RULE: Floor openings shall be guarded by a standard railing and toeboards or cover, as specified in paragraph

(f) of this section. In general, the railing shall be provided on all exposed sides, except at entrances to stairways.

INTENT:

OSHA defines a floor opening as "An opening measuring 12 inches or more in its least dimension in any floor, roof, or platform through

which persons may fall.” This rule is to specifies that holes will be protected with guardrails and toeboards or covers. It also specifies the

requirements of construction for the guardrails, toeboards and covers (1926.500(f)). An exemption is given guarding the exposed side of

an entrance to a stairway. Table 5.2-1 and Table 5.2-2 give details for constructing standard guardrails and toeboards. Floor hole

coverings must meet the construction specifications listed in 1926.500(f) (5). Regular floor hole covers must be capable of supporting

the maximum intended load and must be installed to prevent accidental displacement and covers and their supports when located in

roadways and vehicle aisleways for conduits, and manholes must be designed to carry a rear axle load of two times the maximum

intended load.

HAZARDS:

• Fall from elevation. Probable injuries range from death to sprains/strains.

• Struck by falling objects through floor hole. Probable Injuries range from death to head concussion.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• For new construction identify floor holes as they are created and take immediate action.

• For existing structures, survey the site prior to starting work and continue audit as renovation, repair, etc. proceeds for floor opening and

holes.

• Insure all covers are constructed properly and will support the maximum intended load.

SELECTED CASE HISTORIES:

• An employee fell 16 feet to his death through an improperly guarded roof opening 36”x30” while attempting to stay clear of an

overhead crane load. The improper guarding system consisted of four 2”x4” posts supported using only one nail per post and high

visibility barrier tape strung between the posts.

• An employee fell through an uncovered 36” diameter hole in the top of a slurry tank and fell 32 feet to his death.

COMMENTS:

1. Many deaths occur each year when floor hole covers were removed and were not replaced or when they were constructed of materials

that could not support the person/equipment load. (OSHA 1st Report of Death or Serious Injuries).

2. Toeboards are required to prevent materials from falling through the opening and striking persons below.

3. A floor hole is an opening measuring less than 12” but more than 1” in its least dimension. Floor hole protection is intended to prevent

materials from falling to the level(s) below.

4. This standard was cited in 67 OSHA fatality cases in 5 years.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] sections 500(b) & (f); [19]

OSHA CLARIFICATION LETTER

Date 8/31/89; From Director of Construction Compliance Programs to Regional Administrator; Synopsis - A floor hole 60’ x 40’ x 12”

deep in the middle of a large finished floor is not a floor opening or hole under this standard. Additionally, a uniform enforcement policy

on floor openings is not possible because of the many variables that exist, i.e. the depth of the hole, workers exposure, etc.; therefore, each

particular situation must be evaluated by the CSHO to determine if a hazard exists.

70 
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

!VIOLATION "IN-COMPLIANCE

Employee is wearing the proper goggles while cutting steel for

stairway.

71

!VIOLATION "IN-COMPLIANCE

Properly erected standard guardrail system for

floor opening.

" VIOLATION ! IN-COMPLIANCE

Unguarded floor opening (arrow) which exposes workers

to a 9’ fall into basement.
RANK IN FREQUENCY CITED

#21

1926.

1053(b)(1) LADDER EXTENDED 3’

ABOVE LANDINGS

RULE: When portable ladders are used for access to an upper landing surface, the ladder side rails

shall extend at least 3 feet (.9 m) above the landing surface to which the ladder is used to gain access; or, when

such an extension is not possible because of the ladder’s length, then the ladder shall be secured at its top to a

rigid support that will not deflect, and a grasping device, such as a grabrail, shall be provided to assist

employees in mounting and dismounting the ladder. In no case shall the extension be such that ladder defection

under a load would, by itself, cause the ladder to slip off its support.

INTENT:

The purpose of this rule is to provide protection for employees during two critical phases of ladder climbing: 1) when employees are

on the ladder and their movement may cause forces to be transferred to the ladder and it's support points which night tend to make it

slip or fall; and 2) when the employee is either getting on or off the ladder - if nothing is available to grab and provide support the

employee will be in a bent over position and his/her center of gravity may be outside the vertical line of normal body position in an

attempt to correct this and straighten up and get onto the ladder the employee is vulnerable to a fall. The rule specifies: 1) that the side

rails must extend three feet above the landing; 2) side rails must be secured at the top to a rigid support when the 3 foot extension is

not provided (this can be done by tieing with rope boxing in with lumber, etc.); 3) a grab device must be provided when the ladder's

side rails do not extend 3 feet above the landing (the grasping device can be constructed of materials such as metal, lumber, etc., it can

be a part of the structure providing it's location does not create a hazard in itself and it's easy grasped); and 4) when employees are on

the ladder its deflection cannot cause it to slip off its support; therefore, when selecting/spotting a ladder, consider the amount it will

deflect during use to assure that the proper length is used.

HAZARDS:

Fall from elevation. Probable injuries range from death to sprain/strains.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Abatement is obvious - construct/use ladders according to specification requirement.

• Instruct first-line supervisors to inspect ladders during each shift in their work area.

SELECTED CASE HISTORIES:

An employee was climbing a 10 foot ladder to access a landing which was 9 feet above the adjacent floor. The ladder slid down and

the employee fell to the floor, sustaining fatal injuries. Although the ladder had slip-resistant feet, it was not secured, and the railings

did not extend 3 feet above the landing.

COMMENTS:

1. This standard covers only portable ladders. A similar requirement for fixed ladders is 1926.1053(a)(24).

2. This is a specification standard which is easily identified and substantiated as a violation as evident by it's high ranking on the 100

Most Cited Physical List. . Therefore, the contractor must continually audit the site to remain in compliance with this item.

3. The standard was cited in 6 fatality/catastrophe inspections since January, 1991.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE: 

[1] Subpart X; [18]

72 
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

73

!VIOLATION "IN-COMPLIANCE

The portable ladder extends 3’ above the opening

(landing) of the confined space.

NOTE: The guarding of the floor hole except at the

entrance for the ladder is acceptable.

!VIOLATION "IN-COMPLIANCE

The job made ladder is secured (arrow) and extended 3’

above the landing.

NOTE: The exposure to the open-sided floor when

employees are on the landing would be a violation of

1926.500(d)(1)

" VIOLATION ! IN-COMPLIANCE

The job made ladder does not extend at least 3’ above

landing, nor is it secured against tipping.
RANK IN FREQUENCY CITED

#22

1926.

651(c)(2) EGRESS FROM

TRENCH/EXCAVATION

RULE: Means of egress from trench excavations. A stairway, ladder, ramp or other safe means of

egress shall be located in trench excavations that are 4 feet (1.22 m) or more in depth so as to require no

more than 25 feet (7.62 m) of lateral travel for employee.

INTENT:

When conditions begin to deteriorate in a trench, such as soil beginning to slug off the face of the trench, the risk of a

cave-in increases and emergency egress may be required. This standard requires a means of egress. The intent of the rule is

to specify the following: 1) maximum lateral distances an employee can travel (25 feet) to egress a trench; 2) maximum

depth of the trench (4 feet) when egress must be provided; and 3) means in which egress from the trench can be

accomplished, i.e. stairway, ladder, ramp, or other safe means. Note: It is not intended that this rule apply to large

excavations ([14], pg. 45918). However, a safe means of access/egress from large excavations must be provided as per 29

CFR 1926.1051(a). That standard requires a stairway or ladder be provided at personnel points of access where there is a

break in elevation of 19 inches or more, and no ramp runway, sloped embankment or personnel hoist is provided.

HAZARDS:

• Cave-in. Probable injury is death.

• Hazardous atmospheres caused by broken utility lines, toxic materials entrained in soil, etc. Large range of injuries from

death due to inhalation of toxic material to first aid.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Provide properly constructed /maintained means of egress at predetermined points.

SELECTED CASE HISTORIES:

• Two employees were in a 12 foot deep trench laying pipe when one of the employees saw the bottom face of the trench

move and jumped out of the way along the length of the trench as the wall caved-in fatally injuring the other employee. The

walls of the trench were vertical and no means of emergency egress was provided.

• Two employees laying sewer pipe were in a 15 foot deep trench, which was not shored or sloped properly. The employees

had to egress the trench by climbing the backfill. While exiting the trench the first worker was trapped by a small cave-in.

The second employee tried to extricate him but a second cave-in occurred trapping the second employee at the waist. The

second cave-in actually caused the death of the first employee; the second employee sustained a hip injury.

COMMENTS:

1. Only one means of egress is required in the middle of a trench 50’ long to meet the requirements of this standard.

2. Earthen ramps may be used as a suitable means of egress only if employees can walk the ramp in an upright position

when entering and exiting. The earthen ramp must be evaluated as acceptable by the competent person.

3. This standard was cited in 24 fatality inspections conducted by OSHA since January 1991.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Subpart P; [14]; [20]

74
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

75

! VIOLATION " IN-COMPLIANCE

No means of egress provided. Employee is riding

backhoe bucket out of trench.

"VIOLATION !IN-COMPLIANCE

Required for trench/excavations > 4 feet deep.
RANK IN FREQUENCY CITED

#23

1926.

403(b)(2)

LISTED, LABELED OR

CERTIFIED EQUIPMENT USED

IN MANNER PRESCRIBED

RULE: Listed, labeled, or certified equipment shall be installed and used in accordance with instructions

included in the listing, labeling, or certification.

INTENT:

At times electrical equipment is installed or used in a manner for which it was not designed. This is one of the electrical standards

which a used as a "catch all" for hazardous situations which are not covered by specific electrical standards. While the application of

this standard may be broad, the intent is to ensure that all electrical equipment is used/installed as designed. The most common

specific application of this standard as used by OSHA in construction is to address the situation when a multiple-receptacle box

designed to be mounted is fitted with a power cord and placed on the floor to provide power for various tools. This would not be a

prescribed use for the receptacle box. OSHA also cites this standard for the use of ROMEX® wire for making up extension cords;

using equipment outdoors which is only listed and labeled for in indoor dry locations (this can even apply to double insulated tools

which are listed and labeled for dry indoor locations only); short two-prong adapter plugs with pig tail equipment grounding

connections to facilitate the attachment of cords and tools to electrical systems; and the use of the wrong size circuit breakers or fuses

for overcurrent protection. The situations listed above would not be in accordance with the equipment's prescribed use.

HAZARDS:

• Electrical shock. Probable injuries can vary from death to minor burns.

• Fire. Probable injuries can vary from third degree to minor burns.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Since most violations rated to this standard are the result of original equipment being shop fabricated, altered, modified, etc.

instruct first-line supervisors to watch for such equipment and determine if it is in compliance with OSHA/NEC. If not, take

equipment out of service immediately.

SELECTED CASE HISTORIES:

An employee was texturing a wall using an air compressor. The plug of the compressor and an extension cord had been modified to

fit a wall outlet for a common household dryer (220 V). While attempting to unplug the compressor from the extension cord, the

employee was fatally shocked. The modification to the plugs was not an intended use or prescribed by the manufacturer.

COMMENTS:

1. The shop-fabricated multi-receptacle box laying on the floor is quite common in the industry. After, OSHA CSHO’s become

familiar with this problem it becomes as easy a violation to identify and substantiate as many of the specification standards.

2. If an installation is made in accord with the 1984 National Electric Code, it will be considered to be in compliance with Section

1926.403 thru 1926.408, except 1926.404(b)(1), 1926.405(a)(2)(ii)(E), 1926.405(a)(2)(ii)(F), 1926.405(a)(2)(ii)(G), &

1926.405(a)(2)(ii)(J).

3. This standard was cited in seven fatality inspections conducted by OSHA in 5 years.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Subpart K; [2]; [3]

76
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

NM cable is being run across a field (above) to provide power to an outlet laying on ground (blow-up).

It is being utilized as an extension cord. The use of the NM cable and outlet in this manner is not a

prescribed use. NOTE: The NM cable is run on ground is not protected from damage (this particular

cable was run across a subdivision street). When NM cable is used on a construction site it must be

used in a manner prescribed such as wiring for feeders, branch lines and temporary lighting.

Additionally, it must be installed properly and must be protected from physical damage.

77

! VIOLATION

" IN-COMPLIANCE

! VIOLATION " IN-COMPLIANCE

Multi-receptacle outlet box on the floor

providing power to 3 extension cords. The

supply power to the outlet box is provided by

non-metallic sheath (NM) cable (arrow).

The manner in which the outlet box and NM

cable is used is not a prescribed use.
RANK IN FREQUENCY CITED

#24

1926.

405(a)(2)(ii)(j)

FLEXIBLE CORDS

DESIGNATED FOR HARD OR

EXTRA HARD USAGE

RULE: Extension cord sets used with portable electric tools and appliances shall be three-wire type and shall

be designed for hard or extra-hard usage. Flexible cords used with temporary and portable lights shall be

designed for hard or extra hard usage.

INTENT:

Extension cords when exposed to even “normal” construction use can experience rapid deterioration. When this happens, conductors

with energized bare wires can be exposed. Conductors can break or come loose from their terminal screws, specifically the

equipment grounding conductor. If that should occur the equipment grounding for the tool in use is lost. Since deterioration occurs

more rapidly in cords which are not rugged enough for construction conditions, the National Electric Code [5] and OSHA have

specified the types of cords to use in a construction environment. This rule designates the types of cords that must be used for

various applications including portable tools, appliances, temporary and portable lights. The cords are designated HARD and

EXTRA HARD SERVICE. Examples of HARD SERVICEdesignation types include S, ST, SO, STO, SJ, SJO, SJT & S.JTO

Extension cords must be durably marked as per 1926.405(g)(2)(ii) with one of the HARD or EXTRA HARD SERVICE designation

letters, size and number of conductors.

HAZARDS:

Electrical shock. Probable injuries rrange from death to minor burns.

(AMONG OTHER) SUGGESTED ABATEMENTS:

Continually audit cords on-site. Any cords found not to be HARD or EXTRA HARD SERVICE must be taken out of service

immediately.

SELECTED CASE HISTORIES:

An employee received a fatal shock when he was cutting drywall with a metal casing router. The router’s 3-wire power cord had

been spliced to a 2-wire cord and plug. A fault occurred and with no grounding and the absence of GFCI protection, the employee

was electrocuted. The cord was not a 3-wire HARD SERVICE variety.

COMMENTS:

1. The durable marking required to be on the cord can be found as an indelible marking by the manufacturer approximately every

foot along the length of the cord.

2. Because the use of extension cords is so numerous at construction sites and this is a specification standard, the number of related

violations is quite high. For the OSHA CSHO this situation is relatively easy to identify and substantiate as a violation.

3. Because of the constant movement of contractors and equipment, specifically extension cords, on/off-site and the fact that

sometimes several contractors draw power utilizing the same extension cord, identifying improper service cords may be difficult.

4. This standard was cited in 20 fatality inspections in last 5 years.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Sections 405(b) & (g); [2], [3]

OSHA CLARIFICATION LETTER

Date 3/3/92;From Director of Compliance Programs to Director of Office of Construction and Engineering; Synopsis – Contractor

shop-made extension cords are acceptable if they meet the following criteria; 1) all individual components of the cord set must be

approved by a nationally recognized testing laboratory; 2) the cord sets must meet all applicable requirements such as strain relief,

correct polarity of conductors, proper marking, etc.; 3) cords must be assembled by a qualified person; and 4) the cord set must be

checked prior to its first use, for example, the following tests should be performed a) all equipment grounding conductors shall be

tested for continuity and shall be electrically continuous and b) each receptacle and attachment plug must be tested to insure proper

connection of the equipment grounding conductor to its appropriate terminal.

78
PHOTOGRAPHS, ILLUSTRATIONS and OTHER DOCUMENTS

! VIOLATION " IN-COMPLIANCE

Hard service cord TYPE SO (arrow).

NOTE: The strain relief devices for

ends of the attachment plugs.

" VIOLATION ! IN-COMPLIANCE

2 wire ribbon type cord is not designed for HARD

USAGE.

NOTE: The 2 wire cord does not provide

equipment grounding. Additionally, there are

exposed terminal screws and conductors on the end

of the cord which create a shock hazard.

33
RANK IN FREQUENCY CITED

#25

1926.

405(g)(2)(iv) STRAIN RELIEF FOR CORDS

RULE: Flexible cords shall be connected to devices and fittings so that strain relief is provided which will prevent pull

from being directly transmitted to joints or terminal screws.

INTENT:

The deterioration of electrical cords on construction sites is a common occurrence. If a cord deteriorates to a point where conductors have effectively

worn through their insulation or equipment grounding conductors are no longer attached to their terminal screws, an electric shock hazard is created.

Many times deterioration of the cord is due to the strain, both normal and abnormal, it experiences on the site. One of the weak points of a cord

assembly is the area in which attachments are made (plug cap and connector body). When devices or fittings designed to relieve cord strain are not

used, insulation will tend to pull back and expose conductors or the conductors will loosen from their terminal screws. Therefore, this standard

requires hardware to prevent tension from being transmitted to joints and terminal screws. Manufactured molded plug caps and associated

connections usually do not pose this problem under normal use. However, site-fabricated cords or cords that have been repaired in the field

frequently do not have sufficient strain relief. Loose wires in a plug cap caused by improper connection or tension due to no strain relief can cause

conductors to make contact where not intended causing short-circuit, fires, arching type explosion, etc.

HAZARDS:

Electrocution and fire. Probable injuries can range from death to first degree burns.

(AMONG OTHER) SUGGESTED ABATEMENTS:

• Use approved cords for HARD or EXTRA HARD USAGE (Designated S, ST, SO, STO, SJ, SJO, SJT or SJTO).

• Use only cords which are equipped or designed with strain relief.

• Use factory-assembled cord sets as much as possible.

• Reinforce the simple work practice that everyone learned when they were children -remove cords from receptacles by pulling on the plugs, not the

cords.

SELECTED CASE HISTORIES:

An employee operating a 3/4" electric chisel was electrocuted. An electrical fault occurred in the casing of the tool. An inspection revealed that the

original power cord had been replaced with a flat cord (not designed for HARD service), the ground prong was missing and strain relief was not

provided for the cord at the point it entered the tool. Additionally, no GFCI protection was provided.

COMMENTS:

1. There is no prohibition against fixing a cord or reattaching it to a plug. However, care must be taken to assure the original electrical and mechanical

integrity of the cord is maintained.

2. Splices to flexible cords and cables are prohibited under 1926.405(g)(2)(iii) if their service rating is less than Hard Service No. 12. If the service

rating is greater than No. 12 splices may be made provided they meet other mechanical requirements.

3. This standard was cited in 20 fatality inspections conducted in five years.

ADDITIONAL DOCUMENTS TO AID IN COMPLIANCE:

[1] Section 405; [2]; [3]; [21] Fact Sheet #5; Pull at Joints & Terminals Must Be Prevented

80

5.2 CONSTRUCTION SPECIFICATIONS FOR GUARDRAILS AND 

 TOEBOARDS 

The following section presents construction specifications for guardrails and toeboards.

These specifications relate to GUIDE Sheets #1, #6, # 12, # 15 and #20 listed above in

Section 5.1. These tables compile the requirements for "standard guardrails and toeboards

or their equivalent". Table 5.2-1 lists construction specifications for guardrails and Table

5.2-2 lists construction specifications for toeboards.

TABLE 5.2-1

MINIMUM SPECIFICATIONS FOR GUARDRAIL SYSTEMS

TYPE OF

MATERIAL

SIZE OF

TOP/MID RAIL[IN]

HEIGHT [IN]

TOP RAIL(1)

POST

SIZE/SPACING(2)

STRENGTH(3)

[LBS.]

WOOD 2x4/1x6 42 2”x4”/8’ 200

PIPE 1-1⁄2 nominal OD 42 1-1⁄2 nom./8’ 200

STEEL 2x2x3/8 angle 42 2”x2”x3/8” angle/8’ 200 or equiv.

bend. strength

WIRE ROPE 3/8(4) 42 equivalent to one of

above

200

OTHER

EQUIVALENT

equivalent to one of

above

42 equivalent to one of

above

200

(1) Acceptable heights range from 39" to 45" (42"± 3"). Mid rail height should be about 1⁄2 height of top rail.

(2) Spacing is horizontal distance measured center post to center post

(3) Railing must have minimum deflection in any direction 200 1b. force is applied. Minimum deflection is not defined

although 3" of deflection for wire rope after force is applied is a guideline. Strength criteria also applies to all structural

members of system including post anchorages

(4) There is no present OSHA National Office guidance at this time for size of wire rope guard rails. 3/8" is a recommended

size, however, any wire rope size 1⁄4" or larger (as per NPRM for Subpart M) would be acceptable. OSHA requires a 1⁄2" wire

rope or equivalent for periphery of floors during steel erection.

Note - Lumber sizes listed above can be nominal size.

82
TABLE 5.2-2

MINIMUM SPECIFICATIONS FOR TOEBOARDS

HEIGHT OF PROTECTION(1) MATERIAL CONSTRUCTION SIZE

Standard Toeboard Does

Provide Protection Substantial

1) Solid

2) Opening < 1”

3) 1⁄4 “ max. clear.

 from floor

4” min.

(vertical dimension)

Standard Toeboard Does Not

Provide Protection Substantial Paneling or Screening Floor to Mid or Top Rail

(1) The size of the material containment, i.e. toeboard is dictated by the size of the material or the way it is piled. A standard

toeboard may not be sufficient to contain items near the edge of an open-sided floor/platform. In that case the height of the

containment must be increased accordingly.

83
5.3 REFERENCES 

1. 29 CFR 1926/1910: Construction Industrv - OSHA Safety and Health Standards: OSHA 2207; Revised 1991;

U.S. Department of Labor, Occupational Safety and Health Administration, Washington, DC.

2. Electrical Standards for Construction: OSHA 3097; 1989 (Revised); U.S. Department of Labor, Occupational

Safety and Health Administration, Washington, DC.

3. An Illustrated Guide to Electrical Safety: OSHA 3073; 1983 (Revised); U.S. Department of Labor,

Occupational Safety and Health Administration, Washington, DC.

4. Ground Fault Protection on Construction Sites: OSHA 3007; 1990 (Reprint); U.S. Department of Labor,

Occupational Safety and Health Administration, Washington. DC

5. ANSI/NFPA 70-1990: National Electrical Code; 1990; National Fire Protection Association, Batterymarch

Park, Quincey, MA.

6. Construction Accidents: The Workers' Compensation Data Base 1985-1988; April 1992, U.S. Department of

Labor, Occupational Safety and Health Administration, Office of Construction and Engineering, Washington,

DC.

7. ANSI 289.1-1969; Safety Requirements for Industrial Head Protection 1969; American National Standards

Institute, New York, NY.

8. ANSI Z89.2-1 971; Safety Requirements for industrial Protective Helmets for Electrical Workers; 1971;

American National Standards Institute, New York, NY.

9. Personnel Protective Equipment: OSHA 3151; U.S. Department of Labor. Occupational Safety

and Health Administration, Washington, DC.

10. Analysis of Construction Fatalities -The OSHA Data Base 19854982; Nov. 1990; U.S. Department of Labor,

Occupational Safety and Health Administration, Office of Construction and Engineering, Washington, DC.

11. Safety Standards for Fall Protection in the Construction Industry; Notice of Proposed Rulemaking; Part III;

Federal Register; Nov. 25, 1986; U.S. Department of Labor, Occupational Safety and Health Administration,

Washington, DC.

12. ANSI 910.14-1 975. Requirements for Safety Belts. Harnesses, Lanyards, Lifelines, and Droplines for

Construction and Industrial Use.1971; American National Standards Institute, New York, NY.

13. ANSI-A10.11-1979; Standard for Safety Nets Used During Construction, Repair and Demolition 1979;

American National Standards Institute, New York, NY.

14. 29 CFR Part 1926 Occupational Safety and Health Standards-Excavations: Final Rule: Part II; October 31,

1989; U.S. Department of Labor, Occupational Safety and Health Administration, Washington, DC.

15. ANSI 287.1-1968. Practice for Occupational and Educational Eve and Face Protection, 1968, American

National Standard's Institute, New York, NY.

16. 29 CFR 1910.134; Respiratory Protection, U.S. Department of Labor, Occupational Safety and Health

Administration, Washington, DC.

84
17. ANSI A10.8-1988; Scaffold Safety, 1988, American National Standards Institute, New York, NY.

18. 29 CFR 1926 Safety Standards for Stairways and Ladders Used in Construction Industry; Final Rule; Part III,

Nov. 14, 1990, U.S. Department of Labor, Occupational Safety and Health Administration, Washington, DC.

19. ANSI A10.18-1983 Construction and Demolition Operations: Temporary Floor and Wall Openings, Flat

Roofs, Stairs, Railings, and Toeboards – Safety Requirements, 1983, American National Standards Institute,

New York, NY.

20. Excavations; OSHA 2226; (Revised 1991), U.S. Department of Labor, Occupational Safety and Health

Administration, Washington, DC.

21. OSHA Electrical Hazard Fact Sheets, Revised Nov. 1983; William Watkins, PE for U.S. Department of Labor,

Occupational Safety and Health Administration, OSHA Training Institute, Des Plaines, IL

22. Selected Occupational Fatalities Related to Welding and Cutting as Found in Reports of OSHA

Fatality/Catastrophe Investigations; August 1988, W. Cole, U.S. Department of Labor, Occupational Safety

and Health Administration, Directorate of Policy, Washington DC.

23. ANSI Z49.1-1967 Safety in Welding and Cutting, American National Standards Institute, New York, NY.

24. NGPA 51 – 1992 Standard for the Design and Installation of Oxygen – Fuel Gas Systems for Welding, Cutting

and Allied Operations, 1992, National Fire Protection Association, Quincy, MA

25. Personnel Protective Equipment; OSHA 3151; U.S. Department of Labor, Occupational Safety and Health

Administration, Washington, DC.

26. Concrete and Masonry Construction; Final Rule, June 16, 1988; U.S. Department of Labor, Occupational

Safety and Health Administration, Washington, DC.

27. ANSI A10.9 – 1983 Concrete and Masonry Work – Safety Requirements; (Supplement A10.9A – April 1989);

1983; American National Standards Institute, New York, NY.

28. ANSI Z49.1 – 1967 Safety and Welding and Cutting; American National Standards Institute, New York, NY.

29. Employers Safety and Health Program; Appendix A; OSHA Instruction STD 3-1.1: June 22, 1987; Office of

Construction and Maritime Compliance Assistance; U.S. Department of Labor, Occupational Safety and

Health Administration, Washington, DC.

30. Excavation Safety: Excavation, Trenching and Soil Mechanics; Appendix A: J.L. Mickle, PhD., PE (G.

Bradberry author of Appendix A), for the U.S. Department of Labor, Occupational Safety and Health

Administration, OSHA Training Institute, Des Plaines, IL

31. National Electrical Code Diagrams; William Watkins, PE for U.S. Department of Labor, Occupational Safety

and Health Administration, OSHA Training Institute, Des Plaines, IL

85