OSEA Safety Blog

OSHA is proposing 12 changes to their construction standards. The changes are intended to improve safety by modernized outdated references and clarifying language to make it easier for employers to understand compliance requirements. These changes are part of OSHA’s Standards Improvement Project. This will be the fourth set of changes proposed. Previous changes under the Standards Improvement Project were made in 1998, 2005 and 2011.

1. Reporting Job-Related Hearing Loss Occupational Injuries and Illnesses Recording and Reporting Standards (29 CFR Part 1904)

1904.10 – Recording criteria for cases involving occupational hearing loss.

The revisions would clarify the criteria for determining whether a hearing loss was work-related or not. Hearing loss should be considered work related if any event or exposure caused or contributed in any way, big or small, to the loss of hearing or aggravated a preexisting hearing loss. Employers are required to keep records if hearing loss is work-related.

Remember, OSHA requires employers to provide ear protection and ensure their use to workers when the noise levels or duration of exposure can’t feasibly be reduced below permissible levels. How do you know if your project has hazardous noise. Noise dosimetry is an excellent tool, not only for prescribing hearting protective devices, but as a defense against workers compensation claims.

2. X-Ray Storage

Subpart Z – Toxic and Hazardous Substances

1926.1101 – Asbestos

1926.1127 – Cadmium

Many medical facilities are increasingly converting from film-based X-ray equipment to digital X-ray equipment. OSHA is proposing that the option to allow digital storage of X-rays lieu of film prints in the medical surveillance provisions for asbestos and cadmium in construction.

3. 911 Emergency Services at Worksites

1926 Subpart D – Occupational Health and Environmental Controls

1926.50 – Medical services and first aid.

These requirements were written back in 1979 before 911 services were widely available. Employers are required to prominently post telephone numbers for ambulances, doctors and hospitals at worksites in areas where 911 emergency dispatch services were not available.

With Enhanced 911 dispatchers are automatically provided the caller’s location information. The conversion to E911 hasn’t been completely phased in by all wireless carriers in some of the more remote areas of the country. In areas where automatic location capabilities aren’t available, employers are required to post latitude and longitude coordinates of the worksite or other location information.

OSHA understands that cell phones are the primary means of communication on construction sites. If employers are using cell phones as the communication system for ambulance services, they must ensure that they work effectively at the worksite. If 911 is not available at a worksite, employers must still post the phone numbers currently required.

4. Permissible Exposure Limits (PELs)

1926 Subpart D – Occupational Health and Environmental Controls

1926.55 – Gases, vapors, fumes, dusts and mists.

The proposed changes seek to clarify some of the language in the standard. OSHA wants to make it clear that it is mandatory that an employee’s exposure not exceed the exposure limit for a given substance. Other changes proposed will clean up some of the language of the standard like changing all references of “threshold limit values” to “permissible exposure limits.”

5. Process Safety Management of Highly Hazardous Chemicals

1926 Subpart D – Occupational Health and Environmental Controls

1926.64 – Process safety management of highly hazardous chemicals.

The changes would remove the 31 pages of text for Process Safety Management of Highly Hazardous Chemicals (PSM) and simply cross reference the general industry standard. This would avoid unnecessary duplication since construction firms rarely have a PSM program at their worksite and when they do perform work at refineries or chemical manufacturing plants they can obtain a copy of the standard from the host employer.

6.Personal Protective Equipment (PPE)

1926 Subpart E – Personal Protective and Life Saving Equipment

1926.95 – Criteria for personal protective equipment.

In order for personal protective equipment (PPE) to adequately protect workers, it must fit properly. The construction standard doesn’t explicitly require that PPE fit each affected worker they way the general industry standard does. The revisions proposed would require employers to select and provide PPE that properly fits their workers.

7. Lanyard/Lifeline Break Strength

1926 Subpart E – Personal Protective and Life Saving Equipment

1926.104 – Safety belts, lifelines and lanyards.

The changes proposed would revise the minimum breaking strength of lanyards and vertical lifelines to 5,000 lbs. which would be in line with the requirements in 1926.502 – Fall protection systems criteria and practices. This is based on 5,000 lbs. being equivalent to the force generated by a 250- lb. employee experiencing a force 10 times the force of gravity, plus a two-fold margin of safety. The current 5,400-lb. breaking strength requirement was based on ¾-in. manila ropes used for body-belt systems available when the rule was first written, not on forces generated from falls.

8. Manual on Uniform Traffic Control Devices (MUTCD)

1926 Subpart G – Signs, Signals and Barricades

1926.200 – Accident prevention signs and tags.

1926.201 – Signaling.

1926.202 – Barricades.

The current rules reference outdated versions of the DOT’s Manual on Uniform Traffic Control Devices (MUTCD). The DOT updated the MUTCD in 2009 and made two additional revisions in 2012. The proposed revisions would require compliance with the current MUTCD which the DOT recognized as the national standard for traffic control devices. This will eliminate confusion among employers over which regulations to follow.

9. Load Limit Postings

1926 Subpart H – Materials Handling, Storage, Use and Disposal

1926.250 – General requirements for storage.

The changes proposed would eliminate the requirement to post maximum safe load limits for floors in buildings under construction for single-family houses and townhomes. Unlike with large structures, builders of single-family dwellings don’t store large or heavy amounts of building materials inside for scheduling and staging and therefore the requirement is not necessary.

10. Excavation Hazards

1926 Subpart P – Excavations

1926.651 – Specific Excavation Requirements.

The current provisions require employers to protect workers from loose rock and soil and excavated or other materials in or around excavations that could pose a hazard. The changes proposed would clarify that a hazard is presumed to exist any time loose rock or soil, excavated or other materials or equipment are beside a trench and must be protected against. It also relieves OSHA from having to demonstrate that a hazard exists and better protect workers from cave-ins.

11. OSHA Underground Construction – Diesel Engines

1926 Subpart S – Underground Construction, Caissons, Cofferdams and Compressed Air

1926.800 – Underground Construction

Current rules require that mobile diesel-powered equipment used underground comply with outdated Mine Safety Health Administration’s (MSHA) provisions. The proposed changes would cross-reference the updated MSHA provisions as they pertain to diesel engines.

12. Underground Construction

1926 Subpart S – Underground Construction, Caissons, Cofferdams and Compressed Air

1926.803 – Compressed air.

The revisions proposed would replace current decompression tables with the 1992 French Air and Oxygen decompression tables. OSHA has deemed the French tables safer than the existing ineffective tables in the standard.

13. Rollover Protective Structures

1926 Subpart W – Rollover Protective Structures; Overhead Protection

1926.1000 – Rollover protective structures (ROPS) for material handling equipment.

1926.1001 – Minimum performance criteria for rollover protective structures for designated scrapers, loaders, dozers, graders and crawler tractors.

1926.1002 – Protective frames (roll-over protective structures, known as ROPS) for wheel-type agricultural and industrial tractors used in construction.

1926.1003 – Overhead protection for operators of agricultural and industrial tractors.

The proposed revision would remove provisions that specify test procedures and performance requirements for overhead protection. They would be replaced with references to applicable consensus standards from the International Organization for Standardization (ISO) and Society of Automotive Engineers (SAE).

14. Regulation of Coke Oven Emissions in Construction

1926 Subpart Z – Toxic and Hazardous Substances

1926.1129 – Coke oven emissions.

OSHA has determined that the coke oven emissions provisions don’t fit the scope of construction work. Because of this, OSHA is planning to remove this section entirely. Any work done during the operation of coke ovens is covered under the general industry standard.

15. Collection of Social Security Numbers

OSHA is proposing to remove all requirements to include an employee’s social security number (SSN) on exposure monitoring, medical surveillance and other records from all general industry, construction and maritime standards. The rising threat of identity theft is the primary reason for the change to help safeguard and protect the privacy of employees.