Construction Project Site Specific Safety Plans Expert Article

In this article, civil engineer & construction safety expert, Jason Randle, P.E. provides an overview of construction project Site Specific Safety Plans. His discussion includes a description of Site Specific Safety Plans, an explanation of why they are effective, as well as information on how some plans fall short.

Construction Project Site Specific Safety Plans

Owners and contractors on construction projects are entrusted by multiple participants to continuously manage the risk of injury and damages. A construction accident can cause injury or death, cost money, create unwanted delays, and leave a residual effect on all involved long after project completion.

In most years the construction industry represents more than 20% of private sector worker fatalities.⁵ This statistic is reflected in our own casework, with our engineers investigating hundreds of construction injury incidents each year.

To overcome the enormous effort associated with managing hundreds to thousands of construction workers with varying levels of competency and training, general contractors and construction managers use Site Specific Safety Plans on their projects to assist in risk management and accident aversion.

A Site Specific Safety Plan is a document that is written to outline how a general contractor will manage the risk on a specific project site and the health and safety requirements for that project. The goal of the Site Specific Safety Plan is zero accidents. The Site Specific Safety Plan should:

• Create a system that connects activities to hazards and hazard control.
• Be written to protect site personnel, visitors, and the general public from exposure to health and safety hazards on the job site.
• Involve all contractors and subcontractors who will work at the jobsite.
• Be dynamic and updated regularly to incorporate major changes to project conditions and hazard exposures.

The primary author of the Site Specific Safety Plan is the project general contractor and the Site Specific Safety Plan becomes a contract attachment in subcontracts between the general contractor and the subcontractors.

But what comprises an effective Site Specific Safety Plan? And what resources and standards are available to assist in the creation of a project’s Site Specific Safety Plan? Do these relevant standards provide enough information to create a successful plan? And what are some potential pitfalls?

Construction accidents can damage the reputation of the project stakeholders, impact the financial success of a project, and disrupt the future business plans of those involved. Proactive implementation of safe means and methods is always preferential to a post-accident reactive course.

Additionally, most stakeholders would agree that thoughtful management is imperative to a successful project. For thoughtful project management to occur, project managers and superintendents must treat each project independently using known standards and experience. A thoughtful, relevant Site Specific Safety Plan works in averting accidents and avoiding construction injuries and damages.

The experience of our experts in industry as well as in conducting forensic investigations reveals a wide disparity between the best Site Specific Safety Plans and the worst. In our experience, many project owners, designers, and contractors fail to create a worthwhile Site Specific Safety Plan that protects the safety of the workers, in-place and adjacent construction, project reputation, and the project finances.

To steer project owners, designers, and contractors, the American Society of Safety Engineers (ASSE) developed a worthy standard in its American National Standard ANSI/ASSE A10.1-1-2011 titled Pre-Project & Pre-Task Safety and Health Planning (ANSI 10.1). This standard establishes the elements and activities for pre-project and pre-task safety and health planning in construction.

Within the standard, the purpose is stated as:

1.2 Purpose: The primary purpose of this standard is to assist construction owners, project constructors and contractors in making pre-project and pre-task safety and health planning a standard part of their planning processes.

Additionally, the standard defines the following:

• 3.10 Critical Topics: Topics to be considered during the development of a project specific safety and health program.
• 3.11 Operational Plan (Construction Sequence Plan): The documents that address the milestones, activity dates and updated schedules during each phase of construction, and the methods to be used to achieve them.
• 3.13 Pre-Project Safety and Health Planning: The process of incorporating worker safety and health into the planning of a construction project.
• 3.18 Project Specific Safety and Health Plan: A written plan describing how project specific safety and health issues, such as complex tasks and potentially hazardous tasks will be addressed. The plan is based on the most current operational plans, company safety and health programs, hazard identification reports and all applicable topics¹

The standard lays the foundation for a project’s Site Specific Safety Plan. In the following section we highlight what many professionals do well, areas where some go wrong, and other components that are frequently omitted. A more detailed report is available on our website.

Overview of Elements (Positive, Negative, Missing) on Site Specific Safety Plans

Positive Elements

An informal survey of experienced general contractors indicated that these contractors utilize the following components in their Site Specific Safety Plans.

These components work towards a very good starting point of a worthy Site Specific Safety Plan.

• Use of a general contractor company standard safety prequalification form with safety focus as part of prequalification and vetting process
• Subcontractor compliance with OSHA and reporting of OSHA 300 Log
• Requirement for a subcontractor safety program with corporate safety representative
• Hazard Analysis
• Documentation of employee trainings completed
• Requirement for an English speaking supervisor
• Submission of MSDS sheets
• Near-miss disciplinary program
• First Aid/CPR training
• Identification of competent person
• Documentation of outside inspections and accidents
• Work attire review (PPE) identifying worker and tradesman company
• Hard hat numbering system useful in identifying workers on site
• Documentation of subcontractor tool box talks, i.e., the weekly meetings concerning safety, coordination, material delivery, progress, staffing, schedule and the like
• Site safety orientation with signed documentation including a site safety orientation and worker signature which documents worker has completed orientation

Negative Elements

Canned Site Specific Safety Plans

A current and unsettling trend that has occurred in the construction industry is a scenario wherein the general contractor issues a blank corporate template of a Site Specific Safety Plan to its subcontractors, remiss of any specificity, then requires the project subcontractors to sign and return. This approach is motivated by meeting the requirement of:

The project constructor shall establish a system to confirm that its project specific safety and health plans implemented by all contractors on the project.²(author emphasis added, subcontractors)

Although this approach may be better than no Site Specific Safety Plan, the end result is typically not specific to the work effort. And this weak approach does not relieve the multi-employer component of the general contractor:

Whenever the project constructor or other responsible party (agent) delegates their responsibility, they are not relieved of accountability for oversight (of the activities that were delegated)….If the project constructor or its agent becomes aware of a situation where an entity that has been delegated responsibility fails to or cannot perform the delegated responsibility adequately, then the project constructor or its agent shall be responsible for correction of the deficiency.³

Restating Standards

Another unsettling trend in the construction industry is the general contractor action of plainly re-stating OSHA regulations and ANSI standards within a contract document. This nonspecific integration of general standards is not ideal. There is potential for added risk whenever a simple re-stating or re-interpretation of a standard occurs.

Just restating a standard is not only unnecessary but can increase risk by supplying conflicting information to users if the standard is updated and the update does not directly convey to the contract document. Additionally, typos may occur or major components may be missed when adding a document or cutting and pasting terms to a contract. Whenever a conflict between a construction contract, including the Site Specific Safety Plan and an accepted national standard occurs, unnecessary risk is created.

Missing Elements

Owner and Designer Interaction

Far too many Site Specific Safety Plans lack owner and project designer input. As contractors, a simple and effective way of adding specificity to a Site Specific Safety Plan is the inclusion of other stakeholders including owners and designers. Most understand that a project owner is required to review a contractor’s health and safety plan as part of the prequalification process when awarding the prime contract. What some may fail to realize is that this review and assignment of a contractor does not end the owner’s responsibility on the project.

ANSI A10.1 guides Owner responsibility and incorporation into the planning by specifically stating in the following sections:

• 4.1.1 The construction owner shall ensure that project specific expectations, goals and policies for safety and health are established for the project.
• 4.1.2 The construction owner shall ensure that the project specific safety and health policies are implemented by the project constructor and evaluated for necessary changes throughout the construction.
• 4.2.2 The construction owner shall ensure safety and health design specifications are established and incorporated into the appropriate contract documents.⁴

Additionally, the integration of owner and designer input is not a static relationship. The relationship is dynamic and should continuously be evaluated throughout a project.

Specific Project

Many Site Specific Project Safety Plans neglect to provide specific project safety and control direction.

The Site Specific nature of the safety plan should be applicable to the specific site. Each project is unique and warrants a thoughtful review of the site conditions and surrounding area.

Thoughtful contractors realize that site specific rules that help form the Site Specific Safety Plan should focus on containing worker activity on the jobsite. To accommodate this charge, the following elements should be included:

• Visual diagram of the project.
• Limits of Disturbance of the impacted area.
• Description of the project facility.
• Geographical location of the project in relation to setting: city, campus, etc.
• Description of any usual site conditions or exposures.
• Location of scaffolding, equipment and activities.
• Neighboring structures or businesses.
• Dictated vehicle travel ways and delivery routes to a jobsite.
• Worker movement off-site including parking locations and break areas.
• Dedicated building entry points and dedicated stairwells for worker travel.
• Safety and emergency contacts.

Additional Resources

Additional appropriate resources are available for use in the creation of an effective Site Specific Safety Plan, including:

OSHA Directive CPL 02-00-124 Multi-Employer Citation Policy: Outlines the responsibilities of the various project parties and is relied on heavily when accidents occur.

ANSI/ASSE A10.34 Protection of the Public on or Adjacent to Construction Sites: Provides guidelines for a construction project’s interaction with the public.

ANSI/ASSE A10.38 Basic Elements of an Employer’s Program to Provide a Safe and Healthful Work Environment: Establishes minimum elements of a program for protecting the safety and health of employees involved in construction activities

Site Specific Safety Plan Best Practice Recap

The best construction projects are managed by team members focused on success. Signs of a well-run project include made milestones, maintaining budget, high quality, and zero construction accidents. The well-run project includes a Site Specific Safety Plan written with the guidance of nationally accepted standards, includes owner/designer input, and is specific to the environment surrounding the project.

Owners and contractors must thoroughly review and vet contractual obligations and directions which must include a Site Specific Safety Plan. If an incident were to occur on a project, all documentation is scrutinized and at times, the efforts of the controlling employer are reviewed with an eye on facilitating a safe project site. An effective Site Specific Safety Plan, and its implementation and enforcement on the project, are integral to the ultimate success of a project and can be imperative when answering to post-accident scrutiny.

Our experts can evaluate Site Specific Safety Plans as part of contract and project documents, safety programs, and the GC’s role.

Construction Injury Investigations

The Construction Safety experts at Robson Forensic have worked at every level within the industry, from bricklayer on residential projects to project manager on multi-prime worksites. Our experts have done the work central to your case and can testify regarding the hazards, risks, and responsibilities in the construction industry.

For more information submit an inquiry or contact the author of this article.

Sources

1. Approved American National Standard ANSI/ASSE (ANSI) A10.1-2011 Pre-Project & Pre-Task Safety and Health Planning
2. Approved American National Standard ANSI/ASSE (ANSI) A10.1-2011 Pre-Project & Pre-Task Safety and Health Planning 5.3.2
3. Approved American National Standard ANSI/ASSE A10.34-2001 (R2012) Protection of the Public on or Adjacent to Construction Sites 1.3.2
4. Approved American National Standard ANSI/ASSE (ANSI) A10.1-2011 Pre-Project & Pre-Task Safety and Health Planning 4.12
5. https://www.bls.gov/iif/oshwc/cfoi/all_worker.pdf

Featured Expert

Jason Randle, P.E., LEED AP

Civil Engineer & Construction Safety Expert

Jason Randle is a Civil Engineer with twenty years of professional construction and engineering experience. His project experience has ranged from General Contractor/Construction Manager to Project… read more.