Cal/OSHA Releases Top Ten Citations List
Industry Safety Reminder
Top Ten Cal/OSHA Citations for Heavy and Civil Engineering Construction over the past year.
- Injury and Illness Protection Program
- Heat Illness Prevention Plan
- Haulage and Earth Moving Equipment
- First Aid Kits and Training
- Lead
- Reporting Serious Injuries
- Excavation
- Forklifts
- Permits
- Ladders
Tips to prevent injuries and avoid these citations.
Injury and Illness Protection Program (IIPP).
Contractors are cited for not having a written IIPP, having an IIPP that is not implemented or effective, or not having all the required elements in the IIPP. This often comes from failure to identify or correct hazards. Do good inspections where you find hazards and document that you correct them. Recordkeeping is cited often too. [Construction Safety Order (CSO) 1509 and General Industry Safety Order (GISO) 3203]
- UCON's Safety Handbook is available in our Contractor Resources Library? Make sure your safety leaders have UCON's comprehensive guide to assist them. It is free, and downloadable, for UCON contractor members.
Heat Illness Prevention Program (HIPP).
Citations are for not having a written Heat Illness Prevention Plan (HIPP), having a HIPP that is not implemented or effective, or not having all the required elements in the HIPP and training program. Failure to provide or replenish water is also frequently cited. Review your written program and training to make sure they have all the required elements. New regulations also require heat illness protections for indoor work so if you have not added these requirements to your HIPP now is the time to do it. [GISO 3395 and now 3396]
Haulage and Earth Moving Equipment.
Citations include a wide range of violations. The most common citations are for vehicles not having seatbelts or operators not using them. The most expensive citations are for not controlling operations to protect workers on the ground averaging almost $20,000 per citation indicating these are related to a death or serious injury. Other citations include not doing pre-shift inspections and elevating employees in the bucket.
First Aid Kits and Training.
Not having enough, or not having people current in first aid training. This training is required every two years. View First Aid/CPR training as an employee benefit and offer it to everyone. First aid kits are a consumable item and must be replenished or replaced regularly. [CSO 1512]
Lead.
Lead exposure exists anytime lead-containing materials are ground, sanded, scraped, or otherwise disturbed. Lead is a toxin, and detailed measures are needed to prevent exposure to employees and to prevent them taking this toxin home to their families. If you do not know how to remove lead materials, hire an abatement contractor. If you do your own abatement, provide detailed training and the PPE and other equipment needed. The exposure limits for lead were lowered and new requirements added at the beginning of the year, so this is likely to go up on the list next year. [CSO 1532.1]
Reporting Serious Injuries.
Failure to report a death, or an injury or illness that requires inpatient hospitalization for other than observation or in which an employee suffers an amputation, the loss of an eye, or any serious degree of permanent disfigurement to Cal/OSHA within 8 hours. Train foremen, superintendents, admin, and HR in reporting requirements. It is a stressful time so the more people who know, the more likely someone will remember to report. [Title 8 Section 342]
Excavations.
Eighty percent of the citations are for not using, or improperly using shoring, sloping, or benching. Make sure you have sufficient and proper-sized shores for the work to be done. Sloping and benching are often not cut back to the proper angle, 1 to 1 for type B soil and 1½ to 1 in type C soil. Benching is not allowed in type C soil, the most common type in California. These citations average $26,500, indicating they are often related to a death or serious injury. Most of the other citations are for not having a competent person inspect the excavation and adjacent area daily.
Forklifts.
Citations for training are the most common. This could be no training or certification, or insufficient training. Training must include information specific to the type of forklift that will be used, and information on the type of workplace where the forklift will be operated. It must include training on hazards specific to operating a forklift on construction sites and an evaluation of the operator's performance in the workplace. Sending an employee to get a card may not cover this, and additional training and evaluation at a construction site may be required. Additional citations were for not following the forklift operating rules.
Permits.
Project permits must be obtained prior to any work being done and must be posted at the site. Along with having an annual excavation permit, you must notify Cal/OSHA at least 24 hours before starting any excavation at a new site. If you forget to renew your annual permit, you must go to a Cal/OSHA office for a permit conference. [Title 8 341, 341.1 and 341.4]
Ladders.
Not inspecting or using ladders and not training employees on their inspection and use. The instructions and training material are stuck on the ladder; what an easy tailgate. Ladders must be inspected “frequently” which technically means at least 13 times a year. The ladder user must inspect it at the beginning of each shift, but you should also do more thorough documented inspections at least monthly. Common misuses include using the wrong type or length of ladder, climbing too high and leaning step ladders. Using lean safe ladders goes a long way on that. [GISO 3276 and CSO 1675]
Take some time to ensure your safety programs address these topics in tailgates. Training is a common theme, but training must be practicable and understandable. Bad training covers the rules, good training teaches employees how to work safely. Click for the Safety Orders referenced in this article.
For more information, UCON Contractor Members can contact Mike Donlon, PE, CSP, UCON Chief Safety Officer, (916) 834-1896.