A holistic approach to construction safety compliance: The sum is greater than the parts

Changes to the OSHA regulations, as well as localities adoption of the international building codes has set up situational compliance never experienced before by the construction industry. Compliance to these changes requires sweeping modifications in enforcement of construction safety program components. OSHA's definition of "controlling contractor" and local codes that have codified and qualified safety representatives on site have thrust safety to the forefront in construction and made safety elements as important a component of the pre-construction process as the purchase of concrete or steel. The explosion of the OCIP and CCIP insurance programs have made safety a benefit-cost to the project, not only centralizing the cost of insurance so as to get better purchase numbers from the contractors, but as well as getting a benefit to positive job safety performance which will cause it to be a profit center for the job. All these items point to the need for our industry to plan for all elements of safety for a project, from the development of the job site safety plan and program to the designation of the project safety organization (involving both the overall projects and individual contractor qualified safety representative). Also, job site training programs for OSHA's required qualifications for people working on the job, to orientation programs, to weekly contractor tool box meetings, to accident analysis and lessons "learned" training becomes the highest of priorities. In addition, plan development has expanded, now requiring logistics for various phases of construction as well as engineering of safety protection (nets, barricade, perimeter protection). Designing the use of new perimeter protection based systems (peri, net cocoon, etc.) and development of standard protection details (guardrails, toe boards, hole protection, job ladders, etc) are also a primary goal. The administration of the job also now includes daily safety logs, safety recommendation logs, accident reports and analysis, deficiency notices, fines and backcharge programs as well as contractor report cards and performance assessments, etc. These elements now call for a "holistic" approach to safety, one where it may be a consideration to engage a single contractor who will handle the safety completely on the site for all the elements mentioned. This "single responsibility contract" identifies a one stop presence- where finger pointing doesn't exist. The contractor-through the job safety representative-must be responsible for identifying deficiencies and then—if not corrected by the offending contractor- correcting it with their team and identifying the backcharge. This protection "team" will also be the team installing the initial protection and performing the routine "maintenance" during the job (although contractors will contractually be responsible to replace the protection they remove to do their work). The safety contractor will also be responsible for developing the job site safety program and logistics. The safety contractor is also responsible for creating the job site safety organization by accepting the required safety representative for each contractor and establishing that representative as the point person for each contractor's safety compliance. The safety contractor would also be responsible for the review and acceptance of all contractors' safety plans and the development of the contractor safety plan requirement that will be incorporated into each contract. The job safety representative will also be responsible for monitoring performance with permit requirements both from a governmental and job site (hot work, etc.) perspective. Also incorporated into the safety program the job site safety representative and its Professional Engineer (P.E.) will develop an engineered protection program- showing protection details and location of these elements that will be installed by the safety protection crew. On a daily basis, the job safety representative of the safety contractor will conduct inspection of compliance, identify deficiencies and safety recommendations and issue fines for non compliant activities. The safety representative will also make sure that the contractors are performing their weekly tool box/training requirements as well as all paperwork requirements. The safety representative will conduct weekly safety meetings with contractor safety representatives as well as monthly owner/job safety steering committee meeting where accident/incident and contractor performance will be reviewed. The owner/CM/GM should evaluate this concept of a single source, holistic, construction safety contractor and evaluate it as a "line item" cost-one outside of general conditions and guided by a separate contract. The potential for fines, work stoppages and accidents as well as the cost benefit associated with successful OCIP/CCIP insurance programs would more than pay for these changes in culture and will eliminate cloudy responsibilities, finger pointing and non compliance. Matt Caruso is the executive vice president of operations at Domani, Valley Stream, N.Y.