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Proper Documentation of Job hazards and Corrective Action
Job hazard inspection is a standing requirement within the Injury and Illness Prevention Plan standard. (Cal/OSHA 3203). Each operation carries its own hazard level and needs to be defined in terms of each employer’s specific operations. That is why the Cal/OSHA regulations are so extensive.
But in areas where there is a shifting flow and arrangements of men, equipment and materials, such as may be found on construction sites or dynamic fixed site operations; the hazard level will be naturally higher, irrespective of the actual hazards of the operation.
Regulation Requirement to Inspect for Job Hazards
Physical Hazards: The more static portion of the inspection requirement, involves making sure that you have addressed hazards relating your equipment and materials; in relation to the working environment. These can be addressed within your working IIPP as safety rules and regulations.
Operational Hazards: This is, by the far, is the more dynamic portion of your inspection requirement. It focuses on the way that your operational flow affects the safety and health of employees.
In production terms, the construction industry calls this the job site critical path. For fixed site operations, it is the production schedule. These terms encapsulate the idea of changing conditions within each workplace, and are more descriptive of the hazards created by employee behavior. It is within this arena that hazards and corrective actions take on a more urgent tone. In general, however; Cal/OSHA requires that employers inspect for job hazards daily and per shift.
Regulation Requirement to Prioritize, Institute and Complete Corrective Action
As hazards are found and corrective action must be implemented, they must to be prioritized by the immediacy of the need to correct the condition before an injury or illness, property damage, or worse; occurs. Then the employer needs to actually correct the hazard.
Regulation for Proper Documentation
All this activity must to recorded in writing and communicated to employees. If no hazards are found, recordkeeping is not required on a daily or per shift basis, but should be completed at least weekly on construction operations and every 90 days for fixed site operations with low to moderate hazards. Higher hazard operations of any kind will have more frequent inspection requirements. Employers need to verify with Cal/OSHA regulations for specific operations.
How Long to Keep Documentation
There are varying lengths of time that inspection documents need to be kept. In general, keep safety inspection records as long as you keep your business records (fixed site) or job site records (construction), as required by law. For specific hazards, documentation requirements may be longer. Once again, check the Cal/OSHA regulations for specific operations.
Inspect Frequently and Keep Records
For physical hazards, define your requirements and routinely inspect for deficiencies. For operational hazards, focus on employee behavior and work flows. Inspect by day and per shift.
To obtain more information about General Contractor Specifications for Site Safety Requirements , go to: S.C.B.A. website: www.socalbuilders.org .
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Ask the Code Consultant Q: What do you see for the future in construction? I have been asked this question several times over the past few years. I believe it’s the sign of the times because construction is down and you are all concerned about available jobs.
The proposed work that has crossed my desk involves non-combustible construction materials. These include a metal-framed office building over a parking garage, a hotel with underground parking, a hospital and an industrial facility.
If you have experience and qualifications in steel fabrication, concrete placement or rebar installations, this type of work would be needed on the above jobs.
I have seen only a few plans that would involve wood framing. I have been contacted by several architects that are preparing plans for mixed uses. These are jobs that involve wood-framed apartments over a concrete parking garage. But, none of them have gotten plans to me yet.
Apparently, what’s holding up these jobs from going forward is the lack of financing. It’s my impression that the big developers are self-financed and don’t need a bank to control their investments.
For residential uses, there are many large apartment complexes under construction. I had a meeting with a design-build firm near the Los Angels-Burbank border and driving to their office I saw many large wood-framed jobs under construction. So, the work is out there but for a small segment of our industry.
I have asked a few contractors on what keeps them busy. What they have said is that they have a specialized niche and a loyalty from their clients. The same is true for architects that continue to produce plans.
However, their clients are now asking for discounts so I guess that loyalty only goes so far. The contractors must now ask for discounts from their subs, including architects and engineers.
Based on what I know about the busy contractors is that they provide quality service and excellent workmanship in all their jobs. This could be the key to continued work for you.
Another problem to opening up new jobs is that the State of California has been adopting new Green and Energy codes that affect new construction – BIG TIME!
These new regulations affect the cost of construction by mandating all sorts of extra inspections, testing and certifications. I haven’t gotten an appraisal of the extra costs but I suspect that they could keep a job from going forward.
These rules have also created a cottage industry for pseudo environmentalists and “experts”. I do not involve myself with this type of work for good reasons.
I downloaded the California Green Code and when I got to the part where you will have to regulate lawn sprinklers I gave up.
I wish I could forecast a rosier picture but I cannot. |
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Use Your Head, Wear Your Hard Hat
Your head is the most important part of your body. You think, feel, talk, smell, and hear with your head. Therefore, it makes sense that you should protect your head from any injury.
Wearing a hard hat is the first line of defense against head injuries on the job. A hard hat can protect your head against the hazard of falling material and guard against accidental bumping. The hard hat softens any blow to the head. It resists and deflects the blow and distributes the impact over a large area. The hat’s suspension acts as a shock absorber.Even if the hat dents or shatters, it still takes some of the force out of the blow and off your head. It can also shield your scalp, face, neck, and shoulders against spills or splashes.
Choose the hard hat most suitable for the work being performed and only wear approved hard hats manufactured to meet required standards. These are made to give your head maximum protection. Make sure your hat fits correctly. Hats that fit right provide you with the most comfort and protection.
The ability of a hard hat to protect a worker depends on the shock absorbing space between the shell and head by the suspension provided. Therefore, it is important that sweat bands and suspension straps by properly adjusted to obtain the maximum protection. Sunlight and heat can rot the sweatband and straps, so don’t leave your hard hat on the window ledge of your car. Take good care of your hard hat. Don’t drop it, throw it or drill holes in it. Inspect your hard hat every day for cracks, gouges, and frays or breaks in the straps.
Colors can be used to identify different crafts and supervisory personnel, and should be encouraged and given consideration when purchasing such equipment. All levels of supervision should set the example by wearing hard hats. Observe and comply with "Hard Hat Area” sites. Remember! A hard hat is a status symbol; it identifies a safe worker, one who believes in and practices safety. The above evaluations and/or recommendations are for general guidance only and should not be relied upon for legal compliance purposes. They are based solely on the information provided to us and relate only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards. |
Use la Cabeza, Póngase el Casco de Seguridad
La cabeza es la parte más importante de su cuerpo. Con ella se piensa, se siente, se habla, se huele y se escucha. Por lo tanto, tiene sentido protegerse la cabeza contra cualquier lesión.
La primera línea de defensa contra las lesiones a la cabeza en el lugar de trabajo es el uso del casco de seguridad. El casco protege la cabeza del peligro de caída de objetos y resguarda contra golpes accidentales. El casco reduce la intensidad de cualquier golpe a la cabeza. Resiste y desvía el golpe y distribuye el impacto sobre un área mayor. La suspensión interna del casco actúa como amortiguador. Aún en el caso de que el casco se quiebre o se abolle, absorbe parte de la fuerza del impacto, transmitiéndole menos a la cabeza. También puede resguardar el cuero cabelludo, la cara, el cuello y los hombros contra derrames o salpicaduras.
Elija el casco más apropiado para el tipo de trabajo que se ejecuta, y sólo use cascos aprobados y fabricados para cumplir con las normas aplicables. Éstos están diseñados para proporcionarle la máxima protección a la cabeza. También es importante asegurarse de que el casco le quede bien. Un casco de la talla correcta proporciona el máximo de confort y protección.
La habilidad del casco de proteger al trabajador depende del espacio para absorber impactos que la suspensión mantiene entre la coraza exterior y la cabeza. Por lo tanto, es importante que la banda y las correas de la suspensión estén ajustadas debidamente para obtener la máxima protección. La luz solar y el sudor pueden podrir la banda y las correas, por lo tanto no debe dejarse el casco bajo la ventana trasera del automóvil. Cuide su casco. No lo deje caer, no lo tire ni le taladre orificios. Inspeccione el casco cada día para asegurar que no tenga grietas, ni surcos y que las correas no tengan roturas ni estén deshilachadas.
Se pueden usar colores para identificar diferentes oficios y al personal de supervisión, y se debe tener en cuenta al efectuar la compra de dichos equipos. Todos los niveles de supervisión deben dar el buen ejemplo usando los cascos de seguridad. Observe y cumpla con los avisos de “Área de casco de seguridad” en los lugares de trabajo. Recuerde, el casco de seguridad es un símbolo de prestigio: identifica a un trabajador seguro, uno que practica y cree en la seguridad. The above evaluations and/or recommendations are for general guidance only and should not be relied upon for legal compliance purposes. They are based solely on the information provided to us and relate only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards. |
Kalb's Q&A for Contractors
Like the old school crime drama, Dragnet, the CSLB wants, “just the facts” --including your address changes. Like Detective Joe Friday they now also get your fingerprints! Truth and keeping your information current is your ‘shield’ in avoiding any problems with your contractor’s license. Failure to keep current ‘courts’ potential disaster down the road…
Q: My contractor’s license is due to expire this month. I’m concerned that I have not received the renewal in the mail. After several dry months, work is picking up and I cannot afford to have an expired license. I called the Contractors Board and they are going to send me my renewal. Anything else you can suggest?
A: As we discussed, the reason you did not receive your renewal application is because you moved and failed to notify the CSLB. Mailings from the Contractors Board are typically not forwarded by the postal service so it’s vitally important to file an address change with the Board.
Alternatives to waiting for the renewal to arrive at your new address include: flying or driving to CSLB headquarters; re-contacting the Board to see if they will fax the renewal; or having someone pick up the renewal on your behalf (so it can be sent overnight or emailed to you the same day). When returning the renewal application make sure it’s signed by the Responsible Managing Employee (RME) -- and yourself as the Officer of record – and includes the correct fee.
It is presently taking the Board up to two weeks to process renewals. Therefore, your license may show “expired” for a short period of time. This “expiration” should be erased from your record assuming the renewal is postmarked or delivered in person to CSLB Headquarters no later than the expiration date.
Q: I have been licensed for about 16 years. I have never had any complaints against my license; I have always kept my bond up to date; made sure my Worker’s Compensation was always in force and never had any problems with the Contractors Board – until now.
Apparently last year when I sent in my renewal it was not processed until a week after my expiration date. This lapse was just discovered because I am in a lawsuit and my attorney tells me this is a problem. I’m certain I renewed the license on time. Is there any way you can find out what may have caused this?
A: Your attorney is correct. Having an expired license for even a few days can cause serious problems for contractors. A Certified License History from the CSLB, which your attorney undoubtedly has in hand, would show each and every expiration or suspension.
To delve deeper into the cause of this license lapse, your attorney will need to review your entire file. Have him contact my office and we’ll make such a request on your behalf. I can also personally review this document, and give your attorney some insight into what may have happened with your renewal. If it’s determined that the Board made an error, a request can be made to correct the record.
AB 397 (Monning) is sitting on the Governor’s desk awaiting his signature or veto. This bill hopes to stem the tide of contractor’s claiming a Worker’s Compensation exemption when in fact they have employees. If signed, an active licensee would be required, at the time of renewal, to either recertify they are still exempt or provide a current and valid Certificate of Worker’s Compensation Insurance. As it is today a contractor who may have filed an Exemption at the time his or her license was first issued is never required to reconfirm they are, in fact, still exempt.
While knowledge is power, knowing where to go for the answers is half the battle. Get expert assistance immediately when you call 866-443-0657, email info@cutredtape.com, or write me at Capitol Services, Inc., 1225 8th St. Ste. 580, Sacramento, CA 95814. Research past columns at www.cutredtape.com. |
