|| MOSH Instruction 11-6 - Local
Emphasis Program (LEP) Electrocution Hazards in Construction
|| October 1, 2011
|| October 1, 2011
|| MOSH Instruction 10-11
|| One year from the effective
date, unless replaced earlier by a new Instruction.
|| This Instruction establishes
a Local Emphasis program for electrocution hazards in the
|| This Instruction applies MOSH-wide.
|| Chief of MOSH Compliance Services
10946 Golden West Drive, Suite 160
Hunt Valley, MD. 21031
See MOSH Website for Current Information
|By and Under the Authority of:
||Eric M. Uttenreither, Assistant
Construction has long been recognized as a high hazard industry
and is one of the industries targeted in MOSH's Five Year Strategic
Plan. Accidents relating to electrocution hazards are one of
the leading causes of serious injuries and fatalities. It is
believed through a local emphasis program that increases awareness
and accelerates enforcement activity, injuries can be reduced.
It is also recognized that a tracking mechanism for these type
inspections would prove beneficial in monitoring the area of
electrocution hazards. In the past, many un-programmed inspections
have been conducted through CSHO self referrals, imminent danger
complaints or through accident investigations. This LEP is designed
to increase inspection activity, provide tracking, enhance expertise
and formalize procedures.
MOSH compliance personnel shall ensure that the procedures
contained in this Instruction are followed when conducting this
LEP. The Regional Offices will implement the procedures described
in this Instruction in response to imminent dangers or serious
electrocution hazards that are identified on construction sites.
The Regional Supervisors shall use this LEP as a basis for scheduling
and conducting safety inspections of construction sites. This
LEP is intended to be used on any construction site where electrocution
hazards have been alleged and/or identified to initiate safety
inspections. These inspections shall be expanded to comprehensive
inspections of multi-employer construction sites in accordance
with the guidelines established in the FOM.
- An inspection targeting system which encompasses identification
of sites at the beginning of the quarter and the random selection
of sites is not practical. Hazards related to electrocutions
on construction sites are normally transient and of limited
duration. This limits the practicality of targeting the site
in advance. Therefore, inspections conducted under this LEP
would be initiated by several means: Compliance Officer observance,
non-formal complaints, and referrals from other outside sources.
- All work sites where electrocution hazards are observed
by Compliance Officers will be selected for inspection under
this LEP. Employee exposure to the electrocution hazard does
not have to be observed, only the presence of a potential
electrocution hazard needs to be observed to conduct an inspection.
These sites shall include, but shall not be limited to:
- Heavy Equipment and Crane Operations;
- Aerial Lifts;
- Scaffold Usage;
- Electric Utilities;
- Other activities which constitute potential electrocution
hazards and no protective systems are in use such as electrical
installation activities, excavation activities, and site
- When a jobsite with potential electrocution hazards is noted
during travel, the Compliance Officer shall notify the Supervisor
with the name of the contractor (if known) and the location
of the site. The Supervisor will determine if the site has
been inspected within the last 30 days.
- If the site has not been inspected within the last 30
days, permission may be given to inspect the site. Compliance
officers will record these inspections as planned inspections.
- If the site has been inspected within the last 30 days,
an inspection will be authorized only if an imminent danger
appears to be present or at the Regional Supervisor's discretion.
These inspections will normally be limited to the imminent
danger situation and other serious plain view hazards. The
Compliance Officer will remain at the site to observe the
abatement procedures and/or to recommend abatement methods.
Compliance Officers will record these inspections as referral
- A large number of electrocution hazards are reported via
referrals and complaints, both of a formal and a non-formal
nature. Formal complaints of electrocution hazards on construction
sites will continue to be scheduled before programmed inspections.
- The IMIS identifier code to be used in item 25c on the OSHA-1
will be "ELECTROCUTION HAZARDS IN CONSTRUCTION".
cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
Craig D. Lowry, Deputy Commissioner, Division of Labor and Industry
Jonathan Krasnoff, Assistant Attorney General
Office of Administrative Hearings
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