Construction has long been recognized as a high hazard industry and is one of the industries targeted in MOSH's
five-year Strategic Plan. It is believed that through a local emphasis program that increases awareness and accelerates
enforcement activity, illnesses in construction can be reduced. It is also recognized that a tracking mechanism for these
type inspections would prove beneficial in monitoring the area of health hazards. In the past, many un-programmed inspections
have been conducted through CSHO self-referrals, imminent danger complaints, or 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 health hazards that are identified on construction sites. The Regional Supervisors shall use this LEP as a basis
for scheduling and conducting health inspections of construction sites. This LEP is intended to be used on any construction
site where health hazards have been alleged and/or identified to initiate health inspections. These inspections may be
expanded to comprehensive inspections of multi-employer construction sites in accordance with the guidelines established
in the FOM.
- An targeting system which encompasses identification of sites at the beginning of the quarter and the random
selection of sites is not practical. Health hazards 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 health hazards are observed by Compliance Officers will be selected for inspection under this
LEP. Employee exposure to the health hazard does not have be observed, only the presence of, or evidence of preparation for
activities that could result in potential exposure to health hazards need be observed in order to conduct an inspection under
this LEP. Examples of such activities could include, jackhammering, brick/block work, spray-on insulation, demolition,
paint removal, concrete cutting, burning/welding, excessive noise generating operations, etc.
- When a jobsite with potential health 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.
- Health hazards are reported via referrals and complaints, both of a formal and a non-formal nature. Formal complaints
of health 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 or the OIS equivalent form will be
"HEALTH HAZARDS IN CONSTRUCTION".
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