Excavation Without Evaluation? You’re Next for a Cave-in

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“Trenching and excavating is one of the most hazardous occupations in the construction industry. The only way to minimize these hazards is to follow the OSHA standards requiring engineering controls, protective equipment, and safe work practices.” Said Brian Sturtecky, OSHA’s area director in Jacksonville, FL.

This quote was also accompanied by a $100K willful citation issued to a local contractor for allowing employees to work in an excavation up to 9-feet deep without cave-in protection.

This is because a cave-in is the most common hazard associated with excavation work, as well as the most-deadly. Cave-ins are a risk to workers who repair water, sewer and utility lines, build roadways, perform digging operations, and perform other construction related activities. Some are exposed more than others, but all are at serious risk if proper protective measures are not taken.

AFSCME issued a statement that cave-ins can be caused by:

  • Loose soil / dirt due to vibrations from construction equipment or traffic in the nearby construction area
  • The weight of equipment combined with being too close to the edge of a trench
  • Soil that does not hold tightly together, such as sandy based soils
  • Water is heavily present at the job site, which weakens the strength of trench sides

A competent person must evaluate possible dangers before performing trenching or excavation work begins and throughout the entire operation until completion; NO EXCEPTIONS.  By OSHA standards, protective systems must be used for any trench or excavation that is 5 feet or more in depth. However, client requirements or the competent person may require protection at depths less than 5 feet.

Protective Systems may include:

  • Shoring – This supports the walls of the excavation. Shoring is made up of wales, cross-braces and uprights. Shoring must be installed from the top down and removed from the bottom up.
  • Sloping – This means the sides of the hole open out of from the excavation.  The type of soil determines the required angle.
  • Benching – This system is similar to sloping with steps cut into the sides of the trench.
  • Shielding – Shielding involves trench boxes or trench shields that are placed in the excavation to prevent the sides of a trench from caving in. The worker is only protected while in the “box”.  Some boxes can be moved throughout the work process.  The shield must extend at least 18 inches from the top of the trench.

To evaluate which protective system and other measures need to be deployed, the competent person may have a checklist to properly inspect the excavation like the example below:

  1. How deep is the excavation?
  • If 0’-4’ – Has the competent person inspected it and “safed it up”?
  • If 4’-5’ – Is there a means of egress (ramp, ladder or stairway) within 25’ of where people are working?  Is there a potential for hazardous atmosphere in the excavation?  This could be like in a landfill, chemical dump, nearby blasting or even next to a large highway. Was it tested?
  • If 5’-20’ – Does the excavation meet the egress and hazardous atmosphere standards?  Is the excavation sloped, shielded or shored?
  • If 20’+ – Has a professional engineer registered in the state been engaged to design the excavation?
  1. If sloped or benched
  • Has the soil been classified as stable rock, type “A”, “B” or “C”.  Remember type “C” cannot be benched.
  • What was the basis for classification?
  • Was at least one manual and one visual test completed.
  • Is water coming into the excavation?
  • Is there vibration in the soil?
  • Is it sloped into the excavation steeper than 4 to 1?  Is it previously disturbed?
  • Was it downgraded?
  • Are spoils, materials, and equipment at least 2’ back from the edge of the excavation?

3. If shielded

  • Is the tabulated data on site, and does the competent person understand how to read it?
  • Is the box within its rating?
  • Is it more than 2’ off the bottom of the excavation?
  • Is the dirt 18” down on the side of the shield?
  • Is the worker staying inside the shield?
  • Is there a means of egress within the shield?

4. If shored

  • Was the table in subpart “P” followed or was the calculation provided by a professional engineer?
  • Is everyone in the excavation wearing a hardhat?
  • Was the inspection and classification by the competent person documented?

 

HB NEXT has provided excavation competent person training and expertise to our clients for nearly 20 years.  If you do not have a competent person on site or need more information about excavation safety training, please contact us today.

National Safety Month – What You Need to Know

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Every June in the United States most people are getting ready for barbeques, beaches and summertime fun. However, individuals in the Environmental Health and Safety(EHS) industry are ramping up for National Safety Month.

National Safety Month is aimed at reducing the leading causes of injuries and fatalities in the workplace, on the road, and in our homes and communities. This month is a reminder that we all need to make safe decisions individually to protect ourselves and those we care about. The National Safety Council(NSC) has a different safety emphasis each week in the month of June as follows:

  • Week 1: Emergency Preparedness
  • Week 2: Wellness
  • Week 3: Falls
  • Week 4: Driving

NATIONAL SAFETY MONTH FREE MATERIALS

 

Additionally, National Safety Month is a great time for companies to review their safety program look for areas that need improvement. HB NEXT is offering all companies a Complimentary Review of their program, and $100 off of all Safety Manuals during the month of June. To submit your manual for review, simply fill out the form and upload your manual HERE.

HB NEXT Launches Storm Cloud

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HB NEXT is excited to announce the official launch of Storm Cloud, a multi-tenant cloud software platform that is set to redefine how environmental compliance is managed across the country.

Since 2005, HB NEXT has built custom software for individual companies. However, this year we are packaging some of our most popular products into affordable, out-of-the-box solutions that can be enjoyed by the masses. This is the first of four cloud products that HB NEXT will be launching this year.

Storm Cloud is the first affordable SWPPP software product built for SWPPP / NPDES inspection companies, home builders, & erosion control contractors. This launch represents a new benchmark in the industry. Now, companies of all sizes can deploy robust, industry-proven software to easily manage environmental compliance data.


CLICK HERE to learn more about Storm Cloud.

 

 

Bringing Awareness to Construction’s Top Killer, Falls

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It is critical that companies today are up-to-speed on Fall Protection Training & Awareness. Falls caused 384 out of 991 total deaths in construction in 2016.  Accounting for 38.7% percent of all deaths, it is by far the biggest of the “Fatal Four” killers in construction.

Fall Protection was also number one on the list of citations issues by OSHA in 2017, but that shouldn’t be a surprise considering it is killing more of our dwindling workforce than anything else.

So, what can companies do to protect their employees, subcontractors and wallets from the biggest cause of fatalities in construction?

  1. Prevent the fall!
  • Use guard rails, cover houses, use lifts, ladders or scaffolds with properly engineered controls to keep employees from falling. If this can’t be done, consider PPE options.
  1. Get the necessary fall protection equipment (PPE) for your job.
  • This can vary based on what type of projects you do.  For example, when working on a high rise, tie offs for fall protection prevention are usually readily available.  If you are setting trusses on a home building site, it may be a different story, but ALL workers must be given the opportunity to be safe and provided with equipment to do so.
  1. Train employees on when to use and how to recognize dangers and verify employees know how to use the required equipment (PPE)
  • Employees must also be given the proper training, so they can effectively assess situations and deploy provided PPE effectively.  Like with any tool, you must learn how to use properly and in the right situations.
  • This can be done through third party Fall Protection training classes, or what’s called “Competent Person” training, which helps to ensure the employee or supervisor knows what to do and how to enforce it.  In fact, OSHA requires certification of training for all employees who may be exposed to hazards greater than 6’!
  • As an employer, you must also verify that the employee is using the equipment as they have been directed. You can do this through regular safety inspections and/or having third party “Mock OSHA” inspections to see if you are practicing what is being preached.
  1. Reprimand employees and subcontractors
  • With something as dangerous as falls, it is always recommended that you reprimand an employee immediately if you see a fall protection violation. Remember that one fatality can devastate a family and cause a healthy company to come crashing down.  If you have employees or trades who are choosing not to abide by the safety standards you have set, everyone’s job is at risk without the proper reprimand documentation.

Your job as the employer or controlling contractor is to assess each situation and provide your employees and subcontractors with the training and resources to be safe wherever they work!

Are you subject OSHA’s Multi-Employer policy?

Under this policy, your subcontractors’ safety is 100% your responsibility. You must take the same approach as you do with your employees or under this policy, OSHA can cite you for any violation that occurs on your jobsite no matter who hired them.

Have questions about:

  • Competent Person Training
  • Fall Protection Policies or Equipment
  • OSHA’s Multi Employer Policy
  • Training, Verifying, Reprimanding requirement

Call our experts at 770-619-1669

Other links, resources and info:

OSHA statistics

OSHA’s multi-employer policy

After the Strike…The Notice of Probable Violation

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The potential of an underground utility strike is considerably high.  In fact, The Common Grounds Alliance reported 37,562 utility damages in Georgia in 2016, of which 62% were caused by insufficient excavation practices. Utility strikes, the damage caused, the interruptions of services, and the cost associated with repair are not the only high anxiety situations to deal with; we must also consider what State regulations and laws are violated in the damage of accurately marked facilities.

The Georgia Public Service Commission’s GUFPA unit is tasked with enforcing The Georgia Dig Law, a set of rules governing underground utility facilities.  Each utility damage in the State of Georgia is reported by the utility owner to the Georgia Public Service Commission’s GUFPA unit. GUFPA, then investigates the damage to discover what Dig Law rules were violated. Each investigation involves reviewing damage reports, and onsite investigation reports taken by the excavator and the utility owner. This information is reviewed, and cross referenced with Dig Law rules to find, if any, violations of The Dig law. If such violations are discovered the GUFPA unit will contact the excavator with a Notice of Probable Violation. This notice is an official notification of a utility damage, the Dig Law violations, and the necessary steps to address the damage incident.

Receiving a Notice of Probable Violation (NOPV) from the Public Service Commission can cause some anxiety as with any citation received. But, avoiding the notice is not the answer. The Public Service Commission wants to help you resolve NOPV matter and encourages you to contact them as soon as you receive a notice. The GUFPA utility investigators will help you navigate process.

To understand the NOPV process better, please view the questions and answers from the NOPV FAQ sheet below:

Why are you receiving this letter?

You are receiving the attached information because our office (The Georgia Public Service Commission/ Facilities Protection Division) has been notified by a utility owner or operator that you have damaged their facility and have been submitted as having possibly violated one or more parts of the GA Dig Law.
What is the GA Dig Law (also known as The Georgia Utility Facility Protection Act (GUFPA))?

The Georgia Utility Facility Protection Act (GUFPA), enacted by the General Assembly in July 2000, provides for the protection of the buried utility facility infrastructure within the State of Georgia. Excavators using mechanized equipment are required to call for a utility facility locate prior to excavating with mechanized equipment or blasting. Upon receipt of a locate request, each affected facility owner/operator must locate their respective utility facilities. Violations of the GUFPA are subject to a civil penalty of up to $10,000 each violation. For the full version   of   the   Act   please   visit   our   website    at www.psc.state.qa.us.

I have paid for the damages to the utility company. Why am I getting something from the PSC?

Damages paid for repairs to utility facilities are separate from the civil penalties assessed for violation(s) of GA’s Dig Law. Although you may have paid for the damaged utility facility, you are now being assessed a civil penalty for probable violation(s) of the GA Dig Law.

How has an Investigation been completed, and I was not contacted before now?

Utility owner/operators are mandated by Commission Rule to report ALL damages to their facilities. Utility owner/operators are to conduct an investigation of the damage and any resulting probable violation(s) prior to submitting the probable violation to the PSC. PSC Staff Investigators will assign each case a number and send out a Notice of Probable Violation (“NOPV’) to the Respondent in order to 1) notify the Respondent of the alleged probable violation(s) and 2) request a written response and supporting documents that show a Respondent’s side of the story.

I do NOT agree with the probable violation alleged. How do I tell my side?

Once you have reviewed the information included in this package you have 30 days from the date listed on the letter to respond in writing, to each alleged probable violation and to provide all evidence you wish to submit in support thereof.

What are my response Options?

There are several ways you can respond to the probable violation:

  • Send in a written statement by mail, fax, or email of the events as you recall them. Send in any pictures or other documentation you may have along with witness statements if avail Use the questionnaire attached to the NOPV packet as a guide for your written statement.
  • If you agree with the investigation, please sign and date the attached consent agreement and mail or fax it back to our office.
  • Contact our office and speak with your investigator (you must still submit your statement in writing).

What happens after I submit my response?

Your investigator will review your information along with the information that was submitted by the utility owner/operator and will determine/complete their investigation based upon their findings and will contact you either by mail, email, or phone call of their conclusion.

What happens if the investigator still finds me in violation after I have submitted my response, and I still do NOT agree?

You may request to appear before the GUFPAAC (Georgia Utility Facility Protection Act Advisory Committee). The GUFPAAC is comprised of approximately 13 members of industry stakeholders and your peers who will hear and make a recommendation on your case.

What happens if I do NOT respond at all?

After the 30-day response time has expired your case will be set for a Rule N/S / hearing on the Title 25 probable violations of the Dig Law. Your case will be heard by a hearing officer who will issue a recommended order on the merits of your case. If the hearing officer finds that the probable violation(s) is(are) supported by the evidence, an additional one-thousand dollars will be added to the civil penalty initially recommended by Staff. For Title 25 Rule Nisis, the civil penalties cannot exceed $10,000.00 per violation.

How do I contact the PSC?

Mailing address:

244 Washington Street, SW Atlanta, GA 30334
Phone: 404-463-6526
Fax: 404-463-6532

Dig Safety: Awareness and Preparedness

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Every 4 minutes an underground utility is struck and damaged by mechanized equipment, potentially causing harm to people/property, and interrupting utility services. The Common Ground Alliance, a stakeholder-run organization dedicated to protecting underground utility lines, reports approximately 379,000 utility damages occurred in 2016 resulting in an estimated cost of 1.7 billion in property damage as well as countless number of injuries and deaths.

Why are there so many underground utility strikes?  According to the Common Grounds Alliance there are several re-occurring causes: Notification not made to the One-Call-Center, insufficient locating practices, unmarked facilities, miss-marked utilities, inadequate utility marking, inadequate excavation practices, improper bidding of jobs, improper equipment used during digging, digging with mechanized equipment without first exposing buried utilities using manual digging methods, and the list goes on.

Utility damages impact everyone directly or indirectly. Contractors are affected in terms of a break down in safety, profitability, insure-ability, productivity, legal and civil liabilities. Utility Owner/Operators are affected in terms of utility repairs and loss of resources. Lastly, everyone is inconvenienced by the interruption of vital utility services.

Excavators, locators, utility owners, and the Utility Protection Center all share equal responsibility in the avoidance of utility strikes. There are some best practices that should be adopted to mitigate utility damages. these practices are:

  • Start at the very beginning: Employees should be trained properly on locating underground utilities, the correct use of equipment, and digging techniques. This includes when to use radar to detect the presence of underground lines and hand-digging and soft-digging techniques. They should also emphasize the correct type of equipment to use for every situation during the excavation.
  • Contractors should follow job site checklists and provide adequate on-site supervision as well as ongoing safety awareness and training.
  • Estimate jobs properly: Job estimates should include costs for allowing the time to locate underground utilities and verify marking, document 811 marking, dig around lines, use radar, and have downtime in the event of a strike.
  • Review the site plans and call 811 at least 48 hours before digging. Check the Positive Response Information System to verify excavation request has been processed.
  • Review flags and markings prior to starting the job to determine the proper equipment for the job.
  • Identify, if possible, whether there may be additional lines that are not on site plans and/or are not marked.
  • Document the job site with photographs prior to commencement of digging, taking photos of flags and markings and showing the scale of where you’re digging.
  • Don’t assume the depth of utilities. Digging at a deeper depth than marked utilities does not always solve the problem. If you aren’t sure, dig slower and use manual tools to expose the utility and determine the tolerance zone.
  • Most important, use your industry knowledge, common sense and always keep a focus on safety!

The cost of utility damages is a trickle-down effect that is paid by us all. Having a clear excavation plan and knowing what below can save lives, money time and property.  If we all do our part everyone wins.

Reggie Nelson
HB NEXT

NPDES Construction Site Inspection Best Practices

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This Inspection Guide describes how to conduct stormwater inspections on construction sites and discusses inspector responsibilities, preparation, inspection procedures, report writing, tips on inspecting BMPs, and enforcement.

An on-site construction site inspection will typically consist of the following components:

  • Pre-Inspection Preparation
  • Entry
  • Records Review
  • Site Inspection
  • Inspection Report Preparation

Pre-Inspection Preparation

In preparing for an inspection, you should review available files such as permits, copies of SWPPPs or erosion and sediment control plans, past inspection reports, downstream water quality problems from monitoring/assessment reports, and other correspondence such as maintenance records on the construction sites you will be inspecting. Also take into account sites that discharges to impaired waters as they will have additional requirements that are described in the NPDES permit. Be prepared for the inspection. Dress for the weather and make sure to have the appropriate safety gear/PPE.

Entry

Before entering the construction site, observe the surroundings and the various stages of construction. Note areas for in-depth review and any clear violations. This is also a good time to view construction site vehicle exit locations and perimeter controls. Indicate on the inspection form the date/time and weather conditions (e.g., light rain, sunny, some rain in previous 24 hours).

When entering the site, it is always good practice to locate and ask to speak with the site representative (superintendent, foreman, project manager, etc.) or someone who is familiar with the construction site. Always note the names of the individuals with whom you meet and speak to.

Records Review

During the records review, make sure that all of the required records are on site:

  • Copy of the NPDES Notice of Intent and proof of submittal
  • Copy of the approved erosion and sediment control plans
  • Copies of the past inspection reports (weekly and post rain event)
  • Copies of the stormwater sampling reports (if required) and proof of submittal
  • Copies of any self-reported violations

If these records are not available, ask why and note the response in your report. There are no legitimate excuses for not having stormwater paperwork on-site and available for review. Inform the contractor that the permit requires these records to be on-site or readily available for review.

Site Inspection

A keen eye, an understanding of the construction sequencing process and accurate documentation are the keys to an effective construction site inspection. Use the inspection form, and take notes regarding the location and condition of BMPs, discharge points, and inlets.

Review the sitemap and plan how you will conduct the inspection (this is particularly important for large construction sites). Identify the significant pollutant sources and BMPs you want to inspect (silt fence installation, sediment basins, slope stabilization, material storage areas, etc.). Consider the direction stormwater will flow as you plan the inspection. Begin your inspection at the low point on the construction site, observing all discharge points and walk up the slope to inspect the rest of the site. Consider the current sequence of construction phasing when planning your inspection.

Inspect discharge points and downstream, off-site areas for signs of impact. When inspecting discharge points from the site, if it appears that sediment is leaving the site, walk downstream to document the extent of travel and impact on receiving waters or storm drain systems. Note on the inspection form all environmental impacts and document with photographs if needed. If needed or required, collect samples of stormwater discharges from a construction site at the locations specified in the erosion control plan.

Inspect perimeter controls. Note the type of perimeter controls installed at the site, and whether these have been properly installed and maintained. Note if any perimeter controls need to be replaced. Inspect the construction exit to determine if there is excessive tracking of sediment from the site. Is there evidence of additional construction exits being used that are not in the plan or are not stabilized? Check all sediment controls. All storm drains must be protected and temporary stockpiles must have sediment controls installed.

Compare BMPs in the plans with construction site conditions. Are all BMPs required by the plans in place for the current phase of construction? Are additional BMPs needed? Evaluate whether BMPs have been adequately installed and maintained. Describe in your notes the potential violations and their location. Look for areas where BMPs are needed but are missing and are not included in the plans.

Inspect disturbed areas not currently being worked. All exposed soil areas must have temporary stabilization initiated whenever any construction activity has ceased on any portion of the site and will not resume for a period exceeding 14 calendar days. Note any areas that may require temporary stabilization.

Inspection Report Preparation

Make sure all observations and deficiencies are recorded on the inspection report. Also, note any maintenance that was performed since last inspection. Debrief the person in charge. Explain the results of the inspection and answer any questions and concerns. Explain the identified deficiencies and any areas of concern (reports are missing, inspections are not being done, silt fence was down, sediment leaving the site, etc.). Lastly, if it appears additional BMP’s may be needed, don’t tell the contractor which BMP to use. Explain the problem or the permit requirement that must be met, and describe how other construction sites have addressed typical problems. It’s OK to tell the contractor about what typically works and what doesn’t work in the field, but don’t specify the BMP to use (especially if it is a proprietary BMP). Ultimately, it is up to the contractor to decide which BMPs to use. If the contractor is not sure, recommend that the design professional on record be contacted to revise the erosion control plan.

Common compliance problems at construction sites

  • No temporary or permanent cover where needed or required. All exposed soil areas must be stabilized no later than 14 days after the construction activity in that portion of the site has temporarily or permanently ceased. Ask the contractor when particular exposed slopes were last worked to help you determine if there is compliance.
  • No sediment controls on site. The NPDES permit requires sediment control practices (e.g., sediment traps/basins, silt fences or sediment barriers, check dams, etc.) installed before land disturbing activities begin.
  • No inlet protection. All storm drain inlets that receive a discharge from the construction site must be protected before construction begins, and must be maintained until the site is stabilized. Inlet protection may be removed for a particular inlet if a specific safety concern has been identified.
  • No BMPs to minimize vehicle tracking on public right of way. Vehicle exits must use BMPs such as stone pads, concrete or steel wash racks, or equivalent systems to prevent vehicle tracking of sediment or mud off-site.
  • Sediment on the road. If BMPs are not adequately keeping sediment off the street, then the permit requires tracked sediment to be removed (e.g., street sweeping).
  • Improper solid waste or hazardous materials management. Solid waste must be disposed of properly, and hazardous materials (including oil, gasoline, and paint) must be properly stored (which includes secondary containment).
  • Concrete washout. All liquid and solid wastes generated by concrete washout operations must be contained in a leak-proof containment facility or impermeable liner. Area must have a sign.

For decades, HB NEXT has been serving construction firms in the areas of stormwater compliance. Contact HB NEXT for SWPPP / NPDES inspections at your next jobsite.

 

 

Proper Development and Implementation of Site-Specific Safety Plans

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Ever heard this?

“Our company safety manual has been written specifically for and tailored to (Name of Company).  The safety manual addresses the hazards anticipated on this project. If any other hazards arise or other hazards are identified, (Name of Company) will submit an updated Site-Specific Safety Plan.”

These words succinctly explain a procedure that is used by many employers serving in a Subcontractor role to satisfy requirements of their General Contractor Client.  It’s a procedure designed to identify and control unexpected hazards on a project—hazards to which the contractor’s employees wouldn’t normally be exposed.

For decades, HB NEXT has assisted construction firms in properly creating their safety manuals and their site-specific manuals. This sometimes involves guiding these firms as they work to become and remain compliant with their Client and regulatory requirements.

The Site-Specific Safety Plan is not intended to be—nor should it be—a regurgitation of the company’s overall safety program.  There’s nothing truly ‘site-specific’ about reprinting a manual and changing the cover sheet to reflect the project name and address.  An SSSP should be an exercise in evaluating the scope of work for a project and putting a plan in place to protect employees from hazards unique to that project, that they might not normally encounter.

Keys to developing a smart, usable, and generally acceptable SSSP include:

  • Thorough evaluation of the scope of work
  • Identification of the employees who will be working on that project and make sure they have the necessary training
  • Communication with clients and employees to make sure that specific procedures for that project are understood by all involved
  • If a GC Client has specific unique procedural requirements, this is the time to learn and understand and decide if your company can live by them

So the question to ask, is your site-specific safety plan assembled correctly? Ask HB NEXT to review your plan and make sure your firm is staying compliant. HB NEXT offers many safety compliance services to keep your employees safe.

Draft Changes to the Georgia NPDES Construction Stormwater Permit

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On December 15, 2017, the Georgia Department of Natural Resources – Environmental Protection Division (EPD) issued their draft NPDES Construction General Permit. If approved, the new permit will go into effect August 1, 2018.

Below is a summary of relevant changes:

  • As a result of the EPD’s implementation of the NPDES electronic reporting rule, ALL
    Notices of Intent (NOI), modifications to existing NOI’s, and Notices of Termination
    (NOT’s) MUST be submitted through the EPD’s electronic submittal portal:
    https://geos.epd.georgia.gov/GA/GEOS/Public/GovEnt/Shared/Pages/Main/Login.aspx.
  • The EPD is in the process of developing an electronic method of submitting water
    sampling reports via the electronic submittal portal. Notifications will be sent once this method is completed.
  • Plans required to be submitted directly to the EPD for review must now be submitted electronically via the electronic submittal portal or as a PDF file on a CD-ROM or other
    storage device.
  • The “self-reporting” of permit violations to the EPD has been clarified as follows:
    • Whenever a BMP has failed or is deficient and has resulted in sediment
      deposition into waters of the state, that constitutes a violation and a summary of
      that violation must be submitted to the EPD.
    • If the BMP that resulted in the sediment deposition does not require a new or
      replacement BMP or significant repair, the BMP must be repaired by close of the
      next business day from the time of discovery.
    • If the BMP that resulted in the sediment deposition requires a new or modified
      BMP or significant repair, the BMP must be operational by no later than 7
      business days from time of discovery.
  • Rainfall must be measured and recorded within the disturbed areas of the site that have
    not met final stabilization once every 24 hours except any non-working weekends and
    holidays.
  • Coverage under the infrastructure construction permit (GAR100002) is not required for
    construction projects that consist solely of the installation of cable barriers and guardrail
    within existing rights-of-way, and the installation of buried utility lines.

The public commenting period is 30 days from the date of the public notice. A public meeting regarding the draft permit is scheduled for January 31, 2018. The content of the comments and results of the public meeting may alter these proposed changes. Contact HB NEXT for any other questions pertaining to Storm Water or Environmental Services.

2017 OSHA Regulation Changes Review

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2017 saw a year of changes and modifications to OSHA regulations as the safety industry tries to support the labor workforce in keeping their work environment a safe place to be. HB NEXT is committed to supporting construction firms in understanding and complying with OSHA regulations. HB NEXT Senior Instructor/Consultant Raymond Scott reviews some of the 2017 OSHA changes.

  • The year saw the end of the silica controversy and the adoption of the new standard.  We have seen the industry struggle to even come close to achieving the new standard.  Fortunately, OSHA gave us the T-1 table. If followed, this relieves us of meeting the standard. The first round of lawsuits were concluded Dec 22, 2017, with the courts upholding OSHA. For the time being, we are stuck with the standard. The biggest issue may lie in the B-reader test being used. This is the same procedure used in “black lung” and asbestos testing.
  • Subpart CC had the operator certification pushed to November 10, 2018.  Note, this does not relieve the employer from the responsibility of ensuring operator training.
  • Residential construction continues to be OSHA’s focus with over 6000 fall protection citations issued to home builders.
  • Electronic reporting of form 300a got off to a slow start due to technical issues on OSHA’s end with the filing date extended to December 15, 2017.  Next year, we will have until July 16, 2018. Moving on from 2019, we will have to meet the original March 2 deadline.
  • OSHA has finally recognized the importance of safety training for first and second line supervisors in leadership. It is sorely needed, and they are encouraging it in their Outreach Training 500, 502 Classes.
  • We have seen OSHA starting to push the residential industry to address attics and crawl spaces as confined space.
  • With the new administration’s pro-business approach, we expect to see a slowdown in new regulation over the next few years with a possible review of existing rules.

Staying abreast of OSHA regulation changes is critical to providing a safe work environment and minimizes the impact on project budgets before fines are imposed. HB NEXT is here to serve in a support role for construction firms’ safety and compliance business units. Contact HB NEXT today for any questions regarding your OSHA compliance situation.