Citation Violations OSHA Case Study
Consider the scenario below.
Imagine you are the safety representative on a project with multiple trade activities happening all at once. The project is behind schedule, and the project team is pushing to catch up. There is a concrete pour scheduled for 2:00 AM the next day for the fourth floor in the west wing, and this might help get the project back on track.
West wing : In the west wing, the steel has been set, columns have been poured, and the floors are going in. The subcontractor (Apple) concrete workers are sharing the tower crane with the steel erector subcontractor (Berry) to set the floor decking material, and the rebar crews are busy reinforcing steel to get ready for the next floor pour scheduled for 2:00 AM. The mobile crane is lifting rebar and lumber to the floor. Access to the floor is through an extension ladder, which is moved as the reinforcing steel is completed section by section. There are many piles of scrap lumber, reinforcing steel, and wire on the deck; these will be removed at the end of the day by using a forklift to provide a skid pan (mini-dumpster) to load it all in.
East wing : In the east wing, which is further along, the floors have been poured, and the roofing subcontractor (Cherry) is working to close it in. There is ladder access between the floors, as the stair pans have not been poured yet, and there are no handrails or stair rails in place. The workers, however, keep going under the danger tape to take a shortcut up the stair pans.
Also in the east wing , the heating, ventilation, and air conditioning (HVAC) subcontractor (Dates) is beginning to install the vertical ductwork, which requires the hole covers in the floors to be removed. The electricians (Elderberry) and plumbers (Figs) are working from ladders to install overhead wires and plumbing lines, and they are sharing whichever ladders are most convenient.
In the portion of the east wing that has been roofed over, the curtain wall (glass) installers (Guava) have removed the guardrail to install the glass, using an aerial lift. The carpenters who work for the general contractor (Honeydew) have not been notified that the guardrails have been removed.
The masons (Kiwi) are working from a scaffold to set the brick on the decorative columns that will separate the sections of the building’s face. The roofers (Cherry) are working on the standing seam roof and must traverse the entire roof section.
Site wide : There is also one tower crane onsite that belongs to the steel erectors and one mobile crane that belongs to the concrete subcontractor. The tower crane operator is out sick, and the other crane operator belongs to the concrete crew. He normally uses a mobile crane to lift rebar and lumber to his crew but states he has experience with tower cranes, and he has agreed to lift steel beams to the connectors in the east wing when they need them.
Additionally, there are multiple forklifts moving material around the site, there are some track hoes belonging to the site contractor (Lemon) working on excavations, and there are also dump trucks removing the excavated material from the site.
Workers from all trades are moving throughout the entire site all day. Suddenly, you receive a call from the project manager, who is in the office trailer. The Occupational Safety and Health Administration (OSHA) inspector has arrived onsite as a result of a complaint. It is not clear who made the complaint; however, it does mention that the roofers have dropped material into the masonry access zone below. The inspector will have to pass through the entire site to reach this area.
Draft a response that answers the questions below.
What would your plan consist of for meeting with OSHA?
Using the scenario above and OSHA’s multi-employer policy directive, for what types of violations and which standards could OSHA use to cite, and to whom would the citations be issued? List which contractor(s) and whether they are Controlling / Exposing / Creating / Correcting. Why?
After the OSHA inspection, what would be your next course of action to correct these violations? What would your response plan be?
*Note that you can click on the name of each wing or area for a diagram of the activities that are going on in that area.
Your response should be three pages in length, not counting the title or reference pages.