Background:
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.
Action:
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 fall 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.
Procedures:
- 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 clearing.
- 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
inspections.
- 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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