With full enforcement of OSHA’s new rule for construction work in confined spaces set for October 2, 2015, construction firms large and small need to understand their roles and responsibilities for communicating safety hazards at construction sites.
Understanding the roles of all parties involved is an essential element of hazard communication. It’s sometimes unclear, even for seasoned construction pros.
The three basic roles, as defined by OSHA, are:
This is usually the owner of the site, but may be a firm representing the owner, such as a general contractor.
This party manages the job site as a whole, including firms hired for specific work. In many cases, the controlling employer is the GC.
Affecting or Exposing Employer
Commonly a subcontractor, this is the company or person that tasks individuals with carrying out work at the job site and providing direct instruction to the worker.
The lines between roles often get blurry. For example, when the property owner is also the general contractor, this firm could be the host employer, controlling employer and, if their employees are completing the work, the affecting employer as well. Knowing your role on a job site is the first step on understanding your responsibilities and liabilities.
Every employer and individual is responsible for reporting hazardous behaviors and conditions on a job site. Hazards should be reported to the controlling employer who, in turn, is responsible for distributing this information to the host employer and all affecting employers. The controlling employer is usually responsible for the corrective plan, which they may develop and carry out, or assign the task to an affecting employer. The controlling employer must effectively communicate policies and procedures that mitigate hazards, especially if they have intimate knowledge of the equipment/material being worked on by the affecting employer.
The case of confined spaces in construction where identifying hazards early may be difficult, the affecting employer should provide the controlling employer with an entry program and account of hazards identified with the controlling employer communicating the onsite confined spaces.
All parties on a job site are responsible for keeping the work environment safe, and not creating new hazards.
Understanding roles and responsibilities on a job site is the first step toward minimizing risk to workers and liability for your firm. In the event of an incident, your role and how you executed your responsibilities will be the primary measure in determining if a citation or other punitive action is warranted.