Why Effective Jobsite Training Does More Than Promote Safety— It Makes OSHA Happy

Jobsite training is one of the most important things I stress in my business. I care about my workers and their health, plain and simple. Being safe on the jobsite isn’t just about reading a safety manual, signing off on it on the first day, and going about the day as usual. I’ve said it time after time—remembering what one learns in the training process is paramount for jobsite safety, and you must have continuous training in order to make a training system work. Moreover, creating a culture of safety within a company, from the owner on down, is the ultimate goal in my business and the primary goal of the National Framers Council (NFC). The record isn’t broken; it’s on repeat for a reason.

During the month of June, NFC’s long-awaited Site-Specific Fall Protection Plan will roll out for FrameSAFE subscribers. I want to take some time to talk about how the plan should be used. It’s important to remember this site-specific plan is just one piece of the FrameSAFE manual, and as such, when training employees, begin by reviewing the entire manual with them. You don’t start reading a book in the middle, and the same goes for a safety manual. Reviewing the entire manual allows employers to answer questions and highlight big-picture topics they wish to stress. Furthermore, roles and responsibilities outlined in the fall protection plan are defined earlier in the FrameSAFE manual, and understanding those roles and responsibilities is key to complying with the site-specific aspect of the plan.

Once the manual has been covered in its entirety, share the scope of the fall protection plan with employees based on the tasks to be performed on a particular jobsite. We recognize not every framing crew performs the topics covered in the site-specific plan, which is why we’ve made it a pick-and-choose document to craft for each crew and each jobsite. Employers can select the framing process applicable to their crew and site, while excluding those areas not relevant to them.

Last, but not least, review the terminology used in the manual. This may seem redundant, but after my 40-plus years in the industry, I’ve learned to never assume a word means the same thing from one general contractor to another. Of concern on today’s jobsite is the communication between English- and Spanish-speaking workers. Aside from the obvious differences, many times Spanish-speaking crews begin to use English words interchangeably or even create “Spanglish” versions. The same goes for OSHA terminology; OSHA talk is not the talk you hear on the jobsite. Overcome this by teaching and re-teaching terms and situational words to make communication on the jobsite and between framing crews and code officials consistent.

The culture of safety I mentioned will lead to fewer accidents and injuries because employees will be aware of safety, communicate well with one another, and the jobsite will be clean and orderly. The positive side effect of having a safe, clean jobsite becomes apparent when OSHA inspectors pay a visit. All too often, framers overlook the possibility of an inspection, so I want to take a moment to review the standard operating procedure when an OSHA inspector visits a jobsite. 

OSHA selects inspection sites based on imminent danger situations, sites with known fatalities or catastrophes, sites with a history of complaints, referrals, follow-ups and pre-planned general investigations. Once on the site, an inspection will follow these steps:

• Presentation of credentials: The OSHA inspector will ask to speak with the individual in charge and will identify themself by supplying their credentials.
• Opening conference: The inspector will hold a conference explaining the reason for the inspection and define the scope. The individual in charge of the site will be required to select a representative (or him/herself) to accompany the compliance officer as the jobsite is inspected.
• Walk-around inspection: The inspector will visit each of the areas within the scope of the inspection or specific areas of concern. The inspector will also review jobsite records including, but not limited to, permits, licenses, employee training/certification, etc.
• Closing conference: The inspector will report any findings with the individual in charge and describe what courses of action must be taken to become OSHA compliant. Citations resulting in financial penalties will be shared and directions will be given with regard to payment.

A common misconception among workers during an inspection is that it’s best to just leave the jobsite. You know the drill: “OSHA’s coming!? Better get out of here!” Leaving is the wrong thing to do. It looks bad to the inspector, and it costs the employer a day’s worth of work. A more productive response is to take the time to clean up the jobsite prior to the inspector’s arrival, if it’s known the inspector is coming. Put away unused tools, straighten materials, clear a path for easy access during inspection and address unsafe areas. Above all, be cooperative, patient and pleasant when the inspector is on site; these things make an impression and are viewed favorably. It’s just good business to be professional.

Finally, it is a good idea to take the time to review these procedures before an inspector arrives on site.

Being safe is everyone’s responsibility, but the only way to help employees help themselves is through training, and training is only as good as its mode of delivery. To that end, looking forward, NFC is working on a new stand-alone supplement called Activity Hazard Analysis. These will be short, one-page summaries of risk assessments of each task to be performed on any jobsite. Known hazards, controlling (limiting) factors, equipment to be used, training requirements, and inspection requirements will be identified, and employees will be expected to review the analysis for each task. This is an easy way not only to capture all the pertinent hazards on a jobsite, but also provide everyone on the site with an overview of what they need to know. 

I covered a lot of topics in this month’s NFC article, but there’s been a lot happening. We’ve got more coming up, and it’s going to be an exciting summer. Let’s all do our best to make it one of the safest and most successful seasons ever!