By: Thomas H. Welby Published: December 2013

Safety Policy - A Key Safety Practice: The Site-Specific HASP

There’s good news and bad news from recent studies of construction-industry fatalities from 2006 through 2011.  The bad news is that, while annual fatalities have dropped by almost half, that drop corresponds almost exactly to reduced levels of construction activity nationwide.  The good news is that, despite difficult economic conditions, most construction employers are maintaining — and many are increasing — their commitment to employee safety.

Construction remains highly dangerous, and much remains to be done in enlightening industry players concerning the benefits of having a comprehensive safety program, integrated with virtually all aspects of the employer’s business.  In addition, however, to a continued commitment by most employers, and increasing sophistication in addressing safety concerns (more evident in larger companies) there are trends in play that offer some promise of improved safety performance.  Among these trends are the increased use of BIM (building information modeling) software; collaborative design, which involves general contractors and, in some cases, subcontractors, in project design; and the proliferation of Smartphones, tablets, and other mobile devices on jobsites.  An additional trend, reported as reducing jobsite injuries, is the increased use of prefabrication and modularization.  Yet another major trend, whose implications for safety have yet to be fully evaluated, is the growing use of new and unfamiliar processes and technologies, to achieve “green” project goals.

Studies show substantial differences in safety practices as between general contractors and specialty or trade contractors, and as between larger companies and smaller companies.  General contractors, and larger companies, are markedly more likely than specialty contractors, and smaller companies, to employ most of what are seen as best safety practices on construction projects.  While there is, of course, a rough correspondence between the categories of “larger companies” and “general contractors,” as GCs tend to be larger than specialty contractors, trades that must work closely with other trades (erection, mechanical, electrical) tend to behave somewhat more like general contractors with regard to safety matters, regardless of size.

The explanation, of course, is that GCs and larger firms have more resources than most specialty and smaller contractors, and GCs, especially, have a higher degree of legal responsibility, under OSHA and most states’ laws, as they have overall control over, and responsibility for, the jobsite.

While it is probably unreasonable to expect that specialty contractors will match the full range of safety practices increasingly seen in large companies, the proverbial carrot and stick will, I suspect, result in increased efforts by such companies in the coming years.

The “stick” is that owners, insurers, general contractors, and construction managers are all seeking improved safety performance.  Pressures are being exerted — and will probably increase — to require greater selectivity in choosing subcontractors.  Specialty contractors with bad accident (or OSHA) histories are already finding it harder to get work, on both public and private projects.  In the near future, they will likely be required to show not only acceptably low numbers of reportable injuries and OSHA violations, but affirmative efforts to implement practices now more common among larger companies.

Improving specialty contractors’ efforts will not necessarily be unduly painful or costly.  For one thing, certain practices in which specialty contractors lag far behind general contractors don’t cost a lot of money to implement:  it’s largely a matter of education and leadership.  One such practice is the so-called “open-door” policy, in which all employees are actively encouraged to report unsafe conditions not just to immediate supervisors, but to senior management.  Another is the conduct of meaningful incident and “near-miss” investigations.

Another reason to think that smaller companies’ safety efforts can more nearly approach those of larger companies is that the smaller companies, and specialty contractors, are already doing a number of things well, and those practices, and the positive attitudes underlying them, can be built upon without undue effort.  To give just one example, although budgetary reasons make it impracticable for many smaller companies to employ full-time safety personnel, employees in small companies often take on a wider range of roles.  Often, the rank-and-file in smaller companies are more involved in the safety management process than in larger ones.  Thus, while full-time, specialized safety employees are desirable, many smaller companies, unable to afford them, instead get more of their workers actively involved with safety management and planning.

An additional trend that mitigates smaller companies’ and specialty contractors’ disadvantages and shortcomings in the safety realm is the expanded use of Site-Specific Health and Safety Plans (HASPs).  A site-specific HASP is a comprehensive written plan, created as part of the design process, usually (and desirably) with substantial input from the general contractor and the primary trades.  It’s a practice that originated, some years back, for projects that included known or suspected hazardous waste activities.  OSHA mandates a HASP on such projects, and has standards for the training and qualifications of persons carrying out hazardous waste activities.

A site-specific HASP is a powerful tool for identifying project-specific hazards, and communicating and coordinating how they are to be addressed throughout the course of a project.  While it’s still optional on most projects, in recent years a number of government entities (e.g., the Port Authority of N.Y. and N.J., the U.S. Department of Energy, and the U.S. Army Corps of Engineers) have come to require them on all significant projects.  A benefit of the expansion of the practice is that seldom must a site-specific HASP be devised “from scratch.”  Instead, the owner, design professionals, general contractor, major trades, and safety consultants (the latter to include, in more complex cases, a Certified Industrial Hygienist or Certified Safety Professional) begin work from a template, and tailor it to the specific needs of the project.

Although the defining characteristic of a site-specific HASP is that it varies according to the nature and peculiar characteristics of the project, virtually all plans have detailed information concerning the identification, prevention or control of hazards, safety and health training, and how the effectiveness of the HASP is to be evaluated.

One recent survey of more than 250 contractors revealed that, among the safety practices found to be most effective in increasing project safety, both general contractors and specialty contractors agree that the use of a site-specific HASP ranks as #1.  Roughly three-quarters of the larger companies surveyed, and more than three-fifths of the smaller companies, are using them on at least some of their projects.

Among the many benefits of a site-specific HASP is that, since usually safety professionals, industrial hygienists and engineers will be involved in its preparation, both those subcontractors (if any) as are directly involved in preparing it, and those who are not, will have the benefit of knowledgeable analysis, and advance warning, of hazards requiring an added degree of attention and, possibly, special precautions on the project to be performed.  This compensates, in part at least, for the fact that many trades are less likely than the general contractor to have full-time safety personnel, or one or more such personnel (if they employ any) devoted solely to that project.

There are a number of sources of “templates” for the site-specific HASP, one of which is OSHA:   (www.osha.gov/dep/etools/ehasp).

The quality and effectiveness of a site-specific HASP can only be enhanced by developing it in tandem with a thorough analysis of potential safety hazards during pre-construction, and with the participation of key trades (erection, electrical, mechanical and possibly others) in addition to the general contractor.  Care in organizing and editing the document, with an eye to making it useful by the use of appropriate headings and clear language, will also increase its value.  Another idea worth considering is having it online (in whole or in part) and at all times available via Smartphone, tablet, or other type of electronic device, as are presently burgeoning on construction jobsites.  One can imagine circumstances in which having, for example, emergency response information available to everyone on site with a Smartphone, and not just posted at a single location, could make a life-or-death difference.

General contractors on projects adopting site-specific HASPs should be in touch with their area OSHA office, as OSHA offers special advantages to companies that employ this tool, and maintain injury and illness rates below BLS averages.

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