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By: Thomas H. Welby Geoffrey S. Pope Published: June 2019

Key Elements of a Health and Safety Program for Demolition Operations

In Miami, a condominium building being demolished collapsed suddenly, and a construction worker had his leg severed when he was struck by a “boulder” the size of “the front end of an SUV.”

In New Jersey, a construction worker was trapped and killed, when the last remaining wall of a building under demolition collapsed on top of him.

In Philadelphia, OSHA attributed the unexpected collapse of a four-story building that killed six, and injured fourteen, to the removal of structural supports early in the demolition.  The contractor was charged with third-degree murder and involuntary manslaughter.

In Connecticut, a contractor was hit with almost $200,000 in penalties, when OSHA found it had failed to brace the building’s walls while removing flooring on the upper levels of a building being demolished, had exposed workers to falls of up to 36 feet due to unguarded wall openings, and had taken inadequate measures to protect employees from lead.

Building demolition is not for the careless or the unskilled.  Its perils include collapses, falls, dust, hazardous materials, and dangerous levels of noise.

Before undertaking any demolition operations, you must, first, become thoroughly familiar with subpart T of 29 C.F.R. 1926, “Demolition” (and train your employees correspondingly).

Additional OSHA construction standards that must be integrated into your health and safety program and training for demolition include all or the applicable parts of the following:

  • Subpart D, Occupational health and environmental controls (especially the section on lead);
  • Subpart E, Personal protective and lifesaving equipment (especially the sections on head, hearing, eye and face, and respiratory protection);
  • Subpart J, Welding and cutting (especially the section on gas welding and cutting);
  • Subpart K, Electrical (especially the sections on wiring methods and components (temporary power), general requirements for safe work practices, and lockout and tagging of circuits);
  • Subpart L, Scaffolds (general requirements);
  • Subpart M, Fall protection (duty to have fall protection, systems criteria and practices, and training requirements);
  • Subpart P, Excavations (scope, application and definitions; specific requirements, and requirements for protective systems);
  • Subpart Z (Toxic and hazardous substances (in particular, asbestos); and
  • Subpart CC (Cranes and derricks in construction).

Another key resource is “Safety and Health Program Requirements for Demolition Operations,” ANSI/ASSP A10.6-2006 (R2016) which, while lacking the legal force of OSHA standards, is still authoritative.  (Available for purchase and download on the American Society of Safety Professionals website.

By far the most frequently cited OSHA violation relating to demolition is failure to comply with § 1926.850(a), which mandates that, before employees may be permitted to begin demolition operations:

. . . an engineering survey shall be made, by a competent person, of the structure to determine the condition of the framing, floors, and walls, and possibility of unplanned collapse of any portion of the structure.  Any adjacent structure where employees may be exposed shall also be similarly checked.  The employer shall have in writing evidence that such a survey has been performed.

The required pre-demolition survey must also ascertain the presence and location of lead, asbestos, and other hazardous substances.

Rounding out OSHA’s “Top 5” citation items relating to demolition are inadequate fall protection, the improper shoring or bracing of walls, insufficient inspections of stairways and ladders, and the failure to test for, and remove, hazardous materials.

If “any type of hazardous chemicals, gases, explosives, flammable materials, or similarly dangerous substances” has been used on the property, or is suspected of being present, testing and purging must precede demolition.  All utility service lines must be shut off, capped, or otherwise controlled, and the service providers notified.  If any utilities are to be maintained during demolition, the lines must be temporarily relocated and protected.

Another key preparatory step is the erection of an overhead shed or canopy, to provide safe ingress into the structure to be demolished, and protection from falling objects. Any multistory building must be protected for a minimum of 8 feet from the perimeter.  Canopies must be at least two feet wider than the building entrance, and capable of sustaining a load of 150 pounds per square foot.

Employees on walking/working surfaces must be protected by covers, guardrail systems capable of withstanding a force of at least 200 lbs., or personal fall arrest systems against falls through holes six feet or more above lower levels.  There must also be installed covers to protect against objects falling through holes.

Wall openings must be protected to a height of 42 inches, wherever there exists the danger of employees falling through them.

Floor openings not used as material drops must be covered with material substantial enough to support the weight of any foreseeable load, the covering to be secured to prevent accidental movement.

Access ways to the building interior must be kept closed at all times, excepting designated stairways, passageways and ladders.  These must be periodically inspected, and maintained in a clean safe condition.  Where a stairwell is being used in a multistory building, it must be well-lit, and completely and substantially covered over at a point not less than two floors below where work is being performed.  Access to the floor where demolition is in progress shall be via a separate, protected, and well-lit passageway.

Where chutes are employed, openings must be protected by a guardrail 42” above the floor, and gaps between the chute and the edge of openings in the floors solidly covered over.  Except at ground level, chute openings must be kept closed when not in use.  Nothing may be dropped to any point lying outside the structure’s exterior walls, unless the area is effectively protected.  A toeboard or bumper, at least 4” thick and 6” high, must be securely installed at each chute opening at which material will be deposited into chutes by wheelbarrows or mechanical equipment.

Where debris is to be dropped through holes in the floor without the use of chutes, the area onto which material is to be dropped must be completely enclosed, with barricades not less than 42 inches high, and not less than 6 feet back from the projected edge in the opening above.  Signs warning of the hazard of falling materials must be posted at each level.  Debris must not be removed from the lower area, until debris handling above has come to a halt.

At or near the discharge end of each chute, a substantial gate must be installed, and monitored by a competent employee

Except for work such as cutting holes through which to drop materials, the demolition of exterior walls and floor construction shall proceed downward from the top of the structure, work on each story to be completed, before work on the next floor below begins.

Where floor arches are being removed, the area directly below must be barricaded against access, and employees kept out of it.  Notwithstanding the closing-off of the lower level, it’s still necessary to verify that no one is present there, before the arch removal proceeds.

As demolition proceeds, “continuing inspections by a competent person shall be made to detect hazards resulting from weakened or deteriorated floors, or walls, or loosened material.  No employee shall be permitted to work where such hazards exist until they are corrected by shoring, bracing, or other effective means.”

In addition to all OSHA requirements, demolition work in New York City is subject to all requirements under the City Council’s 2017 enactments requiring a “primary construction superintendent” and “site safety plan,” and OSHA training and Site Safety Training cards for employees.

The foregoing is not a complete list of elements that need to be in your planning and safety program for demolition operations, but it covers much of the ground.

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