Now let us dive into what is being cited and what you can do to prevent injuries and avoid these citations.

1. Injury and Illness Protection Program (IIPP)

Contractors are cited for not having a written IIPP, having an IIPP that is not implemented or effective, or not having all the required elements in the IIPP. This often comes from failure to identify or correct hazards. Do good inspections where you find hazards and document that you correct them. Recordkeeping is cited often too. [Construction Safety Order (CSO) 1509 and General Industry Safety Order (GISO) 3203]

2. Heat Illness Prevention Program (HIPP)

Citations are for not having a written Heat Illness Prevention Plan (HIPP), having a HIPP that is not implemented or effective, or not having all the required elements in the HIPP and training program. Failure to provide or replenish water is also frequently cited. Review your written program and training to make sure they have all the required elements. New regulations also require heat illness protections for indoor work so if you have not added these requirements to your HIPP now is the time to do it. [GISO 3395 and now 3396]

3. Fall protection

The number one citation is not using fall protection when it is required. Other issues include improper use: using insufficient anchor points installing manufactured anchor points incorrectly; sliding the rope grab to the end of the lifeline, or improper installation or makeshift horizontal lifelines. Decisive enforcement and training are the keys. Your employees must know there is no compromise on fall protection. Make them understand the effect a fall would have on them and their family. And they need the best training to make it happen. One final issue is using a fall protection plan without proving conventual fall protection cannot be used. [CSO 1670 and 1671.1]

4. Reporting Serious Injuries

Failure to report a death, or an injury or illness that requires inpatient hospitalization for other than observation or in which an employee suffers an amputation, the loss of an eye, or any serious degree of permanent disfigurement to Cal/OSHA within 8 hours. Train foremen, superintendents, admin, and HR in reporting requirements. It is a stressful time so the more people who know, the more likely someone will remember to report. [Title 8 Section 342]

5. First Aid Kits and Training

Not having enough, or no, people current in first aid training. This training is required every two years. View First Aid/CPR training as an employee benefit and offer it to everyone. First aid kits are a consumable item and must be replenished or replaced regularly. [CSO 1512]

6. Ladders

Not inspecting or using ladders and not training employees on their inspection and use. The instructions and training material are stuck on the ladder; what an easy tailgate. Ladders must be inspected “frequently” which technically means at least 13 times a year. The ladder user must inspect it at the beginning of each shift, but you should also do more thorough documented inspections at least monthly. Common misuses include using the wrong type or length of ladder, climbing too high and leaning step ladders. Using lean safe ladders goes a long way on that. [GISO 3276 and CSO 1675]

7. COVID Procedures

The COVID regulations expired earlier this year, so this is not something you need to worry about. Cal/OSHA is working on a general Infectious Disease Standard and NCAT will keep you informed when this happens.

8. Personnel Protection Equipment

You must conduct a PPE assessment, provide the required PPE, and ensure the employees use it. A frequent problem is employees taking hardhats, or other PPE, off a work location where there is no hazard and forgetting to put it back on when they go out to the larger site. Safety helmets solve many of the reasons employees take off their hardhats and more general contractors are requiring them. [CSO 1514 and GISO 3380]

9. Written Code of Safe Practice

The Code of Safe Practices is a set of worksite rules that stipulate how to perform job duties safely and to keep the work site safe. Every contractor must develop and adopt a written Code of Safe Practices. It must be specific to the employer’s operations. The COSP is a great source for tailgate topics. [CSO 1509(b)]

10. Posting Code of Safe Practice

The COSP must be posted at each job site office or be readily available at the job site. A common mistake is keeping it in the foreman’s truck, but if the foreman is sick or leaves the site, you are out of compliance. [CSO 1509(c)]

Take some time to ensure your safety programs address these topics in tailgates. Training is a common theme, but training must be practicable and understandable. Bad training covers the rules, good training teaches employees how to work safely. The Safety Orders referenced can be found at https://www.dir.ca.gov/samples/search/query.htm.