MIOSHA
Construction Safety and Health Division
Michigan Occupational Safety and Health Administration
Department of Licensing and Regulatory Affairs
DOCUMENT IDENTIFIER:
CSHD-COM-09-1R2
SUBJECT: Construction Inspection Targeting
DIVISION
INSTRUCTION
DATE:
September 14, 2015
I.
Purpose. This instruction establishes the Michigan Occupational Safety and Health
Administration (MIOSHA) Construction Safety and Health Division (CSHD) programmed
inspection targeting plan for the construction industry.
II.
Scope. This instruction applies to MIOSHA CSHD field enforcement operations.
III.
References.
A.
MIOSHA Strategic Plan for FY 2014-2018, Emphasis 1.3A and 1.3B.
IV.
Distribution. MIOSHA Staff; OSHA Lansing Area Office; General; S-drive Accessible;
MIOSHA Weekly; and Internet Accessible.
V.
Cancellations. All previous versions of this division instruction.
VI.
History. History of previous versions include:
CSHD-COM-09-1R1, October 30, 2012.
CSHD-COM-09-1, October 5, 2009.
VII.
Contact. Lawrence Hidalgo, Jr., Director
VIII.
Originator. Lawrence Hidalgo, Jr., Director
IX.
Significant Changes.
X.
A.
Added section XIII Programmed Inspections using Building Permits to allow field
compliance staff to obtain and use building permit lists for targeting inspections.
B.
Revised section XIV. B. Programmed Inspections of Asbestos Projects.
Background. Due to the mobility of the construction industry, the transitory nature of
construction worksites, and the fact that construction worksites frequently involve more
than one construction employer, CSHD has developed a programmed inspection targeting
plan for conducting inspections at construction worksites. CSHD will provide a list of
active construction projects to construction field compliance staff statewide for each area.
Field compliance staff may also obtain a list of active construction projects from state and
local governmental agencies that issue building permits.
A.
The programmed inspection targeting plan relies upon a statistical abstract of
information available on construction project start-ups from F. W. Dodge and on
estimated construction project durations derived from econometric modeling. The
targeting plan is designed to get compliance staff on-site at neutrally selected
projects when they are between 30 percent and 60 percent complete, the time when
CSHD-COM-09-1R2
September 14, 2015
Construction Inspection Targeting
the greatest number of employees and contractors are expected to be on the
construction site.
XI.
B.
The MIOSHA Strategic Plan identifies construction SIC code groups 15, 16, and 17
(North American Industry Classification System 23) as high hazard industries for
targeting purposes. The CSHD assigns programmed inspections at construction
sites from Dodge Reports provided by the University of Tennessee. The University
of Tennessee has a contract with federal Occupational Safety and Health
Administration (OSHA) to use Dodge Reports published by McGraw Hill, to
identify active construction sites for inspection targeting.
C.
The CSHD Dodge Report System (DRS) is designed to provide timely information
on known active construction projects, including the project’s location and contact
employer. The DRS is designed to be a broad-based system that selects projects
randomly in a way that establishes a presence in the construction industry statewide.
Targeting systems intended to address specifically identified hazards or a narrow
range of construction activity are developed as Local Emphasis Programs or Special
Initiatives.
D.
Field staff can access a local copy (most current three-month information) of the
DRS which allows them to search for active construction projects on their own or
when assigned inspections for program targeting. All information will be
accessible when connected to the central database.
DRS Procedures.
A.
B.
Dodge Report Coordinator (DRC).
1.
All users will be assigned a username and password by the DRC, including
field staff, support staff, supervisors, and managers.
2.
The DRC will import an updated list of Dodge Reports from the University
of Tennessee each month. The database will separate them by area, and
deposit into the area lists that reside in the database. Each area list is
overwritten each month with an updated list of Dodge Reports. Dodge
Reports will be removed from each area list after three months; however,
they will remain in the central database. The number of Dodge Report
projects is selected randomly based on the area, workload, and project cost.
3.
An area list audit is to be conducted semi-annually (June and December) by
field staff for inspections that have been issued an Optional Reporting
number. The DRC will send out an email notification to field staff each
time the audit is to be completed. Instructions will also be sent each time
the audit is to be completed.
4.
The DRC will forward the audits to support staff to update the database
when they are completed. The DRC will maintain a folder on the S-drive
after each audit and archived.
Field Staff.
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C.
1.
The DRS can be used either when connected to the S-drive (central
application) or when refreshed, and can be used on field staff’s computer
(local application). The local application will allow the user to look at a
three-month window of any new or open projects downloaded to their
computer for the entire state without being connected to the S-drive.
2.
The database search function allows staff to search by address, Optional
Reporting number, and/or Dodge Report number. The use of asterisks
before and after a street name/partial street name or address will return all
records with the specified information in the entire state. This can be further
narrowed by looking through the records manually on either the local
application or the central application when connected to the S-drive.
3.
Field staff will access the S-drive at least once each month and download
(refresh each month) the Dodge Reports to their computers when notified by
the DRC. Inspection activity that is generated by a Dodge Report or a
strategic plan targeting inspection will be assigned an Optional Reporting
number by the DRS database when the OSHA Information System (OIS)
information is entered.
4.
Field staff will search the jobsite address for each inspection in the DRS
prior to submitting in OIS to ascertain if a Dodge Report number has been
assigned. If found in the search, the Dodge Report number will be entered
in OIS, as State Code, S-518.
5.
Safety field staff will be assigned to inspect a minimum of two Dodge
Report projects in their area each month. The corresponding Dodge Report
number will be entered in OIS as State Code S-518.
6.
Field staff will conduct an audit of their database twice per year as directed
by the DRC. The audit is only for the projects/jobs that have been assigned
an Optional Reporting number.
7.
Since Dodge Reports drop off the area lists every three months, field staff
must copy/save a particular Dodge Report project that they may want for a
future inspection; e.g., larger projects they may not be able to inspect right
away.
8.
Any inspection conducted outside of an assigned work area will be
documented as its original work area. The out-of-area CSHO will inform
the CSHO from the assigned area that an inspection was conducted in their
area. This may be done via email or phone call.
Administrative Staff.
1.
Support staff will add information from OIS to the DRS database.
2.
The search function with the database allows administrative staff to search
by address, Optional Reporting number and/or Dodge Report number. The
use of asterisks before and after a street name/partial street name or address
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Construction Inspection Targeting
will return all records with the specified information in the entire state. This
can be further narrowed by looking through the records manually.
D.
XII.
3.
Administrative staff will enter the information on either the “Add” screen
for all new inspections or the “Edit” screen for existing inspection reports
and any uninspected Dodge Report numbers.
4.
Administrative staff will update the DRS database when receiving the audit
report from the DRC twice per year.
Supervisors.
1.
Supervisors will monitor the area lists and field inspection activity each
month. Supervisors will assign a minimum of two Dodge Report projects
for inspection to each field staff each month as appropriate.
2.
Supervisors are responsible for monitoring field staff for complying with
this instruction.
3.
The search function with the database allows supervisors to search by
address, Optional Reporting number and/or Dodge Report number. The use
of asterisks before and after a street name/partial street name or address will
return all records with the specified information in the entire state. This can
be further narrowed by looking through the records manually.
Strategic Plan Targeting Inspections and Imminent Danger Situations.
A.
The CSHD conducts on-site inspections based on identifying construction projects
in assigned areas, and based on the safety officer/industrial hygienist (SO/IH)
identifying construction projects that are viewed while traveling in their work areas.
This type of inspection is referred to as a strategic plan targeting inspection. When
possible, field staff will review their assigned area list to identify a project for a
potential strategic plan targeting inspection. If the project is not on their assigned
area list, the project will be added for inspection. It is at the discretion of the SO/IH
as to when the inspection will be conducted. An Optional Reporting number will be
generated when entered into the DRS.
B.
Field staff is expected to stop and conduct an inspection when potential “imminent
danger” conditions are viewed. Such conditions include but are not limited to:
1.
Employees working at heights where there is a high probability of a fall
resulting in death or serious injuries.
2.
Employees working in trenches greater than five feet deep, where there is a
high probability of cave-in and there are no protective systems in place to
prevent a cave-in.
3.
Employees working with cranes, boom trucks, aerial lift platforms or other
equipment in close proximity to overhead power lines.
4.
Employees working on roadway projects where the lack of traffic control
may result in an immediate hazard.
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Construction Inspection Targeting
XIII.
5.
Employees working at projects where there is a potential for excessive
exposure to lead, silica, noise, asbestos, hexavalent chromium or isocyanate
containing compounds.
6.
Other conditions are to be discussed with the SO/IH’s immediate supervisor.
7.
Staff has discretion to address other situations where observed hazards may
result in a high gravity serious violative condition.
Programmed Inspections using Building Permits.
A.
Field compliance staff may also obtain a list of active construction projects from
state and local governmental agencies that issue building permits while performing
other work related activities.
B.
Field compliance staff may stop at state and local governmental agencies that issue
building permits and request to see/obtain a copy of their building permits list. The
field compliance staff should select those projects for inspecting that do not appear
on the Dodge Report.
C.
Enter in OIS Optional Report code S-521.
XIV. Programmed Inspections of Asbestos Projects.
XV.
A.
Background. Asbestos abatement, encapsulation and demolition projects are
construction activities that are continually being conducted in Michigan. Asbestos
is often found in thermal system insulation, surfacing material, wallboard, floor tile,
roofing and siding materials and construction mastics. Construction activities
involving these materials have the potential to liberate asbestos fibers. Asbestos
exposure has been associated with asbestosis, lung cancer and mesothelioma. By
targeting employers who perform asbestos-related construction work, CSHD can
reduce and/or eliminate exposure to this carcinogen.
B.
Targeting. Contractors performing friable asbestos removal or encapsulation work
in Michigan must provide project notifications ten calendar days prior to any nonemergency asbestos project. Emergency notices may be submitted at any time. The
notifications must indicate the start and end dates and other job-related information.
CSHD evaluates the notices for the purpose of inspection scheduling. CSHD will
attempt to inspect 50% of all new asbestos licensees who are performing work in
Michigan during the first year of obtaining their license. CSHD will attempt to
inspect 50% of the asbestos licensees who are performing work in Michigan at least
once every three years. Inspections will be scheduled based upon the best
utilization of resources.
C.
Inspections. Each contractor selected for inspection will be inspected to determine
its compliance with the asbestos regulations. Any other serious hazard in plain
view will also be addressed.
Emphasis Programs. Field compliance staff shall refer to National Emphasis Programs
(NEP) and Local Emphasis Programs (LEP) for additional ways of targeting inspections.
XVI. Recording. Inspections conducted as a result of a Dodge Report, a Strategic Plan targeted
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Construction Inspection Targeting
inspection, building permit, or an asbestos case will be recorded in OIS in accordance with
established CSHD procedures.
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