How to...

How to Assemble a Construction Safety Manual: A 6 Step Guide and Resource

Nobody wants to put a safety manual together. It’s boring and tedious and worst of all, incredibly confusing. A safety manual, sometimes called a safety program, is the formal document that outlines your company’s safety mission and how you go about implementing it. Just typing that makes my eyes glaze over.

You’ve likely already been on the OSHA website and gone down a rabbit hole of link after link after link until eventually you forgot what your original question even was.

Then, just to make it that much more complicated, you find out there are 28 states that have OSHA Approved workplace safety and health programs, in addition to OSHA, and you must meet their requirements as well.

Nothing you read gives you a clear answer, and I totally get it. I felt the same way researching this article, and I have a background in safety!

The problem is that there are so many variables that it’s hard to make all-encompassing safety regulations, for every contractor in every trade, in every state. But that sounds more like an excuse than anything and doesn’t help you at all.

Getting Started

Here is what I would do if I was in your shoes: I’d get started by getting something in writing because something is better than nothing. If OSHA knocked on your door tomorrow, at least you’d be able to hand over a document of some sort, which they will likely give you credit for.

I’ve summarized for you below what is most commonly included in a safety manual so you aren’t left staring at a blank page at the end of this. I’ve even provided you with a bunch of links to samples provided by OSHA themselves, so you can start by literally copying and pasting.

However, even OSHA puts a disclaimer on their samples that it’s not a one size fits all situation. They want you to read through everything they give you and make changes based on your company specifically.

Key Elements of a Safety Manual:

1. Company Safety Policy

A safety policy is written by (or at least approved by) the owner, COO or President of your company. It is usually about a page long and expresses their commitment to making worker safety a core company value.

It may also include the motivation or reasoning as to why the policy is in place, which can simply be: to comply with OSHA and state regulations and to prevent employee injury and illness.

It’s important that the policy is personally signed by the highest level of management so that everyone knows the policy is in place from the top down. Best practice says it should be updated and re-signed annually.

Some sample policies are provided by OSHA on page 48 of their Small Business Handbook.

The remainder of your safety manual outlines how the company is going to honor the commitments in the policy you just created.

2. Safety Responsibilities

A safety manual should very clearly define exactly what is expected of each employee. In order to account for employee turnover, this is best broken down into roles. Here are the most common roles and some sample responsibilities to get you started:

  1. The Employer
    • cover the costs of PPE
    • factor in time and resources for safety within each project
    • provide access to safety documentation (SDS, injury data, inspection findings)
    • Provide general and trade specific safety training
    • Comply with local safety regulations as well as company policy
    • Fully investigate incidents
  2. Supervisors / Management
    • Comply with local safety regulations as well as company policy
    • Maintain and wear proper PPE
    • Report safety issues to upper management
    • Ensure crews compliance with rules
    • Report all accidents / incidents / near misses
    • Work in a manner that does not endanger others
    • Take every reasonable precaution to prevent personal injury
    • Conduct toolbox talks, site inspections and JHA’s
  3. Employees
    • Comply with local safety regulations as well as company policy
    • Maintain and wear proper PPE
    • Report safety issues to supervisor
    • Report all accidents / incidents / near misses
    • Attend safety meetings
    • Actively participate in ongoing safety training
    • Work in a manner that does not endanger others
    • Take every reasonable precaution to prevent personal injury

Make sure you add in any additional responsibilities for your company, and feel free to create more roles. As you can see above, there should be an overlap of some of the duties, providing a sense that safety is everyone’s responsibility.

3. Hazard Identification and Controls

This is where your trade really comes into play. A plumber is going to experience very different hazards than, say, an excavator; and the excavator, different than a framer. Luckily, this section does not need to cover every single hazard your team may run into, but the most common ones they are exposed to.

Start by generating a list of hazards specific to your trade. If you need some help getting started, take a look at OSHA Standard 1926 for a list of regulations specific to construction.

The list is not easy to navigate, but if you scan through each lettered subpart (i.e., Subpart D), you’ll get an idea of the main categories. If the category applies to your trade, review the regulations within it for ideas.

For each hazard, you then need to include a control method. Try and use the most effective control (elimination) whenever possible and the least effective (PPE) as a last resort.

(image source: Niosh)

Finally, there are four hazard types that OSHA states must have written plans in place if your trade is exposed to them, even if it’s a rare occurrence. I have listed them for you below with a direct link to the regulation so you can determine if it is applicable to your company.

If the hazard is relevant to your company, you must include it in your safety plan. Some regulations specify what must be included in the written plan, so it is important to read these four regulations.

Thankfully, OSHA offers sample plans for each of these hazards, which I have pulled from the rabbit hole and linked for you as well.

  1. Bloodborne Pathogen Exposure Program
  2. Permit Required Confined Spaces
  3. Hazard Communication Program
  4. Respiratory Protection Program

4. Safety Procedures / Best Practices

This section is used to outline the proper, safe ways to complete common tasks.

For example, if you are a masonry contractor, moving bricks is not likely the most hazardous task you complete, so it wouldn’t be covered in the section above; however, if not done properly, over time, it could lead to back issues.

In this case, a written procedure on how to transport and carry bricks safely will protect your employees from a repetitive strain injury.
Other processes you may wish to include would be the use of hazardous machines or tools.

You don’t have to reinvent the wheel. Once you have identified the procedures you’d like to outline, your local trade association very likely has a copy of the proper steps. Worst case, Google is your friend here.

5. Training

Your safety manual is useless unless it is put into action.
This section should outline how you are going to train all new and existing employees on your new safety program, covering each of the sections.

To do this effectively, most employers opt for a new employee onboarding program to cover all the knowledge and skills their employees require in order to work safely. Some even pair new employees with a mentor to guide them in the right direction during the first few weeks.

You should also include a list of formal training required, based on which role they have been hired into. For example, you may require all workers to take a fall protection course but only your formen to take first aid training.

Finally, you should describe how you are going to track who has taken what training and when it expires. This will ensure everyone’s certifications are completed and kept up to date (not expired).

6. Resources

The final section of your safety manual acts more like an appendix and should include any parts of the program that were not already covered. Some may include:

  • forms or inspections you use on site
  • Safety Data Sheets
  • New Employee Orientation Package
  • Manufacturer Safety Policies

If you have more than ten employees in your company, OSHA stipulates you must include An Emergency Action Plan (OSHA 29 CFR 1926.35/150) and a Fire Prevention Plan (OSHA 29 CFR 1926.24)

Basically, any document that is a part of your program gets added to the end of the manual so there is one central place for all safety related information.

What Now?

Now that you have a first draft of a formal written safety manual, I’d get a professional to review it. Here’s the great news, this doesn’t have to cost you a dime. OSHA offers a no cost, confidential Onsite Consultation Program. Here are the benefits:

  • The consultants are safety professionals from local state agencies or universities, NOT OSHA enforcement officers
  • They are local to you so can reference any state regulations
  • The consultant will NOT report any violations to OSHA
  • The consultant will review your safety manual and provide you with feedback specific to your company
  • They will visit you onsite to help you identify common hazards and provide options to control them
  • After the visit they will send you a written report with all their findings and recommendations

The only obligation you have to the consultation program is a commitment to correct serious health and safety hazards in a timely manner, which is a responsibility of yours as an employer anyhow. There really is no downside.

Like any free program, there are going to be limits to the amount of time the consultant can spend with each of their clients. By having already written out your first draft of your safety manual, you will really make the most of their time with you and get the answers you need.

Extra Helpful Tips

Once you are happy with your written safety manual, you are going to need to make it available to your entire workforce. Lots of contractors print a copy and leave it in their break room, but that doesn’t help the workers who are onsite.

A Safety Management System like Harness can help you solve this problem and many others as you work to improve the safety culture at your company. Our Learning Center is a great place to google your questions, as I’m sure they will arise during the first draft.

You are also more than welcome to reach out to us directly if you have a question that you can’t find an answer to. Feel free to email me or type your question into our live chat and one of our team members (potentially me) will get back to you right away.

Good luck and remember, something is better than nothing, so just get started!

How to... Safety News

Covid-19 Workplace Prevention Program: 11 Key Elements

Responding to President Joe Biden’s executive order on worker health and safety, on January 29 2021, the Occupational Safety and Health Administration issued stronger guidance on identifying coronavirus exposure risks and implementing a COVID-19 Prevention Program at work. Having a program can help protect your employees from contracting the virus and keep your workforce doing what they are supposed to do, work.

Some jurisdictions, including the California Occupational Safety and Health Standards Board have already gone a step further and made a preventions program mandatory. Every business located or operating in California with more than one employee who are not working remotely must have a written Covid-19 Prevention Program in place.

The California guidelines, published weeks ago, can help you develop a program of your own now. We have pulled out what is relevant to contractors and summarized it below, so you don’t have to read the entire 23-page order.

You have our full permission to copy and paste this information into your own document and begin the process of customizing it to your business. You can thank us (and the State of California) by sharing this on your social media accounts; the more businesses who help prevent the spred, the better. We really are all in this together.

Covid-19 Workplace Prevention Program Overview

All employers should establish, implement, and maintain an effective, written COVID-19 Prevention Program. The written elements of the program should include:

1. System for Communicating

  • outline the process for an employee to report symptoms, exposures and hazards at the workplace
  • describe how you will accommodate employees with an increased risk of severe Covid-19 illness provide information about access to Covid-19 testing in your area
  • make a commitment to communicate information about Covid-19 hazards, policies and procedures to your employees, and any other person in contact with the workplace (which includes job sites)

2. Identification, Evaluation and Correction or Reduction of COVID-19 Hazards

  • Develop and implement a process for screening employees prior to work. This may include a written self-evaluation or temperature checks using non-contact thermometers
  • Conduct a workplace-specific identification of interactions, areas, activities, processes, equipment and materials that could potentially expose employees to Covid-19 and treat all persons in these situations, regardless of symptoms, as potentially infectious
  • For indoor locations, maximize the quantity of outdoor air and increase filtration to the highest level with existing ventilation systems
  • Periodically review and inspect local health department and industry-specific guidelines and your existing procedures
  • For every hazard identified above, the company shall implement effective policies and or procedures for correcting or reducing these unhealthy conditions

3. Training and Instruction

  • The employer must train and educate the employees about Covid-19, how it is spread, the symptoms, and methods to prevent its transmission
  • Training sessions should be documented as to who attended

4. Physical Distancing

  • All employees shall be separated from other people by at least six feet, except where you can demonstrate that six feet is not possible or momentary exposure while persons are in movement
  • When not possible, they need to remain as far apart as possible

5. Face Coverings

  • Employers shall provide face coverings and ensure they are worn by employees when indoors or when outdoors and less than six feet from another person
  • Exceptions include: when an employee is alone in a room, eating or drinking as long as they are 6 feet apart, if they are wearing other safety respirators already or if medical or mental health conditions restrict their use
  • If a specific task cannot feasibly be performed with a face covering, the person is exempt but limited to the period in which the task is being performed, and the person is either 6 feet away from others or tested for Covid-19 twice a week
  • Employers cannot prevent an employee from wearing a mask when they are not required to, unless it renders their task unsafe

6. Other Controls and Personal Protective Equipment

  • In fixed work locations where physical distancing is not possible, the employer shall install cleanable solid partitions to reduce aerosol transmission
  • Employers shall clean and disinfect frequently touched surfaces and objects and notify employees of the procedure and frequency
  • Prohibit sharing of PPE and other close contact items when feasible, such as tools, keyboards, pens, phones etc.
  • Complete cleaning and disinfecting of areas, materials and equipment a positive case has come in contact with
  • Employers to provide appropriate hand washing facilities and hand sanitizer and encourage employees to wash regularly
  • Employers evaluate the need and shall provide appropriate personal protective equipment not limited to, gloves, goggles and face shields

7. Employer Provided Transportation

  • Whenever possible, put employees from the same household together, and if not, then from the same crew
  • The operator and passengers are separated by at least three feet in all directions, regardless of vehicle capacity
  • Everyone in the vehicle is wearing a mask
  • Conduct daily screening questionnaires and exclude drivers and riders with symptoms, prior to boarding
  • All high contact surfaces (handles, seatbelts, armrests etc) are disinfected before each trip
  • High contact points for drivers (wheel, shifter etc) are disinfected between drivers
  • Windows are kept open when the weather conditions range between 60 and 90 degrees. When above or below that the heat or AC may be on as long as it is set to maximize outdoor air and not recirculate. Windows can also be closed during rain or snow, having the ventilation system running is still recommended
  • Employers shall provide hand sanitizer in each vehicle and ensure riders and drivers use it before and after each ride

8. Investigating and Responding to COVID-19 Cases

  • Determine day and time the case was last present and if possible the day and time they first experienced symptoms
  • Determine who may have had exposure to the case
  • Give notice to everyone who was exposed within 1 business day and send them home
  • Offer Covid-19 testing at no cost and during working hours to all employees with exposure
  • Investigate whether any workplace conditions could have contributed to exposure and what can be done to reduce or eliminate that hazard
  • Keep all personal information of cases and medical information confidential

9. Exclusion of Covid-19 Cases

  • All positive cases must be excluded from the workplace until the criteria in section 10 is met
  • Employees with exposure to a positive case must be excluded from the workplace for 14 days from the date of the exposure
  • Employees excluded from work due to positive test results or exposure and otherwise able and available to work shall maintain their earnings, seniority and all other rights and benefits as if they had not been removed from their job. Employers may use provided sick leave benefits for this purpose. This does not apply if the employer can demonstrate that the exposure is not work related
  • These regulations do not limit any other law, policy or collective bargaining agreement that provide greater protection

10. Return to Work Criteria

  • Cases with symptoms shall not return to work until:

1. At least 24 hours have passed since a fever of 100.4 or higher has resolved without the use of fever-reducing medications; and

2. Other COVID-19 symptoms have improved; and

3. At least 10 days have passed since COVID-19 symptoms first appeared

  • COVID-19 cases who tested positive but never developed COVID-19 symptoms shall not return to work until a minimum of 10 days have passed since the date of specimen collection of their first positive COVID-19 test
  • A negative COVID-19 test shall not be required for an employee to return to work
  • If an order to isolate or quarantine an employee is issued by a local or state health official, the employee shall not return to work until the period of isolation or quarantine is completed or the order is lifted

11. Reporting, Recordkeeping, and Access

  • Employers must report information about Covid-19 cases and deaths at the workplace to their local health department when required to by law
  • Employer shall maintain written records of their Covid-19 Prevention Program, and the steps taken to implement it and make it available to their employees
  • Record and Track all Covid-19 cases with names, contact info, occupation, location worked, date of last day worked, date of positive test and keep it confidential

How Harness Can Help

Harness can help make navigating the Covid-19 pandemic easier. Our platform has multiple ways to document, train, and track all the requirements mentioned above. Here are some of the ways our current clients are utilizing Harness in addition to their regular safety program:

  • Having each employee fill out a symptom self assessment on their own phone, prior to starting work each morning
  • Storing their Prevention Program so it is available to all their workers on all device types
  • Using our custom Covid-19 Toolbox Talks to train their workers on Covid-19 and document their attendance at the meeting
  • Recording information about positive cases and exposures
  • Documenting cleaning and disinfection schedules
  • Conducting inspections for potential Covid-19 Hazards and tracking how they are corrected

If you have a unique or industry specific Covid-19 concern, we are able to work with you to design a custom solution. If you have any questions or would like to talk more about how Harness can help you through these tough times, please book an appointment to speak with us.

Otherwise, feel free to check out these additional resources.

Top 5 Ways To Foster A Safety Culture In Your Construction Business
Best Construction Safety Apps
What Does Harness Software Cost?

How to...

How to Easily Conduct A Construction Safety Inspection in 10 Steps

Conducting an onsite safety inspection is an integral part of a quality safety program, but if you don’t have a background in safety, it’s hard to know what to even look at, let alone what is considered unsafe.

Your trade also factors into the equation as there are likely hazards that are specific to the tasks your workers complete. A welder is going to face very different hazards than a carpenter.

At Harness, we work with hundreds of contractors, spanning a wide variety of trades. Having designed their electronic inspection forms for them means we have seen thousands of inspection points.

On a large scale the number of items to inspect is pretty overwhelming; however, there are some general areas that show up on every form. Below, we have captured the most common ones so you can begin with them and add in more specific inspection points as you gain experience.

10 Areas You Should Inspect While Onsite

1. Emergency Planning

If there were to be an incident on your job site, are you prepared? Some items to consider are:

  • having a fully stocked first aid kit
  • someone trained in first aid on site
  • a fully charged fire extinguisher nearby
  • an emergency escape route
  • a designated meeting spot

Some states and local municipalities also require you to have certain signage posted on site. This includes posters such as overhead work and emergency contacts.

You should also check with the general contractor as they may want you to produce information such as a written Safety Manual. Making sure these items are available to your workers and that they know where to find them will ensure incidents are dealt with properly if one does occur.

2. Personal Protective Equipment (PPE)

You need to make sure all of your workers have access to and are wearing personal protective equipment specific to the task they are working on.

This is going to differ significantly depending on your trade but should include, at a minimum, protection for:

  • Hands
  • Eyes
  • Hearing
  • Respiratory
  • Feet
  • and proper clothing on the body

3. Material

It is important to consider what materials you are working with and how they impact the safety of your workers.

OSHA requires you to have a Safety Data Sheet available for every material your workers come in contact with. This is especially important when working with hazardous chemicals.

How material is stacked and stored should be checked as well. Items that could fall over easily shouldn’t be stacked high, some combustible materials need to be stored in cages and nothing should be near building perimeters.

Finally, you need to look at how material is being moved around the jobsite. Workers should be using aids such as wheelbarrows whenever possible and proper lifting techniques when not.

4. Housekeeping

A clean job site is not only safer because there is less of a chance your workers will trip, but it also makes it easier to spot hazards.

Check all aisles, passageways, stairs and landings to make sure there is adequate space to move about safely.

Work areas should be cleared of debris at multiple points throughout the day.

5. Access and Egress

Inspect how your workers are getting in and out of the site, especially if they are required to climb ladders, or stairs.

Stairs should have proper rails and landings and all openings should be protected and clearly marked.

Ladders need to be in safe working condition, set up properly and used correctly.

6. Hand, Pneumatic and Power Tools

Tools need to be inspected to make sure they are in good working condition and that their safety features such as guards are in place.

You should also try and see your workers using the tools to ensure they are complying to proper and safe techniques.

Additional PPE is often required when using specific tools so also take a look at what they are wearing.

7. Electrical

Electricity is a hazard on every job site, for every worker and so it should be included in your inspection.

Electricians, however, need a much more detailed level of inspection when it comes to hazards, which is why this item is also included as a trade specific hazard below.

A general inspection of electrical hazards should include making sure all extension cords and tools are protected by a ground-fault circuit interrupter (GFCI), that cords are not frayed or spliced and that electrical equipment is away from groundwater.

Also take note of any overhead wires and make sure workers and equipment are staying well clear of them.

8. Large Machines

Most job sites are not complete without at least one large machine, often many.

These machines are usually used to lift and transport materials or dirt and sometimes to even complete work out of. This includes aerial lifts, forklifts, cranes, backhoes, etc.

Each of these machines needs to be operated by someone who is certified to do so and who conducts a seperate daily inspection on every machine they operate.

9. Other Factors

You can do everything right and then something unexpected happens and suddenly your job site is no longer safe.

If you work primarily outdoors, the weather can have an effect on your safety. You need to consider and check that workers have taken precautions against the elements, including extreme hot and cold, rain, wind, ice, snow and hail.

You should also consider other trades that may be onsite and may create hazards for your workers, simply by doing their job, especially if they are working in close proximity.

Finally, traffic and the general public can cause hazards to your workers and also need to be protected. Taking a few measures to look at the bigger picture is only going to protect your workers more.

10. Trade Specific Hazards

There is no possible way for us to capture every single potential hazard on a job site.

Please take time to write down common hazards specific to your trade.

This may include but isn’t limited to:

  • falls from heights / fall protection
  • compressed air or gas
  • confined spaces
  • electricity
  • open flame
  • Scaffolding
  • Silica protection

One of the best ways to gather a realistic view of what goes on at your job sites is to show up, especially unexpectedly.

If you conduct and document a safety inspection while you are there, you may be able to find and correct hazards before they turn into an incident and can even protect your company from potential citations if an incident occurs.

Next Level Stuff

If you skip the paper inspection and move right to doing your inspections in a safety management system like Harness, it is the same amount of work (actually even less) and provides more benefits to your company.

Harness collects all the data from your inspections in real time and allows you to analyze and graph the results. You can easily see where your crews are struggling to comply and where they are succeeding.

You can also review the results by employee so you know who needs more training and who deserves a raise (or at least a high five).

If you want to see some of the cool analytics Harness provides, you can book a demo.

If you want to start on paper first, we have taken all the information above (and more) and put it into a checklist format that you can print and start using today. Download this free resource below.

Otherwise, you may find these articles helpful:

5 Simple Tasks to Improve Your Construction Safety Program
How Much Does the Harness Safety App Cost
What is a Job Site Hazard Assessment (Definition and Usage)