What goes into a construction safety management system?
Five parts, in the order Pike Consulting Group builds them: a written Health and Safety Plan tailored to the company, training for employees and subcontractors on the hazards of each site and how to abate them, regular job site evaluations, ongoing training matched to the tasks under way, and a progressive reward and reprimand program so safe work is recognized and substandard work has a consequence.
Each part depends on the one before it. Training without a plan teaches a rule nobody wrote down. Inspections without training catch a crew that was never told. A reprimand program without inspections is a policy with nothing to act on. The order is the system.
How is a system different from a safety manual?
A manual is one part of a system, and on its own it is the part that proves least. The written Health and Safety Plan says what the company intends. The training records, inspection reports and corrective action reports say what it did. OSHA’s first question after an accident is what the employer has done to ensure the health and safety of its employees, and a manual answers in the wrong tense.
Pike Consulting Group’s own line on this is that safety programs are not worth the paper they are written on if they are never implemented, which is why its Safety Management Services page describes the system as something administered day to day rather than delivered once.
Does OSHA require a construction company to have one?
OSHA does not use the phrase, but its construction standards require the parts. Under 29 CFR 1926.20 the employer has to initiate and maintain accident prevention programs, and a competent person has to make frequent and regular inspections of job sites, materials and equipment. Each employee has to be trained on the hazards of their work, and under 1926.20(f)(2) each failure to train an employee can be treated as a separate violation.
The prime contractor’s duty is in the same part. Under 1926.16 the prime assumes the employer obligations whether or not the work is subcontracted, and where joint responsibility exists both prime and subcontractor are subject to enforcement. A system is how a builder meets those duties on purpose rather than by luck. The OSHA compliance consultant page goes through what a consultant does with each one.
What records does the system produce?
Six, on Pike Consulting Group’s list: the written Health and Safety Plan, training attendance documentation, employee and subcontractor handbooks, safety agreements, job site inspection forms, and incident and corrective action reports. Together they answer the question an inspector asks and a manual cannot.
Inspection reports carry the most weight day to day. Each one records job site details, personnel on site, the scope of work, photos of hazards, violations and abatement, a synopsis of the work observed and corrective actions taken, and recommendations for rewards or reprimands. A report like that, filed after every visit, is the evidence that the system is running.
How does the system handle subcontractors?
As employees, for the purposes of training and inspection. That is the practical reading of 1926.16, and it is why the system includes subcontractor handbooks and safety agreements alongside the employee versions. On a multi-family build with several trades working at once, subcontractor safety programs are vetted during onboarding and monitored through the project rather than checked once and filed.
The general contractor does not have to be the one who hires the consultant for the subcontractor to be covered. Pike Consulting Group works with both, and the multi-family construction safety consultant page describes how a site is run when many trades share it.
Who runs the system once it is written?
Somebody has to, every day, and the choice is between the builder’s own staff and a firm that does it for them. A builder with a safety manager who owns the plan, the records and the inspection schedule can run the system in-house. A builder without one can have it run as a service.
At Pike Consulting Group that service is Safety Management Services: an assigned safety manager, job site inspections and reporting, ongoing training, secure documentation management, and representation if OSHA visits the project. The safety manager page covers what the assigned manager is accountable for, and the construction safety consulting firms page covers how to compare firms offering it.
What changes the size of the system a company needs?
Four things. How many sites are active at once, because each one needs inspecting. How much of the work is subcontracted, because each trade brings its own program to vet. Which hazards the trades face, because fall protection, trenching, scaffolds and silica each bring their own training and documentation. And whether the company builds, runs an industrial operation, or both, because the system is built for construction and industrial organizations and Pike Consulting Group runs a division for each.
The system itself is described as flexible, meeting compliance requirements while allowing company-specific bolt-on programs. A company that already runs a fleet program or a respiratory program does not start over.
Questions we get asked
Where does a company with nothing written start?
With an introductory safety assessment of safety culture, workplace conditions and system effectiveness, done onsite. A free self-assessment tool is also available to download on the Safety Solutions page, and it is a reasonable first hour’s work before calling anyone.
Is the NAHB award for the company or the system?
For the system. Pike Consulting Group’s Health and Safety Management System was awarded the NAHB Safety Award for Excellence, and the site describes it as tailored to the organization and all related trades.
What does a progressive reward and reprimand program mean in practice?
A trade or a crew that works safely is recognized, and one that does not has a consequence that escalates if it continues. Inspection reports carry recommendations for rewards or reprimands when appropriate, so the program acts on what was seen rather than on reputation.
Does the same system cover industrial sites?
Yes. The five-step system is built for both construction and industrial organizations, and Pike Consulting Group operates a Construction Division and an Industrial Division. The industrial side adds programs such as lockout tagout, machine guarding and forklift certification.
Have a jobsite that needs a safety plan?
Tell us what you are building and where it stands. We will tell you what the program or the inspection support would involve.
