OSHA Publishes Guidance Document for Inspection of Roadway Construction

Each year, more than 100 roadway construction zone workers are killed and 20,000 are injured.  The majority of deaths involved workers on foot.  On October 16, 2012, OSHA published a document to assist Compliance Safety and Health Officers in assessing hazards and issues regarding inadequate construction work zone controls.  This guidance document is intended to clarify existing general enforcement policies in work zones.  Specific hazards regarding traffic control can be enforced using 29 CFR 1926 Subpart G – Signs, Signals and Barricades for construction zones.  In addition, the Manual on Uniform Traffic Control Devices (MUTCD) Part VI has been incorporated by reference in Subpart G.  To address other hazards not specifically listed, Section 5(a)(1) of the OSH Act “General Duty Clause” is used.  Other local, state, and federal governmental entities may also have additional requirements and permitting.

The compliance officer will be evaluating the four typical components of a work zone: advanced warning area, transition area, activity area (including buffer spaces), and termination area.  When evaluating your construction roadway work zones, some areas of concern are:  adequate advanced warning signs, transition tapers appropriately spaced, buffer zones, cone spacing, and control devices indicating a clear path of travel. In addition to flagger signaling and warning garments worn by flaggers, traffic control signs, devices, and barricades must also conform to MUTCD requirements.

Some of the specific areas of the requirement include:  instructing employees on hazard avoidance, use of high-visibility apparel when workers are exposed to public and construction traffic, pedestrian/worker safety, use of a qualified/knowledgeable person to apply provisions regarding signs and devices, and use of appropriate flagger hand-signaling (flagging) procedures according to the MUTCD.  Affected safety programs should review the OSHA guidance document and the Manual on Uniform Traffic Control Devices publications for additional information.