Construction sites, by their very nature, are areas of increased risk, having many components that are potentially hazardous to workers and the general public. Equipment on the site is not permanently anchored; workers may be unfamiliar with that equipment and its inherent hazards; and written procedures and warnings may not be consistently displayed.

Add to this the multiple subcontractor workforces that leave their imprint on the site, and occasional onlookers and trespassers who may wander onto an unsecured site, and the potential for danger increases. OSHA has regulations mandating construction site safety. Failure to adhere can result in heavy fines, serious injury or more disastrous results.

Regulations governing the locking out and tagging out of potentially hazardous equipment are of particular concern. Technically, the construction industry is exempt from the Control of Hazardous Energy (Lockout/Tagout) OSHA regulation 1910.147. However, Standard 1910.147 does apply to construction companies' shops on their own premises.

OSHA regulations for various CFR 1926 (construction standards) violations require that best practices for lockout/tagout (or LOTO, as it's commonly known) be observed. Following are several OSHA regulations that apply:

• CFR (Code of Federal Regulations) 1926.20; General Safety and Health Provisions for Construction.
• CFR 1926.21(b)(2) concerning unsafe conditions.
• Section 5(A)(1) of the OSHA Act, the General Duty Clause. This can refer to LOTO on the construction site, as it's a recognized hazard to which employees are exposed.
• Safety for exposed wiring 1926.417.
• And, especially, 1926.403, the Guarding of Live (electrically live) Parts.

OSHA can also refer to the machinery standard indicating that machines have specific disconnects that can be locked out to enforce safe de-energization work practices on construction sites.

A primary concern on construction sites is the control of electricity. Typically, power generators are used at the beginning of a construction project. As construction progresses, contractors switch to temporary power (electrical) from which they draw their electrical supply needs until they finally switch over to main power. That doesn't usually occur until the finishing stages of the project.

A potential hazard can occur during the time when both main electrical power and residual power (emergency lighting, for instance) are live. There are separate breakers for main electrical and residual. Both sources of electrical power need to be locked out and tested for safety before performing any equipment servicing or maintenance work. Additionally, generators must be tagged out for non-use and “needs repair” conditions. Not doing so can lead to a serious accident if the generator is plugged in.

Another common electrical hazard on a construction site is the potential to hit live wires while excavating. It is possible for old utility lines to still be energized, making it crucial to verify the location of all electrical lines on the site and make sure they are not live in the area that is being excavated.

What measures can be put in place to reduce the potential for accidents and injury on a construction site? By implementing the following four-step plan, contractors will be following best practices for controlling energy.

Step 1: Develop and document an energy control program.

The written lockout policy is the starting point. Who is responsible for providing these procedures on a construction site depends upon how the project contract is written. It could be the general contractor, construction manager or electrical contractor. If the electrical contractor has to verify successful isolation and/or control of the hazardous electrical energy, that party is usually the only one who can lock out. It's generally standard operating procedure to have the electrical contractor perform the lockout. The procedures to be followed, and the person responsible for safety matters, should be determined at the pre-construction conference.

Once it is determined who is responsible for the energy control program, begin by documenting the program. Continue with machine-specific procedure development, training and periodic inspections. OSHA has a Lockout/Tagout Tutorial on its Web site, www.osha.gov, that provides additional advice. There are programs on the market that include a thorough sample energy control policy that can serve as a guide as you develop your own comprehensive energy control program. Such programs allow you to create and manage clear and easy-to-follow visual, machine-specific procedures for all electrical equipment.

Step 2: Identify and mark all energy control points.

Locate and mark all energy control points, including valves, switches, breakers and plugs, with permanent labels or tags. It is important to use labels and tags made of durable materials to withstand exposure to the elements on a construction site. Cross-reference each label and tag with the corresponding step number in the posted energy control procedure for that equipment. Include information about the magnitude and purpose of the control point, as stipulated by OSHA for electrical disconnects and recommended by ANSI for all isolating devices.

Step 3: Train employees, communicate and conduct periodic inspections.

It is important to establish formal training programs for each of the three categories of employees for lockout: Authorized, Affected and Other. OSHA provides advice on how to train these employees and to verify that the training is up-to-date. You can create or enhance a training program by using training DVDs, handbooks and posters currently available. There is also software that provides training modules and quizzes to help formalize and document effective training programs.

Step 4: Equip employees with lockout tools and warning devices.

Ultimately, it's the proper and persistent application of the lockout hardware, per the established procedures, that makes for a successful lockout program. To this end, it's important to know and document specifically what devices are acceptable for use at each and every lockout point. There is a tremendous range of sizes and shapes of valve operating handles, circuit breaker switches and various other energy control devices. A leading lockout device provider will have developed product series that properly fit the majority of these. Because a construction site is more of an uncontrolled environment than an occupied building or plant, there is a greater safety risk for both authorized and unauthorized personnel. Using heavy-duty padlocks to lock all equipment when not in use and displaying visual warning signs that communicate hazards to workers and the general public will also help reduce accidents.

Consistently following the four steps listed above will help contractors adhere to best practices for compliance with OSHA safety regulations regarding energy control on a construction site. This will result in increased personal safety, cost reductions and improved productivity.