-
Record Type: Instruction
-
Directive Number: CPL 2.87
-
Standard Number: 1926 Subpart P; 1926.650; 1926; 651; 1926.652
-
Subject: Inspection Procedures for Enforcing the Excavation Standard,
29 CFR l926, Subpart P
-
Information Date: 02/20/1990
OSHA Instruction CPL 2.87
FEB 20, 1990
Directorate of Compliance Programs
SUBJECT: Inspection Procedures for Enforcing the Excavation Standards -
29 CFR 1926, Subpart P.
A. Purpose. This instruction establishes inspection procedures and provides
clarification to ensure uniform enforcement of the Excavation Standards.
B. Scope. This instruction applies OSHA-wide.
C. References.
1. Construction Safety and Health Standards, Subpart P., 29 CFR 1926.650,
651, and 652.
2. OSHA Instruction CPL 2.45B, June 15, 1989, the Revised Field Operations
Manual (FOM).
3. OSHA Instruction CPL 2.34, September 1, 1979, the Construction SAVEs
Manual.
D. Cancellation. OSHA Instruction STD 3-14.1, October 30, 1978, Citation
Policy - Specific Trenching Requirements, is canceled.
E. Action. Regional Administrators and Area Directors shall ensure that
the guidelines in this instruction are followed and that compliance officers
are familiar with the contents of the standard.
F. Federal Program Change. This instruction describes a Federal program
change which affects State programs. Each Regional Administrator shall:
1. Ensure that this change is forwarded to each State designee.
2. Explain the technical content of the change to the State designee
as requested.
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
3. Ensure that State designees acknowledge receipt of this Federal program
change in writing, within 30 days of notification, to the Regional Administrator.
This acknowledgment should include the State's intention to follow the
inspection guidelines described in this instruction, or a description of
the State's alternate guidelines which are "at least as effective as" the
Federal guidelines.
a. If a State intends to follow the revised inspection guidelines described
in this instruction, the State must submit either a revised version of
this instruction, adapted as appropriate to reference State law, regulations
and administrative structure, or a cover sheet describing how references
in this instruction correspond to the State's structure. The State's acknowledgment
letter may fulfill the plan supplement requirement if the appropriate documentation
is provided.
b. Any alternative State inspection guidelines must be submitted as
a State plan supplement within 60 days. If the State adopts an alternative
to Federal inspection guidelines, the State's submission must identify
and provide a rationale for all substantial differences from Federal guidelines
in order for OSHA to judge whether a different State guideline is as effective
as a comparable Federal guideline.
4. After Regional review of the State plan supplement and resolution
of any comments thereon, forward the State submission to the National Office
in accordance with established procedures. The Regional Administrator shall
provide a judgment on the relative effectiveness of each substantial difference
in the State plan change and an overall assessment thereon with a recommendation
for approval or disapproval by the Assistant Secretary.
2
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
5. Review policies, instructions and guidelines issued by the State
to determine that this change has been communicated to State personnel.
G. Background. The Occupational Safety and Health Administration after
15 years of experience involving the adopted Federal standards for covered
employees in the construction industry (36 CFR 25232 December 30, 1971)
issued revised rules for Subpart P. to 29 CFR 1926 (54 CFR 45894 October
31, 1989).
1. These rules have been reviewed by the Advisory Committee on Construction
Safety and Health (ACCOSH) and many of the changes reflect their recommendations
and those of other interested parties.
2. On April 15, 1987, OSHA issued a notice of proposed rulemaking on
excavations (52 FR 12288). After an extensive comment period and public
hearings, the hearing transcript and related submissions were certified
and closed on December 15, 1988
3. The final rule resolves many issues raised in earlier attempts to
regulate this activity within the construction industry. Many of these
issues involved previous decisions under the existing standard.
a. It is the intent of this rule to establish one set of requirements
which are applicable to all excavations, including trenches.
b. Where compliance requirements are intended to be applicable only
to trenches, the final rule makes it clear that these requirements apply
only to those excavations which are also trenches.
4. So that ongoing guidance may be provided, enforcement problems, including
misinterpretations or other difficulties being experienced by employers
3
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
and apparent efforts by employers to circumvent the standard, shall
be promptly reported to the Office of Construction and Maritime Compliance
Assistance.
H. Inspection Guidelines (Compliance Procedures).
1. Excavation Protection Programs. This standard provides requirements
which allow employers flexibility in developing programs that provide effective
protection for employees working in excavations. In addition to the standard
itself, the preamble provides further guidance and rationale for changes
in the existing standard.
2. Program Compliance. During all inspections at construction sites,
where excavation standards are or will be applicable, compliance personnel
shall ensure that compliance with 29 CFR 1926, Subpart P, Excavations,
is in accordance with the FOM, Chapter III, D.7 and D.8.
a. This review shall include any documentation by employers of the methodology
and background information used to determine whether shoring systems are
required and the type of systems used.
b. The compliance safety and health officer (CSHO) shall evaluate the
employer's compliance with the specific requirements of the standard.
3. CSHO Responsibilities. The following procedural guidance provides
a general framework that is designed to assist the CSHO with all inspections:
a. Ask the employer for the basis on which the employee excavation protection
program related to the standard was developed.
b. Interview a representative cross-section of affected employees to
verify the employer's
4
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
program. This shall include an evaluation of the training of affected employees
and the effectiveness of the employer's enforcement of its program. (See
29 CFR 1926.20(b)(1) and 1926.21(b)(2) .)
c. Evaluate compliance with requirements for periodic inspection of
excavations. (See 29 CFR 1926.651 (k) (1).)
d. Identify all persons (competent person, registered professional engineer,
etc.) responsible for excavation activities and/or operations.
e. Evaluate compliance with training requirements identified by periodic
inspections or changes in equipment and/or procedures. This shall include
an evaluation of the effectiveness of the employer's inspection procedures
and training program for assessment and correction of situations resulting
in near misses and/or injuries or circumstances indicating that modifications
are necessary. (See 29 CFR 1926.20(b)(1) and 1926.21(b) (2).)
4. Specific Excavation Requirements.
a. Scope and Application. This subpart applies to all open excavations
made in the earth's surface. Excavations are defined to include trenches.
All trenches are excavations; all excavations are not trenches. (See 29
CFR 1926.650(a).)
NOTE: If installed form work or other similar obstructions reduce the
depth-to-width dimensions for a particular excavation, it may become a
trench as defined later in the specific requirements of this instruction.
5
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
b. Definitions. The definitions contained in the excavation standard
shall be relied upon to interpret and apply the standard properly. In some
cases terms within a definition are themselves defined within the same
section.
(1) Accepted Engineering Practices. CSHOs shall verify with the employer
which aspects of the employee protection system have been designed or approved
by a registered professional engineer. The name of such individual or,
if a firm, the firm's name, the name of the engineer of record that approved
the work for the firm, and the registration number shall be recorded.
(a) Field offices may review any work which must be certified as to
the status of such certification with the State Board of Certification
and Registration for Professional Engineers and Land Surveyors in their
respective States.
(b) Verification shall also be made for all other aspects of the onsite
excavation conditions which the employer indicates are under the direct
supervision of a registered professional engineer.
1 All inquiries relating to the adequacy of the engineering design shall
be referred to the Regional Office of Technical Support (ARA-TS).
2 In appropriate cases, the Regional Office may refer deficient or inadequate
engineering designs of
6
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
protective systems to the State Board of Certification and Registration
for professional Engineers.
(c) Any equipment, shoring devices, shields or other special aspects
of an employer's excavation program in which the compliance investigation
reveals the use of a Registered Professional Engineer shall be so noted
on OSHA 1-B during the onsite investigation. If such devices, shields or
other special aspects of the employer's program do not comply with the
requirements of the standard, appropriate citations shall be issued.
(2) Competent Person. CSHOs shall pay particular attention to the investigation
and documentation of data to establish that any person serving in this
capacity possesses the capability of identifying existing and potential
hazards for workers.
(a) To be a "competent person" under this standard, a person must have
had training in, and be knowledgeable about, soils analysis, the use of
protective systems and the requirements of this standard.
(b) The competent person having such training and knowledge must be
capable of identifying existing and predictable hazards in excavation work
and have the authority to take prompt measures to abate these hazards.
Thus, a backhoe operator who would otherwise meet the requirements of the
definition is not a
7
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
competent person if the person lacks the authority to take prompt corrective
measures to eliminate existing or potential hazards.
(3) Hazardous Atmospheres. The CSHO shall check for hazardous or oxygen
deficient atmospheres. For example, these include irritating atmospheres
which could be encountered in areas close to a landfill, where it is not
uncommon to encounter hydrogen sulfide H(2)S.
(4) Registered Professional Engineer. The CSHO shall determine that
the Registered Professional Engineer of record is in fact working within
a discipline applicable to the excavation work; i.e., it would be inappropriate
for an electrical engineer to approve shoring design for an excavation.
See also the definition for acceptable engineering practices in this instruction.
(5) Tabulated Data. The CSHO shall examine and ensure that all tabulated
data for protective systems are approved by a Registered Professional Engineer.
NOTE: The use of tabulated data appearing in the appendices to this
standard is excluded from this requirement.
c. General Requirements.
(1) Surface Encumbrances. The standard requires that all surface encumbrances
that are located so as to create a hazard to employees shall have been
removed or supported, as necessary, to safeguard employees. The requirement
is the same as the existing 1926.651(b) and applies
8
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
to all employees at the construction worksite. (See 29 CFR 1926.651
(a).)
(2) Underground Installations. The estimated location of utility installations,
such as sewer, telephone, fuel, electric, and water lines, or any other
underground installations that reasonably may be expected to be encountered
during excavation work, shall have been determined prior to opening an
excavation.
(a) Utility companies or owners shall have been contacted, advised of
the proposed work, and asked to establish the location of the utility underground
installations prior to the start of actual excavation.
1 An employer need not contact utility companies where the excavation
work is to be performed in a remote location where no underground installations
are likely to be encountered and there are no features which would indicate
the presence of underground installations.
2 When utility companies or owners cannot respond to a request to locate
underground utility installations within 24 hours (unless a longer period
is required by State or local law) or cannot establish the exact location
of these installations, the employer may proceed, provided the employer
does so with caution, and detection equipment or
9
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
other acceptable means of locating utility installations are used.
3 The employer is required, while the excavation is open, to ensure
that underground installations are protected, supported, or removed to
safeguard employees from hazards. (See 29 CFR 1926.651 (b)(2) and (3).)
(b) The CSHO shall ascertain whether the employer has contacted the
appropriate utility companies to establish the location of underground
installations that may be encountered.
NOTE: Many States require the "one call system" prior to the start of
excavation work. (See 29 CFR 1926.651(b)(2) .)
(c) When excavation operations approach the estimated location of underground
installations, the exact location of the underground installation shall
be determined by means that are safe to employees. (See 29 CFR 1926.651
(b)(3).)
(d) The CSHO shall determine that underground installations have been
protected, supported or removed as necessary to protect employees. (See
29 CFR 1926.651 (b)(4).)
(e) The sloped end of a trench, e.g., an earth ramp, may be considered
a safe means of egress only if
10
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
employees are able to walk the ramp in an upright manner when entering
or exiting the trench.
1 The CSHO shall consider such factors as the degree of the slope, depth
of the excavation, soil and environmental conditions, and the presence
of any obstructions in determining whether or not the earth ramp can be
used for safe egress.
2 An employer may not use knotted rope lines to assist employees using
sloped areas as access to trenches.
3 OSHA does not consider lifting equipment as "an other safe means of
egress." For example, employees riding in a backhoe bucket to either enter
or exit trench excavations, is not "other safe means of egress" for purposes
of the standard. (See 29 CFR 1926 651(c)(2) and 54 FR 45918 (Oct. 31, 1989)).
(f) The prohibition against employees being under loads handled by lifting
or digging equipment includes both excavated materials and slung loads
(pipe, etc.). (See 29 CFR 1926.651(e).)
(g) The CSHO shall ensure that an adequate warning system has been provided
for mobile equipment operating adjacent to or without a
11
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
clear view of the edge of excavations.
NOTE: This requirement does not apply to equipment used to push spoil
back into the excavation for backfilling. (See 29 CFR 1926.651(f).)
(3) Hazardous Atmospheres. In addition to the requirements set forth
in Subparts D and E of this part (29 CFR 1926.50 --1926.107), to prevent
exposure to harmful levels of atmospheric contaminants and to ensure acceptable
atmospheric conditions, the following additional requirements apply: (See
29 CFR 1926.651(g).)
(a) Air quality tests shall be taken before employees enter excavations
more than 4 feet in depth when a hazardous atmosphere exists or could be
expected to exist.
(b) Tests shall be conducted as often as necessary to ensure the quality
and quantity of the atmosphere. This includes checks for flammable gases
and oxygen O(2) deficiency.
(c) Where hazardous atmospheres exist or may reasonably be expected
to exist, emergency rescue equipment must be on the worksite and readily
accessible to employees. (See 29 CFR 1926.651(g)(2)(i)).
(d) Daily inspections must be conducted by a competent person. Evidence
of the lack of such inspections may include indication of failure of
12
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
protective systems or employees exposed to hazardous atmospheres. (See
29 CFR 1926.651(k)(1) and (2).)
d. Requirements for Protective Systems.
(1) When the employer has elected to protect employees by sloping, 1926.652
(b)(1) requires that the slope be not steeper than 1.5H:1V "unless the
employer uses one of the other options ..."
(a) In a contested case proceeding once OSHA shows that no support system
was used and that the sides of the excavation were steeper than 1.5H:1V,
the employer has the burden of showing its compliance with one of the other
sloping options.
(b) The CSHO, however, shall document all relevant facts to evaluate
the hazard to obtain information which may be necessary for rebuttal of
the employer's case.
(2) If the CSHO observes that a protective system appears inadequate
or in danger of failure, the employer's representative or competent person
shall be notified immediately so as to remove any employees in the excavation
until such danger of failure has been abated. (See 29 CFR 1926.652 (a)(2).)
(3) In evaluating the design of sloping and benching systems, the CSHO
shall refer to the decision chart found in Figure 2 of Appendix F, Selection
of Protective System. (See 1926.652(b)(1) through (b)(4).)
13
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
(4) In evaluating the design of support systems, shield systems and
their protective systems, the CSHO shall refer to the decision chart found
in Figure 3 of Appendix F, Selection of Protection Systems. (See 29 CFR
1926.652(c)(1) through (c)(4).)
(5) The CSHO shall examine appropriate structural members of any protective
system for damage or defects. (See 29 CFR 1926.652(d)(1).)
(6) Observation by CSHOs of excavations beneath the protective system
requires confirmation that the support system was designed to resist forces
calculated for the full depth of the trench. (See 29 CFR 1926.652 (e)(2)(i)
and (g)(2) .)
e. Appendices in the Standard.
(1) The following compliance guidelines apply whenever CSHOs encounter,
excavation operations where employers have elected to provide protective
systems using the appendices in this standard. CSHOs shall provide documentation,
including soil tests where applicable, to support or reject the employer's
decisions on protective systems.
(2) When the employer elects to use sloping option 2 or support option
1, the soils classification procedures are mandatory. Employer guesses
or other shortcuts taken in classifying soils do not meet the intent of
the standard.
(a) Thus, citations shall be issued where one or more provisions of
Appendix A have been violated even
14
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
if the degree of sloping turns out to be appropriate.
(b) Example: A backhoe operator slopes an excavation at what turns out
to be an appropriate slope, but the operator is not a competent person
within the meaning of the standard, and his determination was not based
on both one visual and one manual test. 1926.652(a) will be cited, but
the gravity of the violation will be reduced. (See 29 CFR 1926.652(a) (1)
.)
f. Appendix A to Subpart P - Soil Classification. This appendix describes
a method of classifying soil and rock deposits based on site and environmental
conditions and on the structure and compaction of earth deposits. Appendix
A contains further definition directly related to soil classification.
(1) The classification of soil and rock deposits shall be made based
on the results of at least one visual and one manual test.
(a) Such analysis shall be conducted by a competent person using the
tests described in paragraph (d) of this appendix.
(b) The specific soil tests referenced in this Appendix are given as
examples for an employer to use in making a soil classification. However,
other recognized methods of soil classification and testing, such or those
adopted by the American Society for Testing Materials (ASTM) , are acceptable
for purposes of compliance with the standard.
15
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
(c) The competent person conducting the soil classification may not
base a classification by "feeling" the strength or composition of the soil
through the use of heavy equipment.
1 This method is not an acceptable "other recognized method" of soil
classification and testing" contemplated by Appendix A, (c) (2).
2 OSHA believes this is too indirect a method to classify properly the
qualitative as well as the quantitative properties of soil.
3 For example, an employer may not classify the soil as Type A solely
because its backhoe experienced difficulty digging the excavation.
(2) Each soil and rock deposit shall have been classified by a competent
person as either stable rock, Type A, Type B, or Type C in accordance with
the definitions set forth in paragraph (b) of Appendix A.
(3) In a layered system, the system shall have been classified in accordance
with its weakest layer. However, each layer may be classified individually
where a more stable layer lies under a less stable layer.
(4) If, after classifying soils and rock deposits, the properties, factors,
or conditions affecting its classification
16
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
change in any manner, such as after a rainstorm, such changes shall
have been evaluated by the competent person on site. The soil and rock
deposits shall have been reclassified as necessary to reflect any changed
circumstances.
g. Appendix B to Subpart P - Sloping and Benching. Under section (c)(3)(ii)
of this Appendix, whenever surcharge loads from stored material or equipment,
operating equipment, or traffic are to be present, the competent person's
determination of the degree to which the actual slope must be reduced below
the maximum allowable slope shall have been based on the requirements set
forth in (c) (3) (ii). The requirement to slope back in accordance with
(c) (3) (ii) shall be triggered in situations where the surcharge loads
cause signs of distress.
h. Appendix C to Subpart P - Tables. The compliance officer should note
that Tables C-1.1-1.3 are actual size measurements based on mixed oak or
equivalent with a bending strength not less than 850 psi. On the other
hand, Tables C-2.1, 2.2 and 2.3 are nominal (S4S-Surface 4 Sides) measurements
based on Douglas fir or equivalent with a bending strength not less than
1500 psi.
i. Appendix D to Subpart P - Aluminum Hydraulic Shoring for Trenches.
This appendix contains criteria that can be used when aluminum hydraulic
shoring is to be used as a method of protection in trenches not exceeding
20 feet in depth, in the absence of manufacturer's tabulated data. The
appendix is provided for those situations where manufacturers' data, permitted
under paragraph 1926.652(c) (2), has been lost or is otherwise not available.
When referenced, Appendix D must be used in
17
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
conjunction with Appendix A, Soil Classification.
I. Training. Field inspection procedures must be modified to reflect
the more technical nature of soils classification and protection systems
requirements of the new standard. To classify soils properly, visual and
manual tests must now be performed. It is imperative that CSHOs be trained
in the techniques used in these tests. The training program will consist
of detailed instructions on the new standard and the compliance directive.
1. Train-the-trainer sessions on the new standard will be conducted
at the OSHA Training Institute. These trainers will then conduct sessions
for their respective Regional and Area Offices.
2. This program will supplement OSHA Training Institute Course 301,
Excavation, Trenching and Soils. Additional training will be developed
and presented as needed to maintain currency of the new excavation standard
for CSHOs.
J. SAVEs. Existing SAVEs for 29 CFR 1926.651 and 1926.652 as found in
the existing Construction SAVEs Manual, OSHA Instruction CPL 2.34, shall
not be used for citation of excavation or trenching violations after March
5, 1990. The attached draft SAVEs are provided for interim use and may
be modified, as deemed appropriate, at the discretion of the Regional Administrator,
to accommodate local circumstances, until the final SAVEs are published
and distributed.
Gerard F. Scannell Assistant Secretary
18
OSHA Instruction CPL 2.87 FEB 20, 1990 Directorate of Compliance Programs
Distribution: National, Regional, and Area offices, All Compliance Officers,
State Plan Designees, Consultation Project Managers NIOSH Regional Program
Directors
19
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
DRAFT SAVEs
1 29 CFR 1926.651(a): All surface encumbrances that were located so
as to create a hazard to employees were not removed or supported, as necessary,
to safeguard employees:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY)
2 29 CFR 1926.651(b)(1): The estimated location of underground utility
installations, such as sewer, telephone, fuel, electric, water lines, or
any other underground installations that reasonably may be expected to
be encountered during excavation work, were not determined prior to opening
an excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT UTILITY WAS ENCOUNTERED DURING EXCAVATING
OPERATIONS)
3 29 CFR 1926,651(b)(2): Utility companies or owners were not contacted
within established or customary local response times, advised of the proposed
work, and asked to establish the location of the utility underground installations
prior to the start of an actual excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY)
4 29 CFR 1926 651(b)(3): When excavation operations approached the estimated
location of underground installations, the exact location of the installations
was not determined by safe and acceptable means:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT SHOULD HAVE BEEN A SAFE AND ACCEPTABLE
MEANS TO FIND THE UNDERGROUND UTILITY)
A-1
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.651(b) (4): While the excavation was opened, underground
installations were not protected, supported or removed as necessary to
safeguard employees:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT SHOULD HAVE BEEN PROVIDED TO SAFEGUARD
THE EMPLOYEES)
OPTION 1 2 29 CFR 1926.651(c)(1)(i): Structural ramps that were used
solely by employees as a means of access or egress from excavations were
not designed by a competent person:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT THE RAMP(S) WERE BEING USED FOR BY THE
EMPLOYEES)
OPTION 2 3 29 CFR 1926.651(c)(1)(i): Structural ramps used for access
or egress of equipment were not designed by a competent person qualified
in structural design:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND THE COMPETENT PERSON'S LACK OF QUALIFICATIONS
IN STRUCTURAL DESIGNS)
OPTION 3 4 29 CFR 1926.651(c)(1)(i): Structural ramps used for access
or egress by employees were not constructed in accordance with the design:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHY THE RAMPS DID NOT MEET THE DESIGN)
A-2
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.651(c)(1)(ii): Ramps and runways constructed of two or
more structural members did not have the structural members connected together
to prevent displacement:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY)
2 29 CFR 1926.651(c)(1)(iii) Structural members used for ramps and runways
were not of uniform thickness:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY)
OPTION 1 3 29 CFR 1926.651(c)(1)(iv): Cleats or other appropriate means
used to connect runway structural members were not attached to the bottom
of the runway:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT MEANS WAS USED TO CONNECT THE MEMBERS
TOGETHER)
OPTION 2
4 29 CFR 1926.651(c)(1)(iv): Cleats or other appropriate means used
to connect runway structural members were not attached in such a manner
to prevent tripping:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND HOW STRUCTURAL MEMBERS WERE CONNECTED TO
CAUSE A TRIPPING HAZARD)
A-3
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.651(c)(1)(v): Structural ramps used in lieu of steps were
not provided with cleats or other surface treatments on the top surface
to prevent slipping:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT IF ANYTHING WAS PROVIDED ON THE RAMP
SURFACE)
2 29 CFR 1926.651(c)(2): A stairway, ladder, ramp or other safe means
of egress was not located in trench excavations that were 4 feet (1.22m)
or more in depth so as to require no more than 25 feet (7.62m) of lateral
travel for employees:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, MEASUREMENTS AS NEEDED, AND WHAT IF ANYTHING
WAS PROVIDED)
OPTION 1 3 29 CFR 1926.651(d): Employees exposed to public vehicular
traffic were not provided with a warning vest or other suitable garments
marked with or made of reflectorized or high-visibility material:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY)
OPTION 2 4 29 CFR 1926.651(d): Employees exposed to public vehicular
traffic were not required to wear warning vest provided by the employer:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
WHAT IF ANYTHING THE EMPLOYEE(S) WERE WEARING TO WARN THE TRAFFIC IN THE
AREA)
OPTION 1 5 29 CFR 1926.651(e): Employee was not prohibited to be underneath
loads handled by lifting or digging equipment:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
EQUIPMENT BEING USED)
A-4
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
OPTION 2 1 29 CFR 1926.651(e): Employees were not required to stand
away from any vehicles being loaded or unloaded to avoid being struck by
any spillage or falling materials:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
EQUIPMENT, WHETHER LOADING OR UNLOADING, AND TYPE OF MATERIAL BEING HANDLED
BY THE EQUIPMENT)
2 29 CFR 1926.651(f): A warning system was not utilized such as barricades,
hand or mechanical signals, or stop logs when mobile equipment was operated
adjacent to an excavation, when such equipment was required to approach
the edge of an excavation, and the operator did not have a clear and direct
view of the edge of the excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
WHAT IF ANYTHING WAS WRONG WITH THE WARNING SYSTEM PROVIDED, AND WHAT OBSTRUCTED
THE OPERATOR'S VIEW)
3 29 CFR 1926.651(g)(1)(i): Where oxygen deficiency atmosphere containing
less than 19.5 percent oxygen or a hazardous atmosphere existed or could
reasonably be expected to exist, such as in excavations in landfill areas
or excavations in areas where hazardous substances are stored nearby, the
atmospheres in the excavation were not tested before employees entered
excavations greater than 4 feet (1.22m) in depth:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
TYPE OF HAZARD(S) WHERE NECESSARY, WHAT THE OXYGEN PERCENT LEVEL TAKEN
WAS, AND DEPTH OF EXCAVATION MEASUREMENT OBTAINED)
4 29 CFR 1926.651(g)(1)(ii): Adequate precautions were not taken to
prevent employee exposure to atmospheres containing less than 19.5 percent
oxygen and other hazardous atmospheres:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHAT WAS LACKING IN PRECAUTIONS TAKEN)
A-5
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.651(g)(1)(iii): Adequate precautions were not taken such
as providing ventilation, to prevent employee exposure to an atmosphere
containing a concentration of a flammable gas in excess of 20 percent of
the lower flammable limit of the gas:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, TYPE OF GAS ENCOUNTERED, AND PERCENT OF GAS
OVER THE LOWER LIMIT)
2 29 CFR 1926.651(g)(1)(iv): When controls were used that were intended
to reduce the level of atmospheric contaminants to acceptable levels, testing
was not conducted as often as necessary to ensure that the atmosphere remains
safe:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, TYPE OF CONTROLS BEING USED, AND ATMOSPHERIC
CONTAMINANTS)
OPTION 1 3 29 CFR 1926.651(g)(2)(i): Emergency rescue equipment, such
as breathing apparatus, a safety harness and line, or a basket stretcher,
was not readily available where hazardous atmosphere conditions existed
or could reasonably be expected to develop during work in an excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, THE NEED FOR ANY OR ALL OF THIS EQUIPMENT, AND
LOCATION OF EQUIPMENT PROVIDED)
OPTION 2 4 29 CFR 1926.651(g)(2)(i): Emergency rescue equipment listed
in this section was not attended when in use:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND WHY THE EQUIPMENT WAS NOT ATTENDED)
A-6
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
OPTION 1 1 29 CFR 1926.651(g)(2)(ii): Employees entering bell-bottom
pier holes, or other similar deep and confined footing excavations, did
not wear a harness with a lifeline securely attached to it:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY AND WHAT THE EMPLOYEES WERE ENTERING)
OPTION 2 2 29 CFR 1926.651(g)(2)(ii): The lifeline provided for employee
protection was not separate from any line used to handle materials:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, AND TO WHAT THE EMPLOYEE LIFELINE WAS ATTACHED)
OPTION 3 3 29 CFR 1926.651(g)(2)(ii): The employee lifeline was not
individually attended at all times while the employee wearing the lifeline
was in the excavation:
(A) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY AND DETERMINE AS TO WHY THE LIFELINE WAS NOT
ATTENDED)
4 29 CFR 1926.651(h)(1): Employees were permitted to work in excavations
in which there was accumulated water, or excavations in which water was
accumulating, and adequate precautions had not been taken to protect employees
against the hazards posed by water accumulation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, WHAT PRECAUTIONS THE EMPLOYER WAS LACKING, AND
WHERE WAS THE WATER COMING FROM)
A-7
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.651(h)(2): Where water was controlled or prevented from
accumulating by use of water removal equipment, the water removal equipment
and operations were not monitored by a competent person to ensure proper
operation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
AND IDENTIFY WATER REMOVAL EQUIPMENT BEING USED, AND HAZARDS INVOLVED)
OPTION 1 2 29 CFR 1926.651 (h)(3): Where excavation work interrupted
the natural drainage of surface water such as streams, diversion ditches,
dikes, or other suitable means were not used to prevent surface water from
entering the excavation and to provide adequate drainage of the area adjacent
to the excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
EXCAVATION WORK BEING ACCOMPLISHED, AND HAZARDS WHERE NECESSARY)
OPTION 2 3 29 CFR 1926.651(h)(3): Excavations subject to run-off from
heavy rains were not inspected by a competent person to ensure compliance
with paragraphs (h)(1) and (h)(2) of this section:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, PROVIDE DATE OF LAST INSPECTION AND LAST HEAVY
RAIN)
4 29 CFR 1926.651(i)(1): Where the stability of adjoining buildings,
walls, or other structures was endangered by excavation operations, support
systems such as shoring, bracing or underpinning was not provided to ensure
the stability of such structures for the protection of employees:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
WHAT WAS ENDANGERED RESULTING FROM EXCAVATION OPERATIONS, AND WHAT IF ANY
TYPE OF SUPPORT SYSTEM WAS PROVIDED)
A-8
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.651(i)(2): Excavation below the level of the base or footing
of any foundation or retaining wall that could be reasonably expected to
pose a hazard to the employees was not prohibited:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, WHAT THE EXCAVATION WAS EXCAVATED BELOW OF)
NOTE: See exceptions listed in paragraphs (i)-(iv) of this section
2 29 CFR 1926.651(i)(3): A support system or another method of protection
was not provided beneath sidewalks, pavements, and appurtenant structures
to protect employees from the possible collapse of such structures:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
TYPE OF STRUCTURE NEEDING SUPPORT AND ANY INADEQUATE SUPPORT SYSTEM PROVIDED)
OPTION 1 3 29 CFR 1926.651(j)(1): Adequate protection was not provided
to protect employees from loose rock or soil that could pose a hazard by
falling or rolling from an excavation face:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT IF ANYTHING WAS PROVIDED)
OPTION 2 4 29 CFR 1926.651(j)(1): Equivalent protection to protect employees
such as scaling to remove loose materials; installation of protective barricades
at intervals as necessary on the face to stop and contain falling material
was not provided to protect employees:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT TYPE OF PROTECTION SHOULD HAVE BEEN PROVIDED
TO PROTECT THE EMPLOYEES)
A-9
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Assistance Assistance
OPTION 1 1 29 CFR 1926.651(j)(2): Employees were not protected from
excavated or other materials or equipment that could pose a hazard by falling
or rolling into excavations:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, MATERIAL OR EQUIPMENT, AND WHAT PROTECTION SHOULD
HAVE BEEN PROVIDED)
Option 2 2 29 CFR 1926.651(j)(2): Protection was not provided by placing
and keeping such materials or equipment at least 2 feet (.61m) from the
edge of excavations, or by the use of retaining devices that were sufficient
to prevent materials or equipment from falling or rolling into excavations,
or by a combination of both if necessary:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS.) (DESCRIBE
HAZARDS WHERE NECESSARY, MATERIALS OR EQUIPMENT, AND WHAT PROTECTION SHOULD
HAVE BEEN PROVIDED)
OPTION 1 3 29 CFR 1926.651(k)(1): Daily inspections of excavations,
the adjacent areas, and protective systems were not made by a competent
person for evidence of a situation that could have resulted in possible
cave-ins, indications of failure of protective systems, hazardous atmospheres,
or other hazardous conditions:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHEN THE LAST DAILY INSPECTION WAS CONDUCTED)
OPTION 2 4 29 CFR 1926.651(k)(1): An inspection was not conducted by
the competent person prior to the start of work and as needed throughout
the shift:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, AND WHAT INDICATED THAT INSPECTION WAS NOT CONDUCTED
BEFORE AND AFTER WORK HAS STARTED)
A-10
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Assistance Assistance
OPTION 3 1 29 CFR 1926.651(k)(1): Inspections were not made after every
rainstorm or other hazard increasing occurrence:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT INDICATED AN INSPECTION WAS NEEDED)
2 29 CFR 1926.651(k)(2): Where the competent person found evidence of
a situation that could result in a possible cave-in, indications of failure
of protective systems, hazardous atmospheres, or other hazardous conditions,
exposed employees were not removed from the hazardous area until the necessary
precautions had been taken to ensure their safety:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS UNSAFE AND WHAT PRECAUTIONS SHOULD HAVE
BEEN TAKEN)
3 29 CFR 1926.651(l)(1): Where employees or equipment are required or
permitted to cross over excavations, walkways or bridges with standard
guardrails were not provided:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS LACKING GUARDRAILS, AND PROVIDE OVERALL
MEASUREMENTS INCLUDING THE FALLING DISTANCE)
OPTION 1 4 29 CFR 1926.651(l)(2): Adequate barrier physical protection
was not provided at all remotely located excavations:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT TYPE OF PHYSICAL BARRIER SHOULD HAVE
BEEN PROVIDED)
A-11
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
OPTION 2 1 29 CFR 1926.651(l)(2): All wells, pits, shafts, etc., were
not barricaded or covered:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT SHOULD HAVE BEEN PROVIDED)
OPTION 3 2 29 CFR 1926.651(l)(2): Upon completion of exploration and
similar operations, temporary wells, pits, shafts, etc., were not backfilled:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHEN OPERATIONS WERE COMPLETED)
3 29 CFR 1926.652(a)(1): Each employee in an excavation was not protected
from cave-ins by an adequate protective system designed in accordance with
paragraph (b) or (c) of this section:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS LACKING IN PROTECTIVE SYSTEM DESIGN)
NOTE: See exception in (i) and (ii) of this section
4 29 CFR 1926.652(a)(2): Protective systems did not have the capacity
to resist without failure all loads that were intended or could reasonably
be expected to be applied or transmitted to the system:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS LACKING IN THE PROTECTIVE SYSTEM
TO CAUSE A FAILURE)
A-12
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
OPTION 1 1 29 CFR 1926.652(b): The slopes and configurations of slope
and benching systems were not selected and constructed by the employer
or his designee:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHO MADE THE SELECTION OF THE SYSTEM TO BE
USED)
OPTION 2 2 29 CFR 1926.652(b): The slopes and configurations of sloping
and benching systems selected to be used were not constructed in accordance
with the requirements of paragraph (b)(1):
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS LACKING IN THE SYSTEM THE EMPLOYER SELECTED
TO USE)
OPTION 1 3 29 CFR 1926.652(c): Designs of support systems shield systems,
and other protective systems were not selected and constructed by the employer
or his designee:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHO SELECTED THE PROTECTIVE SYSTEM, OR SHIELD
SYSTEM BEING USED)
OPTION 2 4 29 CFR 1926.652(c): Designs of support systems shield systems
being used were not designed and constructed in accordance with the requirements
of paragraph (c)(1); or, in the alternative, paragraph (c)(2); or, in the
alternative, paragraph (c)3); or, in the alternative, paragraph (c)(4):
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS LACKING IN THE DESIGN AND CONSTRUCTION
OF THE SUPPORT SYSTEMS, OR SHIELD SYSTEM BEING USED)
A-13
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.652(d)(1): Materials and equipment used for protective
systems were not free from damage or defects that might impair their proper
function:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS DAMAGE OR DEFECT IN THE MATERIALS OR
EQUIPMENT BEING USED IN THE PROTECTIVE SYSTEM)
OPTION 1 2 29 CFR 1926.652(d)(2): Manufactured materials and equipment
used for protective systems were not maintained in a manner that was consistent
with the recommendations of the manufacture:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS WRONG WITH THE MATERIALS OR EQUIPMENT
BEING USED THAT IT WAS NOT CONSISTENT WITH THE MANUFACTURER'S RECOMMENDATIONS)
OPTION 2 3 29 CFR 1926.652(d)(2): Manufactured materials and equipment
used for protective systems were not used in a manner that was consistent
with the recommendations, and in a manner that would have prevented employee
exposure to hazards:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS WRONG WITH THE MATERIALS OR EQUIPMENT
THAT PRESENTED A HAZARD TO THE EMPLOYEES)
OPTION 1 4 29 CFR 1926.652(d)(3): When material or equipment that was
used for protective systems was damaged, a competent person did not examine
the material or equipment and evaluate its suitability for continued use:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS DAMAGED IN THE PROTECTIVE SYSTEM BEING
USED AND ITS SUITABILITY FOR CONTINUED USE)
A-14
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
OPTION 2 1 29 CFR 1926.652(d)(3): When the competent person could not
ensure that the material or equipment was able to support the intended
loads or was otherwise suitable for safe use, then such material or equipment
was not removed from service:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS DEFECTIVE WITH THE MATERIAL OR EQUIPMENT
THAT NEEDED TO BE REMOVED FROM SERVICE)
OPTION 3 2 29 CFR 1926.652(d)(3): Material or equipment used for protective
systems that was found to be damaged and had been removed from service
was not evaluated and approved by a registered professional engineer before
being returned to service:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS DEFECTIVE IN THE PROTECTIVE SYSTEM
BEING USED, WHO APPROVED THE MATERIAL OR EQUIPMENT TO BE PUT BACK INTO
SERVICE)
3 29 CFR 1926.652(e)(1)(i): Members of support systems were not securely
connected together to prevent sliding, falling, kickouts, or other predictable
failure:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND HOW THE MEMBERS OF THE SUPPORT SYSTEMS WERE
CONNECTED TOGETHER)
4 29 CFR 1926.652(e)(1)(ii): Support systems were not installed and
removed in a manner that protected employees from cave-ins, structural
collapses, or from being struck by members of the support system:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS WRONG WITH THE SUPPORT SYSTEM THAT
IT PRESENTED HAZARD TO EMPLOYEES WHILE BEING INSTALLED OR REMOVED)
A-15
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.652(e)(1)(iii): Individual members of support systems
were subjected to loads exceeding those which those members were designed
to withstand:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT THE LOADS WERE THAT EXCEEDED THOSE THE MEMBERS
OF SUPPORT SYSTEMS WERE DESIGNED TO WITHSTAND)
2 29 CFR 1926.652(e)(1)(iv): Before temporary removal of individual
members was begun, additional precautions were not taken to ensure the
safety of employees, such as installing other structural members to carry
the loads imposed on the support system:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT PRECAUTIONS SHOULD HAVE BEEN TAKEN BY
THE EMPLOYER PRIOR TO TEMPORARY REMOVAL OF SUPPORT SYSTEM MEMBERS)
OPTION 1 3 29 CFR 1926.652(e)(1)(v): Removal of members from support
system did not begin at, and progress from, the bottom of the excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARD(S) WHERE NECESSARY, AND WHERE DID REMOVAL OF MEMBERS OF SUPPORT
SYSTEM BEGIN)
OPTION 2 4 29 CFR 1926.652(e)(1)(v): Members were not released slowly
so as to note any indication of possible failure of the remaining members
of the structure or possible cave-in of the sides of the excavation:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND AREA WHERE MEMBERS WERE RELEASED TOO FAST
INDICATING A FAILURE OR CAVE-IN WAS EVIDENT)
A-16
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.652(e)(1)(vi): Backfilling did not progress together with
removal of support systems from excavations:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHEN DID BACKFILLING START AS THE SUPPORT
SYSTEM WAS REMOVED)
OPTION 1 2 29 CFR 1926.652(e)(2)(i): Excavation of material to a level
no greater than 2 feet (.61m) below the bottom of the members of a support
system was permitted where the system was not designed to resist the forces
calculated for the full depth of the trench, and there were indications
while the trench was open of a possible loss of soil behind or below the
bottom of the support system:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND HOW FAR BELOW SUPPORT SYSTEM EXCAVATING WAS
ACCOMPLISHED)
OPTION 2 3 29 CFR 1926.652(e)(2)(i): Excavation of material to a level
no greater than 2 feet (.61m) below the bottom of the members of the support
system was allowed when there were indications while the trench is open
of a possible loss of soil from behind or below the bottom of the support
system: (a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)
(DESCRIBE HAZARDS WHERE NECESSARY, AND WHERE LOSS OF SOIL WAS OCCURRING)
4 29 CFR 1926.652(e)(2)(ii): Installation of a support system was not
closely coordinated with the excavation of trenches:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHEN WAS THE INSTALLATION OF THE SUPPORT SYSTEM
STARTED RELATIVE TO THE EXCAVATING OPERATION)
A-17
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.652(f): Employees were permitted to work on the faces
of sloped or benched excavations at levels above other employees when employees
at the lower levels were not adequately protected from the hazard of falling,
rolling, or sliding material or equipment:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WERE THE EMPLOYEES WORKING ON THE FACE DOING,
AND WHAT WERE THEY WORKING WITH THAT CREATED A HAZARD)
2 29 CFR 1926.652(g)(1)(i): Shield systems were subjected to loads exceeding
those which the system was designed to withstand:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WERE THE LOADS THE SHIELD SYSTEMS WERE SUBJECTED
TO THAT EXCEEDED THOSE THE SYSTEM WAS DESIGNED TO WITHSTAND)
3 29 CFR 1926.652(g)(1)(ii): Shields were not installed in a manner
to restrict lateral or other hazardous movement of the shield in the event
of the application of sudden lateral loads:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND HOW THE SHIELD WAS INSTALLED TO ALLOW LATERAL
AND OTHER HAZARDOUS MOVEMENT)
4 29 CFR 1926.652(g)(1)(iii): Employees were not protected from the
hazard of cave-ins when entering or exiting the area protected by shields:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHAT WAS DIRECTION OF TRAVEL BY THE EMPLOYEES)
A-18
OSHA Instruction CPL 2.87 February 20, 1990 Office of General Industry
Compliance Assistance
1 29 CFR 1926.652(g)(1)(iv): Employees were allowed in shields when
shields were being installed, removed, or moved vertically:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT WAS BEING DONE WITH THE SHIELD WHILE EMPLOYEES
WERE IN SHIELD)
OPTION 1 2 29 CFR 1926.652(g)(2): Excavations of earth material to a
level no greater than 2 feet (.61m) below the bottom of a shield was permitted,
when the shield was not designed to resist the forces calculated for the
full depth of the trench, and there were indications while the trench was
open of a possible loss of soil from behind or below the bottom of the
shield:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, WHAT INDICATED THAT SHIELD FAILED TO RESIST THE
FORCES CALCULATED AND POSSIBLE LOSS OF SOIL FROM BEHIND THE SHIELD)
OPTION 2 3 29 CFR 1926.652 (g)(2): Excavation of material to a level
no greater than 2 feet (.61m) below the bottom of a shield system was allowed
when there were indications while the trench was open of a possible loss
of soil from behind or below the bottom of the shield system:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE
HAZARDS WHERE NECESSARY, AND WHERE LOSS OF SOIL WAS OCCURRING)
A-19
|