Getting Into Compliance
The written plan was step one. Training — for myself, my foreman, and my crew — was step two. OSHA requires that you formally designate one person to be responsible for managing safety at your company. Big companies should have somebody on staff whose only task is to make sure safety is in order. Small residential companies who barely have the cash to make payroll can’t afford a dedicated safety officer, but someone has to step up and fill that role. In my company, that person is me. You also have to have a “competent person” at every job site who knows the safety rules and is familiar with the written plan. My foreman, Frank Camara, is the “competent person” on most of our sites, though one of my other supervisors, Peter LaTour, can also fill that role.
The “competent person” has to take a 10-hour formal training class from a qualified OSHA-accredited trainer. But I decided to go a step further and send most of my staff to the class. Now most of my employees carry a card in their wallets certifying that they’ve been trained in safety practices. Next time an OSHA inspector shows up, they’ll be able to show not only their copies of our safety plan, but training cards as well.
Beyond the training and the organizational adjustments, I had to invest in some equipment. I spent some money on scaffolding, including outrigger staging like that shown at the top of the facing page.
I also bought personal protective equipment for my workers. Each employee has a “safety bag” containing the important gear: a hard hat, goggles, gloves, hearing protection, and a fall-protection harness. Workers keep their copies of the safety plan in this bag, too.
I’m not going to try to describe all the safety rules contained in the 10-hour OSHA course, or all the items covered in our written plan. You should take the course yourself, and you need your own written plan. But I do want to explain how we now handle safety in the situation we first got busted for: setting trusses. This fall, we happened to be framing a roof on the same development where I was previously cited for violations. So we had a chance to do everything right that we had been doing wrong the day we got in trouble with OSHA. The photos in this story are from that day’s work, with our full safety plan in place.
Special Rules for Residential
Back in the 1990s, during a boom in home building, OSHA started to increase its enforcement activity on residential sites. But when the agency got a lot of negative feedback from home builders, it ended up admitting that the rules for industrial or commercial sites didn’t really make sense for house framing. So it developed some rules just for residential framing — in particular for the type of work where scaffolding or fall-protection harnesses are not practical.
Setting trusses is one example of this kind of work. You can’t use a fall-protection harness, because there’s nothing to tie off to. You can’t really use a scaffold for most of the work, either, because it would get in the way of the trusses. And some carpenters will have to climb up on the trusses to install spacers and bracing before the trusses themselves are stable. OSHA calls this “leading edge” work; other examples are sheathing a roof or floor frame and standing second-story walls.
So, rather than insist on traditional scaffolding and tie-off rules for these activities, OSHA allows builders to use alternative safe practices — methods that rely on planning, supervision, and organization. You still have to have a written safety plan in place, with a designated “competent person” in charge on site. But how you set the trusses — the exact process that you use — is your responsibility.