Safety Corner
Emphasis Programs
Enforcement strategies by national and local safety offices
By Sean Dewalt
Sean Dewalt

esources are limited for Occupational Safety and Health Administration (OSHA) enforcement, so the agency has implemented National Emphasis Programs (NEPs) as a temporary focus on particular hazards and high-hazard industries. Existing and potential NEPs are evaluated using inspection data, injury and illness data, National Institute for Occupational Safety and Health reports, peer-reviewed literature, analysis of inspection findings, and other available information sources.

At a more granular level, Local Emphasis Programs (LEPs) are enforcement strategies designed and implemented at the regional office and/or area office levels. These programs are intended to address hazards or industries that pose a particular risk to workers in that office’s jurisdiction. The emphasis programs may be implemented by a single area office or at the regional level (Regional Emphasis Programs) and applied to all area offices within the region. These LEPs are accompanied by outreach intended to make employers in the area aware of the program as well as the hazards that the programs are designed to reduce or eliminate. This outreach may be in the form of informational mailings, training at local trade shows, or speeches at meetings of industry groups or labor organizations.

State Implements OSHA Programs
Since June 7, 2023, the Alaska Occupational Safety and Health (AKOSH) has adopted and implemented three new emphasis programs under its program directives.

That June NEP on falls (CPL 03-22-025) was implemented “to ensure uniform implementation of the National Emphasis Program (NEP) to reduce or eliminate injuries and fatalities associated with falls while working at heights in all industries.” On September 22, 2023, AKOSH unveiled another NEP pertaining to warehousing, transportation warehousing, and distribution center operations; mail/postal processing and distribution centers; parcel delivery/courier services; and certain high injury rate retail establishments focused on “workplace hazards common to those industries, including powered industrial vehicle operations, material handling/storage, walking-working surfaces, means of egress, and fire protection.”

Eight days later, on September 30, 2023, an emphasis program to prevent occupational injuries and illnesses among Alaskan workers in the construction industry was implemented. This LEP focuses on the “hazards of fall from elevation, caught-in/between, struck-by, electrocution, exposure to crystalline silica, high noise, hazardous chemicals and ergonomics.” This directive applies to all construction worksites in Alaska that are under AKOSH jurisdiction.

There are currently ten AKOSH compliance safety and health officers in Alaska tasked with carrying out inspections for these newly implemented emphasis programs. Additionally, there are also ten AKOSH consultants. The Consultation and Training Section provides free and confidential assistance to help employers recognize, evaluate workplace hazards, and implement adequate controls. Separate from enforcement, consultants do not issue citations or penalties. This is a great way for companies to have safety professionals assist the business in reducing risk to workers without cost.

Construction Concentration
The latest numbers from Associated General Contractors states there are roughly 2,540 construction industry employers in Alaska that together employ more than 23,000 workers. Because of the nature of construction and associated hazards, advanced targeting of employers is not practical for AKOSH; therefore, the inspections will rely on AKOSH enforcement officers’ field observations, formal and non-formal complaints, and referrals from other outside sources. Due to the nature of many construction sites being highly visible, these jobsites are susceptible to an enforcement inspection with zero advance notice.

The construction industry accounts for 20 percent of worker deaths in America. The exposures that construction workers encounter on construction sites are well documented. OSHA has concentrated efforts of enforcement, outreach, and education on the “Focus Four” exposures in construction. These four areas of specific concern are falls, caught-in-between, struck by an object, and electrocution.

On construction jobsites, fatalities caused by falls from elevation continue to be a leading cause of death for construction employees, accounting for 395 of the 1,069 construction fatalities recorded in 2022. One way that companies can address falls from heights is to conduct a “Safety Stand-Down.” This is a planned work stoppage to have a safety meeting or another safety activity such as safety equipment inspections, developing rescue plans, or discussing job-specific hazards. Managers are encouraged to plan a stand-down that works best for their workplace anytime. The annual OSHA “National Safety Stand Down To Prevent Falls in Construction” is May 6 – 10, 2024. Anyone can participate in these proactive activities, and it is another good way to address hazards in the construction industry.

Electrocution hazards are sometimes invisible. Electrical hazards training for all affected employees should be conducted on-site prior to commencing work, and only qualified electrical professionals should perform electrical work. Grounding, accidental contact with energized lines, exposed panels, and proper extension cord use are just a few of the hazards workers face. OSHA recommends training workers on the acronym BE SAFE (Burns, Electrocution, Shock, Arc Flash/Blast, Fire, Explosives). Acronyms often help people to remember a safer approach to job tasks and help to better assess risks.

OSHA has concentrated efforts of enforcement, outreach, and education on the “Focus Four” exposures in construction. These four areas of specific concern are falls, caught-in-between, struck by an object, and electrocution.
When working around equipment, tool and process-specific trainings are vital to avoid caught-in-between. These are injuries resulting from a person being squeezed, caught, crushed, pinched, or compressed between two or more objects, or between parts of an object. Some examples of controls to help prevent these injuries include guards on equipment, proper use of tools that include a pre-work inspection for deficiencies, a good understanding of kinetic and potential energy, and the potential for cave-ins during trenching. Job hazard analyses of these tasks can provide a good way for workers to see what steps can be taken to mitigate the caught-in-between hazards.

Situational awareness and good communication are the keys to working around mobile equipment, powered industrial trucks, and vehicles. To help reduce the chances of being struck by an object, tool, or equipment, always be aware of your surroundings. When working around heavy equipment, ensure the operator can see you by making eye contact. Operators should be formally trained and knowledgeable about the capabilities and limitations of the equipment they are operating and conduct daily inspections. Never work under suspended loads. An administrative control such as a “10-feet rule” where no employee is allowed within a 10-foot radius of the suspended load in case of equipment malfunction or an accidental drop can help reduce the potential of worker injury. And if a load is suspended more than 15 feet high, increase that radius to compensate for the added height.

Best Practices Start Now
These local and national emphasis programs are all currently in effect. With the upcoming construction season, it is good practice to re-evaluate the exposures and controls for jobsites. Dusting off the required written safety plans, tailgate talks, and operating procedures are just the beginning. Best practices start with employee training and a solid conveyance of the safety expectations that the company requires.

Encourage a proactive safety culture by promoting safety observations and job hazard analyses. Conduct periodic on-site safety inspections using in-house safety staff, outside assistance from the AKOSH consultation, or your insurance company’s loss control professionals. And if OSHA knocks on your door, have a written and prepared response plan to address the inspection, and know your rights and responsibilities.

Always remember: safety is the key to protecting Alaska’s greatest resource, the Alaskan worker.

Sean Dewalt headshot
Sean Dewalt is a Senior Loss Control Consultant for Umialik Insurance Company in Anchorage. Dewalt has been working in safety and risk management in Alaska since 2000. This column is intended to be informational and is not intended to be construed as legal advice.