OSHA Directive Revises National Emphasis Program on Trenching & Excavation

10/12/2018

OSHA recently issued a directive that revises implementation guidance for the agency’s National Emphasis Program (NEP) on trenching and excavation operations. This directive will change the way OSHA conducts inspections and other enforcement activities related to these operations.

Let’s take a closer look at the new directive and its potential impacts on your business.

The Background

OSHA first created an NEP (CPL 02-00-0069) for trenching and excavation operations in 1985 in response to a number of serious incidents involving trench/excavation collapses, sometimes resulting in fatalities. The NEP instructed all OSHA compliance personnel to be on the lookout for trenching and excavation worksites, to make note of the state and condition of the work operations, and to contact the Area Office supervisor to determine if inspections were required.

OSHA continued to prioritize inspection and enforcement over the following decades due to the risks associated with these operations, and the persistence of accidents and injuries. Recent trends in safety performance have greatly concerned OSHA, and caused them to revisit the issue. According to Census of Occupational Injuries (CFOI) data, 130 fatalities occurred during trenching and excavation operations between 2011 and 2016, but 49% of those fatalities occurred between 2015 and 2016 alone! The significant recent increase in the fatality rate prompted OSHA to revise its enforcement and compliance assistance activities in an effort to reduce potential risks associated with these operations.

The new directive (CPL-02-00-161) supersedes the 1985 directive. The directive went into effect on October 1, 2018 and revises enforcement activities to better identify and reduce hazards “likely to cause serious injuries and fatalities during trenching and excavation operations.”

What’s Changing?

There are two significant changes that come with the new directive.

First, Section X of the new directive requires compliance officers to record all enforcement and consultation activities for trenching and excavation operations in the OSHA Information System (OIS). This includes inspections, complaints and referrals, and consultation requests and visits. Officers must record all of these activities using the NEP code “TRENCH.” Through this requirement, OSHA establishes a national reporting system for trenching and excavation operations, which will improve the agency’s efficiency in enforcing and following up on enforcement activities.

Second, the directive requires each Area Office/Region to develop outreach programs in support of the emphasis program, and must implement them for at least 90 days prior to initiating inspections under the revised NEP. OSHA indicates that the outreach materials should include compliance assistance for excavation employers, permitting agencies and other municipal organizations, industry associations, equipment rental organizations, water works supply companies and major plumbing companies. OSHA states that during the 90 day period for implementing outreach activities, enforcement will continue under the terms of the 1985 directive.

OSHA has developed new resources to help with outreach and training activities. These resources include:

• A poster called “Protect Workers in Trenches”
• A sticker called “Trench Safety: Slope It. Shore It. Shield It”
• A flash card called “Working Safely in Trenches.”
• A public service announcement on trenching and excavation safety.

What Should I Do?

Given the alarming recent increase in trenching and excavation fatalities and OSHA’s revised enforcement policies, it’s a good time to make sure your operations are safe and in compliance. Be aware that your area OSHA office may soon be conducting outreach activities that can help your business improve trenching and excavation safety. All of the new OSHA resources above can also help you as you train your workforce and mitigate risks in your operations.

On its Trenching and Excavation page, OSHA also provides several concrete recommendations. They advise employers to prevent cave-ins by sloping or benching/tiering trench walls, shoring walls with supports, or shielding trench walls with trench boxes. They also state that employers should ensure there is a safe way to enter and exit the trench, keep materials away from the edge of the trench, and monitor for standing water or atmospheric hazards – which means that employers must be able to identify chemicals used in the work area in order to properly monitor airborne concentrations and mitigate hazards. OSHA also emphasizes that no one should enter a trench unless it has been properly inspected.

All of this really points to the importance of a pro-active safety management approach, driven by inspections and continuous improvement.

Let VelocityEHS Help!

Our Audit & Inspection solution is just the right tool to help you gain better insight and control over your trenching and excavation safety. You’ll be able to easily schedule and manage inspections, and build tailored checklists to deploy in real-time in the field using the VelocityEHS Mobile App. Our Corrective Actions solution then allows you to seamlessly assign and track all follow-up actions from your inspections, helping ensure that nothing gets overlooked.

You’ll have even greater safety management control with our MSDSonline SDS & Chemical Management software. Our award-winning solutions give you and your workforce 24-hour access to your library of SDSs, letting you retrieve critical chemical hazard information whenever you need it and ensuring that your monitoring program incorporates the most accurate and up-to-date details about the chemicals in your inventory.

With the right tools in place, you’ll be better prepared for future OSHA inspections and will have the resources you need to maintain a proactive and effective culture of safety.