Every company should be focused on eliminating or controlling “struck-by” hazards.
Typical causes of struck-by hazards include traffic passing through a work zone; vehicle and equipment movement within a work zone; rotating or swinging equipment (such as an excavator); and thrown or falling loads, tools, or items.
Occupational Safety and Health Administration (OSHA) standards establish minimum legal requirements for safety programs, and many employers look to OSHA when creating company safety plans and policies. It is essential to underline the word minimum because OSHA standards lag behind the current national consensus standards and recognized industry safety practices. OSHA also cannot address every element of the work, so it is possible to meet the existing legal standard but still have employees exposed to severe hazards. An employer committed to protecting workers from struck-by hazards must set their sights higher than the OSHA minimums, looking to ANSI consensus standards and industry practices for guidance in establishing company policies.
Starting at the most general level, the OSHA General Duty clause requires employers to provide work and a place of work that are reasonably safe: “free from recognized hazards causing or likely to cause death or serious physical harm.” Work sites must be managed, and workers must be trained to recognize and avoid hazards. This is a very broad requirement. OSHA construction standard 29 CFR 1926.21(b)(2) states, “The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.” About half the states in the U.S. have OSHA state plans—which may have stronger standards than federal OSHA; it therefore behooves the contractor to check their jurisdiction for details.
Company policies and site-specific procedures must comply with or exceed OSHA standards. Preventing struck-by hazards starts in the planning phase, and efforts must be monitored and adapted as the work site changes. Management must plan where machinery and workers will operate, where traffic will flow, and how they all will safely interact—balancing safety for the public and workers.
A well-marked perimeter establishes the boundary to alert the public and keep people out of harm’s way. An internal traffic control plan (ITCP) helps to avoid conflicts between workers and moving equipment. Separating workers on foot from heavy equipment and traffic with barriers (“positive protection”) is the safest practice, but may not always be possible given the configuration of the jobsite. Struck-by safety is a shared responsibility; to the extent possible, equipment operators must be trained to avoid operating so as to strike workers, workers must be trained to avoid working or walking where they can be struck, and supervisors must ensure that everyone follows their training, policies, and the ITCP. Management must anticipate travel paths for workers on foot and avoid having foot traffic cross vehicle pathways where possible. Workers must be trained to make radio or eye contact with the equipment operator and receive positive confirmation from the operator before approaching heavy equipment.
Roadway work zone safety is enforced by OSHA, and the details are found in section 6 of the Manual on Uniform Traffic Control Devices (MUTCD). OSHA construction standard 29 CFR 1926.201(a) states that signaling by flaggers (temporary traffic control), use of flaggers, and warning garments worn by flaggers must conform to the MUTCD 2009 edition with revisions 1 and 2. Technology and consensus standards for high-visibility safety apparel (HVSA) have improved dramatically in recent years. OSHA has also published compliance directive CPL 02-01-054 on how it will inspect work zones and issue citations, and that directive can be downloaded free from osha.gov. This CPL provides valuable insight into developing work zone safety practices and avoiding citations. Flaggers need minimum four-hour flagger training courses, and states vary in recognizing flagger training from the National Safety Council (NSC) or American Traffic Safety Services Association (ATSSA) or both. Flagger certification typically must be refreshed every four years.
American National Standard for High-Visibility Safety Apparel and Accessories, ANSI/ISEA 107-2015, is the go-to reference document concerning safety wear. Workers exposed to roadway traffic must wear at least ANSI performance Class 2 high-visibility garments, and those working on interstate highways must wear an ensemble that meets ANSI performance Class 3 requirements. In the latest version of the standard, HVSA garments are now also categorized as type O (off-road), type R (roadway), and type P (public safety). A Class 2 ANSI garment is a vest, and a Class 3 ANSI garment is a vest with sleeves or a Class 2 vest plus high-visibility pants.
There is no specific OSHA standard for non-roadway struck-by hazards, but the hazards are recognized in various industries, and the OSHA General Duty Clause applies. OSHA general industry standard 29 CFR 1910.132(d) requires the employer to “assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).” OSHA construction standard 29 CFR 1926.28 makes the employer responsible for “requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the need for using such equipment to reduce the hazards to the employees.” The ANSI/ISEA 107-2015 standard refers to HVSA as PPE, and responsible employers are requiring workers to wear high-visibility garments due to struck-by hazards on the jobsite and in other areas where increasing conspicuity reduces risk.
Backup alarms and spotters
OSHA construction standard 29 CFR 1926.601(b)(4) states, “No employer shall use any motor vehicle equipment having an obstructed view to the rear unless (i) the vehicle has a reverse signal alarm audible above the surrounding noise level or (ii) the vehicle is backed up only when an observer signals that it is safe to do so.” The standard may appear to offer two equal choices with no preference or weight given to either. Backup alarm is listed first, while the spotter is listed second, so the spotter may be seen by some as the lesser alternative. The reality is that when the view to the rear is obstructed, proper use of a trained observer (“spotter”) is a far safer choice than relying on a backup alarm alone. Despite wide use of backup alarms, workers are still struck, injured, and killed by reversing vehicles and equipment. Workers on foot can become accustomed to frequent backup alarm sounds from equipment around them, and may become complacent or confused. So then, where is the guidance for proper use of a spotter?
American National Standard ANSI A10.47-2015 is the current reference and offers detailed guidance on backing construction vehicles and equipment in the presence of workers on foot. While it is grouped within the A10 construction standards, the principles apply wherever heavy equipment and people on foot interact.
Drivers and spotters must agree on the meaning of hand signals, and radio communication is preferred in addition to hand signals. Inexpensive two-way FRS (Family Radio Service) radios can be used. One spotter should be directly tasked with safely directing the driver of the backing vehicle or equipment and should have no other duties that interfere. Spotters need to be trained to perform their duties safely and consistently without distractions; must not stand in the path of the vehicle or equipment; must wear high-visibility safety apparel; and must remain in the driver’s line of sight at all times. Spotters must not walk backwards while directing the vehicle or equipment, since a trip or slip could put them in harm’s way. For longer maneuvers, the spotter should take a position, direct the vehicle or equipment to a reasonable point, stop the vehicle or equipment while the spotter relocates, then resume directing.
Vehicle or equipment operators must also be trained on how to work safely with a spotter; must keep the spotter in view at all times; must obey the spotter’s signals; must keep glass and mirrors clean and in good repair; and must immediately stop if they lose sight of the spotter. The driver and spotter need to agree on where the spotter will move during complex maneuvers with limited sightlines, such as cresting a hill or making a K-turn.
A 1987 OSHA memo explains what obstructed view means. A simple interpretation would be “anything” that would “block out” or interfere with the overall view of the operator of the vehicle to the rear of the vehicle, at ground level. “Obstructed view to the rear” could include such obstacles as: any part of the vehicle; its load (gravel, dirt, rip-rap); its height relative to ground level viewing; or damage to windows or side mirrors used for rearview movement of the vehicle. It could also include restricted visibility due to weather conditions such as heavy fog or work being done after dark without proper lighting. In short, if there is any interference with the operator’s view to the rear, assistance is needed while backing. From most to least effective, that assistance could be a trained spotter, rear-view camera(s), rear-facing sensors, or a backup alarm.
Training is widely available. The American Road and Transportation Builders Association (ARTBA) offers a four-hour course on preventing run-over and back-over incidents. ATSSA offers work zone Traffic Control Technician and Traffic Control Supervisor training. Industry safety conferences routinely offer courses on struck-by prevention and work zone safety.
Struck-by hazards can be controlled through a commitment to strong safety policies and procedures, worker training, high-visibility safety apparel, proper use of trained spotters, clean and well-maintained equipment, and technology such as cameras, sensors, and backup alarms. Each team member plays a role in worker safety.