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Trenches and Excavations: Some Insights

I’ve surveyed or spoken to quite a few companies during my career that have a trunk-full of excavation/trenching recorded safety training sheets or certificates; they have a safety program that spells out (or actually regurgitates the OSHA standards) the safety rules for trench work.

Pat Stark

Pat Stark, CHST, PCC, PCG
Safety and Health Consultant

Usually all employees have “signed off” that they’ve read and will abide by these “rules.” A person has been trained and has been designated by the company as the competent person in excavation/trenching. Yet, some of these same companies have been cited by OSHA for trench/excavation violations—frequently for not using protective systems, or for spoils piles too close to the trench edge. Though workers, supervisors and managers may receive applicable safety training, or re-training, this alone will not usually suffice to mitigate hazards in workplaces. The company needs to place a value on safe work practices and needs to uphold this value.

Why would a site supervisor or foreman who is trained on the dangers of excavation/trenching take the risk and not properly slope or properly protect a trench from cave-in, or allow a spoils pile on the edge of a six-foot deep trench? I’m not stating instances where there’s a difference of opinion between the employer and OSHA’s exact dimension of a slope-back. The cases I’m referring to are those where there’s no protective system in place when and where it was needed. These are the cases where an employer or a company owner has the opportunity to spotlight its injury illness prevention plan and uphold this plan so that non-conformance is a lot less likely to occur.

For example, it is not uncommon to be on the road and see construction trench/excavation activity taking place, and as you get closer to the scene you observe the tops of hard hats, usually indicating a trench deeper than five feet deep. As you look closer you observe no trench slope back and you might notice a trench box alongside the road—not in the trench where it would protect the workers from a cave-in.

Why are trenching and excavation an issue now? After all, due to the economy some building construction activities have slowed down throughout the nation. However, road improvement and utility-related work appear to remain fairly constant. This type of work usually involves some “digging in the dirt” activity that can expose workers to a multitude of fatal hazards.

The Occupational Safety and Health Administration’s (OSHA) website, specifically its Weekly Fatality Reports section, reveals some sad and tragic results of road and utility-type work. The following fatal events are just a few that occurred in 2011:

  • A worker installing a sewer line was killed when the trench collapsed.
  • A worker was killed when a concrete pipe was displaced and struck the worker.
  • Two workers died when the excavation walls collapsed while they were installing a new waterline.
  • Two workers died from oxygen deprivation when they were trapped inside a manhole.

It’s not surprising then that OSHA continues to have a national special emphasis program on trenches and excavations. Here are a few violations cited last year by OSHA in Highway Street Construction:

  • 1926.651-Specific Excavation Requirements. Cited 49 times for a total penalty of $211,000.
  • 1926.652-Requirements for Protective Systems. Cited 43 times for a total penalty of $203,497.
  • 1926.21-Safety Training and Education (Construction). Cited 28 times for a total penalty of $80,000.

OSHA’s construction standards 29 CFR 1926 Subpart P-Excavations provide federal safety and health regulations regarding excavations and trenches. The standard includes specific requirements related to trenches, protective systems including trench boxes, shoring, sloping and benching of trenches. It also considers workers’ exposure to traffic, falling loads, water accumulation, and hazardous atmospheres.

This is one of the OSHA standards that includes the importance of a competent person and the requirement for daily inspections of “excavations, the adjacent areas and protective systems.”

Though the OSHA Subpart P may not contain specific employee training requirements, employers remain obligated to train and educate their employees in accordance with CFR 29 1926.21(b)(2) (Subpart C-General Safety and Health Provisions-Safety training and education), which states the following: “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.” In addition, in this same Subpart, OSHA defines confined spaces (which includes “open top spaces more than four feet in depth”) and spells out the requirements to employers when employees must enter such spaces. This aligns with the Excavation Subpart P, specifically paragraph 1926.651(g)(1)(i) where employers are required to test the atmosphere if there is a reasonable expectation that a hazardous atmosphere may exist (i.e. “excavations in landfill areas or where hazardous substances may be stored nearby”).

If you want worksite assistance with trenches or excavation, contact USF SafetyFlorida at http://www.usfsafetyflorida.com/ to request a free and confidential on-site consultation.

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