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Why pre-job planning matters

Falls happen quickly and without warning, especially in the fast-paced and often unpredictable environment of a construction site. Pre-job planning creates the framework for identifying potential hazards and implementing strategies to eliminate or control them before work begins.

It also ensures that everyone—from seasoned crew members to new hires—understands how to protect themselves and their coworkers.

OSHA training requirements

The Occupational Safety and Health Administration (OSHA) mandates that all workers exposed to fall hazards receive training. This training must be conducted before any exposure and must be led by a competent person—someone capable of identifying hazards and authorized to take corrective action.

The training must cover:

• How to recognize fall hazards,
• How to minimize exposure to those hazards,
• And the correct use of fall protection systems.

Additionally, employers are required to maintain a written certification record that includes:

• The employee’s name or identifier,
• The date(s) of the training,
• And the trainer’s or employer’s signature.

Retraining is necessary whenever there’s reason to believe a worker lacks the required knowledge or skills. Annual refresher training is encouraged as a best practice.

Preventing falls with pre-job planning

Before you and your workers ever step foot on a construction jobsite, you need to think strategically about the work environment and how you’re going to keep your employees safe.

Once you have determined that your workers will likely be exposed to fall hazards on your next jobsite, you need to develop your plans for fall prevention.

OSHA allows employers to choose from a variety of fall protection systems, including:

• Guardrails,
• Safety nets,
• Personal fall arrest systems,
• Positioning devices,
• Warning lines,
• Controlled access zones,
• Safety monitoring systems,
• Floor hole covers,
• Fall protection plans.

If workers are responsible for installing or maintaining any of these systems, they must be trained in the correct procedures, including:

• Inspecting all equipment for wear or damage,
• Following manufacturer instructions when setting up or breaking down systems,
• Performing regular checks during use to maintain safety standards.

You should also try to think outside the box and determine if there are other, safety alternatives that would better protect workers from fall hazards.

For example, get in the habit of asking yourself: “Which would be the safest way for my workers to reach/access/work from this area?”

Perhaps it means using a ladder. Or an aerial lift. Or a scissor lift. Or maybe it involves installing temporary guardrail on the roof, walkway, or work platform.

Preventing falls with regular toolbox talks

To effectively reduce the risk of falls, your pre-job safety meetings and ongoing training sessions remind workers how to identify fall hazards. Every job site is different, and hazards can change daily. Workers must be trained to spot common fall risks, such as:

• Unprotected edges,
• Floor holes or openings,
• Unstable surfaces,
• Work performed from heights (e.g., ladders, scaffolds, aerial lifts, and roofs).

Remind workers to:

• Inspect their work areas before starting the job,
• Report unsafe conditions like missing guardrails or slippery surfaces,
• Stay aware of environmental factors (rain, ice, wind) that can increase fall risks.

Construction environments are dynamic. Encourage workers to perform ongoing hazard assessments as conditions evolve.

Building a culture of fall prevention

Preventing falls isn’t just about checking boxes for compliance. It’s about creating a culture where safety is ingrained in every task, every day. By taking fall protection seriously during pre-job planning, employers show their commitment to protecting workers’ lives.

From mandatory training to consistent equipment checks, every precaution counts. With proactive planning and education, construction teams can work confidently at heights, knowing they’ve done everything possible to stay safe.

Key to remember: With thoughtful pre-job planning, comprehensive training, and a commitment to safety, we can reduce fall injuries and fatalities on construction sites.

Two studies

In 2022, FSIS contracted two studies to see how much faster line speeds actually impact worker safety at 17 facilities. These facilities were poultry and swine evisceration plants with line speed waivers.

During the studies, the plants submitted worker safety data. Researchers interviewed workers and analyzed footage of plant workers. They also measured muscle activity, posture, and repetition. Finally, the researchers calculated the risk of upper extremity pain and musculoskeletal injury for workers at higher versus lower speeds.

Findings

In January 2025, two final reports were sent to FSIS (here and here). They conclude:

• Workers are at greater risk of a musculoskeletal disorder (MSD) when the piece rate is higher. Piece rate is the number of animal parts a worker handles per minute.
• About 40 percent of workers in both studies reported moderate/severe pain in the last year.
• More than 80 percent of the workers were at increased risk of MSDs in the poultry study. This compared to over 45 percent in the swine study.

“Line speeds” were determined not to be the leading factor in worker MSD risk at these plants, claims FSIS. Yet, the reports offer insights into how line speeds and other factors may work together to contribute to workers’ overall risk.

Former Acting Secretary of Labor Julie Su said on January 13th, “The findings in USDA's report on worker safety in poultry and swine plants show that injuries, including chronic pain and musculoskeletal disorders are too common. These kinds of injuries often go unreported." In fact, a 2016 Government Accountability Office (GAO) report explains that OSHA faces challenges in gathering injury and illness rates for the meat and poultry industry because of underreporting.

Recommendations

All facilities are encouraged to review the two reports. Plus, FSIS advises facilities to examine their own worker safety plans, regardless of operating line speed. In this way, they may determine how they can protect their workers’ health. The reports go on to recommend that meat and poultry companies consider developing an industry-wide set of best practices that reflect input from both workers and companies. Proposed best practices include:

• Lowering the piece rate by, for example, raising the number of staff;
• Improving medical management programs to assess ongoing pain as a metric of exposure to ergonomic risk;
• Promoting a worker safety culture that encourages reporting of pain and discourages retaliation for reporting;
• Frequently sharpening, maintaining, and replacing knives and scissors; and
• Fully implementing industry specific guidelines from OSHA.

OSHA and NIOSH guidelines

Five OSHA guidelines relate to the studies:

• Best Practices for Non-Health Care Employers with On-site Health Care Services, OSHA 3160;
• Ergonomic Program Management Guidelines for Meat Packing Plants, OSHA 3123;
• Prevention of Musculoskeletal Injuries in Poultry Processing, OSHA 3213;
• Safety and Health Guide for the Meatpacking Industry, OSHA 3108; and
• Poultry Processing Industry eTool.

NIOSH recommendations offer more:

• Evaluation of Musculoskeletal Disorders and Traumatic Injuries Among Employees at a Poultry Processing Plant, HHE 2012-0125-3024;
• Evaluation of Ergonomic Risks, Musculoskeletal Disorders, and Peracetic Acid Exposure Among Employees at a Pork Processing Plant in Michigan, HHE 2021-0117-3397; and
• Evaluation of Carpal Tunnel Syndrome and Other Musculoskeletal Disorders among Employees at a Poultry Processing Plant, HHE 2014-0040-3232.

OSHA’s ongoing agreement with FSIS

In 2022, OSHA issued a memorandum of understanding with FSIS to protect workers in 6,600 meat, poultry, and egg processing plants. Under the memo:

• FSIS personnel report to OSHA any serious work hazards at FSIS-regulated plants;
• FSIS provides OSHA with attestations (per 9 CFR 381.45 and 310.27) from plants in the new poultry and swine inspections systems programs; and
• OSHA provides a poster (see here and here) to FSIS-regulated plants on how to report injuries to OSHA.

Related legislation

Note that House and Senate bills introduced (but not passed) in 2023 would have required OSHA to issue an MSDs standard for meat/poultry plants. A 2023 GAO report also pressures OSHA for a rule.

Key to remember

FSIS is directed to extend line speed waivers and no longer require plants to submit redundant worker safety data to FSIS.

If we purchase a chemical from a local store, is it exempt from HazCom?

Assuming the chemical is, in fact, a hazardous chemical by definition, the answer depends. The standard contains 12 exemptions at 29 CFR 1910.1200(b)(6), which may apply to your situation. Often employers can spot an exemption for some of their hazardous chemicals, so it’s worth checking the list.

Consumer products, for instance, are exempt if they’re only used at work as intended by the manufacturer or importer and that use is in a duration and frequency no greater than the range a consumer would reasonably experience. On the flip side, if a consumer product is not used as intended or is used longer or more frequently than a reasonable consumer would, it is covered by the HazCom standard.

In many cases, OSHA lists a substance as exempt at paragraph (b)(6) because it’s regulated by another OSHA standard or another federal agency. In this way, OSHA did not duplicate employer efforts with a HazCom requirement. Hazardous waste covered under EPA’s Resource Conservation and Recovery Act (RCRA), is an example.

If a contractor brings a hazardous chemical into our facility to perform work but our employees aren’t exposed and there’s no potential for exposure, do we need an SDS for it?

If there’s no exposure or potential for exposure to your own employees during normal operating conditions or in a foreseeable emergency, then you don’t need a safety data sheet (SDS) for that hazardous chemical. To help make that determination, see the term “exposure” as defined in 1910.1200(c).

As a contractor specializing in overnight cleaning, we sometimes assign associates to different sites. Would it be compliant to use one binder across multiple locations?

The HazCom Standard does allow you to maintain a single binder at the primary workplace, provided workers can immediately obtain the information in an emergency. This is explained at 1910.1200(g)(9): “Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.”

OSHA offers further clarification in CPL 02-02-079, the agency's guidance document for its inspectors: “If the SDSs are stored at the primary workplace, the employer must ensure there is no delay in a worker receiving a requested SDS while at any mobile, remote, or temporary worksite.

“Access may be accomplished by having a representative always available at the primary workplace or through other technological means (e.g., email, smart phone, electronic tablet).

“The employer must address in their written hazard communication program how SDS information will be conveyed to remote worksites.”

How often do SDSs have to be updated?

From an SDS creation standpoint, when the manufacturer, importer, or employer preparing the SDS becomes aware of any significant information regarding a chemical’s hazards, or ways to protect against the hazards, the new information must be added to the SDS within three months. This is spelled out at 1910.1200(g)(5).

However, as an employer maintaining SDSs for the covered hazardous chemicals in your workplace, the requirement is to keep the most recently received SDS for the product. You’re not required to seek out a newer SDS. It’s worth noting that other countries may require employers to replace SDSs that are a certain age. However, that’s not the case in the U.S.

Can we still use NFPA or HMIS® labels for workplace labels or did that change with the revisions to HazCom last year?

OSHA’s revisions to the HazCom Standard in May 2024 didn’t change the requirements at 1910.1200(f)(6) for workplace (in-house) labels. Let’s take a closer look at that paragraph.

While you’re still not required to relabel incoming containers of hazardous chemicals that are already properly labeled, some employers choose to do so. Additionally, if you transfer chemicals from one container to another, and that container doesn’t meet the “immediate use” definition, it still must be labeled under paragraph (f)(6).

When coming up with an in-house label, one option is to use the same label elements as those required on “shipped” containers of hazardous chemicals, found in paragraphs (f)(1)(i) through (iv), without the supplier information. The second option is to use the product identifier and words, pictures, symbols, or a combination of these, which provide “general information” of the chemical’s hazards. The HMIS® or NFPA® system may be used to meet the second option, though you must ensure employees are trained to use and understand the system. Plus, any OSHA chemical hazards missing from the rating system must be added to the label to make it OSHA compliant.

Could you please help me get a big-picture view of the NFPA® and HMIS® labeling systems?

National Fire Protection Association (or NFPA) is a leading expert in fire safety and prevention. One of its consensus standards, NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, offers a marking system to help emergency responders determine chemical hazards in a building or storage area. This NFPA® system uses a square-on-point configuration with:

• Four hazard quadrants to depict health (blue), flammability (red), instability (yellow), and special hazards (white); and
• Five ratings ranging from zero (no hazard) to four (severe hazard) to indicate the degree of severity for each hazard. Plus, special hazards are depicted by certain letters.

HMIS stands for Hazardous Materials Identification System, an in-house labeling system copyrighted by the American Coatings Association (ACA). It was originally developed for use by the paint manufacturing industry to indicate chemical hazards in the workplace. The system has since spread to other service and manufacturing industries. HMIS® labels appear as a rectangle-shaped block of colored bars with hazard ratings of zero through four, plus personal protective equipment symbols/letters and a carcinogen indicator.

Key to remember: OSHA’s HazCom Standard continues to pose a challenge for employers and safety professionals. Feel free to submit your questions through our Expert Help feature and our regulatory experts will respond to you within one business day.

What prompted the concern?

To determine if someone could safely work alone in a specific situation, the first step is to evaluate why that concern arose. Questions to consider might include:

• What hazards will the employee face, and what is the likelihood the employee will need help in an emergency? Consider both the probability of an incident as well as the severity.
• Did the concern arise because of external threats, such as a security guard who could face a violent situation? Or did the concern arise because of job hazards, such as working with dangerous equipment? How can those hazards be reduced or eliminated?
• Will the employee have a cell phone and designated contact? Will another employee or manager be on call? How long would someone else take to respond?

Keep in mind that unless security cameras are continually monitored, they do not provide any protection for lone workers. If an incident occurs, video recordings might help determine what happened, but cameras cannot prevent an incident from occurring.

For related information, see our article One is the loneliest number: Five steps to lone worker safety.

Trusting the worker

When a job requires working alone, the employer will presumably select a responsible and trustworthy employee. The employer should train that person to recognize hazards, use caution, and avoid any tasks that create an unacceptable level of risk. Lone workers must understand that they are responsible for their own safety and should carefully consider the potential consequences of any actions. If they have to stop and think about whether they can perform a specific task safely, then skipping that task may be best.

Supervisors should be wary of reprimanding lone workers for “not doing the job.” If tasks were not completed because lone workers felt uncomfortable, they should be praised for prioritizing their safety and refusing to put themselves at risk. Supervisors should not inadvertently encourage them to take risks. Instead, ask the employee to explain why they could not complete the task and try to think of alternative procedures that might get the job done with lower risk.

Establishing a check-in procedure could also be an option. Determine how the worker should check in, with whom, and how frequently. That could mean calling a manager before starting a particular task and again upon completion. In addition, decide on a response if the employee misses a call. Will the manager visit the site to check on the worker? For related information, see our article Lone Workers: A recommended policy.

Employers must balance the potential risks to someone working alone against the costs of scheduling a second worker. Options may range from having someone on call to simply delaying specific projects until additional workers are on duty.

Key to remember: OSHA does not prohibit employees from working alone, but employers should carefully evaluate the hazards and ensure that lone workers do not take unnecessary risks.