Inspecting Occupational Safety and Health in the Construction Industry

Section 5: Planning,monitoring and evaluation of an OSH inspection programme

5.1 Planning an OSH inspection programme
5.2 Monitoring and evaluation of an OSH inspection programme

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In any country of the world, the number of construction sites running simultaneously is high or very high, depending on the economy, investment in construction and the priorities of the governments.

However, the number of labour inspectors is usually limited, and they often have to deal with many different kinds of workplaces. Moreover, the number of laws and regulations concerning OSH tends to be very high and many of them require specialist knowledge.

This means that priorities have to be set among construction sites that need attention. Some countries have organised groups of labour inspectors specifically to deal with the construction industry⁶. This is indeed highly recommended for all countries with many and complex construction sites.

Planning an OSH inspection is discussed in subsection 5.1, while subsection 5.2 deals with the monitoring and evaluation of an OSH inspection programme.

5.1 Planning an OSH inspection programme

An OSH inspection programme aims to make best use of the existing human resources of the labour inspectorates by establishing priorities among the workplaces to inspect. In the construction industry, such a programme should consider the following two groups:

• construction enterprises;
• construction sites.

In both cases, priority should go to the construction enterprises and sites with the highest percentages on the evaluations, meaning those with the highest risk. They should be ranked by those percentages. The percentage above which they should be selected for inspection will depend on the number of labour inspectors and how many cases each of them can inspect.

This percentage hereafter called the “reference percentage” could be used to classify the enterprises and sites in two “classes of risk”:

(i) “high-risk”, meaning those with evaluations on or above the “reference percentage”;

(ii) “low-risk”, meaning those with evaluations below the “reference percentage”.

The evaluations should be done periodically, updating the information included in the Prior Notices or, preferably, the Final Notices, and their respective annexes. The period between evaluations should be fixed (e.g. 3 years).

However, in view of the high number of construction enterprises and sites, there should be a balance both between inspections of enterprises and inspections of sites, and also within each of those groups, so as to avoid inspecting the same enterprises and sites, while leaving the others without any inspection.

A percentage (e.g. 25%) should be set for random inspections among enterprises and sites not included in the group with the highest percentages on the evaluations (“low risk” enterprises and sites).

Because most occupational accidents occur on construction sites, inspecting them should take priority over inspecting construction enterprises, unless a single enterprise has many “high-risk” sites. In the latter case, it may be more efficient to inspect the enterprise to evaluate the general procedures that it follows on its construction sites. A proportion of construction enterprises relative to sites to be inspected should be set (e.g. 20%).

The time needed for a full inspection will depend on size and complexity, but also on the construction expertise of the labour inspectors. However, except in particular cases, there is no need to inspect all the activities of a construction enterprise or site. In general, on-site inspections should cover only some areas or activities of the enterprise or site and the report should reflect this. It is better to focus on some issues in depth than on many issues in a superficial way, all the more so when the existing resources of the labour inspectorates are, as usual, limited.

If, for example, each labour inspector takes one day to inspect a construction enterprise or site and another day to prepare the corresponding report, then about 10 cases should be inspected each month by each labour inspector7, say 2 construction enterprises and 8 construction sites (considering a distribution 20% and 80% for inspections to enterprises and to sites). Of those 2 construction enterprises to be inspected, say 0,5 (25% x 2, i.e., 1 enterprise every 2 month per labour inspector or 1 enterprise every month per two labour inspectors) should be enterprises classified as “low-risk” and of the 8 construction sites to be inspected, 2 should be sites not among those with the highest percentages on the evaluation.

This example is illustrated in Figure 13, which shows the distribution of a two-monthly inspections of construction enterprises (20%) and construction sites (80%). In both cases, they are separated by those with “high-risk” (meaning those with the highest percentages on the evaluations, e.g., E = 75%) and those with “low-risk” (meaning those with lower percentages on the evaluations, e.g., E 75%).

Figure 13 – Example of the distribution of two-monthly inspections

The inspections should be performed in a systematic way, using the instruments and methodologies described in Section 9 of this document.

Assuming these figures, if the number of “high-risk” enterprises and sites to inspect is 35 and 100, respectively (taking a group of enterprises and sites evaluated according to the methods described in subsections 42 and 43 above), the number of labour inspectors needed to perform all these inspections during one month should be 18, i.e. 135 cases/(1-25%)/10 cases/labour inspector.

5.2 Monitoring and evaluation of an OSH inspection programme

The OSH inspection programme should be monitored and evaluated through periodic reports: monthly, three-monthly and yearly (Figure 14).

Figure 14 – Control and evaluation of an OSH inspection program

The monthly reports should be prepared by the labour inspectors. They should include the following information:

• number of (high and low risk) construction enterprises and (high and low risk) construction sites planned to be inspected and those that were actually inspected during the month and, if they were not actually inspected, the reasons why not;
• list of construction enterprises inspected and their relevant details (name, address, date of the inspection, reasons why the enterprise was selected for inspection, turnover, number of workers, number of accidents reported and OSH statistics indicators for the previous year, number of cases as per each of the enforcement instruments referred to in Section 9, and other relevant information);
• list of construction sites inspected and their relevant details (name address, date of the inspection, reasons why the site was selected for inspection, project budget, number of workers on the day of the inspection, number of accidents reported since the opening of the site, number of cases as per each of the enforcement instruments referred to in Section 9, and other relevant information);
• summary of the main results achieved, difficulties encountered in performing the inspections, recommendations for continuous improvement of the OSH inspection report (especially the inspection methods).

The three-monthly reports should be prepared by the person responsible at the labour inspectorate, using the monthly reports prepared by each labour inspector under his/her supervision (at the delegation / geographic area level). This report should summarise the main issues, the total number of construction enterprises and sites inspected, total turnover of all enterprises inspected, total number of workers, etc., including the main recommendations for improvement. During the following month, a meeting involving all the labour inspectors should be held to discuss this report, exchange information about the methods used during the inspections, including the situations where each of the enforcement instruments was or should have been used, and other relevant issues.

The yearly report should be prepared during the first three months of every year by the person responsible at the labour inspectorate (at the delegation/geographic area and national levels), summarising the information contained in the three-monthly reports, including the main recommendations, comparison with previous reports, the evolution of the main OSH statistics, namely, frequency rate, incidence rate, severity rate and the days lost per new case of occupational injury. This report should also be included in the yearly report that national labour inspectorates usually prepare for external use and public consultation.

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⁶ The number of labour inspectors dealing specifically with the construction industry per each thousand construction sites could be a good indicator to explore (e.g. comparing it with the OSH accident statistics).

⁷ In this example, the labour inspectors are involved at full-time to inspections of construction enterprises and sites and they have the knowledge and experience on this industry, i.e. the number of cases refers to the equivalent to full-time labour inspectors in the activity of construction inspection. The actual number of cases to be inspected by each labour inspector should be therefore reduced according to the percentage of time effectively spent on the activity of inspection. Other activities may include, for example, general administrative tasks, attendance to training programmes, investigation of occupational accidents, etc. (sometimes these activities may achieve more than 30% of the available time of each labour inspector).

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