CHST Safety Program Management 5 — Questions and Answers
Question 1: A construction safety program is undergoing an external audit. Which document provides the most comprehensive framework for the audit criteria?
- OSHA 29 CFR 1926 Subpart C
- ANSI/ASSP Z10 Occupational Health and Safety Management Systems standard (Correct answer)
- NFPA 70E Standard for Electrical Safety
- AGC Safety Manual, Chapter 1
Correct answer: ANSI/ASSP Z10 Occupational Health and Safety Management Systems standard
ANSI/ASSP Z10 is a voluntary consensus standard specifically designed as a management system framework for evaluating and improving occupational health and safety programs.
Question 2: A project safety incentive program rewards crews with gift cards for zero reported injuries each month. What is the MAIN regulatory concern with this approach?
- It violates the FLSA minimum wage requirements
- It may discourage workers from reporting injuries, violating 29 CFR 1904.35 (Correct answer)
- It creates an unfair tax burden for non-incentivized employees
- It conflicts with OSHA's multi-employer citation policy
Correct answer: It may discourage workers from reporting injuries, violating 29 CFR 1904.35
OSHA's anti-retaliation provisions under 29 CFR 1904.35 prohibit incentive programs that discourage injury reporting by penalizing crews for recorded incidents.
Question 3: When conducting a Job Hazard Analysis (JHA) for a new construction task, who should be involved in its development?
- Only the project safety manager and superintendent
- The workers who actually perform the task, along with the supervisor (Correct answer)
- The project owner's representative and the architect
- Insurance risk manager and project estimator
Correct answer: The workers who actually perform the task, along with the supervisor
Workers performing the task have firsthand knowledge of hazards and practical controls, making their involvement essential to a thorough and realistic JHA.
Question 4: A construction company's Experience Modification Rate (EMR) increases from 0.85 to 1.15. What is the MOST likely direct business impact?
- The company loses its OSHA VPP Star status automatically
- Bid competitiveness decreases because project owners often screen out EMRs above 1.0 (Correct answer)
- The company must immediately retrain all supervisors
- OSHA issues a hazard alert letter to the company
Correct answer: Bid competitiveness decreases because project owners often screen out EMRs above 1.0
Many owners and general contractors use EMR thresholds (commonly 1.0) as a prequalification filter, so a rising EMR can disqualify a firm from bidding on projects.
Question 5: Which approach best describes the 'hierarchy of controls' when applied to a caught-in/caught-between hazard on a construction site?
- Provide hard hats, then train workers on awareness
- Eliminate the hazard first; if not feasible, guard or isolate it before relying on PPE (Correct answer)
- Post warning signs first, then require PPE as a backup
- Conduct daily toolbox talks and document attendance
Correct answer: Eliminate the hazard first; if not feasible, guard or isolate it before relying on PPE
The hierarchy of controls prioritizes elimination and engineering controls over administrative controls and PPE because higher-order controls provide more reliable protection.
Question 6: A safety program's corrective action tracking log shows 40% of actions are overdue. What is the FIRST step a safety manager should take?
- Close all overdue items as 'resolved' to reset the metric
- Escalate every overdue item directly to OSHA for guidance
- Analyze why actions are overdue: resource constraints, unclear ownership, or unrealistic deadlines (Correct answer)
- Replace the tracking system with a new software platform
Correct answer: Analyze why actions are overdue: resource constraints, unclear ownership, or unrealistic deadlines
Understanding the root causes of overdue corrective actions — such as resource gaps or unclear accountability — is necessary before implementing any effective solution.
Question 7: Under the OSH Act's General Duty Clause (Section 5(a)(1)), an employer can be cited even without a specific OSHA standard if which conditions are met?
- A fatality occurred and a union filed a complaint
- A recognized hazard exists, is causing or likely to cause serious harm, and a feasible abatement method is available (Correct answer)
- More than 10 employees are exposed to the same condition
- The employer has a prior citation history within the past three years
Correct answer: A recognized hazard exists, is causing or likely to cause serious harm, and a feasible abatement method is available
The General Duty Clause requires OSHA to show the hazard is recognized by the industry or employer, poses serious harm potential, and can be abated by a feasible means.
A construction safety program is undergoing an external audit.
Which document provides the most comprehensive framework for the audit criteria?