Excavations are essential to many construction projects, but working in trenches and other excavations is among the most dangerous of all construction activities. Dozens of workers die each year while working underground.
When most people hear of a trench accident, they tend to think of a trench wall collapse — but there are many other significant hazards addressed in the excavation standards that can and do lead to fatalities every year. These hazards include being struck by equipment, pipe or other materials being dropped on workers, drowning in a trench, or being overcome by gases while working in a hazardous atmosphere underground. These four hazards, plus eight more, are found in the Specific Requirements segment of the excavation standard.
While all employees must be trained to recognize these hazards, there must be at least one person that is authorized and empowered to correct these problems as they develop. The single most important measure contractors can take to avert trench accidents and injuries is to designate a Competent Person. It’s not just a smart idea but a legal obligation.
OSHA standard 1926 subpart P requires a Competent Person to be onsite during trenching and excavation activities to oversee them. But the value of designating a Competent Person extends beyond OSHA compliance. A qualified Competent Person serves as an on-the-spot expert who can identify hazards early and has the knowledge and authority to take immediate action to mitigate them before an incident occurs. What’s more, the presence of a Competent Person signals to the crew that trench safety is a non-negotiable priority.
OSHA defines a Competent Person as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”
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| Linder Industrial Machinery |
Potential hazards involved in excavation work include water accumulation, a change in soil conditions after a storm, a hazardous atmosphere, and lack of safe means of entry and egress.
Two aspects of the OSHA definition are worth highlighting:
1. Capable
The person must have the knowledge and experience to do the job. OSHA spells out exactly what a Competent Person must be trained in and what they must know. Specifically, the Competent Person must be trained in and have demonstrable knowledge of soils analysis, protective system options, and the requirements of the standard. If that person cannot demonstrate that they know these things, they cannot be deemed the Competent Person.
2. Authorized
Authorization to act immediately to address unsafe conditions versus waiting for approval is critical. Time is of the essence because conditions can change quickly and hazards can escalate fast. Corrective actions may include stopping work while a hazard such as a failing trench protective system is addressed.
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| Dobbs Equipment (DXC) |
In trenching and excavation work, the Competent Person’s responsibilities are broad and all of them are vital to keeping workers safe. Some of those responsibilities include:
Identify Location of Underground Utilities
Gas, water, electrical, and other utility lines must be located prior to excavation. It is the Competent Person's responsibility to ensure no damage is done to those utilities during excavation.
Select the Proper Protective System
Protective systems will vary. Some prevent cave-ins from happening, others protect workers from the effects of a cave-in. Some give more workspace than others. Selecting the right system is crucial.
Classify Soil
Performing visual analysis and manual testing to classify soil as Type A, B, or C helps determine the type of protective system required.
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| Linder Industrial Machinery |
Know When to Get an Engineer Involved
There is no single system that accommodates every need. For example, if an excavation is adjacent to a surcharge that is not factored into the depth ratings, an engineer must be consulted.
Follow Tabulated Data
Protective systems must be used according to OSHA charts or the manufacturer’s tabulated data or be designed by a registered professional engineer (RPE).
Perform Inspections
Trenches should be inspected at the start of each shift and after weather or other events that could cause conditions to change.
Monitor Water Removal
Monitoring dewatering operations ensures that the water level is maintained to an elevation equal to or lower than the bottom of the excavation.
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| Ring Power Corporation |
Test for Hazardous Atmospheres Prior to Worker Entry
Testing for hazardous atmospheres helps prevent asphyxiation from oxygen deficiency or exposure to toxic gases. It’s required when workers are in an excavation that is deeper than 4 feet and it’s reasonable to think that a hazardous atmosphere could exist.
Design Structural Ramps for Access and Egress
When needed, these ramps must be designed by a Competent Person qualified in structural design.
Choosing the right Competent Person is critical. Designating an individual who lacks the requisite skills can be risky. This person must be a leader and may be required to make important decisions about how to proceed with work. An underqualified employee may overlook hazards or misunderstand requirements, creating a false sense of security.
Training alone doesn’t qualify someone to be a Competent Person; all employees must be trained in the same things. The Competent Person must be designated by the employer to be the lead individual. If something goes wrong, OSHA will want to interview that person to determine how decisions were made or ask why work was allowed to continue in the face of a problem. Ongoing training is necessary to fill knowledge gaps and keep knowledge up to date.
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Competent Person training should be delivered by trustworthy subject matter experts. Each decision made by a Competent Person will be based on one or more prior findings. Any miscommunication or error early in the conditional logic process can lead to significant consequences.
A Competent Person class should, at a minimum, consist of proper education on these topics:
- Soil classification
- Sloping and benching
- Timber shoring
- Aluminum hydraulic shoring
- Requirements for protective systems
- Manufacturer’s tabulated data
- Site-specific engineering
- General requirements and Competent Person responsibilities
Fatalities during trench work don’t have to happen. Contractors have the power to prevent them, and a Competent Person is critical to an effective line of defense.
Some contractors may not believe they need a Competent Person or may not realize that having a Competent Person for trench and excavation work is required by law. Others may worry that spending the time required to assess the need for a trench protective system and install a system that complies with OSHA regulations will delay the project or add to the cost.
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| Linder Industrial Machinery |
But contractors who take shortcuts may pay a hefty price. That price can come in the form of significant OSHA fines, a job site shutdown that halts work, and accidents that increase insurance premiums and harm the company’s reputation. In the worst-case scenario, one that happens far too often, workers pay the ultimate price: loss of life.
Designating and training a Competent Person not only meets a legal requirement but helps companies create safer work sites, improve their safety culture, build trust among employees, and protect the bottom line. Above all, it helps them safeguard their most valuable asset: their people.
Bruce Magee is Regional Product Development Manager for United Rentals Trench Safety. Specializing in trench and excavation work, he has delivered more than 400 OSHA Competent Person classes to the underground construction industry.
