What the regulations require of a concrete or masonry contracting operation, in the order an inspector or a prequalification portal will ask for it. Written for the person who has to run the program.
Concrete and masonry work generates respirable crystalline silica during cutting, grinding, drilling, sawing, tuckpointing, and demolition. The construction silica standard (1926.1153) requires employers to either follow Table 1 (specified exposure control methods for 18 common construction tasks) or measure employee exposure and implement a written exposure control plan when exposures exceed the action level of 25 µg/m³ as an 8-hour TWA. The permissible exposure limit is 50 µg/m³. Medical surveillance is required for employees who will be required to use a respirator for 30 or more days per year.
A written exposure control plan identifying the tasks that generate silica, the engineering and work practice controls for each task (wet cutting, local exhaust ventilation, enclosed cabs), and the respiratory protection used when controls are insufficient. For Table 1 compliance: documentation showing the specific engineering controls and work practices from the table are fully and properly implemented for each task. Housekeeping procedures prohibiting dry sweeping or compressed air blowing of silica dust. Medical surveillance for employees exposed above the action level for 30 or more days per year.
Relying on Table 1 without actually implementing the required controls. Table 1 is a safe harbor — if you follow it exactly, you are presumed to be in compliance without air monitoring. But "follow it exactly" means using the specific tool, the specific control (water or vacuum), and maintaining the control in proper operating condition. A concrete saw listed in Table 1 requires an integrated water delivery system that supplies a continuous stream to the blade. Running the saw without water or with a clogged water supply is not Table 1 compliance, and you lose the safe harbor.
Written exposure control plan identifying tasks, controls, and respiratory protection. Documentation of Table 1 compliance for each silica-generating task, or air monitoring records demonstrating exposures are below the PEL. Respirator fit test records for employees using respiratory protection. Medical surveillance records for employees exposed above the action level for 30+ days per year. Housekeeping procedures and training records.
Concrete and masonry contractors use scaffolding extensively — for form work, pour operations, finishing, masonry wall construction, and tuckpointing. All scaffolds must be erected under the direction of a competent person, inspected before each work shift and after any occurrence that could affect structural integrity (1926.451). Supported scaffolds must have a capacity of at least four times the maximum intended load. Guardrails, midrails, and toeboards are required on all open sides and ends at heights of 10 feet or more. Employees must be trained by a qualified person before working on scaffolding.
A scaffold erection and use plan identifying the types of scaffolds used (frame, system, tube-and-coupler, mast-climbing) and the specific requirements for each. Competent person designation for scaffold inspection and the authority to correct deficiencies immediately. Training for all scaffold users covering hazard recognition, load limits, fall protection, and the specific type of scaffold in use. Training for scaffold erectors and dismantlers on the additional hazards of assembly. Inspection records for each scaffold before each shift.
Modifying scaffolds without re-inspection. Masonry work frequently requires adjusting scaffold height as the wall rises. Each modification to the scaffold — adding sections, moving planks, adjusting bracing — requires the competent person to re-inspect before work resumes. Informal modifications without re-inspection are among the most cited scaffold violations in the masonry industry. A plank removed to hoist materials, a guardrail loosened for access, a brace repositioned to clear a corner — each creates a hazard if not formally re-inspected.
Competent person designation documentation. Training records for all scaffold users, erectors, and dismantlers. Daily inspection records by the competent person, including re-inspections after modification. Scaffold capacity calculations or manufacturer specifications for each scaffold in use. Corrective action records for deficiencies found during inspections.
Run the free assessment. Ten minutes of questions about your work, and you get a named list of the programs, trainings, and inspections you're required to hold — not a score out of a hundred.
See what you're missingConcrete and masonry contractors performing foundation work, footing installation, and underground utility connections must comply with the excavation standard (1926.650–.652). Excavations five feet or deeper require a protective system — sloping, benching, shoring, or a trench box — unless the excavation is in stable rock. A competent person must inspect excavations daily and after every rainstorm, vibration source, or other hazard-increasing occurrence. Access and egress (ladders, ramps, or stairways) must be provided within 25 feet of travel for any employee in a trench four feet or deeper.
A competent person trained in soil classification and excavation hazards, designated for every job involving trenching or excavation. Soil classification performed by the competent person before work begins, documented by visual and manual tests. Selection of the appropriate protective system based on soil type, depth, and site conditions. A daily inspection program with the competent person inspecting before employee entry, during the shift, and after any condition change. Emergency response procedures including rescue equipment and training.
Not classifying the soil. The excavation standard bases protective system requirements on soil classification — Type A, B, or C, with different maximum allowable slopes and shoring requirements for each. Many contractors default to a trench box for everything, which is acceptable, but if the trench box is not rated for the soil conditions or is improperly installed, it provides a false sense of security. A competent person must classify the soil and verify the protective system is appropriate for the conditions encountered — not the conditions assumed.
Competent person designation and qualification documentation. Soil classification records for each excavation. Protective system selection documentation showing the system is appropriate for the soil type and depth. Daily excavation inspection records by the competent person. Tabulated data or manufacturer specifications for shoring equipment and trench boxes.
Concrete and masonry contractors using hazardous chemicals must implement a written Hazard Communication program (1910.1200). Concrete work involves numerous hazardous chemicals — Portland cement (caustic/alkaline), concrete curing compounds, form release agents, epoxies, adhesives, sealers, and masonry cleaning acids (muriatic/hydrochloric acid). Wet concrete itself is a chemical hazard — prolonged skin contact causes alkaline burns. On multi-employer sites, the contractor must also account for chemicals other trades bring to the jobsite.
A written HazCom program specific to the concrete and masonry trade. A chemical inventory covering Portland cement products, curing compounds, release agents, cleaning acids, epoxies, and sealers. SDS for every product, accessible at the jobsite. Training on the specific hazards — particularly wet concrete burns (which are frequently undertreated because the burn develops slowly) and the acid hazards from masonry cleaning.
Wet concrete burns. Portland cement is highly alkaline (pH 12-13) and prolonged skin contact causes chemical burns that can progress to full-thickness injuries. Many workers and supervisors treat concrete contact as routine rather than as a chemical exposure requiring immediate decontamination. If employees kneel in wet concrete, handle concrete without gloves, or allow concrete to remain on skin or clothing, the exposure is a HazCom violation and the injuries are preventable.
Written Hazard Communication program, company-specific and dated. Current chemical inventory covering all concrete and masonry products. SDS system accessible at every jobsite. Training records showing employees were trained on wet concrete hazards, acid hazards, and the protective measures for each.
Concrete and masonry contractors must assess the workplace for hazards requiring PPE and provide appropriate equipment at no cost (1910.132). Concrete and masonry work typically requires head protection (1926.100), eye protection during cutting, grinding, and tuckpointing (1926.102), hand protection against wet concrete and chemical contact, foot protection including metatarsal guards for heavy material handling, hearing protection during sawcutting and grinding, and respiratory protection for silica exposure. The PPE hazard assessment must be documented.
A written PPE hazard assessment certification identifying the hazards of each concrete and masonry task and the PPE required. PPE selection based on the specific hazard — alkaline-resistant gloves for concrete, chemical-resistant gloves for acid cleaning, impact-rated safety glasses for cutting, tight-fitting respirators for silica-generating tasks. Training on proper use, maintenance, inspection, and limitations of each piece of PPE. A replacement program ensuring damaged or worn PPE is replaced.
Not providing alkaline-resistant gloves for concrete handling. Standard leather or cotton gloves do not protect against wet concrete — the alkaline moisture penetrates the material and traps it against the skin, actually worsening the exposure. Waterproof, alkaline-resistant gloves are required for employees handling wet concrete, and the gloves must be long enough to prevent concrete from entering at the cuff. This is both a PPE selection issue and a training issue.
Written PPE hazard assessment certification with workplace identification, assessor, and date. Training records for each employee. Documentation of PPE selection rationale, particularly for chemical-resistant gloves, respiratory protection, and hearing protection. Equipment inspection and replacement records.
Concrete and masonry contracting establishments with more than 10 employees must maintain OSHA 300, 300A, and 301 forms (29 CFR 1904). The 300 Log records all recordable injuries and illnesses — including struck-by injuries from falling masonry, concrete burns, silica exposure illness, trench collapses, scaffold falls, and musculoskeletal injuries from heavy lifting. The 300A Summary must be posted from February 1 to April 30 each year.
An OSHA 300 Log recording each recordable injury or illness within 7 calendar days. OSHA 301 Incident Reports for each entry. The 300A Summary posted during the required period. Five-year retention of all forms.
Concrete burns that develop after the shift ends. An employee who kneels in wet concrete may not feel the burn until hours later. If the burn requires medical treatment — prescription medication, wound care by a physician, or days away from work — it is recordable. The date of injury is the date of the concrete contact, not the date the employee sought treatment. Delayed-onset burns are frequently missed on the 300 Log because neither the employee nor the supervisor connected the injury to the exposure.
Current year 300 Log with all entries made within 7 calendar days. Prior year 300A Summary still posted or evidence of posting. Five years of 300, 300A, and 301 forms retained and available for inspection. Electronic submission confirmation if on OSHA's e-submission list.
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