According to OSHA, an Internal Traffic Control Plan is a principle of construction traffic coordination inside the activity area of a temporary traffic control zone. The purpose is to separate - to the extent possible construction vehicles and equipment from workers on foot.
You may wonder if this is necessary for your organization. To illustrate the purpose, I will tell you a story.
Once upon a time, about three years ago, a wonderful little sweeping operation in the beautiful city of Salt Lake was scheduled to sweep on a bridge deck mill and fill. This particular job was a night job on a two lane interstate with one lane closure and one lane kept open. Just like any other milling and/or paving project, the mill started work with the sweeper behind it and the dump trucks slowly filed by. The tack truck and paver would come by later. The mill had made its, first pass and was be ing walked back for the next pass when a dump truck backed over a ground man killing him instantly.
Sorry, but my story is based in reality and not fantasy. It was a horrible and preventable tragedy for everyone involved.
Monday morning following the weekend accident, OSHA showed up in the sweeping company’s office, for when a fatality happens on a construction site it does not matter if your truck had the accident, all companies working on that site are investigated. The investigator asked to see the company’s safety manual. He wanted to know what the sweeper operator was wearing and what safety items the company provided.
As a practice, this company provides safety vests, safety glasses, gloves and hard hats. It also provides each employee with $50 each year towards work boots. Several weeks later the sweeping company received a Citation and Notification of Violation and Penalty. There were two violations. The first violation was that the employer did not provide an Internal Traffic Control Plan and the second was that the employer did not provide the required reflective high-visibility safety apparel that meets the Performance Class 3 nighttime activity requirements of ANSI/ISEA.
The company president shared that they did not realize there were different vests for different applications so the second violation was immediately corrected by buying Class 3 vests and making sure operators knew when they had to be worn.
The first violation of the lack of an Internal Traffic Control Plan was argued that since the general contractor had an Internal Traffic Control Plan that the subcontractors would fall under their plan. Unfortunately OSHA didn't see it that way so the decision was made that it was easier and cheaper to pay the fine of $750 and develop one. Below is that plan:
INTERNAL TRAFFIC CONTROL PLAN
To all employees: The "Company" has adopted the following Internal Traffic Control Plan, which should be followed on all projects:
1. For each road project on which the Company works, a copy of the Internal Traffic Control Plan for such project should be requested from the subcontractor or general contractor for the project before commencing work. The requirements of that Internal Traffic Control Plan should be observed.
2. Employees should stay in the sweeper while in the active work zone area for a project. If a need arises to exit the sweeper, employees should move out of the work zone area to a safe place before exiting.
3. Employees should be particularly careful, in backing the sweeper, or in moving around the work area, to be aware of pedestrians.
4. Employees should be familiar with and follow other safety standards contained in Section 4.6 of the Employee Manual, titled "Safety."
So the moral of this story is to be proactive and develop a plan. More importantly communicate your plan because no matter if you like it or not, safety on the job is everyone’s responsibility.
Debbie Jacketta is owner of Jacketta Sweeping Service, based in Salt Lake City, UT