OSHA Excavation Standards: Top Violations of OSHA Subpart P

September 21, 2023

OSHA Rules & Regulations

OSHA excavation standards exist to protect workers from cave-ins and other accidents, such as slips and falls. Yet each year, hundreds of contractors are cited for violating sections of OSHA 1926 Subpart P, the standard that covers excavations.

Are you violating Subpart P without realizing it? If so, you’re putting workers at unnecessary risk of injury and death, and your company at risk for fines.

Here is OSHA’s list of the top Subpart P violations from October 2022 through April 2023.

Violation #1: Cave-in protection

Working in trenches and other excavations is one of construction’s most dangerous activities. In 2022, 39 people died in trench collapses.

Adequate trench protection is critical, yet by far the most commonly violated section of Subpart P is the one that outlines requirements for protective systems, specifically,the protection of employees in excavations (OSHA 1926.652 appendix a). It calls for an adequate protective system to protect employees in excavations (“adequate” is defined elsewhere in the standard) except when:

Excavations are made entirely in stable rock; or
Excavations are less than 5 feet deep and examination of the ground by a competent person provides no indication of a potential cave-in.

According to the standard, protective systems must have the capacity to resist all loads that are intended or could reasonably be expected.

Violation #2: Access and egress

OSHA 1926.651 appendix c covers access and egress, and it’s the #2 most violated OSHA Subpart P section. It covers structural ramps, runways and means of egress.

Some highlights of this section:

Ramps must be designed by a designated competent person or, if they are used for equipment access, by a competent person qualified in structural design.
Structural members must be of uniform thickness, and if a ramp or runway is made of two or more structural members, the members must be connected.
Cleats used to connect members must be attached to the bottom of the runway or attached in a manner to prevent tripping.
If the ramp replaces steps, it must have cleats or another other surface treatment on the top to prevent slipping.
Trench excavations that are 4 feet deep or deeper must have a stairway, ladder, ramp or other safe means of egress.

Violation #3: Inspections by a competent person

Is a competent person inspecting your excavation, adjacent areas and protective system every day prior to the start of work—and as needed throughout the shift and after a rainstorm? OSHA 1926.651 appendix k is the #3 most often violated section of Subpart P.

The competent person should look for situations that could result in a cave-in, as well as indications of:

Protective systems failure
Hazardous atmospheres
Other hazardous conditions

1926.651(k) also stipulates that employees be removed from the hazardous area if the competent person finds evidence of a situation that could result in a cave-in, or indications of protective system failure, hazardous atmospheres or other hazardous conditions.

Violation #4: Protection of employees from loose rock or soil

Loose rock or soil can injure workers if it falls or rolls from an excavation face. OSHA 1926.651(j) requires companies to protect workers by:

Scaling to remove loose material
Installing protective barricades on the face
Other, equally effective means

Excavated materials and equipment must be kept at least 2 feet from the edge of excavations unless you use a retaining device that’s sufficient to prevent them from falling or rolling in.

Violation #5: Shield systems

Improper use of trench boxes and shields violates OSHA 1926.652 appendix g. Among the rules in that section:

Shield systems must not be subjected to greater loads than they were designed to withstand.
Shields must be installed so as to restrict hazardous movement of the shield in the event of sudden lateral loads.
Employees must be protected from cave-ins when entering or exiting areas protected by shields.
Employees must not be allowed in shields when the shields are being installed, removed, or moved vertically.
In trench excavations, companies may excavate earth material up to 2 feet below the bottom of a shield, but only if the shield is designed to resist the forces calculated for the full depth of the trench and there are no indications while the trench is open of a possible loss of soil from behind or below the bottom of the shield.

Not sure if you’re violating one of the OSHA excavation standards or how to design and install a protective system that’s adequate for the excavation? Contact the Trench Safety team at United Rentals. Our trench experts can help you find a cost-effective solution customized to fit your project and guide you from start to finish. If you need an engineered protective system, our in-house Registered Professional Engineers are here to help design your plan.