APPENDIX C: Site Selection Description
What is the legal basis for the OSHA Construction Inspection Targeting System?
Due to several court challenges to the worksite selection process for inspections, OSHA developed the current Federal programmed construction inspection system. The project selection process which drives the system meets the legal requirement that projects be selected pursuant to an administrative plan containing specific neutral criteria. Projects are randomly selected from a file representing the universe of active construction projects that contains no contractor identifiers.
In addition, the Office of Inspector General (OIG) requires documentation of the project selection procedures for construction inspections that Area Offices follow. However, since preparation and maintenance of such documentation would be impracticable and unduly burdensome on Area Offices, the current system serves as the documentation.
How are sites selected?
A computer-based methodology is used to select projects for inspection on a random, statistical basis. Selected sites represent a broad range of construction projects: residential (excluding single-family housing); nonresidential buildings, such as commercial, manufacturing, transport, industrial, educational, leisure, & public buildings; heavy construction, such as cogenerators, nuclear power, sewage treatment, communications, shoreline maintenance; and highway and highway-related construction, including bridges, tunnels.
Each month, F.W. Dodge provides CIRPC with the names of projects that have entered the start stage (about 18,300 projects per month), based upon the date of the award of a general contract or the date when project decisionmakers state that "work is to start on a particular date". Using a sophisticated construction duration model that factors in the start date of the project, estimated duration of the project, type of construction project, dollar value, type of owner (i.e. Federal government, State, municipality, military or private), number of stories, and a seasonal adjustment, projects are identified that are estimated to be at some stage of construction, i.e., active. Accurate start date information is critical to estimates of when projects will be prime for inspection (30 percent to 60 percent complete).
Projects are randomly selected to obtain the number requested by the Area Office/State Plan State. Initially, only projects $950,000 and more which are estimated to be between 30 percent and 60 percent complete are considered for selection. If the requested quota cannot be met using these criteria, the “percent complete” criterion is expanded to 25 percent to 65 percent and then to 25 percent to 70 percent complete, if necessary. If more projects are still required, the value criterion is lowered to $500,000 (30 percent - 60 percent complete). The final step to meet a sufficient number ofprojects reduces the value criterion to $250,000 with a 30 to 60 percent completion criterion.
Projects are identified by project identification numbers (PID). Once selected, the PIDs are used to order an OSHA Construction Report for each project from F.W. Dodge. Each report contains the following information: project identification number - unique to each project; project title; project address (or site location information when address not applicable); project owner's name, business address, & telephone number; estimated contract value; estimated square footage of buildings; number of units (on residential projects); number of buildings; estimated construction start date; type of ownership (i.e. Federal government, State, municipality, military or private).
How accurate are the data on the projects?
The information source on construction projects for the construction inspection targeting system is F.W. Dodge, Inc., the most extensive construction news gathering operation in the world. Dodge employs 400 full-time reporters and more than 1,000 correspondents to collect information from a large network of news sources, including permit offices. After the information is collected, individual project reports are created. To ensure coverage of as much construction activity as possible, Dodge maintains 100 branch offices around the country. Reporters make personal visits and phone calls, daily, to about 55,000 private firms, permit offices, municipal, state, and government offices to obtain information pertaining to approval, design, development, and construction of all types of construction projects over $50,000, including new construction, additions and alterations. Coverage is not restricted to bid contracts but includes negotiated contracts and major force account work (use of owner's employees rather than contractor's) as well.
F.W. Dodge files represent the best available universe of active construction projects. An independent study funded by OSHA found that the Dodge database covers over 90 percent of the universe of all construction projects over $50,000, excluding single-family housing. Farm construction and small force account projects were areas with less complete coverage.
In an ideal world, all construction projects would be known, each project would start in the month it was planned to start, each project would remain active the number of months estimated by econometric models, and each project would proceed along an orderly path of construction operations that would accurately estimate in advance the day that excavation, steel erection or landscaping, would begin and end.
However, actual construction activity is less orderly. Construction plans are constantly changing; project duration is not available from construction permits or other sources; each project is unique; the scheduling of construction operations and their duration differ from project to project, even of the same type, and schedules are rarely met. Construction schedules for similar end-use projects, such as office buildings, highways, bridges or schools of equal contract value may vary dramatically in duration due todifferent design features, site conditions and the owner's cost of delayed occupancy (use). Even assuming that scheduled duration of projects were available from owners or contractors, project duration errors would still exist because of schedule interruptions due to such things as litigation among contractors/owners, industrial relations disputes, financial problems, or unforeseen construction problems, which are all common events on construction projects. Given the uncertainties, some of the projects expected to be 30 percent to 60 percent complete will be in an earlier stage (or not even started) or at a later stage (or even completed). On the other hand, the systematic process of identifying projects and estimating their status using the best available data increases the likelihood that inspections will occur at all stages of construction.
What are Early Warning Sites?
In addition to the random selections of project sites for inspection each month, high-value projects at the start stage (month the project is planned to start) are identified. The purpose of the Early Warning Site (EWS) List is to alert Area Offices/State Plan States to the initiation of major construction projects, so that their progress might be followed to ensure a timely inspection of specific phases. Each Early Warning Site will appear on the Inspection Site List for the month the project is estimated to be 30 percent complete.
The value threshold to qualify as an Early Warning Site varies by Area Office/State Plan State, ranging from $5 million to $20 million, depending upon the five-year historical pattern of project values in the respective area office jurisdiction.