This is a short orientation to the federal construction rules (29 CFR 1926 and the 1904 recordkeeping rules) that come up most often around observation work. It is a summary, not the standard: always read the current text, and the site's own program, which may go further.
Programs, inspections and training are the employer's
Each employer must initiate and maintain the programs needed to comply, and those programs must provide for frequent and regular inspections of job sites, materials and equipment by competent persons the employer designates.[1] Employers must also instruct each employee in recognizing and avoiding unsafe conditions.[2] An observer supports these duties; the duties stay with the employer.
Competent person
A competent person can identify existing and predictable hazards and is authorized to take prompt corrective measures to eliminate them.[3] The authority part is what separates a competent person from someone who only observes.
Fall protection
Unprotected sides and edges 6 feet or more above a lower level need guardrails, safety nets or personal fall arrest. Holes need covers to prevent tripping or stepping into them.[4]
Aerial lifts
For boom-type aerial lifts: controls tested each day before use, only authorized persons operating, and workers in the basket tied off to the boom or basket.[5]
Hot work
Fire extinguishing equipment must be immediately available, and when normal precautions are not enough, additional personnel are assigned to guard against fire during and after the work.[6]
Electrical proximity
No employee may work close enough to an electric power circuit to contact it unless protected by de-energizing and grounding it or by guarding it effectively.[7]
Reporting severe injuries
Employers must report a work-related fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours.[8] Prompt, factual notes from an observer help the employer meet those deadlines.
Federal OSHA or a State Plan?
Some states run their own OSHA-approved State Plans. Iowa's covers private sector workplaces in the state, with listed exceptions, and is administered by Iowa OSHA within the Iowa Division of Labor Services.[10] Georgia is not a State Plan state, so federal OSHA covers its private sector.[9] State Plans are monitored by OSHA and must be at least as effective as federal OSHA,[9] but details can differ, so check the plan that applies to your site.
Training cards are not certifications
OSHA's 10- and 30-hour outreach courses are voluntary; none is a certification, and OSHA describes the 30-hour class as more appropriate for supervisors or workers with some safety responsibility.[11] Projects set their own requirements for safety staff.
Observers from NSC Enterprises monitor this work against your program's controls. See high-risk work monitoring, or request coverage.
Sources
- [1]OSHA 29 CFR 1926.20, General safety and health provisions. 1926.20(b)(1)-(2): the employer initiates and maintains safety programs, which provide for frequent and regular inspections by competent persons designated by the employer.
- [2]OSHA 29 CFR 1926.21, Safety training and education. 1926.21(b)(2): the employer instructs each employee in the recognition and avoidance of unsafe conditions.
- [3]OSHA 29 CFR 1926.32, Definitions (competent person). 1926.32(f): a competent person can identify existing and predictable hazards and has authorization to take prompt corrective measures to eliminate them.
- [4]OSHA 29 CFR 1926.501, Duty to have fall protection. 1926.501(b)(1): an unprotected side or edge 6 feet or more above a lower level must be protected by guardrail systems, safety net systems or personal fall arrest systems. 1926.501(b)(4)(ii): employees must be protected from tripping in or stepping into or through holes by covers.
- [5]OSHA 29 CFR 1926.453, Aerial lifts. 1926.453(b)(2): lift controls tested each day before use; only authorized persons operate an aerial lift; workers in the basket tied off to the boom or basket.
- [6]OSHA 29 CFR 1926.352, Fire prevention (welding and cutting). 1926.352(d)-(e): suitable fire extinguishing equipment immediately available; additional personnel assigned to guard against fire during and after the work when normal precautions are not sufficient.
- [7]OSHA 29 CFR 1926.416, Electrical: general requirements. 1926.416(a)(1): no employee may work close enough to contact an electric power circuit unless protected by de-energizing and grounding it or guarding it effectively.
- [8]OSHA 29 CFR 1904.39, Reporting fatalities and severe injuries. 1904.39(a): report a work-related fatality within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours.
- [9]OSHA, State Plans. Iowa runs a State Plan covering private and state and local government workplaces; Georgia is not a State Plan state, so federal OSHA covers its private sector. State Plans are monitored by OSHA and must be at least as effective as OSHA.
- [10]OSHA, Iowa State Plan. Iowa OSHA is part of the Iowa Division of Labor Services; the State Plan applies to private sector workplaces in Iowa, with listed exceptions.
- [11]OSHA, Outreach Training Program. Outreach (10- and 30-hour) training is voluntary and is not a certification; the 30-hour class suits supervisors or workers with some safety responsibility.
Sources read 2026-10-30. Regulations change; check the current text and your contract before relying on any summary here. This page is general information, not legal advice.