Building new data centers is a large, complex project involving numerous subcontractors and trades. There are also numerous hazards on a data center worksite, which can include falls from heights; heat stress; struck-by hazards; contact with equipment; caught-in hazards; electrical hazards, including arc flash, electric shock, and electrocution; respirable silica dust; occupational noise; and musculoskeletal disorders (MSDs). The hazards associated with these projects are best handled through a comprehensive safety and health management program, effective hazard controls, subcontractor buy-in and coordination, and training.
Some of the most frequently cited Occupational Safety and Health Administration (OSHA) standards are those for confined space entry, electrical safety, fall protection, hazard communication, powered industrial trucks, ladder safety, and respiratory protection.
A look at a strategic partnership agreement for a data center project offers clues to critical safety and health protections. Last year, OSHA’s Dallas area office established a strategic partnership with Holder Construction Group, LLC, the general contractor on a data center project in Red Oak, Texas.
One of the primary goals of the strategic partnership was to develop a model safety and health program based on OSHA’s updated Recommended Practices for Safety and Health Programs. Strategies for achieving the partnership’s goals included the following:
- Using tools, such as safety reports, job hazard analysis, or job safety analysis, to reduce or eliminate hazards to employees working at the site.
- Using preconstruction contract and bid-submission tools to select subcontractors that showed a consistent commitment to safe work-related practices and employee safety.
- Ensuring all serious hazards were controlled through safe processes and procedures and correcting hazards identified during the project on a day-to-day basis.
- Implementing an aggressive fall protection plan to include fall protection in all cases where work was being performed 6 feet or more above lower surfaces and verifying that each contractor using personal fall protection equipment received the required fall protection training and that the training was documented.
- Encouraging subcontractor participation in jobsite safety awareness activities, including daily or weekly audits and site surveys, and encouraging subcontractors to solicit their employees’ participation in their own safety and health programs.
- Ensuring 100% of Holder’s on-site supervisory personnel (safety managers, project managers, and superintendents) and 50 percent of the first-tier subcontractor’s competent person designees completed the 30-Hour OSHA construction course (or its equivalent).
- Ensuring safety and health training for subcontractors with Spanish-speaking employees was conducted in Spanish and included OSHA’s 10-Hour course, training on struck-by hazards, ladder safety, fall protection, excavation/underground utility installation, and silicosis.
- Requiring that subcontractors that had written safety and health programs submit their written programs to Holder and that subcontractors that didn’t have their own written safety and health programs adopt Holder’s program.
- Ensuring compliance with the National Fire Protection Association (NFPA) 70E standard (Electrical Safety in the Workplace) when working on live electrical equipment, including training specifications and the availability and use of personal protective equipment (PPE).
- Ensuring all equipment capable of extremity amputations was adequately guarded in accordance with OSHA and equipment manufacturer requirements.
- Establishing and using a program to ensure all crane operators were competent and certified to operate the specific crane in use. Crane operators are encouraged to have their Certification of Crane Operators (NCCO).
- Planning all critical lifts to be performed during the project. Lifts over 75% are considered critical and require additional documentation, such as an Engineered Lift Plan.
Electrical Hazards
Electrical work exposes workers to two main dangers: electric shock/electrocution from contact with energized parts and arc flash and burns from short circuits or faults, which can reach thousands of degrees and cause severe burns even without direct contact. Supervisors should treat any energized equipment as potentially life‑threatening and ensure strict work practice controls are in place.
Industry consensus standards include the NFPA’s National Electrical Code (NFPA 70) and Standard for Electrical Safety in the Workplace (NFPA 70E). NFPA 70 covers practices for protecting people and property from electrical hazards through safe electrical design, installation, and inspection. Originally developed at the request of federal OSHA, NFPA 70E details requirements for safe work practices to protect employees by reducing their exposure to major electrical hazards, such as shock, electrocution, arc flash, and arc blast.
NFPA 70E, a private industry standard, can help in complying with OSHA’s general industry (1910 Subpart S) and construction (1926 Subpart K) electrical safety standards. NFPA 70E also identifies the four categories of arc-rated (AR) PPE.
De‑energizing, locking, and tagging out electric machinery and equipment are your primary controls. OSHA and the National Institute for Occupational Safety and Health (NIOSH) emphasize that the most effective protection is to de‑energize circuits before work and use lockout/tagout (LOTO) to prevent accidental reenergization. LOTO procedures must be documented, implemented, and audited regularly.
OSHA’s electrical safety standards and the NFPA 70E industry consensus standard require that employees exposed to electrical hazards receive job‑specific training. Qualified personnel must understand the hazards, safe work practices, and PPE requirements for the voltage and equipment they work on, and unqualified personnel must be trained to recognize electrical hazards and avoid approaching exposed energized parts.
Those who work with electrical equipment must have appropriate PPE, such as insulated gloves, AR clothing, and face shields.
Electrical equipment and power tools must be inspected and properly maintained. Damaged cords and improperly grounded tools are issues commonly cited by OSHA.
Both OSHA and the NFPA stress that managers should establish and enforce an electrical safety program rather than simply reacting to hazards. An effective program would include regular hazard assessments regarding electrical tasks, documented LOTO procedures, supervisor’s audits, incident reviews, and safety meetings focused on electrical risks.
Employer resources available from OSHA include the Outreach Training Program’s training resources for the construction industry’s fatal four hazards, including electrocution; “Protecting Employees from Electric-Arc Flash Hazards”; and the Controlling Electrical Hazards booklet.
Resources provided by NIOSH include an alert titled “Preventing Worker Deaths from Uncontrolled Release of Electrical, Mechanical, and Other Types of Hazardous Energy” and “Preventing Fatalities of Workers Who Contact Electrical Energy.”
Fall Protection
Falls from heights are one of the construction industry’s fatal four safety hazards, and OSHA’s fall protection standard is its most frequently cited regulation. You must protect employees working at 6 feet or more above a lower level using a guardrail, a safety net, or a personal fall arrest system. A personal fall arrest system has three components: an anchor to which the other components are rigged, a full-body harness worn by a worker, and a lanyard or lifeline connecting the worker’s harness to the anchorage point.
Anchor options include a peak anchor—a solid, non-moving piece secured at the rooftop to trusses underneath—or a permanent D-ring attached to a truss frame.
You also need to train employees on fall hazards and the use of fall protection. OSHA’s fall protection training standard (§1926.503) is another of the agency’s 10 most frequently cited standards. Training needs to cover the nature of fall hazards on the job and the content of the fall protection standards. Employees must also receive instruction on correctly erecting, inspecting, maintaining, and disassembling the guardrail, personal fall arrest, and safety net system selected for a worksite, as well as training on how to use these systems.
LOTO, Machine Guarding
OSHA’s top 10 most cited standards also include those for controlling hazardous energy (LOTO) and machine guarding. Both help protect workers from amputation hazards, and the LOTO standard helps keep workers safe from electric shock and electrocution.
LOTO training must cover the purpose and use of the energy control procedures. Workers also need to understand the standard’s prohibition against restarting or reenergizing machines or equipment that have been locked or tagged out. The employees authorized to lock out machines or equipment need additional training on the sources of hazardous energy in the workplace, the types and magnitude of energy present at the worksite, and the means and methods for isolating and/or controlling energy as part of your LOTO procedures.
Machine guarding can include barrier guards and two-hand operating devices. Machine guards should be attached to tools or machinery whenever possible.
Respiratory Protection
Required elements of a written respiratory protection program include the following:
- Policies and procedures for selecting respirators appropriate for hazards at your worksite;
- Medical evaluations to determine employees’ ability to use respirators;
- The use of tight-fitting respirators to ensure a facepiece seal and fit testing following OSHA-approved protocols;
- Maintenance and care, cleaning and disinfection, and storage of reusable respirators;
- Employee training and information that includes training on performing a user seal check each time a respirator is used; and
- Records of medical evaluation, fit testing, and training.
Respirator selection depends on the respiratory hazards present at the worksite. Types of respirators include filtering facepiece respirators (e.g., N95s), elastomeric respirators (quarter-facepiece, half-mask, and full-facepiece), powered air-purifying respirators (PAPRs), supplied-air respirators, self-contained breathing apparatus (SCBA), and a combination supplied-air/SCBA.
Respiratory protection may be necessary to protect workers from silica exposures. Respirable crystalline silica dust is created when cutting, crushing, drilling, grinding, or sawing block, brick, concrete, mortar, rock, and stone. Illnesses from silica exposures can include chronic obstructive pulmonary disease (COPD), kidney disease, lung cancer, and silicosis, an incurable lung disease that can lead to disability and death.
Work practices for controlling silica exposures include using wet methods, properly handling all waste materials, and safe cleanup housekeeping methods. A full-face, tight-fitting PAPR is the prescribed respiratory protection.
Summing up
Data center construction projects are big, complex endeavors. Hazards include the fatal four construction industry safety hazards—caught-in/-between, electrocution, fall, and struck-by hazards—but can also include confined spaces, heat stress, MSDs, and respirable silica dust.
You need a robust safety and health management system of controls, incident or near-miss investigations, and training. You also need to vet subcontractors during the bidding and contracting process. Obtain documentation on subcontractors’ safety and health management systems or insist that they adopt yours.
Training begins with OSHA 10 training for workers and OSHA 30 training for managers and supervisors. However, workers and supervisors may need additional safety training on specifics, such as confined space entry, electrical hazards, fall protection, respiratory protection, and silicosis.