Why We Performed This Audit
We performed this audit to determine if the Public Buildings Service’s (PBS’s) policies and procedures are effective in protecting GSA employees and contractors from roof fall hazards. This audit was included in the GSA Office of Inspector General’s Fiscal Year 2024 Audit Plan based on roof safety deficiencies in GSA-owned buildings that were either identified in prior audit reports or alleged in a December 2022 hotline complaint.
Our audit objective was to determine if PBS’s operations and oversight of operations and maintenance (O&M) contractor performance adequately comply with Occupational Safety and Health Administration (OSHA) and GSA requirements to protect GSA employees and contractors from roof fall hazards.
What We Found
PBS is not consistently complying with OSHA and GSA requirements to protect GSA employees and contractors from roof fall hazards. We found that PBS is not providing adequate oversight of O&M contractors’ safety plans, lacks sufficient fall protection systems and protective equipment, and is not ensuring PBS facility managers receive safety training. As a result, PBS is not ensuring that its employees and contractors comply with fall protection requirements.
We also found that PBS risk management surveys are not effectively identifying and resolving roof fall hazards in a timely manner. Additionally, PBS did not conduct the roof fall protection assessments for roof replacement projects required by GSA’s P100, Facilities Standards for the Public Buildings Service, and did not always post appropriate signage at its buildings to warn GSA employees, contractors, and tenants of roof fall hazards. Taken together, these deficiencies increase the risk of fall-related injury or death.
What We Recommend
We recommend that the Acting GSA Administrator:
- For buildings where GSA employees access the roof, include a requirement to perform roof inspections during annual Occupational Safety and Health surveys conducted in accordance with GSA Order 5940.2, General Services Administration Occupational Safety and Health Program.
We recommend that the PBS Commissioner:
- Improve oversight of O&M contractors to ensure they develop and use safety and health plans that comply with the National O&M Specification and National Consolidated Maintenance Specification contract templates.
- Provide training to PBS contracting officer’s representatives and regional safety offices on their roles and responsibilities for accepting, reviewing, and approving compliant safety and health plans.
- Provide fall protection training to PBS facility managers that addresses roof fall hazards and fall protection requirements issued by OSHA and GSA.
- Resolve identified roof fall hazards in a timely manner by installing necessary OSHA-compliant fall protection on roofs with equipment located near unprotected roof edges. If no funding is available to do so, implement interim controls to protect against fall hazards and monitor the performance of those controls to ensure they remain effective.
- Require contractors to use OSHA-compliant fall protection.
- Implement a consistent process for ensuring facility managers are aware of all open risk conditions in the Inventory Reporting Information System, address open risk conditions in a timely manner, and periodically review open risk conditions until they are abated.
- Improve risk management surveys to ensure survey inspectors identify and record all applicable roof fall hazards under OSHA 1910.28, Duty to have fall protection and falling object protection, consistently.
- Review all ongoing and future roof replacement projects to ensure they comply with P100 roof replacement requirements for a review of existing fall protection by a qualified consultant; and, if the fall protection is deemed inadequate, design and install OSHA-compliant fall protection.
- Post appropriate signage at all roof access points to warn employees, contractors, and tenants of roof fall hazards.
The PBS Commissioner agreed with our recommendations.
