LEGAL NEWS & UPDATES Five OSHA Citation Issues Data Center Contractors May Not See Coming
T he rapid growth of data centers has created enormous demand for generator installation, commis- sioning, load bank testing, and main- tenance services. Whether supporting a hyperscale facility, colocation provider, or enter- prise data center, contractors often focus on the obvious hazards: elec- trical shock, arc flash, and lockout/ tagout. Those risks are real, but they are not always the issues that create the greatest OSHA exposure. After a serious injury or near miss, OSHA often looks beyond the imme- diate incident and evaluates the sys- tems surrounding the work, including planning, training, contractor coor- dination, and equipment inspection practices. Here are five OSHA citation issues data center contractors may not see coming. 1. Contractor Coordination Failures Few work environments involve more contractors than a data center con- struction or commissioning project. Generator contractors, electrical contractors, commissioning teams, controls specialists, fuel system ven- dors, and facility representatives may all be working in the same area at the same time. Under OSHA’s multi-employer worksite doctrine, a company may be cited even if it did not create the hazard. Following an incident, OSHA often examines who controlled the worksite, who created or corrected the hazard, and whether contractors effectively communicated safety re- sponsibilities before work began. A common mistake is assuming an- other contractor is managing the haz- ard. OSHA may reach a different con-
clusion, particularly when a compa- ny’s own employees were exposed.
2. Inadequate Pre-Task Hazard Assessments Data center projects move fast. Schedules are tight, systems are complex, and pressure to maintain milestones can be significant. As a result, pre-task planning some- times becomes a check-the-box ex- ercise. Following an incident, OSHA routine- ly asks whether hazards associated with testing, energization, temporary power, fuel systems, battery sys- tems, equipment access, and work around other trades were identified before work began. If there is no meaningful hazard as- sessment, OSHA may conclude that foreseeable hazards were not ade- quately identified or controlled. 3. Failure to Inspect Temporary Equipment Commissioning and testing activities frequently rely on temporary cables, load banks, connectors, grounding equipment, and temporary power distribution systems. These components may only be used for a short period, but OSHA expects them to be inspected and maintained like other equipment. Cable routing, damaged insulation, improper con- nections, inadequate guarding, and defective components can all be- come enforcement issues after an incident. A damaged temporary cable can quickly transform a routine testing operation into a serious injury event. 4. Training Deficiencies Data center projects often require technicians to perform unfamiliar
Karen F.Tynan Shareholder, EGSA Member Ogletree Deakins
Robert C. Rodriguez Shareholder, EGSA Member Ogletree Deakins
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