Three phases, three different facilities.
Construction, commissioning and operations are genuinely different risk profiles, governed by different standards, staffed by different people. Every requirement on this site is written against the phase it applies to.
Every safety practice intersects the three phases differently. Fall protection during construction is steel and roof; in operations it is rooftop mechanical and elevated cable tray, at a different trigger height. Heat stress during construction is outdoor summer work; in operations it is a contained hot aisle. Electrical safety during construction is temporary power; during commissioning it is deliberate energization; in operations it is 2N isolation.
§ The three phases
Construction
OSHA 1926. Temporary power, falls, excavation, critical lifts, silica, and a workforce hired faster than it can be qualified.
Commissioning
L1 through L5. The most dangerous weeks in the building's life — where construction becomes live.
Operations
OSHA 1910 and NFPA 70E. Concurrent maintainability, 2N isolation, vendor access and work that cannot wait.
| Construction | Commissioning | Operations | |
|---|---|---|---|
| Standard | OSHA 1926 | 1926 + 1910 + NFPA 70E | OSHA 1910 + NFPA 70E |
| Fall trigger | 6 ft | Depends which side you are on | 4 ft |
| Electrical | Temporary power, Subpart K | First energization; 70E begins to apply | 2N isolation, permits, arc flash |
| Workforce | Large, transient, multi-employer | Small, specialised, high authority | Small, permanent, plus vendors |
| Dominant risk | Struck-by, falls, temporary power | Energization | Energized work under production pressure |
| Who is liable | Multi-employer doctrine | Contested — depends on turnover state | The operator, plus contract employers |
§ The overlap is the hard part
On a live campus with an active build-out, all three phases exist simultaneously on one property. A fit-out crew is under 1926 with a 6-foot fall trigger; the operations technician forty feet away is under 1910 with a 4-foot trigger; and the gear between them was energized last Tuesday, which means 70E applies to it regardless of what either crew thinks the room is.
Three controls close most of this: physical demarcation that moves as the boundary moves, a written and posted energization status for every piece of gear, and a single named switching authority per system per phase.
Onsite classes for the whole campus
NFPA 70E for the electrical and commissioning crews, full-practice EHS breadth for the rest of the project.
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