Construction Program Management and Inspection Guide

Labor Compliance
Become familiar with the U.S. Department of Labor
(USDOL) labor compliance provisions contained in Form
FHWA 1273. Evaluate the effectiveness of the contractor
and the contracting agency in administering these
requirements:
▼ Weekly payrolls are submitted from the prime
contractor and all subcontractors.
▼ Statements of compliance are signed and attached to
payrolls.
▼ Seven-day pay periods are established and constant.
▼ Wages and fringe benefits are at rates not less than
those predetermined by the Secretary of Labor as
contained in the contract provisions.
▼ Work performed by any specific class of employees,
including helpers and apprentices, conforms to the
classifications set forth in the contract provisions.
▼ Employee classifications are correct for the work
performed.
▼ Payroll forms reflect number of hours worked per day
and per week.
▼ Gross and net wages are shown.
▼ When hours worked exceeds 40 in any work week, 1.5
base rate is paid.
▼ All weeks to date are accounted for.
▼ There is no evidence of any disproportionate
employment of laborers, helpers, or apprentices that
would indicate avoidance of the appropriate journeyman
wage rate provisions.
▼ Trainee/apprentice documentation on file.
▼ Spot check interviews with employees of the contractor
and subcontractors; comment on how these interviews
are documented in project records. Make several spot
interviews with employees and document findings.
▼ The contract wage rates are posted and available to the
contractor’s and subcontractor’s employees.
▼ Unresolved violations are properly dealt with in
accordance with STA, FHWA, and USDOL
procedures.
▼ FHWA representatives are kept aware of labor
discrepancies.
▼ The STA is preparing and submitting the Semi-Annual
Labor Compliance Enforcement Report, Form FHWA
1494.
Bulletin Board
Verify that the prime contractor maintains a bulletin board in
a prominent location where employees congregate. Refer to
the appendix of FHWA’s Contract Administration Core
Curriculum Manual for a listing of job site posters and
Federal forms to be displayed (www.FHWA.dot.gov/
programadmin/contracts/poster.htm).
Construction Safety
Appendix D: Inspections-in-Depth
CONSTRUCTION PROGRAM MANAGEMENT AND INSPECTION GUIDE (5/01/04)
Become familiar with the USDOL Occupational Safety and
Health Administration (OSHA) provisions contained in 29
CFR 1926 (see the OSHA Web site: www.osha.gov).
▼ Evaluate the effectiveness of the contractor and the
contracting agency in administering safety and health
requirements.
▼ Document STA guidance provided to field engineers
and inspectors on their role and responsibility.
▼ Inspect the project to identify potential safety and
health hazards; photograph concerns for discussion with
the STA and the contractor.
▼ Document how many contractor personnel workdays
have been lost to project injury.
▼ Obtain a copy of OSHA Document 2202 for a quick
reference.
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