S02 Supplemental Attachments - EC-32 Safety and Health During Construstion.pdf

Butler VA Health Care System Medical Center Policy EC-32

Butler, PA March 29, 2022

SAFETY AND HEALTH DURING CONSTRUCTION

I. PURPOSE: To establish policy and procedures to ensure that construction projects are planned, coordinated, and regularly inspected to ensure compliance with applicable fire, infection control, environmental, security, safety and occupational health regulations, and policies.

II. POLICY:

A. In order to protect Butler VA Health Care System’s Veterans, staff, visitors, and contractors from safety and health hazards associated with construction activities and at all Community Based Outpatient Clinics (CBOCs), this policy requires that strategies be established to control the hazards inherent in conducting construction or maintenance operations in areas that are occupied by Veterans, visitors, or staff. These strategies include: the assignment of appropriate responsibility at all levels of the organization, establishing, and maintaining the necessary expertise to manage an effective construction safety and health program, applying technical guidance and best practices to assist in managing the program, and providing a Construction Safety Subcommittee to oversee and enforce the application of this policy.

B. Construction activities are defined to include delegated minor or non-recurring maintenance projects performed by contractors or purchase and hire personnel, as well as station-level projects performed by contractors, purchase and hire personnel, or station Maintenance and Operations (M&O) personnel. Construction also includes non-delegated projects including majors, and this facility will coordinate those construction impacts with the project’s Resident Engineer (RE) through a single point of contact. This definition also applies to enhanced use and lease projects related to structures for which this facility maintains management responsibility or authority.

C. The intent of the Construction Safety Program is to reduce the potential for injury and illness to Veterans, visitors, staff, and contractors that might result from unsafe construction activities; to increase the level of construction safety expertise of those VA employees involved in construction-related activities; to increase and maintain compliance with all applicable Occupational Safety and Health Administration (OSHA) standards and regulations; to provide guidelines for addressing safety-related construction issues; and to reduce the potential for property and liability exposures due to construction-related activities.

D. Proper application of this program will reduce the potential for liability, which may result from construction incidents, life safety deficiencies, or infection control failures.

III. RESPONSIBILITY:

A. Director will:

1. Establish and monitor an effective facility Construction Safety Program.

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2. Establish a Construction Safety Subcommittee to include:

a. Chief Engineer/Facility Manager, as Chair

b. Safety Officer,

c. Infection Control Specialist,

d. Fire Chief/Emergency Preparedness Coordinator,

e. Project Manager/Contracting Officer’s Representative (COR),

f. Environmental Protection Specialist/Green Environmental Management Systems (GEMS) Coordinator,

g. Contracting Officer,

h. Police,

i. Local Union Safety Representatives,

j. Employee/Occupational Health,

k. Patient Safety,

l. Including additional ad hoc representatives from the following program areas as needed to address construction activities impacting other program areas and service lines:

(1) Safe Patient Handling,

(2) Facility Management,

(3) Contracting.

3. Designate a COR as Construction Safety Officer(s) (CSO) that have the necessary training, experience, and authority to carry out their responsibilities with respect to safety and health during construction activities to oversee construction safety.

4. Ensure that appropriate staff receives training in construction safety.

5. Ensure that the designated COR for each project acts as or identifies Competent Persons (CP) who have the necessary training, experience, and authority to carry out their responsibilities with respect to safety and health during construction activities.

6. Ensure that the Construction Safety Subcommittee actively engages in:

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a. Protecting Veterans, visitors, and employees from traumatic injury, toxic environmental exposures, and occupational and facility associated infections.

b. Determining the scope and depth of safety, environmental, infection control, emergency management, and security interventions appropriate for all construction work.

The team may develop threshold criteria for each level of intervention. For instance, upon initial project scope review, some projects may require only CSO surveillance to ensure employee safety and OSHA compliance, while other projects may require additional or all disciplines to be involved.

c. Conducting and/or reviewing preconstruction risk assessments for air quality requirements, infection control, utility requirements, noise, vibration, and other hazards that may affect care, treatment, and services. Using the current American Institute of Architects (AIA) guidelines, staff must conduct and document, in writing, preconstruction risk assessments during the design or planning stage of the work (prior to bidding, award, and starting work). Preconstruction risk assessments must focus on eliminating, or minimizing, the identified risks during construction and renovation activities. The complexity of the preconstruction risk assessment report is determined by the complexity of the threats posed by the construction project. Assigned VHA staff and Facility Management staff must evaluate and affirm compliance during the construction phase of the work.

d. Ensuring that Interim Life Safety Measures (ILSM) are assessed and implemented on all construction work in accordance with The Joint Commission (TJC) standards. ILSMs are required when Life Safety Code deficiencies or construction activities pose significant hazards as determined by the assessment. Each facility must have a local policy addressing ILSM as required by TJC.

e. Participating in all phases of construction work from planning through completion. This includes review and approval of construction plans, contract specifications, and contract submittals related to construction safety and health, and any other documents that may assist in the implementation of an effective Construction Safety Program. The Construction Safety Subcommittee must be involved early in the process and continue oversight on a regular basis to avoid costly and disruptive delays.

f. Overseeing compliance with VA/VHA directives, OSHA, and state construction safety regulations.

g. Overseeing compliance with Environmental Protection Agency (EPA), Pennsylvania Department of Environmental Protection (PADEP), and local environmental regulations.

h. Complies with Federal Acquisitions Regulations (FAR) and VA Acquisition Regulations (VAAR) addressing a contractor’s Construction Safety Program.

i. Responds to, investigates, and reports violations of these policies to upper management through the Associate Director for Operations and the Environment of Care

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(EOC) Committee.

j. Ensuring that the Construction Safety Program includes periodic construction site hazard surveillance activities with appropriate membership, scope, and frequency for each project as determined by the CSO or the Safety Officer and the preconstruction risk assessment. At a minimum, bi-weekly Construction Safety Subcommittee surveillance activities as well as daily COR/CSO inspections are required.

Hazard surveillance activities must be documented (date, time, members of the inspection team, deficiencies, type of corrective action, and time and date of correction).

Correction of hazards must be tracked to completion and documented in the Contractor Performance Assessment Reporting System (CPARS) annually.

k. Ensuring that all contractors entering any owned or leased properties comply with the security management program. At a minimum, contractors must notify and obtain permission from Police Service, be identified by project and employer, and be restricted from unauthorized access.

l. Ensuring that all contractor employees have adequate documentation that they have no active tuberculosis.

m. Evaluating the effectiveness of the Construction Safety Program in an annual report to the EOC Committee.

n. Requiring the contractor’s CP implement and maintain an effective site-specific Construction Safety Program that identifies and controls hazards that may cause injury or illness to Veterans, staff, visitors, and contractor employees.

o. Acting as members of the Construction Safety Subcommittee and meeting on the second Thursday of each month.

p. Ensuring that documentation of the COR’s inspections is provided timely to the Construction Safety Subcommittee and/or the VISN Safety and Health Staff as requested.

7. Develop and implement a written facility policy addressing the responsibilities of the COR and the Construction Safety Subcommittee.

8. Ensure that VA staff receives training as follows:

a. Contracting Officers (CO) and all members of the Construction Safety Subcommittee complete at least ten hours of Construction Safety Training every two years.

b. Appointed CP, CORs, Safety Officer, Chief Engineers/Facility Management, RE, supervisors, and foremen who oversee construction work initially complete an OSHA 30-hour Construction Safety or equivalent VHA training course and subsequently complete ten hours of Construction Safety training every two years.

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9. Ensure that construction contracts awarded after July 31, 2005, specify that on-site general and sub-contractor’s construction workers have completed at least ten hours of Construction Safety Training, the 30-hour OSHA Construction Safety Training course, or other relevant competency training as determined by the Construction Safety Subcommittee. The determination for training is based on the project hazards and complexity, state and federal regulations, and VA requirements.

B. The Associate Director will complete responsibilities delegated from the Director, as appropriate, for oversight of these policies.

C. The Chief Engineer will:

1. Work with contractors and facility staff to coordinate and monitor an effective Construction Safety Program for projects under their direction.

2. Complete the VA’s 30-hour Construction Safety Training and subsequently complete at least ten hours of Construction Safety training every two years.

3. Support the periodic inspections of construction sites by planning and allocating time and resources.

4. Act as the Safety Officer in accordance with VAAR 836.236-87 and ensure contractors and RE’s comply with VA safety and health policies, procedures, and contract requirements.

5. Support the COR’s, Construction Safety Officers, Safety Officer, Contracting Officer, and engineering staff in implementing the Construction Safety Program.

6. Participate in periodic inspections of in-house construction sites to ensure compliance with safety elements of the construction contract and satisfactory performance within the Construction Safety Program.

7. Ensure that in-house, workforces have necessary training and competency for tasks being performed.

8. Serve as chairperson of the facility Construction Safety Subcommittee to ensure contracts meet the committee’s requirements.

D. CO and COR trained and designated as CP will:

1. Complete at least 30 hours of construction safety training and subsequently complete 10 hours of construction safety training every two years. The construction safety training will be documented within the CO’s and the COR’s training record.

2. Ensure that all solicitations and contracts include the FAR clause found in FAR 52.236-13, Accident Prevention, and VAAR clause found in VAAR 836.236-87.

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3. Designate, in writing, the COR-CSO to serve as the Safety Officer for VHA contracts; and the RE to act as the Safety Officer for the Office of Construction & Facility Management (CFM) contracts (applies to CO).

4. Add paragraph (f) found in FAR 52.236-13 to the basic clause, if the contract will involve work of a long duration or hazardous nature, or performance on a government facility that, on the advice of COR-CSO, involves hazardous materials or operations that might endanger the safety of the public or government personnel or property.

5. Ensure that all solicitations and contracts specify that on-site general and sub-contractor’s construction workers have completed ten hours of Construction Safety training or the OSHA 30-hour Construction Safety training, and other relevant competency training, as determined by the CSO with input from the Construction Safety Subcommittee. The determination for other relevant competency training is based on the project hazards and complexity, Federal and State regulations, and VA requirements.

6. Ensure that all projects require contractor certification, verifying completion of required training.

7. Ensure submittals for contract construction or renovation work to include the names, qualifications, and training dates for the contractor CP designated to administer the site-specific safety program as well as the CP for other activities as required by OSHA regulation (such as scaffolds, cranes, excavations, etc.).

8. Evaluate and consider past safety records of prospective contractors in awarding contracts. At a minimum, ensuring that all solicitations and contracts specify that contractors must not have more than three serious, or one repeat, or one willful OSHA violation(s) in the past 3 years or any significant environmental penalties. Additionally, ensuring that all solicitations and contracts specify that contractors must have an Experience Modification Rate (EMR) of equal to or less than 1.0. (EMR of 1.0 indicates that a contractor had an average insurance claim’s rate for worker injuries.). OSHA compliance history can be accessed through the following web site:

http://www.osha.gov/pls/imis/establishment.html. Enter contractor’s name into search engine, review search list for contractor, verifying contractor’s name and address as the one reviewing, and review inspection history for violations.

9. Serve on the facility Construction Safety Subcommittee to ensure contracts meet the committee’s requirements.

10. Support the COR-CSO, Safety Officer, RE, and appropriate staff in implementing the construction safety program and enforcement of the contracts.

11. Ensure that if contracted construction worker(s) have been determined to be at risk for transmission of tuberculosis (TB) based upon the TB preconstruction risk assessment, The contractor must provide written certification that all contract employees assigned to the work site have had a pre-placement tuberculin screening within 90 days prior to assignment to the work site and been found to be with negative screening reactions.

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This can be the Center for Disease Control (CDC) two-step skin testing or a Food and Drug

Administration (FDA) approved blood test. Contract employees manifesting positive screening reactions to the tuberculin must be examined according to current CDC guidelines prior to working on VHA property. Subsequently, if the contractor’s employee is found without evidence of active

(infectious) pulmonary TB, a statement documenting examination by a physician must be on file with the employer (construction contractor), noting that the employee with a positive tuberculin screening test is without evidence of active (infectious) pulmonary TB. If the employee is found with evidence of active (infectious) pulmonary TB, the employee would require treatment with a subsequent statement as outlined in subparagraph 4q(11)(c) before being allowed to return to work on VHA property.

E. COR CSO will:

1. Submit project reviews of all construction projects.

2. Provide oversight of contract construction safety.

3. Be knowledgeable in the general inspection of typical work sites during construction and renovation performed by contract staff and in the review of contractor safety program submittals. CSO(s) do not take the place of the contractor’s CP nor act on their behalf. The CSO(s) determines if the contractor is meeting VA standards and contractual requirements for safety and OSHA compliance. When these standards and contract requirements are not being met, the VA COR, CO, and CSO must take immediate action to prevent injury, exposure, noncompliance, and/or property damage.

4. Complete VA’s 30-hour Construction Safety Training and subsequently complete ten hours of Construction Safety training every two years.

5. Ensure that the site-specific safety requirements for construction operations are implemented during facility projects.

6. Serve as a member of the Construction Safety Subcommittee.

7. Conduct, at a minimum, weekly inspections of VHA construction sites to ensure compliance with safety elements of established program(s).

8. Monitor and inspect construction and renovation work sites periodically to assure compliance with these policies.

9. Maintain competence in the general inspection of work sites during construction, renovation, and maintenance, falls under the purview of this policy.

10. Approve corrective actions.

11. Stop unsafe work or activities that are non-compliant with the contract or OSHA regulations and notify the CO immediately.

12. Maintain communication with the contractor CP on questions of safety.

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F. Facility Safety Officer will:

1. Complete VA’s 30-hour Construction Safety training and subsequently complete ten hours of Construction Safety training every two years.

2. Ensure that VHA policy for the Construction Safety Program is implemented within the facility.

3. Provide guidance on OSHA regulations as they apply to emergency planning, response, and operations in construction (i.e. 29 CFR 1926.35 and 29 CFR 1926.65).

4. Monitor contractor performance to contracted specifications on OSHA Regulations as they apply to emergency planning, response, and operations related to construction operations.

5. Ensure that necessary and relevant ILSMs are established and implemented.

Conducts required additional training for compliance with identified ILSMs.

6. Provide technical advice and assistance as required in connection with life safety and fire protection issues during construction, project design, and development.

7. Oversee compliance with OSHA and other relevant construction safety regulations.

8. Confirm that VA staff receives training required by this policy.

9. Ensure that the Construction Safety Program includes appropriate periodic construction site hazard surveillance.

G. Infection Control Specialist will:

1. Advise and/or provide recommendations on exposure mitigation and the prevention of facility associated infections in Veterans, staff, and visitors.

2. Coordinate with the manager of each construction project (in-house and contract) to conduct an Infection Control Risk Assessment (ICRA) during the planning and/or design stage of work. ICRAs must be documented in writing and focus on eliminating, or minimizing, the risk of infection during construction and renovation activities.

3. Monitor infection prevention protocols during construction activities as indicated in ICRA for that project.

H. Environmental Protection Specialist/GEMS Coordinator will:

1. Provide guidance on EPA regulations and environmental issues, as those

9 Medical Center Policy EC-32 regulations and issues directly and immediately relate to the safety during the design stage.

2. Monitor contractor compliance with contract specifications on EPA regulations, as those regulations directly and immediately relate to the construction project, including environmental compliance, pollution prevention, waste management, and permitting.

3. Complete VA’s 30-hour Construction Safety Training and subsequently complete ten hours of Construction Safety training every two years.

I. The Construction Safety Subcommittee will:

1. Determine the scope and depth of safety, infection control, emergency management, and security interventions appropriate for all construction work. The team may develop threshold criteria for each level of intervention. For instance, after review, some projects may require only CSO surveillance to ensure employee safety and OSHA compliance, while other projects will require all disciplines to be involved.

2. Review COR-CSO’s preconstruction risk assessments for air quality requirements, infection control, utility requirements, noise, vibration, and other hazards that affect care, treatment, and services. Using the current AIA Guidelines, staff must conduct and document in writing preconstruction risk assessments during the design or planning stage of the work (prior to bidding, award, and starting work). Preconstruction risk assessments must focus on eliminating or minimizing the above-mentioned risks during construction and renovation activities. The complexity of the preconstruction risk assessment report is determined by the complexity of the threats posed by the construction project. Assigned VHA staff and CFM REs must confirm compliance during the construction phase of the work.

3. Review COR-CSO’s preconstruction risk assessment for the transmission of TB to the contracted construction workers based upon the construction site location, patient population, hospital layout, and the Center for Disease Control’s (CDC) defined risk as outlined in the “CDC Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in the Health-Care Setting, 2005.”

4. Ensure COR’s and CSO’s ILSMs are assessed and implemented on all construction work in accordance with TJC Standards. ILSMs are required when Life Safety Code deficiencies or construction activities pose significant hazards as determined by the assessment. Each facility must have a local policy addressing ILSM as required by TJC. Please refer to MCP SC-23 Interim Life Safety Measures, dated August 20, 2020.

5. Participate and review all phases of construction work from planning through completion. This includes review and approval of construction plans, contract specifications, and contract submittals related to construction safety and health and any other documents that may assist in the implantation of an effective Construction Safety Program. The Construction Safety Subcommittee must be involved early in the process https://dvagov.sharepoint.com/:b:/r/sites/VHABUTvamc/Policies/MCM1/MCP%20PDF%20Files/SC%20-%20Safety_Security/SC-23%20Interim%20Life%20Safety%20Measures.pdf?csf=1&web=1&e=8zt2S6

10 Medical Center Policy EC-32 and continue oversight on a regular basis to avoid costly and disruptive delays.

6. Ensure that the Construction Safety Program includes periodic construction site hazard surveillance activities with appropriate membership, scope, and frequency for each project as determined by the CSO and the preconstruction risk assessment. At a minimum, weekly surveillance activities are required. In some cases, daily inspections may be warranted. Hazard surveillance activities must be documented (date, time, members of the inspection team, deficiencies, type of corrective action, and time and date of correction). Correction of hazards must be tracked to completion.

7. Ensure all contractors entering VHA properties comply with the security management program. At a minimum, contractors must notify and obtain permission from the Police Service, be identified by project and employer, and be restricted from unauthorized access.

8. Ensure that all contractor employees have adequate documentation that they have no active TB.

9. Evaluate the effectiveness of the Construction Safety Program in an annual report to the EOC Committee, or equivalent committee.

10. Require the contractor CP to implement and maintain an effective Safety Program that identifies, and controls hazards that may cause injury or illness to Veterans, staff, visitors, and contractor employees.

11. Act as members of the Construction Safety Subcommittee and meet on the second Thursday of every month.

12. Ensure that documentation of the team’s inspections is provided to the VISN Safety and Health Staff as requested.

13. Provide CORs with updates on compliance with this policy in the form of an A/E design and construction period’s itemized checklist. Provide a construction safety file template for COR-CSO usage to facilitate Construction Safety Subcommittee’s periodic evaluations and project reviews.

J. Police Service will:

1. Ensure that all contractors entering this facility comply with the Security Management Program. At a minimum, contractors must notify and obtain permissions of the VA Police, be identified by project and employer, and be restricted from unauthorized access.

2. Conduct periodic surveillance of site security and the integrity of barriers for trenches and other hazards.

IV. INTERVENTION AND ENFORCEMENT:

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A. All individuals with defined actions in this policy will intervene, whenever conditions, as a result of construction activities, immediately threaten life or health or threaten to damage equipment or buildings. Intervention and enforcement of this policy and the associated regulatory requirements are as follows:

1. Staff: All staff will identify hazardous conditions in need of intervention and further develop a culture of safety. CPs and all Facility Management staff will take prompt corrective measures to include immediate abatement of hazards, stoppage of work whenever imminent dangers are present, hazard awareness training, administrative controls, etc.

2. Contractors: The COR, CSO, or CO shall notify the contractor orally, with written confirmation, and request immediate initiation of corrective action of hazards identified. After receiving the notice, the contractor shall immediately take corrective action. If the contractor fails or refuses to promptly take corrective action, the CO may issue an order stopping all or part of the work until satisfactory corrective action has been taken (FAR 52.236).

3. Upon a repeat offense of the same or substantially similar hazard, the Construction Safety Officer or CO will inform OSHA or other authorities (i.e., federal, state, or local officials) of the instances where the contractor has been notified to take immediate action to correct serious or imminent dangers (FAR 36.513). The CSO, with assistance from the Construction Safety Subcommittee, is responsible for making the contractor and CO formally aware of hazards in need of correction. The CO is responsible for enforcement of the contract.

V. ATTACHMENTS:

A. Attachment A: OSHA Requirements and Safety and Health Regulations.

B. Attachment B: Daily Inspection Log of Interim Life Safety Measures.

C. Attachment C: Preconstruction Meeting Checklist.

D. Attachment D: Infection Control Risk Assessment.

E. Attachment E: Weekly Construction Area Inspection Form.

F. Attachment F: Daily Inspection Checklist.

VI. RESCISSION: Medical Center Memorandum EC-32, dated May 29, 2016.

VII. REFERENCES:

VHA Directive 7715 Safety and Health During Construction, dated April 6, 2017.

MCP SC-23 Interim Life Safety Measures, dated August 20, 2020.

https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=5380 https://dvagov.sharepoint.com/:b:/r/sites/VHABUTvamc/Policies/MCM1/MCP%20PDF%20Files/SC%20-%20Safety_Security/SC-23%20Interim%20Life%20Safety%20Measures.pdf?csf=1&web=1&e=8zt2S6

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SHARON COYLE, MSN, RN, MBA

Director

(Automatic Review Date: March 29, 2027)

ATTACHMENT A

OSHA REQUIREMENTS AND SAFETY AND HEALTH REGULATIONS

(To be incorporated into the project's contract)

I. GENERAL OSHA REQUIREMENTS:

A. Contractors are required to comply with the Occupational Safety and Health Act of 1970. This includes the safety and health standard found in Code of Federal Regulations (CFR) 1910 and 1926. Copies of those standards can be obtained from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C., 20420.

B. In addition, contractors are required to comply with other applicable facility policies and safety regulations. These policies and regulations will be presented to the contractor at the preconstruction meeting. Each of the contractor’s employees are required to read the statement of policies and regulations and sign an acknowledgment that such policies and regulations are understood. Signed acknowledgment is returned to the Facility Engineer.

C. Contractors involved with the removal, alteration or disturbance of asbestos-type insulation or materials or lead paint will be required to comply strictly with the regulations found in CFR 1910.1001 and the appropriate Environmental Protection Agency (EPA) lead regulations regarding disposal of asbestos or lead paint. Assistance in identifying asbestos or lead will be requested from the facility’s Industrial Hygienist and the Project Engineer.

D. Contractors entering locations of asbestos contamination or lead paint residue (i.e., pipe, basements, walls, windows) are responsible for providing respiratory protection to their employees and ensuring respirators are worn in accordance with the CFR 1910.1001(g). Asbestos or lead paint contaminated areas are defined on project drawings. The minimum equipment requirements are a half-mask air-purifying respirator equipped with high efficiency filters and disposable coveralls, or as determined by air monitoring results.

E. Contractors must submit a complete list of chemicals that will be used and Material Safety Data Sheets (MSDS) for all hazardous materials at least 2 weeks prior to bringing any materials on-site as defined in OSHA 1910.1200(d), Hazard Determination. The Contracting Officer will have final approval of all materials brought on site.

F. Contractors are held solely responsible for the safety and health of their employees. The contractor is also responsible for protecting the health and safety of the VA Community (Veterans, staff, and visitors) from the unwanted effects of construction.

VA staff will monitor the contractor's performance in complying with all safety and health aspects of the project. Severe or constant violations may result in an immediate work stoppage or request for an evaluation by a Compliance Officer from OSHA.

Attachment A

7. During all phases of demolition, construction, and alteration, contractors are required to understand and strictly follow National Fire Protection Association (NFPA) 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. The facility’s Safety Officer or Industrial Hygienist will closely monitor the work area for compliance. Appropriate action will be taken for non-compliance.

II. SPECIFIC FIRE AND SAFETY POLICIES, PROCEDURES, AND REGULATIONS:

A. Introduction:

1. The safety and fire protection of Veterans, employees, members of the public, and government is one of continuous concern to this facility.

2. Contractors, their supervisors, and employees are required to comply with facility’s policies to ensure the occupational safety and health of all. Failure to comply may result in work stoppage.

3. While working at this facility, contractors are responsible for the occupational safety and health of their employees. Contractors are required to comply with the applicable OSHA Standards found in 29 CFR 1910 for general industry and 29 CFR 1926 for construction. Failure to comply with these standards may result in work stoppage and a request to the Area Director of OSHA for a Compliance Officer to inspect your work site.

4. Contractors are to comply with the requirements found in NFPA 241, Building Construction, and Demolition Operation, and NFPA 51B, Fire Prevention in Use of Cutting and Welding Processes.

5. Questions regarding occupational safety and health issues can be addressed to the facility’s Safety Officer or Industrial Hygienist.

6. Smoking is not permitted in any interior areas of this facility, including all interior stairwells, tunnels, construction and/or service/maintenance sites. Note: This includes interior posted patient smoking areas, if applicable. Compliance with this policy is required.

7. Also see Section 01 00 00, General Requirements, Article No. 1.5, and Fire Safety Precautions, available online at: http://www.cfm.va.gov/TIL/spec.asp#01

B. Hazard Communications:

1. Contractors will comply with OSHA Standard 29 CFR 1926.59, Hazard Communication.

2. Contractors will submit copies of SDS covering all hazardous materials to which the Contractor and VA employees are exposed to the facility Safety Officer.

http://www.cfm.va.gov/TIL/spec.asp#01

3. Contractors will inform the Safety Officer of the hazards to which VA personnel and Veterans may be exposed.

4. Contractors will have a written Hazard Communication Program that details how the Contractor will comply with 29 CFR 1926.59 available at the construction site.

C. Fires:

1. All fires must be reported. In the event of a fire in your work area, use the nearest pull box station and notify facility staff in the immediate area. Emergency notification can also be accomplished by dialing extension 255.

2. The exact location of where the call originates must be provided, and the exact nature of the emergency must be explained thoroughly. If a contractor experiences a fire that was rapidly extinguished by staff, the Safety Manager must still be notified within an hour of the event so that an investigation of the fire can be accomplished.

D. Fire Alarms, Smoke Detection, and Sprinkler System: If the nature of your work requires the deactivation of the fire alarm, smoke detection, or sprinkler system, you must notify the Safety Manager. Notification must be made well in advance so that ample time can be allowed to deactivate the system and provide alternative measures for fire protection. Under no circumstance is a contractor allowed to deactivate any of the fire protection systems in this facility.

E. Smoke Detectors: False alarms will not be tolerated. Contractor familiarity with the location of the smoke detectors in the work area is required. When performing cutting, burning, welding, or any other operations that may cause smoke or dust, steps to temporarily cover smoke detectors in order to prevent false alarms must be taken. Failure to take the appropriate action will result in the Contracting Officer assessing actual costs for government response for each false alarm that is preventable. Prior to covering the smoke detectors, the contractor will notify the Safety Manager, who will also be notified when the covers are removed.

F. Hot Work Permit:

1. Hot work is defined as operations including, but not limited to, cutting, welding, thermal welding, brazing, soldering, grinding, thermal spraying, thawing pipes, or any similar situation. If such work is required, whenever possible, the contractor must notify the project manager no less than one day in advance of such work. The project manager will inspect the work area and issue a Hot Work Permit, authorizing the performance of such work.

2. All hot work will be performed in compliance with the facility’s policy regarding Hot Work Permits and NFPA 241, Safeguarding Construction, Alternation, and Demolition Operations; and NFPA 51B, Fire Prevention in Use of Cutting and Welding Processes;

and applicable OSHA Standards. A Hot Work Permit will only be issued to individuals familiar with these regulations.

3. A Hot Work Permit will be issued only for the period necessary to perform such work not to exceed one normal work shift. A Hot Work Permit will apply only to the location identified on the permit. If additional areas involve hot work, then additional permits must be requested.

4. Contractors will not be allowed to perform hot work processes without the appropriate permit.

5. Any work involving the facility’s fire protection system will require the fire department to be notified. Under no circumstance will the contractor or employee attempt to alter or tamper with the existing fire protection system.

6. The contractor’s site supervisor will be notified within 30 minutes of the completion of all hot work to perform an inspection of the area to confirm that sparks or drops of hot metal are not present.

G. Temporary Enclosures: Only non-combustible materials will be used to construct temporary enclosures or barriers at this facility. Plastic materials and fabrics used to construct dust barriers must conform to NFPA 701, Standard Methods of Fire Tests for Flame-Resistant Textiles and Films.

H. Flammable Liquids: All flammable liquids will be kept in approved safety containers. Only the amount necessary for your immediate work will be allowed in the building. Flammable liquids must be removed from the building at the end of each day.

I. Compressed Gas Cylinders: Compressed gas shall be secured in an upright position at all times. A suitable cylinder cart will be used to transport compressed gas cylinders. Only compressed gas cylinders necessary for immediate work will be allowed in occupied buildings. All other compressed gas cylinders will be stored outside of buildings in a designated area. Contractors will comply with applicable compressed gas cylinders standards found in 29 CFR 1910 and 1926 (OSHA).

J. Internal Combustion Engine-Powered Equipment: Equipment powered by an internal combustion engine (such as saws, compressors, generators, etc.) will not be used in an occupied building. Special consideration may be given for unoccupied buildings only if the OSHA and NFPA requirements have been met.

K. Powder-Actuated Tool: The operator of powder-actuated tools must be trained and certified to use them. Powder-actuated tools will be kept secured at all times. When not in use, the tools will be locked up. When in use, the operator will have the tool under his immediate control.

L. Tools:

1. Under no circumstances will equipment, tools, and other items of work to be left unattended for any reason. All tools, equipment, and items of work must be under the immediate control of your employee.

2. If for some reason a work area must be left unattended, then tools and other equipment must be placed in an appropriate box or container and locked. All toolboxes, containers, or any other devices used for the storage of tools and equipment will be provided with a latch and padlock and will be kept locked at all times.

3. All doors to work areas will be closed and locked when rooms are left unattended, and signs of a directive and restrictive nature posted for safety purposes.

Failure to comply with this policy will be considered a violation of VA Regulations 1.218(b) and subject to a $50.00 fine. Subsequent similar violations may result in both imposition of such a fine as well as the Contracting Officer taking action under the contract’s Accident Prevention Clause, according to Federal Acquisition Regulation (FAR) 52.236-13, to suspend all contract work until violations are satisfactorily resolved. Alternatively, under FAR 52.236-5, Material and Workmanship Clause, the Contracting Officer may remove any personnel deemed to be careless to the point of jeopardizing the welfare of facility Veterans or staff from the worksite.

4. Missing tools or equipment must be reported to the VA Police Department.

5. Tools and equipment found unattended will be confiscated and removed from the work area.

M. Ladders: Ladders must not be left unattended in an upright position. Ladders must be attended at all times or taken down and chained securely to a stationary object.

N. Scaffolds: All scaffolds will be attended at all times. When not in use, an effective barricade (fence) will be erected around the scaffold to prevent use by unauthorized personnel (reference OSHA 1926, Subpart L).

O. Excavations: The contractor shall comply with OSHA 1926, Subpart P. An OSHA Competent Person must be on site during excavation. The contractor shall coordinate with the project engineer and utility companies prior to excavation to identify underground utilities, tanks, etc. Excavations will be provided with a barricade suitable to prevent entry by unauthorized persons.

P. Storage: Arrangements for the storage of building materials must be made prior to construction projects with the project engineer. Storage will not be allowed to accumulate in the facility’s building.

Q. Trash and Debris: Trash and debris must be removed from the work area on a daily basis. Trash and debris will not be allowed to accumulate inside or outside of the buildings. Contractors are responsible for making arrangements for removal of trash from the facility.

R. Protection of Floors: It may be necessary at times to take steps to protect floors from dirt, debris, paint, etc. A tarp or other protective covering may be used. However, a certain amount of floor space must be maintained for the safe passage of pedestrian traffic. Common sense must be used in this matter.

S. Signs: Signs must be placed at the entrance to work areas warning people of construction work. Signs must be suitable for the condition of the work. Small pieces of paper with printing or writing are not acceptable. The facility Safety Manager or Project Manager can be consulted in this matter.

T. Accidents and Injuries: Contractors must report all accidents and injuries involving their employees.

U. Infection Control:

1. Contractors must control the generation of dust and the contamination of patient care surfaces, supplies, and equipment. During demolition phases of the construction:

a. The construction area shall be under negative pressure, ensuring there is an appreciable flow of clean air from the VA-occupied portion of the facility into the construction area. The airflow shall be sufficiently strong enough to draw in the plastic door flaps commonly located at the construction entrance or at the specific site within the construction area.

b. Construction debris being transported through the VA-occupied portion of the facility shall be covered and/or whetted.

c. Construction employees will remove dust-laden clothing before entering the VA occupied portion of the facility.

d. Carpet/sticky mats will be placed at all construction entrances and be satisfactorily maintained to minimize the tracking of dust into the VA-occupied portion of the facility.

e. Dry sweeping of dust and debris is not to be performed.

2. Control measures B - E above must be practiced during the construction phase.

V. Confined Space Entry:

1. Contractors will be informed that the workplace contains permit-required confined space, and that permit-space entry is allowed only through compliance with a permit-space program meeting the requirements of 29 CFR 1910.146 and 1926.21(b)(6).

2. Contractor will be apprised of the elements including the hazards identified and the facility’s (last employer) experience with the space that makes the space in question a permit space.

3. Contractors will be apprised of any precautions or procedures that the facility has implemented for the protection of employees in or near permit space where contractor personnel will be working.

4. The facility and contractor will coordinate entry operations when both facility personnel and contractor personnel will be working in or near permit spaces as required by 29 CFR 1910.146(d) (ii) and 1926.21(b) (6).

5. Contractors will obtain any available information regarding permit space hazards and entry operation from the facility.

6. At the conclusion of the entry operations, the facility and contractor will discuss any hazards confronted or created in permit spaces.

7. Contractors are responsible for complying with 29 CFR 1910.246(d) through

(g) and 1926.21(b)(6). The facility, upon request, will provide rescue and emergency services required by 29 CFR 1910.246(k) and 1926.21(b)(6).

W. Contractor Parking and Material Delivery: Contractor parking and the delivery of building materials tools, etc., must be pre-arranged with the Project Manager.

ATTACHMENT B

DAILY INSPECTION LOG OF INTERIM LIFE SAFETY MEASURES

Project Title:________________ Project #:__________Project Coord.:______________

Instructions: One log sheet may be used for one full week with dates entered at top of columns. If the area inspected is in compliance with life safety measures place a “Y” for yes in the box next to the item. If the area is not in compliance with life safety measures place an “N” for no in the box next to the item. If you mark any item with an “N” you must provide comments and actions to abate the situation.

Dates

Areas Inspected Comments/Actions

Means of egress is clear in construction areas.

Access for the fire department and emergency services is clear. Buildings are accessible to fire department apparatus and personnel. Roadways are maintained within 20 feet of all buildings.

Fire detection and sprinkler systems are functional.

Construction partitions are maintained.

Good housekeeping practices are used in the construction area. Flammable materials and combustible fire load are being kept to a minimum.

Buildings, grounds and equipment are being maintained in a safe manner (pay special attention to excavations, construction areas, and construction storage or field offices).

Smoking regulations are being followed.

Area found to be secured.

Signature of COR/Project Coordinator Date

ATTACHMENT C

PRE-CONSTRUCTION CHECKLIST

Date of Meeting: _______ Work Start Date: _______ Projected Completion Date: _______

Contractor: _________________Contractor’s Site Superintendent: __________________

VA Engineer/COR: _______________ Contractor’s Competent Person: ______________

Scope of Work: __________________________________________________________

Initials:

_____ Contractor is responsible for all aspects of injury prevention as well as OSHA, NFPA, and Joint Commission compliance within the scope and impact of their project(s). Failure to follow established safety regulations and safe work practices could lead to work stoppage or dismissal.

_____ Evidence of OSHA 10-hour completion has been presented for all contracted/ subcontracted employees. 30-hour completion must be presented for project superintendent.

_____ Injuries, fires, and major incidents must be immediately reported to the Project

Engineer/ COR.

_____ Written permits must be approved for the following: Confined space entry, excavations deeper than 15”, hot work, live electrical work, and creating any hole or “penetration” in floors, walls, or ceilings.

_____ Any confined space entry requires coordination with the Project Engineer/COR, VA Fire Department and a minimum of 24 hours advance notice. Contractor’s competent person must be designated, rescue equipment provided, and the Fire Department must be contacted before the first entry.

_____ Contractor is responsible for communicating and enforcing requirements with all employees and subcontractors. Contractor will designate a single person to facilitate communication with COR.

OTHER DISCUSSION ITEMS:

I. CONTRACTING OFFICER:

A. General Requirements

Attachment C

1. Patient Security: TMS website / - all workers working inside must complete the online training and submit their certificates to the Contracting Officer Representative (COR) and Contracting Officer CO.

2. Identification (ID) Badges: All personnel on the job are required to obtain from the security office, and wear, at all times, ID badges.

3. Parking Job Trailer: Contractor can only park in the areas designated by the Facility Police. Vehicle passes will be given for designated areas only. Payable parking tickets will be issued to anyone who violates this policy. Job trailer can only be placed upon approval by the Contracting Officer’s Representative (COR).

4. Keys: The COR will issue keys to the contractor who will assume full responsibility for all keys issued to them, and will be liable for any costs incurred for any keys or key systems that are lost or stolen. Duplication of keys is prohibited.

B. Submission of Documents:

1. Schedule of Cost: Must be submitted prior to any invoice submission, no later than 30 days from notice to proceed.

2. Progress Chart: No later than 30 days from notice to proceed.

3. Signed copy of acceptance letter, notice to proceed, and COR delegation memorandum.

4. Insurance Certificates: Prior to starting any work, including subs.

5. Standard Form 1413: Within 15 days of contract award.

C. Survey: Prior to starting any work, the contractor is required by the General Conditions of the contract to make a thorough survey with the Project Manager of existing conditions, sign, and furnish this report to the Contracting Officer Representative and cc the Contracting Officer. Also, a re-survey must be conducted and submitted 30 days prior to a partial or final inspection.

D. Contractor must attend bi-weekly or weekly scheduled job progress meetings at the VA or via teleconference.

E. Post wage rates and posters on the job. If any apprentices are going to be on the job, an approved apprenticeship program must be submitted prior to that individual working on the project.

F. Adhere to all labor standards provisions (i.e., Davis-Bacon Act, Contract Work Hours Standards Act, Overtime compensation, Copeland Act, etc.). Also, adhere to the Buy American Act, Equal Opportunity clause, and submit all Affirmative Action Compliance file://///R04.med.va.gov

Reports. Contractor must protect all existing structures, equipment, and vegetation.

G. Payrolls must be submitted weekly to the Contracting Officer Representative (COR) and Daily logs must be submitted daily to the COR. Payments will not be processed until all payrolls and daily logs are submitted for that payment period. Please ensure the person completing the payrolls also has copies of the daily logs. This prevents any discrepancies between the daily logs and payrolls. All payments will be returned if the daily logs and payrolls do not match, or which are not current to the payment period.

H. Contractor is required to have supervision on the job…