Atch 15 Construction Safety Guidebook.pdf

Research Laboratory Safety Guidebook Volume 1:

Managing Chemical Safety

Construction Safety Guidebook

Published by

VHA Healthcare Environment and Facilities Programs (HEFP) http://vaww.hefp.va.gov/ i

Table of Contents

PREFACE

Disclaimers ................................................................................................................ xii

Executive Summary ................................................................................................. xiv

Acknowledgements ................................................................................................... xv

Update Listing .......................................................................................................... xvii

Acronyms and Abbreviations ............................................................................... xviii

1 Program Management

1.1. Introduction

1.2. Construction Safety Program

1.2.1. VHA Policy

1.2.2. Plan-Do-Check-Act

1.3. Regulations and Standards

1.3.1. FAR

1.3.2. FAR

1.3.3. VAAR

1.3.4. VHA Procurement Manual

1.3.5. OSHA

1.3.6. VA Medical Center Memorandum (MCM)

1.4. Construction Safety Responsibilities

1.4.1. Veterans Integrated Service Network (VISN) Director

1.4.2. VA Facility Director

1.4.3. Multi-Disciplinary Team (Construction Safety Committee)

1.4.4. Chief Engineer and Resident Engineer (RE)

1.4.5. Facility Safety Program Manager

1.4.6. CO and COR or Project Engineer

1.4.7. Construction Safety Officer (CSO)

1.4.8. GEMS Coordinator

1.4.9. Emergency Planning Coordinator

1.4.10. Construction Lead Person

1.4.11. Police and Security

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1.4.12. Infection Control Professional (ICP)

1.4.13. General Contractor

1.4.14. Subcontractor

1.4.15. Intervention Authority and Compliance

1.5. Pre-Award Period and Preconstruction

1.5.1. Responsible Prospective Contractors

1.5.2. ILSM Assessment

1.5.3. Infection Prevention and Control

1.5.4. PICRA

1.5.5. References

1.6. Post-Award and Construction Period

1.6.1. Surveillance

1.6.2. Written Site-Specific Plan

1.7. Post-Construction Period

1.8. Program Evaluation

1.9. Enclosures

2 Hazard Communication

2.1. Key Requirements

2.2. Discussion

2.2.1. Definitions

2.2.2. Certifications

2.2.3. Chemical Classifications

2.2.4. Contractor Written Hazard Communication Program

2.2.5. Employer Written Hazard Communication Program

2.2.6. Labels and Warnings

2.2.7. SDS Documents

2.2.8. Minimum Requirements of SDS Documents

2.2.9. Location and Copies of SDS

2.3. Education and Training

2.4. On-Site Review of Hazard Communication

2.5. References

2.6. Online Resources

2.7. Enclosure

3 Personal Protective Equipment

3.1. Key Requirements

iii

3.2. Discussion

3.2.1. General PPE

3.2.2. Occupational Foot Protection

3.2.3. Head Protection

3.2.4. Eye and Face Protection

3.2.5. Hearing Protection

3.2.6. Safety Belts, Lifelines and Lanyards

3.2.7. Respiratory Protection

3.2.7.a. Permissible Practice

3.2.7.b. Respiratory Protection Program

3.2.7.c. Selection of Respirators

3.2.7.d. Medical Evaluation of Employees

3.2.7.e. Medical Determination

3.2.7.f. Additional Medical Evaluations

3.2.7.g. Fit Testing Requirements

3.2.7.h. Use of Respirators

3.2.7.i. Facepiece Seal Protection

3.2.7.j. Continuing Respirator Effectiveness

3.2.7.k. Maintenance and Care of Respirators

3.2.7.l. Cleaning and Disinfection of Respirators

3.2.7.m. Storage of Respirators

3.2.7.n. Inspection of Respirators

3.2.7.o. Checklist for Respirator Inspection

3.2.7.p. Repairs to Respirators

3.2.7.q. Supplied Air Respirators

3.2.7.r. Identification of Filters, Cartridges and Canisters

3.2.7.s. Program Evaluation

3.2.7.t. Recordkeeping

3.3. Education and Training

3.3.1. Respirator Training and Information

3.4. Certifications

3.5. Formalized Written Program

3.6. References

3.7. Online Resources

3.8. Enclosures

iv

4 Asbestos

4.1. Key Requirements

4.2. Discussion

4.2.1. Definitions

4.2.2. Asbestos History

4.2.3. Initial Project Phase

4.2.4. Design Project Phase

4.2.5. Construction Project Phase

4.3. Training

4.4. Online Resources

4.5. Enclosure

5 Lead

5.1. Key Requirements

5.2. Discussion

5.2.1. Definitions

5.2.2. General

5.2.3. Environmental Lead Assessment

5.3. Education and Training

5.3.1. Certifications

5.3.2. Training

5.4. References

5.5. Online Resources

5.6. Enclosures

6 Silica

6.1. Key Requirements

6.2. Discussion

6.2.1. Definitions

6.2.2. General

6.3. Exposure Assessment

6.4. Controls

6.5. Other Provisions

6.6. Education and Training

6.7. References

6.8. Online Resources

7 Hexavalent Chromium v

7.1. Key Requirements

7.2. Discussion

7.2.1. Definitions

7.2.2. Health Effects

7.2.3. Exposure

7.2.4. Exposure Determination

7.2.5. Methods of Compliance

7.2.5.a. Engineering and Work Practice Controls

7.2.5.b. Respiratory Protection

7.2.5.c. Protective Work Clothing and Equipment

7.2.5.d. Hygiene Areas and Practices

7.2.5.e. Prohibited Activities

7.2.5.f. Medical Surveillance

7.3. Education and Training

7.4. References

7.5. Online Resources

7.6. Enclosures

8 Fire Protection/Prevention and Emergency Planning

8.1. Key Requirements

8.2. Discussion

8.2.1. Mandatory Program Elements

8.2.1.a. Fire Protection

8.2.1.b. Water Supply

8.2.1.c. Portable Fire Fighting Equipment

8.2.1.d. Fire Hose and Connections

8.2.1.e. Sprinkler Protection

8.2.1.f. Fire Alarm Devices

8.2.1.g. Ignition Hazards

8.2.1.h. Hazardous Locations

8.2.1.i. Open Yard Storage

8.2.1.j. Indoor Storage

8.2.1.k. Temporary Heaters

8.2.1.l. Weather Enclosures

8.3. Flammable and Combustible Liquids

8.3.1. Mandatory Program Elements

vi

8.4. Emergency Protection and Prevention

8.4.1. Employee Emergency Action Plans

8.4.2. Mandatory Program Elements

8.5. Education and Training

8.6. References

8.7. Online Resource

8.8. Enclosure

9 Welding and Cutting

9.1. Key Requirements

9.2. Discussion

9.2.1. Permit Authorizing Individual (PAI)

9.2.2. Hot Work Permit

9.2.3. Fire Watch

9.2.4. Gas Welding and Cutting

9.2.5. Arc Welding and Cutting

9.2.6. Welding and Cutting Precautions

9.2.7. Welding, Cutting and Heating in Way of Preservative Coatings

9.3. Education and Training

9.4. References

9.5. Online Resources

9.6. Enclosures

10 Electrical

10.1. Key Requirements

10.2. Discussion

10.2.1. General Requirements

10.2.2. Wiring Design and Protection

10.2.3. Wiring Methods, Components and Equipment for General Use

10.2.4. Specific Purpose Equipment and Installations

10.2.5. Safety Related Work Practices

10.2.6. Locking and Tagging of Circuits

10.2.7. Batteries and Battery Charging

10.3. Education and Training

10.4. References

10.5. Enclosure

11 Energy Isolation vii

11.1. Key Requirements

11.2. Discussion

11.2.1. Definitions

11.2.2. General

11.2.3. Control of Hazardous Energy

11.2.4. Forms of Hazardous Energy

11.2.5. Energy Isolation Procedures

11.2.6. Formalized Written Program Required

11.2.7. Hot Tapping

11.3. Education and Training

11.4. References

11.5. Online Resources

11.6. Enclosures

12 Confined Space Entry

12.1. Key Requirements

12.2. Discussion

12.2.1. Major OSHA Violations

12.2.2. Confined Space Identification

12.2.3. Confined Space Procedures

12.2.4. CSCP/Safety Supervisor Responsibilities

12.2.5. Confined Space Entry Written Program Elements

12.3. Education and Training

12.3.1. Rescue and Emergency Services

12.4. References

12.5. Enclosures

13 Excavation and Trenching

13.1. Key Requirements

13.2. Discussion

13.2.1. Definitions

13.2.2. Soil Testing

13.2.3. Soil Classification

13.2.4. General Protection Provisions

13.2.5. Employee Awareness Training

13.3. Formalized Written Program Required

13.4. Education and Training

viii

13.4.1. Certifications

13.5. References

13.6. Online Resource

13.7. Enclosures

14 Fall Protection

14.1. Key Requirements

14.2. Discussion

14.2.1. Definitions

14.2.2. Formalized Written Program Required

14.2.3. General

14.3. Education and Training

14.3.1. Certifications

14.4. Reference

14.5. Online Resources

14.6. Enclosure

15 Material Handling and Rigging

15.1. Key Requirements

15.2. Discussion

15.2.1. Material Storage

15.2.2. Rigging Equipment

15.2.3. Inspection Criteria

15.2.4. Alloy Steel Chains

15.2.5. Wire Ropes

15.2.5.a. Natural or Synthetic Fiber Rope

15.3. Education and Training

15.3.1. Certifications

15.4. References

15.5. Online Resources

15.6. Enclosures

16 Steel Erection

16.1. Key Requirements

16.2. Discussion

16.2.1. Definitions

16.2.2. Site Layout, Site-Specific Erection Plan and

Construction Sequence ix

16.2.3. Hoisting and Rigging

16.2.4. Structural Steel Assembly

16.2.5. Column Anchorage

16.2.6. Beams and Columns

16.2.7. Open Web Steel Joists

16.2.8. Systems-Engineered Metal Buildings

16.2.9. Falling Object Protection

16.2.10. Fall Protection

16.3. Education and Training

16.4. Reference

16.5. Online Resources

16.6. Enclosure

17 Scaffolds and Aerial Lifts

17.1. Key Requirements

17.2. Discussion

17.2.1. Definitions

17.2.2. Competent Person

17.2.3. General

17.3. Education and Training

17.4. Reference

17.5. Online Resources

17.6. Enclosures

18 Stairways and Ladders

18.1. Key Requirements

18.2. Discussion

18.2.1. Definitions

18.2.2. General

18.3. Training

18.4. References

18.5. Online Resources

18.6. Enclosures

19 Concrete and Masonry

19.1. Key Requirements

19.2. Discussion

19.2.1. Definitions

x

19.2.2. General

19.2.3. PPE and Sanitation Requirements

19.2.4. Requirements for Equipment and Tools

19.2.5. Requirements for Cast-In-Place Concrete

19.2.6. Requirements for Precast Concrete

19.2.7. Requirements for Lift-Slab Operations

19.2.8. Requirements for Masonry Construction

19.3. Education and Training

19.3.1. Certifications

19.4. References

19.5. Online Resources

19.6. Enclosures

20 Hand and Power Tools

20.1. Key Requirements

20.2. Discussion

20.2.1. General

20.2.2. Hand Tools

20.2.3. Power Tools

20.2.4. Abrasive Wheels and Tools

20.2.5. Woodworking Tools

20.2.6. Jacks: Lever and Ratchet, Screw and Hydraulic

20.2.7. Air Receivers

20.3. Education and Training

20.3.1. Certifications

20.4. Reference

20.5. Online Resources

20.6. Enclosure

21 Cranes and Load Handling Equipment

21.1. Key Requirements

21.2. Discussion

21.2.1. Definitions

21.2.2. Types of Cranes

21.2.3. Standard Lift Plan (SLP)

21.2.4. Inspection Criteria for Load Handling Equipment

21.2.5. Safety Devices and Operational Aids

xi

21.2.6. Testing

21.2.7. Operation

21.2.8. Critical Lifts

21.2.9. Environmental Considerations

21.3. Education and Training

21.3.1. Crane Operator Requirements − General

21.3.2. Crane Operator Certification, Qualification and Designation

21.3.3. Signal Person Qualifications

21.4. References

21.5. Online Resources

21.6. Enclosures

Enclosures xii

Disclaimers Endorsement

Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the U.S. Government. The views and opinions of authors expressed herein do not necessarily state or reflect those of the U.S. Government and shall not be used for advertising or product endorsement purposes.

Hyperlinks

The appearance of external hyperlinks does not constitute endorsement by the Department of Veterans Affairs (VA) of the linked websites or the information, products, or services contained therein. For other than authorized VA activities, the Department does not exercise any editorial control over the information you may find at these locations. All links are provided with the intent of meeting the mission of the Department and the VA website. Please let us know about existing external links that you believe are inappropriate and about specific additional external links that you believe should be included.

Liability

With respect to documents available from this server, neither the U.S.

Government nor any of its employees makes any warranty, expressed or implied, including the warranties of merchantability and fitness for a particular purpose, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately-owned rights.

Reference from this website or from any of the information services sponsored by VA to any non-governmental entity, product, service, or information does not constitute an endorsement or recommendation by VA or any of its employees. We are not responsible for the content of any “off-site” websites referenced from the Veterans Health Administration (VHA) Healthcare Environment Facilities Programs (HEFP) website, electronic media, or printed media.

Guidance

VHA HEFP guidebooks are “BEST PRACTICE” resources designed to assist health care facilities implement and enhance programs and more effectively comply with current VA/VHA policy and external regulatory standards. HEFP guidebooks are NOT OFFICIAL POLICY. In accordance with VHA Directive 6330(1), Controlled National Policy/Directives Management System, official policy documents include: (1) Directives, which carry the authority to mandate Department- or Administration-wide policies and (2) Handbooks, which carry the xiii authority to mandate procedures or operational requirements implementing policies contained in directives.

xiv

Executive Summary Safety is a philosophy and a practice that identifies and eliminates jobsite hazards throughout the lifecycle of a project and discourages work practices and equipment that place individuals at risk of injury. The Office of Occupational Safety, Health and GEMS Programs (10NA8) in the

Veterans Health Administration (VHA) Headquarters recognized the need to assist Department of Veterans Affairs (VA) facilities in complying with safety standards and ensuring a safe environment for patients, visitors and staff.

As a result, VHA Directive 2004-012, Safety and Health During Construction Activities, and its subsequent revisions, VHA Directive 2011-036, Safety and Health During Construction (2011), and VHA Directive 7715, Safety and Health During Construction (2017) established policy for consistent construction safety programs across VHA. To support the VHA Directive, the Healthcare Environment Facilities Programs (HEFP) established a standing multi-disciplinary task group to create a functional guidebook that would be revised as needed to reflect the latest guidance for safe construction activities at VHA facilities.

The goal of this guidebook is to provide guidance for active participation in the facility Construction Safety Program. It provides safety training guidelines and will assist managers in identifying risks/hazards and establishing a process for their control, elimination and prevention. This guidebook is designed not only for program officials (e.g., Safety Officer, Chief Engineer, etc.), but is also intended for use by all managers throughout the facility.

Questions regarding the use and application of this guidebook may be addressed to Mr. Richard Watson, HEFP Construction Safety Product and Service Manager, at 937-268-6511, ext. 2069, or by email at Richard.Watson@va.gov.

xv

Acknowledgements This guidebook was possible because of the devoted attention of the personnel and management of the VHA Center for Engineering & Occupational Safety and Health (CEOSH), St. Louis, Missouri.

A special thank you is extended to the Construction Safety Professional Advisory Group (PAG) who developed this guidebook, and to management at their respective facilities for their support.

David Birk, PE, CSP, Construction Safety Engineer, VAMC, West Haven, CT

Claudia Boutot, Construction Safety Engineer, VAMC, Bay Pines, FL

Che Buval, Safety and Occupational Health Specialist, VAMC, Temple, TX

Jerry Fox, BS, Environmental Safety Manager, VAMC, Danville, IL

*Jennifer Hamner, CHSP, MSPH, Safety Manager, VAMC, Biloxi, MS

Michael Henrickson, MPH, CHMM, CFI, Occupational Safety and Health Manager, VISN 7, Columbia, SC

Richard Hofman, CIH, CSP, CPEA, Senior Industrial Hygienist, VHACO, Washington, DC

John Houvener, CHCM, Safety and Occupational Health Program Manager, VHACO, Washington, DC

Sean Kaminski, Contracting Officer, PCAC, Cleveland, OH

Gary Krupa, PE, Senior Electrical Engineer, VAMC, Omaha, NE

Brian Marcyjanik, CSP, CHMM, General Safety Program Manager, VHACO, Washington, DC

David McClintock, Safety Specialist, VAMC, Danville, IL

Mike Minicky, CSP, General Safety Product and Service Manager, HEFP, St.

Louis, MO

Darlene Powell, CHSP, HEM, Chief, Safety and Emergency Management, VAMC, Bay Pines, FL

Michael Reed, BSEE, CHFM, Healthcare Engineering Product and Service Manager, HEFP, St. Louis, MO

George Stevens, PE, MPH, Chief, Safety and Emergency Management, VAMC, Phoenix, AZ

Sheila Taylor, BS, Safety Manager, VAMC, Saginaw, MI xvi

*Richard Watson, MPH, CSP, Construction Safety Product and Service Manager, HEFP, Dayton, OH

Carl Wise, Maintenance Mechanic Leader, VAMC, Danville, IL

*Chairpersons

HEFP Publishing Staff:

Tina Beckner, Lead Technical Information Specialist, St. Louis, MO

Lesley Luscri, Technical Information Specialist, HEFP, St. Louis, MO

Melody Watts, Technical Information Specialist, HEFP, St. Louis, MO

Connie Young, Chief, Publishing Services, HEFP, St. Louis, MO xvii

Update Listing The following listing identifies online updates for this guidebook. It is designed to assist the reader in verifying the most current information available.

Table 1: Update Listing

Update Number Date Updated Remarks Chapter xviii

Acronyms and Abbreviations Acronym/ Abbreviation

Definition μg Micrograms μg/m3 Micrograms per Cubic Meter

A2B Anti-Two Blocking Device

AC Alternate Current

ACD Allergic Contact Dermatitis

ACGIH American Conference of Governmental Industrial Hygienists

ACI American Concrete Institute

ACM Asbestos Containing Materials

AE Architect and Engineering

AHA Activity Hazard Analysis

AHERA Asbestos Hazard Emergency Response Act

AIA American Institute of Architects

AIIR Airborne Infection Isolation Room

ANSI American National Standards Institute

API American Petroleum Institute

APIC Association for Professionals in Infection Control and Epidemiology

APP Accident Prevention Plan

ASHARA Asbestos School Hazard Abatement Reauthorization Act

ASHRAE American Society of Heating, Refrigerating and Air Conditioning Engineers

ASME American Society of Mechanical Engineers

AWE Annual Workplace Evaluation

BLL Blood Lead Level xix

BLS Bureau of Labor Statistics

CAI Capital Asset Inventory

CDC Center for Disease Control

CDZ Controlled Decking Zone

CEOSH Center for Engineering & Occupational Safety and Health

CERCLA Comprehensive Environmental Responsibility, Compensation and Liability Act

CFM Office of Construction & Facilities Management

CFR Code of Federal Regulations

CIH® Certified Industrial Hygienist cm Centimeter

CO Contracting Officer

COR Contracting Officer’s Representative

COTR Contracting Officer’s Technical Representative

CP Competent Person

CPL Compliance

CPR Cardiopulmonary Resuscitation

CPSC Consumer Product Safety Commission

CR(VI) Hexavalent Chromium

CS Construction Safety

CSE Confined Space Entry

CSCP Confined Space Competent Person

CSI Clinical-Specific Initiatives

CSO Construction Safety Officer

DART Days Away, Restricted, Transferred dBA Decibels xx

DC Direct Current

DHHS Department of Health and Human Services

D.O. Doctor of Osteopathy

DOL Department of Labor

DOT Department of Transportation

EMR Experience Modification Rate

EPA Environmental Protection Agency

E-SAFE Environmental Safety Automated Facility Evaluation

ESCBA Escape Self-Contained Breathing Apparatus f/cc Fibers per Cubic Centimeter

FAA Federal Aviation Administration

FAR Federal Acquisitions Regulations

FDA Food and Drug Administration

FGI Facilities Guidelines Institute

ft. Foot/Feet g Gram

GEMS Green Environmental Management Systems

GFCI Ground Fault Circuit Interrupters

GHS Globally-Harmonized System of Classification and Labeling of Chemicals

GPM Gallons Per Minute

H Horizontal

HAI Healthcare Associated Infections

HCP Hazard Communication Program

HEPA

HEFP

High Efficiency Particulate Air

Healthcare Environment Facilities Programs

HVAC Heating, Ventilation and Air Conditioning xxi

HUD Housing and Urban Development

IARC International Agency for Research on Cancer

ICP Infection Control Practitioner

ICRA Infection Control Risk Assessment

ICU Intensive Care Unit

ID Identification

IDLH Immediately Dangerous to Life and Health

IH Industrial Hygienist

ILSM Interim Life Safety Measures

in. Inch

ISO International Standards Organization kPa Kilopascal kv Kilovolt

lb. Pound

LBP Lead Based Paint

LDR Land Disposal Restrictions

LFL Lower Flammable Limit

LHE Load Handling Equipment

LMI Load Moment Indicator

LOI Letter of Interpretation

LOTO Lockout/Tagout

LP Liquefied Petroleum

LWDIR Loss Work Day Incident Rate m Meter m3 Cubic Meter

M&O Maintenance and Operations

MAP Model Accreditation Plan xxii

MCM Medical Center Memorandum

M.D. Doctor of Medicine mg Milligram

MLR Multiple Lift Rigging

MMAD Mass Median Aerodynamic Diameter mppcf Millions of Particles per Cubic Foot

NAICS North American Industrial Classification System

NCCCO National Commission for the Certification of Crane Operators

NEC National Electric Code

NESHAP National Emission Standards for Hazardous Air Pollutants

NFPA National Fire Protection Association

NIOSH National Institute for Occupational Safety and Health

NOB Non-Friable Organically Bound

NPRCS Non-Permit-Required Confined Spaces

NRM Non-Recurring Maintenance

NRR Noise Reduction Rating

NTP National Toxicology Program

OD Optical Density

O&M Operations and Maintenance

OSH Occupational Safety and Health

OSHA Occupational Safety and Health Administration

OTI OSHA Training Institute

PACM Presumed Asbestos Containing Material

PACU Post-Anesthesia Care Unit

PAI Permit Authorizing Individual xxiii

PAPR Powered Air-Purifying Respirator

PCB polychlorinated biphenyl

PCM Phase Contrast Microscopy

PDF Personal Decontamination Facility

PEL Permissible Exposure Limit

PFAS Personal Fall Arrest System

PG Program Guide

PHSC Project Health and Safety Coordinator

PICRA Preconstruction/Infection Control Risk Assessment

PLHCP Professionally Licensed Health Care Professional

PLM Polarized Light Microscopy

PM Procurement Manual

PM&R Physical Medicine and Rehabilitation

PNOR Particulates Not Otherwise Regulated ppb Parts per Billion

PPE Personal Protective Equipment

PPM Parts Per Million

PRCS Permit Required Confined Space psf. Per Square Foot psi Pound Per Square Inch

Q&A Questions and Answers

QLFTP Qualitative Fit Testing Procedures

QNFTP Quantitative Fit Testing Procedures

QP Qualified Person

QR Qualified Rigger

RACM Regulated Asbestos-Containing Material

RCRA Resource Conservation and Recovery Act xxiv

RE Resident Engineer

REL Recommended Exposure Level

ROPS Rollover Protective Structures

RPE Registered Professional Engineer

RPM Revolutions Per Minute

RQ Reportable Quantity

RRP Renovation, Repair and Painting Rule

S Service

SAFE Safety Automated Facility Evaluation

SAR Supplied Air Respirator

SCBA Self-Contained Breathing Apparatus

SCIP Strategic Capital Investment Planning

SEG Similar Exposure Group

SI International System of Units

SiO2 Crystalline Silica

SIC Standard Industrial Classification

SJ Service Junior

SJO Service Junior with Oil Resistant Jacket

SJT Service Junior Thermoplastic

SJTO Service Junior Thermoplastic with Oil Resistant Jacket

SLP Standard Lift Plan

SO Service Oil Resistant Jacket

SOP Standard Operating Procedure

SOW Statement of Work

SPD Supply, Processing and Distribution

ST Service Thermoplastic

STO Service Thermoplastic with Oil Resistant Jacket xxv

SWL Safe Working Load

TB Tuberculosis

TC Toxicity Characteristic

TCLP Toxicity Characteristic Leaching Procedure

TEM Transmission Electron Microscopy

TIL Technical Information Library

TSI Thermal Systems Insulation tsf Tons per square foot

TWA Time-Weighted Average

UL Underwriters Laboratories Incorporated

U.S. United States

USC United States Code

USDL United States Department of Labor

V Vertical

VA Veterans Affairs

VAAR VA Acquisition Regulation

VACO VA Central Office

VAI Vermiculite Attic Insulation

VAMC VA Medical Center

VAT Vinyl Asbestos Floor Tiles

VHA Veterans Health Administration

VISN Veterans Integrated Service Network

W/EDF Waste/Equipment Decontamination Facility

WLL Working Load Limit

XRF X-ray Fluorescence Technology

ZPP Zinc-Protoporphyrin xxvi

Chapter 1 Program Management

1 Program Management

1.1. Introduction

Construction is a high hazard occupation. Over 11 million construction workers build and maintain roads, houses, workplaces and physical infrastructure. This work includes many inherently hazardous tasks and conditions such as work at height, excavations, noise, dust, power tools and equipment, confined spaces and electricity. Construction work includes about 8 percent of United States (U.S.)

workers, but accounts for 22 percent of the fatalities − the largest number of fatalities reported for any of the industry sectors according to the National Institute for Occupational Safety and Health (NIOSH).

The implementation of Construction Safety Programs is expected to reduce the potential for injuries and illnesses to Veterans Affairs (VA) patients, employees and visitors from unsafe construction activities conducted by contractors as well as VA employees, including operations and maintenance crews, permanent construction crews and temporary purchase and hire staff. Construction Safety Programs will also reduce the potential for VA liability, lost time, added costs and other intangibles that often result from construction accidents, life safety deficiencies or infection control failures.

Historically, Infection Control Practitioners (ICPs) have had minimal involvement in construction, demolition and renovation activities in medical centers. They have always been involved in preventing infections such as urinary tract infections, pneumonias, surgical site infections and bacteremias (bloodstream infections) in hospitalized patients. It was not until the late 1990’s that ICPs and others began to see the importance of their early and continuous involvement in construction activities.

Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulations, The Joint Commission requirements and Facilities Guidelines Institute (FGI), formerly the American Institute of Architects (AIA), guidance identify opportunities for maintaining the health and safety of VA patients, staff, visitors and contractors. OSHA and EPA regulations, in addition to requirements with VA Directive 7700, Occupational Safety and Health; Veterans Health Administration (VHA) Directive 7701, Occupational Safety and Health (OSH), occupational safety and health issues for employees and contractors working on VA/VHA property are addressed. The Joint Commission requirements and FGI guidance address patient safety during construction activities.

1.2. Construction Safety Program

Construction work is inherently dangerous and can result in serious injury, illness and even death. In order to protect patients, staff, volunteers, visitors and contractors from safety and health hazards associated with construction activities, strategies need to be established to control the hazards inherent in conducting construction or renovation activities. 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 Multi-Disciplinary Team to oversee and enforce the application of the Construction Safety Program.

The intent of the Construction Safety Program is to reduce the potential for injury and illness resulting from unsafe construction activities conducted by contractors and VA employees. In the past, VHA has experienced several injuries, illnesses and even fatalities of patients, staff and contractors due to unsafe construction activities. According to a U.S. Department of Labor (US DOL) study (National Census of Fatal Occupational Injuries in 2015: USDL-16-2304), fatal injuries among construction and extraction occupations rose by 2 percent to 924 cases in 2015; the highest since 2008. Several construction occupations recorded their highest fatality total in years, including construction laborers (highest since 2008);

carpenters (2009); electricians (2009); and plumbers, pipefitters and steamfitters (2003). The current Bureau of Labor Statistics (BLS) data is available at http://www.bls.gov/news.release/cfoi.nr0.htm.

OSHA conducts half of all enforcement inspections in the construction industry and has established national emphasis programs in general construction, excavation and trenching and falls from elevation. Moreover, OSHA regional emphasis programs may include cranes, confined spaces, electrical safety and scaffolding. OSHA Title 29 Code of Federal Regulations (CFR) Part 1960 (29 CFR 1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters) requires each agency to develop, implement and evaluate an Occupational Safety and Health (OSH) Program to include construction safety. Federal Acquisition Regulations (FAR) require that contracts have provisions for assurance that construction contractors implement Construction Safety and Health Programs and require Contracting Officers (COs) to enforce compliance of Federal safety and health standards. The Joint Commission requires that hospitals have a written plan for managing the safety of patients, staff, volunteers and visitors during construction activities.

The purpose of the Construction Safety Guidebook is to provide users with strategies for reducing the potential for occupational injury or illness and decrease the risk of exposure to hazardous conditions and situations to patients, employees, volunteers and visitors. The challenge of reducing exposure, risks and injury during construction can be met by supporting on-going education, focusing on hazardous exposures and integrating the procedures outlined in this guidebook.

1.2.1. VHA Policy

The VHA policy and specific strategies for construction safety have been updated in revised VHA Directive 7715, Safety and Health During Construction. The directive establishes a program to maintain a safe and healthful environment of http://www.bls.gov/news.release/cfoi.nr0.htm https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=5380 care for patients, and a safe and healthful worksite for staff, volunteers, contractors and the general public during construction and renovation activities.

The directive outlines strategies that include assigning responsibilities at all levels of the organization, publishing technical guidance, outlining best practices to assist in managing the program and providing construction safety training programs to support the implementation of these actions.

VHA policy is for construction and renovation activities on VHA-owned property and VHA-leased property to be conducted in such a way that protects the safety and health of VHA and contractor staff, volunteers, patients and the public. This policy applies to all construction activities performed by VA staff and/or contractor staff (as defined by OSHA) that are performed at VHA-owned or leased facilities.

The implementation of a proactive and comprehensive Construction Safety Program is expected to reduce the potential for injury and illness from unsafe and unhealthful construction activities, and to reduce the potential for VA legal and regulatory liability that could result from construction-related accidents, injuries or exposures.

Understanding the varied risk exposures of construction-related activities requires a method of analysis. Reducing risk involves developing protocols, monitoring these protocols for variances, educating the workforce on hazards and developing safe work practices and procedures. Construction work, by its very nature, is dynamic. Worksites are constantly changing, and a system must be in place to monitor this dynamic change to ensure the continuous elimination of hazards as they arise throughout the project. There are a number of methods to reduce the potential for hazards:

• Comprehensive site survey (safety program audits).

• Job hazard analysis.

• Periodic safety inspections of the worksite.

• Participation in design/construction meetings.

• Preconstruction planning with contractors.

• Interface with existing facility operations.

• Employee reports of hazard.

• Accident and near-miss investigation.

• Injury and illness pattern analysis.

• Preconstruction Infection Control Risk Assessments (PICRA).

• Security assessments.

To establish and monitor an effective construction safety program at a medical center, a Construction Safety Committee should be established by the Medical Center Director utilizing a multi-disciplinary team with representatives from the following program areas: Infection Control, Patient Safety, Occupational Safety and Health, Life Safety, VA Police, Engineering (Facilities Management), Engineering (Projects Management), Green Environmental Management System (GEMS), Unions (from affected bargaining units) and Contracting with Employee

Occupational Health and Emergency Planning Coordinator participating on an ad hoc basis as deemed appropriate by the chair of the Construction Safety Committee,. Additionally, CO(s) are required to designate a Construction Safety Officer (CSO) on all VHA construction projects to oversee the contractor’s implementation of construction safety and health for the project. Assignment of the CSO must give due consideration of qualifications and experience on the project and the identified or potential hazards. (See Enclosure 1-1, Sample Medical Center Memorandum, Delegation of Construction Safety Officer.) This individual satisfies the VA Acquisition Regulation (VAAR) 852.236-87, Accident Prevention (Sept. 1993), to have a Safety Officer to monitor and enforce contractor compliance with FAR 52.236-13, Accident Prevention (Nov. 1991).

The Construction Safety Committee provides oversight of the Construction Safety Program to ensure the continuous protection of patients, visitors, staff, volunteers and contractors from injury and illness, as well as occupational and facility-associated infections during construction and renovation activities. These oversight activities include monitoring to determine compliance with all applicable regulations pertaining to safety and health. This committee shall report to the Environment of Care Committee or Safety Committee.

The Construction Safety Committee determines the scope and depth of safety and health, life safety, infection control and security oversight appropriate for all minor (<$10 Million) in-house and contract construction work. For instance, after review, some projects may require only CSO or the OSHA-required Competent Person (CP) (in-house projects) surveillance to ensure employee safety and health and compliance with OSHA regulations, while other projects may require all disciplines to be involved. The Construction Safety Committee conducts and documents security, safety, health, preconstruction, interim life safety measures and Infection Control Risk Assessments (ICRA) beginning in the design phase and periodically re-evaluates risks and mitigation strategies for effectiveness as needed. However, the CSO and Construction Safety Committee do not take the place of the contractor’s CP or act on their behalf. The contractors are required to implement a construction safety program in accordance with 29 CFR 1926.20(b)(1) & (b)(2) in that they provide the OSHA required CP(s) and conduct frequent and regular inspections of the jobsites, materials and equipment for construction hazards.

The Infection Control representative or other appropriately skilled employee conducts the ICRA with input from the Construction Safety Committee. Staff conduct and document ICRAs for all construction projects (in-house and by contract) during the design or planning stage of the work (prior to bidding, purchasing or starting work) using the current Facilities Guidelines Institute (FGI;

formerly known as the American Institute of Architects Guidelines) and American Society of Healthcare Engineers (ASHE). ICRAs are documented in writing and focus on eliminating or minimizing the risk of infection during construction and renovation activities. The complexity of the ICRA is determined by the complexity of the potential hazards posed by the construction project. Assigned VA staff, including the Office of Construction & Facilities Management (CFM), Resident Engineers or project managers for major construction, will also confirm compliance with ICRA control measures during the construction phase of the project. (See Enclosure 1-2, Infection Control Risk Assessment Matrix of Precautions for Construction and Renovation.)

The Construction Safety Committee conducts preconstruction risk assessments for the transmission of Mycobacterium Tuberculosis (TB) to the contracted construction workers based on the construction site location, patient population, hospital layout and the Centers for Disease Control and Prevention (CDC) defined risk as outlined in the “CDC Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in Health-Care Settings”, 2005. For further guidance, see the VHA Directive Questions/Responses provided on the National Infection Control Call, addressing construction worker TB testing, construction safety inspections and training, etc. (March 2012).

The Construction Safety Committee conducts risk assessment of safety, health and security hazards to identify potential exposure of patients and building occupants to hazardous chemicals, disruptive or hazardous noise and vibration and adverse impacts of planned or unplanned interruptions of utilities, fire hazards, etc. The combination of this risk assessment, TB risk assessment and the ICRA would constitute the completion of a PICRA. A Preconstruction Risk Assessment and Exposure Control Checklist is provided as Enclosure 1-3.

The Construction Safety Committee conducts Interim Life Safety Measures (ILSMs) assessments. ILSMs should be designed and implemented in accordance with the ILSM assessment for the operating units that may be affected.

VA Police are responsible for addressing any security issues and developing control strategies. Issues include badging for identification, worker entry points, parking areas and the policy on weapons on-site. The fact that any crime committed on our property is a Federal issue is also stressed, including traffic laws.

1.2.2. Plan-Do-Check-Act

Like most VA facility programs that fall within The Joint Commission Accreditation Standards, the Construction Safety Program is managed using the Plan-Do- Check-Act model.

Plan. In this model, construction projects and activities are planned with safety in mind at the design stage. Risk assessments for safety, health, life safety, infection control and security are conducted in the design stage and updated as needed.

Control strategies are developed in the planning stage. These include the development of contract specifications that should be reviewed for safety, health, life safety, infection control and security criteria. The Construction Safety http://vaww.hefp.va.gov/resources/enclosure-1-2-icra-matrix-precautions-construction-and-renovation http://vaww.hefp.va.gov/resources/enclosure-1-2-icra-matrix-precautions-construction-and-renovation http://vaww.hefp.va.gov/resources/vha-construction-safety-directive-questions-responses

Committee will develop or approve facility orientation training materials for contractors to include:

• Safety, health, life safety, infection control and security strategies specific to the project.

• Safety, health, life safety, infection control and security language for contract specifications. VHA Directive 7715, Safety and Health During Construction, requires inclusion of VA Master Specifications, Division 1 - General Requirements, Section 01 35 26 - Safety Requirements (https://www.cfm.va.gov/TIL/spec.asp#01) made specific for the associated construction work.

• Contractor orientation for safety, health, life safety, infection control, security and hazard control.

• Roles and responsibilities of VA staff such as CSO, OSH staff, GEMS Coordinator, Infection Control Practitioners, Project Engineers, Contracting Officers and VA Police.

• Monitoring strategies.

Do. Implement the safety, health, life safety, infection control and security strategies that were developed by the Construction Safety Committee for each construction project. These may include conducting orientation training on infection control practices and fire response plans for contractors working in VHA space.

Check. The following monitoring activities are appropriate for the program:

• Ensuring that all solicitations and construction contracts include the following: (a) FAR clause 52.236-13, Accident Prevention; (b) VAAR clause 852.236-87, Accident prevention and (c) VA Master Specifications, Division 1 - General Requirements, Section 01 35 26 - Safety Requirements made specific for the associated construction work.

• Reviewing contractor submittals related to safety and health, such as safety training records and the site-specific safety plan.

• Reviewing submittals related to the contractor’s PICRA Plan and Security Plan.

• Performing at least weekly oversight inspections of construction sites.

• Verifying that corrective actions are completed in a timely manner.

• Environmental sampling for gas, vapor and/or particulate hazardous air contaminants.

https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=5380 https://www.cfm.va.gov/TIL/spec.asp#01

• Verifying the presence of a Safety Data Sheet (SDS) for materials brought onto VHA property by contractors.

• Performing weekly evaluations of the effectiveness of the program during the oversight inspections.

Act. In the final step of the Plan-Do-Check-Act model, recommendations for continual improvement are implemented. These recommendations may result from problems arising during projects, the results of project monitoring and the annual program effectiveness evaluation report. They may include improvements to policies, procedures, checklists, roles and responsibilities, among others.

Figure 1-1: Plan-Do-Check-Act Model

1.3. Regulations and Standards

Requirements and guidance for maintaining the health and safety of patients, staff, visitors, contractors and the general public can be found in the following regulations:

• VHA Directive 7715, Safety and Health During Construction.

• 29 CFR 1926, Safety and Health Regulations for Construction, and compliance with specific General Industry Standards (29 CFR 1910) as incorporated by 29 CFR 1926, such as respiratory protection, HAZCOM, etc.

• EPA regulations address requirements related to specific environmental issues such as asbestos, lead, mercury, polychlorinated biphenyls (PCBs) and hazardous waste management for staff, patients, visitors, contractors and the public.

• FAR.

• VAAR.

• VHA Procurement Manual (VHA PM).

• VA Directive 7700 and VHA Directive 7701 provide an overall requirement that all VHA permanent and temporary employees have a safe and healthy place to work.

• The Joint Commission Health Care Facility Accreditation Requirements.

• National Fire Protection Association (NFPA®) Standards.

• FGI Guidelines for Design and Construction of Hospitals, 2018

• FGI Guidelines for Design and Construction of Outpatient Facilities, 2018

• FGI Guidelines for Design and Construction of Residential Health, Care, and Support Facilities, 2018

A. Key Individuals: Leaders. The primary responsibility of leaders is to provide a workplace designed for the safe delivery of quality of care, treatment and services. The purpose of the hospital’s mission, vision and goals, is to ensure the provision of safe, quality and efficacious healthcare. Safety and quality thrive in an environment that supports teamwork and respect for other people, regardless of their position in the hospital. Leaders demonstrate their commitment to quality and set expectations for those who work in the hospital.

They encourage teamwork; create structures, processes and programs that allow this positive culture to flourish; and evaluate the culture on a regular basis. Safety and quality are achieved through management using the Plan- Do-Check-Act model outlined above.

In a culture of safety and quality, all individuals are focused on maintaining excellence in performance. They accept the safety and quality of patient care, treatment and services as personal responsibilities and work together to minimize any harm that might result from unsafe or poor quality of care, treatment and services. Leaders create this culture by demonstrating their commitment to safety and quality and by taking actions to achieve the desired state.

Leaders identify individuals to manage risk, coordinate risk reduction activities in the physical environment, collect deficiency information and disseminate summaries of actions and results. They also empower individuals to intervene whenever environmental conditions immediately threaten life or health or threaten to damage equipment or buildings. The hospital has a written plan for managing the environmental safety and health of patients and everyone else https://secure.madcad.com/library/ https://secure.madcad.com/library/ https://secure.madcad.com/library/ https://secure.madcad.com/library/ https://secure.madcad.com/library/ https://secure.madcad.com/library/ that enters or works in the hospital facilities. VHA Directive 7715 establishes the model within VHA for construction safety management, assignment of risk managers within all levels of VA facilities and responsibility to intervene due to hazards associated with VA construction operations.

B. Key Concept: Risk Management. Safety, health and security risks are present in most health care environments. These risks affect all individuals in the organization, including patients, visitors and those who work in the hospital. It is important to identify these risks in advance so that the hospital can prevent or effectively respond to incidents. Risks are inherent in the environment because of the types of care provided and the equipment and materials that are necessary to provide that care. The best way to manage these risks is through a systematic approach that involves the proactive evaluation of the harm that could potentially occur. By assigning one or more individuals to coordinate and manage risk assessment and reduction activities and to intervene when conditions immediately threaten life or health, organizations can be more confident that they have minimized the potential for harm. Risks in the environment include safety; health; fire prevention, detection and suppression; and security for people, equipment and the handling of hazardous materials and wastes. VHA Directive 7715 establishes the framework for management of hazards associated with construction and renovation operations at VHA facilities.

1.3.1. FAR

1.3.2. FAR

FAR 52.236-13 establishes construction safety requirements for contracted construction work as follows:

• The contractor shall provide and maintain work environments and procedures that will:

o Safeguard the public and government personnel, property, materials, supplies and equipment exposed to contractor operations and activities.

o Avoid interruptions of government operations and delays in project completion dates.

o Control costs in the performance of this contract.

• For these purposes, on contracts for construction, dismantling, demolition or removal of improvements, the contractor shall:

o Provide appropriate safety barricades, signs and signal lights.

o Comply with the standards issued by the Secretary of Labor in 29 CFR 1926 and 29 CFR 1910.

o Ensure that any additional measures the CO determines to be reasonably necessary for the purposes are taken.

Whenever the CO becomes aware of any noncompliance with these requirements or any condition that poses a serious or imminent danger to the health or safety of the public or government personnel, the CO shall notify the contractor orally, with written confirmation and request immediate initiation of corrective action. This notice, when delivered to the contractor or the contractor’s representative at the worksite, shall be deemed sufficient notice of the noncompliance and that corrective action is required. 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. The contractor shall not be entitled to any equitable adjustment of the contract price or extension of the performance schedule on any stop work order issued under this clause.

If the contract will involve work of long duration, hazardous nature or performance on a government facility that on the advice of technical representatives involves hazardous materials or operations that might endanger the safety of the public and/or government personnel or property, the contractor shall perform the following:

• Submit a written proposed plan of an analysis of the significant hazards to life, limb and property inherent in contract work performance with methods for controlling these hazards.

• Meet with representatives of the CO to discuss and develop a mutual understanding relative to administration of the overall Safety Program.

Typically, large scale and/or complex construction projects would meet the requirement of sufficiently hazardous in nature, as construction operations are one of the highest hazard occupations.

Additionally, the FAR states that the award of a contract to a supplier based on lowest evaluated price alone can be false economy if there is subsequent default, late deliveries or other unsatisfactory performance resulting in additional contractual or administrative costs. While it is important that government purchases be made at the lowest price, this does not require an award to a supplier solely because that supplier submits the lowest offer. A prospective contractor must affirmatively demonstrate its responsibility including, when necessary, the responsibility of its proposed subcontractors.

To be determined responsible, a prospective contractor must have the necessary organization, experience, accounting, operational controls and technical…