4)_Safety_and_Health_During_Construction_Activities.pdf

VA Hospital Policy Memorandum 578-12-138A-076 (R1)

Hines, IL 60141 April 11, 2014

Safety and Health During Construction Activities

Changes:

Add to 3, RESPONSIBILITY: paragraph g, to read:

g. Contracting Officer (CO) and Contracting Officer’s Representative (COR):

(10) Ensuring that if contracted construction worker(s) have been determined to be at risk for transmission of tuberculosis (TB) based upon the TB section of the Infection Control Risk

Assessment ( to be completed by COR and approved by Infection Control prior to Contract

Award), 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 worksite and been found to be with negative screening reactions. This can be the 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 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.

(11) Evaluating and considering 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, one repeat, or one willful OSHA violation(s) in the past 3 years, or any significant environmental penalties, when contract selection is applicable at the station level.

(12) Ensuring that prior to the commencement of all projects that the contractor receive a copy of the HINES VAH Contractor Safety Disciplinary Procedures (Attachment F).

(13) The COR shall ensure proper notification to the CO if unsafe action by the contractor occurs by submitting to both the Contractor and the Contracting Officer (Attachment G)

Hines VAH COR Letter of Concern for Safety Non-Compliance, in accordance with

(Attachment F) HINES VAH Contractor Safety Disciplinary Procedures.

Add to 3, RESPONSIBILITY: paragraph h, to read:

h. Construction Safety Officer(s) (CSOs):

(8) Monitoring and inspecting construction and renovation work sites periodically to ensure compliance with safety elements of established program(s) as noted in Attachment H, titled

OSHA Required Competent Person Inspections.

(13) As applicable if a Crane lift is required to complete aspects of the project then the Hines

VA Hospital Planned Critical Lift Plan & Crane Permit (Attachment J) is required to be completed and approved by a member of the Safety Section prior to the Crane being allowed on campus. Once the Crane is onsite the HINES VAH Onsite Inspection Checklist for

Mobile Cranes (Attachment I) shall be completed by the Construction Safety Officer prior to commencement of work.

References Added:

Above Ceiling Entry and Wall Construction Permits 578-07-001-102 (R-2) dated December

27, 2011

Smoking Policy 578-03-001-038 (R-2) dated February 1, 2012

Cutting, Welding, and other Hot work 578-03-001-089 (R-2) dated July 5, 2013

Hazard Communication Program 578-03-001-034 (R-1) dated January 13, 2012

Confined Space Program 578-12-138S-047 dated May 2, 2012

Asbestos Management Program 578-03-001-046 (R-1) dated January 30, 2012

ISO 14001/Environmental Management System

29 CFR Part 1926, OSHA Standards for the Construction Industry

CDC Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in Health-

Care Setting, 2005

Related Forms:

Replaced: Older Attachment C, VHA Construction Site Safety Review Checklist from

April 2013 with updated Attachment C, VHA Construction Site safety Review Checklist from March 2014.

Added additional Attachments:

F Hines VAH Contractor Safety Disciplinary Procedure

G Hines VAH COR Letter of Concern for Safety Non-Compliance

H OSHA Required Competent Person Inspections

I Crane Operation and Minimum Criteria On-Site Inspection Checklist

J Hines VA Hospital Planned Critical Lift Plan & Crane Permit

Attachment D GEMS Awareness Competent Person Training and Attachment E VA Master

Specifications Section 0174 19 Construction Waste Management combined and renamed

Attachment D GEMS Awareness Competent Person Training

VA Hospital Policy Memorandum 578-12-138A-076 (R1)

Hines, IL 60141 April 11, 2014

Safety and Health During Construction Activities

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

2. POLICY:

a. In order to protect patients, staff, visitors, and contractors from safety and health hazards associated with construction activities, this policy is established for the Edward Hines Jr. VA

Hospital (Hines VA) and for all property where construction is undertaken. This policy requires that strategies be established to control the hazards inherent in conducting construction or maintenance operations in areas that are occupied by patients, visitors, or healthcare 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 health and safety program, applying technical guidance and best practices to assist in managing the program, and providing a Construction Safety Committee to oversee and enforce the application of this policy.

b. Construction activities shall be defined to include delegated minor or non-recurring maintenance projects performed by contractors, station-level projects performed by contractors, and station Maintenance and Operations (M&O) personnel. Construction shall also include non-delegated projects including majors, and Hines VA shall coordinate those construction impacts with the project’s Project Engineer/Contracting Officers Representative (COR) through Hines

VA single point of contact. This definition also applies to enhanced use and lease projects related to structures for which Hines VA maintains management responsibility or authority.

c. The intention of this Construction Safety Program is to reduce the potential for injury and illness to VA patients, employees, and visitors that might result from unsafe construction activities; to increase the level of construction safety expertise of VA employees; to decrease the potential for serious Occupational Safety and Health Administration (OSHA) violations; to provide a guideline 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 could result from construction accidents, life safety deficiencies, or infection control failures.

3. RESPONSIBILITY:

a. VA Hospital Director:

(1) Establishing and monitoring an effective facility Construction Safety Program.

(2) Establishing a Multi-Disciplinary Team (Construction Safety Committee) with representatives from the following program areas:

Infection Control

Patient Safety

Occupational Safety and Health

Police

Engineering (Facilities Management)

Engineering (Projects Management)

Green Environmental Management System (GEMS)

Emergency Planning Coordinator

Local Union Safety Representatives (from affected bargaining units)

Contracting

Employee Occupational Health

(3) Ensuring that appropriate staff receives training in construction safety. All members of the Multi-Disciplinary Team complete at least 10 hours of Construction Safety Training at least every 2 years; or complete 30 hours of Construction Safety Training.

(4) Ensuring that the Construction Safety Committee actively engages in:

(a) Protecting patients, visitors, and employees from traumatic injury, toxic environmental exposures, and occupational and facility-associated infections.

b. Associate Director:

(1) Completing responsibilities delegated from the Hospital, as appropriate, for oversight of these policies.

c. Chief, Facilities Management Service:

(1) Working with contractor and VHA facility staff to coordinate and monitor an effective

Construction Safety Program for projects under their direction.

(2) Completing OSHA’s 30-hour Construction Safety Training and subsequently completes at least 10 hours of Construction Safety Training at least every 2 years.

(3) Supporting the periodic inspections of construction sites.

(4) Ensuring contractors comply with VA safety and health policies and procedures and contract requirements.

(5) Serving on the facility Construction Safety Committee/subcommittee to ensure contracts meet the committee’s requirements.

(6) Supporting the Construction Safety Officer, Facility Safety Manager, Contracting

Officer, and engineering staff in implementing the Construction Safety Program.

d. Chief, Project Planning Section:

(1) Working through safety and health staff, CORs, maintenance staff, contractors, and the

Construction Safety Committee to plan, coordinate and monitor the Construction Safety

Program for all projects at the facility.

(2) Completing OSHA’s 30-hour Construction Safety Training and subsequently complete

10 hours of Construction Safety Training at least every 2 years.

(3) Participating in monthly construction rounds of construction sites to ensure compliance with safety elements of the construction contract and performance of the program.

(4) Serving on the facility Construction Safety Committee to ensure contract requirements meet the committee’s approval.

(5) Supporting the Competent Person (CP), Safety Officer, Infection Control Practitioner, Contracting Officer (CO), and engineering staff in implementation of the Construction Safety

Program.

(6) Working with contracting staff to ensure competent staff is assigned as CORs to oversee work.

e. Chief, Maintenance and Operations Section:

(1) Completing OSHA’s 30-hour Construction Safety Training and subsequently complete 10 hours of Construction Safety Training at least every 2 years.

(2) Participate in construction rounds of in-house construction sites to ensure compliance with safety elements of the construction contract and performance of the program.

(3) Ensure that in-house work forces have necessary training and competency for tasks being performed.

f. Chief, Biomedical Engineering:

(1) Ensuring that all construction accomplished in support of major equipment installations

(as a part of the equipment purchase) are in compliance with the site Construction Safety

Program policy and procedures.

g. Contracting Officer (CO) and Contracting Officer’s Representative (COR):

(1) Completing at least at least 10 hours of Construction Safety Training and completing

OSHA’s 30-Hour Construction Safety training. Subsequently, complete at least 10 hours of construction safety training every 2 years.

(2) Ensuring that all solicitations and contracts include the Federal Acquisition Regulation

(FAR) clause found in FAR 52.236-13, Accident Prevention, and Veterans Affairs Acquisition

Regulation (VAAR) clause found in VAAR 836.236-87.

(3) Designating, in writing, the Construction Safety Officer(s) (CSO) to serve as the Safety

Officer for VHA contracts.

(4) Adding 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 CSO or COR involves hazardous materials or operations that might endanger the safety of the public or government personnel or property.

(5) Ensuring that all solicitations and contracts specify that on-site general and sub-contractor’s construction workers have completed at least 10 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 Multi-Disciplinary Team. The determination for other relevant competency training is based on the project hazards and complexity, Federal, and State regulations and VA requirements.

(6) Ensuring that all projects require contractor certification verifying completion of required training.

(7) Ensuring 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) Serving on the facility Construction Safety Committee or subcommittee to ensure contracts meet the Committee’s requirements.

(9) Supporting the CSO, Facility Safety Manager, and appropriate staff in implementing the construction safety program and enforcement of the contracts.

(10) Ensuring that if contracted construction worker(s) have been determined to be at risk for transmission of tuberculosis (TB) based upon the TB section of the Infection Control Risk

Assessment ( to be completed by COR and approved by Infection Control prior to Contract

Award), 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 worksite and been found to be with negative screening reactions. This can be the 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 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.

(11) Evaluating and considering 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, one repeat, or one willful OSHA violation(s) in the past 3 years, or any significant environmental penalties, when contract selection is applicable at the station level.

(12) Ensuring that prior to the commencement of all projects that the contractor receive a copy of the HINES VAH Contractor Safety Disciplinary Procedures (Attachment F).

(13) The COR shall ensure proper notification to the CO if unsafe action by the contractor occurs by submitting to both the Contractor and the Contracting Officer (Attachment G) Hines

VAH COR Letter of Concern for Safety Non-Compliance, in accordance with (Attachment F)

HINES VAH Contractor Safety Disciplinary Procedures.

h. Construction Safety Officer(s) (CSOs):

(1) Submitting project reviews of all construction projects, to include at a minimum the

Infection Control Risk Assessment, Pre-Construction Risk Assessment (Attachment A), and

National Environmental Protection Act Evaluation (Attachment B).

(2) Providing oversight of contract construction safety.

(3) Being 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. Note: CSC(s) do not take the place of the contractor’s CP nor act on their behalf.

The CSC(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 Contracting Officer’s Representative (COR), CO, and CSC must take immediate action to prevent injury, exposure, noncompliance, and/or property damage.

(4) Completing OSHA’s 30-hour Construction Safety Training and subsequently complete

(5) Ensuring that the specific safety requirements for construction operations are implemented during facility projects.

(6) Serving as a member of the Multi-Disciplinary Team.

(7) Conducting periodic inspections of VHA construction sites to ensure compliance with safety elements of the established program(s); at minimum, weekly inspections are required.

(8) Monitoring and inspecting construction and renovation work sites periodically to ensure compliance with safety elements of established program(s) as noted in Attachment H, titled

OSHA Required Competent Person Inspections.

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

(10) Approving corrective actions.

(11) Stopping unsafe work or activities that are non-compliant with the contract or OSHA and notifying the CO immediately.

(12) Maintaining communication with the contractor CP on questions of safety.

(13) As applicable if a Crane lift is required to complete aspects of the project then the

Hines VA Hospital Planned Critical Lift Plan & Crane Permit (Attachment J) is required to be completed and approved by a member of the Safety Section prior to the Crane being allowed on campus. Once the Crane is onsite the HINES VAH Onsite Inspection Checklist for Mobile

Cranes (Attachment I) shall be completed by the Construction Safety Officer prior to commencement of work.

i. Facility Safety Program Manager or designee:

(1) Completing OSHA’s 30-hour Construction Safety Training and subsequently complete at least 10 hours of Construction Safety Training at least every 2 years.

(2) Ensuring that VHA policy for the Construction Safety Program is implemented within the medical center.

(3) Chairing the Construction Safety Committee.

(4) Ensuring that necessary and relevant Interim Life Safety Measures (ILSMs) are established and implemented. Conducts required additional training for compliance with identified ILSMs.

(5) Rendering technical advice and assistance as required in connection with life safety and fire protection issues during construction, project design, and development.

(6) Overseeing compliance with OSHA and other relevant construction safety regulations.

(7) Confirming that VAMC staff receives training required by this memorandum.

(8) Ensuring that the Construction Safety Program includes appropriate periodic construction site hazard surveillance.

j. Infection Preventionist:

(1) Advising and/or providing recommendations on exposure mitigation and the prevention of facility associated infections in patients, staff, and visitors.

(2) Coordinating 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 the work. ICRAs must be documented in writing and focus on eliminating or minimizing the risk of infection during construction and renovation activities.

(3) Monitoring infection prevention protocols during construction activities as indicated in

ICRA for that project.

k. GEMS Coordinator:

(1) Providing guidance on EPA regulations and environmental issues, as those regulations and issues directly and immediately relate to the safety during the design stage.

(2) Monitoring contractor compliance with contract specifications on EPA regulations, Attachment B – NEPA Assessment) as those regulations directly and immediately relate to the construction project, including environmental compliance, pollution prevention (Attachment D-

GEMS Awareness Competent Person Training), waste management (Attachment E –

Construction Project Waste Minimization Report), and permitting.

(3) Completing OSHA’s 30-hour Construction Safety Training and subsequently complete

l. Emergency Planning Coordinator:

(1) Providing 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).

(2) Monitoring contractor performance to contracted specifications on OSHA Regulations as they appear to emergency planning, response, and operations related to construction operations.

m. The Construction Safety Committee (Multi-Disciplinary Team):

(1) Determining 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 Construction Safety Officer surveillance to ensure employee safety and OSHA compliance, while other projects will require all disciplines to be involved.

(2) Conducting 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 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 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

Construction Facility Management Resident Engineers (CFM REs) must confirm compliance during the construction phase of the work.

(3) Verifying that an Infection Control Risk Assessment (ICRA) was completed prior to construction occurring thereby mitigating the risk of transmission of Mycobacterium

Tuberculosis (TB) to contracted construction workers. The completed ICRA though reviewed by the Infection Preventionist per project is based upon many variables such as the construction site location, duration of construction activity, patient population, as well as the Hines VAH

Annual Tb Risk Assessment, and the Center for Disease Control (CDC) defined risk as outlined in the “CDC Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in

Health-Care Setting, 2005.”

(4) Ensuring 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 medical facility must have a local policy addressing ILSM as required by TJC.

(5) 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 Multi-Disciplinary Team must be involved early in the process and continue oversight on a regular basis to avoid costly and disruptive delays.

(6) 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 Construction Safety Committee. The frequency and location of the hazard surveillance activities shall be defined and adhered to, which will include an agreed schedule for construction safety rounds and appropriate follow up enforcement of the corresponding corrective actions. Hazard Surveillance activities must be documented (date, time, members of the inspection team, deficiencies, types of corrective action, and time and date of correction). Note: Correction of hazards found during hazard surveillance activities must be tracked to completion by the Construction Safety Committee, with action by the appropriate

COR/CSO/CP.

(7) Ensuring all contractors entering VHA properties comply with the security management program. As a minimum, contractors must notify and obtain permission from the VA Police, be identified by project and employer, and be restricted from unauthorized access.

(8) Evaluating the effectiveness of the Construction Safety Program in an annual report to the facility Safety Committee and/or Environment of Care Committee or equivalent committee.

(9) Requiring the contractor CP to implement and maintain an effective Safety Program that identifies and controls hazards that may cause injury or illness to VA patients, staff, visitors, and contractor employees.

(10) Requiring the contractor CP to implement and maintain an effective Safety Program that identifies and makes available their sub-contractors CP qualifications/certifications to the

COR for all generally determined high risk construction activities as defined in 29 CFR 1926.

(11) Ensuring that documentation of the team’s inspections is provided to the Network

Safety and Health Staff as requested.

n. Police and Security:

(1) Ensuring that all contractors entering VAMC property comply with the Security

Management Program. At a minimum, contractors must notify and obtain permission of the

VAMC Police, be identified by project and employer, and be restricted from unauthorized access.

(2) Conducting periodic surveillance of site security and the integrity of barriers for trenches and other hazards.

4. INTERVENTION AND ENFORCEMENT:

a. All of the individuals with defined actions in this directive 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 will take prompt corrective measures to include immediate abatement of hazards, stopping of work, hazard awareness training, administrative controls, etc.

(2) Contractors. The Construction Safety Officer 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. Upon a repeat offense of the same or substantially similar hazard, the Construction Safety Officer or CO should 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.

The Construction Safety Officer, with assistance from the Multi-Disciplinary Team, 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.

5. REFERENCES:

VHA Directive 2011–036, Safety and Health During Construction Activities, dated September

22, 2011 (Data available on Intranet)

Interim Life Safety Measures, Policy Memorandum 578-02-001-088(R-2), dated October 3, 2011 (Data available on intranet)

Above Ceiling Entry and Wall Construction Permits 578-07-001-102 (R-2) dated December 27, 2011 (Data available on Intranet)

Smoking Policy 578-03-001-038 (R-2) dated February 1, 2012 (Data available on

Intranet)

Cutting, Welding, and other Hot work 578-03-001-089 (R-2) dated July 5, 2013 (Data available on intraner)

Hazard Communication Program 578-03-001-034 (R-1) dated January 13, 2012 Data Available on intranet)

Confined Space Program 578-12-138S-047 dated May 2, 2012 Data available on intranet)

Asbestos Management Program 578-03-001-046 (R-1) dated January 30, 2012 (Data available on intranet)

ISO 14001/Environmental Management System (Data available on internet)

OSHA 1926, Construction Standards. www.osha.gov (Data available on internet)

CDC Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in Health-Care

Setting, 2005 (Data available on internet)

29 CFR 1926 (Data available on internet)

6. RESCISSION: Policy 578-12-138A-076 Safety and Health During construction Activities

7. RECERTIFICATION: This Policy Memorandum will be re-certified on or before

April 11, 2017.

8. FOLLOW-UP RESPONSIBILITY: Facilities Management Services (138), Chief, Project

Planning.

/s/

Joan M. Ricard, FACHE

Hospital Director

Distribution: Hines Internet Website and Service Chiefs / Service Line Managers via Email

Attachments:

A Pre-construction/Safety Risk Assessment

B National Environmental Protection Act Assessment

C Construction Safety Checklist

D GEMS Awareness Competent Person Training

E Construction Project Waste Minimization Report

F Hines VAH Contractor Safety Disciplinary Procedure

G Hines VAH COR Letter of Concern for Safety Non-Compliance

H OSHA Required Competent Person Inspections

I Crane Operation and Minimum Criteria On-Site Inspection Checklist

J Hines VA Hospital Planned Critical Lift Plan & Crane Permit file:///C:/Documents%20and%20Settings/VHAHINBEATTC/Desktop/www.osha.gov

Policy Memorandum 578-12-138A-076 (R1)

April 11, 2014

Attachment A

Pre-Construction/Safety Risk Assessment

Location of Construction (Bldg. No. /Room No.): Project No.: 578-__-___

Project Title:

Project Coordinator: Project Start Date:

Contractor Performing Work: Estimated Duration:

Supervisor: Telephone:

Description of Project:

Construction Activities

The following projects do not require completion of the Pre-Construction/Safety Risk Assessment form:

1. Painting and installation of new wallpaper in business offices and non-patient areas.

2. Painting in a patient room, if closed for painting and less than 3 square feet of wall area is to be patched and painted. Contractor shall replace the air filter for the room’s air conditioning unit upon completion of painting.

3. Installation of a soap dispenser/needle box/paper towel holder in a patient room

4. Repair of a window blind.

5. Ceiling tile replacement for areas less than ten (10) 2’ x 2’ tiles, if not in business offices and non-patient areas.

6. Ceiling tile replacement for areas less than five (5) 2’ x 2’ tiles in a patient area, if patient is out of the immediate area and clean up can be accomplished before patient returns.

7. Minimal repair of Nurse Call System/TV/Bed/Telephone.

8. Checking or replacing of electric outlet.

9. Replacing a light bulb.

10. Unstopping sink/commode with no water on floor.

11. Unstopping commode when water on floor requires maintenance to have Housekeeping clean area immediately.

12. Repair of a medical gas outlet. (Front Body)

13. Taking air balance measurement readings.

14. Checking air conditioning unit/system.

15. Intermediate jobs that create a moderate amount of dust inside the room with negative air pressure maintained in the room via use of HEPA-equipped unit with minimum 10 ACH and all air discharged outside. The

HEPA unit must continue running 2 hours after completion of job and Housekeeping must clean room before the HEPA unit is removed from room. All work and use of HEPA unit must be documented and copies forwarded to Infection Prevention and Safety. NOTE: All duct vents to be sealed off during work!

Yes No Will there be noise generated that will impact a department adjacent to, above, or below the construction area?

a. If so, these departments must be notified.

b. How are you going to reduce the noise to an acceptable level?

Yes No Will there be vibration generated that will impact a department adjacent to, above, or below the construction area?

a. If so, these departments must be notified each time this type of work will be performed.

b. How are you going to reduce the vibration to an acceptable level?

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Attachment A

Yes No Are Emergency Procedures in place and posted on each job for accidental events that could greatly impact Patient Care or Life Safety to the facility?

Typically included items in these procedures are:

Emergency telephone numbers of key departments.

A contingency plan describing the location of main valves, switches, and controls.

A contingency plan for unexpected outages.

Environment

Yes No Are any of the following environmental hazards present?

Will hazardous chemicals be used on this project? How will fumes and odors be controlled? Material

Safety Data Sheets (MSDS) are required.

Reference: Hazard Communication Program 578-03-001-034 (R-1) dated January 13, 2012

Is asbestos abatement required on this job? If so, notify Safety at the Pre-Construction Meeting.

Reference: Asbestos Management Program 578-03-001-046 (R-1) dated January 30, 2012

Will there be hot work (welding, brazing, soldering) done on this project? If so, then a Hot Work

Permit must be posted on the job site. All hot work must have a fire watch assigned to each area while the hot work is being performed.

Reference: Cutting, Welding, and other Hot work Policy 578-03-001-089 (R-2)

Will there be work performed above the ceiling? Will repair/construction activities involve penetration in to existing walls, ceilings, door frames, or doors? If so, must apply for an Above Ceiling Entry and

Wall Construction Permit.

Reference: Above Ceiling Entry and Wall Construction Permits 578-07-001-102 (R-2) dated December

27, 2011

Will confined space entry be required on this project? If so, the VAMC Confined Space Entry Program must be followed.

Reference: Confined Space Program 578-12-138S-047 dated May 2, 2012

Utility Failures

Yes No Will any of the following systems be out of service at any time during the project?

Fire alarm (For outages greater than 4 hours, Interim Life Safety Measures must be implemented.)

Sprinkler (For outages greater than 4 hours, Interim Life Safety Measures must be implemented.)

Electrical

Domestic water (For outages greater than 2 weeks, affected domestic water systems will be flushed 5 times the plumbing volume to ensure no residual contaminants i.e. Legionella.)

Oxygen

Sewage

HVAC

* The contractor must provide the COR a minimum of 3 weeks’ notice prior to a scheduled utility outage.

Yes No

Will there be any work that will require activation of the Interim Life Safety Measures (ILSM) during this project? Other work may require ILSMs, but typical work requiring ILSM implementation are:

Any construction that impacts an exit or stairs

Any construction that impacts major breaches in a fire or smoke wall

Taking the main fire protection system out of service (sprinkler)

Taking the main fire alarm system out of service

Taking the “area” fire or fire alarm systems out of service for more than 4 hours within a 24-hour period

Implementation of the ILSM requires a fire watch and the ILSM forms to be completed.

Attachment A

Additional Safety Concerns

Yes No

Will construction affect exit routes from occupied areas adjacent to construction site?

Will the project affect traffic patterns in area? If yes, explain plan.

Will the project involve the deployment of a crane to deliver equipment over occupied facilities?

• Must submit a Lift Safety Plan and the Hines VA Hospital Planned Critical Lift Plan & Crane Permit to the Safety Office for approval a minimum of 3 weeks prior to the arrival of the crane on Hines VA

Hospital. Follow the Safety Office’s Lift Safety Plan format and include the following information:

crane specifications, crane inspection list, and crane staff training record/certification. Contractors shall maintain and present the following items prior to crane start (items can be kept in crane cab): crane certifications, crane registration, fire extinguisher, and crane operating and safety manual.

The following must be completed prior to any construction activities:

Construct separation walls prior to project start.

Fire protection systems must remain intact.

Provide extra fire extinguishers in work areas.

Maintain exit lights in work area.

Maintain negative air pressure in construction area (24/7) throughout project duration.

Maintain means to monitor and ensure negative pressure via barometer / magnahelix.

There cannot be any return air from within the construction area to the rest of the building.

Redirect egress routes; do not allow egress routes to pass through construction areas.

Provide and maintain “Construction Area-Do No Enter” signs on doors leading into the construction area.

Maintain up-to-date daily logs and maintain a current Hot Work Permit.

Provide and install no-slip mats at doors exiting construction area.

All debris removal must be by covered cart.

Maintain a clean and orderly work area.

Determine how, if at all, this project will affect the departments above, below, and adjacent to this project?

Air Quality and Infection Prevention

Construction activity types are defined by the amount of dust that is generated, the duration of the activity, and the amount of shared HVAC systems. Contact Hines VA’s Safety and Infection Prevention Departments if any activity is questionable under these guidelines.

Yes No

Will dust be generated during this project?

If yes, explain location of and plan for interim dust barriers or attach floor plan with barriers clearly marked.

Is work occurring in an area defined by Infection Control as being at risk for Tuberculosis?

If yes, explain location of and plan for notification of floor staff and PPE for assigned contractors, attach floor plan with barriers clearly marked.

Will debris removal be necessary? If yes, explain plan for debris removal and control.

Negative airflow ventilation and filtration in place and assessed for effectiveness.

Exhaust fans in-place and functioning.

Air supply duct to area closed and HEPA filtration unit in-place and functioning in adjacent patient care area?

Will work be done in a sterile area? If so, how will sterile atmosphere be maintained (to include access in/out of the work area)?

Attachment A

Type A Inspections and Non-Invasive Activities or Small Scale/Short Duration Activities. (Refer to

Infection Control Risk Assessment for Type Selection)

Yes No

Removal of ceiling tiles for visual inspection (limited to 1 tile per 50 square feet)

Painting (excludes sanding)

Wall covering—Describe work to be done:

Electrical trim work. Describe:

Minor plumbing. Describe:

Type B Small Scale, Short Duration Activities that create minimal dust. ( Refer to Infection Control Risk

Assessment for Type Selection)

Yes No

Installation of telephone and computer cabling

Access to chase spaces

Sanding of walls for painting or wall covering (minor repairs—excludes sanding for drywall finishing)

Type C Any work that generates a moderate to high level of dust or requires demolition or removal of any fixed building components or assemblies. (Refer to Infection Control Risk Assessment for Type

Selection)

Yes No

Sanding of walls--drywall finishing

Removal of floor coverings ceiling tiles casework Describe:

Cutting of walls or ceiling. Describe:

New wall construction

Minor ductwork or electrical work above ceilings

Major cabling activities

Activity cannot be completed within a single work shift

Type D Major demolition and Construction Projects. (Refer to Infection Control Risk Assessment for

Type Selection)

Yes No

Will require heavy demolition or removal of a complete ceiling system

New construction

Contractor Signature COR / CSO Signature Safety Signature

Date: Date: Date:

Safety Service Recommendations (as needed):

Policy Memorandum 578-12-138A-076(R1)

Attachment B

NEPA Assessment

Project:

Location: Date:

Project #:

Type of Project:

Operation and Maintenance Activities

Repairs/Renovation Project

New Construction Project

Lease

Other______________________________

Project Scope:

Level of NEPA Analysis:

Categorical Exclusion (CATEX)

Environmental Assessment Needed (EA)

Environmental Impact Statement Needed (EIS)

Other Environmental Permits/Analysis Needed:

PROJECT IMPACTS

Would the proposed activity involve or generate any of the following?

Source Yes No Source Yes No Source Yes No

Air Emissions

Including GHG’s Liquid Effluent RCRA or

CERCLA Sites

Asbestos

Petroleum

Storage Wetlands

Excess Noise

Solid Waste Permit

Modification

Utility Modification Hazardous

Waste

Chemical

Use/Storage

Soil Disturbances Biological

Resources Aesthetics

Water Treatment Radioactive

Waste Water/Well

Use

Water Flow

Modification Mixed Waste Other:

DETERMINATION

I find the proposed project qualifies as a CATEGORICAL EXCLUSION with no extraordinary circumstances.

Specify which CATEX:_____________________________________________________

I find that the proposed project MAY have a significant effect on the environment; therefore, an

ENVIRONMENTAL ASSESSMENT will be prepared.

EIS

X P r o j e c t E n g i n e e r

X G E M S C o o r d i n a t o r

Attachment B

VA Categorical Exclusion List

Found in 38 CFR Part 26.6(b)(1)

1. Repair, replacement, and new installation of primary or secondary electrical distribution systems;

2. Repair, replacement, and new installation of components such as windows, doors, roofs; and site elements such as sidewalks, patios, fences, retaining walls, curbs, water distribution lines, and sewer lines which involve work totally within VA property boundaries.;

3. Routine VA grounds and facility maintenance activities;

4. Procurement activities for goods and services for routing facility operations maintenance and support;

5. Interior construction or renovation;

6. New construction of 75,000 gross square feet or less;

7. Development of 20 acres of land or less within an existing cemetery, or development on acquired land of five acres or less;

8. Actions which involve support or ancillary appurtenances for normal operation;

9. Leases, licenses, permits, and easements;

10. Reduction in force resulting from workload adjustments, reduced personnel or funding levels, skill imbalances or other similar causes;

11. VA policies, actions and studies which do not significantly affect the quality of the human environment;

12. Preparation of regulations, directives, manuals or other guidance that implement, but do not substantially change, the regulations, directives, manuals, or other guidance of higher organizational levels or another Federal agency; and

13. Actions, activities, or programs that do not require expenditure of Federal funds.

Extraordinary Circumstances List

Found in 38 CFR Part 26.6(b)(1)

1. Greater scope or size than normally experienced for a particular categorical exclusion

2. Actions in highly populated or congested areas

3. Potential for degradation, although slight, or existing poor environmental conditions

4. Use of unproven technology

5. Potential presence of an endangered species, archeological remains, or other protected resources

6. Potential presence of hazardous or toxic substances

Attachment C

VHA Construction Site Safety Review Checklist Project: Date: _________________________ Time: ___________________________

Contractor: COR: ______

Inspection Team: _______________________________________________________________

Safety & Health General

OK

NC

N/A

Concrete Operations

OK

NC

N/A

1. Safety Program / Injury Illness Protectn Plan 50. Cement/Silica dust exposures

2. Orientation/Code of Safe Practices/Badges 51. Cutting Sawing/Grinding Controls

3. Toolbox Meetings/Pre-Job Safety 52. PPE utilized by Crew

4. Postings (OSHA) (Project Info/POC) 53. Wall or Structure Supported

5. Emergency Numbers/First Aid 54. Pumps/equipment set-up/ cond.

6. Toilets/ Hand Wash/Drinking Water Ladders

Environment 55. Ladder Conditions

7. Ventilation, incl neg. air/ HEPA / Manometer 56. 3’ Above Landing

8. Illumination 57. Braced & Tied

9. Integrity of Dust Control and containment 58. A-Frame Step Ladder Set Up

10. Openings Guarded/Covered-Marked 59. Correct Height

11. Stairs/Walkways Guarded & Accessible 60. Proper Use

12. Rebars Capped Scaffolds/Shoring (Interior/Exterior)

13. Equipment/Material Storage 61. Current certified installation doc

14. Traffic/Public Safety 62. Planks/toe boards

15. 1 or 2 hr. fire separation based upon ILSM 63. Railed Properly

16. Construction Warning Signs Posted 64. Tied to Structure

17. Housekeeping 65. Ladder Access

18. Emergency Exits – Clear / Unlocked 66. Daily Inspections

19. ILSM in place – Exits Blocked/Locked 67. Users trained/Competent person

Electrical Safety 68. Falling Object Protection

20. Cords, Plugs Conditions, Surge Protectors Excavations/Trench

21. GFI Boxes & Grounding 69.Daily Inspections/Competent Person

22. Overhead Lines protected/marked/spotter 70.Shored/sloped > 5’ or soil cond.

23. Lock out Tag Out 71. Spoil Piles at least 2' from edge

24. Power/Generator/breaker panels secured 72. Underground Line located/potholed

Personal Protection (PPE) 73. Barricades/protective measures

25. Hard Hats 74. Ladder every 25’ & after 4’ deep

26. Eye & Face Protection Vehicle/Equipment Operations

27. Ear Protection 75. Seat Belts by Operators

28. Gloves/Clothing 76. Back Up Alarms – all Equipment

29. Footwear 77. Reflective garments/PPE

30. Respiratory (Dust/Canister Masks) 78. Personal cars in designated areas

Site Security 79. Forklift operators trained

31. Fencing 80. Flagmen/Traffic Control

32. Security Scissors/Zoom Booms/Lift Trucks

33. Entrance/Exit 81. Controls Operative

Hand/ Power/Powder Actuated Tools 82. Safety Chains in Place

34. Guards attached/functional 83. Harness & Lanyards (JLG’s)

35. Grounded Properly 84. Operator Certification

36. Working Properly 85. Visual Inspection

37. Trained or Certified Operators/PPE 86. Fluid Levels (Oil, Water)

Fire Protection 87. Brakes/Lights/Back up Alarm(s)

38. Fire Extinguishers checked/accessible 88. Gauges – Operative

39. Alarm/Detection System in Place 89. Scheduled Maintenance

40. Smoking (No Smoking) Welding & Cutting

41. Hot Work Permits approved/current 90. Approved Hot Work Permit

42. Flammable/Combustible Material 91. Cylinders – Use & Segregation

Fall Protection 92. Torches, Horses, Gauges, PPE, etc

43. Use of Fall Protection above 6’ 93. Weld Cables, Holders & Grounds

44. Floor openings/holes securely covered 94. Fire Protection (Task Work)

45. Perimeter/Interior Shaft Guardrails Personnel Hoists & Cranes

46. Falling material/objects 95. Inspections & Maintenance

47. Trained on Use – Competent Person 96. Crane Set Up & Swing Protection

48. Handrails for stairs 4 or more steps 97. Rigging & Loads Secured

49. Fall Protection Equipm’t in place/Inspected. 98. Certified Operator

Legend: OK = Condition of non-compliance was not identified; NC = Needs Correction; N/A = Not Applicable

Attachment C

Tracking for CSC: Identify non-compliance item noted, where & what was observed, corrective actions needed, Date Corrective Action due, and when and how non-compliance was addressed completed.

Content of the above checklist is advisory and should be modified to satisfy the circumstances of the specific contract or work activity. Any modification of the checklist requires the consent of the safety and engineering staff.

All Contractor personnel and Subcontractor employees are responsible to conduct work activities in a safe and healthful manner for their health and well-being as well VHA personnel. The purpose of this Site Safety Review is to increase the Contractor/Subcontractors awareness of the need for safe work habits and a positive attitude toward loss prevention and control. Below columns marked with “NC” answers require the Contractor/Subcontractors implementation of corrective action plans. Additional comments/actions will be described on additional pages to supplement this report.

Section I - Non-Compliance Issues Associated with Project

Section & Line

Number

Deficiency Observed & Where

Corrective Actions Needed Date Due

How Corrective Actions Were Completed Date

Corrected

Attachment D

GEMS Awareness Training for Contractors Competent Person All federal agencies are required by Executive Order to implement an Environmental Management

System, reduce waste, reduce quantity of toxic and hazardous chemical and materials acquired, used or disposed of, increase diversion of solid waste by recycling, and use sustainable environmental practices (acquisition of bio-based, environmentally preferable, energy-efficient, water-efficient and recycled-content products).

The Department of Veterans Affairs has chosen the term GEMS to refer to the department’s Green

Environmental Management System. Green Environmental Management Systems have been shown to be a valuable tool to lessen negative impacts on the environment, and create more efficient, cost effective means of providing service to our veterans. The GEMS program emphasizes importance of compliance to federal, state, and local regulations; encourages pollution prevention strategies whenever possible; and focuses on continued improvement on environmental issues.

The GEMS Program is based on ISO 14001, which relates to Environmental Management Systems

(EMS). The EMS provides a framework to review activities performed by, or on behalf of the organization, including work performed by contractors.

Any parties, including contractors, who perform an activity identified as being significant based on the impact on the environment, environmental compliance, exposure risk, etc., must be aware of our facility GEMS program and ways to reduce the environmental impacts.

Training for contractors involved in construction, renovation or demolition shall consist of being made knowledgeable of VA Master Specifications Section 01 74 19 by their employer regarding…