ATTACHMENT G - Construction Safety Guidebook.pdf

Construction Safety Guidebook

Published by

VHA Center for Engineering & Occupational Safety and Health (CEOSH)

St. Louis, Missouri vaww.ceosh.med.va.gov

March 2012 i

Table of Contents

PREFACE

Executive Summary .................................................................................................... x

Acknowledgements .................................................................................................. xiii

How to Use This Guidebook ..................................................................................... xv

CD-ROM Instructions .............................................................................................. xvii

Update Listing ......................................................................................................... xviii

Acronyms .................................................................................................................. xix

1. Program Management

1.1. Construction Safety Program

1.1.1. VHA Policy

1.1.2. Plan-Do-Check-Act

1.2. Regulations and Standards

1.2.1. FAR

1.2.2. VAAR

1.2.3. OSHA

1.2.4. VA Medical Center Memorandum (MCM)

1.3. Construction Safety Responsibilities

1.3.1. Veterans Integrated Service Network (VISN) Director

1.3.2. VHA Facility Director

1.3.3. Multi-Disciplinary Team (Construction Safety Committee)

1.3.4. Chief Engineer and Resident Engineer (RE)

1.3.5. CO and COTR or Project Engineer

1.3.6. Construction Safety Officer (CSO)

1.3.7. Facility Safety Program Manager

1.3.8. GEMS Coordinator

1.3.9. Emergency Planning Coordinator

1.3.10. Construction Lead Person (VHA and Contracted)

1.3.11. Police and Security

1.3.12. Infection Control Professional (ICP)

1.3.13. General Contractor

1.3.14. Subcontractor

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1.4. Pre-Award Period and Preconstruction

1.4.1. Responsible Prospective Contractors

1.4.2. ILSM Assessment

1.4.3. Infection Prevention and Control

1.4.4. PICRA

1.4.5. References

1.5. Post-Award and Construction Period

1.5.1. Surveillance

1.5.2. Written Site-Specific Plan

1.6. Post-Construction Period

1.7. Program Evaluation

1.8. Enclosures

2. Hazard Communication

2.1. Reference

2.2. Training

2.3. Certifications

2.4. Major OSHA Violations

2.5. Discussion

2.6. Enclosure

3. PPE and Respiratory Protection

3.1. Personal Protective Equipment (PPE)

3.1.1. Reference

3.1.2. Training

3.1.3. Formalized Written Program Required

3.1.4. Major OSHA Violations

3.1.5. Discussion

3.1.5.a. Criteria for Personal Protective Equipment

3.2. Respiratory Protection

3.2.1. Permissible Practice

3.2.2. Respiratory Protection Program

3.2.3. Selection of Respirators

3.2.4. Medical Evaluation of Employees

3.2.5. Medical Determination

3.2.6. Additional Medical Evaluations

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3.2.7. Fit Testing Requirements

3.2.8. Use of Respirators

3.2.9. Face piece Seal Protection

3.2.10. Continuing Respirator Effectiveness

3.2.11. Procedures for Dealing with IDLH Atmospheres

3.2.12. Maintenance and Care of Respirators

3.2.13. Cleaning and Disinfection of Respirators

3.2.14. Storage of Respirators

3.2.15. Inspection of Respirators

3.2.16. Checklist for Respirator Inspection

3.2.17. Repairs to Respirators

3.2.18. Breathing Air Quality and Use

3.2.18.a. Requirements for Cylinders Used to Supply Breathing Air to Respirators

3.2.18.b. Requirements for Compressors Used to Supply Breathing Air to Respirators

3.2.19. Identification of Filters, Cartridges, and Canisters

3.2.20. Training and Information

3.2.21. Program Evaluation

3.2.22. Recordkeeping

3.3. Enclosures

4. Fall Protection

4.1. Reference

4.2. Training

4.3. Certifications

4.4. Definitions

4.5. Formalized Written Program Required

4.6. Major OSHA Violations

4.7. Discussion

4.8. Enclosure

5. Lead

5.1. Reference

5.2. Training

5.3. Certifications

iv

5.4. Definitions

5.5. Formalized Written Program Required

5.6. Major OSHA Violations

5.7. Discussion

5.8. Enclosures

6. Silica

6.1. References

6.2. Training

6.3. Certifications

6.4. Formalized Written Program Required

6.5. Major OSHA Violations

6.6. Discussion

6.7. Enclosure

7. Fire and Emergency Protection and Prevention

7.1. Fire Protection and Prevention

7.1.1. Reference

7.1.2. Training

7.1.3. Certifications

7.1.4. Major OSHA Violations

7.1.5. Discussion

7.1.5.a. Fire Protection

7.1.5.b. Fire Prevention

7.1.5.c. Flammable and Combustible Liquids

7.2. Emergency Protection and Prevention

7.2.1. Reference

7.2.2. Training

7.2.3. Certifications

7.2.4. Discussion

7.2.4.a. Employee Emergency Action Plans

7.3. Enclosure

8. Confined Space Entry

8.1. Reference

8.2. Training

8.3. Certifications

v

8.4. Definitions

8.5. Formalized Written Program Required

8.6. Major OSHA Violations

8.7. Discussion

8.7.1. Non-Permit-Required and Alternate Entry Confined Space

8.7.2. Permit-Required Confined Space

8.8. Enclosures

9. Excavation and Trenching

9.1. References

9.2. Training

9.3. Certifications

9.4. Definitions

9.5. Formalized Written Program Required

9.6. Major OSHA Violations

9.7. Discussion

9.8. Enclosures

10. Scaffolds and Aerial Lifts

10.1. Scaffolds

10.1.1. Reference

10.1.2. Training

10.1.3. Certifications

10.1.4. Definitions

10.1.5. Formalized Written Program Required

10.1.6. Major OSHA Violations

10.1.7. Discussion

10.2. Aerial Lifts

10.2.1. Reference

10.2.2. Training

10.2.3. Certifications

10.2.4. Formalized Written Program Required

10.2.5. Major OSHA Violation

10.2.6. Discussion

10.3. Enclosures

11. Stairways and Ladders vi

11.1. Reference

11.2. Training

11.3. Definitions

11.4. Major OSHA Violations

11.5. Discussion

11.6. Enclosures

12. Cranes and Heavy Equipment

12.1. Reference

12.2. Training

12.3. Certifications

12.4. Definitions

12.5. Formalized Written Program Required

12.6. Major OSHA Violations

12.7. Discussion

12.8. Enclosures

12.9. Addendum to Chapter 12, Cranes and Heavy Equipment

13. Electrical

13.1. Reference

13.2. Training

13.3. Certifications

13.4. Major OSHA Violations

13.5. Discussion

13.5.1. General Requirements

13.5.2. Wiring Design and Protection

13.5.3. Wiring Methods, Components, and Equipment for General Use

13.5.4. Specific Purpose Equipment and Installations

13.5.5. Safety Related Work Practices

13.5.6. Locking and Tagging of Circuits

13.5.7. Batteries and Battery Charging

13.6. Enclosure

14. Energy Isolation (Lockout/Tagout)

14.1. Reference

14.2. Training

14.3. Definitions

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14.4. Formalized Written Program Required

14.5. Major OSHA Violations

14.6. Discussion

14.6.1. Elements of a Written Control Plan

14.7. Enclosures

15. Hand and Power Tools

15.1. Reference

15.2. Training

15.3. Certifications

15.4. Formalized Written Program Required

15.5. Major OSHA Violations

15.6. Discussion

15.6.1. Hand Tools

15.6.2. Power Tools

15.6.3. Abrasive Wheels and Tools

15.6.4. Woodworking Tools

15.6.5. Jacks: Lever and Ratchet, Screw, and Hydraulic

15.6.6. Air Receivers

15.7. Enclosure

16. Steel Erection

16.1. Reference

16.2. Training

16.3. Certifications

16.4. Definitions

16.5. Major OSHA Violations

16.6. Discussion

16.6.1. Scope

16.6.2. Site Layout, Site-Specific Erection Plan, and Construction Sequence

16.6.3. Hoisting and Rigging

16.6.4. Structural Steel Assembly

16.6.5. Column Anchorage

16.6.6. Beams and Columns

16.6.7. Open Web Steel Joists

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16.6.8. Systems-Engineered Metal Buildings

16.6.9. Falling Object Protection

16.6.10. Fall Protection

16.7. Enclosure

17. Material Handling and Rigging

17.1. Reference

17.2. Training

17.3. Certifications

17.4. Formalized Written Program Required

17.5. Major OSHA Violations

17.6. Discussion

17.7. Enclosures

18. Welding and Cutting

18.1. Reference

18.2. Training

18.3. Certifications

18.4. Major OSHA Violations

18.5. Discussion

18.5.1. Gas Welding and Cutting

18.5.2. Arc Welding and Cutting

18.5.3. Welding and Cutting Precautions

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

18.6. Enclosures

19. Concrete and Masonry Construction

19.1. Reference

19.2. Training

19.3. Certifications

19.4. Definitions

19.5. Major OSHA Violations

19.6. Discussion

19.6.1. General PPE and Sanitation Requirements

19.6.2. General Requirements

19.6.3. Requirements for Equipment and Tools

19.6.4. Requirements for Cast-In-Place Concrete

ix

19.6.5. Requirements for Precast Concrete

19.6.6. Requirements for Lift-Slab Operations

19.6.7. Requirements for Masonry Construction

19.7. Enclosure

20. Hexavalent Chromium

20.1. References

20.2. Training

20.3. Certifications

20.4. Definitions

20.5. Formalized Written Program Required

20.6. Major OSHA Violations

20.7. Discussion

20.7.1. Health Effects

20.7.2. Exposure

20.7.2.a. Exposure Determination

20.7.2.b. Employee Notification of Determination Results

20.7.2.c. Observation of Monitoring

20.7.3. Methods of Compliance

20.7.4. Respiratory Protection

20.7.5. Protective Work Clothing and Equipment

20.7.6. Medical Surveillance

20.7.6.a. Communicating with the PLHCP

20.7.7. Communicating Chromium Hazards to Employees

20.7.8. Monitoring Data

20.8. Enclosure

Enclosures x

Executive Summary 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 has about 8% of U.S. workers, but 22% 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 xi 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 (TJC) on Accreditation of Healthcare Organizations 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, with VA Directive 7700, Veterans Health Administration (VHA) Directive 7701, and VHA Handbook 7701.1 requirements address occupational safety and health issues for employees and contractors working on VA/VHA property. TJC requirements and FGI guidance address patient safety during construction activities.

Safety is a philosophy and a practice that identifies and eliminates job site hazards throughout the lifecycle of a project and discourages work practices and equipment that place individuals at risk of injury. The Occupational Safety & Health, Environmental, and Emergency Management Office (10NS) in VHA Headquarters recognized the need to assist VA Medical Centers 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 xii

Construction Activities and its subsequent revision, established policy for consistent construction safety programs across VHA. To support the VHA Directive, the Center for Engineering & Occupational Safety and Health (CEOSH) 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 goals of this guidebook are to encourage participation and provide guidance for the facility Construction Safety Program. It will assist managers in identifying hazards and establishing a process for the control, elimination and prevention of similar hazards. It will also provide safety training guidelines for all levels. This guidebook is targeted not only to program officials (i.e., Safety Officer, Chief Engineer, etc.), but is intended for use by all managers within the facility.

The CD-ROM included with this guidebook provides an electronic version of the Construction Safety Guidebook that facilities can use to tailor the sample documents to meet individual program needs. These documents can be customized easily with minimal cost to provide a fully functional and professional manual to satisfy changing requirements.

In addition to this current hard-copy edition and CD-ROM, the entire Construction Safety Guidebook is available online through the CEOSH Web site at: http://vaww.ceosh.med.va.gov.

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

http://vaww.ceosh.med.va.gov/ xiii

Acknowledgements This guidebook was possible because of the devoted attention of the personnel and management of the 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 VISNs and medical centers for their support.

Philip Andris, General Engineering Intern, VAMC Cheyenne, WY

Thomas Basham, Program Manager, VACO, Washington, DC

Linda Danko, Clinical Program Coordinator, VAMC, Cincinnati, OH

Douglas Dulaney, Program Manager, VACO, Washington, DC

Jeff Dulka, Manager of Design Development, VAMC, Milwaukee, WI

Hamner, Jennifer, Facility Safety Manager, VAMC, Biloxi, MS

William (Andy) Kay, RA, Staff Engineer, VAMC, Charleston, SC

Oleh Kowalskyj, Senior Healthcare Facility Engineer, VACO, Washington, DC

Gary Krupa, Senior Electrical Engineer, VACO, Washington, DC

Pete Larrimer, PE, Fire Protection Engineer, CEOSH, Pittsburgh, PA

Matthew McCoy, Safety and Health Officer, VISN 23, Des Moines, IA

Powell, Darlene, Facility Safety Manager, VAMC, West Haven, CT

Quel, Dana, Senior Resident Engineer, CFM-VACO, Washington, DC

*Watson, Richard, Construction Safety Program Manager, CEOSH, Dayton, OH

*Chairperson

Special thanks to the following individuals for their efforts in peer reviewing this guidebook and also for the support provided by their facility management:

Erwin, Daniel, Industrial Hygienist, VISN 1, VA New England Healthcare System, Brockton, MA

Murdzia, Michael, Construction Safety Engineer, VA Connecticut Healthcare System, West Haven, CT xiv

Romero, Ruben, Senior Resident Engineer, CFM, Fort Worth, TX

Vaughan, Frank, Safety Manager, VISN 1, VA New England Healthcare System, Brockton, MA

Welch, Barbara, Nurse Epidemiologist, VA New England Healthcare System, West Haven, CT

CEOSH Publishing Staff:

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

Sharon Brown, Supervisory Technical Information Specialist, St. Louis, MO

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

Carol Sanders, Program Support Assistant, CEOSH, St. Louis, MO

Melody Watts, Technical Information Specialist, CEOSH, St. Louis, MO xv

How to Use This Guidebook This guidebook was developed to provide guidance for Construction Safety Programs and assist managers in identifying hazards and establishing a process for the control, elimination, and prevention of similar hazards. This guidebook is divided into 20 chapters; each provides a general discussion of the topic and information on standards, definitions, and compliance requirements. The chapters are further divided into sections according to the complexity of the topics. Enclosures containing supplementary information are consolidated at the end of the guidebook.

The Construction Safety Guidebook is divided into 20 chapters, as described below:

Chapter 1: Program Management

Chapter 2: Hazard Communications

Chapter 3: Personal Protective Equipment and Respiratory Protection

Chapter 4: Fall Protection

Chapter 5: Lead

Chapter 6: Silica

Chapter 7: Fire and Emergency Protection and Prevention

Chapter 8: Confined Space Entry

Chapter 9: Excavation and Trenching

Chapter 10: Scaffolds and Aerial Lifts

Chapter 11: Stairways and Ladders

Chapter 12: Cranes and Heavy Equipment

Chapter 13: Electrical

Chapter 14: Energy Isolation (Lockout/Tagout)

Chapter 15: Hand and Power Tools

Chapter 16: Steel Erection

Chapter 17: Material Handling and Rigging

Chapter 18: Welding and Cutting

Chapter 19: Concrete and Masonry xvi

Chapter 20: Hexavalent Chromium

Enclosures provide a substantial amount of supplemental information and samples to aid engineers and managers in the Construction Safety Program.

A list of relevant enclosures can be found at the end of each chapter. The enclosures are located in a separate section at the end of the guidebook and are listed in numerical order as identified throughout the text.

The Printer-Friendly Version contains the Construction Safety Guidebook information as it appears in printed form and will permit printing the Construction Safety Guidebook in its entirety or by selected pages. To access individual enclosures and attachments, please see the Enclosure Listing at the end of the guidebook.

Web sites listed as references throughout this guidebook were current at the time of publication. This complete guidebook, along with all books in the guidebook series, is available on the CEOSH Web site (http://vaww.ceosh.med.va.gov). The most recent information, should any changes be required to this guidebook, will be available through online updates.

For a record of online updates made since the publication of this edition, refer to the Update Listing section.

xvii

CD-ROM Instructions The enclosed CD-ROM contains an electronic version of the Construction Safety Guidebook. You can view these files directly from the CD-ROM with no installation, or copy them to your hard drive. The complete guidebook can also be found on the CEOSH Web site: (http://vaww.ceosh.med.va.gov).

The CD-ROM contains the following files:

File Description

2012 Construction Safety Guidebook

This folder contains links to all of the chapters in the guidebook.

Enclosures This folder contains all of the enclosures for each chapter.

Printer Friendly Version This folder contains guidebook information as it appears in printed form. It can be used for printing selected information or full chapters at once.

Visit CEOSH Web Site This links the user to the CEOSH Web site, from which all guidebooks can be accessed.

The CD-ROM should start automatically when inserted into the CD Drive. If it does not start automatically, right-click on Start, select Explore, select CD Drive, select Autorun.exe to activate the CD options.

If your internet explorer options automatically block active content, you will need to temporarily allow blocked content by right clicking on the information bar and selecting “Allow Blocked Content”. At the security warning dialog box, select “Yes” to allow content.

Internet Explorer screen shot enabling ActiveX controls.

xviii

Update Listing The following listing identifies online updates since the initial publication of the October 2010 edition of this guidebook. It is designed to assist the reader in verifying the most current information available.

Update

Number Date Updated Remarks Chapter

1 10/06/2010 Changed verbiage for Figure 8-1 in Chapter 8, Confined Space Entry, section 8.7, Discussion 8

2 03/05/2012

Updated Chapter 1, Program Management to reflect changes from VHA Directive 2011-036:

Safety and Health During Construction 1

3 03/05/2012

Replaced Enclosure 1, Draft VHA Directive for Safety and Health During Construction with VHA Directive 2011-036: Safety and Health During Construction 1

4 03/05/2012

Updated Enclosure 2, Sample MCM Safety and Health During Construction Activities; Enclosure 3, Sample MCM Interim Life Safety Measures Policy;

and Enclosure 8, Pre-Award Contractor Evaluation Form to reflect changes from VHA Directive 2011-

036. 1

5 03/05/2012

Replaced Enclosure 4, Construction Safety Responsibility Matrix with Enclosure 4, VHA Memo: Clarifications Regarding the VHA Construction Safety Directive and Q/A Concerning VHA Memo: Clarifications Regarding the VHA Construction Safety Directive 1 xix

Acronyms

Acronym Definition

AC Alternate Current

ACD Allergic Contact Dermatitis

ACGIH American Conference of Governmental Industrial Hygienists

ACM Asbestos Containing Materials

AHA Activity Hazard Analysis

AIA American Institute of Architects

AIIR Airborne Infection Isolation Room

ANSI American National Standards Institute

APIC Association for Professionals in Infection Control and Epidemiology

APP Accident Prevention Plan

ASHRAE American Society of Heating, Refrigerating and Air Conditioning Engineers

ASTM American Society for Testing and Materials

AWE Annual Workplace Evaluation

BLL Blood Lead Level

CDC Center for Disease Control

CDZ Controlled Decking Zone

CEOSH Center for Engineering & Occupational Safety and Health

CFM Office of Construction & Facilities Management

CFR Code of Federal Regulations cm Centimeter xx

CO Contracting Officer

COR Contracting Officer’s Representative

COTR Contracting Officer Technical Representative

CP Competent Person

CPL Compliance

CPR Cardiopulmonary Resuscitation

CR(VI) Hexavalent Chromium

CS Construction Safety

DART Days Away Restricted Transferred dBA Decibels

DC Direct Current

DHHS Department of Health and Human Services

DOT Department of Transportation

DVA Department of Veterans Affairs

EMR Experience Modification Rate

EPA Environmental Protection Agency

E-SAFE Environmental Safety Automated Facility Evaluation

ESCBA Escape Self-Contained Breathing Apparatus

FAR Federal Acquisitions Regulations

FDA Food and Drug Administration

FGI Facilities Guidelines Institute ft Foot/feet

GEMS Green Environmental Management Systems

GFCI Ground Fault Circuit Interrupters

GPM Gallons Per Minute

H Horizontal xxi

HAI Healthcare Associated Infections

HEPA High Efficiency Particulate Air

ICP Infection Control Practitioner

ICRA Infection Control Risk Assessment

ICU Intensive Care Unit

IDLH Immediately Dangerous to Life and Health

ILSM Interim Life Safety Measures lb Pound

LFL Lower Flammable Limit

LOTO Lockout/Tagout

LWDIR Loss Work Day Incident Rate

M&O Maintenance and Operations

MCM Medical Center Memorandum

MMAD Mass Median Aerodynamic Diameter

MSDS Material Safety Data Sheet

NAICS North American Industrial Classification System

NCCCO National Commission for the Certification of Crane Operators

NEC National Electric Code

NFPA National Fire Protection Association

NIOSH National Institute for Occupational Safety and Health

NRR Noise Reduction Rating

OD Optical Density

OSH Occupational Safety and Health

OSHA Occupational Safety and Health Administration

OTI OSHA Training Institute xxii

PACU Post-Anesthesia Care Unit

PAPR Powered Air Purifying Respirator

PCB polychlorinated biphenyls

PEL Permissible Exposure Limit

PFAS Personal Fall Arrest System

PHSC Project Health and Safety Coordinator

PICRA Preconstruction/Infection Control Risk Assessment

PLHCP Professionally Licensed Health Care Professional

PM&R Physical Medicine and Rehabilitation

PNOR Particulates Not Otherwise Regulated

PPE Personal Protective Equipment

PPM Parts Per Million psi Pound Per Square Inch

QLFTP Qualitative Fit Testing Procedures

QNFTP Quantitative Fit Testing Procedures

RE Resident Engineer

REL Recommended Exposure Level

RPM Revolutions Per Minute

S Service

SAFE Safety Automated Facility Evaluation

SAR Supplied Air Respirator

SCBA Self-Contained Breathing Apparatus

SI International System of Units

SIC Standard Industrial Classification

SJ Service Junior

SJO Service Junior with Oil Resistant Jacket xxiii

SJT Service Junior Thermoplastic

SJTO Service Junior Thermoplastic with Oil Resistant Jacket

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

SWL Safe Working Load

TB Tuberculosis

TJC The Joint Commission tsf Tons per square foot

TWA Time-Weighted Average

USDL United States Department of Labor

V Vertical

VA Veterans Affairs

VAAR VA Acquisition Regulation

VACO VA Central Office

VAMC VA Medical Center

VHA Veterans Health Administration

VISN Veterans Integrated Service Network

WLL Working Load Limit

ZPP Zinc-Protoporphyrin

Chapter 1 Program Management

1. Program Management

1.1. 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 Veterans Affairs (VA) employees. In the past, the Veterans Health Administration (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 (USDL) Study (National Census of Fatal Occupational Injuries in 2009: USDL-10-1142), fatalities in the construction and mineral extraction group accounted for nearly one-fifth of all fatalities in 2009.

Specifically, 816 fatalities occurred in the construction industry.

The Occupational Safety and Health Administration (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) 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 (TJC) 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.

1.1.1. VHA Policy

In 2004 VHA recognized the need for a policy and specific strategies for construction safety and developed VHA Directive 2004-012: Safety and Health During Construction Activities. This directive was revised and reissued in 2011 as VHA Directive 2011-036: Safety and Health During Construction (Enclosure 1).

The directive establishes a program to maintain a safe and healthful environment of 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 assure 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 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.

Enclosures/Encl%201%20VHA%20Directive%202011-036.pdf

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), Emergency Planning Coordinator, Unions (from affected bargaining units), Employee Occupational Health, and Contracting. Additionally, CO(s) are required to designate a Construction Safety Officer (CSO) to oversee the implementation of construction safety and health by the contractors. This individual satisfies the VA Acquisition Regulation (VAAR) 852.236-87: Accident Prevention requirement to have a Safety Officer to monitor and enforce contractor compliance with FAR 52.236-13: Accident Prevention.

The Construction Safety Committee provides oversight of the Construction Safety Program to assure 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 in-house and contract construction work. For instance, after review, some projects may require only CSO or the OSHA-required Competent Person (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 Competent Person (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 job sites, materials, and equipment for construction hazards.

The Infection Control representative conducts the ICRA with input from the Construction Safety Committee. Using the current Facilities Guidelines Institute (FGI) or the American Institute of Architects (AIA) Guidelines, staff conducts and documents 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). 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. For the Infection Control Risk Assessment Matrix of Precautions for Construction and Renovation, please see Enclosure 12.

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 Setting, 2005.”

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 are provided in Enclosure 23.

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.

1.1.2. Plan-Do-Check-Act

Like most VA Medical Centers (VAMCs), programs that fall within TJC 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 Committee will develop or approve VAMC orientation training materials for contractors to include:

file://vhaceomul11/Guidebook/Guidebooks/CD-Guidebooks/2010ConstructionSafety/WordDocuments/Enclosures/Encl%2012%20ICRAMatrixofPrecautions.doc file://vhaceomul11/Guidebook/Guidebooks/CD-Guidebooks/2010ConstructionSafety/WordDocuments/Enclosures/Encl%2023%20PreconstructionRiskAssesment.doc

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.

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:

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 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.

Verifying the presence of a Material Safety Data Sheet (MSDS) 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

1.2. 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 2011-036: Safety and Health During Construction.

29 CFR 1926 addresses general construction safety requirements.

Environmental Protection Agency (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.

VA Directive 7700, VHA Directive 7701 and VHA Handbook 7701.1 provide an overall requirement that all VHA permanent and temporary employees have a safe and healthy place to work.

TJC Health Care Facility Accreditation Requirements.

National Fire Protection Association (NFPA) Standards.

FGI and/or AIA Guidance for Design and Construction of Hospitals and Health Care Facilities.

A. Key Individuals: Leaders. The primary responsibility of leaders is to provide for the safety and quality of care, treatment, and services. The purpose of the hospital’s mission, vision, and goals, is to ensure the provision of safe, quality healthcare. Safety and quality are achieved through management using the Plan-Do-Check-Act model outlined above.

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.

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 that enters or works in the hospital facilities.

VHA Directive 2011-036 establishes the model within VHA for construction safety management, assignment of risk managers within all levels of VAMC, 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 2011- 036 establishes the framework for management of hazards associated with construction and renovation operations at VHA facilities.

1.2.1. FAR

FAR 52.236-13 establishes construction safety requirements for contracted construction work. For fixed price contracts, the FAR requires the following:

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 work site, 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 skills, or the ability to obtain them. This requirement includes elements such as production control procedures, property control systems, quality assurance measures, and safety and health programs applicable to materials to be produced or services to be performed by the prospective contractor and subcontractors.

1.2.2. VAAR

VAAR 852.236-87, along with VHA Directive 2011-036, establishes that the CFM Resident Engineer or other VA employee, if designated in writing by the CO, shall serve as the Safety Officer on all assigned construction projects. In this position, the Resident Engineer or other designated VA employee has authority on behalf of the CO to monitor and enforce contractor compliance with construction safety and health requirements. The CSO is to be designated in writing by the CO to serve as the Safety Officer for VAMC construction projects that are not being controlled by a Resident Engineer (facility level projects). However, only the CO may issue an order to stop all or part of the work while requiring satisfactory or corrective action to be taken by the contractor.

1.2.3. OSHA

A. Key Individual: OSHA Competent Person (CP).

The Following are excerpts from VA Master Construction Specification 01010.

Contractor CP:

1.1 F. Prior to commencing work, general contractor shall provide proof that an OSHA certified Competent Person (CP) [29 CFR 1926.20(b)(2)] will maintain a presence at the worksite whenever the general contractor’s or subcontractor’s employees are present.

Specification Writer Note: The length of training is based on the project hazards and complexity, State and Federal regulations and VA requirements.

1.5 B. Prior to any contractor’s or subcontractor’s employees beginning work, they shall undergo a safety briefing provided by the general contractor’s CP per OSHA requirements.

1. CP Overview. A significant element in reducing the potential for accidents is to have supervision that can understand the risks of the specific tasks, understand the elements of control, and has the authority to make changes. The CP bears the burden of responsibility for the safety and health of the employees. The term CP is referenced in many OSHA standards and documents. OSHA defines a CP as “an individual who, by way of training and/or experience, is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, is designated by the employer, and has authority to take appropriate actions” (See 29 CFR Subpart C, 1926.32).

Some standards, particularly Subpart L, Scaffolds, Subpart P, Excavation and Trenching, and Subpart N: Cranes have additional specific requirements that must be met by the CP. Throughout the OSHA Construction Standards, reference is made to a CP. This section will define the role of the CP, as well as when and where it applies. References to the CP can be found throughout this guidebook. Similarly, within the VA and the VA’s policy and guidance, the term will be widely used with varying meanings. These will range from an overall broad awareness and general understanding of a variety of typical construction issues related to general oversight to detailed knowledge of the safe and healthful practices related to specific tasks or trades. One individual may be competent in a variety of contexts; however, being competent in one situation does not imply competency in others.

In summary, key provisions for a CP include:

Has training and/or experience specific to the task.

Is knowledgeable of standards applicable to the task (OSHA).

Can identify hazards to the specific operations.

Is an individual designated by the employer.

Has the authority to take corrective actions.

2. Role of the CP. As indicated in the definition, the CP must have knowledge of the applicable standards, must be able to identify hazards relative to the specific tasks, and is authorized by the employer to take corrective measures.