Attachment 13-FD_FM 70-09 Occupational Safety and Health Program - 508.pdf

DEPARTMENT OF HOMELAND SECURITY

FEDERAL LAW ENFORCEMENT TRAINING CENTERS

FLETC DIRECTIVE NO: 70-09

DIRECTIVE TITLE: Occupational Safety and Health Program EFFECTIVE DATE: June 28, 2019

I. POLICY: The Federal Law Enforcement Training Centers (FLETC) are committed to proactive safety management as an integral aspect of operations and control.

II. SCOPE: This directive applies to all FLETC locations and training delivery points and contains elements that apply to all FLETC staff, Partner Organization staff, students, visitors, and contractor personnel.

III. REFERENCES:

A. Specific authorities and references related to the FLETC Occupational Safety and

Health Program elements are provided as program supplements to the Department of Homeland Security (DHS) Occupational Safety and Health Manual.

B. 29 Code of Federal Regulations (C.F.R.) §1910, OSHA Standards for General Industry.

C. 29 C.F.R. §1904, Recording and Reporting Occupational Injuries and Illnesses.

D. 29 C.F.R. §1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs.

E. 29 C.F.R. §1926, Construction Industry Regulations.

F. National Fire Protection Association (NFPA) 101, Life Safety Code.

G. NFPA 70, National Electric Code (NEC).

H. NFPA 70E, Standard for Electrical Safety in the Workplace.

IV. CANCELLATIONS:

A. This directive supersedes FLETC Directive 70-09, Safety Program Management, dated August 29, 2013.

B. This directive hereby supersedes and cancels FLETC Policy Bulletin 2014-04, Occupational Safety and Health, Medical Surveillance Program dated April 14, 2015.

V. ADDITIONAL GUIDANCE: FLETC Manual 70-09, Occupational Safety and Health Program.

VI. OFFICE OF PRIMARY INTEREST: Environmental and Safety Division, Mission and Readiness Support Directorate.

Signature on File

Marcus L. Hill Assistant Director Mission and Readiness Support Directorate

POST PUBLICATION

Revision History

Date Revision Request

By:

Summary of Revisions Revisions

Made By:

7/2/2019 Cynthia Johnson- Hall Uploaded revised forms;Changed AED training from Annual to Every 2 Yrs; Added Exit Audiograms and MSPs for WAEs

C.Haney

7 't

FLETC MANUAL 70-09

Occupational Safety and Health Program

Supporting Publication to FLETC Directive 70-09 Occupational Safety and Health Program

June 2019

SIGNATURE PAGE

FLETC Manual 70-09, Occupational Safety and Health Program

APPROVED BY:

Signature on File June 28, 2018

___________________________________ DATE: _______________________________

Marcus L. Hill Assistant Director Mission and Readiness Support Directorate Federal Law Enforcement Training Centers

FLETC Manual 70-09

FLETC SUPPLEMENT to the DHS Occupational Safety and Health Manual

FLETC MANUAL 70-09

FLETC Supplement to the DHS Occupational Safety and Health Manual

Occupational Safety and Health Program

TABLE OF CONTENTS

Page

1. Introduction…………………………………………………………………...….…..5

2. Responsibilities………………………………………………………………………8

3. Occupational Safety and Health Standards

4. Operational Risk Management

5. Councils and Committees

6. Safety and Health Assessment Program

7. Incident Reporting, Records and Investigations Program

8. Employee Reports of Unsafe/Unhealthful Working Conditions

9. Prevention and Control of Workplace Hazards

10. Training Program

11. Personal Protective Equipment Program

12. Respiratory Protection Program

13. Hearing Conservation Program

14. Hazard Communication Program

15. Asbestos Awareness and Control Program

16. Confined Space Entry Program

17. Isolation of Energy Sources (Lockout/Tagout)

18. Bloodborne Pathogen Exposure Control Program

19. Driving Safety Program

20. Laboratory Safety Program

21. Fire Protection Program

22. Electrical Safety Program

23. Explosives Safety Program

24. Aviation Safety Program

25. Afloat Safety Program

FLETC Manual 70-09

26. Ionizing Radiation Program

27. Non-Ionizing Radiation Program

28. Lead Control Program

29. Public Access Defibrillation Program

30. Ergonomics Program

31. Smoking/Use of Tobacco Program

32. Medical Surveillance Program

33. Forklift Operators Program

FLETC Manual 70-09

Chapter 1

INTRODUCTION

I. INTRODUCTION:

A. The Department of Homeland Security (DHS) considers safety to be a critical consideration in all departmental activities. Accordingly, DHS published Directive 066-01, Safety and Health Programs, and corresponding DHS Occupational Safety and Health (OSH) Manual that is applicable to all DHS operations and activities except those involving unique military equipment and military personnel.

B. Likewise, the Federal Law Enforcement Training Centers (FLETC) considers safety to be an integral component of FLETC operations and program management. FLETC has established an OSH Program with requirements and procedures that impact all FLETC activities and orient personnel to safe behavior both within and outside their immediate work environment.

C. The FLETC OSH Manual is a supplement to the DHS OSH Manual and it is applicable to personnel and activities on FLETC facilities. The FLETC OSH Manual is not intended to be a completely independent document, rather it seeks to provide FLETC-specific safety program guidance and clarify requirements identified in the DHS OSH Manual; and as such it must be viewed in conjunction with the DHS OSH Manual.

II. SCOPE: The DHS OSH Manual and the FLETC OSH Manual apply to all FLETC employees, Partner Organization (PO) staff, students, visitors and contractor personnel working on or training at FLETC facilities. This includes U.S. Coast Guard civilian personnel who serve as detailed instructors to FLETC, as well as related law enforcement training equipment, operations, and worksites that are not characterized as uniquely military.

III. REFERENCES: DHS OSH Manual (DHS OSH Manual).

IV. FORMS: Included in the FLETC OSH Manual.

V. DEFINITIONS: Included in the FLETC OSH Manual.

VI. RESPONSIBILITES: Included in Chapter 2 and throughout the FLETC OSH Manual.

VII. PROCEDURES:

A. FLETC Occupational Safety and Health Programs:

1. Are developed by the Environmental Safety Division (ESD) to be in compliance with the Occupational Safety and Health Administration (OSHA) 29 CFR §1910, General Industry Standards. This manual is not meant to be all inclusive and topics not covered in this manual will be addressed by ESD through use of supplemental guidance from OSHA and other resources such as National Institute for Occupational Safety and Health (NIOSH), National Fire Protection Association (NFPA), American Society of Mechanical Engineers (ASME), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), etc.

2. Are implemented at all FLETC sites according to the hazards present and the controls required to protect employees in their work sites.

3. Are updated as required due to changes in regulatory requirements.

4. Provide the program elements, roles, and responsibilities for each FLETC safety program as a supplement to the DHS OSH Manual.

FLETC Manual 70-09 June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf

5. The Pandemic and Emerging Infectious Diseases Workforce Protection Plan is not included in the FLETC Occupational Safety and Health Manual. Guidance on Pandemic plans to include risk assessments and PPE requirements is a separate document provided by the Office of Emergency Management and Continuity.

B. Establishment of Authority Having Jurisdiction:

1. ESD recognizes that consensus safety standards (e.g., the National Fire

Protection Association (NFPA Life Safety Code) may not be sufficient in specific and unique circumstances and therefore it may rely upon the independent, expert judgment and advice of FLETC personnel in determinations of reasonable care in these circumstances.

2. Additionally, FLETC has adopted the International Building Code and NFPA guidelines as design and construction standards for FLETC facilities.

3. In order to ensure compliance with these standards, FLETC has established a process for determining when a variance from the standards is appropriate and reasonable. This is accomplished through an “Authority Having Jurisdiction (AHJ)”, which the NFPA defines as “the organization, office, or individual responsible for approving equipment, materials, an installation or a procedure.”

4. At FLETC, the AHJ is a chartered, standing body, with the following guidance establishing the charter. The AHJ consists of the following members:

a. ESD Division Chief (DC) and/or Assistant Division Chief (ADC) who will serve as chair of the AHJ;

b. Facilities Management Division (FMD) Engineer with formal training in fire protection requirements;

c. Glynco safety specialist with formal training in life safety code requirements;

d. Charleston Site Director or designee and the site environmental and safety specialist;

e. Cheltenham Site Director or designee and the site environmental and safety specialist; and

f. Artesia Site Director or designee and the site safety specialist; and

g. Union representation.

5. The Charleston, Cheltenham, and Artesia team members should have some experience in facilities management, engineering and/or life safety code requirements. The site directors may elect not to participate in the review of a particular AHJ project that is not located on their facility by providing a written declaration in response to the notice issued to the AHJ team members. Any such declinations will be included in the record for that AHJ assignment.

6. Issues will be brought before the AHJ based on the concurrent recommendations of the following individuals: for Glynco facilities, the Chief, Design and Construction Branch, FMD (or for field sites, the equivalent position to the Chief, Design and Construction Branch, Field Sites); and the DC and/or Assistant Division Chief, ESD.

FLETC Manual 70-09

7. Additional team members for the AHJ may be appointed temporarily at the consensual discretion of ESD and the field site members when other subject matter expertise is required.

8. AHJ team members shall use all appropriate sources of data and information relating to the project to thoroughly evaluate all options, including, but not limited to, contacts at similar facilities, agencies with similar activities or issues and regulatory compliance experts.

AHJ members will meet by teleconference and video-teleconference whenever reasonable.

Funding for site visits (only if needed) would be provided from the individual project budget.

The Chief of the Design and Construction Branch (or field site equivalent) shall ensure that contingency funding for potential AHJ reviews is identified in project estimates.

9. The AHJ team shall make a written recommendation after reviewing the provided data and any additional information obtained in response to pertinent issues. The recommendation must be a consensus of all team members. If the AHJ team members report they cannot reach consensus, the ESD DC and the Glynco FMD Chief, Design and Construction Branch, will meet with the team and assist in resolving any conflicts.

10. All AHJ recommendations shall be reviewed in draft by the Office of Chief Counsel, which will provide legal interpretations and research as needed for AHJ issues prior to their implementation. The written recommendation shall be addressed to the ESD DC and Glynco FMD Chief, Design and Construction Branch, and shall be signed by all AHJ team members.

11. AHJ reports will be retained on file at both FMD and ESD, with ESD retaining the original report. When an AHJ recommendation is approved and implemented, FMD will include this process in its next revision of the FMD Design Guide. ESD will also include this process change in the program elements section of the safety program affected.

C. The Director’s Occupational Safety and Health Policy:

Federal Law Enforcement Training Centers

Safety and Health Policy It is the Federal Law Enforcement Training Centers (FLETC) policy to comply with all Occupational Safety and Health Administration (OSHA) standards, in particular those found in 29 Code of Federal Regulations §1910.

The most important aspect of FLETC’s Occupational Safety and Health Programs is to provide FLETC and Partner Organization employees, students, contractors, and visitors a safe and healthy workplace. No person will be required to work or train in surroundings or under conditions which are unsafe or dangerous to their health.

If at any time, you identify a dangerous or unsafe condition, report it immediately to your supervisor, instructor, or program manager.

Signature on file Thomas J. Walters Director

FLETC Manual 70-09

Chapter 2

RESPONSIBILITIES

I. INTRODUCTION: Safety is integral to all FLETC activities and is the responsibility of all FLETC employees, Partner Organization (PO) staff, students, visitors, and contractor personnel.

A. Director. The Director is ultimately responsible for the implementation of an OSH Program and for the health and safety of FLETC staff, PO staff, students, and visitors when on FLETC property.

B. Executive Team. The Executive Team is responsible for incorporating OSH Program requirements in strategic planning and for leading the integration of safety programs in their individual functional areas.

C. Assistant Director, Mission and Readiness Support Directorate (MRSD). The Assistant Director, MRSD serves as FLETC’s Designated Safety and Health Officer (DSHO) pursuant to 29 Code of Federal Regulations, Parts 1960.6(a) and 1960.2(f), and as such has overall responsibility for the effective and efficient conduct of FLETC OSH Program.

D. Chief, ESD. The Chief, ESD is the FLETC Safety Officer. The Safety Officer integrates safety program processes for all activities, tracks compliance, and reports outcomes with respect to goals and benchmarks of the OSH Program. In addition, the Safety Officer is responsible for providing technical safety expertise to the DSHO and for providing technical management of FLETC OSH Program, establishing and maintaining standard operating procedures (SOPs) to document this process.

E. Site Directors (Artesia, Charleston, Cheltenham). Site Directors are responsible for executing the requirements of FLETC OSH Program and for ensuring employees at their sites comply with the mandates of the program.

F. Chief, Procurement Division (PRO). The Chief, PRO is responsible for ensuring that FLETC contracts incorporate health and safety requirements that correspond to the requirements of FLETC OSH Program and ensure that contracting officer representatives (CORs) are charged with enforcement of these provisions to the same extent as for any other contract provisions.

G. Supervisors. Supervisors are responsible for executing the requirements of FLETC OSH Program and for ensuring employees within their organizations comply with the mandates of the program.

H. Instructors. Instructors are responsible for conducting face-to-face communications with their students to ensure compliance with the requirements of the FLETC OSH Program.

I. Employees. Employees are responsible for their own safe behavior and for alerting supervisors or other proper authority of conditions, procedures, or behavior of others that appears unsafe.

J. Students. Students are responsible for their own safe behavior and for alerting instructors or other proper authority of conditions, procedures or the behavior of others that appear unsafe.

FLETC Manual 70-09

K. PO Staff. PO representatives and personnel are expected to comply with the requirements of the FLETC OSH Program while on FLETC facilities to the same extent required of FLETC personnel.

L. Visitors. Visitors are responsible for their own safe behavior and for alerting their sponsors or other proper authority of conditions, procedures, or the behavior of others that appear unsafe.

M. Contractors. Contractors and/or contractor employees are responsible for their own safety programs and their own safe behavior; and, for alerting their supervisor or other proper authority of conditions, procedures, or the behavior of others that appear unsafe.

FLETC Manual 70-09

Chapter 3

OCCUPATIONAL SAFETY AND HEALTH STANDARDS

I. INTRODUCTION: The OSH Standards guidance is located in Chapter 3 of the DHS OSH Manual (DHS OSH Manual). The FLETC OSH Manual is a supplement to the DHS OSH Manual and does not require additional FLETC specific guidance on this chapter.

FLETC Manual 70-09 June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf

Chapter 4

OPERATIONAL RISK MANAGEMENT

I. INTRODUCTION: Workers are injured and killed in the workplace every day.

Workplace injuries and illnesses, however, can be prevented or minimized through operational risk management procedures which include looking at workplace operations, establishing proper job procedures, and ensuring that all employees are trained properly.

One of the best ways to determine and establish proper work procedures is to conduct a job hazard analysis/risk assessment (JHA/RA). Supervisors can use the findings of a JHA/RA to eliminate and prevent hazards in their workplaces. This is likely to result in fewer workplace injuries and illnesses; safer, more effective work methods; reduce workers’ compensation costs;

and increase worker productivity. The analysis also can be a valuable tool for training new employees in the steps required to perform their jobs safely.

FLETC Training Divisions utilize JHAs/RAs to identify hazards in training courses and control measures that are required to reduce and/or minimize hazards. RAs are attached to all lesson plans as per the guidance provided for the FLETC Training Divisions. Guidance on RAs for lesson plans is covered in the FLETC Directive: Risk Assessment for Courses of Instruction. All non-training divisions with identified/potential hazards will have a completed JHA/RA performed as required.

II. SCOPE: This supplement applies to all FLETC training delivery points and contains elements that apply to all FLETC employees and PO staff.

III. REFERENCES:

A. 29 CFR §1910.132, Personal Protective Equipment.

B. FLETC Directive 066-01 Training Risk Assessment, dated February 2013.

C. DHS OSH Manual (DHS OSH Manual).

IV. FORM: FLETC Form FTC-ESD-70a, Job Hazard Analysis (Job Hazard Analysis).

V. DEFINITIONS:

A. Hazard has the potential to harm and is associated with a condition or activity that, if left uncontrolled, could result in an injury or occupational illness.

B. JHA/RA is a process to identify physical and health hazards in the workplace.

Potential hazards may be physical or health-related and a comprehensive hazard assessment should identify hazards in both categories. Examples of physical hazards include moving objects, fluctuating temperatures, high intensity lighting, rolling or pinching objects, electrical connections and sharp edges. Examples of health hazards include overexposure to harmful dusts, noise, chemicals or radiation.

C. Personal Protective Equipment (PPE) is equipment worn to minimize exposure to a variety of hazards. Examples of PPE include such items as gloves, foot and eye protection, protective hearing devices (earplugs, muffs) hard hats, respirators and full body suits (see Chap.

11 Personal Protective Equipment).

FLETC Manual 70-09 June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20Form%202%20-%20FTC-ESD-70a%20Job%20Hazard%20Analysis%20Rev.pdf

VI. RESPONSIBILITIES:

A. FLETC Safety Staff will:

1. Provide oversight of the Operational Risk Management Program.

2. Assist supervisors and/or division risk assessment work groups in determining what control measures are required according to the hazard exposure.

3. Assist supervisors and/or division risk assessment work groups with choosing the appropriate PPE, if required, for protecting employees from hazard exposures.

4. Review JHAs/RAs provided by divisions/supervisors to ensure measures are utilized to control workplace hazards and to evaluate if employees require medical surveillance physicals.

B. Supervisors will:

1. Complete or assign an RA work group to complete a JHA for each job task that potentially exposes employees to hazards.

2. Ensure employees are educated in:

a. The potential hazards associated in performing their job tasks as identified in their JHA/RA.

b. The control measures required to protect against exposure to hazards.

c. The proper use, care, maintenance, storage, and inspection of any required

PPE.

3. Request assistance from the FLETC Safety Staff as needed in completing

JHAs/RAs to include identifying hazards; determining control measures; and ensuring PPE is appropriate and approved by the FLETC Safety Staff.

C. Employees will know:

1. The potential for exposure to hazards in their job tasks/workplace.

2. The requirement to ensure control measures are in place and utilized to reduce or eliminate the hazard exposures.

3. The PPE required, if any, for use during a job tasks to protect them from exposure to hazards.

4. How to report a hazard or unsafe/unhealthful working conditions (see Chap. 8, Employee Reports of Unsafe/Unhealthful Working Conditions).

VII. PROGRAM ELEMENTS:

A. Jobs that require priority when conducting a JHA/RA:

1. Jobs with the highest injury or illness rates;

2. Jobs with the potential to cause severe or disabling injuries or illness, even if there is no history of previous accidents;

3. Jobs in which one human error could lead to a severe accident or injury;

FLETC Manual 70-09

4. Jobs that are new or have undergone changes in processes and procedures; and

5. Jobs complex enough to require written instructions.

B. Steps in conducting a JHA/RA.

1. Involve employees. They have a unique understanding of their job and their knowledge is invaluable for finding hazards.

2. Review accident history reports. Review the history of accidents, occupational illnesses, OSHA recordable injuries and near misses. This information may identify existing hazard controls that may not be adequate or new hazards in the workplace.

3. Conduct a preliminary job review. Discuss with employees the hazards they know exist in their current work and surroundings. Identify ideas to eliminate or control those hazards.

a. If any hazards exist that pose an immediate danger to an employee’s life or health, take immediate action to protect them.

b. Any problems that can be corrected easily should be corrected as soon as possible. Do not wait to complete your JHA/RA.

4. Outline the job steps or tasks.

a. Select an experienced, cooperative worker and watch the employee perform the job and list each step as the worker performs it.

b. Be sure to record enough information to describe each job action without getting overly detailed.

C. Identifying workplace hazards. Ask the following questions:

1. What can go wrong?

2. What are the consequences?

3. How could it happen?

4. What are other contributing factors?

5. How likely is it that the hazard will occur?

D. Hazard/Risk Categorization. Unabated risks are categorized using a Risk Assessment Code (RAC) Matrix. This matrix uses the combination of assessment of hazard severity and mishap probability to obtain a single number rating. This number is used to determine the appropriate priority in correcting the identified hazard versus all other identified hazards.

1. Hazard Severity. This is an assessment of the worst potential consequence, defined by the actual or potential degree of injury, occupational illness or property damage, which is likely to occur as a result of the hazard.

a. Category I - Catastrophic: The hazard will or may cause death or loss of a facility.

FLETC Manual 70-09

b. Category II - Critical: The hazard will or may cause severe injury, severe occupational illness, or major property damage.

c. Category III - Marginal: The hazard will or may cause minor injury, minor occupational illness or minor property damage.

d. Category IV - Negligible: The hazard involves a violation of a federal or state health and/or safety standard(s) or the FLETC program or policy, but is unlikely to cause injury, illness or property damage.

2. Mishap Probability. This is an assessment of the likelihood of a given health or safety deficiency or hazard producing a mishap. The assessment is based on such factors as location, exposure frequency and affected population or group.

a. Category A: Likely to occur immediately or within a short period of time.

b. Category B: Probably will occur in time.

c. Category C: May occur in time.

d. Category D: Unlikely to occur.

3. RAC Matrix. This is the expression of total risk combining hazard severity and mishap probability. Using the matrix shown, the RAC is expressed as a single number. This value can be used to assign hazard abatement priorities.

RAC Matrix

Hazard Severity

Mishap Probability

A Likely to occur immediately or within a short period of time

B Probably will occur in time

C May occur in time

D Unlikely to occur

I 1 1 2 3

II 1 2 3 4

III 2 3 4 5

IV 3 4 5 5

E. Develop control measures to eliminate or reduce the hazards.

1. Engineering Controls.

FLETC Manual 70-09

a. The most effective and should be first priority;

b. Eliminate/minimize the hazard by physically changing a machine or work environment;

c. Enclosure of the hazard (good for noisy environments);

d. Isolation of the hazard (machine guards, welding curtain); and

e. Removal or redirection (local and exhaust ventilation).

2. Administrative Controls.

a. Involves changing how employees do their jobs;

b. Limit exposure time;

c. Utilize written operating procedures;

d. Alarms, signs and warnings;

e. Use of the buddy system; and

f. Training.

3. PPE. This includes respirators, hearing protection, protective clothing, safety glasses, hardhats, safety shoes, gloves, etc. PPE is acceptable in the following circumstances:

a. When engineering controls are not feasible or do not totally eliminate the hazard;

b. While engineering controls are being developed;

c. When safe work practices do not provide sufficient additional protections;

d. During emergencies when engineering controls may not be feasible; and

e. When a hazard cannot be eliminated entirely, the adopted control measures are likely to be a combination of all three measures instituted simultaneously.

F. Evaluate the effectiveness of control measures.

1. Assess control measures to ensure they are effective in eliminating or minimizing the hazards in the workplace.

2. Assess the effectiveness of required PPE in protecting the employee from the exposure to the hazards.

3. If control measures are not effective, review the JHA/RA and initiate additional control measures as required.

G. Review of JHA.

1. Periodically review the JHA to ensure it remains current and continues to reduce workplace accidents and injuries.

2. Should be reviewed whenever an illness or injury occurs on a specific job to prevent similar incidents in the future.

H. Training.

FLETC Manual 70-09

1. Required by employees prior to exposure to hazards in the workplace.

a. Educates them in the hazards;

b. Steps to perform their job safety;

c. Control measures in place;

d. How and when to wear PPE if required, to include care and storage; and

e. How to report hazards in the workplace (see Chap. 8, Employee Reports of

Unsafe/Unhealthful Working Conditions).

2. When a JHA/RA has been revised employees require training in the changes of the new job methods, procedures, or protective measures adopted.

FLETC Manual 70-09

Chapter 5

COUNCILS AND COMMITTEES

I. INTRODUCTION: The Councils and Committees guidance is located in Chapter 5 of the DHS OSH Manual (DHS OSH Manual). The FLETC OSH Manual is a supplement to the DHS OSH Manual. Additional FLETC specific guidance can be found in the FLETC Safety Committee Charter (development process July 2018).

FLETC Manual 70-09 June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf

Chapter 6

SAFETY & HEALTH ASSESSMENT PROGRAM

I. INTRODUCTION: Section 19(a) of the OSH Act of 1970 requires that all employees be provided a safe and healthy place of employment. To ensure that this requirement is met, FLETC requires assessments or inspections of all workplaces to ensure potential hazards are identified. Workplace safety is everyone’s responsibility. Both the hazard reporting process and the Safety and Health Assessment Program inspection process will be used to identify and evaluate hazards at FLETC facilities. This program provides the procedures for the inspection of all FLETC buildings and work areas.

II. SCOPE: This program applies to all FLETC training delivery points and contains elements that apply to all FLETC employees, PO staff, students, visitors, and contractor personnel.

III. REFERENCES:

A. 29 CFR §1960.25-31, Inspection and Abatement.

B. 29 CFR §1910, OSHA General Industry Standards.

C. NFPA 101, Life Safety Code.

D. IBC, International Building Codes.

E. EM-385-1-1, Engineers Manual, U.S. Army Corps of Engineers (USACE) Safety and

Health requirements.

F. DHS OSH Manual (DHS OSH Manual).

IV. FORMS:

A. FLETC Form FTC-ESD-31 Safety Inspection Form (Safety Inspection).

V. DEFINITIONS: None.

VI. RESPONSIBLITIES:

A. FLETC Safety Staff will:

1. Perform safety and health inspections at least annually in all workplaces, classrooms, training areas and offices.

2. Perform pre-occupancy/pre-acceptance safety inspections of all new or remodeled buildings upon notification from FLETC Facilities Management Project Managers.

The Project Manager should accompany the FLETC Safety Staff during the inspection.

3. Perform brief informal building inspections as needed whenever they walk through a building or training facility on other business.

4. Perform follow-up building inspections as needed to ensure abatement of serious hazards identified during the recent inspection.

B. FLETC Facilities Management Project Manager will:

1. Be responsible for all abatement actions identified by FLETC Safety Staff on new or remodeled buildings during the pre-occupancy/pre-acceptance safety inspections.

FLETC Manual 70-09 June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20Form%203%20-%20FTC-ESD-31%20Annual%20Safety%20Inspection%20Rev%20Mar2018.pdf

2. Be responsible for reporting the status of abatement actions to FLETC Safety Staff to include when the abatement actions will be completed.

C. Supervisors will:

1. Perform daily informal walkthrough inspections of their assigned worksites to monitor compliance with safety and health requirements;

2. Reinforce safe work behaviors amongst their employees;

3. Make on-the-spot corrections of unsafe conditions and behaviors; and

4. Notify FLETC Safety Staff when guidance or assistance is required on safety and health issues in their work areas.

D. FLETC Employees, PO Staff, Students, Visitors, and Contractors will:

1. Take an active role in identifying and reporting potential occupational safety or health hazards in their work areas.

2. Contractors will report any potential hazards on their worksites to their safety officer, quality assurance coordinator or other personnel as designated by their company policy.

VII. PROGRAM ELEMENTS:

A. Safety and Health Inspection of Buildings and/or Work Areas.

1. FLETC Safety Staff and other designated competent employees will perform safety and health inspections at least annually in all workplaces, classrooms, training areas and offices.

2. Pre-occupancy/pre-acceptance safety inspections of all new or remodeled buildings will be performed upon notification from facilities management project managers.

3. The inspection process includes but is not limited to assessment for Life Safety Code compliance; walking and working surfaces to include stairs and ladders; electrical safety;

hazardous materials; and general safety such as exterior lighting and other exterior building hazards.

B. FLETC Safety and Health Inspection Report.

1. The inspections will be documented on the Safety Inspection Form and the type of inspection will be noted.

2. Both positive and negative findings will be identified.

3. Every reasonable attempt will be made by the safety inspector to allow for on-the-spot corrections of safety and health deficiencies; however, the judgment of the safety and health inspector regarding whether a deficiency will be recorded and reported will be final.

4. All findings will be forwarded to the party responsible to correct the deficiency (i.e. Facilities Maintenance, Facilities Maintenance Project Manager, contractor, COTR, division/workgroup, etc.). A request for work orders will be emailed to facilities and a work order number will be assigned.

5. A prospective follow-up inspection date, if needed to ensure correction of identified deficiencies, will be performed.

FLETC Manual 70-09

6. The building inspection program coordinator at each FLETC training delivery point will track inspections to ensure they are performed at the scheduled time at least annually. Each inspector will track deficiencies and corrective actions to completion.

Documentation of corrective actions including emails will be attached to the Safety Inspection Form once completed.

7. Safety and health inspections will be maintained in FLETC Safety Staff files in accordance with established filing requirements and/or databased with supporting documentation in an inspection program computer file. A copy of the annual safety and health inspection will be provided to the division/workgroup to maintain on file and ensure deficiencies are corrected.

FLETC Manual 70-09

Chapter 7

INCIDENT REPORTING, RECORDS AND INVESTIGATIONS PROGRAM

I. INTRODUCTION: The purpose of this program is to establish the guidelines for FLETC employees to report mishaps (“near misses”, “close calls”, and “accidents”) without fear of retribution or punishment; and to establish a mishap investigation and reporting system which emphasizes lessons learned and prevention. The principle goal of any mishap investigation will be to provide the FLETC Director a clear determination of the root cause of the mishap.

Additional purposes include: identifying ways to engineer-out mishap opportunities, tracking corrective actions, accomplishing all reporting responsibilities, and identifying trends in mishaps to include student mishaps. PO staff, visitor and contractor mishaps will also be reviewed to ensure FLETC poses no hazards to other personnel.

II. SCOPE: This program applies to all FLETC training delivery points and contains elements that apply to all FLETC employees, PO staff, students, visitors, and contractor personnel.

III. REFERENCES:

A. 29 CFR §1904, Recording and Reporting Occupational Injuries and Illnesses.

B. DHS OSH Manual (DHS OSH Manual).

IV. FORMS: FTC-ESD-20 FLETC Injury Information Form (Injury Information Form).

V. DEFINITIONS:

A. Mishap is an unpredictable event that results in an accident, incident, or near miss.

B. Accident is an undesired event that results in personal injury or property damage.

C. Incident is an unplanned, undesired event that adversely affects completion of a task.

D. Near miss describes incidents where no property was damaged and no personal injury sustained, but where, given a slight shift in time or position, damage and/or injury easily could have occurred.

VI. RESPONSIBILITIES:

A. FLETC Safety Staff will:

1. Provide management an oversight of FLETC Mishap Program.

2. When requested, provide information on mishap analysis and reporting to supervisors, division chiefs, deputy assistant directors, assistant directors, site directors and FLETC Director.

3. Brief the FLETC Safety Committee of any trends in mishaps and illnesses so the divisions can address the issues and implement measures to prevent reoccurrence of mishaps.

Due to the sensitive and confidential nature of the information, it will be summarized without the names of affected individuals.

4. Shall report, by telephone, any incidents that fall under the OSHA mishap reporting regulations to the DHS Safety and Health Manager and to the Area OSHA Safety Office in conjunction with other reporting requirements as directed.

B. Supervisors will:

FLETC Manual 70-09

June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20Form%204%20-%20FTC-ESD-20%20Injury%20Information%20Form%20Rev.pdf

1. Contact FLETC Safety Staff by telephone or e-mail immediately after a serious mishap has occurred and provide details of the mishap to include any safety hazards that require immediate abatement.

2. Initiate and document an investigation of mishaps as soon as possible.

3. Ensure the affected employee completes the documentation of injury (CA-1) and the mishap form (OSHA 301) in FLETC ECOMP reporting system within one working day of the mishap. If the injured employee is unable to complete the entries into ECOMP, the supervisor can complete them on behalf of the employee. The Supervisor will also review the information provided and approve the forms in ECOMP within three (3) working days.

4. Provide required information to FLETC Safety Staff on the status of the affected employee which will assist in determining if the mishap is OSHA recordable. Information to include, but not limited to:

a. Restricted/Limited duty days,

b. Transfer to other duty days,

c. Number of lost time days that equal full 8 hour days to include calendar date(s),

d. The first day the employee returns to normal work duty,

e. Any known medical treatment received such as sutures, cast, surgery, etc., and

f. If prescriptions related to mishap received.

5. Update FLETC Safety Staff on the status of the affected employee as changes occur.

C. FLETC Employees will:

1. Immediately, if possible, notify their supervisor by any means, or within 8 hours of a mishap occurrence and enter documentation of injury (CA-1) to include completing the mishap form (OSHA 301) in FLETC ECOMP reporting system.

2. Provide all information to their supervisor relating to the incident to include, if applicable, but not limited to:

a. Number of restricted/limited duty days as recommended by the physician,

b. Medical treatment received such as sutures, cast, surgery, etc., and

c. Prescriptions received related to mishap.

3. Provide written approval from their physician to return to normal work duty in cases where the mishap resulted in restricted/limited duty and/or job transfer.

D. PO Staff and Student Employees will:

1. Immediately, if possible, notify their supervisor by any means, or within eight hours of a mishap occurrence. Follow agency mishap reporting requirements to include, if applicable, entering documentation of injury (CA-1) to include completing the mishap form (OSHA 301) in the agency ECOMP reporting system.

FLETC Manual 70-09

2. If seen by medical professional, either Health Unit or a local hospital:

a. Complete an Injury Information Form at the Health Unit,

b. Provide documentation of visit to supervisor/class coordinator, and

c. If a student, must follow-up at the Health Unit, if applicable, immediately after being seen or if after hours, the next working day morning before attending class.

E. Contractor staff will:

1. Immediately, if possible, notify their supervisor by any means, or within 8 hours of a mishap occurrence. Note: contractors are responsible for their own safety programs and documentation of injuries to include entry on the contractor OSHA 300, if applicable.

2. Provide documentation of injuries to FLETC Contracting Officer to be forwarded to ESD for mishap review.

F. Visitors will:

1. Report any injuries to their sponsor.

2. Provide a statement, if possible, concerning the injury to their sponsor and/or

FLETC security staff.

VII. PROGRAM ELEMENTS:

A. Mishap Control Methods:

1. FLETC will utilize engineering controls, administrative controls and/or PPE to remove, minimize exposure and/or protect any persons from hazards identified to be relevant to occupational injury or illness incidents and work areas throughout FLETC.

2. Engineering controls will be the primary means to implement for removal of hazardous condition(s) if possible.

3. Administrative controls will be secondary in implementation if engineering controls are not possible.

4. PPE will be the last control utilized only when the hazardous condition(s) or exposure to the condition(s) cannot be removed through the use of the previous controls (See DHS OSH Manual, Ch. 9, Prevention and Control of Workplace Hazards).

B. Recordkeeping:

1. After receipt of a mishap in FLETC ECOMP reporting system, FLETC Safety

Staff will review the mishap form, supervisor’s comments/investigation information and will complete the OSHA Record-Keeper Review section in ECOMP.

2. FLETC Safety Staff will prepare a mishap case file for each separate mishap investigation which may include field inspection records, correspondence, photographs, and other information pertinent to the work-related injury or illness.

3. All mishaps will be investigated and analyzed for cause by FLETC Safety Staff.

Mishaps due to reported safety hazards will be investigated as soon as possible, but not later than three (3) working days after the mishap occurred. Analysis will include a thorough examination of the accident location and interviews with involved persons and witnesses as required.

FLETC Manual 70-09

4. FLETC Safety Staff will document all recordable mishaps and illnesses on the OSHA 300 log within seven (7) days of notification or sooner. A recordable injury or illness must be recorded if it results in one or more of the following:

a. Death;

b. Days away from work;

c. Restricted work or transfer to another job;

d. Medical treatment beyond first aid;

e. Loss of consciousness; or

f. A significant injury or illness diagnosed by a physician or other licensed health care professional such as, but not limited to, a fracture or ruptured eardrum.

5. FLETC field sites (Artesia, Charleston, Cheltenham) will notify the FLETC

Safety Mishap Program Manager at Glynco of any and all mishap occurrences that meet the OSHA recording and reporting criteria, to include all pertinent information for serious mishaps or deaths at the field sites. Note: each field site is responsible for keeping the OSHA 300 log for their respective sites and following all requirements of this program to include reviewing their site ECOMP mishap entries.

6. FLETC field sites will also provide FLETC Mishap Program Manager at Glynco a copy of their OSHA 300 log and other pertinent information requested, for input to the Annual OSHA Report to the DHS OSH Manager. FLETC Mishap Program Manager will notify the field sites of the annual suspense date for this requirement.

7. Each FLETC site will post a copy of the previous year’s OSHA Form 300A from February 1 through April 30 at highly visible locations throughout their facilities.

8. Mishap documentation will be filed and retained for five (5) years following the end of the applicable calendar year.

C. Training:

1. FLETC employees are required to be familiar with the requirements of the

Incident Reporting, Records and Investigations Program.

2. During in-processing by the Human Capital Office (HCO), the Office of

Worker’s Compensation (OWCP) provides the guidance on employee roles and responsibilities such as reporting mishaps, filling out CA-1s and OSHA 301s in ECOMP, and any other documentation requirements.

3. Through the Initial Safety Awareness Training provided on the DHS Performance and Learning Management System (PALMS), all new employees shall receive and review guidance on mishap notification procedures and documentation requirements.

FLETC Manual 70-09

Chapter 8

EMPLOYEE REPORTS OF UNSAFE/UNHEALTHFUL WORKING CONDITIONS

I. INTRODUCTION: Identification and reporting of potentially unsafe or unhealthful working conditions is the responsibility of all FLETC employees. Since many conditions can be eliminated as soon as they are identified and reported, effective oral and written communication is imperative. The purpose of this program is to provide guidance to FLETC employees on how to report hazards and the process of investigating hazards.

II. SCOPE: This program applies to all FLETC training delivery points and contains elements that apply to all FLETC employees, PO staff, students, visitors and contractor personnel.

III. REFERENCES:

A. 29 CFR §1960.25-31 Inspection and Abatement.

B. DHS Manual (DHS OSH Manual).

IV. FORMS: FLETC Form FTC-ESD-7, Hazard Report of an Unsafe or Unhealthful Working Condition (Hazard Report).

V. DEFINITIONS:

A. Hazard, has the potential to harm and is associated with a condition or activity that, if left uncontrolled, can result in an injury or occupational illness.

B. Hazard report is documentation of a suspected or known hazard for reporting and investigation.

VI. RESPONSIBILITES:

A. FLETC Employees, PO Staff, Students and Visitors will:

1. Take an active role in identifying and reporting potential occupational safety or health hazards.

2. It is FLETC policy that no employee or student at any FLETC location will be restrained, interfered with, coerced, discriminated against or suffer reprisal for:

a . Reporting a potential health or safety hazard;

b . Participating in an inspection related to that hazard;

c . Participating in follow-up abatement/corrective actions;

d . Providing evidence or supporting documents to the FLETC Safety Staff, or any health or safety inspector; and e . Participating in FLETC Safety Committee meetings and activities.

B. Contractors will: Report any potential hazards on their worksites to their safety officer, quality assurance coordinator, or other personnel as designated by their company policy.

FLETC Manual 70-09 June 2019 https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20-%20DHS%20Safety%20Manual%202010.pdf https://fletcconnect.fletcnet.dhs.gov/do/DirectivesDelegations/Forms%20for%20Directive%20Links/FD%2070-09%20Form%205%20-%20FTC-ESD-07%20Hazard%20Report%20Form%20Rev.pdf

VII. PROGRAM ELEMENTS:

A. Reporting. Reports of potential unsafe/unhealthful working conditions can be made in any of three ways depending on the severity of the hazard by:

1. Verbally, in writing or by e-mail to the reporting employee’s supervisor or to

FLETC Safety Staff. When a supervisor receives a hazard report, they should immediately contact FLETC Safety Staff and report it. FLETC Safety Staff will investigate the potential hazard and take appropriate action, typically in conjunction with the Facilities Maintenance Division.

2. Completing a FLETC Hazard Report of an Unsafe or Unhealthful Working Condition form and submitting it to FLETC Safety Staff by guard mail. Under this method, the employee may remain anonymous.

3. Calling FLETC Security Staff who will notify FLETC Safety Staff of a potential hazard(s) that require immediate action.

B. Investigation of Hazard Reports.

1. Upon receipt of a FLETC Hazard Report of an Unsafe or Unhealthful Working

Condition form, FLETC Safety Staff will contact the originator (unless anonymous) by telephone to acknowledge receipt and to discuss the reported hazard.

2. FLETC Safety Staff will contact the supervisor of the process, operation or location that was the subject of the hazard report.

3. FLETC Safety Staff will investigate all reports brought to their attention.

4. Reports of cases involving potential imminent dangers will be investigated in all cases on the day the report is received.

5. Reported hazards determined to be potentially serious in nature, but not a threat of imminent danger, will be investigated within three (3) working days upon receipt.

6. Reports of alleged hazards categorized as other than serious will be investigated within five (5) working days upon receipt of the report.

7. If the alleged hazard involves a potential traffic safety issue, FLETC Safety

Staff will involve the Office of Security and Professional Responsibility, or other appropriate security authority, and request their participation in the investigation, if applicable.

C. Response to a Hazard Report.

1. FLETC Safety Staff will provide an interim response, in writing, to the originator of the hazard report, upon request (unless anonymous), within 15 working days upon receipt.

2. If the investigation validates the reported hazard, the employee who initiated the hazard report, upon request (unless anonymous), will be provided a complete response including a summary of the action to be taken for abatement, the supervisor or manager who will be responsible of ensuring completion of the action and the anticipated remediation date.

FLETC Manual 70-09

Finding of No Significant Hazard. If the investigation does not identify a hazard, FLETC Safety Staff will notify the employee, upon request (unless anonymous), the basis for the determination and offer the individual initiating the hazard report the opportunity to appeal the results.

D. Appeals of Hazard Report Investigation Conclusions.

1. In the event the individual initiating a hazard report disagrees with the response they receive, the individual may appeal in writing.

2. Appeals will be reviewed by the ESD Chief and the DSHO. For field sites, the Site Director will review the appeal and request assistance from the Glynco ESD Chief and/or DSHO as needed. He/she will respond within 10 working days.

3. Further appeals will follow the procedure contained in the DHS OSH Manual.

FLETC Manual 70-09

Chapter 9

PREVENTION AND CONTROL OF WORKPLACE HAZARDS

I. INTRODUCTION: The Prevention and Control of Workplace Hazards guidance is located in Chapter 9 of the DHS OSH Manual (DHS OSH Manual). FLETC OSH Manual is a supplement to the DHS OSH Manual and provides additional FLETC specific guidance in Chapter 4, Operational Risk Management.

FLETC Manual 70-09 June 2019…