ATTACHMENT J.5_Site-Wide_Health_And_Safety_Plan_IFB_72044020B00001 BH IM2.pdf

DISCLAIMER:

THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR

INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.

DIOXIN REMEDIATION AT BIEN HOA

AIRBASE AREA PROJECT

INITIAL SITE-WIDE HEALTH & SAFETY PLAN

DECEMBER 5, 2019

This publication was produced for review by the United States Agency for International Development.

DISCLAIMER:

THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR

INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.

DIOXIN REMEDIATION AT BIEN HOA

AIRBASE AREA PROJECT

INITIAL SITE-WIDE HEALTH & SAFETY

PLAN

US AGENCY FOR INTERNATIONAL DEVELOPMENT

CONTRACT NUMBER: AID-OAA-I-15-00053

ORDER NUMBER: 72044019F00001

DECEMBER 5, 2019

PREPARED BY

TRIGON ASSOCIATES, LLC

1515 POYDRAS ST. SUITE 2200

NEW ORLEANS, LA 70112

USA

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | i

CONTENTS

CONTENTS I

TABLES IV

FIGURES IV

RECORD OF REVISIONS V

ACRONYMS AND ABBREVIATIONS VI

1 SIGNATURE SHEET 1-1

2 BACKGROUND INFORMATION 2-1

2.1 PROJECT INFORMATION AND BACKGROUND 2-1

2.2 CONTRACTOR INFORMATION 2-1

2.3 SCOPE 2-2

3 SAFETY AND HEALTH POLICY STATEMENT 3-1

3.1 PROJECT SAFETY AND HEALTH POLICY STATEMENT 3-1

3.2 PROJECT SAFETY GOALS 3-1

3.3 SITE-WIDE HEALTH AND SAFETY PLAN DESCRIPTION 3-2

4 RESPONSIBILITIES AND LINES OF AUTHORITIES 4-3

4.1 KEY PROJECT PERSONNEL 4-3

4.2 KEY PROJECT PERSONNEL SAFETY AND HEALTH RESPONSIBILITIES 4-2

4.3 DESIGNATED COMPETENT PERSONS 4-1

4.4 PRE-TASK SAFETY AND HEALTH ANALYSIS 4-1

4.5 SAFETY COMPLIANCE AND ENFORCEMENT 4-2

4.5.1 GENERAL SAFE WORK PRACTICES 4-2

4.5.2 SAFE WORK PRACTICES FOR USE OF TOOLS, EQUIPMENT AND

MACHINERY 4-2

4.5.3 SAFE WORK PRACTICES FOR OPERATION OF MOTOR VEHICLES AND

HEAVY EQUIPMENT 4-3

4.5.4 SAFETY RULE ENFORCEMENT 4-3

5 SUBCONTRACTORS AND SUPPLIERS 5-4

5.1 LIST OF SUBCONTRACTORS 5-4

5.2 SELECTION OF QUALIFIED SUBCONTRACTORS 5-4

5.3 SUBCONTRACTOR SAFETY REQUIREMENTS 5-5

6 TRAINING 6-6

6.1 GENERAL TRAINING REQUIREMENTS 6-6

6.2 SITE ORIENTATION BRIEFING 6-7

6.3 DIOXIN MEDICAL SURVEILLANCE PROGRAM ORIENTATION 6-8

6.4 SAFETY MEETINGS 6-8

6.5 EMERGENCY RESPONSE PLAN TRAINING 6-9

7 SAFETY AND HEALTH INSPECTIONS 7-9

7.1 SAFETY INSPECTIONS 7-9

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7.2 SAFETY AUDITS 7-11

8 INCIDENT REPORTING AND INVESTIGATION 8-11

8.1 INCIDENT REPORTING 8-11

8.2 INCIDENT INVESTIGATION 8-12

8.3 INCIDENT FOLLOW-UP 8-13

8.4 MONTHLY EXPOSURE REPORT 8-14

9 PLANS AND PROGRAMS REQUIRED BY THE SAFETY MANUAL 9-1

9.1 FATIGUE MANAGEMENT PLAN 9-2

9.2 EMERGENCY PLANS 9-3

9.2.1 EMERGENCY PLAN: PROCEDURES AND TESTS 9-3

9.2.2 EMERGENCY PLAN: FIREFIGHTING PLAN 9-5

9.2.3 EMERGENCY PLAN: POSTING OF EMERGENCY TELEPHONE NUMBERS 9-6

9.2.4 EMERGENCY PLAN: SEVERE WEATHER 9-8

9.2.5 EMERGENCY PLAN: SPILL PREVENTION AND CONTROL PLAN 9-9

9.2.6 MEDICAL EMERGENCY PROCEDURES PLAN 9-9

9.2.7 FIRST AID AND CARDIOPULMONARY RESUSCITATION AVAILABILITY

PROGRAM 9-10

9.2.8 BLOODBORNE PATHOGENS PROGRAM 9-10

9.2.9 EMERGENCY DECONTAMINATION PROVISIONS PLAN 9-10

9.3 SITE SANITATION/HOUSEKEEPING PLAN 9-11

9.3.1 HOUSEKEEPING 9-11

9.3.2 DRINKING WATER 9-11

9.3.3 NON-POTABLE WATER 9-11

9.3.4 TOILETS 9-12

9.3.5 WASHING FACILITIES 9-12

9.3.6 WASTE DISPOSAL 9-12

9.4 MEDICAL SUPPORT AGREEMENT AND FIRST AID AVAILABILITY PROGRAM 9-13

9.5 BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN 9-13

9.6 SITE LAYOUT PLAN FOR TEMPORARY SITE FACILITIES 9-13

9.7 ACCESS AND HAUL ROAD PLAN 9-14

9.8 PERSONAL PROTECTIVE AND SAFETY EQUIPMENT, HEARING CONSERVATION,

RESPIRATORY PROTECTION PLAN 9-14

9.8.1 RESPIRATORY PROTECTION 9-15

9.8.2 HEARING CONSERVATION PROGRAM 9-16

9.9 HEALTH HAZARD CONTROL PROGRAM 9-17

9.9.1 CHEMICAL HAZARDS 9-17

9.9.2 BIOLOGICAL HAZARDS 9-17

9.9.3 MANUAL MATERIAL HANDLING HAZARDS 9-23

9.9.4 AIR CONTAMINANT HAZARDS 9-23

9.10 PPE REQUIREMENT PROGRAM 9-23

9.11 HAZARD COMMUNICATION PROGRAM 9-26

9.12 HEAT STRESS MONITORING AND PREVENTION PLAN 9-27

9.12.1 CONTRIBUTING FACTORS 9-27

9.12.2 HEAT STRESS PREVENTION PLAN 9-28

9.13 TRAFFIC CONTROL PLAN 9-30

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9.14 FIRE PREVENTION PLAN 9-31

9.14.1 FIRE PREVENTION PLAN INFORMATION 9-31

9.15 ASSURED EQUIPMENT GROUNDING CONDUCTOR PROGRAM 9-33

9.16 HAZARDOUS ENERGY CONTROL PROGRAM & PROCEDURES 9-34

9.16.1 DEFINITIONS 9-35

9.16.2 EQUIPMENT SURVEY 9-36

9.16.3 SELECTION OF LOCKS, TAGS, AND BLOCKS 9-36

9.16.4 WRITTEN STANDARD OPERATING PROCEDURE 9-37

9.16.5 PERIODIC INSPECTIONS 9-40

9.16.6 TRAINING 9-40

9.17 EXCAVATION/TRENCHING PLAN 9-40

9.17.1 DEFINITIONS 9-41

9.17.2 UTILITY CLEARANCE SURVEYS 9-42

9.17.3 OVERHEAD UTILITIES 9-43

9.17.4 PERIMETER GUARDING OF EXCAVATIONS 9-43

9.17.5 COMPETENT PERSON SUPERVISION AND INSPECTIONS 9-43

9.17.6 PERSONNEL ENTRY INTO A TRENCH OR EXCAVATION 9-44

9.17.7 PERSONNEL WORKING NEAR TRENCHES OR EXCAVATIONS 9-45

9.17.8 EXCAVATION PROCEDURES 9-45

9.17.9 SOIL CLASSIFICATIONS 9-46

9.17.10 EXCAVATION PROTECTION SYSTEMS 9-47

9.17.11 EXCAVATIONS GREATER THAN 20 FEET (6 METERS) DEEP 9-48

9.17.12 TRAINING 9-48

9.18 SHASP FOR HAZARDOUS, TOXIC OR RADIOACTIVE WASTE (HTRW) WORK 9-48

9.18.1 DIOXIN MEDICAL SURVEILLANCE PROGRAM 9-50

9.18.2 BLOOD SERUM DIOXIN MONITORING 9-52

9.18.3 CONTRACTOR AND SUBCONTRACTOR HEALTH AND SAFETY PLAN

REQUIREMENTS 9-58

9.19 SITE CONTROL MEASURES 9-58

9.19.1 CLEAN ZONE 9-58

9.19.2 CONTAMINATION REDUCTION ZONE 9-58

9.19.3 EXCLUSION ZONE 9-60

9.19.4 ACCESS CONTROL 9-60

10 RISK MANAGEMENT PROCESSES 10-63

10.1 HEALTH AND SAFETY PLAN FORMS 10-63

10.2 REPORTING OF HAZARDS AND SAFETY INSPECTIONS 10-63

APPENDIX A. HEALTH AND SAFETY PLAN FORMS A-1

APPENDIX B. HEALTH AND SAFETY OFFICER AND LSECS RESUMES B-1

APPENDIX C. LIST OF DESIGNATED COMPETENT PERSONS C-1

APPENDIX D. ACTIVITY HAZARD ANALYSES D-1

APPENDIX E. SUBCONTRACTOR LIST E-1

APPENDIX F. PROJECT PERSONNEL TRAINING INFORMATION F-1

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APPENDIX G. BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN G-1

APPENDIX H. HAZARD COMMUNICATION PROGRAM H-1

APPENDIX I. ASSURED EQUIPMENT GROUNDING CONDUCTOR

PROGRAM REQUIREMENTS I-1

APPENDIX J. LIST OF DESIGNATED FIRST AID RESPONDERS J-1

APPENDIX K. PERSONAL PROTECTIVE EQUIPMENT DONNING

PROCEDURES AND PERSONNEL DECONTAMINATION PROCESS K-1

APPENDIX L. DIOXIN MONITORING INFORMATION L-1

APPENDIX M. SHORT-FORM SUPPLEMENTAL HEALTH AND SAFETY PLAN

FORMAT (NON-INTRUSIVE SITE ACTIVITIES) M-1

TABLES

Table 4-1.Key Project Personnel ............................................................................................................................... 4-1 Table 4.2 Key Project Personnel Safety and Health Responsibilities ................................................................ 4-2 Table 6-1. Training Requirements ............................................................................................................................. 6-6

7.1. Table of Inspections* ............................................................................................................................................ 7-9 Table 9-1. Plans Required by EM 385-1-1 ................................................................................................................ 9-1 Table 9-2. Emergency Contact List ........................................................................................................................... 9-4 Table 9-3. Evacuation Alarm and Assembly Information ..................................................................................... 9-5 Table 9-4. Hygienic Works in Workplaces ........................................................................................................... 9-12 Table 9-5. Heat Stress Conditions .......................................................................................................................... 9-28 Table 9-6. Screening Criteria for TLV and Action Limit for Heat Stress Exposure .................................... 9-29 Table 9-7. General Clearances Required from Energized Overhead High-Voltage Conductors ............. 9-43 Table 9-8. Maximum Allowable Sloping ................................................................................................................. 9-47 Table 9-9. OSHA Safety and Health Program Cross-Reference Table .......................................................... 9-49 Table 9-11. Summary of 95th Percentile PCDD/F Congener Serum Lipid Concentrations....................... 9-56

FIGURES

Figure 2-1 Bien Hoa Airbase Site Map ...................................................................................................................... 2-1 Figure 8-1 Incident Reporting Flow Chart ............................................................................................................. 8-12 Figure 9-1 Vicinity Map of Dong Nai International Hospital and Emergency Hospital Route: ................... 9-7 Figure 9-2 Site Zones .................................................................................................................................................. 9-62

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RECORD OF REVISIONS

Revision Date Pages Revisions Approval

000 November 11, 2019 All Initial development/submittal of draft Health & Safety Plan. USAID CO/COR

001 December 5, 2019 All Response to USAID and Trigon Comments USAID CO/COR

001.1 June 23, 2020 9-7, M-10 Updated the map to the hospital Not applicable

001.2 August 10, 2020 2-1 Updated the overview map Not applicable

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ACRONYMS AND ABBREVIATIONS

% percent °C degree(s) Celsius °F degree(s) Fahrenheit A&E Architecture and Engineering ACGIH American Conference of Industrial

Hygienists ADAFC Air Defense Air Force Command AED Automatic External Defibrillator AEGCP Assured Equipment Grounding

Conductor Program AHA Activity Hazard Analysis ANSI American National Standards Institute APR Air purifying respirator BBP Bloodborne Pathogens CBC Complete Blood Count CDC Centers for Disease Control and

Prevention CFR Code of Federal Regulations CIH Certified Industrial Hygienist CIT Certified Instructional Trainer CM Construction Manager CO Contracting Officer COP Chief of Party COR Contracting Officer Representative CPM Contractor Project Manager CPR Cardiopulmonary Resuscitation CRZ Contamination Reduction Zone CSO Contractor Safety Officer CSP Certified Safety Professional CZ Clean Zone dB Decibels dBA Decibels measured on the A-Weighted scale DCOP Deputy Chief of Party Decon Decontamination EA Environmental Assessment EM 385-1-1 USACE Safety and Health Requirements

Manual EMR Experience Modification Rate EPA U.S. Environmental Protection Agency ERT Emergency Response Team EZ Exclusion Zone FMP Fatigue Management Plan GFCI Ground-fault Circuit Interrupter GHS Globally Harmonized System GPS Global Positioning System GVN Government of Vietnam HASP Health and Safety Plan Hazwoper Hazardous Waste Operations and

Emergency Response HBV Hepatitis B Virus HCS Hazard Communication Standard HCV Hepatitis C Virus HIV Human Immunodeficiency Virus HSO Health and Safety Officer HTRW Hazardous, Toxic, and Radioactive

Waste JECFA Joint Food and Agriculture

Organization/World Health

Organization Expert Committee on Food Additives km kilometer LEL Lower Explosive Limit LSECS Lead Safety and Environmental

Compliance Specialist m3 Cubic meter mA milliampere NHANES National Health and Nutrition

Examination studies NIOSH National Institute of Occupational Safety and Health OPIM Other Potentially Infectious Materials OSHA Occupational Safety and Health

Administration PCDD/F polychlorobenzodioxins and polychlorodibenzofurans PEL Permissible Exposure Limit (OSHA) pg/g picograms per gram pg/kg-day picograms per kilogram per day PPE Personal Protective Equipment QC Quality Control SAP/QAPP Site-Wide Sampling and Analysis

Plan/Quality Assurance Project Plan SAR Supplied air respirator SCBA Self-contained breathing apparatus SCPM Site Contractor Project Manager SDS Safety Data Sheet SHASP Supplemental HASP SMA Sequential Multi-channel Analysis SOP Standard Operating Procedure SWEMMP Site-Wide Environmental Mitigation and

Monitoring Plan TCDD 2,3,7,8-Tetrachlorodibenzodioxin TDI Tolerable Daily Intake TEF Toxicity Equivalence Factor TEQ Toxicity Equivalent TLV Threshold Limit Value tsf Tons per square foot TWA Total Weight Average U.S. United States USAID U.S. Agency for International

Development USACE U.S. Army Corps of Engineers USCG U.S. Coast Guard UXO Unexploded ordnance VPAF Vietnam People’s Air Force

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1 SIGNATURE SHEET

Dioxin Remediation at Bien Hoa Airbase Area Project

SITE-WIDE HEALTH & SAFETY PLAN SIGNATURE PAGE

United States Agency for International Development Contract Number: AID-OAA-I-15-00053

Order Number: 72044019F00001

November 2019

Plan Prepared By:

Lynne Black, CIT Health and Safety Officer; (434) 422-4656

Plan Reviewed By:

Michael R. Grasso, CIH, CSP Safety and Health Advisor (607) 201-6737

Plan Submitted By:

Sal Mansour Chief of Party

Plan Approval By:

Suzanne Johnson Contracting Officer

This Health & Safety Plan (HASP) has been prepared to meet the requirements of Government of Vietnam (GVN) Occupational Safety and Health standards, United States Occupational Safety and Health Administration (OSHA) standards found in Title 29 Code of Federal Regulations (CFR), Parts 1910 and 1926; and the United States Army Corps of Engineers (USACE) “Safety and Health Requirements Manual” (30 November 2014 edition) (EM 385-1-1).

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2 BACKGROUND INFORMATION

2.1 PROJECT INFORMATION AND BACKGROUND

Client: United States Agency for International Development (USAID) Project Name: Dioxin Remediation at Bien Hoa Airbase Area Project (Project) A&E Bien Hoa Contractor: Trigon Associates, Inc.

Contract Number: AID—OOAA-I-15-00053 Order Number: 72044019F00001

This Site-Wide HASP has been prepared for USAID under the Task Order 72044019F00001, Contract Number AID—OOAA-1-15-00053 by the A&E Bien Hoa Contractor. This Site-Wide HASP presents the Dioxin Remediation at Bien Hoa Airbase Area Project (Project) health and safety procedures that apply to Project personnel and activities. This HASP applies to Project activities including site investigations/evaluations, remediation, construction, and post-construction activities. USAID requires compliance with this Site-Wide HASP by Project Contractors, base personnel, and associated third parties to ensure a safe work environment for Project personnel.

The Project location is the Bien Hoa Airbase Area which includes the Bien Hoa Airbase and associated off-Airbase locations (Figure 2-1). The Bien Hoa Airbase is an active Air Defence Air Force Command (ADAFC) airbase located in Bien Hoa City, Dong Nai Province, approximately 30 kilometers (km) northeast of Ho Chi Minh City. The Bien Hoa Airbase property is located within the Tan Phong Ward and is adjacent to the Trung Dung, Quang Vinh, and Buu Long Wards, which are densely populated residential neighborhoods.

The Bien Hoa Airbase Area is one of three major dioxin contamination hotspots in Vietnam identified through studies completed in the 1990s. Bien Hoa, along with Phu Cat and Danang Airport, were used by the United States (U.S.) military for the import, storage, and loading of Agent Orange between 1961 and 1971. In 2016, USAID, in close collaboration with the GVN, completed the "Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase". The overall objective of the Environmental Assessment (EA) was to inform potential future actions at the Bien Hoa Airbase Area to address dioxin-related contamination. The EA serves as the primary resource documenting characterization of dioxin contamination on and around the Bien Hoa Airbase Area.

2.2 CONTRACTOR INFORMATION

This Site-Wide HASP applies to Project personnel and activities. Project activities will be implemented by the Project Contractors including the A&E Bien Hoa Contractor. Project Contractors will be identified through awards by USAID to implement the dioxin remediation activities at the Bien Hoa Airbase Area.

USAID is expected to specify particular health and safety requirements for each contractor in these awards. However, in general, this HASP will be an essential guide for all contractors and establishes the minimum safety and health requirements for Project Contractors and personnel to follow.

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2.3 SCOPE

This Site-Wide HASP defines the required Project health and safety procedures and programs that apply to Project personnel and activities. Project workers speak either English and/or Vietnamese, and safety and training material will be made available in the appropriate language through either written or oral translation. As the Project progresses, supplemental HASPs (SHASPs) will be prepared by the Project Contractors (including the A&E Bien Hoa Contractor) for site investigations/evaluations, remediation, construction, and post-construction activities. The types of activities may expand to include confined space entry, electrical, and elevated work depending on the Project needs. These SHASPs will comply with this Site-Wide HASP and be included as annexes. The A&E Bien Hoa Contractor is responsible for maintaining this Site-Wide HASP and implementing those portions of the Site-Wide HASP assigned to it.

This Health & Safety Plan (HASP) has been prepared to meet the requirements of Government of Vietnam (GVN) Occupational Safety and Health standards, United States Occupational Safety and Health Administration (OSHA) standards found in Title 29 Code of Federal Regulations (CFR), Parts 1910 and 1926; and the United States Army Corps of Engineers (USACE) “Safety and Health Requirements Manual” (30 November 2014 edition) (EM 385-1-1).

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FIGURE 2-1 BIEN HOA AIRBASE SITE MAP

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3 SAFETY AND HEALTH POLICY STATEMENT

3.1 PROJECT SAFETY AND HEALTH POLICY STATEMENT

The objective of the Project safety and health program is to establish work procedures that ensure Project work is performed in a safe and healthful manner. During the course of the Project, the safety and health of Project personnel will be the first consideration when planning and executing work and will not be questioned or compromised. To be successful, the Project safety and health program must encourage a culture of safety that fosters proper attitudes toward incident prevention on the part of both supervisors and employees. It also requires cooperation in all safety and health program aspects, not only between supervisors and employees, but also between employees and their fellow workers. Only through such a cooperative effort can an effective safety and health program be maintained.

One of the primary objectives of the Project safety and health program is incident prevention. The Project safety and health program strives to maintain incident-free operations, which can only be achieved through total demonstrated commitment to this safety and health policy from Project personnel. Project personnel must recognize and understand that incidents and injuries can be prevented.

To establish and maintain an effective safety and health program, Project personnel must:

Maintain a safe workplace, equipment, and materials;

Establish and comply with safe work operations and accepted safe work rules, procedures, and practices in compliance with safety and health regulations;

Provide effective safety and health training that teaches Project personnel how to identify potential hazards and provides the necessary protocols, tools, and equipment to appropriately mitigate identified hazards;

Understand that they have a duty and responsibility to maintain their own safety and the safety of their coworkers; and

Actively support the Project safety and health program and embrace the philosophy that “Incidents Can Be Prevented.”

3.2 PROJECT SAFETY GOALS

The Project accident experience goal is zero incidents. Project personnel will complete required training and, when necessary, retraining will be provided. Project personnel will report near misses and site hazards in a timely manner. Several measures will be taken to achieve and maintain the goal of zero incidents.

Project Contractors must engage in open dialog with site workers to identify and mitigate hazards that could cause injury, accident, environmental incident, security incident, or property damage.

Project Contractors will conduct daily inspections to monitor the proper use of personal protective equipment (PPE), general safe work practices, and housekeeping. The results of inspections will be presented in Project Contractor meetings, and mitigation measures will be discussed and implemented.

Prior to beginning a new work activity, Project Contractors must provide to USAID, through the A&E Bien Hoa Contractor, an Activity Hazard Analysis (AHA) that describes the work, associated

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hazards, mitigation measures, training requirements, engineering controls, work practices, and PPE to be used.

Project Contractors will require their personnel to report accidents or injuries. When an incident occurs, Project Contractors must conduct a thorough investigation to ascertain the cause and measures to be taken to prevent recurrence.

Project Contractors must initiate a hazard and “Near Miss” reporting system for Project personnel. Project Contractors will require their personnel to report identified hazards and, if assistance is required in removing a hazard, measures will be identified to mitigate the hazard.

3.3 SITE-WIDE HEALTH AND SAFETY PLAN DESCRIPTION

This Site-Wide HASP establishes the written Project safety and health program that applies to Project personnel and activities to be conducted at the Bien Hoa Airbase Area. Project activities will be implemented by the Project Contractors (including the A&E Bien Hoa Contractor) and will include the following activities related to the treatment and isolation of dioxin contaminated soil and sediment at the Bien Hoa Airbase Area:

Mobilization, Site investigations/Evaluations, Excavation, Maintenance of contaminated material short-term storage, General construction, Construction of a remedial system, Construction of a long-term storage area, Remediation, Environmental monitoring, and Demobilization.

As the Project progresses and additional site data is collected, additional activities may be added to the scope of the Project. Project Contractors will be identified through awards by USAID to implement the dioxin remediation activities at the Bien Hoa Airbase Area. USAID is expected to specify particular health and safety requirements for each contractor in these awards. However, in general, this HASP will be an essential guide for Project Contractors and establishes the minimum safety and health requirements for Project Contractors and personnel to follow. Project Contractors (including the A&E Bien Hoa Contractor) are required to prepare SHASPs for their contract-specific work activities that must comply with the minimum safety and health requirements established in this Site-Wide HASP. This Site-Wide HASP will be provided to Project Contractors required to prepare a SHASP. During preparation of SHASPs and/or review of the Site-Wide HASP, Project Contractors must immediately notify USAID and the A&E Bien Hoa Contractor if safety and health deficiencies are found in the Site-Wide HASP.

This HASP has been prepared to meet the requirements of: GVN Occupational Safety and Health standards; OSHA standards as found in Title 29 CFR, Parts 1910 and 1926; and USACE EM 385-1-1. The implementation of this HASP assists Project personnel to take proactive measures to recognize, evaluate, and control workplace hazards in order to minimize the potential for injuries and illness. The main objectives of the Site-Wide HASP are to:

Provide personnel with a safe working environment;

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Establish an effective Project safety and health program;

Identify key Project personnel, their safety and health responsibilities, and the lines of authority;

Establish procedures for identifying and evaluating workplace hazards and prescribe safety control measures to mitigate them;

Create and reinforce safety conscious attitudes amongst Project personnel;

Establish a system to facilitate Project personnel compliance with safe work practices and procedures for correcting unsafe conditions;

Provide safety and health training for Project personnel;

Establish a medical monitoring program for Project personnel that includes a blood serum dioxin monitoring program; and Implement procedures for the reporting and investigation of Project site-related injuries, illnesses, vehicular accidents, property damage, security incidents, and environmental damage.

USAID requires compliance with the Site-Wide HASP by Project Contractors and personnel and associated third parties. A copy of the Site-Wide HASP will be maintained on site during work activities and will be available for inspection and review. Project personnel are required to review applicable aspects of the Site-Wide HASP before site work and sign a “Site-Wide HASP Review” acknowledgment form (see HASP Appendix A – HASP Forms) indicating that they have reviewed the pertinent aspects of the Plan.

Project Contractors will prepare SHASP for site investigations/evaluations, remediation construction, post construction, and other activities to be included in the Site-Wide HASP. The A&E Bien Hoa Contractor will amend the Site-Wide HASP to incorporate SHASPs as annexes once they are approved by USAID.

The A&E Bien Hoa Contractor may recommend, and/or USAID may direct, revision and/or amendment of the Site-Wide HASP as additional information becomes available regarding the site hazards or when significant changes occur in the scope of work, operational procedures, site hazards, or hazard control measures. This Site-Wide HASP may be modified by the A&E Bien Hoa Contractor Lead Safety and Environmental Compliance Specialist (LSECS) upon review and approval of the A&E Bien Hoa Contractor Health and Safety Officer (HSO) and Chief of Party (COP), and USAID Contracting Officer (CO). USAID will inform Project Contractors of changes to the Site-Wide HASP. Project Contractors are required to inform Project personnel of the changes in the revised/amended Site-Wide HASP through safety meetings and other means. Safety and health responsibilities of key Project personnel and lines of authority are presented in the following Section.

4 RESPONSIBILITIES AND LINES OF AUTHORITIES

Responsibility for safety and health is shared by Project Contractors and personnel. An effective safety and health program can only be maintained through a cooperative effort between supervisors and employees, and employees and their fellow workers. This section identifies key Project personnel, their safety and health responsibilities, and the lines of authority and cooperation. This section also describes designated competent persons, establishes pre-task safety and health analysis procedures, and establishes safety compliance and enforcement procedures.

4.1 KEY PROJECT PERSONNEL

USAID, the A&E Bien Hoa Contractor, Project Contractors, and Project personnel are responsible for the implementation and compliance with the Project safety and health program as presented in this Site-

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Wide HASP. Key USAID and A&E Bien Hoa Contractor Project personnel are identified in Table 4-1.

Additional Key Project personnel are identified in the Project “Emergency Contact List” (see Table 9-2).

For other Project Contracts, the required SHASPs must specify and identify the following positions:

USAID Contracting Officer’s Representative (COR) Contractor Project Manager (CPM) Site Contractor Project Manager (SCPM) Contractor Safety Officer (CSO)

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TABLE 4-1.KEY PROJECT PERSONNEL

Position Current Personnel Organization Contact Information Start Date Record of Revisions Contracting Officer (CO) USAID Suzanne Johnson USAID

Phone: 02439351231 Email: sjohnson@usaid.com

Contracting Officer’s Representative (COR)

USAID

Anthony (Tony) Kolb USAID Mobile: +84 (96) 2002758 Email: akolb@usaid.gov

Chief of Party (COP) A&E Bien Hoa Contractor

Souheil (Sal) Mansour Trigon Associates

Mobile: +84 058-686-1240 Email:

SMansour@TrigonAssociates.com

Deputy Chief of Party (DCOP) / Remediation Specialist A&E Bien Hoa Contractor

Andrew Sayers-Fay, Ph. D. Trigon Associates

Office: +1 504.585.5767 Mobile: +84 (84) 9360544 Email: asayers-fay@trigonassociates.com

Safety and Health Advisor

Michael Grasso, Certified Industrial Hygienist (CIH), Certified Safety Professional

(CSP)

Trigon Associates

Office: 504.585.5767 Mobile: 607.201.6737 Email: mgrasso@trigonassociates.com

Health and Safety Officer

(HSO)

A&E Bien Hoa Contractor

Lynne Black, Certified Instructional Trainer (CIT) Cardno

Office: +1 434-295-4446 Email: lynne.black@cardno-gs.com

Construction Manager

(CM)

TBD TBD TBD TBD

Lead Safety and Environmental Compliance Specialist (LSECS)

Contractor Project Manager Project Contractor

Site Contractor Project Manager

Contractor Safety Officer

TBD TBD TBD TBD

Notes:

A&E – Architect and Engineer TBD – To Be Determined USAID – United States Agency for International Development

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4.2 KEY PROJECT PERSONNEL SAFETY AND HEALTH RESPONSIBILITIES

Table 4-2 describes the safety and health responsibilities for the identified key Project personnel and site personnel, and established lines of authority. The key Project personnel include USAID, A&E Bien Hoa Contractor, and other Project Contractor(s) personnel.

TABLE 4.2 KEY PROJECT PERSONNEL SAFETY AND HEALTH RESPONSIBILITIES

Title Role Safety and Health Responsibilities USAID Key Project Personnel

USAID Contracting Officer Manages the Project contract and is the USAID primary point of contract for safety and health issues.

The USAID CO can designate their safety and health responsibilities to the USAID COR.

• Provide final approval of the Site-Wide HASP prior to any work, except non-intrusive site work, and

USAID Contracting Officer’s Representative

Manages and oversees the Project technical direction. • Review the Site-wide HASP and recommend approval to Contracting Officer . Review and approve subsequent annexes to the Site-wide HASP, including SHASPs and new AHAs.

A&E Bien Hoa Contractor Key Project Personnel A&E Bien Hoa Contractor Chief of Party (also acts as A&E CPM and SCPM)

Leads the A&E Services for Dioxin Remediation at the Bien Hoa Airbase Area activity and is the primary point of contact with USAID on the Site-Wide HASP.

• Direct, coordinate, and implement the A&E contract;

• Review and submit to USAID the Site-Wide HASP and A&E Bien Hoa SHASPs;

• As requested by USAID, review and comment on SHASPs and new AHAs submitted by other Project Contractors;

• Review addenda to the Site-Wide HASP to incorporate updates approved by the CO;

• Emphasize safety and health to workers and guests at the Bien Hoa Airbase Area;

• Request dismissal of Project personnel who consistently exhibit unsafe work performance after notice to the worker from the CO and COR;

• Notify the USAID CO and COR and direct or suspend Project Contractor’s work when the continued performance of the work will endanger the health, or safety of the public or Project personnel;

• Communicate with the CO to evaluate and resolve contractor/subcontractor safety and health issues.

• Allocate the necessary resources and support required to implement and enforce this

HASP;

• Provide resources and support to the A&E Bien Hoa Contractor CM and safety and health staff (Safety and Health Advisor, HSO, and LSECS); and

• Communicate with the CO to evaluate and resolve safety and health issues.

A&E Bien Hoa Contractor Deputy Chief of Party

Leads the technical aspects of the A&E Services for Dioxin Remediation at the Bien Hoa Airbase Area activity. The A&E Bien Hoa Contractor COP can designate their safety and health responsibilities to the A&E Bien Hoa Contractor DCOP.

• Direct, coordinate, and implement the technical aspects of the A&E contract;

• Review the Site-Wide HASP and annexes including SHASPs and new AHAs;

• Provide resources an-d support to the A&E Bien Hoa Contractor CM and safety and health staff (Safety and Health Advisor, HSO, and LSECS);

• Emphasize safety and health to workers and guests at the Bien Hoa Airbase Area; and

• Schedule safety and health inspections and audits for the A&E Bien Hoa Contractor LSECS to conduct.

A&E Bien Hoa Contractor Safety and Health Advisor

Supports and advises the A&E Bien Hoa Contractor COP and DCOP on safety and health aspects of the

• Advise and support the A&E Bien Hoa Contractor COP and DCOP on safety and health topics;

A&E Services for Dioxin Remediation at the Bien Hoa Airbase Area activity.

• Review the Site-Wide HASP and annexes including SHASPs and new AHAs; and

• Work collaboratively with the A&E Bien Hoa Contractor HSO.

A&E Bien Hoa Contractor Health and Safety Officer

Overall safety manager assigned to support the Project. The A&E Bien Hoa Contractor LSECS and CSO have a direct reporting relationship to the A&E Bien Hoa Contractor HSO regarding all safety and health matters. The A&E Bien Hoa Contractor HSO implements the Site-Wide HASP and oversees the activities of the A&E Bien Hoa Contractor LSECS and CSO. The HSO has an independent reporting relationship from Project management and supervision. A resume for the HSO is provided (see Appendix B – Health and Safety Officer and LSECS Resumes). The A&E Bien Hoa Contractor HSO can designate their safety and health responsibilities to the A&E Bien Hoa Contractor LSECS.

• Develop the Site-Wide HASP and A&E Bien Hoa Contractor SHASPs;

• Review addenda to the Site-Wide HASP to incorporate updates approved by the CO;

• Review SHASPs for compliance with the Site-Wide HASP;

• Review new AHAs for compliance with the Site-Wide HASP;

• Review modifications to existing AHAs;

• Work collaboratively with the Safety and Health Advisor;

• Provide safety and health technical assistance to the A&E Bien Hoa COP, DCOP, CM, and LSECS; and

• Communicate with the CO and designated representatives to evaluate/resolve safety and health issues.

A&E Bien Hoa Contractor Construction Manager

Provides primary oversight of Project Contractors and directly reports to the A&E Bien Hoa Contractor

COP.

• Review the Site-Wide HASP and annexes including SHASPs and new AHAs;

• Allocate resources, as required, to implement the Site-Wide HASP;

• Recognize and award the safety achievements of crews/team/contractors;

• Begin every meeting with a safety moment;

• Recognize unsafe acts and conditions and take the necessary corrective actions;

• Implement and enforce the Site-Wide HASP; and

• Emphasize safety and health to workers and guests at the Bien Hoa Airbase Area.

A&E Bien Hoa Contractor Lead Safety and Environmental Compliance Specialist (also acts as A&E

CSO)

The onsite Project safety and health supervisor who is present during fieldwork activities and responsible for ensuring site activities are being conducted in accordance with Project documents such as the Site- Wide Environmental Mitigation and Monitoring Plan and Site-Wide HASP. As per EM 385-1-1 requirements, the A&E Bien Hoa Contractor LSECS must be present at the site when work is performed.

If the A&E Bien Hoa Contractor LSECS must be absent from the site, the safety and health duties must be delegated to another qualified responsible party. The A&E Bien Hoa Contractor LSECS must ensure that the person assuming this temporary role is first aid/cardiopulmonary resuscitation (CPR) certified and is fully aware of their role and responsibilities during the A&E Bien Hoa Contractor LSECS’s absence. The names of Competent and/or Qualified Persons that can act as replacements for the A&E Bien Hoa Contractor LSECS and proof of their competency or qualification will be provided in Appendix C – List of Designated Competent

• With HSO, develop the Site-Wide HASP and A&E Bien Hoa Contractor SHASPs;

• Review addenda to the Site-Wide HASP to incorporate updates approved by the CO;

• Review SHASPs for compliance with the Site-Wide HASP;

• Review AHAs for compliance with the Site-Wide HASP;

• Review modifications to existing AHAs;

• Maintain copies of the Site-Wide HASP on site during field activities;

• Implement provisions of the Site-Wide HASP and the Project safety and health program;

• Recommend safety and health inspections and audits to the A&E Bien Hoa Contractor

COP;

• Conduct safety and health inspections and audits as scheduled by the A&E Bien Hoa Contractor COP;

• Require that site personnel meet training and medical surveillance requirements;

• Conduct site orientation training and Site-Wide HASP reviews;

• Conduct training as new activities and/or hazards are introduced;

• Emphasize safety and hold personnel accountable for safe work performance;

• Review site hazards and establish safety control measures;

• Maintain a hazardous substance inventory list;

• Maintain copies of each safety data sheet (SDS);

• Maintain safety equipment and supplies;

• Perform weekly safety inspections and document safety and health findings;

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Persons as site activities progress. Several Competent and/or Qualified Persons will be named as replacements for the A&E Bien Hoa Contractor LSECS to ensure that work is not delayed by a safety stand-down until a qualified/certified person is available.

The resume for the A&E Bien Hoa Contractor LSECS will be provided in Appendix B once the position is filled

• Collect, review, and provide comments on copies of the Daily Safety Log prepared by the CSO;

• Enforce implementation and compliance with the Site-Wide HASP and Project safety and health program;

• Ensure site control work zones and boundaries comply with the Site-Wide HASP;

• Determine PPE requirements and monitor proper use;

• Direct decontamination procedures to be used;

• Perform and/or coordinate site exposure monitoring;

• Report safety violations or safety and health concerns promptly to the A&E Bien Hoa Contractor COP and HSO;

• Request dismissal of Project personnel who consistently exhibit unsafe work performance after notice to the worker from the USAID CO/COR;

• Notify the USAID CO and COR and direct or suspend Project Contractor’s work when continued performance of the work will endanger the health, or safety of the public or Project personnel;

• Ensure correction of unsafe work conditions and/or unsafe work practices;

• Monitor and evaluate safety and health performance of Project operations;

• Maintain Project safety and health records including anonymous blood serum dioxin monitoring results to be shared with USAID;

• Maintain and update AHAs as Project activities progress;

• Report and investigate accidents and incidents;

• Serve as a member of the A&E Bien Hoa Contractor quality control staff on safety and health matters;

• Communicate with the A&E Bien Hoa Contractor HSO regarding site activities and Site- Wide HASP compliance; and

• Communicate with the CO to evaluate and resolve safety and health issues.

Project Contractor Key Project Personnel (to be identified in SHASPs) Contractor Project Manager

Each Project Contractor (except the A&E Bien Hoa Contractor) will have a CPM who is responsible for overall direction, coordination, technical consistency, and review of the Project Contractor contract.

• Direct, coordinate, and implement their contract;

• Review the Site-Wide HASP;

• Review and submit their contract-specific SHASP;

• Emphasize safety and health, and hold their personnel accountable for safe work performance;

• Enforce implementation and compliance with the Site-Wide HASP, contract-specific SHASP, and Project safety and health program;

• Per its contract with USAID, establish a procedure to notify the USAID CO and COR and to direct or suspend Project Contractor’s work when the continued performance of the work will endanger the health, welfare, or safety of the public or Project personnel;

• Provide resources and support to the SCPM and CSO;

• Monitor and evaluate safety and health performance of their operations; and

• Communicate with the CO to evaluate and resolve contractor/subcontractor safety and health issues.

Site Contractor Project Manager

Each Project Contractor (except the A&E Bien Hoa Contractor) will have a SCPM who is responsible for the successful completion of the Project Contractor

• Prepare and organize Project Contractor activities on site;

• Review the Site-Wide HASP;

• Review and concur with their contract-specific SHASP;

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field operations. The SCPM reports to the CPM for site-related matters.

• Provide equipment and materials for site operations;

• Emphasize safety and health and hold personnel accountable for safe work performance;

• Enforce implementation and compliance with the Site-Wide HASP, contract-specific SHASP, and Project safety and health program;

• Ensure correction of unsafe work conditions and/or unsafe work practices;

• Monitor and evaluate safety and health performance of site operations;

• Report and investigate accidents and incidents and sign the reports; and

• Communicate with the CO to evaluate and resolve safety and health issues.

Contractor Safety Officer Each Project Contractor (except the A&E Bien Hoa Contractor) will have a CSO who is the on-site Project Contractor safety and health supervisor present during Project Contractor fieldwork activities as required by EM 385 1-1. The CSO will work directly with the A&E Bien Hoa Contractor LSECS. If the CSO must be absent from the site, the safety and health duties must be delegated to another qualified responsible party at the site (e.g., SCPM).

The CSO must ensure that the person assuming this temporary role is first aid/CPR certified and is fully aware of their role and responsibilities during the CSO’s absence. If a qualified replacement is not available, then work shall stop for a safety stand-down until a qualified/certified person is available.

• Review the Site-Wide HASP;

• Prepare the contract-specific SHASP and submit for approval;

• Prepare and facilitate the Project Contractor serum dioxin monitoring program;

• Maintain copies of the Site-Wide HASP and contract-specific SHASP on site during field activities;

• Implement provisions of the Site-Wide HASP, contract-specific SHASP, and the Project safety and health program;

• Ensure that Project Contractor personnel meet training and medical surveillance requirements;

• Conduct site orientation training, Site-Wide HASP and contract-specific SHASP review, and daily safety meetings;

• Conduct training as new activities and/or hazards are introduced;

• Emphasize safety and hold Project Contractor personnel accountable for safe work performance;

• Review site hazards and establish safety control measures;

• Maintain a hazardous substance inventory list and provide to the A&E Bien Hoa Contractor LSECS;

• Maintain copies of each SDS and provide updates to the A&E Bien Hoa Contractor

LSECS;

• Maintain safety equipment and supplies;

• Perform daily safety inspections and document safety and health findings on inspection log and provide to the A&E Bien Hoa Contractor LSECS;

• Track safety and health deficiencies to ensure that they are corrected and report any deficiencies to the A&E Bien Hoa Contractor LSECS;

• Enforce implementation and compliance with the Site-Wide HASP, contract-specific SHASP, and Project safety and health Program;

• Establish site control work zones and boundaries;

• Enforce and monitor the PPE requirements in the Site-Wide HASP;

• Enforce and monitor the decontamination procedures established in the Site-Wide

HASP;

• Perform and/or coordinate site exposure monitoring;

• Report safety violations or safety and health concerns promptly to the SCPM and A&E Bien Hoa Contractor LSECS;

• Ensure correction of unsafe work conditions and/or unsafe work practices;

• Monitor and evaluate safety and health performance of Project Contractor operations;

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• Maintain and report safety and health records including anonymous blood serum dioxin monitoring results to the A&E Bien Hoa LSECS to be shared with USAID;

• Work with the A&E Bien Hoa Contractor LSECS to maintain and update Activity Hazard Analyses (AHAs) as Project Contractor activities progress;

• Report and investigate accidents and incidents and provide reports to the SCPM and A&E Bien Hoa Contractor LSECS;

• Communicate with the A&E Bien Hoa Contractor LSECS regarding site activities and Site-Wide HASP compliance; and

• Communicate with the CO to evaluate and resolve safety and health issues.

All Project Personnel Site Personnel Perform designated work activities. • Understand and comply with the Site-Wide HASP and the applicable Project Contractor

SHASP,

• Follow instructions of the CSO or other competent authority,

• Promptly report any unsafe work conditions or unsafe work practices,

• Immediately report all injuries or illnesses to direct supervisors and the CSO, and

• Stop work for a safety stand-down if unsafe working conditions are encountered.

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4.3 DESIGNATED COMPETENT PERSONS

A “Competent Person” (as defined by OSHA) is a person who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authority to take prompt corrective measures to eliminate them.

The Project safety and health program requires that a designated competent person be present on the job site for work to be performed. The names of Competent and/or Qualified Persons and proof of competency or qualification to meet specific OSHA Competent/Qualified Persons requirements will be provided as site operations progress (Appendix C – List of Designated Competent Persons). At a minimum, the Designated Competent Persons shall successfully complete the OSHA 30-Hour Construction Outreach Training Course or equivalent and the USACE 40-Hour EM 385-1-1 USACE Safety & Health training course, and present certificates of successful completion of training. The competent person shall present a letter from the CSO designating them as a Competent Person. For a list of Competent Persons for this Project, refer to Appendix C.

4.4 PRE-TASK SAFETY AND HEALTH ANALYSIS

The first step in safety and health planning for a new work activity is defining the types of work and associated risks. AHAs are tools to identify and define the work activities and associated tasks, identify the sequence of work and specific anticipated hazards, and establish necessary control measures to eliminated or reduce each hazard to an acceptable risk level. The Project safety and health program requires that AHAs be prepared before beginning new work activities that involve hazards not previously experienced or where a new Project Contractor is to perform the work activities. New work crews must review and familiarize themselves with the applicable AHA. The AHA is developed to identify hazards and control measures for primary work activities and tasks. Work does not proceed on a new activity (or one with a modified AHA) until the AHA (or modified AHA) has been reviewed by the CSO and A&E Bien Hoa Contractor HSO, accepted by the relevant, contract-specified USAID official, and the AHA has been reviewed with involved Project personnel. AHAs are living documents that are continuously reviewed and modified when appropriate to address changing site conditions or operations.

AHAs will be prepared for work activities and tasks considered potentially hazardous including the initial work tasks listed below.

General site activities, Site reconnaissance, Site characterization activities, Vehicle travel, Mobilization Decontamination/Demobilization, Excavation and earthmoving, and Working over or near water.

AHAs have been prepared for the first three tasks and are presented as example AHAs in Appendix D

– Activity Hazard Analyses Forms. However, preparation of AHAs will be required for all work activities considered potentially hazardous. The blank AHA form is included in Appendix A. AHAs will be developed to suit new site activities and annexed to the Site-Wide HASP. Project Contractors shall prepare AHAs for their specific activities and include them in their contractor-specific SHASP.

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4.5 SAFETY COMPLIANCE AND ENFORCEMENT

Compliance with safe work practices and the Project safety and health program is required of Project personnel in every capacity. Project personnel have the right to stop work if they determine the conditions are unsafe or will rapidly become unsafe. Effectiveness of the Site-Wide HASP is highly dependent upon the involvement, direct supervision, and enforcement of safety requirements by supervisory personnel.

4.5.1 GENERAL SAFE WORK PRACTICES

Project personnel must work in a safe manner to ensure a safe work environment. Standard safe work procedures include, but are not limited to, the following:

Project personnel must report to work in a ready-to-work state and in suitable work clothing;

Illicit drugs, alcohol, and firearms are not allowed on site;

Horseplay and gambling are not allowed on site;

Use of personal radios or other items that may distract attention are not permitted;

Eating, drinking, and smoking are not permitted in work areas;

The buddy system will be observed while working at the site unless the work activity requires the work to be conducted alone, the exception has been approved by their CSO, and the LSECS has been notified;

PPE and respiratory protection will be properly used by all site workers;

Harassment, bullying, or physical violence of any kind will not be tolerated and will result in dismissal.

4.5.2 SAFE WORK PRACTICES FOR USE OF TOOLS, EQUIPMENT AND MACHINERY

Tools, equipment, and machinery inspection and maintenance are required to promote safe working conditions. Tools (including hand and power tools), equipment, and machinery must be inspected daily or before each use for defects.