Attachment 7 - Safety Health Checklist.doc

Attachment 7

DTFAAC-15-R-02838

U.S. DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

1/11/99

SUBJ: FAA PRE-CONSTRUCTION AND MAINTENANCE PROJECT

SAFETY AND HEALTH CHECKLIST

1. PURPOSE. This order provides information on construction and maintenance project safety and health requirements. Appendix 1, FAA Pre-Construction and Maintenance Project Safety and Health Checklist, Form FAA 3900-8, will be used during construction and maintenance activities.

2. DISTRIBUTION. This order is distributed to the division level in Airway Facilities and Air Traffic in Washington, to the branch level in regional Airway Facilities and Air Traffic Divisions, and a limited distribution to all Airway Facilities and Air Traffic field offices and facilities.

3. BACKGROUND.

a. During 1997, an unusually high number of incidents occurred in asbestos abatement, construction, and maintenance-related projects. These incidents showed that improvements are needed relative to planning and communication, minimizing and eliminating project risks, following established procedures, and ensuring appropriate oversight of contract work by Federal Aviation Administration (FAA) personnel. As a result, significant concerns have been raised by the unions, airline industry, flying public, and Congress.

b. The National Airspace System Transition and Integration (ANS) organization reviewed the FAA project construction process to determine methods to reduce or eliminate project-related incidents at FAA facilities. This review determined that project-related incidents can be reduced or eliminated by initiating a requirement for the completion of the checklist prior to starting construction or maintenance activities and as on site work progresses.

c. On March 9, 1998, FAA Notice 3900.60, FAA Pre-Construction and Maintenance Project Safety and Health Checklist, was published to require the use of the FAA Pre-Construction and Maintenance Project Safety and Health Checklist as a tool by each individual who oversees construction and maintenance activities that potentially have occupational safety, health, and environmental related impacts, on Air Traffic and Airway Facilities operations. Notice 3900.60 requested FAA facilities to assess the effectiveness and usefulness of the checklist and provide feedback to the Environmental, Energy, and Safety Division, ANS-500. No feedback was received. Available information regarding project-related incidents at FAA facilities indicates that incidents have been reduced at those FAA facilities where the checklist is used for construction and maintenance activities.

d. Due to the urgency to continue to reduce or eliminate project-related incidents at FAA facilities, without interruption, this order is being issued without further coordination of the checklist.

4. CANCELLATION. FAA Notice 3900.60, FAA Pre-Construction and Maintenance Project Safety and Health Checklist, dated March 9, 1998, is canceled.

5. ACTION.

a. Effective immediately, Appendix 1, FAA Pre-Construction and Maintenance Project Safety and Health Checklist, Form FAA 3900-8, shall be used as a tool by each resident engineer (RE), contracting officer’s technical representative (COTR), designated facility point of contact, and System Management Office (SMO) and System Support Center (SSC) manager who oversees construction and maintenance activities that potentially have occupational safety and health, and environmental related impacts on Air Traffic and Airway Facilities operations. This checklist shall be used, as appropriate, during critical phases of construction and maintenance activities; e.g. the pre-construction meeting, 30-60 days prior to commencement of work, daily/weekly construction meetings, etc. Emphasis should be placed on using the checklist as a tool to assess, as well as reassess, hazards as projects progress. The checklist contains detailed instructions regarding its use.

b. As appropriate, each RE, COTR, and SMO and SSC manager or designated facility point of contact is responsible for ensuring completion and distribution of the checklist. Occupational safety and health, and environmental (OSH/E) professionals who receive copies of the checklist, shall maintain copies a minimum of 3 years. Upon request, OSH/E professionals shall provide copies to the Regional Program Managers for Environment and Safety and Regional Occupational Safety and Health Managers, or the Washington headquarters program office for review.

6. FEEDBACK. When using the checklist, all organizations are encouraged to assess its effectiveness and usefulness. Organizations should provide feedback regarding the effectiveness and usefulness of the checklist to the Environmental, Energy, and Safety Division, ANS-500, through memorandum or electronic mail. FAA Form 1320-19, Directive Feedback Information, may also be used.

7. ISSUANCE OF CONSTRUCTION AND MAINTENANCE ORDER. The Environmental, Energy, and Safety Division, ANS-500, has issued this order to replace FAA Notice 3900.60. Since the Notice expires on March 9, 1999, the order is published as a permanent directive to ensure the adherence to the policies and practices set forth in this document. This order will establish minimum requirements for construction and maintenance safety and health programs. The checklist has been converted into an agency form and is available through the FAA distribution system. Revisions to the order are planned in the near future to incorporate further clarification of responsibilities and to refine the checklist. All suggestions and recommendations received to improve the order will be considered in developing revisions.

Stanley Rivers

Director of Airway Facilities

Form 3900-8, FAA PRE-CONSTRUCTION AND MAINTENANCE PROJECT

SAFETY AND HEALTH CHECKLIST

Purpose

This checklist is intended to be used as a tool by RE/COTRs, designated facility POCs, or SSC managers who oversee construction and maintenance activities that potentially have Occupational Safety, Health, and Environmental (OSH/E) related impacts on AT/AF operations. This tool shall be used, as appropriate, during critical phases of construction and maintenance activities (e.g. the pre-construction meeting, 30-60 days prior to commencement of work, weekly/daily construction meetings, etc.). Emphasis should be placed on using this checklist as a tool to assess as well as reassess hazards as the project progresses. Specifically, this checklist is intended to:

· Promote sensitivity to potential OSH/E hazards associated with projects and stress the importance of not disrupting NAS operations

· Assist in identifying and validating potential project hazards and associated risks

· Assist in preventing safety and health incidents/accidents and facility shutdowns

· Ensure appropriate contractor measures and controls are in place to address potential project hazards

· Facilitate discussion with the contractor regarding plans to prevent/minimize potential incidents/accidents

· Enhance coordination between OSH/E professionals, project personnel and contractors

· Facilitate review of critical FAA OSH/E procedures with contractors

· Raise OSH/E awareness

- This checklist relies on the training and professional judgment of the user. OSH/E personnel should be consulted as needed.

- A facility POC with a thorough understanding of facility procedures and equipment considerations should participate in the site walk-through.

NOTE: For small procurements (e.g. credit card purchases) and internal FAA projects (e.g. field maintenance party projects), without specifications, immediately contact the designated OSH/E professional for assistance in completing this checklist.

1 Project Summary Information

Fill in the requested site specific information.

Project Name and Description:

24 V DC Bus System ______________________________

SMO:

Facility ID:

Project Designer:DC System Program Office, AJW-221 Transmittal #:

Env & Safety Review By:

Date:

Project/Activity/Task:

Install 24V DC Bus System

Planned Start:

Expected Completion Date:

Contractor Contact:Name: ___________________________ Phone: ___________________

OSH/E Contact:Name:

Phone:

Facility POC: Name:

Phone: ______________________________ 2 Facility Procedures

Review site specific FAA procedures and considerations with the contractor. For example, discuss when or how during the project, emergency plans will be used/required. After the procedures have been reviewed, perform a site walk-through with the contractor.

Asbestos Contingency Plan

Critical Power Systems Awareness

Lock Out/Tag Out

Work Permits (e.g. Asbestos, Lead)

Emergency Plans (e.g. Occupant Emergency Plan)

Impacts to Fire Alarm and Suppression Systems

Site Walk-Through (With Facility POC & Contractor(s))

Hazard Communications (e.g. MSDSs)

Other (e.g. Access/Security/Communications Equip.)

3 Project Hazard/Risk Analysis

Think about your project and its potential hazards and risks. Consider sensitive NAS operations and all facility personnel that may be impacted by your projects. As an example: Construction activities with potential for impacting asbestos materials in or near sensitive operations could result in incidents which disrupt NAS operations. For each potential project hazard indicate (with a checkmark) a level of potential risk for exposure/release/incident.

Potential Project

Hazards

Consider Sensitive AT/AF Operations:

Hazardous Substances and Environmental Controls

Asbestos (e.g. Tiles & Insulation)

Chemical, Gas, Fumes, Dust, Radiation

Indoor Air

Ventilation System

Lead-based Paint

Electrical Power Systems

Pressurized Equipment and Systems

Work at Heights (>6 feet)

Other (e.g. Confined Space)

4 Site Safety and Health

After reviewing the potential hazards and risks in block 3, ensure that the contractor has identified measures and controls to address applicable site safety and health risks (e.g. through discussions, available site safety plans, or other applicable documents). In your judgment, if the contractor has appropriate measures to address the potential project hazards (see block 3), check the appropriate YES boxes below. If a potential project hazard has been identified in block 3 and no associated measures or controls are evident, then check the appropriate NO boxes below. If a NO box is checked, use the close-out date box to indicate when appropriate measures or controls have been incorporated into the contractor’s site safety and health approach.

Program Elements

Hazardous Substances & Environmental Controls

Asbestos

Chemicals (e.g. Introduced to site)(Provide MSDS)

Gas

Fumes

Lead Paint/Other Coatings

Radiation and Electric Fields

Ventilation and Exhaust Systems

Electrical Power Systems

Procedures for Critical Power Systems Coordination

Provisions for GFCI

Control of Hazardous Energy (Lockout/Tagout)

(e.g. Electrical, Mechanical, Hydraulic, Thermal, Radiation)

Pressurized Equipment and Systems

Work at Heights (>6 feet)

Safe Access and Fall Protection

Work Platforms

Floor and Wall Holes and Openings

Personal Protective and Safety Equipment

Fire Prevention

Accident Prevention

Excavations (New Construction or Tie in)

Welding and Cutting

Demolition of Existing Facility in Whole or Part

Medical and First Aid Requirements

Hand and Power Tools

Material Handling, Storage, and Disposal

Rigging

Machinery and Mechanized Equipment

(e.g. Equipment & Operator Certifications)

Sanitation

Lighting

Concrete & Masonry Construction & Steel Erection

Hazardous, Toxic, Radioactive Waste Activities

Other (e.g. Noise)

5 Review Information

The appropriate FAA point of contact and the contractor shall sign below to document discussion of the items on this form.

FAA POC:

Contractor:

Incident Prevention and Hazard Control Methods Discussed? Yes FORMCHECKBOX No FORMCHECKBOX

This block indicates routing of this checklist for project coordination.

SECM, OSH/E Contact:

AF Facility Manager:

AT Facility Manager:

Other:

Notes (e.g. Provide further explanation of potential hazards, locations, etc. below and attach additional sheets if necessary.)

6 Specific Safety & Environmental Issues

Complete checklist below during site survey and design.

Issue

If YES, always coordinate with OSH / E Contact.

NOTES:

(Identify if an Asbestos Survey was done, when, and where asbestos materials are located in the work area. Include Asbestos Work Permit requirements.)

1. Check Index of Asbestos and Lead Paint Surveys to see if the facility has been surveyed for asbestos. Index available from the SECMs, AGL-473, ANI-400C, and ANI-451.25.

2. If no survey available, then all impacted suspect materials must be sampled & tested.

3. Review Order 1050.20, SMO Asbestos Control Program (ACP), bargaining union agreements, and 29 CFR 1926.1101.

If yes:

4. Include in specifications applicable regulatory and union agreement requirements along with safe work practices.

Dispose of Mercury Switches, Radioactive tubes, or other hazardous waste?

1. Check the PCB Inventory available from each SECM.

If yes:

2. Review Order 1050.14A & 17, 40 CFR 761 Subpart D, 40 CFR 260-270, 10 CFR 30, and State regulations.

3. Comply with applicable regulatory requirements for storage and disposal.

If yes:

1. Review Order 1050.17 & 18 and 40 CFR 82.

2. Replace with non-CFC equipment.

3. Recover & recycle existing CFCs.

1. Check Fuel Storage Tank Inventory available from the Regional FST Manager or the SECM.

2. Review Order 1050.15 & 17, 40 CFR 280, and State regs.

3. Use State-specific plans & specifications for removal and installation available from the Regional FST Manager.

4. Prepare Spill Prevention Control and Countermeasure Plans (SPCC) for tanks per 40 CFR 112.

NEPA

(National Environmental Policy Act) Significantly impact the environment with respect to noise, water quality, air quality, wetlands, historic and archeological sites, endangered species & other protected areas?

1. Review Order 1050.1D & 17.

2. Is activity classified as a Categorical Exclusion (Cat X)?

3. If no Cat X, prepare Environmental Assessment (EA).

4. Prepare Finding Of No Significant Impact (FONSI) or Environmental Impact Statement (EIS) as appropriate.

EDDA

(Environmental Due Diligence Audit) Acquire, lease and/or dispose of property?

If yes:

1. Review Order 1050.17 & 19.

2. Coordinate with AGL-74, Real Estate.

3. Conduct EDDA.

LEAD PAINT

LEAD-ACID BATTERIES

Disturb or dispose/recycle lead paint or lead acid batteries?

1. Check Index of Asbestos and Lead Paint Surveys to see if sampling has been conducted.

2. If no paint sampling results available, then all impacted materials must be sampled & tested.

If yes:

3. Comply with applicable OSHA regulatory requirements for worker protection and EPA requirements for removal & disposal. Initiate recycling efforts for scrap metal or batteries when feasible.

4. Follow MSDS guidelines for battery handling.

AIR EMISSIONS

(Clean Air Act) Replace and/or install new emission sources such as boilers, incinerators, storage tanks, engine generators, painting booths, space heaters, equipment using CFCs or Halon, and others?

1. Review Order 1050.17 & 18 and State CAA regulations.

2. Prepare and submit CAA Construction and Operating Permit if required.

CHEMICALS

Pesticides & Herbicides (FIFRA) Apply pesticides and/or herbicides? Use other hazardous chemicals/

1. Review Order 1050.17 and State regs.

2. Specify the use of State-certified applicators for pesticides/herbicides.

3. Specify copy of pesticide/herbicide application records be provided to SECM/Environmental Protection Specialist.

4. Obtain Material Safety Data Sheets for chemicals to be brought into work area.

WATER

(Clean Water Act) Clear, grade, and excavate over 5 acres; impact navigable waters; utilize equipment which can discharge to stormwater or wastewater systems (cooling tower discharges or boiler blowdows)?

1. Review Order 1050.17, 40 CFR 120-143, and State regs.

2. Prepare and submit CWA Permits (i.e. NPDES, sanitary sewer discharge, etc.) as required.

3. Prepare Spill Plan (SPCC) for fuel tanks as required by 40 CFR 112.

1. Review Orders 1050.17 & 3900.19A, and 29 CFR 1910 & 1926.

2. Comply with applicable regulatory requirements.

If yes:

1. Comply with applicable regulatory requirements. Initiate recycling efforts if feasible.

1. Review Energy Policy Act of 1992 and Executive Order 12902 which require energy reduction in all Federal buildings by 2005: 30% at Administrative facilities and 20% at Industrial facilities.

2. Lighting: Use energy efficient system w/electronic ballast

3. HVAC: Use energy efficient equipment

4. Controls: Contact AGL-473, Energy Manager

5. Building/Structure: Contact AGL-473, Energy Manager

7 FAA OSH / E CONTACTS

AXX REGION

PHONE

FAX

470 RPMES

ANI-XXX

Env & Safety

Env & Safety

XXX SMO

SECM

Safety Manager

· Consult with your SECM or designated OSH/E professional for additional guidance and assistance. Page 1 of 7