EOSH Impacts.pdf

ATTACHMENT

EOSH IMPACTS

Project:

HVAC Replacement Project at the GGG ATCT in Longview, TX

3/11/21

Engineer / Routing Code: Jeremy Hamby / AJW-2C11C Manager / Routing Code: Thomas Clayton / AJW-2C11C SECM (District): Lenny Ramos / AJW-C21B SECM (District): Keith Rogers / AJW-C21B EOSH Coordinator: Hudson Varner / AJW-2C15H

EOSH IMPACTS

1. Asbestos:

The facility was surveyed and found asbestos containing materials (ACM) throughout the facility. Any activity that will result in the material being disturbed or subject to sanding, grinding, cutting, abrading, or burning may cause the material to become regulated. For ACM abatement, a FAA CSA asbestos work permit will need to be filed with the district SECM prior to the start of the work and shall be posted at the facility during all project activities. If previously unidentified materials are observed during construction, these materials should be presumed to contain asbestos and be treated as asbestos containing materials, the contractor should stop work, and the EOSH Professional should be contacted.

2. Chlorofluoro Carbons (CFCs):

Ensure replacement of HVAC systems with non-CFC equipment and ensure recovery and recycling of existing CFCs in accordance with Federal, State, Local, and FAA regulations.

Review FAA Order 1050.17 and 1050.18.

3. Compressed Gases:

Compressed gases may be utilized during the welding process of this project. Workers in charge of the oxygen or fuel-gas supply equipment, including generators and oxygen or fuel-gas distributions shall be instructed and judged as being competent by their employers for this work before being left in charge. Rules and regulations covering the operation and maintenance of oxygen or fuel-gas supply equipment shall be readily available. All welding activities should conform to the Engineering Services SOP for Welding and Compressed Gas.

4. Concrete and Masonry Work:

When providing project oversight pouring/placing or demolishing concrete the employees shall wear all required Personal Protective Equipment to reduce eye, skin, face, and head injury. All regulations will be followed according to OSHA 1926, Subpart Q. It is recommended that the employees wear pants and long sleeve shirts and don the proper hand, foot, eye, and face protection.

5. Confined/Permit Required Confined Spaces:

29 CFR 1926.21 (6) (i-ii)- All employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas. The work within the manholes shall be considered a permit required confine space if they meet the criteria set forth in 29 CFR 1910.146.

6. Cranes, Derricks, Lifts, and Hoists:

Employees or contractors that operate cranes, derricks, lifts, and hoists must complete specialized training for certification and authorization. All cranes onsite shall meet or exceed OSHA 29 CFR 1926, Subpart N. The crane service company shall have a licensed operator, crane inspection information, proper crane setup, proper rigging and lifting equipment, and follow and stay within all lifting charts. The crane company will need to have a certified rigger onsite with proper communication between them and the operator (radios and hand signals).

When utilizing cranes, derricks, lift, and hoists be aware of obstacles and obstructions including electrical power lines and ditches or trenches. Proper fall protection must be utilized when occupying such equipment.

7. Employee Health (First Aid / Blood Borne Pathogen / Infectious Disease):

When first aid situations arise, local emergency response systems shall be the primary source of emergency first aid. Ensure a viable and reliable source to contact first responders is present and functional within the worksite and ensure employees or contractors be properly instructed in how to access the system, e.g., by dialing 911. If working in rural areas where there is no coverage by a local emergency medical response system, make provisions for acceptable emergency transportation. Ensure that job sites or vehicles have a properly stocked and approved first aid kit.

To ensure compliance with FAA Blood Borne Pathogen/Infectious Disease rules and regulations make sure of the following;

• Appropriate engineering and work practice controls are in place.

• Ensure that appropriate personal protective equipment is available at the project site.

• Ensure social distancing is maintained, as required.

• Ensure the worksite is maintained in a clean and sanitary condition.

• Any spills of blood or other potentially infectious material on work surfaces are cleaned with an appropriate disinfectant.

All incidents resulting in first aid treatment should be reported in the same manner as any other occupational injury or illness as described in FAA Order 3900.19.

If you require further assistance with respect to first aid or blood borne pathogen requirements, please refer to FAA Order 3900.19, PASS CBA, Article 52, Section 15, NATCA CBA, Article 53, Section 5, OSHA - 29 CFR 1910.1030 - Bloodborne pathogens, PASS CBA, Article 52, Sections 8 and 15, NATCA CBA, Article 53, Sections 5 and 7, and OSHA - 29 CFR 1910.151 - Medical and First Aid.

8. Equipment Disposal:

Equipment to be removed contains hazardous materials (i.e. adhesives, CFC’s, sealants, etc.).

All disposal of the excessed equipment shall comply with 40 CFR Parts 260 - 266 and FAA Order 4600.27C, Personal Property Management.

9. Excavations, Trenching, or Boring:

All excavations, trenches, and boring activities shall adhere to the OSHA regulations within 29 CFR 1926, Subpart P. Employees should be aware of the hazards of open trenches, operation of vehicles and machinery near excavations, and familiar with trench protective systems.

https://employees.faa.gov/org/staffoffices/ahr/emp_labor_management_relations/labor_relations/agreements/media/07-02-00%20PASS-AF%20-%20Bus%200067.pdf https://employees.faa.gov/org/staffoffices/ahr/emp_labor_management_relations/labor_relations/agreements/media/07-02-00%20PASS-AF%20-%20Bus%200067.pdf https://employees.faa.gov/org/staffoffices/ahr/emp_labor_management_relations/labor_relations/agreements/media/NATCA_2009_BU_0053_0061_1545.pdf http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10122 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10122

10. Fall Protection:

A safety net, guardrails, or personal fall arrest/restraint system protect employee working at heights greater than four (4) feet or near an unprotected edge should use. The employee/contractor should follow all OSHA regulations and FAA order 3900.63, Fall Protection Program. The possible use of ladders and lifts are the existing fall hazards for this project. Inspects ladders before use.

The use of buckets trucks, cherry pickers, and personnel lifts require specific training on that piece of equipment. The employee/contractor should follow the manufacturer’s instructions for safe operations. The use of a Personal Fall Arrest System may be required for safe operation at heights while elevated work platform is in use.

11. Fire and Explosion Hazards:

Fire and explosion hazards are prevalent in virtually every job site. Maintain effective fire protection and prevention programs at the job site throughout all phases of the construction, repair, alteration, or demolition work. Ensure the availability of proper fire protection and suppression equipment throughout each phase of the project. Guidance on fire and explosion hazards on the job site can be found within 29 CFR 1910 Subparts E, G, H, L, N, Q, R and Z, 29 CFR 1926 Subparts C, D, F, H, J, K, R, S, T and U and FAA Order 3900.19.

12. Fire Life Safety:

An emergency action plan should be established to identify exit routes and means of egress in case of an emergency. Good housekeeping practices are required to ensure a safe means of egress and to eliminate a possible fuel source for fires. For additional reference regarding fire life safety, refer to OSHA CFR 1910 Subpart L.

13. Hazard Communication:

• Familiarize yourself with the applicable FAA and OSHA standards regarding hazard communication.

• Obtain from SSC or create a list of the hazardous chemicals in the workplace.

• Obtain safety data sheets for all chemical substances in the workplace.

• Ensure that all containers are labeled.

• Request and review the District SSC Written Hazard Communication Programs.

Guidance on Hazard Communication include, FAA Order 3900.19B, Chapter 19, FAA Order 6000.54, Airway Facilities Hazard Communication Program, PASS CBA, Article 52, Section 10, and OSHA - 29 CFR 1910.1200 - Hazard Communication. If you need further assistance regarding hazard communication, contact the District Safety and Environmental Compliance Manager (SECM) or EOSH contract support staff at the pertinent Technical Support Center

(TSC).

14. Hazardous Energy (Construction):

Based on the parameters of the project, lockout/tag out is required. The contractor/employee is responsible for creating equipment specific lockout/tag out procedures for this project. Refer to the Engineering Services Standard Operating Procedures (SOP) Hazardous Energy for work https://employees.faa.gov/employee_services/safety/occ_safety/order3900/media/ch19.pdf http://www.faa.gov/documentLibrary/media/Order/6000_54.pdf http://www.faa.gov/documentLibrary/media/Order/6000_54.pdf https://employees.faa.gov/org/staffoffices/ahr/emp_labor_management_relations/labor_relations/agreements/media/07-02-00%20PASS-AF%20-%20Bus%200067.pdf http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099 requirements regarding lockout / tag out. For reference regarding hazardous energy lockout / tag out, refer to OSHA (29 CFR 1910.147 and 1960) and by FAA Order 3900.19.

15. Hearing Conservation:

Based on the project parameters, the potential for employees or the contractor to be exposed to high intensity and frequent high levels of noise exist. When conducting project oversight, ensure the use of appropriate personal protective equipment (PPE) to reduce noise level exposure of the employee or contractor. When the lack of suitable determination for the selection of proper PPE is not offered, ensure the most stringent PPE is available. This would include the use of ear plugs and ear muffs in combination. Utilize PPE when noise levels become uncomfortable for the individual. For further guidance regarding hearing conservation, refer to OSHA 1910 Subpart G and FAA Order 3900.19.

16. Housekeeping

• During the course of construction, alteration, or repairs maintain the following:

• Form and scrap lumber with protruding nails, and all other debris, shall be kept cleared from work areas, passageways, and stairs, in and around buildings or other structures.

• Walkways shall be kept clear of obstructions.

• Combustible scrap and debris shall be removed at regular intervals during the course of construction.

• Containers shall be provided for the collection and separation of waste, trash, oily and used rags, and other refuse.

• Containers used for garbage and other oily, flammable, or hazardous wastes, such as caustics, acids, harmful dusts, etc. shall be equipped with covers.

• Garbage and other waste shall be disposed of at frequent and regular intervals.

17. Indoor Air Quality (IAQ):

• The FAA will comply with all State and local IAQ regulatory requirements. To prevent IAQ issues from occurring:

• Conduct work operations in such a manner as to prevent IAQ problems from arising.

• Take care not to hinder the operation of the heating, ventilating and air conditioning systems (HVAC) system (e.g. blocking vents).

• Keep the work environment clean.

• Follow instructions on container labels and Safety Data Sheets (SDS) when using chemicals.

• If water leaks or moisture is observed, dry materials within 48 hours.

• Repair any damaged and / or leaking pipe systems and other water intrusions.

• Discard all sewage contaminated porous materials.

• Conduct routine surveillance inspections of the building envelope and all mechanical systems for moisture intrusions.

18. Lead Acid Batteries:

This project will involve the removal and installation of lead acid batteries. Standard precautions should be taken for handling and moving these batteries to prevent spills of the electrolyte fluids.

Any spills or indications of spills should be promptly cleaned up.

19. Lightning Safety:

Know your local weather patterns and if lightning is observed, avoid water, open areas, metal objects, and take shelter in a building or vehicle. Suspend outdoor activities for 30 minutes after the last observed lightning or thunder. When working with power equipment, ensure the use of lightning arresters.

Ensure FAA-STD-019, Lighting and Surge Protection, Grounding, Bonding and Shielding for Facilities and Electronic Equipment is followed for installation of new equipment.

20. Mercury:

Examples of equipment or building components that may contain mercury include switches, thermostats, batteries, fluorescent lamps, thermometers, flame sensors, and flow meters. For this project it has been determined that mercury switches are present. Ensure proper identification and disposal or recycling of mercury containing components prior to the demolition of the facility. Ensure proper disposal and / or recycling in accordance with Federal, State, and Local regulations.

21. NEPA:

The project qualifies for a Categorical Exclusion, per FAA Order 1050.1F, Paragraph 5-6.4.o, and 5-6.4.aa.

22. Personal Protective Equipment (PPE):

Following review of the project scope of work, the EOSH Coordinator has determined that PPE is required for this project. PPE should consist of gloves, hard hats, hearing protection, reflective vests, respiratory protection, safety glasses, and safety boots / shoes. OSHA 1926 Subpart E and FAA Order 3900.19B JC Supplement; Personal Protective Equipment Program provides guidance and instructions on the selection, use, and maintenance of PPE.

23. Post Construction Lockout / Tag out (LOTO) Plan:

The designer/contractor will develop a site-specific LOTO plan for existing equipment modifications and new installation. This plan will be based on manufacturers recommended procedures and site-specific switch locations and conditions. The plan will follow the standard FAA LOTO format.

24. Slips, Trips & Falls:

• Wear proper footwear with slip-resistant soles.

• Ensure that work environments are properly maintained through good housekeeping practices.

• Keeping walking areas free of electrical cords and wires.

• Provide sufficient lighting in walkways, eliminating uneven floor surfaces.

• Pay attention to your surroundings.

Guidance on slips, trips, and falls can be found within 29 CFR 1910 Subpart D- Walking Working Surfaces, 29 CFR 1926.500 (Subpart X)-Ladders, ANSI A1264.1 Safety Requirements for Workplace Floor and Wall Openings, Stairs and Railing Systems, and FAA Order 3900.19.

25. Thermal Stress:

Exposure to extreme heat or cold may result in occupational illnesses or injury. Ensure proper clothing, hydration and work practices are utilized to minimize the effects of thermal stress.

Check local weather conditions prior to site activities and if questions arise concerning thermal stress, contact an EOSH coordinator.

26. Two Person Rule To comply with OSHA regulations and FAA orders, a “Two Person Rule” will be implemented, which prohibits employees from working alone under certain situations where there are employees working at heights, where employees are working with electrical systems over 50v, where employees are at risk of electrocution, or where medical emergency response is not readily available, must be trained in first aid and CPR. In each case, the second person must be trained in first aid and CPR.

27. Walking-Working Surfaces:

The employer should protect their employees from floor openings when working on the jobsite.

OSHA 1910, Subpart D specifies worker safety and eliminating falls from stairs, scaffolding, ladders, and working platforms by outlining handrail requirements, tread heights, safe ladder usage, and the proper selection of fall protection methods. OSHA 1910.22 provides guidance on how to assist in the elimination of potential hazardous conditions by practicing good housekeeping and keeping aisles and passageways free of any clutter, materials, or debris. FAA Order 3900.63 covers all walking and working surfaces and fall protection requirements for construction and installation projects within the FAA. If not specified, use the more stringent of the two sources for fall protection requirements (e.g.- Duty to provide fall protection).

28. General:

The Longview SSC and DFW District shall provide Safety Data Sheets (SDS) for hazardous materials already present in the workplace. Contractors shall identify and provide SDS’s for all hazardous materials brought into the work area by themselves or their sub-contractors. All Personal Protective Equipment shall be worn at all times to protect from head, eye, face, and foot injuries. Please contact any of the following personnel if any environmental, health or safety issues arise:

DFW District SECM/EPS Lenny Ramos 817-858-7450 214-563-3328 SECM/EPS Keith Rogers 972-615-2347 EOSH Coordinator Hudson Varner 817-222-5279

29. PRE-CONSTRUCTION CHECKLIST:

This checklist (see Attachments, below) is intended to be used as a tool by RE/COTRs, designated facility POCS, or SSC managers who oversee construction and maintenance activity that potentially have EOSH 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 EOSH 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 EOSH professionals, project personnel and contractors

• Facilitate review of critical FAA EOSH procedures with contractors

• Raise EOSH awareness

This checklist relies on the training and professional judgment of the user. EOSH 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.