Exhibit C - Construction EHS Manual - Version 7.pdf

Version 7 (0519)

Construction Environment, Safety & Health Manual i

Table of Contents List of Acronyms and Abbreviations ....................................................................................................... vi 1 Introduction

1.1 Background

1.2 Definitions

1.3 Layout and Use of this Manual—Imperative Information

1.3.1 Scope

1.3.2 Layout of this Manual

1.3.3 Use of this Manual

2 Program Policy

2.1 Applicability

2.2 Regulatory Requirements

2.3 NREL Specific Requirements

2.3.1 Construction ESH Plan

2.3.2 Training and Documentation

2.3.3 Safety Bulletin Boards

2.3.4 Subcontractor Incident Response and Notification

2.3.5 NREL Response to Emergencies on Major Construction Sites

2.3.6 Construction Subcontractor Event Investigation

2.3.7 Construction Subcontractor Initial Screening Process

2.4 NREL Special Emphasis

2.4.1 Integrated Safety Management (ISM) System

2.4.2 Stop Work Authority

2.5 Subcontractor Responsibilities

2.6 References

3 Occupational Medicine

3.1 Applicability

3.2 Regulatory Requirements

3.3 NREL Specific Requirements/Permits

3.4 NREL Special Emphasis

3.5 Subcontractor Responsibilities

3.6 References

4 Construction Hazard Identification and Control Process

4.1 Applicability

4.2 Regulatory Requirements

4.3 NREL Specific Requirements/Permits

4.3.1 General Requirements

4.3.2 Activity Hazard Analyses

4.3.3 Worker Training

4.3.4 Record of Training

4.4 Subcontractor Responsibilities

4.5 References

5 ESH Meetings, Inspections, and Orientations

5.1 Applicability

5.2 Regulatory Requirements

5.3 NREL Specific Requirements

5.3.1 Daily ESH Activity Briefings

5.3.2 Plan of the Day Meeting

5.3.3 Monthly ESH Meetings

5.3.4 Daily ESH Inspections, Hazard Analyses and Permits

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5.3.5 Weekly ESH Inspections

5.3.6 Subcontractor Employee ESH Orientation

5.3.7 Bilingual Requirements

5.4 NREL Special Emphasis

5.4.1 Weekly ESH Report

5.5 References

6 Control of Hazardous Energy, Lockout/Tagout

6.1 Applicability

6.2 Regulatory Requirements

6.3 NREL Specific Requirements/Permits

6.3.1 Energized Electrical Work

6.3.2 NREL Building Equipment and Systems Lockout/Tagout

6.3.3 Equipment Specific Lockout/Tagout Procedures

6.3.4 Subcontractor Lockout/Tagout Inspection Procedures

6.3.5 Subcontractor Training Requirements

6.4 NREL Special Emphasis

6.4.1 Applying Lockout/Tagout

6.5 References

7 Electrical Safety

7.1 Applicability

7.2 Regulatory Requirements

7.3 NREL Specific Requirements/Permits

7.3.1 General Electrical Work Safety Requirements

7.3.2 Lockout/Tagout

7.3.3 Hazardous Energized Electrical Work

7.3.4 Two-Worker Rule

7.3.5 Safe Penetration of Building Surfaces

7.3.6 Excavations

7.4 References

8 Excavations

8.1 Applicability

8.2 Regulatory Requirements

8.3 NREL Specific Requirements/Permits

8.3.1 NREL Excavation Permit

8.3.2 NREL Excavation Lockout/Tagout

8.3.3 Subcontractor Training Requirements

8.4 NREL Special Emphasis

8.4.1 Underground Services/Utilities

8.4.2 Munitions and Explosives of Concern

8.5 Subcontractor Responsibilities

8.6 References

9 Fire Protection and Prevention

9.1 Applicability

9.2 Regulatory Requirements

9.3 NREL Specific Requirements/Permits

9.3.1 Working with Open Flame, Welding, Cutting, or Grinding

9.3.2 Hot Work Permit System

9.3.3 Fire Protection System Outages and Impairments

9.3.4 Exits and Exits Access

9.3.5 Flammable and Combustible Liquids Storage

9.3.6 Smoking/Wildfire

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9.3.7 Housekeeping/Trash

9.3.8 Portable Electric Heaters

9.4 References

10 Hoisting and Rigging

10.1 Applicability

10.2 Regulatory Requirements

10.3 NREL Specific Requirements/Permits

10.3.1 Operator Training and Certification

10.3.2 Hoisting and Rigging Operating Requirements

10.3.3 Environmental Factors

10.3.4 Crane Inspection, Maintenance, and Testing

10.3.5 Rigging Safety Requirements

10.3.6 Inspection Criteria for Slings, Below-the-Hook Lifting Devices and Rigging Hardware

10.3.7 Personnel Hoisting

10.4 NREL Special Emphasis

10.4.1 Department of Energy Hoisting and Rigging Standard

10.4.2 Suspect and Counterfeit(S/CI) Rigging and Hoisting Components

10.5 References

11 Fall Protection

11.1 Applicability

11.2 Regulatory Requirements

11.3 NREL Specific Requirements/Permits

11.3.1 Fall Protection Program

11.3.2 Subcontractor Training Requirements

11.3.3 National Wind Technology Center

11.4 NREL Special Emphasis

11.4.1 Presumption of Feasibility

11.4.2 Rescue Planning

11.5 References

12 Hearing Conservation

12.1 Applicability

12.2 Regulatory Requirements

12.3 NREL Specific Requirements

12.3.1 Control Measures

12.3.2 Noise Evaluation

12.3.3 High Noise Area Posting

12.4 References

13 Industrial Hygiene

13.1 Applicability

13.2 Regulatory Requirements

13.3 NREL Specific Requirements/Permits

13.3.1 General Requirements

13.3.2 Sanitation

13.3.3 Temperature Extremes

13.3.4 Lighting and Illumination

13.3.5 Ventilation

13.3.6 Lead Program

13.3.7 Hexavalent Chrome

13.3.8 Laser Use

13.3.9 Safety Showers and Eyewashes

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13.3.10 Ionizing Radiation

13.3.11 Blood-Borne Pathogens

13.3.12 Other Health Hazards

13.4 NREL Special Emphasis

13.5 Subcontractor Responsibilities

13.6 References

14 Asbestos Management

14.1 Applicability

14.2 Regulatory Requirements

14.3 NREL Specific Requirements/Permits

14.3.1 Subcontractor Responsibilities

14.3.2 Permits

14.4 NREL Special Emphasis

14.5 References

15 Silica Management

15.1 Applicability

15.2 Regulatory Requirements

15.3 NREL Specific Requirements/Permits

15.3.1 Subcontractor Responsibilities

15.4 References

16 Personal Protective Equipment (PPE)

16.1 Applicability

16.2 Regulatory Requirements

16.3 NREL Specific Requirements/Permits

16.3.1 General Requirements

16.3.2 Training

16.3.3 Specific Requirements

16.4 Subcontractor Responsibilities

16.5 References

17 Hazard Communication

17.1 Applicability

17.2 Regulatory Requirements

17.3 NREL Specific Requirements/Permits

17.3.1 General Requirements

17.3.2 Specific Communication Requirements

17.4 NREL Special Emphasis

17.5 Subcontractor Responsibilities

17.6 References

18 Confined Space

18.1 Applicability

18.2 Regulatory Requirements

18.3 NREL Specific Requirements/Permits

18.3.1 Confined Space Work at NREL

18.3.2 Confined Space Classification

18.3.3 New or Previously Unidentified Confined Spaces

18.3.4 NREL Verification of Subcontractor’s Compliance with Confined Space Entry

18.3.5 Confined Space Entry Notification

18.3.6 Subcontractor Training Requirements

18.4 References

19 Building Surface Penetrations

19.1 Applicability

v

19.2 Regulatory Requirements

19.3 NREL Specific Requirements/Permits

19.3.1 Surface Penetrations

19.4 References

20 Environmental Requirements

20.1 Applicability

20.2 Regulatory Requirements

20.3 NREL Specific Requirements/Permits

20.3.1 National Environmental Policy Act Requirements (NEPA)

20.3.2 Stormwater Discharge Requirements

20.3.3 Air Emissions Requirements

20.3.4 Pipe Flushing

20.3.5 Trash, Construction Debris, and Sanitary Waste

20.3.6 Wastewater

20.3.7 Hazardous Waste

20.3.8 Noise

20.3.9 Pesticide and Herbicide Use

20.3.10 Vegetation

20.3.11 Natural Resources—Wildlife

20.3.12 Preservation of Historical Resources

20.3.13 Wetland and Drainage Areas

20.4 Subcontractor Responsibilities

20.5 References

21 Temporary Traffic Control Requirements

21.1 Applicability

21.2 Regulatory Requirements

21.3 NREL Specific Requirements/Permits

21.3.1 Temporary Traffic Control Plan (TTCP)

21.4 NREL Special Emphasis

21.5 References

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List of Acronyms and Abbreviations ACGIH American Conference of Governmental Industrial Hygienists

ACM asbestos-containing material

AHA activity hazard analysis

ALARA as low as reasonably achievable

ANSI American National Standards Institute

APCD Air Pollution Control Division (Colorado)

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

BEC building emergency coordinator

BMPs best management practices

CCR Colorado Code of Regulations

CFHA Construction Fall Hazard Analysis

CFR Code of Federal Regulations

CMS Central Monitoring Station

CPR cardiopulmonary resuscitation

CRS Colorado Revised Statute

CSWP Construction Safe Work Permit dB decibels dBA decibels, A-weighted scale

DOP di-octyl phthalate

DOE U.S. Department of Energy

ECT equivalent chill temperature

EEWP Energized Electrical Work Permit

ESH Environment, Safety, Health vii

EPA U.S. Environmental Protection Agency

FHA Fall Hazard Analysis

FM Facility Manager

GFCI ground fault circuit interrupter

HEPA high efficiency particulate absolute

H&R hoisting and rigging

IH industrial hygiene

IPT Integrated Project Team

ISM Integrated Safety Management

LEED Leadership in Energy and Environmental Design

LO/TO lockout/tagout mA milliamps

MEC munitions and explosives of concern

MOP method of procedure

MUTCD Manual on Uniform Traffic Control Devices

NEPA National Environmental Policy Act

NFPA National Fire Protection Association

NIST National Institute of Science and Technology

NREL National Renewable Energy Laboratory

FC Flatirons Campus

OSHA Occupational Safety and Health Act, or Occupational Safety and Health Administration

PFAS personal fall arrest system

POC point of contact

POD plan of the day

PPE personal protective equipment viii

PM Project Manager

RCRA Resource Conservation and Recovery Act

RFP request for proposal

RSO radiation safety officer

SAIA Scaffold & Access Industry Association

SDS safety data sheet

S/CI suspect and counterfeit items

STM South Table Mountain

SWPPP stormwater pollution prevention plan

TOA Task Order Agreement

TTCP Temporary Traffic Control Plan

TLV threshold limit value

TWA time-weighted average

UL Underwriter’s Laboratory

USC United States Code

1 Introduction The Construction Environment, Safety & Health (CESH) Manual (hereafter referred to as “this Manual”) has been developed to identify the minimum requirements for Construction Subcontractors and their lower-tier subcontractors (hereafter referred to as “Subcontractor”) that require personnel to perform construction activities at the U.S. Department of Energy (DOE)’s National Renewable Energy Laboratory (NREL) Sites.

1.1 Background

It is DOE policy that all construction subcontractors shall provide a safe and healthful workplace for their personnel. In part, these conditions will be ensured by implementing the worker safety and health program established in 10 CFR Part 851—Worker Safety and Health Program. Each Contractor is responsible for ensuring compliance with “all applicable requirements” that govern their work at NREL facilities, including any consensus standards incorporated therein by reference.

1.2 Definitions

Activity Hazard Analysis: A work control document that identifies the work tasks, hazards and controls of the work to be performed; it is conveyed to the workers for review, input, acceptance and adherence.

Competent Person: One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt, corrective measures to eliminate them. A Competent Person also is one who has extensive training knowledge/experience in a particular activity or job function. A Competent Person at NREL shall be capable of demonstrating the “knowledge and skill-sets” that match their “Competent Person” designation.

Construction Activity: Is any combination of erection, installation, assembly, demolition, or fabrication activities involved to create a new facility or to alter, add to, rehabilitate, dismantle, or remove an existing facility. It also includes the alteration and repair (including dredging, excavating, and painting) of buildings, structures, or other real property, as well as any construction, demolition, and excavation activities conducted as part of environmental restoration or remediation efforts.

Construction Subcontractor: A person, corporation, or other entity, other than the prime contractor (NREL), who furnishes labor, supplies, materials, equipment, or services in furtherance of the DOE’s mission under a construction or similar contract with NREL, including a task order agreement (TOA). A subcontractor's site tenure may vary depending on the nature of the project, and its employees are not considered a permanent construction force.

Construction Subcontractor Safety Orientation Checklist: An NREL form used to document the project relevant ESH information conveyed to the subcontractor prior to starting work. The subcontractor then has the responsibility to ensure the content covered in the checklist/orientation is effectively flowed down to all their employees and their subcontractors prior to the start of any work.

http://www.nrel.gov/extranet/pol_proc/forms/f1189.doc

Construction Environmental, Safety and Health Plan (CESHP): A document prepared by the Subcontractor and submitted to the NREL Environmental, Safety, Health & Quality (ESH&Q) Point of Contact (POC) for review and concurrence. Describes the subcontractor's environment, safety and health plan and for a particular construction project and the AHA(s) for each definable activity/feature of work.

Construction Project Manager (NREL): NREL-delegated representative authorized to approve and accept work, provide technical liaison, and interpret NREL plans and specifications on behalf of NREL.

Subcontractor Safety Manager: An employee of the subcontractor at the work site who is responsible for assisting the implementation of the CESHP and compliance with applicable laws and regulations. The qualifications of the subcontractor’s Safety Manager shall be listed in the subcontractor’s CESHP. For some projects, the project specifications may require the subcontractor to have the full-time on-site services of a more highly qualified individual (e.g., Certified Safety Professional, Qualified person etc.).

Graded Approach: Applying a level of rigor commensurate with the importance or significance of the activity, in relation to the associated hazards and consequences to ensure available resources are used most efficiently and effectively. A graded approach is recommended for implementing the work planning and control (i.e., the CESHP and accompanying AHAs). The level of detail within each CESHP and corresponding AHA should be based on the size, complexity and risk level of the construction project.

Hold Point: A point of defined circumstances (i.e., Excavation Permit, Hot Work Permit) beyond which a construction activity must not proceed without the approval of a designated authority.

Imminent Danger: A condition or practice that could reasonably be expected to cause death or serious injury, severe property damage, or environmental impairment unless immediate actions are taken to mitigate the effects of the hazard created.

Non-NREL Site: Land, buildings, or structures, including installed equipment and utilities, that are used by NREL workers conducting NREL work but are neither leased or government owned specifically for NREL operations. Examples are sites owned by research partners or other government agencies and used by NREL workers conducting NREL business.

NREL Site: A geographic area owned or leased by or for the account of the federal government for the performance of DOE program activities. This includes extant building, infrastructure, and other improvements. Some of the areas included in the NREL Site that are more commonly referred to include the South Table Mountain (STM) Site, Flatirons Campus, Denver West buildings, ReFUEL and the Warehouse.

Qualified Person: One who, by possession of a recognized degree, certificate, or professional standing, or with extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the construction project.

Subcontractor Administrator: An NREL employee who is authorized to award and administer a subcontract on behalf of NREL.

Worker: A leased worker, subcontractor, independent contractor/consultant, volunteer, or other individual providing construction services to NREL or working on NREL Sites.

1.3 Layout and Use of this Manual—Imperative Information

1.3.1 Scope

This Manual contains excerpts from, and references to, numerous regulations, codes, and standards that are not presented in their entirety. Similarly, not all Environmental, Safety, Health & Quality (ESH&Q) subject matter is covered in this Manual. Each Subcontractor is responsible for ensuring compliance with “all applicable requirements” that govern their work at NREL facilities, including any consensus standards incorporated in 10 CFR 851 by reference. If the Manual does not contain information relative to a particular ESH&Q topic, the Subcontractor shall ensure the governing regulatory provisions or national consensus standards as applicable are implemented as part of their CESHP. If there is a conflict between requirements, the Subcontractor is to apply the most stringent unless otherwise directed by the NREL ESH POC.

Subcontractors are always encouraged to apply best management practices in all endeavors.

1.3.2 Layout of this Manual

The chapters in this Manual are arranged according to topic area and, in general, are laid out in the same format. The chapter will identify who the requirements apply to, the broad regulatory drivers and the Subcontractor’s responsibilities.

Each chapter also will identify any requirements specific to the NREL site and/or the DOE. Also presented in each chapter are issues of special emphasis that NREL has identified or for which additional risk control mechanisms are required (i.e., safety plans to be submitted for review and acceptance by the ESH POC, or permits required prior to performing work, etc.).

1.3.3 Use of this Manual

It is the responsibility of the subcontractor to know, understand and plan for the NREL-specific requirements/special emphasis programs. Further, it is the responsibility of the subcontractor to ensure lower tier subcontractors know, understand and comply with the requirements identified in this Manual. To help ensure on-going compliance, the prime Subcontractor Superintendent must maintain a copy (hard or electronic) of the current version of this Manual on each project. NREL-specific requirements may affect what the subcontractor includes in their AHAs, Lockout-Tagout, Method of procedures (MOPs), etc. and how the Subcontractor conducts work and the overall project schedule.

2 Program Policy

2.1 Applicability

The requirements of this section apply to all Construction Subcontractors and lower-tier sub-contractors (hereafter referred to as “Subcontractor”) performing construction activities on NREL Sites.

This section provides requirements for identifying key aspects of the subcontractor environmental, safety and health policies to provide all employees a safe and healthful workplace while also protecting the environment in compliance with DOE and OSHA.

2.2 Regulatory Requirements

The NREL facilities are government-owned or leased facilities and subject to 10 CFR 851 Worker Safety & Health Program requirements. While the enforcement provisions of OSHA of 1970 do not apply, as NREL facilities are government-owned, DOE has exercised its statutory authority to prescribe that all subcontractors comply with the OSHA Safety and Health Standards for General Industry (29 CFR 1910) and Construction (29 CFR 1926); DOE will enforce compliance with these standards. The provisions of 10 CFR 851.23 require subcontractors to comply with specific safety and health standards, including:

• Title 29 CFR, Parts 1904.4 through 1904.11, 1904.29 through 1904.33; 1904.44, and 1904.46, ‘‘Recording and Reporting Occupational Injuries and Illnesses’’

• Title 29 CFR, Part 1910, ‘‘Occupational Safety and Health Standards,’’ excluding 29 CFR 1910.1096, ‘‘Ionizing Radiation’’

• Title 29 CFR, Part 1926, ‘‘Safety and Health Regulations for Construction’’

• American Conference of Governmental Industrial Hygienists (ACGIH), ‘‘Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices’’ Latest edition

• American National Standards Institute (ANSI) Z88.2, ‘‘American National Standard for Respiratory Protection’’ (2015)

• ANSI Z136.1, ‘‘Safe Use of Lasers’’ (2014)

• ANSI Z49.1, ‘‘Safety in Welding, Cutting and Allied Processes,’’ Sections 4.3 and E4.3 (2012)

• National Fire Protection Association (NFPA) 70, ‘‘National Electrical Code’’ (2017)

• NFPA 70E, ‘‘Standard for Electrical Safety in the Workplace’’ Latest edition

• Title 10 Code of Federal Regulations (CFR) 850, ‘‘Chronic Beryllium Disease Prevention Program.”

Other regulations are listed at 10 CFR 851.23 but may not be applicable depending on the construction activities. It must be understood that 10 CFR 851 provides the basic foundation for a worker safety and health program and that subcontractors may need to go beyond the rule’s minimum requirements in establishing programs to protect workers from hazards associated with their activities.

2.3 NREL Specific Requirements

2.3.1 Construction ESH Plan

Each subcontractor performing construction work at NREL is required to develop a Construction Environmental, Health & Safety Plan (CESHP) prior to conducting any work activities on site.

The subcontractor shall ensure that the requirements in this Manual are incorporated into their CESHP and the associated Activity Hazard Analyses (AHAs). The CESHP shall be submitted in accordance with the contract requirements document and undergo a review and concurrence by the ESH POC prior to the Subcontractor being allowed to start work.

NREL provides each subcontractor with an electronic copy of the CESHP template to be used for their plan. A new CESHP shall be submitted for each construction project, regardless of whether the subcontractor has performed prior work at NREL. The template is provided in electronic format to enable cut-and-paste functions for those Subcontractors whose basic data remains unchanged yet tailor the hazard and controls information pertinent to the activities/materials/location of the project at hand. Similarly, the core safety management mechanism, the AHA, is provided in electronic format to make production of the AHA as easy as possible yet project specific (see Section 4.3).

NREL recommends using a graded approach in the development of CESHPs. This approach determines the level of rigor for implementing the work planning and control attributes based on the importance/significance of the activity in relation to the associated hazards and consequences. The level of detail within each CESHP and corresponding AHA should be commensurate with the size, complexity and risk level of the construction project.

Field changes (i.e., red line, pen/ink changes) to the CESHP are acceptable. All affected Subcontractor supervision personnel involved in the work being performed shall review the CESHP and any subsequent changes. The updated CESHP shall be made available for review and concurrence by the ESH POC. The CESHP shall be kept at the worksite.

2.3.2 Training and Documentation

For all subcontractor workers at NREL, site-specific environment, safety and health orientation will be required in accordance with Section 5.3.6. This orientation will be documented by having each affected worker sign the Subcontractor Safety Orientation Checklist.

For work activities in which specific training is required by safety regulations (e.g., OSHA), the Subcontractor shall maintain records on-site, showing proof of current training records for any particular authorized workers. Designated “Competent Persons” are expected to have a higher level of experience, training and qualification. Subcontractors shall have in place a mechanism to verify the “Competent Person’s” knowledge and skill-sets match the “Competent Person” designation (i.e., written test, training certifications, etc.).

Additional requirements to provide verification of worker training are identified on the CESHP template. Photocopies of training certificates, certification cards, wallet IDs, licenses, etc.

identifying the individual, the specific training, who conducted the training and the date completed (and/or expiration date) are accepted in lieu of originals.

In addition, NREL may require some projects to have specific qualifications for their designated on-site safety representative (e.g., 30-hour Construction Safety, Safety Trained Supervisor, Board of Certified Safety Professionals Certification, etc.), depending on the complexity of the project and hazards involved. NREL will identify this requirement in the request for proposal.

2.3.3 Safety Bulletin Boards

The subcontractor is responsible for installing and maintaining a safety bulletin board at the location where most employees report to work. Workers shall be advised of the location of the nearest bulletin board. Employees shall be responsible for reviewing the bulletin board to keep informed of safety-related information. Safety bulletin boards shall be sufficient size to display and post safety bulletins, newsletters, posters, accident statistics, and other safety educational material. At a minimum, the safety bulletin board shall display:

• DOE Occupational Safety and Health Poster DOE-F 5480.2 (Your Rights as a Worker)

• DOE Occupational Safety and Health Complaint Form 5480.4

• Requirements, provisions and number of the Employee Concern Program Hotline (Whistleblower Protection)

• Citations and notices as appropriate

• OSHA 300A form during February 1 to April 30

• NREL-furnished safety bulletins and publications

• Stormwater discharge permit notice (as applicable).

Suggested additional items to be posted include:

• Topical safety and health posters

• Minutes of safety meetings

• Information on accidents and lessons learned

• Hazard communication information.

2.3.4 Subcontractor Incident Response and Notification

The subcontractor shall report all incidents involving injury, property damage and near misses, no matter how minor, to the NREL ESH POC and the NREL PM as soon as the scene is stabilized, but in all cases, a notification shall be made as soon as possible, but within one hour of occurrence. This reporting time frame is necessary in order to meet DOE notification time requirements to begin any necessary event investigation, scene security, cleanup, and traffic rerouting, etc.

For all emergencies at the NREL Sites (excluding the Flatirons Campus), the subcontractor shall contact the Security by:

• Utilizing any building red phone

• Dialing extension 1234 from the building landline

• By calling (303) 384-6811 from any outside line (cell phone) Note: DO NOT call 911, as this will cause confusion and delays. The Central Monitoring Station (CMS) will coordinate and direct the emergency response services to your location.

• For work at Flatirons Campus, the subcontractor shall call 911 and then call security at 303 384-6811. All other incident response requirements apply to work at the Flatirons Campus.

For CLI construction projects or projects independent of NREL buildings, the subcontractor, as part of its emergency response plan, must designate a member (or members) of their staff, who has the authority and is capable of directing emergency response on the job site. This individual will act as the communication point of contact between internal (NREL) and external agencies and is responsible for the coordination of an on-scene emergency situations from initial response through stabilization in coordination with the incident commander (West Metro). For construction projects associated with existing NREL buildings, the NREL Building Emergency Coordinator (BEC) will direct the emergency response actions until West Metro arrives.

The subcontractor must provide and identify the method for prompt notification to NREL’s Central Monitoring Station (CMS)/Security via landline, cell phone or contractor provided radio.

A site map showing assembly points and directions to the subcontractor’s authorized medical facilities shall be posted on site at the project location (e.g., site project office) and included as part of its CESHP (this should be the last page of the CESHP to facilitate easy of retrieval). A copy shall also be posted at the subcontractor’s project field office. Upon award of the work, contact the NREL PM or ESH POC for electronic copies of building evacuation routes and assembly areas to include in the CESHP’s map(s), as needed.

2.3.5 NREL Response to Emergencies on Major Construction Sites Upon notification of an emergency situation on a major construction site, NREL will provide notification to external and internal responders. Internal responders include: ESH POCs, Security & Emergency Preparedness personnel, and if applicable, our internal Chemical Response Team

(CRT).

NREL internal responders will be required to have completed the Site-Specific Safety Orientation (subcontractor provided) and must have the minimum required PPE. Other stipulations include:

• Health and Safety staff has no medical response responsibilities. Only ESH POCs shall respond to major construction incidents (medical or otherwise). Other properly oriented and trained ESH&Q staff may respond to provide support and direction in accordance with established procedures (such as spills).

• Occupational nurse response shall be at the request of the Subcontractor.

• Occupational nurses may respond to the construction site administration area and offer services. Access/response to the injured worker’s location shall be only at the request of the subcontractor.

• Occupational nurse PPE will be a minimum of sturdy footwear, safety glasses and hardhat. In the absence of this PPE, no response will be provided.

• Even if requested by the subcontractor, occupational nurse response is not guaranteed— workload and availability may preclude a response.

2.3.6 Construction Subcontractor Event Investigation

After the response has occurred and the scene is stabilized and secure, the subcontractor must initiate an event investigation and/or participate with the ESH event investigation, as determined by NREL. There is an expectation and responsibility to fully understand what occurred, what caused the event and to identify corrective actions. The subcontractor is further responsible for the prompt implementation of corrective actions for deficiencies identified through an ESH event investigation, or as reported by DOE, the PM, ESH POC, or other authorities having jurisdiction.

2.3.7 Construction Subcontractor Initial Screening Process

All NREL subcontractors and all their lower-tier subcontractors are required to meet pre-established ESH risk criteria prior to being awarded a subcontract to perform construction work at NREL Sites. The NREL Acquisition Services includes the ESH Subcontract Risk Evaluation Worksheet as part of construction solicitations and confirms and verifies all potential subcontractors and lower-tier subcontractors have properly completed the worksheet. NREL Procurement will forward the subcontractor or lower-tier Experience Modification Rate (EMR).

The subcontractor is responsible for ensuring all its lower-tier subcontractors’ ESH&Q Subcontract Risk Evaluation Worksheets are submitted to NREL ESH POC for review and approval prior to performing work on an NREL Site. All subcontractors are required to meet the minimum EMR of 1.0. Additional information regarding the subcontractor screening process can be found on the NREL Construction Subcontractor website located at https://www.nrel.gov/about/ehs-construction.html

2.4 NREL Special Emphasis

2.4.1 Integrated Safety Management (ISM) System

The subcontractor shall incorporate the elements of ISM into its CESHP that conforms to NREL’s Integrated Safety Management requirements. An effective ISM plan establishes a single system that integrates requirements into the work planning and execution process to protect the workers, public, and the environment. NREL implements the following five core ISM functions for work activities that could potentially affect workers, the public, or the environment and applies them as a continuous cycle with the degree of rigor appropriate to address the type of work activity and the hazards involved.

• Define the Scope of Work. Translate missions into work, set expectations, identify and prioritize tasks, and allocate resources.

http://www.nrel.gov/extranet/pol_proc/forms/f1320.doc http://www.nrel.gov/extranet/pol_proc/forms/f1320.doc https://www.nrel.gov/about/ehs-construction.html

• Analyze the Hazards. Identify, analyze, and categorize hazards and potential environmental impacts associated with the work.

• Develop and Implement Hazard Controls. Identify and agree upon standards and requirements, identify controls to prevent/mitigate hazards, establish the ESH&Q parameters, and implement controls.

• Perform Work Within Controls. Confirm readiness and perform work safely and in the prescribed manner to protect workers, the public, and the environment.

• Provide Feedback and Continuous Improvement. Gather feedback on the adequacy of controls from workers and appropriate stakeholders, identify and implement opportunities for improvement, and conduct line management and independent oversight.

Subcontractor program flexibility is understood and encouraged as long as the subcontractor’s program tenets adequately address the spirit and intent of the ISM provisions.

2.4.2 Stop Work Authority

All workers at NREL Sites have the authority to stop work and the work of others upon discovery of imminently dangerous conditions or other serious hazards to workers or the public and are not subject to reprisal or retaliation. Workers have the authority to stop the work immediately and notify their supervisor and ESH POC. Work may not proceed until the circumstances are reviewed and deficiencies corrected.

2.5 Subcontractor Responsibilities

As required in 10 CFR 851, the subcontractor shall establish a worker safety and health program.

Worker protection measures should be based on the use of a graded approach to ensure that available resources are used most efficiently and effectively. Worker safety and health programs shall be integrated into other related site-specific worker protection activities and within the ISM system. There must be an open and continuous line of communication between the subcontractor and NREL to address any unsafe acts or conditions that may arise during the project. Workers must be instructed to report to the construction contractors designated representative, hazards not previously identified or evaluated. If immediate corrective action is not possible or the hazard falls outside of project scope, the construction subcontractor must immediately notify affected workers, post appropriate warning signs, implement needed interim control measures, and notify the subcontractor PM and the NREL PM of the action taken. The subcontractor designated representative must stop work in the affected area until appropriate protective measures are established.

The basis for the implementation of the Subcontractor Worker Safety and Health Program will be contained in the CESHP.

The subcontractor has overall accountability for the safety of its project and shall allocate the resources necessary for implementing all required safety-related codes and contract/subcontract requirements. The Subcontractor shall:

• Follow all NREL site-specific environmental, safety and health (ESH) requirements and associated permits as defined by this manual.

• Establish ESH flow-down requirements in all subcontracts.

• Implement the appropriate requirements of this manual into the CESHP.

• Designate a Subcontractor Safety Manager/designated on-site safety representative to oversee all activities.

• Develop, implement, and/or adhere to activity hazard analyses (AHAs) and other pre-job planning documents required by this manual.

• Provide training to employees in safe-work practices.

• Document all required training and have available for review.

• Provide required personal protective equipment (PPE), training employees on how to use the equipment and enforcing its use in the field.

• Monitor the workplace for unsafe conditions and take immediate action to correct unsafe conditions, acts, and other deficiencies identified during inspections.

• Perform necessary personal exposure monitoring.

• Coordinate and conduct pre-job planning with subcontractors, field supervisors, affected lab managers, and others, as required.

• Conduct a daily walk-around safety inspection and document this inspection.

• Instruct all employees, initially and periodically, on matters pertaining to employee safety and health rights, protections, obligations, and responsibilities.

2.6 References

• 10 CFR 851, Worker Safety & Health Program

• 29 CFR 1926, Safety and Health Regulations for Construction

• 29 CFR 1910, Occupational Safety and Health Standards for General Industry.

http://www.pnl.gov/contracts/esh-procedures/forms/sp00e010.doc

3 Occupational Medicine

3.1 Applicability

The requirements of this section apply to all Construction Subcontractors and lower-tier subcontractors (hereafter referred to as “Subcontractor”) activities that require personnel to work on NREL Sites if either of the two criteria applies:

• The subcontractor’s workers are on site for more than 30 days in a 12-month period

• The subcontractor’s workers on site are enrolled for any length of time in a medical or exposure monitoring program required by any rule or other obligation.

3.2 Regulatory Requirements

The subcontractor shall establish and provide comprehensive occupational medicine services to workers on the site, as required in Appendix A.8. of 10 CFR Part 851—Worker Safety and Health Program.

3.3 NREL Specific Requirements/Permits

Where applicable, NREL requires subcontractors to submit health and safety plans that document compliance with the occupational medicine provisions contained in Appendix A.8. to 10 CFR Part 851—Worker Safety and Health Program.

3.4 NREL Special Emphasis

The occupational medicine requirements in 10 CFR Part 851 are unfamiliar to many subcontractors and “flowing down,” or transferring the responsibility for compliance with these requirements to lower-tier subcontractors, is irregular and generally tends to lack proper oversight to ensure high quality compliance. Further, subcontractors may fail to inform occupational medicine services providers of their responsibilities specified in 10 CFR Part 851— Worker Safety and Health Program, which is a regulation unique to DOE sites and applicable at

NREL.

3.5 Subcontractor Responsibilities

The subcontractor is responsible for compliance with Appendix A.8. of 10 CFR Part 851— Worker Safety and Health Program, including the accurate and timely flow down of these requirements to all lower-tier subcontractors and for insuring all lower-tier subcontractors comply with these requirements.

The subcontractor is responsible for providing its occupational medicine services providers access to worksite hazard information.

• The subcontractor is responsible for coordinating with the NREL ESH POC and providing the occupational medicine services provider with access to the following:

o Current information about actual or potential work-related site hazards (chemical, radiological, physical, biological, or ergonomic) o Employee job-task and hazard analysis information, including essential job functions o Actual or potential work-site exposures of each employee o Personnel actions resulting in a change of job functions, hazards, or exposures.

• Subcontractors shall notify the occupational medicine services providers when an employee has been absent because of an injury or illness for more than five consecutive workdays (or an equivalent time period for those individuals on an alternative work schedule).

The subcontractor and occupational medicine services provider are responsible for developing and maintaining a record containing any medical, health history, exposure history, and demographic data collected for the occupational medicine purposes, for each employee for whom medical services are provided. All occupational medical records shall be maintained in accordance with Executive Order 13335, Incentives for the Use of Health Information Technology.

The subcontractor is responsible for notifying the occupational medicine services provider of the requirements contained in Appendix A.8. of 10 CFR Part 851—Worker Safety and Health Program. The occupational medicine services provider and subcontractor are responsible for implementing and ensuring compliance with the following requirements:

• The occupational medicine services provider determines the content of the worker health evaluations.

o Workers shall be informed of the purpose and nature of the medical evaluations and tests offered by the occupational medicine services provider.

o The occupational medical provider shall determine the necessary health evaluations.

o Diagnostic examinations will evaluate employee’s injuries and illnesses to determine work-relatedness, the applicability of medical restrictions, and referral for definitive care, as appropriate. After a work-related injury or illness or an absence due to any injury or illness lasting five or more consecutive workdays (or an equivalent time period for those individuals on an alternative work schedule), a return to work evaluation will determine the individual’s physical and psychological capacity to perform work and return to duty. At the time of separation from employment, individuals shall be offered a general health evaluation to establish a record of physical condition.

• The occupational medicine services provider shall monitor ill and injured workers to facilitate their rehabilitation and safe return to work and to minimize lost time and its associated costs.

• The occupational medicine services provider shall include measures to identify and manage the principal preventable causes of premature morbidity and mortality affecting worker health and productivity.

o The subcontractor shall include programs to prevent and manage these causes of morbidity when evaluations demonstrate their cost effectiveness.

• The occupational medicine services provider shall review and approve the medical and behavioral aspects of employee counseling and health promotional programs, including the following types:

o Subcontractor-sponsored or subcontractor-supported EAPs o Subcontractor-sponsored or subcontractor-supported alcohol and other substance abuse rehabilitation programs o Subcontractor-sponsored or subcontractor-supported wellness programs.

3.6 References

• 10 CFR Part 851 Appendix A—Worker Safety and Health Functional Areas

• 10 CFR Part 851—Worker Safety and Health Program

• Executive Order 13335—Incentives for the Use of Health Information Technology

• 10 CFR 712.38(b)(2)—Maintenance of medical records

• 5 USC Sec. 552a.—Records maintained on individuals

• 10 CFR Part 1008—Records maintained on individuals

• 29 CFR 1910.1020—Access to employee exposure and medical records

• 42 USC Sec. 7384—Energy Employees Occupational Illness Compensation Program Act.

4 Construction Hazard Identification and Control Process

4.1 Applicability

The requirements of this section apply to all subcontractors and lower-tier subcontractors construction work activities on NREL Sites unless otherwise specifically exempted by NREL.

This section provides the requirements for establishing a method for identifying, controlling, and documenting hazards associated with subcontractor work activities and communicating this information to all affected workers.

4.2 Regulatory Requirements

Subcontractor methods for identifying, controlling, and documenting hazards associated with subcontractor work activities shall be conducted in accordance with the following statutory requirements:

• 29 CFR 1926, Construction

• 29 CFR 1910, General Industry

• 10 CFR 851, Worker Safety and Health Program.

4.3 NREL Specific Requirements/Permits

In addition to Section 4.2, all subcontractor work activities shall meet the following specific NREL requirements for hazard identification and control.

4.3.1 General Requirements

The subcontractor is responsible for understanding the scope of work in sufficient detail to ensure the work is effectively planned for each definable work activity, the hazards associated with the work are identified and the planned protective measures are implemented. This shall be accomplished utilizing the AHA process described in Section 4.3.2 below. These analyses shall be listed in the CESHP. The CESHP template provides additional guidance on developing AHAs, in addition to completed example AHA templates to assist the Subcontractor in the development of their AHAs.

4.3.2 Activity Hazard Analyses

For each separately definable construction activity (e.g., excavations, foundations, structural steel, roofing, electrical, mechanical, etc.), the Subcontractor shall develop an AHA prior to commencement of the associated work/definable feature. A definable work activity is a task which is separate and distinct from other tasks, has separate control requirements. A definable work activity may be identified by different trades or disciplines, or it may be work by the same trade in a different environment. Within each definable work activity there may be other sub-phases of work that warrant separate AHAs. It will be the responsibility of the Subcontractor to determine the best breakdown of separately definable activities and the subsequent work steps to produce clear, concise, and effective, AHAs. The Subcontractor AHAs shall be kept with the CESHP and at the worksite for review by NREL ESH POC or the NREL Project Manager.

NREL recommends using a graded approach in the development of AHAs; however, the subcontractor AHAs shall be developed in sufficient detail to preclude confusion and misunderstanding and shall be commensurate with the size, complexity and risk level of the construction project. When used appropriately, the graded approach will incorporate the level of rigor for implementing the work planning and control attributes based on the importance/ significance of the activity in relation to the associated hazards and consequences.

The analyses shall contain and/or meet the following elements as applicable to the activity:

• Identification of the definable work activity

• Identification of the job steps for each work activity

• Identification of foreseeable hazards for each step/activity and the planned protective measures to include appropriate protective devices and/or equipment as needed

• Identification of competent persons required for workplace inspections of the construction activity, where required by OSHA standards.

• Identification of Emergency Response Action relative information (e.g., gas shutoff valve location, etc.)

• Identification of project-required hold points or other logistical requirements

• Address additional hazards revealed by supplemental site information (e.g., site characterization data, as-built drawings)

• Provide drawings and/or other documentation of protective measures for which applicable OSHA standards require preparation by a Professional Engineer or other qualified professional

• Review and approval of the AHA by the subcontractor’s management

• Places for signatures of the involved workers to signify they have been briefed on and understand the requirements of the AHA and acknowledge their intended compliance with the AHA.

In many cases, the AHAs shall be submitted with the CESHP and require acceptance of the ESH POC prior to starting that work phase.

The subcontractor shall conduct a pre-task/phase meeting addressing the corresponding AHA, the work tasks, and associated procedures and hazards with all affected parties to identify and coordinate logistics, controls and communications required for the activity. Each worker involved in that work must review and sign the AHA prior to performing work. All AHAs must be kept at the worksite to be available for review by workers and oversight personnel.

If, while working, it is discovered that the controls addressed in the AHA will not/do not provide adequate protection, the task at hand shall be stopped until the hazards have been re-assessed, the AHA updated, and adequate controls implemented. In these instances, the Subcontractor may utilize field changes (i.e., red line, pen/ink changes) as needed to reflect changing conditions associated with the activity. All contractor personnel involved in the work being performed shall review each AHA and subsequent updates/changes. The updated AHA shall be made available for review by the NREL ESH POC.

4.3.3 Worker Training

The subcontractor shall ensure affected workers are made aware of foreseeable hazards and protective measures described within the activity analysis prior to beginning work on that activity.

4.3.4 Record of Training

The subcontractor shall ensure workers acknowledge being informed of the hazards and protective measures associated with assigned work activities and understand those requirements.

Each worker involved in that work must sign the AHA prior to performing work.

4.4 Subcontractor Responsibilities

The provisions of this procedure apply to the development and implementation of the subcontractor’s Hazard Identification and Control program. The subcontractor shall be responsible for implementing an effective Hazard Identification and Control program that:

• Identifies, evaluates, and controls potential and existing hazards/agents in the workplace through the pre-job safety planning process

• Incorporates the controls into the AHAs

• Determines engineering devices, administrative controls, and personal protective equipment are available, appropriate, tested, and utilized by employees

• Determines employees are trained as required

• Has provisions to manage and notify NREL when there are changes related to the work scope, materials, and/or processes that may introduce new or different hazards to the project.

4.5 References

• 10 CFR 851, Worker Safety and Health Program

• 29 CFR 1926, Construction Standards

• 29 CFR 1910, General Industry Standards.

5 ESH Meetings, Inspections, and Orientations

5.1 Applicability

The requirements of this section apply to all subcontractors and lower-tier sub-contractors performing construction activities on NREL Sites unless otherwise specifically exempted by the

NREL.

5.2 Regulatory Requirements

Subcontractors will be…