Attachment_40 _CDP_Safety_Management_System.pdf

Training Delivery Services

Attachment 40

CDP Safety Management System

Center for Domestic Preparedness (CDP) MANUAL 619-2-0

Safety Management System

APPROVAL DATE: 04/09/2015

DEPARTMENT OF HOMELAND SECURITY

FEDERAL EMERGENCY MANAGEMENT AGENCY

CENTER FOR DOMESTIC PREPAREDNESS

Charle£~M. King Superintendent

Date

Foreword

This Manual provides guidance and policy direction for the administration, implementation and oversight of the Federal Emergency Management Agency's (FEMA), Center for Domestic Preparedness (CDP), Safety and Occupational Health Program.

Table of Contents

CHAPTER 1: GENERAL INFORMATION

1-1. Purpose

1-2. Applicability and Scope

1-3. Supersession

1-4. Authorities/References

1-5. Policy

1-6. Definitions

1-7. Responsibilities

1-8. Reporting Requirement

1-9. Forms Prescribed

1-10. Questions

CHAPTER 2: Safety Management System

2-1. Overview

CHAPTER 3: Occupational Safety & Health Standards

3-1. Compliance Hierarchy

3-2. Contractor Safety

3-3. CDP Wide Programs

3-4. COBRATF Safety Programs

3-5. Risk / Hazard Assessment

3-6. Hierarchy of Controls

ANNEX 1: CDP Safety Management System 5 Year Strategic Plan

CHAPTER 1: GENERAL INFORMATION

1-1. Purpose

The purpose of this manual is to establish a framework for a safe and healthful work environment for Federal employees, contractors, students, and visitors at the Center for Domestic Preparedness (CDP). This manual is part of a set of integrated documents which includes the Department of Homeland Security (DHS) Safety Manual, the Federal Emergency Management Agency (FEMA) Safety Manual, and this document. Together they form a comprehensive program designed to protect worker health and safety, comply with regulatory requirements, and continually improve the program.

1-2. Applicability and Scope This Manual applies to:

A. All CDP federal employees, B. All CDP contactors unless they have an accepted accident prevention program/safety and health program document on file with CDP, and C. All CDP course students and visitors.

1-3. Supersession Not applicable.

1-4. Authorities/References A. DHS Safety Manual B. FEMA Safety Manual C. Occupational Safety and Health Administration regulations (OSHA) - 29 CFR

1904, 1910, 1926, 1960 D. American National Standards Institute (ANSI)/American Industrial Hygiene

Association (AIHA) Z10 Safety and Health Management System E. U.S. Army Corps of Engineers Safety Manual (EM 385-1-1), Appendix A

1-5. Policy It is the policy of CDP to:

A. Provide a safe and healthful workplace free from recognized hazards;

B. Enable effective employee participation in the program;

C. Comply with all applicable Federal, state, and local rules and regulations related to safety and occupational health; and

D. Strive to continuously improve the program through application of a comprehensive safety and health management system.

1-6. Definitions See References noted above.

1-7. Responsibilities

A. CDP Superintendent is responsible for:

1. Establishing a comprehensive safety and occupational health (SOH) program;

2. Providing adequate resources (personnel, equipment, time, and funding) to this program; and

3. Holding managers, supervisors, and employees accountable for assigned program elements.

B. Directors, Managers, Supervisors are responsible for:

1. Supporting the SOH program by holding subordinate managers, supervisors, and employees accountable for assigned program elements;

and

2. Ensuring all employees are properly trained and equipped for their assigned duties.

C. SOH Staff are responsible for:

1. Providing technical support for SOH program development;

2. Supporting managers, supervisors, and employees by routinely reviewing

CDP operations for safety and health hazards, then recommending controls to responsible supervisors and managers; and

3. Staying current with all applicable rules and regulation and required certifications to safely conduct operations.

D. Contracting Officer Representatives (CORs) are responsible for:

1. Ensuring an Accident Prevention Plan (APP) conforming to EM-385-1-1

Appendix A has been submitted and accepted prior to the start of any construction contract; and

2. Providing quality assurance oversight of the contract for compliance with the APP and applicable OSHA regulations.

E. Employees shall:

1. Comply with the provisions of this Manual;

2. Utilize/comply with all engineering, administrative, and personal protective equipment (PPE) listed on the job safety analysis / hazard assessment for the task being performed;

3. Immediately report any potentially unsafe conditions or actions to their supervisor; and

4. Stop work whenever any hazard presents an immediate danger to life or health.

1-8. Reporting Requirement A. All federal employees are responsible for:

1. Reporting any unsafe condition or action to their supervisor, and

2. Reporting any work related injury or adverse health condition to their supervisor.

B. All contractors are responsible for submitting reports required by their contract as well as reporting all work related injuries/illnesses to the CDP Safety Office.

1-9. Forms Prescribed

Hazard Assessment Form 1-10. Questions

Questions concerning this program should be directed to your immediate supervisor, Contracting Officer Representative (COR), or the CDP Safety Officer.

CHAPTER 2: Safety Management System 2-1. Overview

A. The CDP Safety Management System (SMS) is designed to provide an effective tool for continual improvement of our Safety and Occupational Health (SOH) program. It contains multiple levels of implementation as noted in the figure 1 below.

Figure 1. Layers of Safety Management System Implementation

B. The system is based on the recognized quality concept of “Plan-Do-Check- Act” as outlined in ANSI/AIHA Z10 Figure 2 below.

Figure 2. ANSI / AIHA Z10 Plan-Do-Check-Act model

C. The ANSI/AIHA Z10 approach also includes the key elements contained in the OSHA Voluntary Protection Program (VPP) and facilitates not only quality improvement, but also regulatory compliance.

D. Key Elements The key elements of the CDP SMS program are as described in the ANSI/AIHA Z10 standard. They include:

1. Management Leadership & Employee Participation,

2. Planning,

3. Assessment and Prioritization,

4. Implementation and Operation,

5. Evaluation and Corrective Action, and

6. Management Review.`

CHAPTER 3: Occupational Safety & Health Standards 3-1. Compliance Hierarchy

A. The following compliance hierarchy shall be used for all CDP activities whether performed by Federal employees or contractors:

1. OSHA Standards (e.g. 29 CFR 1904, 1910, 1926, 1960).

2. DHS Safety Manual requirements.

3. FEMA Safety Manual requirements.

4. CDP Safety Manual.

5. Chemical, Ordnance, Biological, and Radiological Training Facility

(COBRATF) Safety Annexes.

6. Contract specific safety requirements as outlined in the accepted Accident

Prevention Plan (APP) or Site Safety and Health Plan (SSHP).

B. In the event of a conflict between requirements, the higher level requirement shall be followed (i.e., the more stringent of the requirements). In the event that a contractor program does not address a job specific hazard, the requirements in the COBRATF Safety Annex shall apply.

C. Table 1. Cross-walk of SOH requirement subjects within

DHS/FEMA/CDP/COBRATF

Subject

DHS

Safety Manual Chapter

FEMA

Safety Manual Chapter

CDP Safety & Occupational

Health Program Manual

COBRATF

Safety Annex

Introduction 1 1 0 Responsibilities 2 1, 2 1 Safety Management System 2 Occupational Safety and Health Standards 3 12 3

CDP 5 Year Strategic Plan Annex 1 Occupational Exposure to Blood Borne Pathogens 18 A

Confined Space Entry Program 16 B Fall Protection Program C Fire Prevention Plan 21 D Powered Industrial Trucks (Forklifts) E

Hazard Communication Program 14 E Hearing Conservation Program 13 G Isolation of Energy Sources (Lockout/Tagout) 17 H

Radiation Plan I Respiratory Protection Program 12 J Spill Prevention and Control Plan K

Subject

DHS

Safety Manual Chapter

FEMA

Safety Manual Chapter

CDP Safety & Occupational

Health Program Manual

COBRATF

Safety Annex

Laboratory Safety (Chemical Hygiene Plan) 20 L

Toxic Agent Exposure Control Plan M Biosafety Plan N Operational Risk Management 4 Prevention and Control of Workplace Hazards 9 6, 10

Heat & Cold Stress Program CDP Wide

Plan

Emergency Action Plans

See also CDP Emergency

Plan

See also

CDP

Emergency Plan

Ionizing Radiation Program 26 CDP Wide

Plan

Councils and Committees 5 4 Safety and Health Assessment Program 6 7

Incident Reporting, Records and Investigations 7 11

Employees Reports of Unsafe/Unhealthful Working Conditions

8 8

Training 10 Personal Protective Equipment 11 Asbestos Awareness 15 Driving Safety 19 Electrical Safety 22 Explosive Safety 23 Aviation Safety Program 24 Afloat Safety Program 25 Non-Ionizing Radiation Program 27 FEMA OSH Disaster Cadre 9

3-2. Contractor Safety A. All contractors shall prepare and submit an acceptable written APP/SSHP) prior to the start of any work.

B. In order to be accepted the plan must address all the elements outlined in

USACE EM 385-1-1, Appendix A. For small contracts without high hazard activities an abbreviated plan may be accepted. Required elements must be agreed upon at the contract kick-off meeting. For ongoing Operations and Maintenance (O&M) work a written hazard assessment must be performed and be filed with the contractor safety office prior to the start of work. Written hazard assessments must be completed for each Program of Instruction (POI) and be filed with the contractor safety office prior to the start of training.

C. Subcontractors. The prime contractor is responsible for ensuring that all subcontractors are aware of the requirements contained in the accepted APP/SSHP. In the event that the subcontractor does not intend to comply with these requirements, an amendment must be prepared and accepted prior to the start of that subcontractor’s work.

D. The prime contractor Site Safety & Health Officer (SSHO) is responsible for monitoring the job site(s) for compliance with all accepted APP/SSHP requirements.

E. The Contracting Officer’s Representative (COR) is responsible for providing quality assurance oversight of APP/SSHP requirements.

3-3. CDP Wide Programs The following CDP-wide safety programs have been promulgated and must be followed by all Federal employees, contractors, staff and visitors:

A. Radiation Safety Program B. Heat and Cold Stress Program

3-4. COBRATF Safety Programs A. A number of safety programs have been developed specifically for the

COBRATF. These are shown in Table 1 above. These programs are COBRATF specific and may not need to be followed outside this facility. (See Compliance Hierarchy section above).

B. These programs are individually identified and signed. They are numbered as annexes to this base document.

3-5. Risk / Hazard Assessment A. No activity will be conducted without first conducting a job/activity specific risk/hazard assessment. The assessment shall address both the probability (likelihood) of the hazard and its severity using the definitions and matrix outlined below. OSHA (29 CFR 1910.132) requires a written hazard assessment for all activities where Personal Protective Equipment (PPE) is selected as part of the hazard control.

B. Contractors may utilize their own risk forms clearly defined in their approved APP/SSHP submission and if consistent with the risk matrix below.

C. In general, risks must be controlled at the moderate or low level. Residual risk levels of high or very high must be approved prior to operations and will require direct CDP Safety Office or designee review, approval, and oversight.

D. Risk Acceptance

1. The higher the residual risk the higher level of management that must accept the risk. At CDP residual risks at the low or moderate level may be accepted at the Assistant Director level. Risks at the high level may be accepted at the Director level, and extremely high at the Superintendent level.

2. Contractors’ operations will require this same level of CDP internal approval prior to the start of work.

E. Risk Probability and Severity Definitions

Probability Symbol Definition

Frequent A Occurs very often; known to happen regularly Likely B Occurs several times; a common occurrence Occasional C Occurs sporadically; but is not common Seldom D Remotely possible; could occur at some time

Unlikely E Can assume will not occur but is not impossible

Severity Symbol Definition

Catastrophic I

- 1 or more deaths or permanent total disabilities;

- loss >$1M,

- mission failure

Critical II

- 1 or more permanent partial disabilities or temporary total <3 months total LT;

- loss >$200K but <$1M;

- significantly degraded mission capability

Marginal III

- 1 or more injuries or illnesses <3 months LT;

- loss >$20K but <$200K;

- degraded mission capability

Neglible IV

- 1 or more injuries or illnesses requiring first aid or medical treatment;

- loss <$20K;

- little or no adverse impact on mission capability

F. Risk Matrix

Risk Matrix Probability

Severity Frequent (A)

Likely (B)

Occasional (C)

Seldom (D)

Unlikely (E)

Catastrophi c (I)

Extremely High Extremely High High High Moderate

Critical

(II)

Extremely High High High Moderate Low

Marginal (III) High Moderate Moderate Low Low

Negligible (IV) Moderate Low Low Low Low

3-6. Hierarchy of Controls

To the extent practicable and consistent with the risk / hazard acceptance the following hierarchy of controls shall be utilized.

Figure 3. Hierarchy of Controls

ANNEX 1: CDP Safety Management System 5 Year Strategic Plan Sample Plan – See CDP Safety folder on Common Drive for current version

Focus Area FY 15 FY 16 FY 17 FY 18 FY 19 A-1. Management Leadership & Employee Participation

A. Review CDP SOH Policy.

B. Develop & Implement SMS.

Review employee participation program;

refine/improve based on review.

A-2. Planning A. Develop 5 year Strategic Plan.

B. Refine current & next year objectives.

Review 5-year strategic plan and develop objectives for next out-year and refine objectives for next

FY.

Review 5-year strategic plan and develop objectives for next out-year and refine objectives for next

FY.

Review 5-year strategic plan and develop objectives for next out-year and refine objectives for next

FY.

Review 5-year strategic plan and develop objectives for next out-year and refine objectives for next

FY.

Focus Area FY 15 FY 16 FY 17 FY 18 FY 19 A-3. Assessment and Prioritization

A. Review COBRATF Air Monitoring (AM) Data - refine AM Plan based on data review.

B. Conduct Noise Survey.

C. Conduct assessment of silica & welding fume exposures.

D. Review Position Hazard Analysis (PHA) for 25% of Federal employees.

A. Review 25% of course hazard assessments.

B. Review JSAs for 25% of Federal employees.

A. Review 25% of course hazard assessments.

B. Review JSAs for 25% of Federal employees.

A. Review 25% of course hazard assessments.

B. Review JSAs for 25% of Federal employees.

A. Review 25% of course hazard assessments.

B. Review JSAs for 25% of Federal employees.

A-4. Implementation and Operation

A. Update written programs requiring annual review.

B. Conduct 3-year review of all programs.

Update written programs requiring annual review.

Update written programs requiring annual review.

A. Update written programs requiring annual review.

B. Conduct 3-year review of all programs.

Update written programs requiring annual review.

Focus Area FY 15 FY 16 FY 17 FY 18 FY 19 A-5. Evaluation and Corrective Action

A. Evaluate design review and management of change procedures for

SOH

engagement.

B. Review contractor SOH programs and identify improvement opportunities.

C. Review SOH training requirements for 25% of Federal staff positions.

Review SOH training requirements for 25% of Federal staff positions.

Review SOH training requirements for 25% of Federal staff positions.

Review SOH training requirements for 25% of Federal staff positions.

A-6. Management Review

Conduct audit of one of the five elements noted above.

Conduct audit of one of the five elements noted above.

Conduct audit of one of the five elements noted above.

Conduct audit of one of the five elements noted above.

a. Conduct audit of one of the five elements noted above.

ANNEX 1: CDP Safety Management System 5 Year Strategic Plan