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Washington

Review of Contractor Accident Prevention Plans

Introduction: Good morning, for those of you who don’t know me, my name is Dave Halley and I am the PWD Annapolis Site Safety Manager. I am here to discuss the “Spot Check” program

NAVFAC

Requirement and Format EM385-1-1 Section 01.A.11 Before initiation of work at the job site, an APP shall be reviewed and found acceptable by the GDA.

The APP shall contain appropriate appendices (for example, a SSHP for hazardous waste site cleanup operations, a Lead Compliance Plan when working with lead, or an Asbestos Hazard Abatement Plan when working with asbestos).

The APP shall be written in English by the Prime Contractor and shall articulate the specific work and hazards pertaining to the contract. The APP shall also implement in detail the pertinent requirements of this manual.

APPs shall be developed and submitted by the Contractor in the format provided in Appendix A of this manual. The Contractor shall address each of the elements/sub-elements in the outline contained in Appendix A in the order that they are provided in the manual. If an item is not applicable because of the nature of the work to be performed, the Contractor shall state this exception and provide a justification. > See Appendix A.

For limited scope supply, service and R&D contracts, the Contracting Officer and local SOHO may authorize an abbreviated APP. > See Appendix A, paragraph 11 for details.

The APP shall be developed by Qualified personnel and then signed in accordance with appendix A, paragraph 1. The Contractor shall be responsible for documenting the Qualified person’s credentials.

For contract operations, the Contractor's APP shall be job specific and should include work to be performed by subcontractors. In addition, the APP should state measures to be taken by the Contractor to control hazards associated with materials, services, or equipment provided by suppliers.

Updates to the APP shall be reviewed and approved by the GDA.

1. Signature Sheet Title, Signature, and Phone numbers of:

Plan Preparer – Qualified competent person such as corporate safety staff

Plan Approved by – This must be someone with the authority to obligate the company

Plan Concurrence – Shows the following have reviewed and agree with the safety plan:
Chief of Operations
Corporate chief of safety
Corporate Industrial Hygienist
Project Manager
Superintendent
Site Safety and Health Officer
Project QC
Other applicable corporate/project personnel (Contractor)

2. Background Information Contractor

Contract Number

Project Name

Brief Description, description of work to be performed, location, phases of work anticipated (these require an AHA)

3. Statement of Safety and Health Policy Provide a copy of current corporate/company Safety and Health Policy Statement, detailing:

Commitment to providing a safe and healthful workplace for all employees

The Contractor’s written safety program goals, objectives, and accident experience goals for this contract

4. Responsibilities and Line of Authority A statement of the employer’s ultimate responsibility for the implementation of the safety plan

Identification of personnel responsible for safety at the corporate and project level.

Include resumes Qualifications shall include the OSHA 30-hour course

Names of competent and/or qualified personnel Proof of competency to meet OSHA Competent/Qualified person requirements must be attached

Requirement that no work shall be performed unless a designated competent person is present on the job site

4. Responsibilities and Line of Authority (continued) Requirement for pre-task safety and health analysis

Lines of authority

Policies and procedures regarding noncompliance with safety requirements (to include disciplinary actions for violations)

Written company procedures for holding managers and supervisors accountable for safety

5. Subcontractors and Suppliers Provide procedures for coordinating SOH activities with other employers on the job site:

Identify known subcontractors

Safety responsibilities of subcontractors

6. Training Requirements for new hire SOH orientation training at the time of hire

Requirements for mandatory training and certifications applicable to this project

Procedures for periodic safety and health training for supervisors and employees

Emergency Response Training for Spill response Fire fighting Man overboard/abandon ship Medical support (if more than 5 minutes away from the nearest medical treatment facility, must have 2 CPR/1st Aid certified personnel

7. Safety and Health Inspections Specific assignment of responsibilities for a minimum daily job site safety and health inspection:

Proof of inspector’s training/qualifications When they will be conducted Procedures for documenting, deficiency tracking system, and follow-up procedures

Any external inspection/certification requirements Such as USCG or third party crane certifications

8. Accident Reporting Identify the person who will provide:

Exposure data (man-hours worked)

Accident Investigations, reports and logs Report to KO ASAP but not later than 24 hours following Conduct complete investigation and submit findings on the Contractor Significant Incident Report form (CSIR) not later than 5 days following Implement corrective actions

Immediate notification for:

Fatality Permanent total or partial disability Hospitalization of 3 or more people from a single mishap Property damage >$200,000

9. Plans Required by the Safety Manual Layout Plans

04.A.01 Plans for the layout of temporary construction buildings, facilities, fencing, and access routes and anchoring systems for temporary structures shall be submitted to and approved by the GDA. > See 09.A.19 for temporary building spacing requirements; Section 11 for temporary power distribution approval requirements; and Section 24 for temporary ramp, trestle, scaffold, and platform approval requirements.

04.A.02 The design and construction of temporary structures

04.A.04 Fencing and warning signs

9. Plans Required by the Safety Manual (continued)

b. Emergency Response Plans Procedures and tests 01.E.01 Emergency plans to ensure employee safety in case of fire or other emergency shall be prepared, in writing, and reviewed with all affected employees. Emergency plans shall be tested to ensure their effectiveness.

Spill Plans (01.E.01) Firefighting plan (01.E.05) Posting of emergency telephone numbers (01.E.05) Man overboard/abandon ship (19.A.04) Medical support (03.A.02 and 03.D) Outlines:

On site medical support available (2 CPR/1st Aid personnel, 1st aid kit) Off site medical arrangements Rescue and medical duties for on site employees

9. Plans Required by the Safety Manual (continued) Plan for prevention of alcohol and drug abuse (01.C.02)

Site sanitation plan (section 02)

Access and haul road plan (04.B)

Respiratory protection plan (05.G)

9. Plans Required by the Safety Manual (continued) Health hazard control program (06.A)

Exposure, through inhalation, ingestion, skin absorption, or physical contact, to any chemical, biological, or physical agent in excess of the acceptable limits
Hazard evaluation
Testing and monitoring
control of exposure to hazardous or toxic agents and environments

Hazard communication program (06.B) A written hazard communication program shall be developed when the use of hazardous or toxic agents (any chemical which is a physical/health hazard) are procured, stored or used at a project site

9. Plans Required by the Safety Manual (continued) Process Safety Management Plan (06.B.04)(highly hazardous chemicals)

Lead Abatement Plan (06.B.05 & Specifications)

Asbestos Abatement Plan (06.B.05 & Specifications)

Radiation Safety Program (06.E.03.a)

Abrasive Blasting Plan (06.H.01)

Heat/Cold Stress Monitoring Plan (06.I.02)

Crystalline Silica Monitoring Plan (06.M)

9. Plans Required by the Safety Manual (continued) Nite operations lighting plan (07.A.08)

Fire prevention plan (09.A)

Wild land fire management plan (09.K)

Hazardous energy control plan (12.A.01)

Critical lift plan (16.H)

Contingency plan for severe weather (19.A.03)

Float plan (19.F.04)

9. Plans Required by the Safety Manual (continued) Site specific fall protection & prevention plan (21.C)

Demolition plan (23.A.01) – Signed by RPE

Excavation and trenching plan (25.A.01)

Emergency rescue (tunneling) (26.A)

Underground construction fire prevention protection plan (26.D.01)

Compressed air plan (26.I.01)

Formwork and shoring erection plan (27.C)

9. Plans Required by the Safety Manual (continued) Precast concrete plan (27.D)

Lift slab plan (27.E)

Steel erection plan (27.F.01)

Site safety and health plan for HTRW work (28.B) – Hazardous waste site cleanup

Blasting safety plan (29.A.01)

Diving plan (30.A.131) – must be accepted by our district dive coordinator Confined space program (34.A)

Section 10 Risk Management Processes

Activity Hazard Analysis (AHA):
Risk Assessment Tool

Defines the Activity or Work to be Performed

Identifies Hazards

Establishes Controls to Reduce the Hazard to an Acceptable Risk Level

Living Document
Changes with Site Conditions or Operations
Changes of competent/qualified personnel

EM 385 2008 01.A.13 FIGURE 1-2

Contractor Required – AHA (New Format)

Activity Hazard Analysis (AHA) Activity/Work Task: Overall Risk Assessment Code (RAC) (Use highest code) Project Location: Risk Assessment Code (RAC) Matrix Contract Number: Probability Date Prepared: Severity

Frequent Likely Occasional Seldom Unlikely Catastrophic E E H H M Prepared by (Name/Title):

Critical E H H M L Marginal H M M L L Reviewed by (Name/Title):

Negligible M L L L L Step 1: Review each “Hazard” with identified safety “Controls” and determine RAC (See above) “Probability” is the likelihood to cause an incident, near miss, or accident and identified as: Frequent, Likely, Occasional, Seldom or Unlikely.

RAC Chart

E = Extremely High Risk “Severity” is the outcome/degree if an incident, near miss, or accident did occur and identified as: Catastrophic, Critical, Marginal, or Negligible H = High Risk

M = Moderate Risk

Notes: (Field Notes, Review Comments, etc.)

Step 2: Identify the RAC (Probability/Severity) as E, H, M, or L for each “Hazard” on AHA. Annotate the overall highest RAC at the top of AHA. L = Low Risk

Job Steps Hazards Controls RAC

Equipment to be Used Training Requirements/Competent or Qualified Personnel name(s) Inspection Requirements

The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person’s

EM 385 2008 EDITION

BACK PAGE OF AHA EM 385-1-1 2008 EDITION

01.A.13 Contractor-Required AHA. Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, the Contractor(s) performing that work activity shall prepare an AHA. > See Figure 1-2 for an outline of an AHA. An electronic version AHA may be found on the HQUSACE Safety Office Website.

a. AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk.

b. Work shall not begin until the AHA for the work activity has been accepted by the GDA and discussed with all engaged in the activity, including the Contractor, subcontractor(s), and Government on-site representatives at preparatory and initial control phase meetings.

c. The names of the Competent/Qualified Person(s) required for a particular activity (for example, excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the GDA for acceptance prior to the start of that work activity.

d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person(s).

(1) If more than one Competent/Qualified Person is used on the AHA activity, a list of names shall be submitted as an attachment to the AHA. Those listed must be Competent/Qualified for the type of work involved in the AHA and familiar with current site safety issues.

(2) If a new Competent/Qualified Person (not on the original list) is added, the list shall be updated (an administrative action not requiring an updated AHA). T he new person shall acknowledge in writing that he or she has reviewed the AHA and is familiar with current site safety issues.

Contractor Required - AHA COE EM 385-1-1, para 01.A.13.a: AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk.

COE EM 385-1-1, para 01.A.13.b: Work will not begin until the AHA for the work activity has been accepted by the Government Designated Authority (GDA) and discussed with all engaged in the activity, including the Contractor, subcontractor(s), and Government on-site representative at preparatory and initial control phase meetings.

COE EM 385-1-1, para 01.A.13.c: Identify the names of the Competent/Qualified person(s) required for a particular activity as specified by OSHA and EM 385-1-1. (i.e., Excavation, Fall Protection, Scaffolding, etc.)

COE EM 385-1-1, para 01.A.13.d: AHAs shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified personnel. **Living document**

Develop Site Specific AHAs Six Step Process

Step 1:
Identify: Definable Features of Work
Reference
Contractor Quality Control Plan
Contractor Project Schedule
Subcontractors and suppliers working on the project shall also contribute in developing an accurate “Project Schedule”.
Within each “Definable Features of Work” there may be other sub-phases of work to complete the “Definable Features of Work” such as
Set-up/Demobilization of office trailers
Staging of construction materials
Demolition of walls, HVAC systems, etc.
Asbestos/Lead abatement activities

Definable Features of Work Examples of “Definable Features of Work” from start to finish Within each “Definable Features of Work” there may be other sub-phases of work to complete the “Definable Features of Work”

For Example: Mobilization

Sub-phases:

Placement of field office
Utilities tie-in
Erection of project fencing
Establish lay-down areas
Environmental controls
Erection of project sign
Etc.

Definable Features of Work List “Definable Features of Work” and sub-phases of work on AHAs under “Job Steps:

For Example:

Mobilization

Placement of project field office

Utilities tie-in

Erection of project fencing

Establishing lay-down areas

Environmental controls

Erection of USACE project sign

Project Location: Risk Assessment Code (RAC) Matrix

Negligible M L L L L Step 1: Review each “Hazard” with identified safety “Controls” and determine RAC (See above) “Probability” is the likelihood to cause an incident, near miss, or

The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person’s

01.A.13 Contractor-Required AHA. Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, the Contractor(s) performing that work activity shall prepare an AHA. > See Figure 1-2 for an outline of

a. AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or

b. Work shall not begin until the AHA for the work activity has been accepted by the GDA and discussed excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the GDA

d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or

(1) If more than one Competent/Qualified Person is used on the AHA activity, a list of names shall be

(2) If a new Competent/Qualified Person (not on the original list) is added, the list shall be updated (an

Hazards

Step 2:
Identify: Recognized or anticipated hazards for each definable and/or sub-phases of work
Ask yourself the following to help identify hazards (not all inclusive):
Is there a danger of the employee of being struck by something (falling objects, moving equipment, etc.) from above, side, behind or in front?
Can the employee slip or trip?
Can the employee be caught in or between objects, machinery, collapsing walls, confined space, etc.?
Strains or sprains?
Electrical shock?
Can the employee fall from same or different levels?
Can employee or equipment come into contact with overhead lines or underground utilities?
Can employee be exposed to hazardous environments or chemicals?
Utilize past experiences, Lessons Learned, After Action Reports, Accident Trends, common sense, etc. to help identify hazards

Hazards List “Hazards” on the AHAs under “Hazards”

Examples of Hazards (not all inclusive)::

Struck By Struck by Falling Object Struck Against Fall on Same Level Fall on Different Level Slipped/ Tripped (No fall) Punctured By Laceration Caught On Caught By Caught Between Contacted by (Object was moving) Electric Shock Impaled Downing Oxygen Deficient Atmosphere Exposed To Stung By Equipment Failure Equipment Rollover Fire Cave-In

Project Location: Risk Assessment Code (RAC) Matrix

Negligible M L L L L Step 1: Review each “Hazard” with identified safety “Controls” and determine RAC (See above) “Probability” is the likelihood to cause an incident, near miss, or

The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person’s

01.A.13 Contractor-Required AHA. Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, the Contractor(s) performing that work activity shall prepare an AHA. > See Figure 1-2 for an outline of

a. AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or

b. Work shall not begin until the AHA for the work activity has been accepted by the GDA and discussed excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the GDA

d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or

(1) If more than one Competent/Qualified Person is used on the AHA activity, a list of names shall be

(2) If a new Competent/Qualified Person (not on the original list) is added, the list shall be updated (an

Controls

Step 3:
Identify: Site specific control measures to eliminate or reduce each hazard to an acceptable risk level
Ask yourself the following (not all inclusive):
How can the working condition or process be changed?
Can the hazard be eliminated with engineering controls?
What type of PPE can we use?
Can the hazard be eliminated with administrative controls?
What can the employee do to prevent an accident or eliminate the hazard?
Utilize past experiences, Lessons Learned, After Action Reports, Accident Trends, common sense, etc. to help formulate control measures.
GOAL: Reduce each Hazard to Acceptable Risk Level

Controls

Job StepsHazardsControlsRAC
Mobilization:

Project field office placement

Utilities tie-in

Stuck by moving equipment

Fall from elevated heights

Wear reflective vests.

Establish “No Zone” with flagging or barrier tape. Authorized personnel only!

Back up alarms.

Operators maintain eye contact with spotters at all times.

Provide ladder for safe access to roof.

Personnel shall wear full body harness with lanyard.

Install manufacture approved anchor point at least 6 ft (1.8 m) from the roof line.

100 percent tie-off at all times.

Competent/Qualified Personnel

Step 4:
Identify: Names of the Competent or Qualified Personnel required for the activity or job step
Reference
EM 385-1-1
OSHA
Proof of competency/qualification shall be submitted to the GDA for acceptance prior to start of work
Attached competency/qualification documentation to AHA
Examples of Competent/Qualified Personnel
Excavation
Scaffolding
First Aid/CPR
Electrical
Confined Space

Competent/Qualified Personnel Names of the Competent or Qualified Personnel required for the activity or job step

Reference

EM 385-1-1

Spec Section 013526

OSHA

Attached competency/qualification documentation to AHA

Include training requirements for all other workers also in this section

Project Location: Risk Assessment Code (RAC) Matrix

Negligible M L L L L Step 1: Review each “Hazard” with identified safety “Controls” and determine RAC (See above) “Probability” is the likelihood to cause an incident, near miss, or

The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or change of competent/qualified person’s

01.A.13 Contractor-Required AHA. Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or subcontractor is to perform the work, the Contractor(s) performing that work activity shall prepare an AHA. > See Figure 1-2 for an outline of

a. AHAs shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials, and the control measures to be implemented to eliminate or

b. Work shall not begin until the AHA for the work activity has been accepted by the GDA and discussed excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the GDA

d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations, or

(1) If more than one Competent/Qualified Person is used on the AHA activity, a list of names shall be

(2) If a new Competent/Qualified Person (not on the original list) is added, the list shall be updated (an

Risk Assessment Code (RAC)

Step 5:
Identify: Risk Assessment Code (RAC)
Review each “Hazard” for “Probability” and “Severity” per Risk Assessment Code Matrix chart
Probability: Likelihood of the hazard to cause a incident, near miss, or accident
Frequent - Occurs very often, known to happen regularly
Likely - Occurs several times, a common occurrence
Occasional - Occurs sporadically, but is not uncommon
Seldom - Remotely possible, could occur at some time
Unlikely - Can assume will not occur, but not impossible

Risk Assessment Code (RAC)

Step 5 con’t:
Severity: Outcome/degree of the incident, near miss, or accident
Catastrophic - Death or permanent total disability; Major property damage
Critical - Permanent partial disability or temporary total disability; Extensive damage to equipment or systems
Marginal - Lost workdays due to injury or illness; Minor damage to equipment or systems, property, or the environment
Negligible - First aid or minor medical treatment; Slight equipment or system damage, but fully functional or serviceable; Little or no property or environmental damage

Risk Assessment Code (RAC)

Step 5 con’t:
Ask yourself: How often (probability) will this hazard result in a incident, near miss, or accident?
For Example:
Employee falling from roof or elevated heights (Hazard)
Probability: Occasional
Ask yourself: What will be the outcome or degree (severity) of injury or property damage if the incident, near miss, or accident did occur on site?
For Example:
Broken arm or leg with lost time (outcome or degree)
Severity: Marginal
Review “Risk Assessment Code (RAC) Matrix” chart to determine Risk Assessment Code (RAC) as E, H, M, or L
RAC: M (Moderate Risk)

Risk Assessment Code (RAC) Risk Assessment Code (RAC)

Moderate Risk (M)
Identify (M) as RAC for the hazard on AHA
Repeat RAC process for each hazard

Severity: Marginal M

Probability: Occasional

Risk Assessment Code (RAC)

Step 5 con’t
RACs that are E (Extremely High Risk) or H (High Risk) after safety controls
Contact QA, GDA. Do not proceed until management agrees on the course of action
Potential E or H activities or job steps
Energized Electrical operations
Contractor Diving operations
Entry into Permit Required Confined Spaces
Hot Work on or around fuel systems
Critical lift crane ops
Review and acceptance from GDA (when necessary)

Equipment, Training, and Inspection

Step 6:
Identify: Equipment to be Used, Training Requirements, and Inspection Requirements
Reference:
EM 385-1-1
Governmental Safety Specs 013526
OSHA 29 CFR 1926
Manufacture Instructions/Recommendations (Operator Manual)
Industry Practices
Utilize past experiences, Lessons Learned, After Action Reports, Accident Trends, common sense, etc.
Communicate with subcontractors, suppliers, etc.

Equipment, Training, and Inspection

Equipment to be UsedTraining RequirementsInspection Requirements
Excavator

Generator Scaffolding (Frame or Tube Clamp?)

Full body Harness with Lanyard Portable Toilets 5 Ma GFCI Power Cord Sets Crane First Aid Kit Safety Shoes Safety Glasses Hardhat Respiratory Protection 30 OSHA Construction Safety Indoctrination Training First Aid/CPR Fall Protection Daily Tool Box Meetings (Japan) Weekly/Monthly Safety Training Respirator Emergency Response Procedures Fire Extinguisher Qualified Crane Operator Qualified Heave Equipment Operator Qualified Electricians Qualified Scaffold Erectors SSHO/QC Daily Site Inspections Scaffolding Shoring Systems for Excavation Monthly First Aid Kits Fall Protection PPE and Anchors All Heavy Equipment Power Cord Sets (Daily) GFCIs (at least Monthly) Grounding (Monthly)

AHA’s with Risk Assessment Codes that are E (Extremely High Risk) or H (High Risk) require on site visit to verify all conditions agreed to in accepted AHA are as stated before beginning work.

a. First time high risk operations must have mutual GO/NO GO point where the contractor and GDA agree it is safe to continue work.

2. AHA’s for sites with previous mishaps involving the same type of work require a site visit to verify conditions are as stated in accepted AHA

Sites with AHA’s that require a visit to check on conditions;

a. Remote Locations
b. New contractor teams i.e. first time working with a new sub.
c. After hours-work
d. Lessons learned in the past for same contractor

Special Note: This is also the time to check for changed conditions, either in the AHA stated objectives or site conditions

CC

CM/ET/GDA Action Based on Accepted AHA

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