S02_Attachment - Contractor Safety SOP.pdf

Standard Operating Procedure National Cemetery Administration

Safety SOP B06 Issued: 03/10/2023 Page 1 of 15

CONTRACTOR SAFETY

1. PURPOSE AND SCOPE:

The National Cemetery (NCA) program will establish procedures and practices that comply with VA policy, NCA policy, and current Occupational Safety and Health Administration (OSHA) Standards in providing a safe work environment for its employees and volunteers.

This program will ensure compliance with OSHA 29 CFR 1910, 29 CFR 1926 and 29 CFR 1960. This program outlines procedures to follow but it is not intended to supersede the requirements detailed in the applicable OSHA Standards.

2. STANDARD OPERATING PROCEDURE

It is through the use of this NCA Standard Operating Procedure (SOP) that employees and volunteers will be protected from injury/illness due to Contractor work. The Contractor Safety Program will be implemented and maintained through training and safe work practice procedures.

3. RESPONSIBILITIES

a. Facility Directors are responsible for the implementation and evaluation of this program at their facilities. Facility Directors will ensure that employees are provided the proper equipment and training to protect them from all hazardous conditions in the workplace and comply with OSHA Standards and recognized safe work practices.

b. Supervisors/Foremen and Collateral Duty Safety Officers (CDSO) will:

i. Support this program by the implementation of approved standards, regulations, and work practices.

ii. Train subordinates in safe working practices when working in areas where they are subject to any type of health hazard.

iii. Identify and evaluate hazard(s) in the workplace.

iv. Schedule required inspections.

v. Ensure all employees follow safe work practices (as described below) at all times.

c. Employees will:

i. Comply with all Cemetery Safe Work Practices, Procedures, Requirements, Policies and SOPs.

ii. Ensure they have an understanding of the hazards and safety precautions prior to performing their designated duties.

4. REFERENCES:

a. OSHA 29 CFR 1960

b. OSHA 29 CFR 1910

c. OSHA 29 CFR 1926

5. EFFECTIVE:

This SOP is effective immediately and will remain in effect until rescinded.

6. EFFECTIVENESS CRITERIA:

N/A

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7. FORMS/RECORDS:

Attachment 1: NCA Contractor Safety (FAR Clause) Attachment 2: Contractor Safety Orientation Checklist Attachment 3: NCA Contractor Safety Checklist

8. REVISION HISTORY:

Revision Date Description of Changes

0.0 01/01/2019 Initial Release

0.1 05/26/2021 Reviewed – no changes

0.2 03/10/2023 Added Attachments 1, 2 and 3 and changed to V4

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CEMETERY PROCEDURE:

1. DEFINITIONS:

A. Contractor: Any non-NCA employee hired to perform a task for the NCA B. COR: Contracting Officer's Representative C. ILSM: Interim Life Safety Measures D. SDS: Safety Data Sheet E. Sub-contractor: Any contractor or worker hired by a general contractor

2. PROCEDURES

A. Training

1. All employees and volunteers shall have basic Contractor Safety training including:

a. The potential hazards.

b. Key safe work practices used to control the hazards.

2. Frequency of training:

a. All employees and volunteers shall receive instruction:

i.Before the employee or volunteer is first assigned duties.

ii.Whenever there is new hazard.

iii.Whenever the employer has reason to believe that there are inadequacies in knowledge of hazards or safe work practices.

iv.At a frequency that ensures adequate employee and volunteer knowledge of hazards and safe work practices B. Inspections

1. Regularly evaluate the Contractor work area to verify that there are no uncontrolled hazards to NCA employees, volunteers, or visitors.

2. Have the NCA Facility COR contact the Contractor if any uncontrolled hazards to NCA employees, volunteers, or visitors are observed.

3. Verify that the Contractor has abated any uncontrolled hazards to NCA employees, volunteers, or visitors for which they received NCA notification.

C. Contractor Orientation

1. It is strongly suggested that any onsite contract workers view an NCA Safety & Health Overview presentation prior to starting work to orient them to the facility and safety program.

D. Contractor work at NCA Facilities WITH a formal contract

1. The Contracting Agency (CCD, VAMC, NCA or other) shall meet all requirements of VA Policy, OSHA 29 CFR 1960, OSHA 29 CFR 1926 and OSHA 29 CFR 1910, including:

a. Require the Contractor to submit copies of all applicable OSHA-required programs.

b. Require the Contractor to certify that every designated onsite employee has completed applicable training and certifications required by OSHA and other Federal, state and local regulatory agencies.

c. Complete a Contractor pre-qualification (including review of submitted Safety & Health written programs and training/certification).

d. Require Contractor compliance with OSHA 29 CFR 1910 and OSHA 29 CFR 1926 and applicable Federal, state and local regulations.

e. Require the Contractor to provide a written Project Emergency Action Plan when applicable.

f. Designate a Contracting Officer’s Representative (COR).

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g. Establish the responsibilities of the COR.

h. Notify Contractors of the designated COR.

i. Obtain a SDS for every hazardous substance that may be brought onsite or generated onsite by the Contractor.

j. Provide a copy of all Contractor SDS forms to the NCA facility.

k. Arrange Contractor orientation including sharing information regarding facility Safety & Health programs, a facility overview, and a worksite walk-through.

l. Provide a plan for Contractor Surveillance and periodic Worksite Inspection.

m. Designate qualified personnel for Contractor Surveillance and Worksite Inspections.

n. Verify completion of required Safety & Health Training for the designated Contractor Surveillance and Worksite Inspections personnel.

E. Contractor work at NCA Facilities WITHOUT a formal contract

1. The Facility Director, Supervisor, Foreman, or Collateral Duty Safety Officer shall verify that the Contractor is qualified to complete the assigned tasks. This qualification can be accomplished by various means, including:

a. Verification that the Contractor workers are certified to perform the involved tasks, or

b. Verification that the Contractor has a company certification to perform the involved tasks, or

c. Verification that the Contractor workers have received adequate training to perform the involved tasks, or

d. Verification that the Contractor workers have adequate experience to perform the involved tasks, or

e. Verification that the Contractor has recognized experience in the tasks to be completed.

2. The Facility Director, Supervisor, Foreman, or Collateral Duty Safety Officer shall require Contractor compliance with OSHA 29 CFR 1910 and OSHA 29 CFR 1926 and applicable Federal, State and Local regulations.

F. ALL Contractor work at NCA facilities

1. The Facility Director, Supervisor, Foreman, or Facility Safety Officer shall:

a. Inform the Contractor of the Cemetery Lockout/Tagout program.

b. Inform the Contractor of any hazards that might be anticipated in their assigned work area.

c. Inform the Contractor of any permit-required confined spaces in their work area.

d. Inform the Contractor of potential hazards in a permit-required confined space if they will be performing an entry.

e. Obtain an SDS from the Contractor for every hazardous substance that they may bring onsite or generate onsite and supply this information to any affected NCA employees and volunteers.

2. Obtain information on the Contractor Lockout/Tagout program and inform affected NCA employees and volunteers of the Contractor's Lockout/Tagout program (if applicable).

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ATTACHMENT 1:

Contractor Safety (FAR Clause)

52.236-13 Accident Prevention (https://www.acquisition.gov/far/52.236-13)

As prescribed in 36.513, insert the following clause:

Accident Prevention (Nov 1991)

a. The Contractor shall provide and maintain work environments and procedures which will-

i. Safeguard the public and Government personnel, property, materials, supplies, and equipment exposed to Contractor operations and activities.

ii. Avoid interruptions of Government operations and delays in project completion dates; and

iii. Control costs in the performance of this contract.

b. For these purposes on contracts for construction or dismantling, demolition, or removal of improvements, the Contractor shall-

i. Provide appropriate safety barricades, signs, and signal lights.

ii. Comply with the standards issued by the Secretary of Labor at 29 CFR Part

1926 and 29 CFR Part 1910; and

iii. Ensure that any additional measures the Contracting Officer determines to be reasonably necessary for the purposes are taken.

c. If this contract is for construction or dismantling, demolition, or removal of improvements with any Department of Defense agency or component, the Contractor shall comply with all pertinent provisions of the latest version of U.S. Army Corps of Engineers Safety and Health Requirements Manual, EM 385-1-1, in effect on the date of the solicitation.

d. Whenever the Contracting Officer becomes aware of any noncompliance with these requirements or any condition which poses a serious or imminent danger to the health or safety of the public or Government personnel, the Contracting Officer shall notify the Contractor orally, with written confirmation, and request immediate initiation of corrective action. This notice, when delivered to the Contractor or the Contractor’s representative at the work site, shall be deemed sufficient notice of the noncompliance and that corrective action is required. After receiving the notice, the Contractor shall immediately take corrective action. If the Contractor fails or refuses to promptly take corrective action, the Contracting Officer may issue an order stopping all or part of the work until satisfactory corrective action has been taken. The Contractor shall not be entitled to any equitable adjustment of the contract price or extension of the performance schedule on any stop work order issued under this clause.

e. The Contractor shall insert this clause, including this paragraph (e), with appropriate changes in the designation of the parties, in subcontracts.

36.513 Accident prevention.

a. The contracting officer shall insert the clause at 52.236-13, Accident Prevention, in solicitations and contracts when a fixed-price construction contract or a fixed-price https://www.acquisition.gov/far/52.236-13

Safety SOP B06 Issued: 03/10/2023 Page 6 of 15 dismantling, demolition, or removal of improvements contract is contemplated, and the contract amount is expected to exceed the simplified acquisition threshold. The contracting officer may insert the clause in solicitations and contracts when a fixed-price construction or a fixed-price contract for dismantling, demolition, or removal of improvements is contemplated and the contract amount is expected to be at or below the simplified acquisition threshold. If the contract will involve work of a long duration or hazardous nature, the contracting officer shall use the clause with its Alternate.

b. The contracting officer shall insert the clause or the clause with its Alternate in solicitations and contracts when a contract for services to be performed at Government facilities (see 48 CFR Part 37) is contemplated, and technical representatives advise that special precautions are appropriate.

c. The contracting officer should inform the Occupational Safety and Health Administration (OSHA), or other cognizant Federal, State, or local officials, of instances where the contractor has been notified to take immediate action to correct serious or imminent dangers.

NCA Safety Requirements:

1. Contractor shall meet all requirements of VA Policy, OSHA 29 CFR 1910, Occupation Safety and Health Standards for General Industry and 29 CFR 1926, Safety and Health Regulations for construction and applicable Federal, state, and local regulations., including:

a. Submit copies of all applicable OSHA-required programs.

b. Certify that every designated onsite employee has completed applicable training and certifications required by OSHA and other Federal, state, and local regulatory agencies

c. Provide a Safety and Health written program and training/certification.

d. Provide a written Project Emergency Action Plan when applicable.

e. Submit copies of all applicable OSHA-required programs.

f. Certify that every designated onsite employee has completed applicable training and certifications required by OSHA and other Federal, state, and local regulatory agencies.

g. Provide a Safety and Health written program and training/certification.

h. Provide a written Project Emergency Action Plan when applicable.

i. Shall maintain on site and readily accessible current hazard communication program, current chemical inventory and copy of Safety Data Sheets (SDS) or all chemicals on the inventory/on site and readily available when workers are onsite. Contractor must provide the CO/COR/Facility with a list of hazardous materials that will be used on the job. Quantities of single container, 30 gallons or more of hazardous chemicals must be reported to the CO/COR/Facility prior to bringing the chemicals on site. Ten gallons or more in a single container must have secondary containment and spill response material available.

j. Must notify the COR/CO/Facility prior to generating hazardous waste. The contractor is responsible for removing all hazardous waste generated from the project from the property. Chemicals must be stored in secondary containers to prevent storm water contamination. Hazardous waste requiring a manifest for disposal will have a completed manifest returned to the COR/CO/Facility and NCA

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Environmental Protection Specialist within 30 days of the manifested waste leaving the site.

k. Arrange Contractor orientation including sharing information regarding facility Safety & Health programs, a facility overview, and a worksite walk-through.

l. Complete NCA Contractor Safety Checklist.

m. Provide required Personal Protective Equipment (PPE) and training for the work being performed. Minimum PPE consists of safety glasses and hardhats meeting ANSI standards and safety toe work boots meeting ASTM standards. All VA construction projects require employees to wear hard hats, safety glasses and protective footwear from the start of the contract until completion. Contractor is responsible to ensure anyone on the site is in correct PPE. Additional PPE may be required based on job-specific hazards. N95 and other respiratory protection require medical approval and fit testing. Hearing protection, gloves, etc. must be worn when related hazards are present.

n. Bodily injury, property damage incidents, and near misses must be immediately reported to the COR/CO/Facility and Facility Collateral Duty Safety Officer. This does not relieve contractors of OSHA or insurance carrier reporting requirements.

The contractor shall conduct an accident investigation. The CO/COR/Facility and the Collateral Duty Safety Officer must be copied on the investigation report within 30 days of the incident.

o. Conduct and document jobsite safety and environmental inspections on the jobsite.

A weekly inspection report must be completed by the contractor of the project.

Additionally, the CO/COR/Facility and Collateral Duty Safety Officer will perform safety, health, and environmental inspections. CO have the authority to stop work if imminent safety and health hazards are identified or safe work practices are not being utilized. Immediate corrective actions are required for hazards identified as presenting medium or high risk as determined by the Collateral Duty Safety Officer.

Contractor must reply to CO/COR with corrective actions.

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ATTACHMENT 2 :

NCA CONTRACTOR SAFETY ORIENTATION CHECKLIST

CONTRACTOR INFORMATION (Must be completed for each review) Contractor(s): Date of Orientation Facility Rep:

SAFETY REQUIREMENTS (Check every box if discussed. Blank indicates not discussed.)

The following information was reviewed at the time of the safety orientation. All contractors are to complete the orientation.

OSHA Poster. The OSHA Worker Protection Poster indicates basic safety and health requirements and the point of contact for inquiries. It must be posted / available at the work site. If you have a safety concern, contact, in order, the following: 1) your supervisor, 2) the COR/CO for your project contact name/#: ___________________________, 3) Collateral Duty Safety Officer: XXX-XXX-XXXX. If still unresolved, return to the poster for instructions on who to contact next.

VA Safety/Occupational Safety and Health Administration (OSHA) Requirements. 29 CFR 1910, Occupation Safety and Health Standards for General Industry and 29 CFR 1926, Safety and Health Regulations for construction are in effect and enforced by the VA. In addition to OSHA law, you must also comply with Section 01 35 26, Safety Requirements of your construction specifications.

Job Site Inspections. The contractor is responsible for conducting and documenting jobsite safety Infection Control and environmental inspections and for enforcing safety, health, and environment on the jobsite. A weekly inspection report must be completed by the supervisor/superintendent of the project. Additionally, the COR/CO and Collateral Duty Safety Officer will perform safety, health, and environmental inspections. Inspectors have the authority to stop work if imminent safety and health hazards are identified or safe work practices are not being utilized. Immediate corrective actions are required for hazards identified as presenting medium or high risk as determined by the Collateral Duty Safety Officer.

Contractor must reply to COR/CO with corrective actions.

Emergency Reporting. Fire Emergencies: Call XXX-XXX-XXXX and notify of fire location. Evacuate for alarms. Medical emergencies, including the need for emergency medical services, must be reported by dialing 9-1-1. In addition, the contractor must call XXX-XXX-XXX to notify of the emergency and that 9-1-1 was called. Rescue, Alert, Confine (fire), Evacuation/extinguish. Display the emergency procedures in a conspicuous place where workers can see them.

Accident Reporting and Investigation. PREVENTION: Identify tasks – Identify hazards in tasks – Identify controls to protect from the hazards. POST INJURY: Bodily injury, property damage incidents, and near misses must be immediately reported to the construction project manager and the Collateral Duty Safety Officer. This does not relieve contractors of OSHA or insurance carrier reporting requirements. The contractor shall conduct an accident investigation.

The COR/Collateral Duty Safety Officer must be copied on the investigation report within 30 days of the incident.

Exit Access. INSIDE: A clear path of at least 44 inches must be maintained to exits in common corridors. Inside the construction zone, maintain a clear path for evacuation.

Hazardous Materials. The contractor shall maintain on site and readily accessible their current hazard communication program, current chemical inventory and copy of Safety Data Sheets for all chemicals on the inventory/on site and readily available when workers are onsite. Contractor must provide the COR/CO with a list of hazardous materials that will be used on the job. Quantities of single container, 30 gallons or more of hazardous chemicals must be reported to the COR/CO prior to bringing the chemicals on site. Ten gallons or more in a single container must have secondary containment and spill response material available.

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Hazardous Waste. The contractor must notify the project manager prior to generating hazardous waste. The contractor is responsible for removing all hazardous waste generated from the project from the property. Chemicals must be stored in secondary containers to prevent storm water contamination in the event of a spill. Hazardous waste requiring a manifest for disposal will have a completed manifest returned to the COR/CO and Safety within 30 days of the manifested waste leaving the site.

LEAD and LEAD liners: Contractor is responsible for identification of lead containing materials, appropriate PPE and removal procedures and must notify COR/CO should LEAD removal or dust generation work be planned.

Asbestos-Containing Materials (ACM). The location of ACM must be determined prior to the start of work. ACM must not be disturbed, and the contractor must comply with EPA and state requirements for removal of any ACM through a qualified contractor. The Collateral Duty Safety Officer must be notified of plans to remove any ACM material.

Unplanned disturbance or damage to any ACM must be reported immediately to the COR and NCA Environmental Management XXX-XXX-XXXX. Any proposed ACM work must be pre-approved by submitting appropriate submittals and technician certifications as noted in spec section, a minimum of 2 weeks in advance.

Aboveground Storage Tanks. Contractor must notify COR/CO and Collateral Duty Safety Officer of desire to place an AST on VA property prior to placement. Notification must include planning for location, security, spill response, warning signs and secondary containment.

Lockout/Tagout (LO/TO). The contractor must comply with OSHA LO/TO requirements. Voltage work on systems greater than 440 must have the LO/TO plan reviewed by COR/Safety prior to initiating work. Contractor must use own lock and key for LOTO work. Keys will not be shared or turned over to VA at end of individual contractor/sub-contractor work. COR/CO will be notified of need to place VA lock and tag prior to departure.

Electrical Hazards. Electrical installations shall comply with the requirements of the National Electric Code and the codes enforced by the authority having jurisdiction. Electrical safe work practices shall comply with OSHA and the requirements identified in National Fire Protection Association 70E.

Work on energized electrical systems is prohibited. Work on energized systems requires a hazard analysis by a qualified Electrical Engineer.

Portable power tools and other electrical equipment on extension cords at construction projects will be protected with ground fault circuit interrupter (GFCI). All power cords and plugs will be inspected and maintained in safe condition.

Cords will not be taped as temporary repair. Cords and equipment identified as failing inspection will be removed by to ensure the safety of workers.

Scaffolds Work. Scaffold work will comply with the requirements of 29 CFR 1926, Subpart L. Rolling scaffold will have wheels locked when workers are on scaffold. Scaffolding six feet or higher will have top rail, mid rail and toe board.

Scaffold weight load will not be exceeded. Scaffolds will have a “safe zone” identified with cones or tape to prevent pedestrians walking into the hazard area. Suspended scaffolds must have a scaffold plan review prior to setting up and walk through after set-up with COR/CO and/or Collateral Duty Safety Officer. Contractor is responsible for safety of the system reviewed and used. Scaffold systems must be constructed under the guidance of a competent person. This person must be identified in the safety plan or contract. Scaffolding will have a daily inspection system employed such as “green tagging” to show daily inspections were completed. Suspended scaffolding and constructed scaffolding plans must be provided to COR/CO/ Collateral Duty Safety Officer before starting any scaffold work.

Ladders. Ladders must be in working conditions with no broken, missing, or lose components. They will be inspected before the start of each work shift. Weight loads must not exceed weight rating. Ladders will be used in accordance to 29 CFR 1926.1053. Ladders used at or near doors, stairs, corridor intersections or similar limited visibility areas will have warning signs, cones, or similar devices to warn of the ladder’s presence. Ladders will not be combined with a platform for raised work area. Step ladders will be used in expanded operation only. Extension ladders will have 3 feet step off clearance at top and be secured when upright.

Fall Protection. Fall protection systems, such as handrail systems or PFAS shall be established to protect workers exposed to falls of six feet or more, when working within six feet or less of a six foot or greater drop off. Full body harnesses, shock-absorbing lanyards, and appropriately rated anchor points are required for PFAS systems. Workers must be properly trained and qualified in the care and use of such systems. The contractor shall submit a project-specific fall protection plan to the COR/CO or Collateral Duty Safety Officer for review prior to start of work. Fall protection will comply, at a minimum, with 29 CFR 1926, Subpart M and 29 CFR 1910, Subpart I, ANSI/AFFT Z359.

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Personal Protective Equipment (PPE). The contractor is required to supply the required PPE for the work being performed. Minimum PPE consists of safety glasses and hardhats meeting ANSI standards and safety toe work boots meeting ASTM standards. All construction projects require wear of the hard hat, safety glasses and safe work boots from the start of the contract until completion. Contractor is responsible to ensure anyone on the site is in correct PPE.

Additional PPE may be required based on job-specific hazards. N95 and other respiratory protection require medical approval and fit testing. Hearing protection, gloves, etc. must be worn when related hazards are present.

Permit Required Confined Spaces. A confined space list will be provided by the COR/CO at the start of the contract.

Contractor is required to identify any potential confined spaces they may enter before entry and evaluate if will require a permit for entry. Contractor will notify the COR/CO and Collateral Duty Safety Officer prior to entry into a permitted confined space. Notification will include review of entry procedures and confirmation of rescue equipment. A Confined Space Entry Permit must be completed and maintained at the entry area with attendant. Contractors must provide the necessary equipment to support this activity, such as multi-gas detector, rescue devices, attendants, trained rescue personnel, and ventilation equipment. Workers involved in this activity, such as entrants and attendants, shall be qualified and properly trained.

Hot Work. A Hot Work Permit shall be obtained from the COR/CO or Collateral Duty Safety Officer prior to hot work or spark producing activities. The hazards and controls specified in the Hot Work Permit and Hot Work Permit Checklist shall be followed. HW Permits are good for one day. Weekend work requires coordination with COR for extended permits. All weekend permits will be completed each day of hot work activity and turned in Monday morning to the

COR/CO.

Excavation. Excavation safety requirements are those specified in OSHA29 CFR 1926, Subpart P. The contractor shall perform daily inspection of excavations. A competent person shall conduct this inspection prior to the start of work, after a rainstorm, or other hazard increasing occurrence. COR/CO must be notified of excavations > 4ft prior to initiating dig.

Compressed Gas. Compressed gas cylinders must be secured at all times to prevent fall and damage to cylinder valve.

When not in use or end of workday, regulators must be removed, and the cylinder stored with the cap screwed in place.

Flammable gas and oxidizers must be stored separately by a wall or by distance of 20 feet. All cylinders must be tagged as to FULL, IN USE, or EMPTY.

Powder Actuated Tools (Gas Actuated Tools). If an alternative method is available, please use. If powder actuated tools are the only appropriate tool, ensure the following: Post “Powder Actuated Tool in Use” signs when powder actuated tools are in use located within 50 feet of the area where the tool is being used. Notify clinical and in-patient staff on the floor and above/below of the tool being used. Do not place hands or fingers over the front muzzle end of the tool.

Wear appropriate hearing and eye protection. Powder-actuated tools must be left unloaded until they are ready to be used. Know the misfire procedures. Documentation of training by manufacturer must be available. Store the shot and tool separately, UNLOADED, under lock and key. Gas Actuated Tools. Wear eye protection, set up screen or shield to protect others from flying fragments, ensure air supply is clean, dry, and free of oil. Attachments limited to those recommended by manufacturer. Air hose rated for 150% of max pressure produced. Inspect hoses at start of each shift.

Interim Life Safety Measures (ILSM). ILSM requirements occur whenever work is being done that requires removing any of the following from service: Notification (fire alarms), detection (smoke/heat detectors), suppression (sprinklers/extinguishers) and evacuation (exit door, exit hallway, smoke door, exit discharge or other emergency path of travel must be blocked, secured in a non-protective state (fire door propped open), or otherwise rendered out of order or use, an ILSM must be put in place. ILSMs are coordinated with the COR/CO and requires an advance 15-day written notice. ILSM inspection checklists must be initiated with start date and time – NEVER predate. They must be closed with final date and time.

Penetration Permit. All penetrations through walls, ceilings and floors must be planned with a penetration permit. The penetration permit ensures an assessment of the planned penetration includes impact on structural design for fire containment and protection. Penetrations must be sealed with a recognized laboratory approved fire penetration sealant which has also been accepted by the COR/CO through the penetration permit. Penetration permits are obtained from the COR/CO and must have a closeout inspection before closing the permit.

Temporary Heaters. Not permitted except in pre-approved special conditions – (may require up to a 30-day approval process). No propane or other combustible fuel heaters indoors or on rooftops.

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Cranes, Hoisting, and Rigging. All proposed crane lift activities require a 45-day approval process. Requests and all safety documentation must be submitted 6 weeks in advance of the planned lift date. Cranes shall be inspected, certified, and maintained. Cranes operating at NCA are subject to the requirements identified in 29 CFR 1926 and Subpart CC 29 CFR 1910 Subpart M. It is the responsibility of the crane owner and operator to comply with OSHA requirements.

Operators, riggers and signal person shall have equivalent certification (operator/rigger) and appropriate training (signal person). Tag lines shall be used to control loads during lifts. No one is permitted beneath suspended loads. A written lift plan is required for all VA lifts. Crane operators shall be ready to review load charts and conduct an onsite inspection prior to the start of the lift. A pre-left meeting must occur and include everyone who will be around the lift, at the time of the lift, and daily as long as the lift is in place.

Operating Equipment. Operating equipment shall be equipped with a rollover protection system, seatbelts, and functioning back-up alarms. The contractor shall provide experienced and qualified operating staff. This equipment shall be properly stored and maintained while on site. Spills or leaks involving lubrication/hydraulic fluids shall be immediately reported to the Safety Office and properly remediated. Fire extinguishers shall be provided.

Recycling. The VA is mandated to recycle the following items: wood/pallets, cardboard, paper (white or comingled), batteries (lead acid, NiCad, etc.), Scrap Metals (ferrous), Precious Metals, Non-Ferrous Metals (e.g., silver amalgam), non-ferrous metal (e.g., aluminum, brass, copper, lead, etc.), fluorescent lamp ballast, electronics (used computers, printers, etc.) and used oil. Other recycling categories include the following: organic solvents (e.g., alcohols, xylene, and formaldehyde), plastics, composting and fats (grease recycling). Questions on recycling should be directed to the CO/COR. Standard VA RECYCLING AND WASTE reports must be submitted every month with invoice.

Spills/Releases/Petroleum Oil and Lubricants (POL) Spills. I accordance with the VA’s Spill Prevention, Control and Countermeasures Plan all POL spill or releases of product that appears to be a threat of severe environmental harm must be reported to the authorities and your COR/CO immediately. All spills reaching storm drains or navigable water ways are considered severe. Verification for periodic checks of POL containing vessels will be required by your COR/CO.

All other spills and releases (chemicals spills, release of mercury, and damaged asbestos containing-materials) which exceed the on-site personnel knowledge or training to safely mitigate the hazard must be reported to your COR/CO immediately.

Storm water drains must be protected from anything entering except storm water. Notify COR/CO and GEMS immediately if any prohibited material enters storm water drain.

Smoking. Smoking is prohibited within any building at------------National Cemetery administration facilities. Smoking is permitted outside of the building, at least 25 feet away from the entrance of the building. Smokers should obey any “NO SMOKING” signs posted on the cemetery property. Cigarette butts should not be disposed on the grounds. All cigarette butts must be properly extinguished and disposed of in trash receptacles.

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ATTACHMENT 3:

National Cemetery Administration

Safety Checklist for Contractors

Location (Cemetery name and location) Cemetery Contact

Contract Number Contractor Name

Reviewer’s Name (Print) Reviewer’s Signature

This checklist serves as a guide only, it does not replace or eliminate the need to comply with the requirements set forth in OSHA 29 CFR 1910 General Industry Regulations and OSHA 29 CFR 1926 Construction Regulations. Based on a risk assessment of contracted activities and on mandatory OSHA compliance programs, the Contractor shall address all applicable occupational risks and compliance plans. Plans may include but not be limited to:

Item Description Yes No N/A Remarks (Any No or N/A item)

1. Statement of Safety and Health Policy

a. Includes: Copy of current company Safety and Health Policy Statement, detailing commitment to providing a safe and healthful workplace for all employees.

b. Includes: Contractor’s written safety program goals, objectives, and accident experience goals for the current contract.

c. Includes: Risk Management Processes. Detailed project-specific hazards and controls shall be provided by a Job Hazard Analysis (JHA) for each major phase/activity of work.

2. Responsibilities and Lines of Authorities

a. Includes: A statement of the contractor’s ultimate responsibility for the implementation of their Safety and Health Program.

b. Includes: Lines of authority.

c. Includes: The identification and job responsibilities of personnel responsible for safety - at both contractor (Corporate) and cemetery level.

3. Accident Prevention Plan

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a. Accident Reporting and Investigation Procedures PREVENTION: Identify tasks – Identify hazards in tasks – Identify controls to protect from the hazards.

POST INJURY: Bodily injury, property damage incidents, and near misses must be immediately reported to the construction project manager and the Collateral Duty Safety Officer. This does not relieve contractors of OSHA or insurance carrier reporting requirements. The contractor shall conduct an accident investigation. The CO/ COR/ Collateral Duty Safety Officer must be copied on the investigation report within 30 days of the accident.

b. OSHA 300 Log

c. Accident Reporting

• The plan identifies how, when, and who shall complete the Exposure data (man-hours worked).

• The plan identifies how, when, and who shall complete accident investigations, reports, and logs.

• The plan identifies how, when, and who shall make immediate notification of major accidents (fatality or any amputation, loss of an eye, or hospitalization of an employee).

d. Emergency Response Plans

• Procedures & Tests/Drills Program

• Severe Weather Plan

• Spills Plans

• Fire Prevention Plan/Fire Extinguisher Training

• Posting of Emergency Telephone Numbers

4. Medical Support Outline on-site medical support and off-site medical arrangements including rescue and medical duties for those employees who are to perform them, and the name(s) of on-site Contractor personnel trained in first aid and CPR. A minimum of two employees shall be certified in first aid and CPR per shift/site.

5. Training

a. Includes requirements for new hire Safety Orientation training at the time of initial hire of each new employee.

b. Includes the list of mandatory training and certifications applicable to this project (e.g., fall protection, confined space entry, equipment operator, vehicle operator, Safety SOP B06 Issued: 03/10/2023 Page 14 of 15

HAZCOM training, PPE) and any requirements for periodic retraining/ recertification.

c. Includes the identity requirements for emergency response training.

d. Includes the procedures for periodic safety and health training for supervisors and employees.

6. Safety and Health Inspections

a. Includes the name(s) of individual(s) responsible for conducting safety inspections. (e.g., PM, safety professional, QC, supervisors, employees).

b. Includes proof of inspector's training/ qualifications.

c. Indicates when inspections will be conducted.

d. Furnished sample forms upon which inspections will be recorded.

e. Indicates deficiency tracking system and follow-up procedures.

f. Includes the names of competent and/or qualified person(s) and proof of competency/ qualification to meet specific OSHA competent/ qualified person(s) requirements.

g. Includes any internal/external inspections (e.g., OSHA, NCA AWE)

7. Site Specific Plans and Procedures

a. Site Sanitation Plan

(29 CFR 1910.141)

b. Respiratory Protection Plan

(29 CFR 1910.134)

c. Hazard Communication Program (HAZCOM)

d. Abrasive Blasting Plan (29 CFR 1910.94(a)(5)-(6))

e. Heat/Cold Stress Monitoring Plan

f. Crystalline Silica Monitoring Plan

(29 CFR 1910.1053)

g. Hazardous Energy Control Plan – Lock Out Tag Out (LOTO)

h. Fall Protection & Prevention Plan (Site- Specific)

i. Confined Space Entry Program

Safety SOP B06 Issued: 03/10/2023 Page 15 of 15

Remarks:

j. Hearing Conservation (29 CFR 1910.95(c)

k. Flammable Liquid Storage (29 CFR 1910.106 (d))

l. Excavation Safety Plan

m. Other:

n. Other:

o. Other:

8. Other:

9. Other:

10. Other: