Amendment No. 1_ Sol. SAQMMA09R0315.pdf

ATTACHMENT NO. 1

TITLE: Solicitation No. SAQMMA09R0315 AMENDMENT NO. 001

SECTION C, EXHIBIT 1

ENVIRONMENTAL, HEALTH & SAFETY REQUIREMENTS

TABLE OF CONTENTS

Introduction

Documents Included by Reference

EHS Management System

Environmental Program Requirements

Affirmative Procurement

Hazardous Materials Management

Recycling and Waste Minimization

Solid Waste Management

Hazardous Waste Management

Regulatory Compliance Requirements

Health and Safety Program Requirements

Written Health and Safety Program

Additional Health and Safety Requirements

Accident Prevention

Arc Flash

Confined Spaces

EHS Kickoff Meeting

Hazard Communication Program

Hazardous Conditions

High Risk Activities

Obstructions

Public Protection Requirements

Storage

Welding, Cutting and Burning

Training and Qualifications

Program Evaluation

INTRODUCTION

It is Department of State (DoS) policy to conduct all activities that support our diplomatic missions in an environmentally sound, healthy, safe, energy-efficient and sustainable manner.

The DoS Domestic Environmental and Safety Division (DESD) is responsible for implementing environmental, health and safety (EHS) policies for all domestic Department of State (DoS) facilities, including facilities that are owned by the Government or leased from private landlords. The Contractor and its subcontractors are responsible for complying with this Exhibit and all applicable

Federal, state and local EHS regulations. The Contractor shall assume full responsibility and liability for compliance with all applicable regulations pertaining to the health and safety of personnel during the execution of work, and shall hold the Government harmless for any action on the Contractor’s part or that of its employees or subcontractors, which results in illness, injury or death.

The Contracting Officer’s Representative (COR) for this contract is responsible for ensuring EHS requirements addressed in this exhibit are adhered to by the Contractor and any subcontractors working under this contract. The COR should work with DESD regarding questions pertaining to EHS issues, and resolve any contractor noncompliance issues by working with the Contractor and the Contracting Officer.

The Contractor, not the DoS, is responsible for ensuring its subcontractors are qualified to safely perform the work under this contract and are adhering to the requirements of this contract and all applicable regulations. At times, DESD or DoS may review contractor and subcontractors work plans, drawings, or EHS procedures to ensure the deliverables adequately document the planned work procedures.

These deliverable reviews and approvals are to ensure the planned work has been well thought out, but do not constitute an endorsement of the proposed work practices and do not absolve the contractor and its subcontractors of any liability.

The contractor is required to actively participate in third party management system certification programs pursued by the Department of

State. Such programs may include US Green Building Council Leadership in Energy and Environmental Design for Existing Buildings Operations and Maintenance (LEED EB O&M), the Occupational Safety and Health

Administration’s Voluntary Protection Program (VPP), and the

Environmental Protection Agency’s Performance Track Program.

The contractor is encouraged to seek assistance and guidance on any and all EHS issues from the COR and DESD.

Compliance with applicable regulatory requirements is the responsibility of the Contractor. The contractor shall be fully responsible for providing and accomplishing the required services as outlined in the solicitation while maintaining conformance with applicable environmental, energy, health, and safety mandates. Where there is a conflict between applicable regulations, the most stringent shall apply.

DOCUMENTS INCORPORATED BY REFERENCE

The following regulations are incorporated into the contract by reference. The contractor is expected and required to comply with each of the regulations pursuant to their contract activities. The latest regulation, interpretation, and compliance directives shall apply to the work being performed by the Contractor and subcontractors under this contract. No information in this Exhibit is intended to supersede any FAR regulation.

1) 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses

2) 29 CFR 1910, Occupational Safety and Health Standards for General Industry

3) 29 CFR 1926, Occupational Safety and Health Standards for the Construction Industry

4) National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 61)

5) Clean Air Act of 1990

6) Resource Conservation and Recovery Act of 1976.

7) The most current National Fire Protection Act (NFPA) and International Building Code (IBC) requirements.

8) Executive Order 13423, Strengthening Federal Environmental, Energy and Transportation Management

9) 40 CFR, Protection of Environment

10) Dept of State, Affirmative Procurement Plan

11) Clean Water Act (33 U.S.C. 1368)

12) Pollution Prevention Act (1990)

13) Energy Policy Act (1992, amended 2005)

14) Energy Independence and Security Act (2007)

15) Federal Acquisition Regulation: Subchapter D, Part 23, and

Parts 1, 2, 4, 7, 10,11, 12, 13, 15, 16, 17, 36, 37, 42, and 52.

www.acquisition.gov/far/current/html/FARTOCP23.html http://www.acquisition.gov/far/current/html/FARTOCP23.html

EHS MANAGEMENT SYSTEM

The Contractor must institute an EHS Management System as part of this contract and designate the person who is ultimately responsible for managing the EHS program (EHS Coordinator). As part of the bid process, the Contractor must provide a written summary of how EHS considerations are integrated into their routine contract operations.

The summary should address the following:

leadership commitment and employee involvement roles and responsibilities workplace analysis, hazard prevention and control training and communication program auditing, evaluation and management review recordkeeping

The EHS Coordinator is responsible for communicating with the COR and

DESD with respect to EHS issues; ensuring personnel performing assigned tasks are appropriately qualified and certified; performing quality assurance audits, documenting corrective actions, and performing follow-up inspections; developing trend analysis data; and providing written technical reports concerning technical issues or potential problems. The EHS Coordinator may be supported by other EHS professionals at the contractor’s discretion.

ENVIRONMENTAL PROGRAM REQUIREMENTS

It is Department of State (DoS) policy to conduct all environmental, transportation, and energy-related activities that support our diplomatic missions in an environmentally, economically and fiscally sound, integrated, continuously- improving, efficient, and sustainable manner. The Government expects the following to be incorporated in the contractors overall EHS program.

Affirmative Procurement (Green Purchasing)

It is Department Policy (US DoS Affirmative Procurement Program) to give preference for the purchase of recycled content products, Energy Star Products, FEMP designated energy efficient products, water efficient products, energy from renewable sources, bio-based products, environmentally preferable products and services including EPEAT-registered electronic products alternative fuel vehicles and alternative fuels, and non-ozone depleting substances. It is our goal that all product acquisitions meet one or more of these categories as appropriate, unless precluded by performance, price or availability.

The characteristics of green products can vary significantly depending on the product. The green attributes of a concrete mix, for instance, might include the use of fly-ash (a post-industrial recycled content material), while the green attributes of an interior paint might focus on low VOC content. Realizing this, we do not expect every purchase to meet every environmental attribute; however, we do expect that one or more attributes be met (as appropriate for the product type) for the purchase of all products and materials associated with this contract. This is not limited to those products used for facility maintenance, but also includes items such as computer electronics, office supplies, or any other materials purchased for on-site use by contract staff.

Additionally, we expect that at least 50% of all purchases (based on total cost) be “green” purchases.

Listed below are common definitions for various categories of

“green products” and some examples.

Bio-based products - are defined as commercial or industrial products (other than food or feed) that utilize biological products or renewable, domestic, agricultural

(e.g., plant, animal and marine), or forestry materials.

Examples of bio-based products include deicers, wood and concrete sealers, hydraulic fluids, etc.

http://www.biopreferred.gov/Default.aspx?SMSESSION=NO

Environmentally preferable - means products or services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose. This comparison may consider raw materials acquisition, production, manufacturing, packaging, distribution, reuse, operation, maintenance or disposal of the product or service.

Environmentally preferable does not consider any single product attribute, rather considers the “bigger picture” and the thought process behind purchasing decisions – Is a low VOC product really better for the environment if you have to apply twice as much or re-apply more frequently, or ship here from China?

Post Consumer Content – the percentage of material in a product that is recycled from consumer waste. Examples of products with post consumer recycled content include wallboard, carpeting, insulation, ceiling tiles, roofing products, plastic and paper products, packaging materials, etc. Look for products with third party certification labeling or data sheets that identify the recycled content of the product.

Pre-Consumer Content (post-industrial content) – the percentage of material in a product that is recycled from manufacturing waste (print overruns, trimmed materials, http://www.biopreferred.gov/Default.aspx?SMSESSION=NO sawdust, etc.) excluding materials commonly re-used within an original manufacturing process. Same examples as above.

Rapidly Renewable Materials – planted and harvested in less than 10 years.

Regionally Harvested (or extracted) and processed materials

– come from within a 500 mile radius of the project site.

Recycled Content – Combined sum of pre- and post-consumer recycled content.

Third-Party Certification - The certification of a specific product or process that is performed by an organization independent from those who produce the product or process.

Certification is often used to substantiate the environmental attributes of specific products (such as the percentage of recycled content) or processes (such as a sustainable harvesting operation for forests). Examples of third party certifications include Forrest Stewardship Council, Green Seal, Green Guard, Design for the Environment, Energy Star, etc. Selection of products with third party certification removes the research and guesswork from product selection and is the easiest means of showing compliance with green purchasing requirements.

Volatile Organic Compound (VOC) - Chemicals that contain carbon molecules and have high enough vapor pressure to vaporize from material surfaces into indoor air at normal room temperatures (a process known as off-gassing). While most VOCs are relatively inert at typical indoor concentrations, they can react with oxidants such as ozone and possibly nitrogen oxide and nitrogen dioxide to form reactive species and possibly strong irritants, including various acids and aldehydes. VOCs may cause eye and upper respiratory irritation, nasal congestion, headache, and dizziness. Examples of building materials that contain VOCs include, but are not limited to, solvents, paints, adhesives, carpeting, and particleboard. Limits on “acceptable” VOC emissions vary depending on product type (carpeting, paints, adhesives). For example, for paints and coatings the VOC concentration of the product shall not exceed those (grams of VOC per liter of product) as determined by ASTM D6886-03; for adhesives and sealants, VOC concentrations should not exceed limits established by SCAQMD #1168, etc.

Contractor Responsibilities include the following:

Purchase “green products” in accordance with DoS policy.

Ensure available documentation to verify product selection.

Note: the easiest means of complying with this requirement is to select third party certified products with documentation on the label i.e. Green Seal, Design for the

Environment, SCAQMD compliant, etc.

Contractors are required to submit to the COTR, on a quarterly basis, a summary of total purchases with documentation of the products environmental attributes. An example of this is shown in the table below:

Product

Name

Quantity

Purchased

Unit Cost

Green Attribute Total

Purchase

Amount

Paintbrush 20 3.34

Recycled plastic handle/refill bristles to minimize waste

66.80

Olympic

Paint 5 Gallon 32.00

Zero VOC, Greenseal labeled

160.00

WD-40

Case 12 / 12 oz cans

69.90 _____ 69.90

GeoGreen

Adhesive

1 case (12 units) 49.90

Lox toxicity, low VOC 49.90

Hazardous Material Management

The contractor is required to minimize use of hazardous materials in performance of this contract. Preference shall be given to selection and purchase of EPA designated environmentally preferable products and USDA designated bio-based products.

The Contractor shall submit to the COR for approval, an inventory of all hazardous material/ chemicals that the contractor (or any subcontractor) intends to use. The Contractor shall have copies of Material Safety Data Sheets (MSDSs) readily available on-site for all hazardous materials used or stored on-site.

A hazardous material is any material that, because of its quantity, concentration, physical characteristics, or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released.

The Contractor shall not use materials/chemicals unacceptable to the COR and shall substitute alternatives within fifteen (15) days after notification of submittal rejection, or as otherwise directed by the COR.

The Contractor shall notify the COR, in writing, of any change in the Hazardous Materials Inventory. Prior to using any new or substitute chemical, the Contractor shall obtain the aforementioned approvals of the COR.

Contractor material/chemical use shall in no way threaten the health or safety of employees or disrupt DOS operations. The

Contractor shall comply with all existing Government regulations for safe handling, storage, disposal, and use of hazardous materials/chemicals. The words materials and chemicals are interchangeable for the purpose of this Section.

The Contractor shall be responsible for escorting Safety and

Environmental Management subcontractors of the DOS who will be conducting hazardous material inventory surveys through the buildings. The Contractor shall be responsible for maintaining a file, during the life of this contract, which shall include a copy of the survey, and correction of the findings, which shall be made 30 days after receiving the report.

The Contractor shall not stockpile, and shall immediately remove, any hazardous material generated in the performance of this contract.

The Contractor shall prepare a written hazard communication program in accordance 29 CFR 1910.1200 for protecting personnel and property during the transport, storage and use of hazardous materials. The contractor’s hazard communication plan shall address, as a minimum, the following:

Emergency procedures for spill response and disposal of hazardous materials.

Labeling system to identify contents on all containers on-site.

Current inventory of hazardous chemicals on site.

Location and use of Material Safety Data Sheets (MSDSs) at the Government jobsite.

Training (to include potential safety and health effects from exposure to hazardous substances).

The Contractor shall bring to the attention of the COR/DESD any material suspected of being hazardous that is encountered during execution of the work. A determination will be made by the

COR/DESD as to whether the Contractor shall perform tests to determine if the material is hazardous. If the COR directs the

Contractor to perform tests, and/or if the material is found hazardous and additional protective measures are needed, a contract scope of work change may be required.

Recycling & Waste Minimization

The Department of State is committed to the minimization of non-recyclable waste generated in all of our activities, including the performance of this contract. This strategy is synergistic with our requirements for green purchasing (minimal packaging, biodegradable, recyclable, etc.).

Like most federal agencies, the Department has a recycling program in place. It is expected that the successful bidder will fully participate in existing recycling programs for paper (all types), cardboard, pallets, batteries, beverage bottles, cans, toner cartridges, fluorescent bulbs, and other common recyclable materials.

Offerrors shall propose methods or procedures, 1) for minimizing the non-recyclable waste generated in performance of this contract and 2) to enhance separation under the existing recycling program of recyclable materials from waste generated in the performance of this contract. With respect to enhancement of separation under the existing recycling program, offerors should address each of the following areas:

procedures for monitoring volume of waste and recyclables recovered, measures to ensure Contractor observance of the recycling program, and procedures for recovery and recycling of the listed recycled materials.

Offerrors shall participate in existing facility recycling programs as follows:

Provide recycling containers (in space occupied by the contractor) for the collection of paper/beverage bottles/cans/newspapers/rechargeable batteries/toner cartridges. These items will be collected by building custodial services.

For building maintenance generated recyclables (fluorescent bulbs, lubricants, etc.) the contractor will collect and store these materials in an area designated by FMS. FMS will be responsible for having these materials recycled.

Solid Waste Management

The Contractor shall comply with EO 13423 requirements for Solid

Waste Diversion and Recycling. Reduce solid waste generation, reuse and recycle waste including packaging, glass, plastic, bimetal, cardboard, mixed paper. The Contractor shall integrate recycled products into the building’s waste stream in accordance with the building’s program for recycling. The volume of any recyclable waste stream that is not incorporated into the building-recycling program shall be reported monthly to the CO.

The Contractor shall use post-consumer recycled content paper products to the extent feasible. The Contractor shall buy products with packaging that can be recycled and recycle all packaging.

Hazardous Waste Management

The Contractor shall bring to the attention of the COR/DESD any excess material known to be, or suspected of being hazardous, prior to disposal. A determination will be made by the COR/DESD as to the method of disposal. If the COR directs the Contractor to coordinate waste disposal, and/or if additional protective measures are needed, the contract scope of work may be changed.

Regulatory Compliance Requirements

The contractor is expected and required to comply with all applicable Federal, state and local regulations pursuant to specific contract activities. All work, including contact with and handling of hazardous materials, the disturbance of or dismantling of structures containing hazardous materials and/or the disposal of hazardous materials shall comply with the applicable requirements of 29 CFR 1926/1910 and 40 CFR 761.

Work involving the disturbance and/or dismantling of asbestos and/or asbestos containing material; and/or the disposal and removal of asbestos, shall also comply with the requirements of

40 CFR, Part 61, Subparts A and M. All work shall comply with applicable state and municipal safety and health requirement.

Where there is a conflict between applicable regulations, the most stringent shall apply.

HEALTH AND SAFETY PROGRAM REQUIREMENTS

The Contractor is responsible for developing and implementing OSHA-compliant, contract-specific health and safety programs and procedures to be used under this contract. Compliance with the OSHA standards and other applicable laws and regulations for the protection of

Contractor and subcontractor employees performing work under this contract is exclusively the obligation of the Contractor. The

Government will assume no liability or responsibility for the

Contractor's or subcontractor’s compliance or noncompliance with such requirements.

Written Health and Safety Program

The Contractor shall submit a written health and safety program with sufficient detail for the Government to evaluate the adequacy and completeness of the program. The program should provide:

A description of the accident prevention, accident reporting and corrective action procedures.

A job safety analysis for each labor category and/or work task identifying the potential hazards (including specific chemical hazards) and the work practice and personal protective equipment controls to be used to eliminate or minimize the hazard.

A list of all the OSHA-required written programs (e.g., hazard communication, hearing conservation, lead, etc.)

expected to apply to the work being performed under the contract and which written programs the contractor already has prepared. The Contractor should only submit those written programs asked for in the Submittal schedule located in Section J. Attachment A.

A description of the methods the Contractor will employ to audit Contractor and subcontractor health and safety performance, evaluate potential corrective actions, and perform follow-up inspections.

Additional Health and Safety Requirements

The Contractor shall adhere to the following DoS-specific requirements in addition to complying with applicable OSHA standards:

Accident Reporting: The Contractor is responsible for recording work-related injuries and illnesses on OSHA Form

301, Injury and Illness Incident Report, or an equivalent form within 7 days of being notified of a work-related injury or illness to one of their employees or their subcontractor’s employees. If the injury or illness involved days away from work, the Contractor is responsible for notifying the COR of the incident within twenty-four hours of the occurrence. A copy of the accident report, which the Contractor or Subcontractors submit to their insurance carriers, must be forwarded to the COR as soon as possible, but in no event later than seven (7) calendar days after the day the incident occurred.

At the end of each quarter of the calendar year, the

Contractor must submit the OSHA Form 300, Log of Work-

Related Injuries and Illnesses, to the COR. At the end of the calendar year, the Contractor must submit OSHA Form

300A, Summary of Work-Related Injuries and Illnesses, to the COR.

Arc Flash: The examination, adjustment, servicing or maintenance of energized switchboards, panel-boards, control panels, and motor control centers of over 50 volts is prohibited unless approved by the COR. Whenever possible, lockout/tag out procedures should be used to de-energize these systems prior to working on them. Work on energized electrical systems can be approved on a case-by-case basis by the COR or DESD as long as the Contractor evaluates the system in accordance with NFPA 70E to determine the flash protection boundary, its incident energy level, and the required personal protective equipment necessary to safely work on the equipment.

Confined Spaces: A list of confined spaces and permit-required confined spaces for DoS owned or operated buildings can be obtained from the COR. A list of confined spaces and permit-required confined spaces for GSA or landlord owned or operated buildings can be obtained from

GSA or the landlord. All work within confined spaces must be performed in accordance with OSHA requirements. In addition, a confined space entry permit must be completed by the contractor and submitted to DESD for approval prior to entering permit-required confined spaces.

EHS Kickoff Meeting: During initial contract start-up, the

Contractor shall meet with the COR for the purpose of reviewing the Contractor's plan for integrating safety and health provisions pertinent to the work to be performed under the contract. The Contractor shall be prepared to discuss, in detail, the measures he intends to take in order to control any unsafe or unhealthy conditions associated with the work. The Contractor's Project Manager an EHS Coordinator shall attend this meeting, and a representative from DESD may also attend. In addition, the

Contractor shall hold regularly scheduled safety and health meetings with their employees to review newly identified safety and health hazards.

Hazard Communication Program: The Contractor shall submit to the COR a written, site-specific Hazard Communication

Program that documents how the Contractor and

Subcontractors will comply with the OSHA Hazard

Communication standard. The program must include:

A list of job tasks that require the use of chemicals which identifies, for each job task, the chemical to be used, frequency of use, method of chemical application, and required personal protective equipment.

Description of how Hazard Communication training will be provided to all employees that use chemicals.

Description of how MSDSs for each chemical will be made readily available on-site and how chemical containers will be labeled.

Procedures for responding to accidental spills or releases of chemicals.

Hazardous Conditions: The Contractor is responsible for identifying any hazardous conditions they encounter, and immediately notifying the COR of the condition. Hazardous conditions include suspected hazardous materials, such as asbestos and lead-based paint, that need to be disturbed to perform the required work.

High Risk Activities: The Contractor is required to submit a detailed health and safety plan to the COR, and the plan must be approved by DESD prior to the work being conducted.

High-risk activities include, but are not limited to; crane lifts, locating utilities embedded in concrete slabs with radiology, and entering underground storage tanks.

Obstructions: No corridor, aisle, stairway, door, or exit shall be obstructed or used in such a manner as to encroach upon routes of ingress or egress utilized by the public or building occupant, or to present unsafe or unhealthy conditions to the public or building occupants.

Public Protection Requirements: The Contractor shall take all necessary precautions to prevent injury to the public, building occupants, or damage to the property of others.

For the purpose of this contract, the public or building occupants shall include all persons not employed by the

Contractor or a subcontractor working under the

Contractor’s direction. Whenever practicable, the work area shall be fenced barricaded, or otherwise blocked off from the public or building occupants to prevent entry into the work area. When the nature of the work prevents isolation of the work area and the public or building occupants may be in or pass through, under or over the work area, alternate precautions such as the posting of signs, the use of signal persons, and the erection of barricades or similar protection around particularly hazardous operations shall be used as appropriate.

Storage: Storing, positioning or using equipment, tools, materials, scraps, and trash in a manner likely to present a hazard to the public or building occupants by its accidental shifting, ignition, or other hazardous qualities is prohibited. Storage of combustible or flammable liquids shall be in accordance with the current edition of the

National Fire Protection Association Code for Flammable and

Combustible Materials (NFPA 30). Storage of chemicals and solvents used for routine housekeeping or maintenance activities must be stored in accordance with the guidance found in the applicable Material Safety Data Sheets (MSDS).

Access to and handling of these chemicals must be limited to those trained in their use.

Welding, Cutting, and Burning: DOS specifically requires permits for hot work, such as welding, cutting, and burning. These permits, GSA Form 1755, Welding, Cutting and Burning, shall be obtained each day by the Contractor whenever welding, cutting or any open flame work is performed. The GSA Forms must be approved and signed by the COR or the DOS Fire/ Safety Branch prior to any welding, cutting and burning taking place. The following requirements must be met:

Work areas shall be kept clear of combustibles within a

25 foot radius of any open flame work. Combustibles which cannot be removed shall be covered with flame-resistant blankets.

Compressed gas cylinders shall be secured in a vertical position at all times. Valve protection caps shall be in place whenever cylinders are moved or stored.

Appropriate fire extinguishers shall be maintained at welding and cutting operations.

A designated fire watch shall sign and return the permit.

The fire watch shall be on duty during all hot work and for a sufficient time afterwards to ensure no possibility of fire exists.

TRAINING AND QUALIFICATIONS

The Contractor must ensure that all personnel performing work under this contract are qualified and/or certified to perform the work. In addition to the technical skills and abilities required in the performance of this contract, the Contractor must demonstrate an effective EHS training program for all staff. As part of the bid process, the Contractor must provide an overview of their training program, including specific details of the types of qualifications or training required for specific job functions or tasks. The Pre-

Contract submittal should provide specific qualification or training requirements for:

The EHS Coordinator and other key EHS staff that will be responsible for program implementation and oversight.

Managers and supervisors with respect to their EHS leadership responsibilities.

General training for all staff including a review of the site’s emergency procedures, a review of the site’s waste minimization and recycling programs, and training that enables employees to recognize hazardous conditions and the signs, symptoms of workplace related injuries and illnesses (including reporting procedures for these conditions)

Specific training for job functions or tasks that are based on a job hazard analysis to ensure each employee understands the hazards and control measures associated with his/her specific job

( i.e. forklift training, lockout/tag out, green purchasing requirements, spill prevention control and countermeasure, etc.)

The training program must include a method for assessing employee comprehension and training effectiveness. And provide documentation of all training that individual employees receive.

Bid submittal must include an overview of how the company’s EHS training program is managed and include examples of written program materials for the Control of Hazardous Energy (Lockout/tag out);

Hazard Communication; and Personal Protective Equipment.

Within thirty days of award, the successful bidder must submit copies of their job hazard analysis and specific EHS training requirements for each job classification.

PROGRAM EVALUATION

An effective management program includes a review process to ensure the goals and objectives of the program are being met. Offerrors must provide a detailed written description of the internal auditing, evaluation, and management review of the EHS management program to evaluate EHS regulatory compliance and program effectiveness. The

Offerror must also discuss their internal procedures for reporting potential EHS risks and opportunities for improvement, evaluating corrective actions or solutions, and tracking the corrective actions or solutions.

On a periodic basis, the COR, in conjunction with DESD, may perform a contract compliance review of the Contractor’s operations that include the EHS elements identified in this contract. This review typically includes workplace observation, review of written program materials and records, and employee interviews. The contractor will be provided with a summary of this review and be permitted to provide feedback and to implement corrective actions.

The Government reserves the right to inspect or audit the Contractor’s

EHS management program and associated records to determine if the program is effective and achieving desired goals.