T2658 - Appendix B HASP Minimum Requirements~1.doc
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- 24DPP00939
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- New Jersey
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This document details the minimum health, safety, and emergency response requirements for a non-emergency remedial action services contract between the New Jersey Department of Environmental Protection (NJDEP) and a potential contractor. The contract, titled "T2658 - Non-Emergency Remedial Action Services (NERAS)", covers hazardous waste site work within the jurisdictions of Mercer County and Trenton City, New Jersey.
The document outlines the programmatic health and safety plan (HASP) requirements, including organizational responsibilities, risk/hazard analysis, employee training, personal protective equipment, medical surveillance, air monitoring, site control, decontamination procedures, contingency planning, and specialized operations such as confined space entry and excavation. It also specifies the required contents of the site-specific E-Z HASP that must be submitted and approved by the NJDEP Office of Site Safety and Health prior to commencing any site work. The contract does not have a specified term or renewal options noted in the provided materials.
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T2658 - NJDEP Non-Emergency Remedial Action Services
Appendix B – Minimum Specifications for Programmatic HASP and E-Z- HASP
PROGRAMMATIC HEALTH, SAFETY NON-EMERGENCY RESPONSE MINIMUM REQUIREMENTS (2009)
INDEX
1.0
GENERAL
2.0
REQUIREMENTS
1.0
GENERAL
1.1
DESCRIPTION OF SCOPE
A.
Hazardous Waste Site
Prior to being engaged for any work to be performed at any hazardous waste site as defined within the meaning of 29 CFR 1910.120, the Contractor shall submit a Health and Safety Plan to the New Jersey Department of Environmental Protection (NJDEP). The HASP must receive NJDEP approval before a notice to proceed with any site work will be granted.
B.
Minimum Requirements
This document describes the minimum safety, health, and emergency response requirements for remedial activities at the site. The responsibility for development, implementation, and enforcement of the HASP lies with the Contractor and its health and safety personnel. The HASP developed by the Contractor shall include programs for accident prevention, personnel protection, medical surveillance, training, special and permit operations, excavation and trenching, spill containment, emergency responses and contingency planning, and air monitoring.
C.
Compliance and Termination
Safety and health requirements shall conform to 29 CFR 1910.120, other federal and state codes and statutes as identified by the text of this document. Controls and procedures specified herein and by the HASP may be terminated only when a Certified Industrial Hygienist, or other qualified person, determines that hazards have been eliminated. Such termination shall be effective only if approved in writing by the NJDEP.
D. The Programmatic and Site Specific HASPs are in addition to, and do not preclude, the Contractor from following any relevant State or Federal statutes, or Executive Orders related to employee safety.
1.2
SITE DESCRIPTION
Specific Location
The site's description includes: Street address, Lot #, Block # and all other locations where work is to be conducted for this contract.
Supplements and Additions
The site may be described in supplementary sections. Additional details provided should be referenced and presented in listed subsections.
Site History
A short history of the site prior to the contracted operations should be presented, indicating industrial/hazardous activities.
1.3
SUBMITTALS
Contractor Submissions to State Department of Environmental Protection
1.
The Contractor shall submit three (3) copies of a HASP to the NJDEP and one (1) copy to the specified lead Contract Manager of the department for this contract.
2.
The Contractor shall submit to the department four- (4) copies of analytical results from any area or personnel samples that are specified in the subsections.
3.
The Contractor shall submit to the department on a weekly schedule, four (4) copies of the daily air monitoring log as specified by the NJDEP Office of Site Safety and Health (OSSH).
Health and Safety Plan (HASP) Approval
Review and approval of the HASP shall be the responsibility of the OSSH.
The OSSH shall provide back to the Contractor, through the NJDEP site/construction manager a written evaluation of the submitted HASP. Evaluation of the HASP shall be performed by comparison to the minimum requirements presented in this document and applicable state and federal statutes.
2.0
MINIMUM REQUIREMENS
2.1
ORGANIZATIONAL RESPONSIBILITIES
Key Personnel and Organizational Chart.
The Contractor must provide, at a minimum, an organizational chart and resumes of key personnel involved in all phases of the operations on site. Also, the Contractor must submit the names of other personnel needed for hazardous waste site operations and emergency response, indicating their functions and responsibilities. This chart must include Senior‑Level Management, Project Manager, Health and Safety Officer (HSO), Field Supervisor, and on-site Foreman Personnel, at a minimum.
Site Health and Safety Officer (HSO)
The Contractor must utilize a qualified individual (e.g., a certified industrial hygienist, safety engineer, certified hazardous materials manager, etc.) to function as the Site HSO for the project. That individual must be responsible to the Contractor and have the authority and knowledge necessary to implement the site HASP and verify compliance with applicable safety and health requirements.
At a minimum, the HSO shall have the following responsibilities and authority to perform the following functions:
a. Be present at all times during site operations.
b. Have the authority to enforce the HASP and stop operations if safety and health of personnel at the site, or surrounding population, be jeopardized.
c. Effect evacuation of the site or work area and notify appropriate response agencies and authorities if necessary.
d. Evaluate monitoring data to make field decisions regarding safety and health.
2. If an alternate HSO is named, he/she must meet the same requirements as the primary HSO.
The HSO must meet the following minimum educational and experience qualifications in matters of health and safety:
1. Possess a sound working knowledge of State and Federal occupational safety and health regulations.
Have formal professional development training in occupational safety and health. Initial forty (40) hour (or twenty-four - 24 hour) HAZWOPER, or any other basic training necessary for general work eligibility, will not satisfy this requirement.
3. Satisfy either 3a or 3b.
a. Have a minimum of five (5) year’s experience in the environmental and health and safety services field, chemical industry, or chemical waste disposal industry, more than 50% of which must be in the area of industrial hygiene and/or environmental safety related to the site operations; or
b. Have a bachelor of science degree in biology, chemistry, engineering, industrial hygiene, or other related natural or physical science, and one (1) years experience in the environmental and health and safety services field, chemical industry, or chemical waste disposal industry, more than 50% of which must be in the area of industrial hygiene and/or environmental safety related to the site operations.
NOTE: A graduate degree in occupational safety and health can be substituted for 3a or 3b.
2.2
RISK OR HAZARD ANALYSIS
Health and Safety Evaluation
The Contractor shall perform and provide a hazard assessment for each location and the tasks to be performed.
Best Information available
The assessment shall be based upon the best information available regarding the contaminants and conditions present at the site as well as the practices, tools and other equipment to be applied in the operation and shall include but not be limited to the following:
A preliminary evaluation of the site's characteristics performed prior to the initial site survey.
An evaluation of the known, or suspected, contaminants and conditions that may pose inhalation, skin absorption/contact, exposure or ingestion hazards.
Material Safety Data Sheets (MSDS) shall be provided on site for any chemicals known to be present which workers may be exposed to during site normal operations or in a foreseeable emergency.
4.
An evaluation of known or potential safety hazards and appropriate safety equipment associated with each task (i.e. personal flotation devices when working on or near water).
5.
An overview of the following information:
a.
Size and location of the site.
b.
Description of the operation and tasks to be performed.
c.
Approximate duration of each operation and task.
d.
Site topography, accessibility and special features (e.g., structures, tanks) e.
Known or suspected pathways of contaminant dispersion pertinent to the operations and tasks performed.
f.
Safety and health hazards expected on the site.
g.
Status and capabilities of emergency response teams that shall provide assistance during site emergencies, including those providing medical treatment and transport of any contaminated injured persons.
2.3
EMPLOYEE TRAINING
Training Requirements for On‑Site Personnel
Pursuant to 29 CFR 1910.120, et al, all Contractor and subcontractor employees for on‑site activities must have met one of the following requirements prior to the start of operations at the site:
General site workers (such as equipment operators, general laborers, and supervisory personnel) engaged in hazardous substance removal, or other activities that expose or potentially expose workers to hazardous substances and health hazards, shall receive a minimum of forty (40) hours of instruction off the site, and a minimum of three (3) days actual field experience under the direct supervision of a trained, experienced supervisor.
Workers on site only occasionally for a specific limited task (such as, but not limited to, groundwater monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of twenty-four (24) hours of instruction off the site, and a minimum of one (1) day actual field experience under the direct supervision of a trained, experienced supervisor.
Workers regularly on site, who work in areas that have been monitored and are fully characterized indicating that exposures are under permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization indicates that there are no health hazards or the possibility of an emergency developing, shall receive a minimum of twenty-four (24) hours of instruction off the site and a minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor.
Workers with twenty-four (24) hours of training who are covered by paragraphs b. and c. of this section, and who become general site workers or who are required to wear respirators, shall have the additional sixteen (16) hours and two (2) days of training necessary to total the training specified in paragraph a.
In addition, an annual eight (8) hour minimum refresher course after the initial training shall be provided to all field (site) personnel in order to continue on site employment eligibility.
On‑site management and supervisors directly responsible for or who supervise employees engaged in site operations, including the on‑site HSO, shall have also received eight (8) hours additional training in managing such site operations prior to the start of site activities as stipulated in 29 CFR 1910.120.
Employees who have been designated as responsible for responding to on‑site emergencies shall have received additional training in how to respond to such expected emergencies prior to the start of site operations as stipulated in 29 CFR 1910.120.
Employees who have not received the required training prior to the start of site operations are not to engage in site operations until such training has been completed.
Employee Training Program
The Contractor shall include in the HASP a summary of the hazardous materials safety and health training program and a list of elements and topics covered.
Program Certification
The Contractor shall provide written certification statement of completed training and/or acquired experience for all employees designated to engage in on‑site activities. Such certification shall be endorsed by a member of top‑level management, a corporate officer, or the health and safety program manager and shall be incorporated into the HASP.
D.
Site Specific Training and Pre-entry Briefings
The Contractor shall provide site specific training and perform daily safety briefings that will provide an awareness of planned operations, the site‑specific HASP, the form and warning properties of potential hazards, work zones, locations of emergency/safety equipment, local emergency response procedures and any changes in site characteristics, levels of protection, communications, decontamination procedures, emergency facilities and signals, and evacuation procedures.
2.4
PERSONNEL PROTECTION
Engineering and Work Practice Controls.
The Contractor must consider the need to apply engineering and/or work practice controls as a means of protecting personnel in the performance of site‑specific tasks. When practicable, engineering controls shall be implemented to reduce and maintain employee exposures to or below safe levels for those tasks demonstrating known or suspected hazards. Work practice controls shall next be applied when engineering controls are impractical and shall be incorporated as site‑specific standard operating procedures (SOPs) for personnel precautions and routine operations.
Personnel Protective Equipment (PPE) and Levels of Protection
The Contractor shall use personnel protective equipment (PPE) only when engineering and/or work practice controls have been deemed impractical or insufficient to protect employees during site operations.
The Contractor shall select PPE based on an evaluation of performance characteristics, site‑specific tasks, and known or suspected hazards and shall assemble the PPE into Levels of Protection (LOP) or ensembles appropriate for the site.
The Contractor shall include in the HASP a list of components for each protective ensemble, the LOP selected for each task, the rationale for each task‑specific selection, and any contaminant action levels to be followed in LOP decision making. This information can be presented in a block‑type chart with specific references to fabric, Level of Protection, permeation, etc., in a text.
These specific tasks requiring identification of protective clothing ensembles shall include but not be limited to:
Existing Debris and Waste Removal.
Recovery, Injection, and Monitoring Well Construction.
Excavation.
Contaminated Soil Removal.
Sampling and Monitoring.
Dewatering.
Erosion and Sediment Control.
h.
Operating specialized equipment, containers.
i.
Confined Space and Hazardous Area Entry.
If the Contractor's HASP provides for respiratory protection, the Contractor shall include a description of the respiratory protection program and the method of respirator fit testing employed.
The Contractor shall use only NIOSH/DHSS approved respiratory protective equipment. Any other PPE selected shall be in conformance with appropriate ANSI standards for that equipment.
6.
The Contractor shall establish a PPE program addressing the following elements:
Site hazards.
PPE selection.
PPE use and limitations.
Duration of site operations.
PPE maintenance and storage.
PPE decontamination and NJDEP approved disposal.
PPE training and proper fit.
Donning and doffing procedures.
PPE inspection prior to, during and after use.
j.
Evaluation of program effectiveness.
l.
Heat stress and temperature limitations.
2.5
MEDICAL SURVEILLANCE
Medical Surveillance Program
The Contractor shall establish, implement and maintain a medical surveillance program (MSP) for employees engaged in on‑site operations, if any of the following 29 CFR 1910.120(b) criteria are met:
All employees who are, or may be, exposed to hazardous substances, or health hazards, at or above the permissible exposure limits, or if there is no permissible exposure limit, above the published exposure levels for these substances, without regard to the use of respirators, for thirty (30) days or more per year.
All employees who wear a respirator for thirty (30)days or more a year or as required by 29 CFR 1910.134/139.
c. All employees who are injured due to overexposure from an emergency incident involving hazardous substances or health hazards.
d. Members of HAZMAT teams
The MSP program shall include physical examinations administered or supervised by a board‑certified physician knowledgeable in internal or occupational medicine. The Contractor shall include the name and business address of the administering physician in the HASP.
The Contractor shall include a written description of the components of both the MSP program and the physical examination in the HASP and whether the examination is administered or supervised by the physician.
The Contractor shall address the need for personnel exposure monitoring and post-exposure medical screening in the HASP and include a description of those provisions.
The Contractor shall provide to the employee, the physician’s written opinion. The written opinion shall contain the attending physician’s opinion as whether the employee has any detectable medical condition which would place the employee at increased risk of material impairment of the employee’s health from work in hazardous waste operations or emergency response, or from respirator use.
The physician’s written opinion shall contain the physician’s recommended limitations upon the employee’s assigned work and the results of the medical examination and tests
7. The Contractor shall provide a statement that the employee has been informed by the physician of the results of the medical examination, and any medical conditions, which require further examination or treatment.
8.
The physician’s written opinion obtained by the employer shall not reveal specific findings or diagnoses unrelated to occupational exposures.
Medical Records Retention
The Contractor shall retain all medical records and personnel exposure monitoring data for 30 years as described in Subpart C of 29 CFR 1910.120.
Fitness Certification
The Contractor shall provide written certification of the medical fitness for work of all employees designated to engage in on‑site operations prior to the start of those operations. A senior officer of the corporation’s management shall endorse such certification and the endorsement shall be incorporated into the site HASP.
Heat and Cold Stress Monitoring
As dictated by seasonal conditions, the Contractor shall implement an employee heat, and/or, cold stress-monitoring program during site operations and shall incorporate the program into the site HASP. The program shall include employee awareness of the signs and symptoms of heat and/or cold stress, preventive measures, and employee and/or environmental parameters that will be measured. The Contractor shall maintain a daily heat and/or cold stress log on all employees wearing protective ensembles on‑site and it shall describe the log in the site HASP.
2.6
AIR SURVEILLANCE
Site Specific Monitoring
The Contractor shall establish and implement a site‑specific air-monitoring program to identify areas of elevated airborne contaminant concentrations and to determine the level of the concentrations relative to background. The Contractor shall provide the personnel, instruments, and materials necessary to perform such air monitoring and identify the individual responsible for administering the program. The program shall be included in the HASP.
The Contractor must incorporate the following information into the air-monitoring program:
a. Type, make, and model of instrument(s) selected for use.
b. All instrument settings for each instrument used.
c. Method of instrument calibration, including calibrant and sample calibration data sheet.
d. Method of field checks, including field check materials and record of checks.
e. Manner and frequency of calibration and pre and post (or greater) field checks.
The Contractor must present the frequency of air measurements and the tasks or locations to be monitored.
Area and Personnel Air Sampling
The Contractor shall examine and report to the NJDEP's satisfaction the need, or lack thereof, to develop and implement area and personnel air sampling programs during the project, based upon adequate initial Area and Personnel Air Sampling episodes, and shall include any resultant air sampling program in the site HASP.
Special considerations shall be given to intrusive or high‑risk tasks and the potential for exposure to those performing such tasks.
The Contractor shall provide all necessary sampling devices, pumps, collection media, and support equipment to perform the sampling per the program. The sampling devices and pumps must bear all approvals necessary for use in combustible or flammable atmospheres.
The sampling devices, pumps, collection media, and any necessary support equipment shall be appropriately assembled into a sampling train, and each resultant sampling train shall be flow calibrated as a complete system before and after each day's use against a primary standard.
The Contractor shall maintain a daily sampling record as part of the air-sampling program. The record must include, as a minimum, the following:
Collection date.
Sample identification number.
Location and/or task monitored.
Wind speed and direction during each sample collection period.
Duration of each sample collected, including the start and stop times of each sample.
Ambient temperature and humidity of sampling period.
Pre‑ and post sampling train flow rate checks.
Instrument readings, calibration and field checks.
Any pertinent comments.
The laboratory selected for sample analysis must be accredited by the AIHA for the analysis required. Sampling and analytical methods of first NIOSH, then OSHA, must be used preferentially when such methods are available for the samples collected and all appropriate QA and QC provisions regarding sample collection, transport, and holding times must be followed. Sampling and health and safety protocols are presented in the NJDEP's most current Field Sampling Procedures Manual, (August 2005).
Records Retention and Data Reporting
1. The Contractor shall retain all personnel exposure sampling results and monitoring data in accordance with the requirements set forth in OSHA, Subpart C of 29 CFR 1910.120. The Contractor shall follow all other pertinent provisions of that regulation.
2. The Contractor shall submit, in writing, the analytical results from any area and personnel samples collected within thirty (30) working days of the collection of each sample. Sample flow rates in liters per minute (lpm) and sampling periods in minutes for each sample collected must be reported with the analytical results. Sample locations or tasks and identification numbers shall also be reported.
3. The Contractor shall maintain a daily air-monitoring log and include, as a minimum, the following information:
a. Monitoring date.
b. Location and/or task monitored.
c. Wind speed, direction, ambient temperature, and humidity.
d. Instruments used including make and model and all instrument settings.
e. Instrument readings.
f. Pertinent comments or information.
g. Results of instrument calibration checks, including date and time of each check, the calibration agent used, and its concentration, for each instrument employed.
4. The Contractor shall report verbally all data resulting from daily air monitoring to the State Contract Manager, at a minimum, at the end of the work period. If at any time the instrumentation indicates an adverse change in conditions, the HSO must notify the State Contract Manager immediately and follow up this reporting in writing by the close of business on that day.
5. The Contractor shall furnish copies of the daily air-monitoring log to the State Contract Manager at a minimum, weekly, unless otherwise noted or arranged.
2.7
SITE CONTROL
Routine Requirements
For ongoing operations, the Contractor and/or its designee will be required to meet with the on‑site State Contract Manager, when present, prior to the start of the day's activities to prepare all the necessary paperwork and outline the day's activities. The Contractor shall also meet at the completion of the day's activities to discuss the work performed.
Control of Work Zones
The Contractor shall be responsible for conducting operations at the site in such a controlled fashion as to reduce the possibility of contact with any contaminants present and to prevent the removal of contaminants by personnel or equipment leaving the site. The Contractor shall delineate work zones in which specific operations or tasks will occur and shall institute specific site entry and decontamination procedures at designated control points.
Three (3) work zones that shall be established to perform work are an exclusion (contaminated) zone, a contamination reduction zone and a support (clean) zone. A map, or diagram, showing the specific work zones and a description of the site control plan shall be included in the HASP. The work zone boundaries shall be revised as the work of removing hazardous materials proceeds, so as to reflect the reduced area containing hazardous materials. The revised map or diagram shall be inserted in the HASP and provided to the State Contract Manager upon adoption of each revision. The Contractor shall include any SOPs pertaining to site control in the HASP and shall incorporate plans for routine and emergency communications appropriate for the site and project.
The Contractor shall keep a daily site control log. The log shall include:
Personnel visiting the site.
Affiliation.
Date.
Arrival time.
Departure time.
Purpose of visit and locations visited.
The Contractor shall provide the NJDEP lead Contract Manager with a list of all Contractor and subcontractor personnel who are authorized to enter the site prior to the start of operations, updating the list as necessary. Authorized NJDEP personnel shall have unlimited access to the site. The Contractor shall be responsible to exclude all unauthorized entrants from the site.
2.8
DECONTAMINATION
Personnel and Equipment Requirements
All contaminated personnel and equipment exiting the exclusion zone must be decontaminated prior to entering the support zone. This decontamination must be performed in order to prevent contamination from being transferred into clean areas and contaminating or exposing unprotected personnel.
The Contractor shall develop and implement personnel and equipment decontamination procedures appropriate for the site and shall include those procedures into the site HASP. The procedures shall include the necessary equipment and number of steps to achieve the objective, provisions for any personnel protection, and a diagram outlining the steps or stations in the procedures.
The procedures must ensure adequate containment and removal of any decontamination solutions and spent disposable protective apparel.
Provisions shall be made to facilitate personal hygiene at breaks and following daily operations. Where decontamination procedures indicate shower usage and changing rooms away from the exclusion zone, they shall meet the requirements of 29 CFR 1910.141 and 1926.51.
2.9 SITE STANDARD OPERATING PROCEDURES
The Contractor shall be responsible for developing and implementing all necessary SOPs for safe and healthful site operations. Such SOPs shall be incorporated into the site HASP. A copy of these SOPs and the HASP are to be on site at all times.
2.10 CONTINGENCY PLANNING
Emergency Response Plan (ERP).
The Contractor shall develop and implement an Emergency Response Plan, (ERP) to handle anticipated on‑site emergencies prior to the start of site operations.
Plan Up‑Dates
The ERP shall be incorporated into the site HASP as a separate section of that document and shall be periodically reviewed and, as necessary, amended to keep it current with new or changing site conditions or information.
The ERP shall address, as a minimum, the following:
Preplanning of site operations to prevent emergencies.
Personnel roles and lines of authority.
Key personnel at the site authorized and responsible for implementing the plan.
Emergency recognition and control measures.
Evacuation routes and procedures, and the frequency of emergency drills.
Safe distances and places of refuge.
Emergency security and site control measures.
Decontamination measures not previously listed in the HASP and specific for all anticipated emergencies.
Emergency medical treatment and first aid.
j.
Emergency alerting and response procedures.
k.
Site communications.
l.
Site diagrams showing general layout, work zones, and prevailing weather conditions.
m.
Procedures for reporting incidents to pertinent local, state, and Federal agencies.
n.
A list of emergency telephone contacts including the name, location, telephone number, written directions and a route map to the nearest medical facility that will provide emergency medical services.
o.
Measures to review and follow up on site responses.
p.
Emergency and personal protective equipment kept at the site for emergencies, with an equipment list and a drawing indicating their on site location.
Prior to start up of site operations, the Contractor shall attend any and all meetings necessary with local officials and/or those responsible for local emergency management and public safety for the purpose of coordinating the site specific ERP with any emergency response efforts that would be performed by such agencies. These agencies include but are not limited to:
Fire.
Ambulance.
Police.
Local/County health officials.
Special First Aid/CPR Training
The Contractor shall ensure that at least one person holding up‑to‑date certifications (American Red Cross or equivalent) in basic first aid and CPR is present at the site during all site operations. A photocopy of the current certifications must be included in the HASP.
Verification of Medical Facility Preparedness
The Contractor shall contact the local medical facility selected for inclusion into the ERP to ensure that said facility is willing and is capable of providing that medical support necessary to satisfy those anticipated hazards and emergencies detailed in the ERP. Material Safety Data Sheets (MSDS), product information or any technical information on hazard, exposure and treatment of anticipated/known hazards should be provided by the Contractor to the medical facility. Written verification of such contact and agreement of medical services must be detailed in the ERP to include the name and title of individual contacted and shall be provided to the NJDEP prior to start of site operations.
E.
Accident and Exposure Reports
The Contractor shall notify the State Contract Manager of all on‑site accidents at the time of occurrence and follow up in writing within twenty-four (24) hours. This notification shall include, but not be limited to, the date, time and identity of individual(s) involved in the accident, the nature of the accident, the actions taken to treat the victim(s), and the steps taken to prevent recurrence.
2. The Contractor shall notify the State Contract Manager of all person(s) exposed at the time of occurrence and follow up in writing within twenty-four (24) hours. This notification shall include, but not be limited to, the date, time, and identity of individual(s) involved in the exposure, the nature of the exposure episode, what the individual(s) were exposed to, the personnel protective equipment worn during the exposure, and the steps taken to prevent recurrence.
3. The Contractor shall notify the NJDEP immediately of any incident/accident that results in death or severe injury to personnel, of any fire or explosion or any incident that results in public disruption, media attention or closure of a roadway. Notification of such events shall be addressed to called into the NJDEP Communications Center (DEP HOTLINE) 1‑877‑297‑6337 (1‑877‑WARNDEP).
2.11
CONFINED SPACE OPERATIONS
If no confined space entry is to be made, then a statement indicating such is sufficient for this section, however, all confined spaces must be identified in the HASP.
Standard Operating Procedures for Confined Spaces
Should site operations include activities within confined spaces, the Contractor shall develop and implement a confined space entry program and SOPs and shall incorporate them into the HASP pursuant to 29 CFR 1910.146. If the confined space entry meets the OSHA definition of a Permit Required Confined Space Entry, then a section addressing such entries shall be included in the HASP.
Entry Permit System
The Contractor shall develop and implement an Entry Permit System to ensure that the following are addressed and complied with:
a. Identification of all confined spaces to all employees.
b. Identification of hazards in the confined space.
c. Training program.
d. A system of monitoring for atmospheric hazards.
e. A system of calibration of monitoring equipment.
f. A system of barricades, to prevent unauthorized entry.
g. A system of identifying authorized entrants, attendants, rescuers and those authorized to sign the entry permit.
h. A procedure for emergency evacuation.
i. Emergency rescue procedures.
j. Procedures to test the program to ensure effectiveness.
2. Pre-entry briefings shall be held prior to initiating any confined space entries and at other times as necessary to ensure that employees are aware of the HASP provisions governing such activities and that they are being followed. The completed permit shall be made available at the time of entry to all authorized entrants, by posting it at the point of entry or by any other equally effective means, for assurance that the pre-entry preparations have been completed.
Inspection and Effectiveness of SOP Verification
Inspections shall be conducted by the HSO, or, in the absence of that individual, another qualified individual acting on behalf of the HSO, as necessary to determine the effectiveness of the confined space SOP with regard to those confined spaces identified on site. The Contractor shall correct any deficiencies in the SOP.
Atmospheric Monitoring for Safe Entry
The Contractor shall ensure that the HSO, or, in the absence of that individual, another qualified individual acting on behalf of the HSO, test the atmosphere of the confined space prior to entry. Atmospheric testing will continue during entry to ensure that all measures necessary to protect the health and safety of employees entering have been taken and are working properly. Monitoring shall be appropriate for the contaminant(s) that are known or suspected of being present in the space.
E.
Emergency Equipment and Rescue Services
The Contractor shall provide appropriate protective and entry equipment for all entrant personnel necessary for the Permit Required entry. On site rescue personnel must be present or off site rescue must be able to respond to the site within 3 minutes of notification. Equipment necessary for a rescue must be identified and present at the point of entry.
F.
Training of Entrants, Attendants and Rescuers
The Contractor shall comply with the Federal OSHA training requirements for all personnel involved in confined space entry. A training program must be administered to all personnel involved in confined space entry before entrance can be initiated. Rescue teams shall practice at least annually at the confined space or at Contract Manager openings having the same size, configuration and accessibility as the confined space from which an actual rescue would be performed. A record of training and authorized personnel shall be kept on-site and listed in the HASP.
2.12
SPILL CONTAINMENT
Containment Program
The Contractor shall establish and implement a written spill containment program to handle the possibility of a spill or leakage of drummed or containerized hazardous materials involving any of the following activities:
Transfer.
Transport.
Disposal.
Excavation.
The Contractor shall identify the following on site and off site personnel and equipment or services necessary to isolate, contain and mitigate the spill:
Clean up Contractor or personnel.
Estimate of response time of off site contractors.
Spill containment procedures (Diking, Overpack, etc.).
Special safety precautions (fire, corrosive, radioactivity, etc.).
Equipment and supplies on hand at site or readily available to respond to contain and clean up the spill.
2.13 SPECIAL AND PERMIT OPERATIONS
Excavations and Trenching
If no trenching or excavation is to be performed on site during site operations, then a statement indicating such is sufficient for this section.
All excavation work shall comply with 29 CFR 1926, Subpart P and other state and federal regulations governing excavations and trenching. The need to perform any excavations, or trenching, as part of the site operations must be described in the HASP.
The methods of preparing the trench, or excavation, must be detailed to include descriptions of sloping, shoring and guarding.
Proper spacing of equipment, use of barriers, means of exit, placing of machinery and spoils must be observed.
Personnel working around and in trenches and excavations must be trained in such operations to assure knowledge of hazards, safe operations and procedures to be followed in the event of an emergency.
Avoidance of overhead electric lines, underground utilities and storage structures, and service passageways must be addressed by including drawings, measurements and descriptions in the HASP. All pertinent sections of 29 CFR 1910, Subpart S and 29 CFR 1926, Subpart K for electrical safety must be complied with and identified in the HASP.
7. Under Ground Utilities: (gas, water, sewer, cable, phone and electric or process related) As per N.J.S.A. 48:2-73 and in compliance with OSHA Regulation 1926.651, no ground intrusive work is to commence without a current under ground utility mark out. The One-Call system (1 800-272-1000) or (811) must be notified not less than three (3) full business days before digging. Other means of locating underground utilities must be identified for utilities not covered by One-Call system. The One-Call Markout Ticket Confirmation Number(s) will be recorded in the HASP, or attached to the HASP that is kept on site.
B. Traffic Control
1. All traffic signage shall conform to the “Manual for Uniform Traffic Control Devices”.
2. The New Jersey Department of Transportation (DOT) shall be notified prior to any work to be conducted on any highway, road, right of way, or property under their jurisdiction.
3. Local, or County, police authorities shall be notified prior to work on or adjacent to any local road.
4. Traffic safety PPE shall conform to applicable ANSI regulations (ANSI 107-1999).
Hot Work
1. If no hot work is to be performed on site, then a statement indicating such is sufficient for this section.
2. The performance of Hot Work, such as welding, cutting, etc., during site operations must be addressed in the HASP. A Hot Work "Permit" procedure must be included in the HASP if hot work is performed and must comply with the sections of OSHA 1910.119(k), OSHA 1910.146 and OSHA 1926.64 (k) et al as they apply to these operations.
3. All hot work procedures should be outlined and shall comply with both state and local fire codes as well as with OSHA regulations.
4. All electrical supply wiring and distribution shall comply with the local and National Electric Codes as well as any state and OSHA 1926.400 Subpart K, governing such installations.
5. Proper utilization and storage of flammable cutting gases and other compressed gases shall comply with the requirements of OSHA 1926.350 et al. All gas cylinders shall be secured from falling or being damaged.
INDEX OF HEALTH AND SAFETY PLAN SECTIONS
Citations from NJ State codes/regulations, 29 CFR 1910.120 and other federal regulations as well as OSSH requirements
SECTION SUBJECT
CITATION:
NUMBER NAME
FEDERAL/NJDEP
1.1
Scope of HASP
29 CFR 1910.120
1.2
Site Description
NJDEP Contract
1.3
Submittals
NJDEP Contract
2.1
Key Personnel
(b) (1) (ii) (A)
2.2
Hazard Assessment
(b) (4) (ii) (A)
2.3
Employee Training
(b) (4) (ii) (B)
2.4
Personnel Protection
(b) (4) (ii) (C)
2.5
Medical Surveillance
(b) (4) (ii) (D)
2.6
Air Surveillance
(b) (4) (ii) (E)
2.7
Site Control
(b) (4) (ii) (F)
2.8
Decontamination
(b) (4) (ii) (G)
2.9
Site Standard
Operating Procedures
(b) (1) (ii) (F) 2.10
Contingency Planning
(b) (4) (ii) (H)
2.11
Confined Space Oper.
NJSA 34:1‑20 et seq
(b) (4) (ii) (I) 2.12
Spill Containment
(b) (4) (ii) (J)
2.13
Special/Permit Oper.
1910.11;
1926.64;
1926.35;
1910.146
E-Z HASP FOR
(SITE NAME)
FOR NON-EMERGENCY ENGAGEMENT
INTRODUCTION
This site health and safety plan (E-Z HASP) provides site specific guidelines and information for on-site activities. Prior to submittal of this E-Z HASP, a Health and Safety Program (Generic or Programmatic HASP) must be submitted for approval by the Office of Site Safety and Health (OSSH), Division of Publicly Funded Site Remediation, New Jersey Department of Environmental Protection. The Programmatic HASP, used in conjunction with the E-Z HASP, shall comply with 29 CFR 1910.120 (b)(1) and the New Jersey Department of Environmental Protection’s (DEP) Minimum Requirements for contractors conducting work at hazardous waste sites and other related activities. Copies of both this E-Z HASP, and the Programmatic HASP, must be available at the site for the duration of any activities being conducted.
SECTION 1:
GENERAL SITE INFORMATION
Site name:
Location (street address)
Block(s):
Lot(s):
City/Town:
County:
Site Description: (type of operation(s), past use, size/area, known and potential contaminants, previous investigation/remedial activities, media impacted etc…)
Starting Date of Proposed Work
Anticipated Duration of Project
SECTION 2:
KEY PERSONNEL
The following is a list of the names and job functions of all site personnel anticipated to be on site:
Project Manager:
Project Supervisor: (if different from Manager)
On-Site Health and Safety Officer:
Corporate Safety Officer:
Project Coordinator (DEP):
Others:
Responsibilities:
Project Manager:
Project Supervisor:
On-Site Health and Safety Officer:
Corporate Health and Safety Officer:
SECTION 3:
SITE OPERATIONS
Tasks to be performed: (check all that apply)
( ) Building demolition
( ) Underground tank removal
( ) Capping/paving
( ) Hydropunch or Geoprobe
( ) Monitoring well installation
( ) Sample collection (waste, soil, surface/ground water, etc.)
( ) Excavation/Trenching
( ) Spill cleanup
( ) Waste load out for disposal
( ) Other(s)_________________________________
Work Zone Map
Attached is a site map lay out grid indicating the locations of the work zones, staging areas, exclusion zones, decontamination area, etc.
A B C D E F G H I J
Include scale (suggest 1” = _______ ft)
SECTION 4:
SAFETY and HEALTH RISK / SITE HAZARDS Contaminant/Waste Characteristics:
General Forms: ________solid _____liquid ________sludge _____Gas/vapor
Contaminant/Waste classes:
___ corrosive ___radioactive ___reactive ___ toxic ___ignitable __volatile
___unknown ___other
Known or suspected contaminant/wastes present:
List contaminants and provide MSDS as attachment to HASP.
Substances Concentration and Media Primary Exposure Hazard.
Known:
Potential:
Safety hazards:
X-mark off items for site hazards
___ heavy equipment
___ excessive noise
___ hoses, tools, etc. lying on ground ( slip, trip, fall )
___ surface debris (broken glass, sharp objects )
___ wet or slippery surfaces
___ subsurface/buried objects
___ unstable building structures
___ excavations
___ above ground or underground utilities**
___ stacked drums
___ confined spaces (Confined Space Entry Program required if applicable)
___ motor vehicle traffic
___ poison ivy/oak
___ ticks/other insects
___ infectious waste
___ darkness
___ Other safety hazards: (animals, high crime area etc..)
**Under Ground Utilities: (gas, water, sewer, cable, phone and electric or process related) As per N.J.S.A. 48:2-73 and in compliance with OSHA Regulation 1926.651, no ground intrusive work is to commence without a current under ground utility mark out. The One-Call system (1 800-727-1000) must be notified not less than three (3) full business days before digging. Additional mark outs may be needed to be performed for utilities not covered by One-Call system.
The One Call Markout Ticket Confirmation Number(s) will be recorded in the HASP, or attached to the HASP that is kept on site.
New Jersey One Call System Confirmation Number: (attach ticket to HASP kept at site) Hazard Prevention: (procedures, steps to be taken, to address all identified site hazards) Potential for heat/cold stress:
Temperatures are expected to be in the ___( to ___ ( range. There is a minimal___ , moderate ___, or severe___ potential for heat/cold stress.
Safety Item Safety Note Location
Phone:
Eye wash:
First Aid Kit:
Fire Extinguishers:
Other___
SECTION 5:
PERSONAL PROTECTION
Level of Protection (L.O.P.) to be employed for each site task (initial site survey, mobilization, excavation, etc.)
TASK INITIAL L.O.P.
UPGRADE L.O.P.
Personal Protective Clothing/Equipment Check List (may reference Programmatic HAPS)
Level D/Modified D*: steel toe/steel shank safety shoes rubber over-boots or disposable boot covers *
( ) work coveralls
Tyvek coveralls* outer gloves (type of material – nitrile, PVC, etc.. )* inner gloves (type material)* work gloves hard hat safety glasses hearing protection dust mask (nuisance dust only)*
“Modified D” * Modified Level D is defined as any chemical protective clothing ensemble worn without inclusion of an air purifying respirator.
Level C: steel toe/shank safety shoes
( ) FULL-FACE RESPIRATOR with appropriate cartridges (identify type)
( ) rubber over boots or disposable boot covers
( ) Tyvek or other appropriate chemical resistant coveralls (identify type of material)
( ) splash/lab apron
( ) outer gloves (material)
( ) inner gloves (material) ( ) hard hat
( ) hearing protection
Level B: steel toe/shank safety shoes
( ) PRESSURE - DEMAND SCBA
( ) rubber over boots or disposable boot covers
( ) PVC Tyvec or other appropriate chemical resistant coveralls (identify type material) ( ) outer gloves (material)
( ) inner gloves (material)
( ) hard hat
Other safety equipment:
( ) hearing protection ( ) traffic cones
( ) face shields ( ) safety vests
( ) tick spray ( ) traffic warning signs
( ) sunscreen ( ) other______________________
( ) cooler(s) ______________________
SECTION 6:
AIR MONITORING
Monitoring instruments selected:
| Contaminant |
| Instrument (make/model) |
| Settings |
(span, etc.)
Calibrant
(type/conc) Frequency of Use
(time period) Type Atmosphere
VOCs
LEL/UEL
Oxygen
Dust
Fibers (asbestos)
NOTE: Continuous monitoring required for Level C Protection and above.
Air Quality Action Levels
Organic Vapors (unknown) Background Level D
*>Background-5ppm in breathing zone Level C
* 5-500 in breathing zone
Level B
* 500-1000 in breathing zone
Level A
* Concentrations above background sustained for one minute or longer
NOTES: These action levels established by the USEPA Emergency Response Team are guidance only and do not apply to substances with very low TLVs or IDLH concentrations. Action levels should be revised in relation to the presence of known and suspected substances. There are also substances against which full-face, cartridge equipped masks do not protect.
Action Levels
Condition Range
Action Required
Oxygen:
Less than 19.5%
Leave site or go on Supplied Air
More than 23.5%
Leave site – Fire/Explosion Hazard
Combustible Gases:
>10% LEL
Leave site – Fire/Explosion Hazard
Radiation:
> 0.08 mR/hr
Proceed with caution
> 1 mR/hr
Continue only on advice of Health Physicist Other Monitoring: (If required, if no other monitoring is anticipated state “NONE”)
SECTION 7 - DECONTAMINATION
All personnel and portable equipment used on site shall be thoroughly decontaminated before leaving the site.
7.1 Decontamination Procedure for personnel: (include doffing steps, decon solution to be used, how performed)
Diagram of Decon Area (Attachment-include steps, locations etc..)
7.2 Decontamination Method/Procedure for Equipment and Instruments:
7.3 Disposal of Contaminated Material:
Disposable protective clothing, respirator cartridges and similar items will be bagged for proper disposal. Contaminated rinsate from decontamination of personnel and equipment will be disposed of per state/federal guidelines, unless other arrangements have been made.
7.4 Decontamination Equipment and Supply Checklist
___ Steam Cleaner/power washer ___ Buckets ___ other
___ Water sprayers
___ Scrub brushes
___ Detergent (Alconox)
___ Deionized water
___ Tap Water
___ Garden Hoses
___ Plastic garbage bags
___ Disposable wipes
___ Poly sheeting
___ 55 gallon drums
SECTION 8 - EMERGENCY RESPONSE
8.1 Communication
Team members will always work in groups of a minimum of two while on site. Visual contact distance among team members must be maintained at all times.
Site Personnel Roles/Line of Authority:
Emergency Signals:
8.2 Evacuation:
EXAMPLE: In the event of an emergency, such as fire, explosion, toxic gas release etc, personnel will leave the work area or site and meet at a location agreed upon before starting work (case manager’s support vehicle, nearest street, facility entrance etc.)
8.3 Response to Personnel Injury or exposure (indicate procedures)
Skin or eye contact:
Inhalation:
Ingestion:
EXAMPLE: Symptoms and First Aid for Heat related injuries:
Symptoms of heat stress include: fatigue and muscle weakness; reddening of extremities (ears); cramping of stomach, arms and legs.
Symptoms of severe heat injury requiring IMMEDIATE MEDICAL ATTENTION include: seizures, fainting, loss of consciousness, bizarre behavior; profuse sweating than cessation of sweating resulting in hot dry skin.
Suggested first aid:
· Cool victim
· Remove victim out sun into shaded area (air condition vehicle)
· Dampen victims clothing and remove excess impervious garments
· Provide water, if conscious and not vomiting
· TRANSPORT TO HOSPITAL WHILE ADMINISTERING TREATMENT FOR SEVERE HEAT INJURIES
8.4 Emergency Decon Procedures
If decon cannot be done, the victim will be wrapped in blankets, plastic or rubber to reduce contamination of other on-site personnel and rescue workers. Rescue workers and hospital must be informed if victim is potentially contaminated. HASP, or minimally MSDS material, must accompany the victim to hospital.
8.5 Emergency Information
Emergency Service Phone Number(s)
Ambulance 911
* Hospital Emergency Room _______________________________
(Name, address and phone #) _______________________________
Local Municipal Offices _______________________________
Police Department _____________________ and/or 911
Fire Department _____________________ and/or 911
HazMat Team DEP “Hot Line” 1-877-927-6337 (1-877 WARNDEP)
Poison Control Center 1-800-962-1253
NJDEP Case Manager ________________________________
NJDEP Office of Site Safety and Health 609-984-9779
USEPA Emergency Response 1-800-424-8802
Other ________________________________
Per requirements of the NJDEP’s Minimum Requirements, the hospital that is to provide emergency room services to potentially contaminated victims must be notified prior to commencing of site activities.
If an employee…
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