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A. EHS/Facilities Guidelines for Renovation & Construction Projects

B. Facilities Projects and Infrastructure Hazard and Regulatory Requirement Assessment Criteria

C. Hazards Analysis Process/Maximo Work Flow (includes Procedure for Safe Work Control Release) 

A. EHS/FACILITIES GUIDELINES FOR RENOVATION & CONSTRUCTION PROJECTS 

Project Kick-off

• Facilities assigns team (Project Manager, Construction Manager, in-house design staff, and inspector)

• EHS assigns Team Lead & EHS subject matter experts as needed

• Facilities conducts opening meeting with client & EHS

  • Discusses SOW, renovation process, duties, responsibilities and how project design, demolition, construction & inspection will proceed

  • Organizes walk through of space conducted with all parties

  • Client describes activities, equipment needs & anticipated chemical usage

  • IH can provide current inventory beforehand – client needs to update

    • Chemical usage has impact on controls

  • IH explains the role of EHS & informs client

    • Preliminary idea of controls needed based on client input

    • Area needs to be cleaned before renovation begins

    • Safety equipment should be upgraded (hoods, eyewash/showers & storage) 

Develop Design Drawings & Specs

• Facilities develops design drawings, schedule & budget        

  • Current standards, codes & specs

  • Facilities Specs (e.g., fume hood spec) 

  • Use “standard details”

• Client, IHs & other EHS personnel review & provide written comments to Facilities

• Facilities addresses & resolves each comment

  • Incorporate comments directly into drawings & specs. Includes asbestos, lead & mercury controls.

  • Show Revision No and/or date on updated drawings

  • Equipment schedule & budget reflects design review comments made

  • Parties review final design package, concur & sign off

Area Preparation

• Client cleans lab: waste, sharps, excess chemicals, equipment, debris & residues

• Space owner requisitions Waste Mgt to handle/remove excess chemicals/wastes

• IHs & Rad Control Techs perform final inspection

• Facilities conducts/contracts out necessary abatement before area demolition 

Demolition & Construction - Space released to Facilities

• Transportation moves equipment, unopened chemicals & furnishings out of lab

• Waste Mgt. moves opened chemicals

• Demolition & construction begin

• Installation of equipment & furnishings

• Facilities monitors progress of renovation & installation of equipment through regular inspections (to ensure proper installation IAW code)

Punch List Walkthrough

• Facilities organizes “Punch List” walk through (renovation must be near completion)

  • All parties (including EHS) participate at same time

• Facilities responds to & corrects each issue identified Commissioning

  • EHS performs/assists in tests and certifications (e.g., fume hoods, biosafety cabinets, etc.) in accordance with requirements

• Perform Functional Performance Testing per sequence of operations (SOOs) in accordance with Cx Plan prior to Project sign off

B. Facilities Projects and Infrastructure Hazard and Regulatory Requirement Assessment Criteria

Provided by EHS at the initiation of a project.

C. Hazards Analysis Process/Maximo Work Flow

Contents

1. Overview

2. Roles and Responsibilities

3. Qualifications and Training

4. Definitions

5. Hazards Assessment Process

6. Unscheduled Work

7. Safe Work Control Release

8. Attachments

1.OVERVIEW

1.1           Purpose

This procedure describes the graded approach the Facilities Division applies to its work control process, ensuring that the greater the hazards associated with its activities, the more rigorous the work planning process required. Work Leads analyze the hazards associated with Facilities work and communicate the required controls to the workers.

1.2           Scope

This procedure applies to work performed by Facilities Division staff, as processed through the Maximo Work Management system.Excluded from this procedure is work performed by:

• Staff under the line management of other LBNL divisions (i.e., Engineering and Information Technology Divisions)

• Construction subcontractors

• Non-construction subcontractors (i.e., vendors)

2.ROLES AND RESPONSIBILITIES

2.1                             Work Leads

In the Facilities Division, ‘Work Leads’ encompasses:

• Small Projects Manager

• Technical Services Manager

• Transportation/Shipping/Receiving Manager

• Project Managers

• Construction and Maintenance Managers

• Supervisors

• Leads

Individuals in all of these positions have responsibility for leading work performed by Facilities staff and work order (WO) approval authority in Maximo. Their responsibilities include:

• Analyze hazards associated with work.

• In consultation with the Environment/Health/Safety Division (EHS), as necessary, develop and document controls for the hazards present (i.e., formal work authorizations and/or Task-Based Job Hazards Analyses).

• Ensure formal work authorizations are in place prior to starting work, as applicable.

• Revisit hazard analyses when work conditions change. Revise hazard analyses, as necessary.

• Review hazard analyses with worker, as appropriate.

• Ensure workers review and sign applicable hazards analysis documentation.

2.2           Workers

• Review conditions in the field prior to starting work.

• Do not begin work until the hazards analysis accurately describes the work and has been re-authorized.

• Perform work in accordance with work instructions and established ES&H controls.

• Stop Work and notify Work Lead if work instructions cannot be followed safely as presented or controls are believed to be inadequate.

• Provide feedback on work instructions and controls

3.QUALIFICATIONS AND TRAINING

Facilities Division ensures its’ staff possess the necessary skills, knowledge, and abilities to carry out their assigned tasks. This assurance of base skills is provided through the hiring process and ongoing performance reviews. EHS training requirements are identified through the completion of the Job Hazards Analysis (JHA). Completion of the required EHS training courses provides greater assurance that all Facilities Division personnel know the hazards associated with their jobs, understand the possible health and safety effects of exposure to those hazards, and know how to perform operations safely and in accordance with all environmental protection requirements.

4.DEFINITIONS

Job Hazards Analysis (JHA) - Job Hazards Analysis (JHA) is the process that results in a worker hazard and control description (Hazards Profile) and Work Authorization document. The JHA includes a description of the work to which the JHA applies (the Scope); descriptions of the tasks incorporated into that work and associated hazards and controls. All Facilities workers have an Individual Baseline JHA identifying the tasks, hazards, and controls that the worker encounters on a regular or routine basis as part of normal work assignments.Task-based JHA - Work that is unpredictable, short-term, or unusual and is not included in the Individual Baseline JHA must be analyzed in a Task-based JHA.Work Lead - A Work Lead is anyone who directs, trains, and/or oversees the work and activities of one or more workers. Work Leads provide instruction on working safely and the precautions necessary to use equipment and facilities safely and effectively. A workers default Work Lead is his/her supervisor, but the supervisor may designate another person to be the Work Lead. Work Leads authorize work with the concurrence of the worker’s supervisor.

5.HAZARDS ASSESSMENT PROCESS

5.1           Work Planning

The objective of the work planning process is to ensure the hazards and environmental aspects associated with the work activity are clearly understood and appropriately addressed. Work Leads begin this process by reviewing the requested work location and work scope as described in Maximo. They perform the following steps to ensure the scope of work includes sufficient detail  to perform a hazards analysis:

1. Review scope for completeness

2. Contact the requestor for additional information, as necessary

3. Perform a job walk, as necessary

4. Modify and/or supplement the long description of work in Maximo, as necessary

5. Consult with the appropriate EHS Division Subject Matter Expert, as necessary, if uncertain of the hazards or environmental aspects present in the work.

Both scheduled and unscheduled work is managed through Maximo and originates from multiple sources:
Scheduled Work

• Work requests through the Work Request Center (WRC).

• Predictive/Preventative Maintenance (PPM) auto generation of work orders

• Facilities projects – Capital and Small Projects Groups manage LBNL-performed work through Maximo

• VFA – Condition Assessment Program

• Contractor support

• Corrective (scheduled) Unscheduled Work

• Corrective (unscheduled) – direct dispatch to diagnose and/or correct

• Emergency response that includes Electrical Incident Emergency Response according to  LBNL PUB-3000, Chapter 8, Work Process K

Unscheduled work is discussed further in Section 6 of this appendix.

5.2           Hazard Analysis

Work Leads categorize Work Orders based on the hazards present in the work location and/or the work itself. Depending on the location and/or scope of work, the Work Lead selects one of the following hazard categories:

Table 1

5.3           Control and Mitigation of Hazards and Environmental Aspects

Based on the category of work, the Work Lead develops controls to mitigate hazards and environmental aspects. The Work Lead consults with the appropriate EHS SME(s), as necessary, depending on the complexity of the work and/or hazards present.Routine Work – Employee’s baseline JHA covers the scope of work. The WO includes location hazards and precautions from the Hazards Management System.Formally Authorized Work Controls – Work is performed under a formal ES&H authorization. The Work Lead consults with the appropriate EHS SME, as necessary, and ensures the authorization is prepared prior to starting work.Task-based Job Hazards Analysis – The Work Lead completes the Task-based Job Hazards Analysis form, in consultation with the appropriate EHS SME(s), as necessary. This analysis includes the following considerations:

• Principal steps in task

  • Potential hazards

  • Controls

  • Equipment and machinery to be used

• Inspection requirements for applicable equipment and machinery

• Training and hazard communication requirements for applicable equipment and machinery

Refer to Attachment B for the Task-based Job Hazards Analysis form.

5.4           Work Authorization and Performance

Once the Work Lead completes the hazards analysis and develops and documents the necessary controls, he/she approves the WO and authorizes the work. Table 2 below specifies which Maximo forms and associated documents apply to each category of work. It also specifies which work orders require signature and by whom.

Table 2
* Includes Hazards & Precautions from HMSFor categories 2, 3, and 4, Work Leads review the complete WO and associated documents with the employee(s) before the start of work and sign the WO as authorizer. For Routine Work (category 1), the Maximo date/time stamp of who approved the WO serves as acknowledgement by the Work Lead that he/she has reviewed and understands the hazard associated with the work.For categories 1, 2, 3 and 4, employees performing work under the WO sign the WO, indicating they understand the hazards present and controls required to perform the work safely.When the scope of a WO requires multiple days of work, the Work Lead and/or workers sign the applicable forms (Table 2) on the first day only, as long as the hazards and controls remain the same over the course of the job. When a new worker is assigned to the job, the Work Lead and/or worker must sign the applicable forms. If at any time the hazards change, the scope is reanalyzed for hazards and appropriate controls.For all categories, employees are instructed to perform work in conformance with instructions on the WO and associated documents. If the instructions cannot be followed safely as presented, or if controls are believed to be inadequate, the employee is responsible for stopping work and notifying the Work Lead.

5.5           Performance Monitoring and Feedback

Based on the complexity and hazards associated with the work, Work Leads periodically observe workers to verify that work is performed according to the defined ES&H work controls. If there is indication that the proper limits and/or controls of a work activity are not being followed, the Work Lead is to immediately evaluate the work. This may prompt the Work Lead to un-approve the WO. The WO is re-approved only after the appropriate controls are developed and communicated to the worker.Each worker is empowered and required to stop work if there is an unsafe or unapproved condition. Prompt notification of the Work Lead is required. Resumption of work will not proceed until after the condition has been evaluated and the appropriate remedial actions have been taken.

6.UNSCHEDULED WORK

Emergency and unscheduled corrective work, by nature, is not fully defined from the onset.   Initial response to these situations is covered by a worker’s baseline JHA.  An example is  response to a broken water line. The initial responders secure the scene in order to mitigate property damage, and then take further action at the direction of the Work Lead. The Work Lead is responsible for performing the hazards analysis prior to resumption of work to address the situation.  Workers are instructed to stop work at any point they encounter situations outside their baseline JHA.

7.SAFE WORK CONTROL RELEASE

To ensure that craft work has been left in a safe condition at the end of the work, Facilities uses a Safe Work Control Release procedure. This procedure is used for Maximo Work Order Worktypes Alterations and Improvements, Deferred Maintenance and LSAD – Programmatic & Institutional. This process is described in further detail in Attachment C, Procedure for Safe Work Control Release.

8.ATTACHMENTS

Attachment A - Formal Work Authorizations & Examples of Work Potentially Requiring a Task- Based JHA

Attachment B - Task-Based Job Hazards Analysis

Attachment C - Procedure for Safe Work Control Release

ATTACHMENT A

Formal Work Authorizations &

Examples of Work Potentially Requiring a Task-Based JHA

(Lists not intended to be all-inclusive. Consult with EHS as necessary)

Formal Work Authorizations

Confined Space Permit

Hot Work Permit

Radiological Work Permit

Penetration Permit

LOTO and/or Energized Electrical Work Permits

Lead Work Permit (for permit-required lead work) 

Example Work That May Require a Task-Based JHA

Critical lifts

Fall protection in areas with no clear tie off points

Multiple craft task

Work on Scaffolds

Use of respirator

Space constraints

Asbestos removal/abatement

Lead work (non-permit required)

LOTO

ATTACHMENT B

Task-Based Job Hazards Analysis

ATTACHMENT C

Effective 10/31/08                                                                                                CATS #5751-3

PROCEDURE FOR SAFE WORK CONTROL RELEASE

This post job inspection procedure is to ensure that craft work has been left in a safe condition at the end of the work. This procedure will be used for the Maximo Work Order Worktypes listed below. At the end of each job performed by in-house craft or in the event the in-house craft is pulled off the job for another priority or emergency, a Safe Work Control Release must be signed by the worker, supervisor, and also the Construction Manager, if one has been assigned to the project. If the supervisor is unavailable, the next level manager must sign.

Applicable Maximo Work Order Worktypes and Descriptions:

AI-Alterations and Improvements: Work intended to alter or improve an asset’s functionality in the same or new location, e.g., additions new work, enhancements, alternations, expansions, and major alterations to subsystems (e.g., enclosure, interior, mechanical).

DM- Deferred maintenance: Replacement and renewal maintenance work that was not performed when it should have been or was scheduled to be and is put off or delayed for a future period. This replacement and renewal maintenance work has been reported to DOE as Deferred Maintenance in the FIMS database.

LSAD – Programmatic & Institutional: All Programmatic and Institutional LSAD safety work performed by Facilities.

SAFE WORK CONTROL RELEASE

Check Appropriate Box

1. Criteria for Post Job Inspection Completed Work (#1 & #2 Below)

Pulled-Off Job - Other Priority (#2 Below) Pulled-Off Job - Emergency (#2 Below)

Check Appropriate Box

1. Post Job Inspection

2. Completion of all work

1. Left in Safe Condition

Work Request #:                          Job Name:                                                              

Job Location_                                                                                                           

Building                        Room #’s Signatures based on site inspection:

Worker:                                                                                                                     

Print Name                           Signature                                                       Date Supervisor:              

Print Name                          Signature                                                       Date

*CM:                                                                                                                         

Print Name                           Signature                                                       Date

*If Applicable

ENVIRONMENT/HEALTH/SAFETY

This section summarizes and highlights Environment/Health/Safety (EHS) procedures that relate to the activities of Facilities Design and Construction Management (DCM). All DCM employees must comply with the requirements of the LBNL Health and Safety Manual, PUB-3000. DCM work shall be carried out in accordance with the Facilities Division Integrated Safety Management Plan and all applicable federal, state, and local regulations. Work will be performed in a manner that protects the environment and the safety and health of subcontractor employees, LBNL employees, and the general public.            

The Facilities ISM Plan is part of a coordinated focus on safety that flows down from the DOE contract through LBNL to the vendors and construction subcontractors performing work at LBNL. This integral relationship is illustrated in Figure 1. Safety requirements are detailed in many hierarchical documents, including the Facilities ISM Plan and the DCM Procedures Manual.

GENERAL EMPLOYEE RESPONSIBILITIES

DCM employees must comply with the requirements of the LBNL Health and Safety Manual, PUB- 3000. Individual responsibilities for all employees are as follows:

• Must complete the LBNL employee Job Hazards Analysis (JHA) and fulfill all identified training requirements within a month of being hired.

• Must complete General Employee Radiation Training (EHS0470 GERT).

• Must be familiar with the sections of PUB-3000 that relate to the work they are performing at LBNL.

• Must be knowledgeable of LBNL’s “Stop Unsafe Work Policy” whenever they encounter or become aware of a situation that poses an imminent danger.

• Must not perform or direct the performance of any work in the presence of any existing or previously unrecognized hazards inherently dangerous to themselves, their co-workers, the public, or the environment. If employees, contractors, and casual and participating visitors encounter such a situation, they must bring it to the attention of their supervisor or LBNL EHS coordinator immediately. Work will not commence until the hazard(s) is/are resolved through elimination or control (either administrative or engineering controls).

• Owners of hazard control equipment, personal protective equipment (PPE), and hazard monitoring equipment must ensure that the equipment is in good order and working within operational parameters. Any equipment failing to satisfy operational requirements must be taken out of commission and repaired or replaced.

• Must proceed with work only after ensuring that appropriate ES&H procedures have been implemented.

• Must perform all work safely, and be aware of potentially hazardous operations and conditions.

• Must minimize the volume and toxicity of LBNL-generated waste, and maintain chemical inventories at as low a level as reasonably achievable.

Refer to PUB-3000, Chapter 24, for additional responsibilities for managers and supervisors.

PROJECT TEAM MEMBER RESPONSIBILITIES

A. PROJECT DIRECTOR

The Project Director (PD) is responsible for all “contractor requirements” provided in Department of Energy Order 413.3A, including adherence to:

• established technical, cost, and schedule baselines

• utilization of an Earned Value Management System

• development of a risk mitigation plan

• utilization of a configuration management process

• implementation of an Integrated Safety Management (ISM) system

The LBNL Director, through the Associate Laboratory Director for Operations, delegates to the Project Director full responsibility and accountability to design and execute projects in a manner that will not compromise the safety and health of workers, the public, or the environment. The Project Director will be supported in this effort by the Project Manager, Project Office Staff, and various Subject Matter Experts. The Project Director reports to the DCM Department Head.

The Project Director will be responsible for identifying all potential ES&H hazards and associated mitigation procedures. The Project Director has full responsibility to ensure the safe completion of the project and to implement continuous improvement of the project safety plans through implementation of ISM principles.

The Project Director will be responsible for control of scope, budget, and schedule throughout the life of the project, from conceptual design through start-up. The Project Director will chair regular meetings with the Project Manager and the Project Team that will help ensure that the project is successfully being executed in accordance with the cost, schedule, and technical baseline.

The LBNL Project Director interacts directly with the DOE Berkeley Site Office (BSO) Federal Project Director (FPD). The LBNL Project Director has overall responsibility for the management of the safe execution of the project.

The Project Director:

• leads LBNL’s project team

• ensures that project environment, safety, and health accountability is integrated throughout project-related efforts and is integrated by all project personnel, from the Integrated Project Team (IPT) to subcontractor workers

• supports the Federal Project Director in implementing DOE’s project management process

  • has primary responsibility for community relations

B. PROJECT MANAGER

The Project Manager (PM) reports to the Project Director. The Project Manager has responsibility for managing day-to-day construction-related activities consistent with DOE orders, as well as applicable federal, state, and local laws and LBNL policies. The Project Manager has direct oversight of the architect and engineering consultants, the contractor, additional consultants, the

Project Coordinator, the LBNL Construction Manager, the quality inspector, and the LBNL project team.

The Project Manager:

• ensures that LBNL’s Integrated Safety Management policies are followed

• approves the subcontractor’s safety plan

• is directly responsible for design and execution of a project in a manner that will not compromise the safety and health of workers, the public, or the environment

• is directly responsible for the safe and successful execution of the project scope of work

• ensures that National Environmental Policy Act (NEPA)/California Environmental Quality Act (CEQA) mitigation monitoring measures are enforced; reports on mitigation measure implementation

• provides the number of complete sets of design and construction documents requested by the EHS Team Leader at each review stage

• is responsible for the distribution of the design documentation (drawings, specifications, calculations, etc.) at the completion of each design phase to the EHS Team Leader for review and sign-off. An adequate period must be allocated for review of design documentation.

• in conjunction with the subcontractor and RI, develops an equipment energization plan that reflects the requirements in the Facilities Safe Electrical Installations Policy and Procedure when applicable work is performed by subcontracted QEWs

• refers subcontractor submission of any QEW acceptance and supporting documents to appropriate individuals for approval

• ensures that a project specific Soil Management Plan is approved by the EHS team for all projects that disturb LBNL soil, and that all work performed follows that plan

• manages project risks and resolves technical issues raised by contractors

• controls the cost, schedule, and scope of the design and construction-related activities

• is responsible for coordinating design input from all the team members and incorporating the information into the design

• implements effective quality assurance procedures

• conducts daily site walks

• drafts monthly reports submitted by the Federal Project Director

• manages the work of the architect and engineering consultants

• identifies and ensures timely resolution of critical issues within LBNL’s control that impact project performance

C. LBNL CONSTRUCTION MANAGER

The LBNL Construction Manager is the primary interface with the construction subcontractors’ Field Superintendent and with LBNL craft supervisors. The LBNL Construction Manager reports to the Project Manager and:

• is overall responsible for safe execution of the work including all work performed by subcontractors, in-house crafts, vendors, and other LBNL divisions

• monitors overall worksite status, ensures safe performance of work by contractors, and ensures physical controls are in place (including security fence and hazardous materials storage areas)

• monitors construction activity in accordance with Integrated Safety Management practices

• monitors contractors’ and site craft achievement of work according to technical specifications

• supports contractors when they need information and resolves issues that threaten work progress

• manages traffic and logistics on site and adjacent

• manages the soil handling process in accordance with an approved Soil Management Plan

• is the primary interface with all LBNL craft and EHS personnel, coordinating utility shutdowns, dig permits, burn permits, Job Hazards Analysis process, etc.

• in conjunction with the Construction Safety Engineer, performs worksite safety inspections, including an interview of subcontractor workers. Refer to Appendix H, Environment/Health/Safety.

• manages and oversees the Energization Validation & Authorization Package (EVAP) process and other requirements according to the Facilities Safe Electrical Installations Policy and Procedure.

• prepares a daily construction progress report for each day s/he is on the job, noting all construction activity, field conditions, and number of subcontractor personnel by trade. Progress photos should be included as needed.

D. EHS CONSTRUCTION SAFETY DESIGN REVIEW TEAM LEAD

• identifies the EHS Team Leader

• assigns technical professionals to specific projects and tracks their participation

• assists the EHS Team Leader in resolving conflicting EHS issues when requested by the Team Leader

• distributes EHS/Facilities Guidelines for Renovation and Construction Projects (see below) outlining safety procedures and responsibilities for project team

E. EHS TEAM LEADER

The EHS Lead oversees and supervises the EHS team (including subcontractors). The EHS Team Leader:

• coordinates and supervises the activities of all the EHS team members

• advises team members of project activities (meetings, reviews, events, etc.)

• distributes design and construction documents for review to the EHS team members

• coordinates EHS review comments, resolves conflicts, and returns a consolidated set of comments at each review milestone to the Project Manager

• coordinates the sign-offs for the EHS team members at project review milestones, ensuring that EHS issues have been resolved

• provides support and advice to the Project Manager to ensure EHS integration into all project activities at an appropriate level

• provides advice and support to the Project Manager and Construction Manager on the continuous improvement of safety throughout the project

• provides an interface with the subcontractor safety manager and staff to ensure that safety requirements are understood and that LBNL and the subcontractor perform as an effective team to support the safe conduct of work

• inspects the worksite as needed and gathers and integrates data from other EHS staff to provide the Construction Manager with prompt and effective information and status on safety compliance on the project

• reviews and ensures that the Construction Safety Engineer approves the subcontractor hazard assessments and safety plans

F. CONSTRUCTION SAFETY ENGINEER

The Construction Safety Engineer is a key project team member. S/he provides oversight and support for safety at the jobsite and interacts with the Construction Manager and subcontractor. The Construction Safety Engineer’s responsibilities include:

• reviews subcontractor safety plans and Job Hazards Analyses

• reviews subcontractor safety implementation documents: permits, such as excavation, LOTO, air quality, asbestos, National Emissions Standards for Hazardous Air Pollutants, (NESHAPS), etc., and sampling results

• performs worksite safety inspections in conjunction with the Construction Manager, including an interview of subcontractor workers. Refer to Appendix H, Environment/Health/Safety, Safety Controls and Oversight. Reports positive and negative findings/issues to the Project Manager.

• documents positive and negative inspection findings and provides trending reports to the Project and Construction Managers each week. Provides recommendations as appropriate. Summarizes trending reports monthly, or as needed.

• tracks open safety issues and verifies resolution. Performs effectiveness reviews of serious noncompliances to ensure that corrective actions have addressed the root cause of the noncompliance.

• periodically observes subcontractor tailgate and other safety meetings. Provides input on topics of interest.

• participates in all project review meetings and provides timely and constructive input on the safety performance of the subcontractor.

• develops and delivers any project-specific safety training to LBNL project personnel. This will include Lessons Learned from project errors and incidents and corrective training when project staff demonstrate a lack of effective knowledge on specific areas of safety compliance.

• develops any project-specific safety procedures as directed by the Project or Construction Manager.

G. EHS TEAM MEMBERS/SUBJECT MATTER EXPERTS

EHS team members participate in the same manner as all design team members, to review information, identify EHS issues, sign off at formal review periods, and assist with issue resolution.

At any point in the process, if any team member identifies any EHS issues that need to be reviewed by additional technical staff, s/he shall make recommendations to the EHS Team Leader.

PLANNING PHASE ACTIVITIES

Pre-project planning is an interactive process that identifies user needs and evaluates the function, form, and site requirements of the proposed facility. Requests for new capital projects are often handled as studies, resulting in preliminary scope definition and preliminary cost estimates. A strategic assessment of potential environmental impacts, hazards analysis, government regulations, economic, and technology changes is important during this phase.

Hence, the EHS Construction Safety Design Review Team Lead shall assign an EHS Team Lead to aid the Project Team in the environmental and hazards assessment. During this planning phase the Project Team:

• determines the appropriate Hazards Analysis process, including a Safety Analysis Document, Hazards Analysis Report, or other tailored approach

• performs a preliminary NEPA/CEQA determination

• identifies testing that should be performed to analyze any contamination, lead, or asbestos considerations

• performs a site characterization study for brownfield sites (a brownfield site is defined as any site with prior development)

• A graded approach is used to determine the appropriate level of Commissioning rigor to achieve a safe, efficient, and reliable product without performing unnecessary testing, witnessing, and documentation. For further information, please refer to Commissioning Process: Standard Operating Procedure.

DESIGN PHASE ACTIVITIES

The EHS Construction Safety Design Review Team Lead will assign support team members and Team Leaders for all DCM work. The Orange Folder for team assignments will be routed to the EHS Construction Safety Design Review Team Lead, who will assign team members appropriate for each project. The Project Manager is responsible for including the EHS team in the project design process and providing responses to their concerns and comments. Guidelines for EHS team members are prepared by the EHS Construction Safety Design Review Team Lead as part of the team assignment email. The Interface Policy between EHS and Facilities: Project Support describes the participation and review responsibilities of the EHS team.

Chemical inventories should be obtained from the client and forwarded to the EHS Team Lead, the design professional, and Fire Marshal for determination of controls needing inclusion in the project scope.

The Project Manager and EHS Team Lead will initiate the agreed upon hazards analysis documents, i.e., a Hazards Analysis Report, or other tailored approach. This analysis will consider and incorporate the Site Characterization Study.

The Project Manager will initiate a hazardous materials survey of the project area to identify materials that may be disturbed by the construction work. The Project Manager will discuss with the EHS team the requirements for hazardous materials abatement during construction. The Hazards Analysis document and contract documents shall include these requirements. The Hazards Analysis Report/document shall also include the requirement for a site specific Soil Management Plan.

The Project Manager will initiate a site specific Soil Management Plan for all projects within the boundaries of LBNL which involve land disturbance, i.e., affect LBNL soil. The Soil Management Plan shall be consistent with PUB-3000 Chapter 11, Soil Management Plan. The plan shall include the size of area anticipated to be disturbed, soil testing and analysis to be completed, restrictions on handling and/or hauling of material, and approved disposal site. On sites that have had prior development (brown field sites) or have known soil contamination, a Site Characterization Study shall be developed to identify underground hazards that may exist at the construction site, including the extent of any debris that may be encountered and the recommended disposition of the debris. The plan will be approved by the Project Manager, the EHS Team Lead, and the environmental SME; the findings communicated to the project team and construction subcontractor and included in the construction contract documents.

Prior to surface penetrations, a Permit to Penetrate Ground or Existing Surfaces of LBNL Property must be obtained in accordance with the requirement of Facilities' Administrative Procedure (ADMN-053). This permit requires that the Responsible Individual/Project Manager notify the EHS Environmental Services Group (ESG) to initiate a preconstruction site evaluation. If a Site Characterization Study has not already been prepared as part of the Soil Management Plan, the ESG will then determine the nature and extent of any contamination known or suspected to be present in the soil; and whether any preconstruction soil sampling is required. Soil cleanups have been completed at LBNL which should eliminate the known hazards to construction workers.

However, if contaminated soil is unexpectedly encountered, excavation must be stopped, and ESG must be contacted to perform a hazard evaluation.

Soil that is contaminated, but below hazardous thresholds, will be disposed of in a Class II or other acceptable landfill, depending on the acceptance criteria of the landfill. A Class III landfill may accept the soil depending on the type and concentration of the contaminant. The landfill may require analytical testing of the soil to document that chemical concentrations do not exceed their waste acceptance criteria. Clean excavated soil will be reused onsite to the extent practicable. When not practicable, clean soil should be sent to a Class III or other acceptable

landfill. It is not anticipated that soil containing contaminants at hazardous levels will be encountered; however, should that be the case, the Waste Management Group should be contacted for instructions on waste handling and disposal requirements.

Division 01 Specification Section 013529, Environment, Safety, and Health General Requirements, should be included in all project specifications documents. This specification should be reviewed by the Project Managers and EHS team members assigned to the project, and tailored to the project if necessary.  Requirements for the subcontractor to provide an on-site health and safety representative may need to be quantified (full-time, weekly visits, etc.), depending on the size and type of project.

The EHS team lead will sign the final design Project Plan Review form to confirm that the design includes EHS requirements.

BID AND AWARD

For projects that will be publicly advertised, consideration should be given to pre-qualifying subcontractors, using their past construction safety record as a qualification criterion.

Construction subcontract bidding that uses best value source selection, with safety as one of the selection criteria, is encouraged.

A Site Specific Safety Plan (SSSP) is required in all cases for DCM and MRO construction projects. Procurement, after award of the subcontract, will send the SSSP form to the subcontractor, who will fill it out and forward it to the Project Manager.  The Project Manager will ensure that the completed SSSP is reviewed and approved in accordance with PUB-3000, Chapter 10, before recommending that Procurement issue a Notice to Proceed. The Project Manager is responsible for ensuring that work does not start on site without an approved SSSP.

The subcontractor shall ensure compliance with the SSSP and Job Hazards Analyses (along with any supporting documents described in PUB-3000) and communicate the requirements of the SSSP, supporting documents, and JHAs to their workforce.

In the event a non-construction hands-on project is being managed, follow PUB-3000,

Chapter 31 requirements (Non-Construction Safety Assurance for Vendors, Subcontractors, and Guests at LBNL Facilities).

CONSTRUCTION SAFETY

A. SAFETY DOCUMENTS

Project Managers are responsible for obtaining the following safety documentation from the construction subcontractor:

• Injury and Illness Prevention Plan (IIPP)

• Signed Site Specific Safety Plan (SSSP) and its embedded Construction Safety Checklist

• Job Hazards Analysis (also known as Activity Hazard Analysis or JHA). The JHA and all other work procedures for Demolition, Excavation and Trenching permits shall be submitted by the subcontractor a minimum of seven days prior to the start of this work.

• Any subcontractor or lower-tier subcontractor requests for QEW acceptance and supporting documentation as required in PUB-3000 Chapter 8, Work Process F, AHJ Acceptance of Construction Subcontractor QEWs.

The subcontractor will prepare and submit to the Project Manager a Job Hazards Analysis (also known as an Activity Hazard Analysis) for each construction activity listed in the project specifications. This should be reviewed by the Construction Safety Engineer and approved by the Project Manager before work can start on that activity.

No construction activity is allowed on site until the safety plan or safety checklist has been approved.

B. SAFETY DOCUMENT REVIEW 

Outside Construction Subcontractors:

• The Project Manager receives the safety documents from the subcontractor and gives them preliminary review, then forwards them, along with plans, specifications, and other project- pertinent information, to the Construction Safety Engineer.

• • The Project Manager will submit to the Facilities Division Electrical Safety Officer who, in conjunction with the Electrical AHJ will review and approve as appropriate any Subcontractor Employer’s Statement of QEW Approval and related Electrical Safety documents.

• The Construction Safety Engineer reviews and signs the documents and returns them to the Project Manager.

• The Project Manager approves and signs the documents, and transmits them to the subcontractor.  The Project Manager may delegate responsibility for this review and approval to the Construction Manager.

• The Construction Manager shall review Job Hazards Analyses with the construction workers.

• All construction workers sign the JHA to acknowledge that they have reviewed it.

• The approved safety documents will be maintained in the project files and on the jobsite. In-house Construction Support:

• The DCM Construction Manager shall hold a pre-start meeting with the Scheduled Work Center Supervisor, EHS representative, and leads from the crafts, to discuss safety hazards, schedule, logistics, and work coordination. (Also refer to Section 3.3.1, Bid and Award).

C. SAFETY CONTROLS AND OVERSIGHT

Safety controls and oversight are required to be implemented on all projects, including, at a minimum:

• Pre-start Meeting: A pre-start meeting will be held for all projects. The Construction Pre- start Meeting Agenda lists construction safety topics to be discussed at this meeting. The Construction Manager shall attend all pre-start and work kick-off meetings.

• Safety Orientation: The Project Manager and Construction Manager will ensure that subcontractors provide worksite safety orientation to their employees prior to performing work on site.

• Tool Box Safety Training:, The Project Manager and Construction Manager will ensure that tool box safety training is conducted at least weekly.

  • Plan of the Day (POD): Subcontractors on every project shall schedule a Plan of the Day meeting to communicate to the workforce all of the work planned for the job site for that day. The primary purpose of the POD is to provide communication to the various crews and site personnel the various activities planned for the day, hazards that everyone needs to be aware of, and provides an opportunity to resolve potential conflicts between work tasks. The POD may also be used to communicate lessons learned, special safety  topics, and other general project communications. The Plan of the Day will be appropriately documented.

  • All active permits on the project shall be referenced during the POD.
  • Refer to PUB-3000 Chapter 10 and the LBNL Construction Safety Manual Section Contractor Plan of the Day Meeting for additional information and specific requirements.

  • Pre-task Hazard Analysis (PTHA) Meeting.  A PTHA shall be completed according to the requirements contained in PUB-3000 Chapter 10 and in the LBNL Construction Safety Manual at the crew level at the beginning of each shift and updated as necessary to address changes that occur during the shift. This meeting is typically held after the Plan of the Day meeting.

  • Only the work documented in the PTHA and discussed in the Pre-job briefing may be performed. Any change in scope or hazards during the shift requires an update of the PTHA and a re-briefing of the affected workers.   If, while working, it is discovered that the controls addressed in the PTHA will not/do not provide adequate protection then the task at hand shall be stopped and not be conducted until the hazards have been re-assessed, the PTHA updated, and adequate controls implemented.
  • If new workers join the task after the briefing, the new workers must receive the pre-job briefing prior to starting work.
  • The subcontractor shall conduct a pre-task meeting that discusses the corresponding PTHA, the work tasks, and associated procedures and hazards with all affected parties to identify and coordinate logistics, controls and communications required for the activity. Each worker involved in that work must sign the PTHA prior to performing work.  All PTHAs must be kept at the work site to be available for review by workers and oversight personnel.
  • LBNL Coordination Meeting. As required by contract or change notice: Prior to the Daily POD Meeting a daily LBNL Coordination Meeting shall be held to review project/task status and confirm readiness of the proposed work package, to include personnel (qualification tasking), tools, equipment, and required permit status. The minimum required attendees include: the LBNL Project Manager or designee, the Subcontractor’s Superintendent, the Work Planner/Coordinator and the Subcontractor’s Safety Officer. The meeting will verify the risk matrix and basis of safety of each proposed activity, adequately address any concerns, identify hold points, and schedule coordination actions to complete the preplanning activities. All items will be updated and only the line items confirmed as complete will be authorized for the next day’s activities.

• Electrical Safety: All subcontractor electrical work and electrical installations shall comply with the LBNL Electrical Safety Program requirements, including the applicable contents of the LBNL Electrical Safety Manual (ESM), PUB-3000 Chapter 8 and Chapter 18, NFPA 70E and associated implementing processes and procedures.

  • Construction Managers in conjunction with QEW Supervisors and LOTO Responsible Individuals (RI) shall ensure as appropriate that Subcontractor Electrical Foreman validate implementation and submit to the CM for review their documentation of compliance with all required processes and steps mandated in these policies and programs as necessary.

• OAC Meeting: The Project Manager will schedule a weekly Owner, Architect, Contractor (OAC) meeting for each project. The OAC meeting will include Safety as a standing agenda item, including: discussion on the submittal and approval status of safety documentation, status of safety related permits (e.g., LOTTO, penetration permit, etc.), a review of the safety  observations on the work in progress, the hazards and controls associated with upcoming work activities, and confirmation that safety staffing is adequate and responsibilities are clearly understood.

• Daily Report: The Construction Manager will prepare a daily construction progress report for each day s/he is on the job, noting all construction activity.

• Inspection Report: The Construction Inspector will issue construction inspection reports for each day s/he is on the job, noting observations from jobsite visits.

• Safety Walkaround: Line management up to the DCM Department Head will convene a weekly Safety Walkaround with the project team, including safety representatives, to review the scope of work and how risks are being addressed.

• Safety Inspections (Walkarounds): Facilities Supervisors, Project Directors, Projects Managers (AI), and Construction Managers (RI) must conduct and document safety inspections / observations in work areas and projects under their control according to the requirements of Facilities SOP0007 Safety Inspection Standard Operating Procedure

• Stop Work Order: For serious or repeat violations, the Construction Safety Engineer may issue a verbal stop work order followed by a Safety Deficiency Notice, requiring, within 24 hours, a written correction plan that identifies steps to be taken to correct the hazard and prevent further occurrences of the same type.

• RI Safety Roundtable: The RI Safety Roundtable is a regularly scheduled mandatory meeting for all Facilities staff designated as Responsible Individuals, interested parties (e.g., Authorizing Individuals, EHS, Procurement, Facilities Safety). The RI Safety Roundtable will include the discussion of the following topics:

  • Recent construction related Lessons Learned

  • Construction Safety Best Practices

  • Download on recent safety incidents

  • Training refreshers

  • Subcontractor safety performance

  • DBO2 safety observation trends

  • Work Authorization/Work Control policy and procedures updates

  • Coordinate construction activities, shut downs, road closures, parking impacts, traffic control, and deliveries

  • Forecasting MRO Craft Support requirements

• Subcontractor Worker Field Interview: As part of the RI’s responsibilities for daily observation and reporting, the RI will interview subcontractor workers. The results of these interviews will be used as a means to help evaluate and provide critical feedback for improving the quality of current training programs. The following questions were developed for use in conducting these worker interviews:

1. 1. Have you taken the LBNL worker safety orientation?
   2. Who is required to attend the LOTO orientation training?
   3. What is work authorization?
   4. Did you review and sign a PTHA this morning?
   5. Name three of the core functions of ISM?
   6. What should you do if someone has a slip and fall?
   7. What is the difference between “air gap” and LOTO?
   8. When working under LOTO what is the most important issue? [A: one worker, one lock.]
   9. What should you do before using an acetylene torch or grinder?
   10. When is fall protection required?
   11. What is the minimum PPE? When do you need additional PPE?
   12. What should you do if a tool is damaged or the cord is damaged?

Optional Worker Interview:

1. What work are you performing?
2. What are the hazards associated with this work?
3. What controls are you using to protect yourself from those hazards?

The answers to these questions, as part of the daily inspection, shall be included in daily reports submitted to the EHS Construction Safety Manager who will trend the results and make improvements to the program as required.

D. PERMITS

A listing of common permits follows:

1. AIR EMISSIONS PERMITS AND NOTIFICATIONS: All projects that involve demolition of a structure or involve removal of regulated asbestos-containing materials require notification or permits from the Bay Area Air Quality Management District (BAAQMD). The Project Manager  shall coordinate with EHS team to ensure proper notification is made.
2. DIG PERMITS: A Permit to Penetrate or Excavate Surface of LBNL Property must be obtained prior to any work at LBNL that will require penetration or excavation of any ground surface, concrete wall, column, or slab deeper than 1½ inches, including the use of stakes or poles. The Project Manager or Construction Manager will request the permit from the LBNL Utilities Coordinator, and after surveys are completed and signatures obtained, the permit will be posted at the jobsite. Construction activities shall adhere to any conditions of the permit.
3. LOTO Permits: All subcontractors performing work for LBNL are required to conform to the LBNL LOTO Program as mandated in PUB-3000 Chapter 8 and Chapter 18, and other related electrical safety documents. All subcontractor LOTO permits require a designated LOTO Responsible Individual (RI) who submits LOTO requests through the LOTO Permit Database. Before participating in any LOTO, subcontractors must have an approved and printed subcontractor LOTO permit and must be briefed by the designated LOTO RI. Prior the issuance of a subcontractor LOTO permit, the subcontractor shall first submit their company LOTO program or equivalent company policy document to the EHS Electrical Safety Group. Additionally, the subcontractor company must submit a signed statement on company letterhead certifying that all their employees have been trained as LOTO Authorized Persons in the context of OSHA 1910.147(c)(7) as described in Chapter 18. All subcontractors shall receive a subcontractor LOTO orientation by the RI that covers the specific process requirements used at LBNL. Refer to PUB-3000 Chapter 18 for additional RI responsibilities.
4. ELECTRICAL PERMITS: All electrical repair work shall be performed deenergized by a Qualified Electrical Worker and in an Electrically Safe Work Condition, unless approved by an Energized Electrical Work Permit (EEWP). An EEWP shall only be approved in extraordinary circumstances and as a last resort as defined and in accordance with the requirements in PUB- 3000 Chapter 8 and other applicable electrical safety documents. Applications for EEWP are reviewed and approved by the Electrical AHJ for Safe Work Practices. Work will not commence until the permit is issued. Construction activities shall adhere to any conditions of the permit. Subcontractor employees are not permitted to be within the Limited Approach Boundary of uninsulated energized electrical parts without a Subcontractor Energized Electrical Testing Permit (EETP). This includes testing, troubleshooting, inspecting, and nonelectrical work within the Limited Approach Boundary. LOTO verification testing is treated as energized work, but is covered by the LOTO permit. An EETP is not required in this case. The LBNL Responsible Individual (RI) obtains the permit and shall conduct a briefing with all of the workers, explaining to them the scope of the EETP and their respective roles and responsibilities as mandated in PUB-3000 Chapter 8 and in the Electrical Safety Manual. Workers shall comply with the requirements of these documents including all terms, scope, and conditions stated on the permit. Any changes to the EETP must be routed through the Electrical Safety Group for approval.
5. FIRE SAFETY (BURN) PERMITS: All operations with open flames that cause sparks, or are near gas lines or combustible storage containers, require a Fire Safety Permit for Hot Work or Hazardous Operations issued by the Fire Department (ext. 6015). The Project Manager or Construction Manager will request the permit from the Fire Department. Activities requiring a permit include electric arc and gas welding and flame-cutting, other open flame operations, tar kettles, powder-activated tools, and excavations. Work will not commence until the permit is issued. Construction activities shall adhere to any conditions of the permit. In order to keep track of permits during construction, a color-coded map of LBNL shall be kept in the Facilities Division Office and updated by Construction Managers to show current penetration permits. Original wet-signed permits are posted on the jobsite. When the project is completed or the Penetration Permit is no longer active, the original will be kept in the project files.

E. REPORTING

ACCIDENTS: The Project Manager is to promptly inform line management of any accidents, injuries, or occupational illnesses that occur on the project for determination of reporting requirements. Significant construction safety events may require DOE Occurrence Reports (refer to PUB-3000, Chapter 15, for requirements). In case of serious accidents, the worksite must remain undisturbed until the proper LBNL authorities have been notified and the accident site has been released for work by the EHS Division.

F. JOBSITE POSTINGS

When jobsite activities require them, the Construction Manager is responsible for posting at each jobsite current approved copies of documentation (refer to Construction Subcontractor Safety Handbook), including:

1. Safety Checklist

2. Job Hazards Analysis (JHA)

3. Fire Safety (Burn) Permit

4. Permit to Penetrate or Excavate Surface of LBNL Property

5. LOTO Permit and/or Energized Electrical Work Permit (EEWP)

6. Energized Electrical Testing Permits (EETP)
7. Radiological Work Permit (RWP)

If a project is using a subcontractor safety plan, it should be on site in the job trailer or job box, so that it is available for inspection. Job information boards listing LBNL project team contact information, subcontractor contact information, permits currently in effect, and other safety information should be posted at the main jobsite entry.

G. PERSONAL PROTECTIVE EQUIPMENT (PPE)

1. PPE GENERAL REQUIREMENTS

In keeping with the division’s commitment to achieving a no-injury workplace, supervisors are responsible for ensuring that employees are trained in the proper selection, use, and limitations of PPE.

Supervisors are responsible for making available all needed PPE to employees.

Employees are responsible for using, maintaining in good condition, and reporting the need for additional PPE to their supervisor.

Questions regarding PPE may be addressed to an employee’s supervisor or to the Facilities Safety Coordinator.

DCM personnel entering an active construction site are required to follow all jobsite postings and to wear, at a minimum:

• Hard hat: regardless of whether the worksite is posted as a “hard hat area” or not.

• Safety shoes (protective footwear): Employees who work primarily at construction sites, such as inspectors and superintendents, are required to wear safety-toe shoes (refer to Safety Shoes, below). Occasional visitors to the jobsite may wear supportive, sturdy sole shoes instead of safety-toe shoes, but must not enter areas where active construction is in progress. The use of open, soft, or high-heeled shoes is not permitted at construction sites.

• Safety glasses: Eye protection must be worn when entering construction areas. Safety eyewear or “visitor safety glasses” shall be worn over prescription eye glasses. Side shields may be worn in lieu of safety eyewear as long as lenses on the prescription glasses are impact- resistant. LBNL employees can receive an eye examination and obtain prescription safety glasses free of charge through Health Services (ext. 6266).

• Hearing protection: Ear plugs or ear muffs must be worn when entering high-noise-level areas. Pre-shaped foam ear plugs are recommended for this purpose. They are small, easy to carry, and provide protection against most construction noises.

• Reflective vests: Reflective vests must be worn when working around heavy construction vehicles or mechanized equipment, when working outdoors in areas of limited visibility, or on or around roadways.

• Appropriate clothing: Loose-fitting garments or jewelry that can be caught in moving machinery or any part of the work under construction should not be worn. This is particularly important when entering mechanical or other equipment rooms. Shorts and tank tops are not appropriate attire for construction areas. Long pants should be worn.

References:

CFR 29, 1926, Subpart E, Personal Protective and Life-Saving Equipment PUB-3000, Chapter 3, Health Services

PUB-3000, Chapter 10, Construction Safety

PUB-3000, Chapter 19, Personal Protective Equipment

       2. SAFETY SHOES

Facilities Division employees are required to wear safety shoes. Supervisors are responsible for implementing this policy and ensuring that employees fulfill their responsibility.

LBNL encourages the wearing of safety shoes by making them available to all employees at cost and delivered by the manufacturer’s Shoe Mobile. For certain types of work, wearing safety shoes is required by LBNL Policy or by federal regulations (29 CFR 1910.136), as specified in American National Safety Standard Z41.1. Examples are work that exposes employees to foot injuries   from hot, corrosive, or poisonous substances; work in shops, in equipment handling, or in construction jobs where there is a danger of falling objects; or work in abnormally wet locations.

a. Employees’ Responsibilities

If the employee’s current classification (duties/responsibilities) requires that s/he wear safety shoes to perform his/her primary job duties (crafts, custodians, truck drivers, material handlers, etc.):

Employees shall arrive at the start of their shift with their safety shoes on.

If in the event an employee is found not wearing safety shoes during an assigned shift or when in a location where they are required, the employee shall be told to stop work, get his/her safety shoes, and put them on. If an employee needs to go off site to obtain safety shoes, the time off site shall be considered time away from the Laboratory and shall result in loss of pay.

For employees who are required to wear safety shoes on limited or specific occasions, such as project managers when they go to active construction sites, employees must have their safety shoes available on site.

b. Accountability

Violations of this safety shoe procedure will be noted in the annual performance review/evaluation. Failure to comply with this internal safety shoe procedure may also lead to disciplinary action, up to and including termination.

c. Procedure for Obtaining Safety Shoes:

LBNL shall subsidize safety shoe purchases up to the current authorized amount of $120 one time per year. If the shoe cost exceeds the authorized amount of $120, the employee shall pay the difference to the vendor (cash, check, or credit card). LBNL also allows for a payroll deduction for the amount exceeding the authorized LBNL allowance ($120).

A Safety Shoe Request Form (available from the Work Request Center) must be submitted to an employee’s supervisor for issuance of safety shoes.  The supervisor shall be responsible for clarifying the shoe type, justification for issuance, and approval for the request (signature) prior to the shoes being purchased.

The supervisor shall validate that the employee has not been issued a pair of safety shoes during the last year. Note: The date on which the Safety Shoe Request Form is approved by the supervisor is taken as the start of the tracking year for safety shoe allowances.

At the time of purchase, the vendor will take appropriate copies of the Safety Shoe Request Form and give the employee two copies (employee and supervisor/approver). The employee must immediately return the Approver copy to the supervisor to validate that the appropriate type of shoe was purchased. The supervisor will then return the form to the Work Request Center.

Employees may retain or discard their copy.

If within one year from the date of purchase the safety shoes show significant wear and tear or are defective and could compromise the safety of the employee, the supervisor should verify the need to replace the safety shoes and submit a safety shoe issuance form, with a written justification for replacement.

SAFETY HANDOVER TO OPERATIONS

Prior to taking beneficial occupancy of the project, the project team shall complete the Project Turnover (Beneficial Occupancy) letter. This document formally transfers the responsibility for safety to the operating entities. Turnover refers to the official and documented project turnover to Operations. Turnover requires acceptance and sign-off by the Operations Manager and the Operations Team Lead (as designated by the Department Head of Operations), and Project Commissioning Team Lead. Official sign-off is implemented through the Project Turnover to Operations Memo.

The responsibility for safety will be transferred to:

1. the client for program operations and scientific-related items, and

2. to Facilities Operations for building systems maintenance-related items.

SAFETY TRAINING

It is LBNL policy, and required by federal law, that all staff, participating guests, visitors, and others who perform work at, or for, LBNL receive the training necessary to protect their health, and to perform work in a safe and environmentally sound manner. This training must include information regarding job hazards, possible health effects, and required work practices and procedures.

Line managers are responsible for analyzing the work of all those under their direction and for ensuring that the proper training for safe conduct of the work is identified and completed. Until an individual has been properly trained, s/he will work under the direct supervision of someone who is already trained. Employees are required to maintain general and job-specific training so that they can work safely, under Integrated Safety Management guidelines. Workers should follow their Job Hazards Analysis to identify potential hazards and train accordingly (refer to PUB- 3000, Chapter 24).

LESSONS LEARNED

Providing feedback under ISM principles allows for continuous improvement, as hazards are analyzed, information on the adequacy of controls is gathered, and line and independent oversight is conducted in order to develop and implement safety measures in the workplace.

At the completion of a project at a minimum, the Project Manager will call a meeting of the Integrated Project Team to review its performance and look for opportunities to improve upon the process in future work. Safety is a crucial component of any Lessons Learned meeting.

The Project Director, Project Manager, other line managers, and individual workers are expected to provide feedback as appropriate. Procedures, practices, tools or equipment that can be adjusted or improved should be identified and discussed. All procedures, practices and controls should be updated and communicated.

EHS/FACILITIES GUIDELINES FOR RENOVATION & CONSTRUCTION PROJECTS

Project Kick-off

• Facilities assigns team (Project Manager, architect, mechanical, electrical, structural, Construction Manager, and inspector)
• EHS assigns Team Lead and EHS Subject Matter Experts as needed
• Project Team determines method of documenting the Hazards Analysis process; a Safety Analysis Document, Hazards Analysis Report or other tailored approach.
• Facilities conducts opening meeting with client and EHS
  • Discusses scope of work, commissioning planning, renovation process, duties, potential contamination issues, responsibilities, and how project design, demolition, construction, commissioning, and inspection will proceed
  • Organizes walk-through of space, conducted with all parties
  • Client describes activities, equipment needs and anticipated chemical or other hazardous material or equipment usage
    • Industrial Hygienist can provide current inventory beforehand – client needs to update
    • Chemical usage has impact on controls
    • Fire Marshal analyzes impact of projected chemical / hazardous material usage on fire control areas if existing structure is involved with project

• • Industrial Hygienist explains the role of EHS and informs client
    • Preliminary idea of controls needed based on client input
    • Area needs to be cleaned before renovation begins
    • Safety equipment should be upgraded (hoods, eyewash/showers, and storage)
  • EHS Subject Matter Experts discuss other environment, health, safety and security issues as necessary.
    • The Project Manager and EHS Team Lead determine whether a project specific Soil Management Plan and/or a Site Characterization Study are required.
    • The Project Manager and EHS Team Lead determine whether a project specific Storm Water Pollution Prevention Plan are required.
    • The Commissioning Director is accountable for creating project based Cx Teams and for capturing and disseminating commissioning related Lessons Learned.

Develop Design Drawings and Specs

• Facilities develops the BOD, design drawings, schedule, and budget including commissioning activities

  • Current standards, codes, and specifications 

  • Facilities Specs (e.g., fume hood spec)

  • Use “standard details”

• Client, Industrial Hygienists and other EHS personnel, and the iCxA and/or Cx Team, review and provide written comments to Facilities

• Facilities addresses and resolves each comment

  • Incorporate comments directly into drawings and specs. Includes asbestos, lead and mercury controls.

  • Show revision number and/or date on updated drawings

• Equipment schedule and budget reflects design review comments made

  • Parties review final design package, concur, and sign off

Area Preparation

• Client cleans laboratory: waste, sharps, excess chemicals, equipment, debris and residues

• Space owner requisitions Waste Management to handle/remove excess chemicals/wastes

• Industrial Hygienists and Radiological Control Technicians perform final inspection

• Facilities conducts/contracts out necessary abatement before area demolition

Demolition and Construction – Space Released to Facilities

• Transportation moves equipment, unopened chemicals and furnishings from LBNL

• Waste Management moves opened chemicals

• Demolition and construction begin

• Demolition activities follow Approved Deactivation Plans and Site Characterization Study

• Installation of equipment and furnishings

• Facilities monitors progress of renovation and installation of equipment through regular inspections (to ensure proper installation in accordance with code)

Punch List Walkthrough

• Facilities organizes “Punch List” walk through (renovation must be near completion)

• All parties (including EHS) participate at same time

• Facilities responds to and corrects each issue identified