The Safety Professionals Guide to Planning and … Safety Professionals Guide to Planning and...

The Safety Professionals Guide to

Planning and Executing Capital

Projects

Steven M. Hochstadt, P.E., CSP

Sr. Environmental, Health & Safety Manager

Bay Area Safety Symposium

American Society of Safety Engineers

March 5, 2014

Introduction

Responsibilities of EHS Managers

Regulatory Compliance

Program Development

Audits & Inspections

Hazard Control

Claims Management

Plan Review - Projects

Safely Planning & Executing Capital Projects 2 March 5, 2014

Definitions

Capital Projects: A long-term investment made in order to build upon, add to or improve on a capital-intensive project. A capital project is any undertaking which requires the use of notable amounts of capital, both financial and labor, to undertake and complete. Capital projects are often defined by their large scale and large cost relative to other investments requiring less planning

and resources. (Investopedia)


Definitions (con’t)

Screening - is the investigation of a great number of something (for instance, potential EHS issues) looking for those with a particular problem or feature.

Capital Projects – Requires investment of >$10M.

Screening Tools – Used to identify

critical EHS aspects or risks

of a project.


Types of Projects

New building construction

Building demolition

Major lab renovations (exhaust,

waste systems, new equipment)

Seismic & safety retrofits (ADA, Code Updates)

Installation, or replacement, of key building systems (fire prevention, alarms, security)

Site improvements (café, fitness, conference)


Project Teams Capital projects are usually delivered using a prescribed process by a project-specific cross functional team of stakeholders, including:

Business unit/end user (Customer) Project Management/Engineering Facilities Planning & Services Risk Management & Compliance Finance Reliability, Validation, QA EHS Consultants & Contractors


Screening Tools EHS screening checklist can vary depending on size

& complexity of project

Small (non-capital) projects may require a quick review of general EHS categories

Capital projects require a more comprehensive review of all EHS aspects & risks

Usually completed by EHS &

Project Manager during Basic

or Conceptual Design Phase.


Use of Screening Checklists

Used to identify various EHS aspects of the project.

Will help Project Manager budget for the EHS items identified.

Will require planning & follow-up by EHS Project Manager to assure proper permits are obtained and compliance achieved.

Used to determine EHS strategy &

plan and for project documentation.


EHS Aspects All projects are evaluated for potential EHS impacts & risks during Conceptual Design including: Fire/Life Safety – fire/gas detection, alarms, egress Physical Safety – electrical, noise, eqpt, ergonomic layout Hazardous Materials – storage & distribution systems Chemical/Industrial Hygiene – lead, asbestos, chemical, bio,

radiation exposures and exhaust ventilation Environmental – hazardous wastes, emissions, soil, GW, SPCC, storm water & wastewater Process Safety – hazard control, eqpt review Sustainability – energy, recycling, refrigerants


You have the List, Now What? Use the aspects identified on the list to:

Determine EHS Strategy – How am I going to mitigate the issues, keep the project on schedule, within budget and obtain all permits?

Are consultants needed? What type? Who?

Is in-house support available (SMEs)?

Which permits are needed? What data is

required?

Which agencies need to be contacted?

Contractor Selection: Skills Required,

Safety Record.


EHS Project Support

Plan Review

Contractor Selection & Audits

Site Inspections

Accident/incident investigations

Site permits & agency inspections

Equipment review & commissioning

Program development & training


Plan Review

Fire code – alarms, pull stations, exits, signage

Gas & fire detection – smoke, O2, NH3, explosion

Safety eqpt – shower/eye wash, first aid, rescue, fire extinguishers, PPE & spill cabinets.

Haz mat & waste storage, classifications

Safety – railings, barriers, signage

Waste collection & treatment

Ergonomics & material handling

Environmental – spill containment


Contractor Selection

Need to do your due diligence

Services available to provide

review criteria……for a fee

IIR, Xmod, OSHA history

Insurance coverage & certificates

IIPP & Written Safety Programs

Organizational Structure, Policies & Staff

Experience on similar projects


Contractor Safety Plan Review

Review their plans & written programs:

Is their IIPP site & project specific?

Are the written programs adequate & applicable to the project?

Does their Emergency Plan address

reasonable contingencies for location?

Do they have proper training & records?

Are inspection records maintained?

Job safety analyses for all hazardous tasks?

Yes, subcontractors must be included!


Written Safety Programs IIPP – project specific, most important

Job Safety Task Analyses & hazard controls

Training Program

Emergency Plan – site specific, first aid, fire, injuries

Hazard Communication with MSDSs on-site

Fall prevention, confined space, PPE,

excavation, ladders/scaffolds, hot work, subs,

LOTO, fire prevention, industrial trucks, injury

reporting, and many more as applicable to project

****Review, and if NOT satisfactory, request revisions, as these written programs are the Contractors “Commitment to Safety”


Inspections Auditing the Contractors “Commitment to Safety”

Review the implementation of their written plans

Check inspection, training, incident & JHA records

Perform site inspection with Contractor’s Safety Rep

Observe behaviors, as well look for hazards

Use checklist for documentation & forward to Safety Rep

Request corrective actions & follow-up

Provide praise as needed, as construction sites

are full of potential hazards & contractors

have key investment in project’s safety.


Inspection Checklist Must meet Construction Safety Orders: 29 CFR 1926 & CCR Title 8, Subchapter 4

Look for the following, indicate S, U or N/A: PPE, what’s required & are they wearing it? Emergency/first aid – eye wash, first aid kits, fire

extinguishers, exits marked & not blocked, postings with emergency phone #s

Hazardous materials – MSDSs, storage, labels, flam liquids, spill eqpt, compressed gases, gas monitoring

Ladders, stairs, scaffolds, floor openings, power tools Permits (site & regulatory) – excavations, hot work, lifts,

industrial trucks, confined spaces Electrical – GCFI, grounding, cords, LOTO, panel labeling Housekeeping – Not a clean room. Clear egress. ID hazards.


Construction Safety Training The OSHA Outreach Training Program:

Training on the recognition, avoidance, abatement, and prevention of safety and health hazards in the construction industry.

Voluntary program, does not meet training requirements for any OSHA standards.

Reviews key sections of CFR. Delivered by OSHA-authorized trainers.

The 10-hour class is intended for entry level workers,

The 30-hour class is more appropriate for supervisors or workers with some safety responsibility.

Classes offered at ASSE PDCs & NSC Congresses http://www.osha.gov/dte/outreach/construction/index.html


http://www.osha.gov/dte/outreach/construction/index.html



Consultants

Why Do you Need Them?

How Do You Select Them?

Preparing RFQ/SOW & Reviewing Quotes .

Who’s Doing the Work?

Do’s & Don’ts.

Checking on Progress.

Deliverables.

YOU ARE Responsible for your Consultants!


The Safety Professionals Guide to Planning and Executing Capital

Projects

Case Study # 1

Construction of a New Research Building


EHS Screening Checklist Project Description

Project Title Location Project Manager Project Team Members Funding Approval Estimated Start & Finish dates Brief Description – Planned use, square

footage, acreage, number of floors, etc.


Project Scope Are contractors needed? Is GC selected? Yes

GC TBD. Several sub contactors to be used.

Is demolition needed for existing structures? NA.

Is building or space to be remodeled? NA.

Will there be soil excavation? Yes. Soil to be tested prior to disposal.

Will fire alarms, suppression system or walls be impaired? NA. New building.

Will new property be purchased or leased?

Yes. Property purchased. Check prior usage. Phase I

ESA? Safely Planning & Executing Capital Projects 22 March 5, 2014

Hazardous Materials Will hazardous materials be used during project? Yes,

as needed for construction. HMBP submitted by GC.

Will hazardous materials be added after project? Yes, as needed for research. HMBP submitted by EHS.

Will hazardous wastes be generated during or after project? Yes. EPA Generator ID# for research wastes.

Will project change hazardous materials used in existing processes? NA.


Equipment

Will existing utility systems (drains, piping, electrical, HVAC) be altered? No. New building.

Will removing existing equipment require hazardous waste disposal? NA.

Is new equipment added for exposure control or haz mat containment? Yes. Exhaust vents, hoods.

Will new eqpt added create hazards? Yes. Evaluate.

Will sewer or storm systems be modified? Yes. New sewer connections to be made.

Will permanent safety equipment be added? Yes. Fire extinguishers, first aid kits, shower/eye wash, AEDs.


Physical Hazards Will new energy sources be involved? Yes. Eqpt &

processes require steam, heat, pressure & electricity. LOTO.

Will there be hot work (welding, brazing, grinding)? Yes. Hot work permit required.

Off hours construction, noise, dust concerns? Yes. As typical in construction. Few neighbors in area. Use controls.

Confined space entry required? Yes. Excavations.

Fall protection needed? Yes. Unprotected elevations.

Overhead work? Yes. Cranes, lifts & ladders.

Will changes be made to exits or egress routes?

NA. New building.


Environmental

Will there be discharge of industrial wastewater? Yes.

Use process knowledge to characterize discharge. Apply for permit.

Will there be air emissions (VOCs, Toxics)? Yes. Review eqpt specs. Hire air consultant. Apply for permits from AQMD.

Will there be generators or boilers? Yes. Special permitting & monitoring requirements. Source testing required per AQMD.

Will there be haz wastes requiring disposal? Yes. Typical lab wastes. Apply for EPA ID #. Hire waste handling & disposal contractor.

Will there be haz mat storage in tanks? Yes. Gases, fuel & treatment chemicals. Add to HMBP, SPCC.

Will haz mats be handled near storm drains? Yes. Need containment, spill control plan (SPCC) & SWPP.

Will lead or asbestos be disturbed? NA. New construction.


EHS Issues

Hazardous Materials & Waste Permits

HMBP filed with County, multiple inspections

Secondary containment required in utilities area

Typical lab quantities & hazard classes (FL, CL, NFG, Corr)

ABTs for fuel and cryogenic liquid storage

Waste storage room with secondary containment, gas detectors, alarms, emergency eqpt

EPA Generators ID# obtained for site

Emergency Response Plan prepared & Team formed

Waste collections & inspections performed by contractor


EHS Issues Waste Water Permit

Strict discharge limits due to Regional GW issue

Concerns with pH, salinity, minerals, temp, flow

Process, sanitary & industrial waters modeled for discharge, using various conditions

Treatability study to select neutralization system

Application submitted, amended, negotiated

Interim permit granted. Flow limitations.

Extended sampling program. Flow meter issues.


EHS Issues Air Permits

Boilers, heaters, generators

Consultant used to file permit applications

Risk Assessment & Air Dispersion Model - contours

Initial & Annual Source Testing (CO, NOX, O2, CO2)

AQMD site inspection – during source testing

Permit issued with conditions

Annual reporting & testing (operating hours, gas use)


EHS Issues SPPC & SWPP

Oil and fuel tanks present (>55 gal)

Spill prevention plan written (CA – APSA)

Site inspection & training programs

Fueling, drainage & spill procedures

Shut off valves & covers for storm drains

Catchment drains at loading docks

Storm water runoff to private basin

No permit reqd. Lease agreement controls (BMPs)



Projects Case Study # 2

Demolition of Old Research Building


EHS Screening Checklist Project Scope

Are contractors needed? Is GC selected? Yes. GC TBD. Several sub contractors to be used. Support selection process.

Is demolition needed for existing structures? Yes. Structures & utilities to be demolished. Select demo contactor.

Is building or space to be remodeled? Yes. Site to be used for parking lot.

Will there be soil excavation? Yes. Test soil prior to disposal.

Will fire alarms, suppression system or walls be impaired? Yes. At some point, system to be disconnected.

Will new property be purchased or leased? NA.


Hazardous Materials Will hazardous materials be used during

project? Yes. Labs & eqpt to be decontaminated using various cleaning solutions.

Will hazardous materials be added after project? No.

Will hazardous wastes be generated during or after project? Yes. Decontamination wash waters, lab wastes and surplus chemicals to be collected for off-site hazardous waste disposal.

Will project change hazardous materials used in existing processes? NA.


Equipment

Will existing utility or eqpt systems (drains, piping, electrical, HVAC) altered? Yes. All utilities to be removed.

Will removing existing equipment require hazard waste disposal? Yes. All equipment to be decontaminated.

Is new equipment added for exposure control or hazardous materials containment? NA.

Will new eqpt added create hazards? NA.

Will sewer or storm systems be modified? Yes. Cap.

Will permanent safety equipment be added? NA.


Physical Hazards Will new energy sources be involved? No.

Will there be hot work (welding, brazing, grinding)? Yes. Cutting. Hot work permit required.

Off hours construction, noise, dust concerns? Yes. Adjacent building occupied. Controls to be implemented.

Confined space entry required? Yes. Trenches. Non-permit.

Fall protection needed? Yes. Eqpt required while on roof.

Overhead work? Yes. Cranes, lifts & ladders.

Will changes be made to exits or egress routes? Yes. Changes made during various phases of demolition.


Environmental Will there be discharge of industrial wastewater? No. Terminate

existing discharge permit.

Will there be air emissions (VOCs, Toxics)? No. Asbestos.

Will there be generators or boilers? Yes. Clean, remove & dispose. Terminate air permits.

Will there be hazardous wastes requiring disposal? Yes. Decontamination wastes & lab surplus chemicals to be collected & disposed.

Will there be haz mat storage in tanks? Yes. Drain, clean & remove above ground fuel tanks.

Will haz mats be handled near storm drains? Yes. Cover drains. Prepare storm water plan for construction project.

Will lead or asbestos be disturbed? Yes. Hire licensed contractors to sample and test, and to remove and dispose. File permit.


EHS Issues

Haz Mat Decontamination

SOW. Quotes from qualified contractors. Decontamination and Health & Safety Plans prepared. All eqpt drained & surfaces to be decontaminated. Hoods & ducts cleaned or removed as hazardous waste. Chemical & biological hazards. Surplus chemicals & contaminated supplies collected. Decontamination rinse waters collected for disposal. Wipe samples taken for analysis (pH, CAM 17 metals). Site inspections by CUPA. Closure report sent to CUPA. Permits retired.


EHS Issues Asbestos & Lead

Present in older buildings (pre 1970s). Must be abated prior to demolition permit issued. Survey performed, samples taken by certified sampling

contractor (CAC). Analysis at approved lab. Abatement report with results, locations & estimated

quantities. Bid documents for abatement contractor. Abatement by licensed asbestos removal contractor.

Permit required. Warning signs posted at site. PPE. Containment required.

Disposal at Class 1 or 2 landfill. Approved hauler. Manifest to be included in final report.


EHS Issues Soil Sampling

Soil data needed due to excavation, disposal & worker

exposure needs, and to determine prior spills.

Required for site HMBP closure.

Potential sources – fuel tanks, lab waste discharge.

Contractor with subsurface sampling experience hired.

Borings made around all sides of bldg. Samples at multiple depths. Analyzed for VOCs, metals, etc.

No contamination found. No further action needed.

Report provided to CUPA. Safely Planning & Executing Capital Projects 39 March 5, 2014

EHS Issues

Equipment Disposal

Much eqpt, tools & supplies left as surplus. If contaminated, clean, or dispose as

hazardous waste. Tools & supplies distributed to depts & ee’s. Larger eqpt gets sold to brokers, dealers. Many require certificate of decontamination. Sales contracts reviewed by Legal Dept. Buyer to transport. Assure eqpt is “safe off”.



Projects Conclusions

EHS has a key role in Capital Projects. EHS is involved with Project Team early in design. EHS evaluates risks by “screening” project. EHS develops plan to mitigate risks. EHS obtains all permits & works with all agencies

& inspectors. EHS assists with project turnover. EHS works with the Project Team & all contractors

to assure project’s safety & success.



Projects Q&A?

Thank you for attending. Steven M. Hochstadt, P.E., CSP


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