Construction / Renovation Safety Program
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1 Construction / Renovation Safety Program Prepared by: Environmental Health and Safety 11/3/ Commonwealth Avenue 85 E. Newton Street, M-470 Boston, Massachusetts Boston, Massachusetts (617) (617)
2 1. Purpose and Scope 1.1. The purpose of this program is to describe the process of developing project safety plans that identify potential hazards and the interim safety measures that minimize those hazards and disruptions during renovation or construction activities. It is intended to ensure an adequate level of safety when existing safety measures are disrupted due to work in an area. This plan applies to internal and external work Whenever possible this document will be provided in project bid packages. 2. References 2.1. Regulations Local Boston Fire Code Brookline Fire Code Cambridge Fire Code State Massachusetts State Building Code, CMR 780 Massachusetts Fire Prevention Regulations Massachusetts Department of Environmental Protection, 310 CMR 7.15 Asbestos Massachusetts Department of Environmental Protection, 310 CMR Hazardous Waste Federal Occupational Safety and Health Administration, 29 CFR 1910 Environmental Protection Agency, 40 CFR Part 745, Lead; Renovation, Repair, and Painting Program Guidelines and Standards National Fire Protection Association (NFPA) NFPA 101 (Life Safety Code) NFPA 10 (fire extinguishers) National Electric Code National Plumbing Code 2.2. Related Programs Asbestos Management Plan Fire Response Plan Laboratory Decommissioning Plan Control of Hazardous Energy (LOTO) Confined Space Entry Lead Management Plan Page 2 of 19
3 3. Definitions 3.1 Construction and demolition is defined as any physical change which involves the wrecking, taking out, removal, stripping of, or altering of a building structure or appurtenances. Appurtenances such as, but not limited to; HVAC equipment and components, piping, boilers, condensate tanks, lighting, and all building operations equipment. Boston University further defines construction as all new construction or any project that involves the removal of load bearing walls, partitions or smoke/fire walls and/or the erection of same or any work which compromises the Life Safety Code. In addition, any project which involves hazardous materials, or in the opinion of a representative of the EHS or the BU/BMC Construction Project Manager, has the potential for providing a hazard that could compromise safety, shall be considered a construction project requiring the implementation of one or more measures outlined this Program. Please Note: A Department of Environmental Protection (DEP) notification is required for demolition activities. Please see Appendix VII for its use and application. 3.2 Interim life safety measures (ILSM s) are administrative or physical systems to temporarily compensate for fire hazards posed by construction activities. ILSM s to be implemented during projects will be determined during the pre-construction planning meeting with EHS, the BU Project Manager and involved contractors or FMP trades personnel. Identified ILSM s apply to all personnel, including construction workers, and are assessed for implementation upon project development, and enforced through project completion. One or more ILSM s may be implemented as defined in this program. 4. Roles & Responsibilities Environmental Health and Safety (EHS) is responsible for determining the level of implementation of this plan. EHS will determine what safety measures including ILSM s will be used and to what degree and will determine if the potential for disruption in sensitive areas (patient care, research, etc) requires unique measures EHS will periodically inspect the project for proper implementation of the plan. Facilities Management and Planning (FMP) is responsible for identifying a Project Manager for activities performed by internal or external staff that constitute Construction Demolition as defined in Section 3.1. FMP will ensure all interim measures are in place for the duration of the project. FMP will distribute construction and design coordination meeting minutes identifying work being planned. Information Services and Technology (IS&T) is responsible for identifying a Project Manager for activities performed by internal or external staff that constitute Construction as defined in Section 3.1. IS&T will ensure all interim measures are in place for the duration of the project Page 3 of 19
4 BU Project Manager is responsible for ensuring the implementation of this plan and any other related BU policy or procedure. The Project Manager will report any variations or violations of the plan to EHS. A Project Manager is any BU employee, from any department, who is responsible for any renovation, cosmetic, construction, utility, or infrastructure improvement project. Contractors and BU Employees and Staff will comply with this plan, applicable regulations and standards, and other related BU policies and procedures. 5. Special Requirements 5.1. Equipment and Supplies Required As dictated by the development of the site specific safety plan under this plan Safety Requirements See Procedures, section 7 of this plan Training Contractor / Worker Training. Prior to commencing work on any construction project the Project Manager and the Principal in charge of each contracting firm on the project will read, acknowledge and sign the Contractors Agreement. They will also be responsible for ensuring that all project workers (in-house or contractors) have each been trained on the site specific safety plan Contractors and vendors will be provided appendix III which lists safety rules when working in laboratories and patient areas Monitoring Requirements Projects requiring negative air containment will be checked continuously by the General Contractor or BU FMP project manager. A magnehelic monitor or similar device installed directly adjacent to the entrance door of the project area. Monitor device readings shall be posted on a log sheet posted on the Board Personnel Protective Equipment (PPE) Will be reviewed and discussed at the preconstruction safety meeting. 6. Applicable Locations 6.1. This plan currently applies to renovation and construction projects at Boston University Page 4 of 19
5 6.2. This plan applies to all BU personnel and contractors performing work in any BU building or on BU property, including leased space. The level of implementation of this plan will be determined by EHS in cooperation with the BU Project Manager and will be administered by both EHS and the assigned BU Project Manager and Contractor representative, if applicable. 7. Procedures and Instructions 7.1. Construction and Design Coordination Meetings will be hosted by FMP and will include representatives of all areas that may be impacted by scheduled work Project Notification. BU Project Managers are responsible for notifying EHS before the start of any renovation or construction project. In addition, an EHS representative will attend scheduled FMP Construction meetings to assist in determining if a project requires a specific construction safety plan. As new projects are planned and discussed, the EHS representative will assess if a project requires a specific safety plan. The construction minutes will reflect if a project has been waived of a site specific plan or if a safety planning meeting has been scheduled Project Safety Planning. The BU Project Manager will request a safety planning meeting with EHS to review the scope of work and develop a site specific safety plan through the Preconstruction Risk Assessment. The safety plan including any identified ILSM s will be documented. The BU Project Manager will schedule the appropriate project contractor(s) and / or FMP staff conducting related project tasks for meeting attendance. These meetings may also be requested by EHS during the construction meeting Work Stoppage. EHS is authorized to stop work on any project which is not adhering to the agreed upon safety plan. Prior to shutdown, notification shall be made to FMP Leadership, the Project Manager, the Director of Campus and Clinical Safety, the Executive Director Research Compliance, and if necessary the Associate Vice President Research Compliance and the Assistant Vice President, Campus Construction. The BU Project Manager will modify the scope of work or project schedule to maintain compliance with the safety plan. Any modifications will be reviewed by EHS prior to resumption of construction activities. EHS has the authority to stop any work that is immediately dangerous to life and/or health. Notifications to those listed above will be made as soon as practical Inspections. An inspection of the construction area and surrounding areas may be conducted by EHS on a weekly basis depending on the scope of the project. The inspection will be documented utilizing the EHS Safety Information Management System (SIMS) should deficiencies be noted. All deficiencies will be reported to the Project Manager or designee for timely correction. Deficiencies that are immediately dangerous to life and/or health will be corrected immediately and reported directly to the BU FMP Project Manager, Director of Campus and Clinical Safety and FMP Leadership Page 5 of 19
6 7.6. Signage. The contractor will be responsible for posting proper warning notification (signage) at all entrances to the work site. The signage shall state: Construction Zone Authorized Personnel Only. The Project Manager or if directed by the Project Manager, the Contractor will install a construction safety board where all applicable permits, this risk assessment and other related safety information will be installed at the worksite entrance Permits. Obtaining and posting all required permits will be the responsibility of the contractor unless otherwise decided. Permits include but are not limited to: City Building Department, Local Fire Department, Department of Environmental Protection, Life Safety system impairments, use of torches, a copy of this safety plan, etc. Construction will not begin unless permits are on site. Copies of the permits will be posted at the job site and forwarded to the BU Project Manager and EHS, as requested. A Board will be used to post all applicable permits. It is ultimately the responsibility of the BU Project Manager that all necessary permits are obtained and posted Fire Watch. Whenever welding or cutting is anticipated, a paid local fire department detail is required. In other instances, such as, major fire alarm or fire sprinkler system impairment or malfunction, an internal qualified fire watch, other the local Fire Department personnel may be used if approved by the local Fire Department Flammables. Flammable products and materials will be properly stored in a flammable storage cabinet. A permit will be obtained through the BFD for the storage or use of flammables, per applicable BFD regulation. Only materials containing no or low Volatile Organic Compounds (VOC S) shall be used (painting materials, etc...) Compressed Gases. All compressed gases will require a BFD Permit, per applicable regulation. Flammable compressed gases are prohibited from storage inside buildings Laboratory Animal Housing Areas. All work that may involve disruption to normal operations in Laboratory Animal Housing Areas will require coordination with representatives from that area in order to minimize disruption to those operations Hazardous Materials. All hazardous materials must be considered, including hazardous materials within building materials such as asbestos and lead based paint. EHS Industrial Hygienists must be coordinated with through this plan to assess building materials that will be impacted by the project. Other hazardous materials must be considered especially when working in or around laboratories. For the purpose of this plan, hazardous materials include; certain building materials, chemicals, radioactive materials, chemotherapeutic, biological, and universal wastes. Chemical decontamination and hazardous waste disposal must be coordinated with EHS. Any radioactive decommissioning must be coordinated with Medical Physics and Radiation Safety Page 6 of 19
7 7.13. Contractor Parking. Contractors are permitted to park in authorized areas only. Parking is not allowed on sidewalks, fire lanes, or in front of fire hydrants. Vehicles parked in unauthorized areas will be towed at the owner s expense Dust Control. Every effort will be made to control dust and debris from the project area. Control measures include, but are not limited to barriers, negative air machines, dust control walk-off mats, sealing unused doors, damp mopping between tasks, High Efficiency Particulate Air (HEPA) vacuums with dust generating tools, and sealing air intakes as appropriate. Determination of these control measures will be discussed at the pre-construction safety meeting Interim life safety measures (ILSM s) will be considered for all renovation and construction projects, including demolition phases, to temporarily compensate for hazards posed by construction activities. ILSM s to be implemented during the project will be determined during the pre-construction planning meeting with EHS, the BU Project Manager and involved contractors. Identified ILSM s apply to all personnel, including construction workers, and are assessed for implementation upon project development, and enforced through project completion. One or more of the following ILSM s may be implemented for the duration of the project unless otherwise stated Egress. Any areas under construction and other affected areas must maintain exits at all times. Exit routes in affected areas may be inspected on a daily basis. This will be determined during the pre-construction safety meeting. The BU Project Manager, construction company representative, or EHS will conduct these inspections if egress is affected by the project. The Daily Egress Inspection Form shall be posted at the job site and signed daily, as determined during the planning meeting or requested by EHS. The inspection will ensure that the egress is free and unobstructed and smoke/fire doors are fully operational. Personnel in or around the area shall receive training if alternative exits must be designated Life Safety Systems. Temporary but equivalent fire systems will be used when systems are impaired. Fire systems include fire alarm, detection and suppression systems. Fire systems shall not be impaired for more than four hours. During the four (4) hour period, an authorized BU representative will be on standby at the impaired system control to initiate system reactivation in the event of building fire alarm system activation. The BUMC Control Center or BU Control Desk, and the designated BU Impairment Coordinator will be notified. Impairments longer than four (4) hours will require submittal of an Impairment Plan to the BU Impairment Coordinator for input and approval. A permit will be required for the impairment. Prior to requesting a permit for system impairment, EHS will also be consulted with the specifics of the method of impairment, equivalent measures, and duration. Impairments may require installation of a temporary, but equivalent, system. Temporary systems will be inspected and tested monthly by the appropriate licensed trade as necessary. The completion date of the tests will be documented Page 7 of 19
8 Fire Extinguishers. Additional fire-fighting equipment shall be provided as necessary and determined during the pre-construction safety meeting. Additional fire extinguishers will be provided by the contractor and will be maintained per the NFPA10 Standard. Maintenance shall include: Adequate number and type, placement for access, tamper seal, pull pin, gauge reading, label, weight, and nozzle/hose in place and undamaged. Construction personnel shall be properly trained on the use of firefighting equipment by the appropriate contractor representative. Extinguishers will be inspected monthly and serviced annually. Documentation will be provided on the extinguisher by use of a tag Construction Barrier. Temporary (hard) construction partitions that resist the passage of smoke will be noncombustible or made of limited-combustible material that will not contribute to the development or spread of fire. The need for barriers will be determined during the pre-construction safety meeting. The construction partition, including any doors or windows, must be maintained at all times until project completion. Use of additional dust barriers is considered a temporary enclosure, per fire department regulations. A permit is required for such use. Note: Polyethylene (Plastic) enclosures are not a substitute for a hard noncombustible construction partition Inspections. Increased surveillance of buildings, grounds, and equipment giving special attention to construction areas and storage, excavations, and field offices are conducted as necessary and determined during the pre-construction safety meeting. An inspection of the site will be conducted by EHS on a weekly basis, or as necessary. Deficiencies will be recorded and reported to the appropriate personnel for corrective action through the EHS SIMS Housekeeping. The storage, housekeeping, and debris-removal practices that reduce the buildings flammable and combustible fire load to the lowest feasible level is enforced as necessary and determined during the pre-construction safety meeting Training. Additional training to those that work in or around the project area on the use of fire-fighting equipment will be provided as necessary and determined during the pre-construction safety meeting. In addition, education to promote awareness of building deficiencies, construction hazards, and temporary measures implemented to maintain fire safety is conducted as necessary and determined during the pre-construction safety meeting. This notification shall be conducted by the BU Project Manager Fire Drills. A fire drill will be conducted as necessary and determined during the pre-construction safety meeting. Drills will be conducted by EHS Page 8 of 19
9 Forms The following forms are located in the appendices of this plan. Construction Notification Form Appendix I Preconstruction Risk Assessment Appendix II Safety Instructions for Contractors and Vendors Appendix III Daily Egress Inspection Form Appendix IV EHS Monitoring Form Appendix V Contractors Agreement Appendix VI Guidance for Notifying the MassDEP for Construction/Demolition Appendix VII 8. Records Management 8.1. A copy of the site-specific safety plan shall be posted at the job site. EHS will maintain all originals for the duration of the project and at least three (3) years after project completion. 9. SOP Revision History Version Section / Paragraph Changed Changes Made Effective Date V.1 N/A None, Original Version V.2 Entire Edits throughout based on March Meeting between EHS and FMP. V.3 Appendix 1 Added Appendix III Added items to Appendix II Added appendix IIV notification guidance to DEP 4/6/10 8/13/10 V.4 Sections 4, 7.1, 7.11 Added BU employees and staff responsibilities, FMP construction meetings, Lab animal housing areas requirements 9/21/ Page 9 of 19
10 Construction Notification Appendix I Date: Start Date: Completion Date: Project Number: Project: Location: Department: Scope of work: The Project Manager must request a meeting with EHS to complete the Preconstruction Risk Assessment Date Inspection Requested: Inspection Required Yes No Site Specific Planning Meeting Waived Yes No EHS Representative Signature Distribution: Safety ORC Radiation Safety (RSO) Laboratory Safety Cmt. Facilities Management Administration Return to Environmental Health and Safety Page 10 of 19
11 PRECONSRUCTION RISK ASSESSMENT Appendix II Date of Assessment: EHS Rep.: Location: Project Manager/ Project #: Yes No N/A 1. Dust control necessary? 2. Will construction affect exit routes around construction site? A. Is the Daily Egress Inspection Form needed? 3. Will any of the following systems be affected? A. Fire Alarm. If impaired, is a temporary but equivalent fire alarm system necessary? B. Sprinkler. If impaired, is a temporary but equivalent system necessary provided? C. Electrical D. Water E. Medical/Laboratory Gases F. HVAC G. Wall/ceiling cutting & patching 4. Is a local Fire Department Fire Watch required (welding, cutting, major F/A or sprinkler system impairment) 5. Will additional Fire Extinguishers be necessary? Are existing units sufficient? 6. Are temporary partitions to resist the passage of smoke/noncombustible/appropriately rated? 7. Are additional inspections of buildings, grounds, and equipment, construction areas and storage, excavations, and field offices necessary? 8. Will storage, housekeeping, and debris removal that reduce the buildings flammable and combustible fire load to the lowest feasible level be practiced? 9. Are construction personnel trained on the RACE fire plan and fire fighting equipment? Will access be unobstructed (fire extinguishers, pull stations, phones for emergency calls)? 10. Do additional fire drills need to be conducted? 11. Will temporary fire safety systems be inspected and tested monthly by the appropriate licensed trade? 12. Will affected personnel be educated on construction activities and the interim measures to promote awareness of building deficiencies and construction hazards? Yes NO N/A Page 11 of 19
12 13. Are any of the following safety/environmental hazards present? A. Asbestos B. Hazardous Materials (Chemicals, Radiation, Biohazard, Sharps, Chemotherapy) C. Flammable Products (stored in cabinet, BFD Permit) D. Compressed gases E. Confined Spaces F. Hot Work 14. Noise and Vibration Plan required/submitted? 15. Have all contractors been instructed on the NO SMOKING policy? 16. Will construction safety signs and Safety Board (Permit Posting) be posted? 17. Have the work stoppage rules been communicated? 18. Have all necessary permits been obtained and posted? 19. Have the parking rules been communicated? 20. Has Appendix III been distributed to Contractors/Vendors? Notes Project Specific Safety Measures: Page 12 of 19
13 HANDOUT FOR CONTRACTORS/VENDORS Appendix III Safety Instructions for Contractors / Vendors Working in Research Laboratories Boston University and Boston Medical Center expect all persons, including employees, visitors, vendors and contractors to fully comply with all Occupational Health and Safety and Environmental Protection regulations and standards. BU and BMC facilities include patient care, research and teaching facilities with a unique work environment, and have certain safety precautions that must be observed by everyone who enters these facilities. The following general rules are to be followed when working in any BU or BMC laboratory or patient care areas: Make prior arrangements with the Facility Project Manager for after-hours and weekend access to facilities and procedures to secure the worksite. Coordinate with the Facility Project Manager and the affected building occupants before planning any utilities interruption. Observe safety notices and warning signs posted on doors, benches, fume hoods, and cabinets. Introduce yourself to area personnel and explain the work you will be performing upon entry. Clarify with area personnel (laboratory, patient area) any necessary safety or biological safety precautions before entering or performing work in these areas. Inform the Facility Project Manager and occupants if odorous chemicals (e.g., adhesives, pesticides, paints, solvents, etc.) will be used. Provide the Facility Project Manager and EHS with MSDSs for all the chemicals used. MSDSs must be readily available at the project site. Do not remove any ceiling tiles, or open any access panels, without consulting with the Facility/Project Manager regarding potential asbestos or other hazards. Consult with Facility Project Manager regarding required safety procedures if the job requires removal of ceiling tiles. Work above ceilings in Boston Medical Center (BMC) locations; require an Above Ceiling Work Permit available from BMC Facilities. The Facility Project Manager will coordinate with laboratory personnel if ongoing experiments or sensitive equipment need to be covered, protected, or moved. Notify the Facility/Project Manager if work involves vibration or excessive noise before you perform work. Smoking is strictly prohibited in all BU and BMC buildings. No eating or drinking is permitted in any laboratory; discarding food containers, cups or wrappers in the laboratory waste container is prohibited. Do not discard any construction debris in waste containers located inside laboratories. Remove construction waste from labs, offices, hallways, and elevators Page 13 of 19
14 Do not stand or walk on any furniture or equipment. Do not turn fume hood fans off without first consulting with the Facility Project Manager and the laboratory supervisor. If a fume hood fan is shut down, notice must be posted at the affected fume hood(s). Do not block elevators, exits, corridors, hallways, emergency showers, eye washes, fire extinguishers, or other safety equipment. Report any accidents or damage in the work site to the Facility Project Manager and to the occupants immediately. Do not open windows or prop doors open. Do not leave unattended laboratory open or unlocked. Do not unplug or move any laboratory equipment or computers unless authorized by the Facility Project Manager and appropriate laboratory personnel. Clearly identify and secure all gas cylinders in an approved manner. Tying cylinders to railings is not approved! All unsecured cylinders will be disposed as hazardous waste at contractor's expense. Extension cords in use must be grounded and in good condition. Do not string extension cords across hallways or aisles. Cords must be disconnected at the end of the work shift. Non compliant cords will be removed by the Facility Project Manager or EHS. All hazardous waste generated from the project must be coordinated for disposal with EHS. Hazardous waste costs are the responsibility of the contractor. DO NOT dispose of the following in regular trash dumpsters: o Paint o Asbestos o Solvents o Compressed gas cylinders o Universal wastes (e.g. batteries, electronic components, etc.) o or other restricted wastes Environmental Health and Safety is authorized to stop all operations which are not compliant with health and safety or environmental regulations. For additional information contact the Environmental Health and Safety at (Medical Campus) or (Charles River Campus) Page 14 of 19
15 DAILY SAFETY and EGRESS INSPECTION Form to be used if deemed necessary by an EHS Appendix IV Project (name/number): LOCATION: DATE/TIME SIGNATURE DATE/TIME SIGNATURE Page 15 of 19
16 PROJECT MONITORING and SAFETY CHECKLIST Form to be used if deemed necessary by EHS Appendix V Note: EHS conducts regular inspections of projects. Deficiencies are entered in the EHS Web based Compliance Program. Date of Survey: Inspector: Location: Project number: EXITS 1. Are exits free and unobstructed? 2. Are phones/fire extinguishers/fire alarm pull boxes unobstructed? FIRE EQUIPMENT 3. Are fire alarms, detection, and suppression systems operational? Including temporary systems. YES NO N/A 4. Is additional fire fighting equipment provided, accessible, and maintained? FIRE SAFETY 5. Is the NO SMOKING policy enforced? 6. Are the work areas free from storage/debris from daily operations? 7. Are required temporary construction partitions compliant and maintained? GENERAL SAFETY 8. Is the power properly secured at the end of the shift? 9. Are hand/safety rails in place and good condition? 10. Are extension cords grounded and in good condition? 11. Are power tools and other equipment in good condition and secured when not in use? 12. Are "hot works" operations properly conducted? 13. Does scaffolding comply with OSHA requirement ( )? 14. Are construction areas, storage areas, excavations and field offices compliant and free of recognized hazards? 15. Are good housekeeping practices employed? 16. Dust Control Compliance 17. ILSM Compliance Page 16 of 19
17 18. Signage posted at entry(s) to the job site? 19. All Project Permits posted on site Board? COMMENTS: Page 17 of 19
18 Appendix VI PROJECT AGREEMENT I have read, understood, and will instruct all of my personnel on the provisions outlined in this plan. Print Name Signature Date Contractor Project Manager BU Project Manager EHS Representative BU In House FMP Staff THIS ENTIRE DOCUMENT WILL BE POSTED ON THE PROJECT CONSTRUCTION SAFETY BOARD Page 18 of 19
19 Appendix VII Guidance for Notifying MassDEP for Construction/Demolition The following are the requirements for notifying the MassDEP for Construction and Demolition activities. Construction and demolition is defined as any physical change which involves the wrecking, taking out, removal, stripping of, or altering to a structure. Boston University further defines construction as all new construction or any project that involves the removal of load bearing walls or smoke/fire walls and/or the erection of same or any work which compromises the Life Safety Code. In addition, any project which involves hazardous materials, or in the opinion of a representative of the EHS or the BU/BMC Construction Project Manager, has the potential for providing a hazard that could compromise safety, shall be considered a construction project requiring the implementation of one or more measures outlined in the Program. The DEP Construction/Demolition Notification Form AQ-06 is required when abating asbestos containing building materials. The form shall also be used under the following conditions and only after building materials identified to be disturbed have been tested and proven not to contain asbestos. When six (6) sq. ft. interior or twenty (20) sq. ft. exterior building materials will be altered, renovated or removed and/or any time more than three (3) different, non-asbestos building materials will be affected. The DEP Construction/Demolition Notification Form AQ-06 in not required for the following; When replacing floor tile or floor sheeting the notification is not required. Replacement of broken or stained ceiling tiles does not require notification. Replacing windows or door frames do not require notification unless the size of the affected building material is equal or greater than six (6) sq. ft. Questions regarding the use of the DEP Notification should be directed to EHS at (Medical Campus) or (Charles River Campus). The MassDEP encourages filing Construction/Demolition Notification Form AQ-06 online via edep! If you have not already done so, please register online with edep at Page 19 of 19
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