ESH Roles and Responsibilities Jack Cassidy Construction Management
ES&H Roles and Responsibilities Jack Cassidy Construction Management and Safety 14 August 2014
Objectives • Understand your ESH roles and responsibilities as a Task Manager/ Construction Coordinator • Understand the ES&H requirements in the subcontract documents and FESHM chapters • Know where to find resources when you need assistance 2 Construction Management and Safety
Integrated Safety Management Principles • Line Management responsible for safety • Clear roles & responsibilities • Competence commensurate with responsibilities • Balanced priorities • Identification of safety standards & requirements • Hazard controls tailored to work • Operations authorization 3 Construction Management and Safety
Integrated Safety Management Core Functions • • • 4 Define Work Analyze Hazards Establish Controls Perform Work Provide Feedback & Improvements Construction Management and Safety
Division/Section Head Responsibilities • Ensure implementation of the requirements of FESHM Chapter 7010 for those construction activities managed by his/her staff. • Assign properly trained Construction Coordinators & Task Managers 5 Construction Management and Safety
Procurement Administrator Role • Obtain the Fermilab Subcontractor Safety Information Questionnaire Form from potential bidders and submit to ESH&Q for review. • Incorporate the Subcontractor’s ES&H Plan as part of the contract requirements. • Chair the pre-construction meetings. 6 Construction Management and Safety
Procurement Administrator Role • Provide assistance to TM/CC with contractual matters – Administer all contractual requirements including safety. – Notify the subcontractor of issues and concerns, including safety issues. • Coordinate and chair the meeting to complete the Subcontractor Performance Evaluation process. 7 Construction Management and Safety 7
Division/Section SSO Role • Provide support and oversight of construction projects under $25 k, including communicating observations to the TM/CC. • Assist the TM/CC with the review of the HA, as requested. • Assist the TM/CC in conducting incident investigations, as requested. • Participate as a team member in the evaluation of the subcontractor. 8 Construction Management and Safety
Responsibilities of ESH&Q Section • Assist the TM/CC in the review of the hazard analysis, as requested. • Provide safety oversight of construction projects. • Conduct ES&H audits of subcontractor construction activities. – Construction activities include daily work planning meetings, weekly toolbox meetings, monthly ES&H meetings, and site inspection reports. – Observations will be provided verbally and in writing to the TM/CC. 9 Construction Management and Safety
Responsibilities of ESH&Q Section • Interpret OSHA requirements for construction work, as requested. • Provide additional field support, when requested. • Participate in the subcontractor performance evaluation process 10 Construction Management and Safety 10
Subcontractor’s Responsibility • Comply with contractual requirements and their safety plan • Provide a safe working environment for employees • Flow down all contractual requirements to their sub-tier subcontractors 11 Construction Management and Safety
ES&H Responsibilities of CC • Review the Pre-construction list in the Preconstruction meetings to establish ES&H expectations for the contractor. • Ensure the subcontractor is following their ES&H Program. • Review and accept the subcontractor hazard analysis. 12 Construction Management and Safety
ES&H Responsibilities of CC • Ensure that no work is performed by the subcontractor or sub-tier contractor until the hazard analysis has been accepted, and reviewed and signed off by each subcontractor and sub-tier contract employee on the job. • Ensure that all subcontractor and sub-tier contractor employees attend required Fermilab provided training. 13 Construction Management and Safety 13
ES&H Responsibilities of CC • Monitor and enforce compliance with ES&H requirements in the contract, the hazard analysis and the contractor’s ESH plan. Document noncompliance in a daily log. • Initiate the call tree upon a subcontractor report of an incident. 14 Construction Management and Safety
ES&H Responsibilities of CC • Obtain incident report from the subcontractor. • Prepare an independent incident report for the Construction Manager, as requested. • Participate in the subcontractor performance review at end of the contract. 15 Construction Management and Safety 15
ES&H Responsibilities of CC • Review the condition of mobile cranes used as part of the project, using the guidance in FESHM 7010, Appendix 3 - Mobile-Crane. • Verify training for subcontractor employees prior to execution of the following work – Permit-required confined space entry – Entry into a facility or area classified as ODH – Entry into a radioactive or controlled work area. (provided by Fermilab) 16 Construction Management and Safety 16
ES&H Responsibilities of CC – Lead and asbestos work – Use of respiratory protection when potential exposure levels will be above established limits – Fall Protection – Lock out/Tag out – Electrical activities that require compliance with NFPA 70 E. 17 Construction Management and Safety
ES&H Responsibilities of TM • Prepare the HA and obtain all required reviews and acceptances. • Plan and direct all work activities. • Act as competent person for the job. • Obtain the required work permits. • Conduct pre-job work planning meeting with T&M subcontractor employees to assure they understand the work activity, ESH hazards, and mitigation measures. 18 Construction Management and Safety
ES&H Responsibilities of TM • Assure all subcontractor employees have received all appropriate training. • Arrange for Hazard Analysis training for subcontractor supervisor, if not done by T&M Manager. • Review HA with subcontractor employees, seeking their input, and making changes as appropriate. • Assure that all subcontractor employees sign the HA. 19 Construction Management and Safety
ES&H Responsibilities of TM • Notify the Senior Safety Officer (SSO) and T&M Manager of any employee injuries. • Conduct incident investigations. • Inform T&M Manager of ES&H noncompliance issues. • Submit subcontractor performance review to the T&M Office after completion of the job (Form-7010 -F 4_Performance-Assessment) 20 Construction Management and Safety
ES&H Responsibilities of TM • Review the condition of any mobile crane used as part of the project, using the guidance in FESHM 7010, Appendix 3 - Mobile-Crane. • Conduct and document daily inspections of excavations. 21 Construction Management and Safety
Stop Work Activity Authority “Fermilab employees have the authority to stop construction activities if an imminent danger condition is noted or perceived. After the work activity is stopped, whoever stopped the work activity shall contact the CC; who will gain consensus from the subcontractor on restart conditions. This is an informal process designed to stop work, quickly abate the hazard, and restart the work. ” Construction Management and Safety 22
Stop Work Activity Authority Occasionally, a more formal work stoppage process must be invoked. If exposure to the hazard cannot be abated quickly, or if consensus cannot be reached as to the corrective action, the TM/CC shall stop the associated work using the Subcontractor ESH Stop Work Order Form. The stop work activity authority is to stop a specific activity within a project and not an entire project. Construction Management and Safety 23
Stop Work Activity Authority to restart an activity after a formal Stop Work Order has been issued resides with the D/S head after consultation with other appropriate organizations and individuals, such as the PM, CC, D/S SSO, ESH&Q Rep. , and PA. Construction Management and Safety 24
Fermilab Safety Requirements • • Contract with DOE Work Smart Set Fermilab ES&H Manual Contract with Subcontractor – Must flow down to sub-tier contractors 25 Construction Management and Safety
Work Smart Set • • • 26 OSHA - 29 CFR 1910 and 1926 EPA IEPA DOT ASME/ANSI Construction Management and Safety
Fermilab ESH Manual (FESHM) • FESHM 7010 - ES&H Program for Construction • Other FESHM Chapters referencing subcontractor work include: – – 27 FESHM 7030 Rules for Excavating FESHM 7040 Concrete Cutting and Coring FESHM 7050 Rules for Demolition FESHM 5000 Series Construction Management and Safety
Contract with Subcontractor • Exhibit A - Schedule and Supplementary Terms and Conditions – Section 6 – Environment, Safety and Health • • • 6. 2 Environment Safety and Health Program 6. 3 Environment Safety and Health Plan 6. 7 Subcontractor Training 6. 8 Subcontractor Safety and Health Records 6. 9 ES&H Inspections 6. 10 Job Site ES&H Meetings • Terms and Conditions(FL-3) – Section 31 ES&H 28 Construction Management and Safety
Subcontractor’s ES&H Plan • Required to be submitted if contract is >$100 K • Reviewed & accepted by Fermilab • Plan needs to address – ISM Principles – Site specific information – Safety Elements listed in Section 6. 3 29 Construction Management and Safety
Subcontractor’s ES&H Plan • Subcontractor will be held to the requirements of their program • Sub-tier subcontractors are expected to follow subcontractor’s plan – Or submit their own to subcontractor for acceptance 30 Construction Management and Safety
Subcontractor Field Superintendent • Designated for the duration of the project to the running of the day-to-day operations of the work including safety, quality control and sub-tier subcontractor coordination responsibilities. • Shall have knowledge and experience of Occupational Safety and Health Administration (OSHA) and other related safety standards, and has the authority to enforce such standards in the field. 31 Construction Management and Safety
Subcontractor Field Superintendent • Must be present on the Fermilab project site whenever work activities are ongoing. • In the absence of the designated Field Superintendent, the Subcontractor shall identify an alternate individual with similar qualifications acceptable to Fermilab. • Multiple shifts requires a designated individual meeting the above requirements for each work shift. 32 Construction Management and Safety
Safety Representative • The Subcontractor shall employ a Safety Representative who acts as an authorized agent of the Subcontractor, responsible for safety activities of all work sites under the subcontract. Unless stated otherwise in Section 4. 1 of Addendum A, the Subcontractor’s Field Superintendent can function as the safety representative. 33 Construction Management and Safety
Competent Persons • If excavations are part of the project scope, the Subcontractor shall provide a competent person for excavation activities who meets the requirements of OSHA 29 CFR 1926. 32 (f). • If scaffolding is be utilized during the execution of the project, the Subcontractor shall provide a competent person for scaffolding who meets the requirements of OSHA 29 CFR 1926. 32 (f). 34 Construction Management and Safety
Subcontractor Hazard Analysis • Construction Coordinators – HAs are submitted by the subcontractor or sub-tier contractor (via the Subcontractor), and are reviewed and accepted by the CC. – The PA will not issue the Notice to Proceed (NTP) until the CC sends notification of the hazard analysis acceptance to the PA. – For large projects, only the initial HA is required to be accepted prior to NTP. Afterward, each identifiable feature within a project requires a written hazard analysis. 35 Construction Management and Safety
Subcontractor Hazard Analysis – Work will not proceed on that identifiable feature until the CC has accepted the hazard analysis. • Task Managers – The TM will prepare an HA, in coordination with the subcontractor. – The TM must then have the HA reviewed and accepted by another qualified Fermilab employee. This individual may be the R/TS, the TM’s supervisor, another TM, or the SSO. – The TM will notify the T&M Manager when the HA has been accepted and is ready to start work. 36 Construction Management and Safety
Subcontractor Hazard Analysis – The TM will review the HA with the subcontractor employees to assure that they understand the work plan. – The TM will assure that all subcontractor employees working on the job have reviewed and signed the HA. – HA training is required for subcontractor supervisory personnel and will be provided by the ESH&Q Section. 37 Construction Management and Safety
Subcontractor Hazard Analysis • Criteria for Accepting HA – Cover Sheet completed – Work steps clearly defined • Equipment specifically identified – Hazards specifically identified – Mitigation clearly spelled out • PPE specifically identified – MSDS sheets must be attached • FL-3 requires MSDS to be submitted before bringing hazardous material on site 38 Construction Management and Safety
Pre-construction Meeting • Held when contract is >$100 K, or at request of the CM or CC • Conducted by Procurement Administrator • ESH&Q and or the SSO attend to ensure that local ESH considerations are conveyed to the subcontractor • The CC will use Pre-Construction Checklist to review contractual ESH requirements with the subcontractor. 39 Construction Management and Safety
Subcontractor Required Training • Subcontractors and sub-tier subcontractors are expected to have provided employees with all appropriate training • TM/CC must verify training for subcontractor employees prior to execution of the following work Permit-required confined space Rad or controlled work area Respirator use Lock out/Tag out 40 Construction Management and Safety ODH Lead/Asbestos Fall protection NFPA 70 E
Fermilab Provided Training • All Subcontractor employees must attend Subcontractor Orientation provided by ESH&Q Section – Daily at 7: 30 am WHGF Training Room – If GERT is needed the TM/CC should notify to ESH&Q by sending an email to gert@fnal. gov to ensure training. • All other Fermilab training requires enrollment or contacting the course contact person. 41 Construction Management and Safety
Subcontractor Safety Meetings • Daily Planning Meeting (~5 minutes) – Discuss hazards and plans for the shift • Weekly Toolbox(~ 10 minutes) – Discuss safety issues, incidents, and current phase of work • Monthly (1 hour) – For long term larger projects. • TM/CC and ESH&Q attend periodically 42 Construction Management and Safety
Incident Reporting • CC must ensure subcontractor conducts incident investigation and submits report within 2 working days of the incident • TM, with the assistance of the SSO, must conduct the incident investigation and submit report within 2 working days of incident 43 Construction Management and Safety
Site Inspections • Subcontractor is responsible for having a site and equipment inspection program – This includes inspections of sub-tier contractors – Results must be documented – TM/CC is responsible for ensuring that the subcontractor conducts inspections • TM/CC’s are also responsible for conducting and documenting site inspections 44 Construction Management and Safety
Site Inspections • ESH&Q Section provides safety audits as part of their oversight responsibilities – Provide information to TM/CC for action – Follow up to see if items are addressed • Frequency of inspections should be sufficient to regularly identify and ensure correction of safety concerns 45 Construction Management and Safety
Work Clothing and PPE • Sturdy work type shoes or boots that cover the ankle. • Long trousers and short sleeve shirts covering the ball of the shoulder • Hardhats, safety glasses, hearing protection and any other personal protective equipment identified in the HA must be worn by all entering the construction site 46 Construction Management and Safety
Loaning of Fermilab Tools • Fermilab does not loan tools and equipment unless the tool or equipment is specifically authorized in the subcontract. – Excluded from this policy are non-powered hand held tools and lockout/tagout locks and tags. 47 Construction Management and Safety
Loaning of Fermilab Tools • Conditions may arise where a CC finds it absolutely necessary to loan power tools or a piece of equipment • To loan a tool or equipment – The Fermilab Tool Loan form shall be completed before the tool is loaned. – The original shall be sent to the PA after the tool is returned to Fermilab control. 48 Construction Management and Safety
Evaluation of Subcontractors • Completed jobs over $100 K or as requested by interested parties • Evaluation will be used as a basis for future bidders list • The PA will chair the meeting using the Fermilab Subcontractor Performance Evaluation Form 49 Construction Management and Safety
Summary • What is your role and responsibility as a Task Manager and/or Construction Coordinator • What are the ES&H requirements in the subcontract documents and FESHM chapters • What resources do you have if you need assistance • The TM/CC/SC Webpage link on the ESH&Q Web page. 50 Construction Management and Safety
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