Chapter 10 – Construction Safety

Contents

Approved by Kevin Goodwin
Revised 1/24

10.1 Policy
10.2 Scope
10.3 Program Descriptions
10.4 Exceptions
10.5 Roles and Responsibilities
10.6 Definitions
10.7 Required Work Processes

• Work Process A. General Requirements
• Work Process B. Review Safety Performance of Bidding Subcontractors
• Work Process C. Review Selected Subcontractors’ EHS Submittal Package(s)
• Work Process C.1 Job Hazard Analyses
• Work Process D. Review of Subcontractors’ Key Safety Personnel
• Work Process E. Required Safety Training
• Work Process F. Emergency Procedures
• Work Process G. Incident Site Control and Reporting
• 🚩🚩Work Process H. Stop Work Authority 🛑
• Work Process I. Visitors
• Work Process J. Work Planning and Control
• Work Process K. Specific ES&H Requirements: Permits
• Work Process L. Specific ES&H Requirements: Accident and Injury Information
• Work Process M. Specific ES&H Requirements: Hazard Communication
• Work Process N. Specific ES&H Requirements: Procurement of Hazardous Materials
• Work Process O. Specific ES&H Requirements: Return to Work
• Work Process P. Noncompliance
• Work Process Q. Work Site ES&H Observations

10.8 Source Requirements
10.9 Reference Documents
10.10 Appendix A. LBNL Construction Safety Manual

Note:
🚩🚩    Denotes a new section

🚩    Denotes the beginning of changed text within a section

🛑    Denotes the end of changed text within a section

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10.1 Policy

The Construction Health & Safety Program ensures the safety of Berkeley Lab employees, visitors, and subcontractors during construction activities at the Laboratory by flowing down Integrated Safety Management (ISM), 10 CFR 851, and other requirements to subcontractors. This is achieved by:

• Providing construction leadership (project managers, construction managers, superintendents, foremen, etc.) with construction safety support and oversight.
• Selecting qualified subcontractors.
  • Reviewing all subcontractor safety performance, programs, and qualifications.
• Ensuring proper Environment/Health/Safety (EHS) documentation is submitted for the work to be performed.
  • Ensuring that subcontractors adequately evaluate hazards and implement safety controls.
  • Ensuring that the subcontractors stop to assess work changes or new tasks for hazards and to ensure hazards are controlled prior to proceeding with the work.
• Ensuring key safety personnel are available and on site when necessary.
• Ensuring that subcontractors train their employees and visitors on the safety program elements.
• Ensuring that emergency procedures are in place.
• Ensuring that incidents are properly reported.
• Ensuring that the subcontractor employees understand Stop Work Authority.
• Ensuring that construction site visitors are controlled.
• Ensuring that Berkeley Lab EHS requirements are understood and followed.
• Notifying subcontractors of noncompliance, and taking appropriate action.
• Implementing subcontractor inspections by construction safety staff to ensure compliance with Berkeley Lab EHS requirements.

10.2 Scope

• This document establishes the institutional Construction Safety Program for Berkeley Lab. Specific safe construction-work practices are outlined in the LBNL Construction Safety Manual.
• The Construction Safety Program is established in accordance with the variance granted to LBNL and SLAC for the requirements of 10 CFR 851.24, which allows the use of Cal/OSHA standards in lieu of Federal OSHA. The primary safety standard is California Code of Regulations, Title 8, Subchapter 4 – Construction Safety Orders.

10.3 Applicability

This program applies to all construction activities. Construction activities may originate from construction subcontracts, service contracts, and purchase orders.

10.4 Exceptions

Persons performing work on projects or sites that do not fall under DOE jurisdiction are not required to follow the requirements of this program. However, an equivalent program meeting applicable regulatory requirements will apply.

10.5 Roles and Responsibilities

Role	Responsibilities
Division  management	The primary safety responsibility of division management is to ensure that project managers and the construction manager set and follow LBNL safety policies from “bid day” to the Project Closeout Meeting. Performs a safety audit every time they visit a job. Sets the example by ensuring all personnel follow LBNL safety policies. Ensures that the safety training of all operating group personnel meets or exceeds LBNL and Cal/OSHA requirements. Takes an active role in the Facilities Division’s safety program. Holds each project manager and construction manager accountable for safety and health performance. Ensures that safe construction activities are a part of the annual performance review. Leads by example by following the ISM philosophy. Takes required disciplinary action when supervisory and/or management personnel do not perform their safety duties per LBNL policy. Promotes consistency in safety from project to project. Evaluates all project managers, construction managers, and leads on their safety performance. Attends all required safety training courses. Implements and maintains an effective safety program. Ensures workers under their supervision maintain safe work areas and perform their tasks in a safe manner
Construction workers	Must accept responsibility for their own safety and for the safety of others around them by working safely and insisting that their coworkers do the same. Conduct work in a safe manner. Stop work immediately to correct any unsafe conditions. Take corrective actions so that work may proceed in a safe manner. Arrive at work alert and ready to focus on safely performing their job. REMEMBER: Your safety and the safety of everyone around you require your full attention. Follow safety instructions given by the foreman or superintendent. Be on guard for unsafe conditions or activities and take action to correct them. If the problem cannot be fixed, report it to the foreman. Use good judgment to provide for personal safety and for the safety of coworkers. Use the required safety equipment. Comply with all LBNL policies and with Cal/OSHA regulations and good safety practices. Wear the proper clothing for the job. Constantly strive to improve your safety education. Immediately report all injuries to your supervisor.
Contractor employers	Oversee the safety of their employees and/or visitors as required by the rules and regulations of this manual; Title 8 CCR Subchapter 4, Construction Safety Orders; and all other applicable local, state, and federally recognized current standards and codes. Understand and follow the contents of this ES&H Manual program and the Contractor Safety Manual.  Train/educate their employees and/or visitors in the contents of this Manual, and the requirements for conduct of work under this LBNL EHS program. Document all employee training. Oversee the safety of their employees and/or visitors as required by the rules and regulations of this program; the Code of Federal Regulations 10 CFR 851, Worker Safety & Health Program; Title 8 CCR Subchapter 4, Construction Safety Orders; and all other local, state, and federally recognized current standards and codes. Understand and follow the contents of this program. Train/educate their employees and/or visitors in the contents of this program, and the requirements for conduct of work under the Berkeley Lab ISM Plan. Document all employee training.
Subcontractor employees	Have the same safety rights and obligations as those of Laboratory employees.
Subcontractor On-Site Health and Safety Representative	Conducts regular documented inspections of the construction work site to identify and correct any instances of noncompliance with the project health and safety requirements. Assists in the development of the contractor’s safety plan and job-site management system. Supports training of contractor personnel. Evaluates the contractor safety process continuously. Responds to questions regarding the contractor safety process. Attends pre-job meetings to discuss the contractor’s site-specific safety plan. Conducts and documents job-site safety audits. Assists in the identification of jobs requiring an activity-based hazard analysis. Attends all required meetings. Is a proponent of safety in words and actions. Conducts daily documented inspections of the construction work site to identify and correct any instances of noncompliance with the project health and safety requirements. Assists in the development of the subcontractor’s safety plan and job-site management system. Supports training of subcontractor personnel. Evaluates the subcontractor safety process continuously. Responds to questions regarding the subcontractor safety process. Attends pre-job meetings to discuss their site-specific safety plan. Assists in the identification of jobs requiring an activity-based hazard analysis. Attends scheduled meetings at the request of LBNL. Attends or conducts Plan of the Day meetings. Reviews JHA to ensure it has been properly completed.
Competent Persons	Identify existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and have the authorization to take prompt corrective measures to eliminate them.
Qualified Persons	Use skills and knowledge to solve or resolve problems relating to the subject matter, the work, or the project Possess recognized degree, certification, or professional standing; or have extensive knowledge, training, and experience in the subject matter.
EHS Construction Safety Professional	Coordinates, tracks, and provides quality assurance for the EHS document package review for Berkeley Lab construction projects Conducts routine observations of construction work sites to identify and correct unsafe workplace conditions and behaviors
Berkeley Lab construction and project managers	Safety begins with the construction manager. The culture that the construction manager brings to the job is what sets the baseline for the entire job. You have the authority and responsibility to run a safe job. Pre-construction phase: Attend a safety analysis meeting. Identify any special hazards in advance by reviewing plans, specifications, and construction methods with technical assistance from EHS. Assist project manager with pre-construction subcontractor safety meetings Construction phase: Arrange pre-start-up meetings with each subcontractor. Plan, conduct, or review the daily pre-task planning outlines. Attend weekly safety progress meetings. Implement a project housekeeping program from the very start of the project. Enforce LBNL employee and subcontractor safety compliance. Attend and participate in the weekly toolbox safety meetings. Ensure subcontractors hold weekly toolbox meetings. Obtain a copy of the minutes. Issue subcontractor non-compliance notices for safety hazards when appropriate. Verify that the safety program is effective and that the job is safe. Conduct or attend job-wide safety meetings at least monthly. Establish and maintain access routes for vehicle, pedestrian, and emergency response crews. Make sure that all safety equipment is provided and used correctly. Assist in investigating all accidents. Investigate and correct all unsafe conditions. Maintain safety training requirements. Create a constantly improving safe site environment and culture. Oversee completion of a daily audit. Attend all required safety training courses. Support LBNL loss prevention efforts by cooperating with the project manager, EHS, and other loss control agencies. Approve EHS document packages submitted by subcontractors. Conduct routine observations of construction work sites to identify and correct unsafe conditions and behaviors.

10.6 Definitions

Term	Definition
ANSI	American National Standards Institute
Authorized Person	A person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the job site
Competent Person	One who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt, corrective measures to eliminate them. A Competent Person is also one who has extensive training knowledge/experience in a particular activity or job function. A Competent Person at LBNL shall be capable of demonstrating the ”knowledge and skill sets” that match their “Competent Person” designation.
Construction work	Any combination of erection, installation, assembly, demolition, or fabrication activities involved to create a new facility or to alter, add to, rehabilitate, dismantle, or remove an existing facility. It also includes the alteration and repair (including dredging, excavating, and painting) of buildings, structures, or other real property, as well as any construction, demolition, and excavation activities conducted as part of environmental restoration or remediation efforts.
Contamination	Refers to the impact of sources in any amount and at any degree below or above permissible levels for health and safety toward the environment or to life.
Controlled Access Zone	An area in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems, and access to the zone is controlled
Graded approach	Applying a level of rigor commensurate with the importance or significance of the activity, in relation to the associated hazards and consequences to ensure that available resources are used most efficiently and effectively. A graded approach is recommended to be used for implementing the work planning and control.
Hazardous	When referring to a spill, “hazardous” means the spill is above the permissible levels for health and safety toward the environment and life and is regulated under government standards.
Hold point	A point of defined circumstances (e.g., excavation permit) beyond which a construction activity must not proceed without the approval of a designated authority.
Integrated Safety Management (ISM)	The Department of Energy’s systematic approach to analyzing work and hazards and implementing controls
Imminent danger	Any condition or practice that could reasonably be expected to cause death or serious physical harm (such as permanent or prolonged impairment of the body or temporary disablement requiring hospitalization) to employees or the public unless immediate actions are taken
Project Inspector	The Facilities Division’s representative responsible for monitoring construction quality and verifying compliance with the terms and conditions of the design documents
Site-Specific Safety Plan (SSSP)	A document prepared by the construction subcontractor and submitted to the LBNL EHS Office and Project Manager for review and concurrence. Describes the construction subcontractor’s Environment, Safety & Health Plan and for a particular construction project and the activity hazard analysis(s) for each definable activity/feature of work.
Subcontractor	A firm that has sole contractual responsibility for execution of the construction work related to a project, and for compliance with all safety, health, and environmental codes, standards, and regulations
Qualified Person	One who by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the construction project.

10.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Review Safety Performance of Bidding Subcontractors
Work Process C. Review Selected Subcontractors’ EHS Submittal Package(s)
Work Process C.1 Job Hazard Analyses
Work Process D. Review of Subcontractors’ Key Safety Personnel
Work Process E. Required Safety Training
Work Process F. Emergency Procedures
Work Process G. Incident Site Control and Reporting
Work Process H. Stop Work Authority
Work Process I. Visitors
Work Process J. Work Planning and Control
Work Process K. Specific ES&H Requirements: Permits
Work Process L. Specific ES&H Requirements: Accident and Injury Information
Work Process M. Specific ES&H Requirements: Hazard Communication
Work Process N. Specific ES&H Requirements: Procurement of Hazardous Materials
Work Process O. Specific ES&H Requirements: Return to Work
Work Process P. Noncompliance
Work Process Q. Work Site ES&H Observations

Work Process A. General Requirements

The following work processes describe the general requirements for the Environment, Safety & Health (ES&H) construction site management. Requirements specifically related to work performed on construction sites are found in Appendix A, LBNL Construction Safety Manual. The Environment/Health/Safety (EHS) and Facilities divisions expect all subcontractors to follow the requirements of this program, including Appendix A.

Work Process B. Review Safety Performance of Bidding Subcontractors

1. Construction subcontractor selection must include an evaluation of the subcontractor’s prior safety performance, the subcontractor’s current written safety programs, and qualifications of key EHS personnel to assure Berkeley Lab that the subcontractor is capable of meeting safety-performance goals. All subcontractors being considered to perform construction activities at Berkeley Lab–controlled sites and property must undergo such an evaluation.
2. During the construction subcontractor selection process, Facilities Division Procurement personnel request evidence of the subcontractor’s workers’ compensation experience modification rates (EMRs).
   1. In general, the subcontractor must achieve an EMR of 1.0 or less to be considered for a contract award.
   2. Occasionally, a subcontractor’s EMR may not be an accurate representation of safety performance (due to statistical variations in the EMR calculation from small payroll numbers, outlier workers’ compensation events, etc.). In these cases, an evaluation of a minimum of the past three years of the subcontractor’s OSHA Form 300 and Form 300A data may be used to qualify a subcontractor on the basis of construction safety.
3. Additionally, during the selection process a copy of the subcontractor’s corporate program or the Cal/OSHA-required Injury and Illness Prevention Program (IIPP) is requested for review.
4. The Berkeley Lab Project Management Team, EHS Construction Safety, and Procurement personnel must evaluate the information submitted by subcontractors. Subcontractors must demonstrate an equivalent process in the selection of lower-tier subcontractors and must submit evaluation criteria and results to Berkeley Lab.

Work Process C. Review Selected Subcontractors’ EHS Submittal Package(s)

1. Each subcontractor must provide Berkeley Lab with a written Site-Specific Safety Plan (SSSP). An SSSP template is available for contractor use at the LBNL EHS Construction Subcontractor Safety Reference website, under 3. Construction Safety for Site Specific Safety Plans.
2. The Berkeley Lab Project Manager and EHS Construction Safety Professional review, and the Project Manager approves, the submitted package before notice to proceed is given for the construction activity.
3. Lower-tier subcontractors must use and abide by the general contractor’s written site-specific safety program.
4. General contractors that engage lower-tier subcontractors must ensure that each lower-tier subcontractor complies with the governing safety plan and LBNL policy.

Work Process C.1 Job Hazard Analyses

1. Subcontractor Job Hazards Analysis (JHA) Submittal
   1. Subcontractors must submit a JHA for all construction activities that require a JHA defined below in section 2.
   2. The JHA must be submitted for review and approval at least 10 working days prior to the start of the task. The JHA must be approved by the Berkeley Lab Project Manager or Construction Manager before work commences.
   3. The subcontractor must maintain at least two copies of the Berkeley Lab-approved JHA. The first copy should be maintained with the project files. The second copy must be conspicuously posted on the job site/project.
   4. Each employee scheduled to perform the activities identified in a JHA must receive a safety briefing on those activities described in the applicable JHA and sign the JHA prior to performing the work. The subcontractor must maintain proof of employee safety briefings at the work site and make it available to the Berkeley Lab Project Manager upon request.
   5. The JHA is supplemented on a daily basis by a Pre-Task Hazard Analysis (PTHA). The PTHA reinforces safety planning and hazard control on a daily basis with an emphasis on verifying that work can proceed safely
2. JHA Requirements
   1. A Job Hazards Analysis (JHA) is required for all projects, regardless of the size, scope, or complexity of work. The JHA is the heart of the project’s safety information and acts as a work control document. Every project will have at least one definable construction activity and therefore at least one JHA. Depending upon the complexity of the project, one or several JHAs may need to be completed. In some cases, JHAs may need to be staged in coordination with the initiation of the various phases of a project.
   2. Each JHA should be written for a well-defined scope of work and written such that the hazards and the required control measures are clearly defined and easily understood. The following are examples of construction activities for which a JHA is required. Activities that logically go together should be combined. For example, roofing work typically involves a fall potential and some hoisting and rigging of materials. The roofing JHA can include the complete scope of the activity. The subcontractor may choose to combine or separate tasks as appropriate for communications with his or her workforce.
      
      Examples of construction activities that require a JHA include, but are not limited to:

• Roofing
• Hoisting and rigging of materials
• Excavation, trenching, drilling, and other earthwork
• Concrete placement and false work
• Welding
• Steel erection
• Work performed where there is a fall potential of 6 feet or greater
• Electrical work, with a potential greater than 50 volts
• Demolition
• Work in confined spaces
• Work that causes the release of silica, such as demolition or drilling of concrete or work with materials that contain silica
• Work with epoxy coatings
• Work with hazardous materials
• Work on steep hillsides
• Use and handling of flammable materials

3. An LBNL Construction JHA must be used. JHA instructions can be found here. A 🚩 Site Specific Safety Plan 🛑 template is available for contractor use at the LBNL EHS Construction Subcontractor Safety Reference website, here

4. Requirements for Reporting Hazardous Conditions
   1. Workers must be instructed and encouraged to report hazardous conditions and actions to their supervisor or Health and Safety Representative.
   2. If immediate corrective action is not possible or the hazard falls outside the project scope, the construction subcontractor must immediately remove affected workers, post appropriate warning signs, implement needed interim controls measures, and notify the Berkeley Lab Construction Manager of the actions taken.
   3. The subcontractor or the designated representative must stop work in the affected area until appropriate protective measures are established.
5. Review of Subcontractor Engineered Protective Systems
   1. The subcontractor must submit, to the Berkeley Lab Project Manager for review, the design of any protective system that is required by regulations or applicable specifications, or standards to be designed by a registered professional engineer.
   2. Berkeley Lab’s review of such a system design is solely to verify that the subcontractor has had the required protective systems prepared and stamped by a registered professional engineer.
   3. Berkeley Lab’s review of any documents showing the design or construction of protective systems for worker and property protection does not relieve the subcontractor of the obligation to comply with applicable laws and standards for the design and construction of such protective work.
6. Coordination and Tracking of Construction EHS Package Reviews
   1. The Project Manager (PM) or Construction Manager (CM) is responsible for coordinating and tracking the required EHS documentation for a project, and performs a quality review to assure all required submittals are included in the final safety document package.
   2. The PM or CM is responsible for ensuring that the EHS Division Construction Safety Professional (CSP) reviews EHS submittals from the subcontractor.
   3. The CSP reviews the packages and, if necessary, distributes appropriate parts to additional EHS subject matter experts (SMEs) for their review and comment. The SMEs return their completed documents to the CSP, who combines comments, identifies and resolves conflicts, and forwards EHS comments to the PM/CM.
   4. The PM or CM is responsible for ensuring that any comments received from the EHS Division Construction Safety Professional (CSP) are addressed prior to final approval of any EHS documentation.
   5. The PM/CM is the final LBNL approver for all safety documentation. The subcontractor must have a JHA signed by the PM or CM prior to starting the activity.
   6. The subcontractor is responsible for ensuring that the requirements of the Injury and Illness Prevention Program (IIPP) or Site-Specific Safety Plan and the applicable JHAs are communicated to the subcontractor’s workforce to ensure compliance.
   7. Copies of the final safety document package and review comments are maintained by the CM and the subcontractor for use during construction.
   8. When the construction work is completed, the safety document package is filed with the project file.

Work Process D. Review of Subcontractors’ Key Safety Personnel

1. Subcontractor On-Site Environmental Health and Safety Professional or Representative (EHS Representative)
   1. The subcontractor must provide a qualified on-site health and safety representative who has been accepted by the Berkeley Lab Project Manager, and who has the authority to enforce all applicable project safety requirements.
   2. The Berkeley Lab Project Management and EHS Construction Safety Office will make a risk-based decision as to the qualification level of the Subcontractor EHS Representative. The required level will be documented in Master Specification 013529. One of three options will be selected:
      1. 🚩 Option A: Full-time Onsite Health and Safety Representative, with a minimum of ten (10) years construction health and safety experience and possesses one of the following certifications: a) CSP; or b) CIH. The person must also have the authority and responsibility to monitor and enforce the health and safety requirements of the project. The Option A Onsite Health and Safety Representative must be onsite during all hands on work and will have the ultimate responsibility and authority for monitoring the Environment, Health and Safety aspects of the work. This role shall not have any other duties assigned at any time during the project outside of the role of Onsite Health and Safety Representative or any safety specific duties that would diminish the ability to perform safety oversight for the entire project. For the purposes of this Safety Representative option, the term onsite, means at the specific project location at all times during hands on work.
      2. Option B: A Full-time Onsite Health & Safety Representative with a minimum of five (5) years construction health and safety experience. The person must have a minimum of 30-Hour OSHA Outreach Training for Construction or a CHST Certification. Completions of OSHA Courses 500, 510, or 5109 are also acceptable. The Option B Onsite Health and Safety Representative must be onsite during all hands on work and will have the ultimate responsibility and authority for monitoring the Environment, Health and Safety aspects of the work. This role shall not have any other duties assigned at any time during the project outside of the role of Onsite Health and Safety Representative or any safety specific duties that would diminish the ability to perform safety oversight for the entire project. For the purposes of this Safety Representative option, the term onsite, means at the specific project location at all times during hands on work.
      3. Option C: A Part-time Onsite Health & Safety Representative with a minimum of two years construction health and safety experience. The person must have a minimum of 30-Hour OSHA Outreach Training for Construction. Completions of OSHA Courses 500, 510, or 5109 are also acceptable. The Option C Onsite Health and Safety Representative must be onsite during all hands on work and will have the ultimate responsibility and authority for monitoring the Environment, Health and Safety aspects of the work. This role may have other duties assigned during the project. For the purposes of this Safety Representative option, the term onsite, means at the LBNL site at all times during hands on work. 🛑

2. Qualification Evaluation
   1. Based on the level of safety personnel required in the contract— Option A, B or C — the subcontractor must submit the following documentation for review and acceptance by the Berkeley Lab EHS Construction Safety Manager prior to the start of work:
      1. Option A: A résumé or curriculum vitae for the proposed Health and Safety Professional showing the required health and safety experience and/or proof of professional certifications (, ASP, CSP, or CIH) as applicable.
      2. Option B or C: Evidence of construction safety training with a minimum of the 30-hour OSHA Outreach Training in Construction ( 🚩 CHST Certification or 🛑 completion of OSHA course 500 or 510 is also acceptable)
   2. A subcontractor must replace his or her EHS Professional, EHS Representative, or Superintendent at the discretion of the Berkeley Lab Project Manager within 24 hours upon written notification if the project is unsuccessful in enforcing project safety requirements. Replacement shall be at no additional cost to LBNL.
   3. 🚩 Any alternate safety representative must meet the same minimum requirements of the Option selected for the project and follow the same review process outlined above. 🛑

3. Subcontractor EHS Professional or Representative Responsibilities
   
   🚩 The Subcontractor Onsite Health and Safety Representative must be identified on the Daily Pre-Task Hazard Analysis (PTHA) form. Any change to the assignment of the Onsite Health and Safety Representative for the day’s activities requires all project work to cease and a new POD/PTHA meeting held, providing a formal handoff of the role. The Subcontractor Onsite Health and Safety Representative will be identified using a PIMD Construction Badge that identifies the agreed upon representative for the project from the defined options above and the minimum roles and responsibilities associated with the role. 🛑
   4. The subcontractor EHS Professional or Representative must:
      1. Assist in the development of the subcontractor’s 🚩 Site Specific Safety Plan 🛑
      2. Support training of subcontractor personnel
      3. Evaluate the subcontractor safety process continuously
      4. Respond to questions regarding the subcontractor safety process
      5. Attend pre-job meetings to discuss their site-specific safety plan
      6. Conduct and document job-site safety audits
      7. Assist in the identification of tasks requiring a Job Hazards Analysis
      8. Ensure that the LBNL Work Planning and Control process is effectively implemented.
      9. Ensure tiered subcontractor safety is properly flowed down and managed.
4. Competent Person
   1. OSHA requires that a Competent Person be available to evaluate and address specific hazard topics. Each subcontractor must provide Berkeley Lab with a written list 🚩(documented via the SSSP) 🛑 of those persons on site capable of identifying existing and predictable hazards, and who has the authorization to take prompt corrective measures to eliminate them.
   2. Subcontractors must ensure that each Competent Person listed has been trained in the following areas as applicable to the scope of work:
      1. Asbestos
      2. Cranes, hoisting, rigging
      3. Confined space
      4. Demolition
      5. Excavations
      6. Fall protection
      7. Ladder
      8. Scaffold
      9. Steel erection
      10. Underground construction
      11. 🚩 Any other hazard that warrants added rigor 🛑
5. Qualified Person
   1. OSHA requires that a qualified person be available to evaluate and address specific hazard topics. Each subcontractor must provide Berkeley Lab with a written list 🚩(documented via the SSSP) 🛑 of on-site persons whose recognized degree, certification, or professional standing, or extensive knowledge, training, and experience, have successfully demonstrated their ability to solve or resolve problems relating to the subject matter, the work, or the project.
   2. Subcontractors must ensure that each qualified person listed has been trained in the following areas, as applicable:
      1. Asbestos
      2. Hazardous-waste operation
      3. Crane
      4. Chemical hazards
      5. Concrete and masonry construction
      6. Electrical, overhead lines (For more information, see Chapter 8 Electrical Safety and Chapter 18 Lockout/Tagout.
      7. Steel erection, open joists, site layout, and plans
      8. Hoists and rigging
      9. Scaffold
      10. Underground construction
      11. Gases, vapors, dust, mist
      12. Ventilation
      13. Material hoisting, personnel hoist, elevators
      14. Excavation

Work Process E. Required Safety Training

1. Training Requirements
   1. Subcontractors must provide a workforce trained to the requirements set forth in general and in the specific substance- and subject-specific standards of 10 CFR 851, Title 8 CCR Subchapter 4 (and as applicable Title 8 CCR Subchapter 7)
   2. Subcontractors must be able to demonstrate the completion of training requirements. 🚩 Proof of training for the work being performed and the workers performing the work must be maintained at the project site at all times. 🛑
2. LBNL Construction Safety Orientation Training
   1. Prior to starting work, all subcontractors and their lower-tier subcontractors must require all employees to complete the LBNL Construction Safety Orientation Training covering at a minimum the Berkeley Lab and subcontractor safety program requirements.
   2. LBNL maintains records of personnel who have completed the orientation training. 🚩 The subcontractor is responsible for tracking completion and retraining requirements for their employees and notifying the LBNL Construction Manager in advance of any training expiration for any subcontractor personnel working onsite.🛑
3. Site Specific Orientation
   1. The subcontractor can require at their discretion additional project site specific training for site access. If such training is required, the subcontractor must make such training available to LBNL staff who need regular job site access.
4. Weekly Toolbox Safety Talks
   1. All subcontractors are required to conduct and document a weekly safety toolbox talk. These talks will be conducted at the job site and contain safety information that will increase safety awareness on this project. The weekly toolbox safety talks must relate to work that is under way or immediately forthcoming.
   2. An attendance roster of signatures must be collected and filed with a copy of the toolbox talk.
   3. Copies of the attendance roster and toolbox talks must be available to Berkeley Lab upon request.
   4. Each subcontractor is responsible for ensuring employee attendance at the safety toolbox talks.
5. Safety Instruction for Employees
   1. When workers are first employed they must be given instruction regarding the hazards and safety precautions applicable to the type of work in question and directed to read the Code of Safe Practices in their company’s IIPP.
   2. The subcontractor must allow only Qualified Persons to operate equipment and machinery.
   3. Where employees are subject to known job-site hazards, such as flammable liquids and gasses, poisons, caustics, harmful plants and animals, toxic materials, confined spaces, etc., they must be instructed in the recognition of the hazard, in the procedures for protecting themselves from injury, in the first-aid procedure in the event of injury, and the location of material hazard information (e.g., Safety Data Sheets [SDSs]).

Work Process F. Emergency Procedures

1. An emergency is any situation that poses an immediate threat to life or property. This would include but not be limited to the collapse of all or part of a building; fire; explosion; equipment failure such as the collapse of a crane; release or exposure to toxic liquids, vapors, or fumes; presence of gas or other explosive atmospheres; or natural disasters, such as floods, earthquakes, etc. Violent or suspicious behavior may also be cause for initiating emergency procedures.
2. All subcontractors must ensure that they maintain one person currently qualified in American Red Cross or equivalent cardiopulmonary resuscitation (CPR) and first aid on site at all times.
3. In the event of a life-threatening or other serious incident (fire, injury, etc.) requiring the assistance of outside personnel, contact Berkeley Lab emergency services immediately at:
   1. 7-9-1-1 for assistance; from an outside line, call 9-1-1
      1. Upon calling, the person must state their name, their contractor’s name, the location of the emergency, and the type of emergency. The caller must stay on the call until released by the emergency dispatcher. The Berkeley Lab Construction Manager must be contacted as soon as practicable.
4. The subcontractor must establish evacuation procedures and provide direction to their employees on changes to evacuation procedures as the job progresses.
   1. For emergencies involving evacuation, all subcontractor personnel will follow the developed, posted evacuation routes to their designated assembly points, and remain there until they are accounted for and an “all clear” or alternate directive is given.
   2. Subcontractors must inform Berkeley Lab as to the location of the designated assembly points for their employees. In the event of an evacuation, the subcontractor must conduct a head count and immediately notify the responding Emergency Services of any missing personnel.
5. After the emergency, the subcontractor must ensure that all proper incident reports are completed and distributed through the Project Manager in the required time frame.
6. A list of “key” on-site and home-office personnel (with 24-hour phone numbers) must be developed by each subcontractor and submitted to the Berkeley Lab Project Manager prior to commencement of work.
7. The Berkeley Lab Project Manager or designated Berkeley Lab management team member in off-hours will take charge in the event of a major catastrophe. The applicable steps are to be followed:
   1. Stop work.
   2. Take whatever actions are needed to make people on the project safe.
   3. Call 7-9-1-1 for assistance; or from an outside line, call 9-1-1.
   4. If necessary, call for site evacuation with roll call and clear the site-access roads.
   5. Issue instructions to all supervisors and employees.
   6. Set up security control at the emergency area.
   7. Refer all media requests to the Berkeley Lab Communications and Media Relations Group.

Work Process G. Incident Site Control and Reporting

1. Incident Control. If a job-site accident occurs, the subcontractor will immediately implement controls and restrictions on the accident site to ensure the scene of an accident remains undisturbed until the Berkeley Lab Project Manager issues a written release to resume work.
2. Near-Miss/Injury-Free Event. The subcontractor must review near-miss incidents for lessons learned and report these occurrences to the Berkeley Lab Project Manager within 24 hours of the near miss. OSHA defines a near miss as “incidents where no property was damaged and no personal injury sustained, but where, given a slight shift in time or position, damage and/or injury easily could have occurred.”
3. First-Aid Event. The subcontractor must collect and log their incident reports and recommended corrective action. The incident logs and work-hour statistics will be sent to the Berkeley Lab Construction Manager by the first of each month.
4. Medical Treatment Event. If the injury is considered an emergency, immediately call 7-9-1-1 from Laboratory phones or 9-1-1 from any cell phone. The subcontractor must immediately notify the Berkeley Lab Project Manager. The subcontractor must furnish a copy of OSHA Form 301(or equivalent) to the Berkeley Lab Project Manager within five days of the injury.
5. Electric Shock
   1. All electric shocks regardless of apparent injury or status of the person receiving the shock are potentially serious and require immediate medical evaluation and care. The individual receiving a shock must be immediately transported to the nearest available medical facility for an assessment. If the individual has any apparent symptoms from the shock then emergency services should be immediately contacted via 9-1-1. During normal business hours, the LBNL Health Services at Building 26 is the closest medical facility.
   2. Report all electrical shocks to the LBNL Project Manager (PM) or Construction Manager (CM) immediately.
6. Post-Injury Event or Post-Scene Stabilization. The prime subcontractor must immediately notify the Berkeley Lab Construction Manager of any serious injury event requiring medical treatment. Refer ALL media inquiries to Berkeley Lab Communications and Media Relations Group.
7. Fatality
   1. The subcontractor must notify the Berkeley Lab Project Manager. Division management will then notify the appropriate Department of Energy (DOE) office.
   2. The subcontractor must notify Cal/OSHA within eight hours.
   3. Refer ALL media inquiries to the Berkeley Lab Communications and Media Relations Group.

🚩🚩Work Process H. Stop Work Authority (SWA) Order

As a subcontractor working within the LBNL organization, you have the right and responsibility to stop work when you see something unsafe, when you have questions or concerns, when you see something that poses an imminent danger, when conditions or the job scope changes, when any established control is rendered ineffective, or when a deficiency in the plan is noted. An “imminent danger” is defined as any condition or practice that could reasonably be expected to cause substantial harm to the health and safety of employees or the public, or to the environment.

Stop Work Authority should not only be initiated for conditions or behaviors that threaten danger or imminent danger to person(s), equipment or the environment.

Subcontractor Personnel are also expected to stop work:

• if anyone feels that personnel, the environment, or equipment is at risk
• immediately following an incident
• following any unexpected alarm or alert
• if there is any unplanned change in conditions
• as unplanned changes to scope of work or work plan arise
• when an emergency occurs
• when equipment is being used or could be used improperly
• if there is a perceived or actual lack of knowledge, understanding, or information
• immediately following a near-miss incident
• anytime a control is potentially rendered ineffective or changed from an established or agreed upon control or procedure
• if you are unsure about the task you are performing

The purpose of the Stop Work Authority is to establish a uniform method for stopping work. Stop Work Authority establishes the responsibility and authority of any individual to stop work when an unsafe condition or act could result in an undesirable event. This applies to everyone (regardless of time on the job or experience level). Any form of retribution or intimidation directed at any individual or company for exercising their right to issue a stop work authority will not be tolerated.

The STOP WORK AUTHORITY process is stop, notify, correct, and resume.

The STOP WORK AUTHORITY process detailed below is used to create framework for the use of Stop Work Authority, to create lines of communication that are uniform and consistent during a Stop Work order, to identify a path for correction of conditions that align with the nature and risk of the condition, and perhaps most importantly to establish clear conditions for restart based on a graded assessment of the condition and an agreed upon rigor for correction.

A Stop Work Order is initiated when anyone believes a condition or behavior poses the risk of imminent danger to people, equipment, or the environment, sees something unsafe, has questions or concerns, believes conditions or scope have changed or are changing, believes an established control is possibly rendered ineffective, or when a possible deficiency in a plan is noted, a stop work order must immediately be initiated and all affected employees notified. The stop work order should be clearly communicated and identified as a stop work action and initiated in a non-combative manner.

The Stop Work Order is initiated universally without regard to the severity or the perceived risk associated with the condition. The graded approach to Stop Work Authority begins after the Stop Work Order is issued and is detailed in the steps below.

The graded approach for each step will be applied based on the three tiers outlined below. These conditions must be agreed upon by the person issuing the Stop Work Order and all affected personnel and any disagreement in regards to tier, will defer to the higher tier.

Tier 1: Conditions are deemed to have no effect on the safety of personnel, the perceived risk is deemed not to be credible by all parties involved, the perceived risk is deemed to be incorrect, or the information provided after the Stop Work Order provides sufficient details that render the Stop Work Order unnecessary. These conditions are generally considered low risk, can usually be resolved quickly in the field at the time without follow up actions, and will have no impact on other projects.

Tier 2: Conditions are deemed to have a potential effect on safety, the perceived risk is deemed to be credible by any parties involved, or the information provided after the Stop Work Order does not provide sufficient details to render the Stop Work Order unnecessary. These conditions are generally considered to be medium risk and may require follow up actions beyond the project or time of the order.

Tier 3: Conditions are deemed to have a definite effect on safety and the risk is confirmed. These conditions are generally considered high risk and will require formal follow up actions beyond the field and have impact beyond the project.

Stop has been initiated. Once all affected workers have complied, and all conditions have been rendered safe, the following steps must be taken in ascending order:

Notify the line management and oversight personnel of the Stop Work Order.

Minimum tier 1 notifications include the Subcontractor Onsite Health and Safety Representative, Subcontractor Superintendent, and the LBNL Construction Manager.

Minimum tier 2 notifications include all of the tier 1 plus the LBNL EHS Field Representative, Subcontractor Project Manager, and the LBNL Project Manager.

Minimum tier 3 notifications include all of tier 1 and tier 2 plus the LBNL Project Director, PIMD Division Director, EHS Division Director.

Correct the condition in a manner consistent with the level of risk and the severity of the potential outcome.

Minimum tier 1 corrections will be determined with agreement from the person issuing the Stop Work Order, all affected personnel, the Subcontractor Onsite Health and Safety Representative, the Subcontractor Superintendent, and the LBNL Construction Manager. These corrections may be informal in nature and are not required to be documented.

Minimum tier 2 corrections will be determined with agreement from all tier 1 personnel plus the LBNL EHS Field Representative, Subcontractor Project Manager, and the LBNL Project Manager. These corrections may be formal in nature and must be documented. These corrections may require follow up or corrective actions.

Minimum tier 3 corrections will be determined with agreement from all tier 1 and tier 2 personnel, the LBNL Project Director, the PIMD Division Director, and the EHS Division Director. In addition, these corrections will require formal corrective actions based on formal investigations.

Resume work only after receiving authorization from all parties and confirmation of the above corrections.

Minimum tier 1 restart authorization will be determined with agreement from the person issuing the Stop Work Order, all affected personnel, and the Subcontractor Onsite Health and Safety Representative. The Subcontractor Superintendent, and the LBNL Construction Manager should be engaged by the Subcontractor Onsite Health and Safety Representative. This Authorization may be informal in nature and is not required to be documented.

Minimum tier 2 restart authorization will be determined with agreement from all tier 1 personnel plus the LBNL EHS Field Representative, Subcontractor Project Manager, and the LBNL Project Manager. This will be formal in nature and must be documented. This tier requires verification of all corrections or corrective actions.

Minimum tier 3 restart authorization will be determined with agreement from all tier 1 and tier 2 personnel, the LBNL Project Director, the PIMD Division Director, and the EHS Division Director. In addition, these corrections will require verification of completion of all formal corrective actions and may require an effectiveness review.

• STOP WORK AUTHORITY (SWA) ROLES AND RESPONSIBILITIES
  • LBNL employees and contract workers-employees and contract workers are responsible for initiating stop work intervention when appropriate, supporting the intervention of others, reporting all stop work actions and assisting in the investigation of SWA matters.
  • Subcontractor foremen, supervisors and managers-Foremen, supervisors and managers shall promote a culture where SWA is exercised freely, work to investigate and address SWA concerns and ensure all SWA concerns are addressed before work resumes. These individuals ensure all necessary stop work follow-up is completed and that all stop work reports are filed and reviewed.
  • Safety personnel-Provide guidance, expertise, and support to help guide the SWA process.
  • Senior management-Senior management creates a culture that promotes SWA, allows SWA to be exercised freely, establishes clear expectations and responsibilities, resolves SWA conflicts when they arise and holds accountable anyone who chooses not to comply with established SWA policies. They also hold employees and contractors accountable for full compliance with the SWA program. All stop work reports will be reviewed by senior management.

Difference of Opinion

Differences of opinion regarding a Stop Work Authority among the Berkeley Lab Project Manager, Berkeley Lab Construction Safety Professional, and others must be immediately referred to the respective functional supervisors for resolution.

The recommendations of the Berkeley Lab Construction Safety Professional must be followed until a final decision is made. The Berkeley Lab EHS Division Director makes the final determination. 🛑

Work Process I. Visitors

1. Visitor Access
   1. All visitors must report to the project field office upon entering the project site.
   2. Access to the site must be denied to any individual who does not have justifiable business on the job site.
2. Visitor Tours
   1. Requests for tours of the project site must be carefully screened and limited in frequency and numbers of people.
   2. Tours of the site must be approved by the Berkeley Lab Project Manager and the Berkeley Lab Construction Manager.
   3. Berkeley Lab will establish the time and travel route for any tour.
   4. Areas that may present hazards to tour groups must be avoided.
   5. The tour’s travel route must be clear of any tripping hazards and properly protected to avoid potential personal injury.
   6. A designated member of Berkeley Lab must guide the approved tours.
3. Visitor Protective Wear. All visitors must wear long pants, shirts with sleeves over the shoulder, hard hats, safety glasses, and hard-soled work shoes or boots when on site. No penny loafers, dress shoes, or other inappropriate footwear will be permitted. In addition, any specific PPE the general contractor may require.

Work Process J. Work Planning and Control

1. Contractor Plan-of-the-Day Meeting. The plan of the day (POD) process is required to maintain daily positive control over task-level work and to establish a high level of communication between subcontractors prior to the start of construction activities for the day.
   1. The basis of the POD process is in preplanning. First-tier contractors and any/all lower-tier subcontractors shall identify all planned tasks on a POD and Pre-Task Hazard Analysis (PTHA) form. The level of detail must be appropriate to define all tasks’ that may present a hazard to people, property or environment. The listed task(s) shall include the corresponding PTHA. If the proposed task does not have a corresponding PTHA, then a new PTHA will need to be developed and reviewed prior to the work moving forward.
   2. The completed POD and PTHA must be submitted to the first-tier subcontractor for review against conflicting operations, regulatory hold points, and required permits and with an acceptable level of detail. The plan must be submitted in a timely fashion (preferably the day before) to ensure that the first-tier subcontractor can perform a quality review of the plan. A representative for each subcontractor performing work that day must have submitted their proposed POD/PTHA to the first-tier contractor superintendent or designee prior to the start of the meeting for review and work approval. The first-tier subcontractor shall record what subcontractors were in attendance at the POD. Subcontractors that are not present at the POD shall not be authorized to perform work until their POD/PTHA is submitted and approved by the first-tier subcontractor.
   3. During the POD meeting, each subcontractor must present their POD work activities to the attendees to control co-located hazards. The first-tier contractor should have a size D drawing or other effective project pictorials available that can be referenced during the POD meeting.
   4. Upon completion of the initial POD meeting, each subcontractor is then required to have breakout sessions (daily “tailgate” meetings) with each work crew member prior to the start of each work shift, or when an individual arrives at work. The meeting shall include a discussion of the specific POD and corresponding PTHA for their work and additional safety topics of interest related to the site.
   5. All crew members shall acknowledge the POD (daily “tailgate meeting) by signing an attendance roster for the POD/PTHA.
2. All construction work must be planned and controlled at a level that ensures all personnel understand:
   1. The authorized scope of work
   2. The hazards of performing the work
   3. The control measures that will be used to address the hazards
   4. The requirements to stop whenever the work changes from what has been authorized and the actions required to ensure that the change is incorporated into the work plan and can proceed safely.
   5. The POD is focused on all activities at the job-site whereas the PTHA briefing is focused on a single crew or group of workers performing the same tasks.
3. Pre-Task Hazard Analysis (PTHA) briefings shall be held each day prior to the start of work activities. The flexibility exists for each subcontractor to integrate these requirements into their existing EHS program format as long as the required information is effectively provided to employees, and documentation for these briefings and/or meetings is maintained. This may be accomplished through daily construction meetings, plan of the day (POD) meetings, pre-task activity reviews, or other means that prove to be effective in disseminating required information and have been accepted by LBNL.
4. Records for briefings that document meeting content and attendance shall be maintained in the on-site project binder. All crew members shall acknowledge the disseminated information by signing the attendance roster.
5. The briefing content shall include at a minimum the following topics:
   1. EHS pre-task planning for the day’s work activities
   2. Changes in work practices or environmental conditions
   3. Required equipment/system daily inspections
   4. Previous days incidents, near misses, lessons learned, and/or other relevant issues as applicable
   5. Other ongoing activities that may have project EHS implications
   6. New or modified site-wide procedures or requirements
   7. Review of JHA for new activities and/or revised existing JHAs
6. Each briefing must reinforce the requirement to stop and update the PTHA prior to making any changes in task assignments or locations that differ from what was covered in the briefing and documented in the PTHA. Another pre-job briefing addressing the change is required prior to implementing any changes that occur after the start of shift briefing.
7. Perform the Work.Only the work documented in the PTHA and discussed in the pre-job briefing may be performed.
   1. Any change in scope or hazards during the shift requires an update of the PTHA and a re-briefing of the affected workers.
   2. If new workers join the task after the briefing, the new workers must receive the pre-job briefing prior to starting work.
8. Feedback and Lessons Learned. During any given work shift there may be significant or simple lessons learned. Lessons learned should be shared at PODs, safety meetings, and pre-job briefings in order to improve the overall performance of the job. Examples of lessons learned that should be identified and shared include:
   1. Identification of new hazards
   2. Identification of new or improved hazard controls
   3. Identification of process improvements
   4. Identification of potential flaws in the design or work plan that could be improved
   5. Identification of better work practices that make the work safer or more productive
9. Out of Sequence Change Control. As required by contract or change notice: If during the course of the day, additional task(s) need to be performed that are not identified on the POD, then the subcontractor’s responsible supervisor shall add this task to the POD, revise the PTHA as necessary, receive approval from the first-tier contractor superintendent or designee, and contact the LBNL Construction manager for Authorization. If approved, the requesting contractor will brief the affected crew of the work task changes and revised PTHA. Affected crew members must initial and date their re-review of the POD/PTHA.
10.  Contractor /LBNL Permit Meeting
    1. As required by contract or change notice: A daily permit meeting shall be held to facilitate upcoming work activities in a timely manner. The meeting shall be attended at a minimum by the contractor’s permit requestor and the project work planner/coordinator. Permit requests shall be identified on the applicable LBNL permit form. A workability walk down shall be completed, a risk value assigned per the Work Planning and Control (WPC) procedure, and any required hold points identified. The completed information will be submitted by the work planner/coordinator to the LBNL Site Manager for review and authorization through the LBNL coordination meeting.
    2. The first-tier contractor should have size D drawings or other effective project pictorials available, and all active permits shall be clearly identified on the permit board. The permit board shall be maintained on a daily basis and shall be referenced during the POD meeting to communicate co-located hazards.
11.  LBNL Coordination Meeting
    1. As required by contract or change notice: A daily 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 contractor’s superintendent, the work planner/coordinator, and the contractor’s site safety manager.
    2. The meeting will verify the risk matrix and safety basis 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 completed will be authorized for the next day’s demolition activities.
    3. The POD activities report will be provided by the LBNL Project Manager or designee to the construction superintendent for presentation at the next day’s contractor POD meeting.

Work Process K. Specific ES&H Requirements: Permits

1. General. Permits are required for the activities listed below and must be obtained prior to start of work. Permits must be posted conspicuously at the work site.
2. Fire Safety Permit
   1. All hot work requiring the use of open flames and/or heat- or spark-producing equipment requires a Fire Safety Permit from the Berkeley Lab Fire Department.
   2. Construction subcontractors may request a Fire Safety Permit directly from the Fire Department or through the Project Manager.
   3. Upon request for a Fire Safety Permit, the Fire Department’s representative meets the requester at the work location to discuss precautions to be taken, including the placement of fire extinguishers or a fire watch.
3. Penetration Permit
   1. All work that requires excavating, drilling, or driving stakes or poles 1 5/8 inches or deeper into a surface requires a permit.
   2. A permit is also required to penetrate any depth into existing concrete surfaces such as floor slabs, walls, beams, or columns.
   3. The permit is issued by the Berkeley Lab Utilities Engineer.
      1. Subcontractors may obtain the permit through the Construction Manager or Project Manager.
4. Fall Protection Matrix Permit
   1. All work that requires work on any walking or working surface having an unprotected side or edge that is 4 feet high or more for General Industry workers, and 6 feet high or more for construction workers requires a Fall Protection Matrix Permit. Surfaces include, but are not limited to, leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 1.2:1 (horizontal to vertical), hillsides, roofs, and surfaces with open holes or skylights.
   2. The fall protection matrix permit must be filled out and signed by an LBNL Fall Protection Competent Person prior to start of work.

Work Process L. Specific ES&H Requirements: Accident and Injury Information

1. Contaminated Spills
   1. Berkeley Lab’s primary concern is to protect the workers and the environment in the event of an incidental spill.
   2. If a spill occurs, it must be immediately isolated and contained to prevent contamination of the surrounding area, waterways, sewer systems, or any other environmental impact.
   3. The subcontractor is responsible for all costs associated with the cleanup and disposal of the contaminated/hazardous materials.
   4. If a spill occurs, the SDS for the chemical will provide the emergency information necessary to address the spill. The emergency cleanup team will need a copy of the SDS to begin the cleanup process.
   5. The subcontractor must immediately notify the Berkeley Lab Project Manager in the event of any spill.
   6. All subcontractors must assign trained employees who are capable of handling spills. Whenever chemicals are brought on site, the SDS must be reviewed by the subcontractor and its information communicated to all personnel exposed to its usage. If special spill response materials or equipment are specified in the SDS, then the subcontractor must be provided those materials or equipment in quantities adequate to address the largest potential spill of the material.
   7. All subcontractor records regarding spills must be copied and given to the Berkeley Lab Project Manager for filing.
2. CPR and First Aid
   1. All subcontractors must have at least one person certified in first aid and CPR at the job site at all times.
      1. Subcontractors are solely responsible to ensure the required and proper CPR and first-aid training of their employees.
      2. First aid providers must also be trained in the decontamination of blood spills and bloodborne pathogens.
   2. Subcontractors must provide an ANSI Z 308.1–approved first-aid kit on the job site.
      1. The subcontractor site superintendent must ensure that the kit is properly stocked, maintained, and inspected weekly per OSHA requirements.
      2. The first-aid kit will also contain equipment and materials to be compliant with Cal/OSHA, General Industry Safety Orders, Section 1593 — Blood-borne Pathogens, including mouth-to-mouth resuscitation devices, powdered bleach, and disposable latex gloves.
3. Bloodborne Pathogens
   1. Bloodborne pathogens are disease-causing organisms transmitted through contact with infected blood and other bodily fluids.
   2. Any exposure to an infected individual’s body fluids may result in transmission of bloodborne pathogens, which could lead to disease or death.
   3. When dealing with blood or other bodily fluids, subcontractor employees are required to follow universal precautions.
      1. According to the concept of universal precautions, all human blood and other human body fluids are treated as if known to be infectious for HIV, hepatitis B, and other bloodborne pathogens.
   4. All subcontractors certified in first aid must wear disposable latex gloves and eye protection while performing first aid on an injured individual.
   5. If rescue breathing or CPR is performed, a resuscitation mask must be provided by the subcontractor to protect the injured and the provider.
   6. The subcontractor must immediately contain and clean all blood spills with an antiviral solution, or with a solution of bleach and water.
   7. Any material saturated with blood must be considered regulated waste, including liquid or semiliquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semiliquid state if compressed; and items caked with dried blood or other potentially infectious materials.
      1. Discarded Band-Aids and gauze containing small amounts of blood products are not considered regulated waste.
   8. The cleanup and disposal of all regulated waste are the sole responsibility of the subcontractor under his or her bloodborne pathogen control program.

Work Process M. Specific ES&H Requirements: Hazard Communication

1. General
   1. The Cal/OSHA Hazard Communication Standard requires that all employers with employees potentially exposed to hazardous chemicals at their work site establish a hazard communication program.
   2. The regulation is more commonly known as “HazCom” or the “Right-to-Know Law.”
2. Subcontractor Hazard Communication
   1. All subcontractors are solely responsible to abide by the Hazard Communication Standard in training their own employees, their Safety Data Sheet (SDS) record keeping, their notification procedures, and any other aspects of the requirement.
   2. All subcontractors must supply the Berkeley Lab Project Manager with a written copy of their hazard communication program along with the SDS, or the SDS for any chemical materials brought on to the job site.
   3. Subcontractors must train their workers in accordance with their hazard communication program.
   4. All containers must be labeled in accordance with the applicable program.
   5. The exchange of SDS must take place initially when the subcontractor comes onto the site, at regular site-safety meetings, and/or at any other designated time by the Berkeley Lab Project Manager.
   6. All workers on the job site, regardless of their employer, must be informed of the location of SDSs and have access to SDSs for all chemicals in use on the site.
   7. All subcontractors must abide by this exchange and are to immediately inform the Berkeley Lab Project Manager of any new chemical substances brought onto the job site.

Work Process N. Specific ES&H Requirements: Procurement of Hazardous Materials

1. The subcontractor must submit to the Berkeley Lab Project Manager, for review by the Berkeley Lab EHS Division, any proposed procurement, stocking, installation, or other use of materials containing asbestos, cadmium, chromates, or lead. Additionally, the subcontractor must submit the product’s safety data sheet (SDS) for architectural and surface coatings, solvents, adhesives, sealants, oils, compressed gasses, pesticides, herbicides, welding materials, or other chemicals used in the construction process, for review and acceptance by the Berkeley Lab EHS Division prior to the start of work.
2. All materials and applications must comply with all requirements of the Bay Area Air Quality Management District (BAAQMD) regulations, including, but not limited to architectural coatings, general solvent and surface coatings, solvent cleaning operations, adhesive and sealants, visible emissions, and asbestos.
3. The subcontractor must keep and maintain proof of compliance with the above-referenced regulations, including any recordkeeping obligations, for two years after completion of the project. The subcontractor must make such documents or evidence available if requested by the BAAQMD or Berkeley Lab.

Work Process O. Specific ES&H Requirements: Return to Work

1. To provide prompt quality medical services and to return injured employees to the project as soon as possible, all subcontractors must establish a “light duty” or “restricted duty” policy for their employees in the event they are injured on this project and cannot perform normal daily duties.
2. A restricted-duty assignment must be provided to any employee who, because of a job-related injury or illness, is physically or mentally unable to perform all or any part of his/her normal assignment during all or any part of the normal workday or shift.
3. All work-related injuries must be reported to the Berkeley Lab Project Management Team immediately.
4. If any employee has any doubt as to where to go for medical treatment for a job-related injury, he or she must contact the Berkeley Lab Project Management Team.
5. When an injured employee returns to work, all physical and mental limitations must be evaluated to prevent additional injury or aggravation. The safety of other employees working with the injured individual must also be considered.
6. Injured employees may return to work on restricted duty under the following circumstances:
   1. The employee’s attending physician has defined the physical restrictions.
   2. The subcontractor has a task that can be assigned that meets the restrictions
   3. The project managers, supervisors, and foreman are informed of the restrictions.
   4. The employee must receive full medical release from a physician before resuming normal work activities. No employee on restricted duty will be allowed to work more than 40 hours per week.
   5. The injured employee will remain on the project where the injury occurred while on restricted duty.

Work Process P. Noncompliance

To ensure compliance with the requirements of this safety program and all established OSHA standards, Berkeley Lab implements this procedure to address noncompliances by subcontractors working on Berkeley Lab–controlled property. Noncompliances identified by LBNL are to be attributed to the offending subcontractor and timely corrective action is expected. Except in cases of clear negligence or willful violation by an individual worker, LBNL will not get involved in disciplinary actions for individual subcontractor employees.

1. Safety Partnering
   1. LBNL expects all subcontractors to self-identify and correct non-compliances and unsafe conditions on the job site without prompting from LBNL.
   2. LBNL will recognize and reward subcontractor efforts to self-identify and correct non-compliances and unsafe conditions.
   3. LBNL EHS resources strive to work as partners with subcontractors to ensure safe and compliant projects. LBNL EHS resources assist subcontractors and their workers in the understanding of LBNL and regulatory requirements. Cooperation and teamwork between all parties is welcome and necessary to achieve the high level of safety performance desired by all.
   4. The LBNL Construction Safety Professional, LBNL Construction Safety SME, the LBNL Construction Manager, or the LBNL Project Manager may identify non-compliances with applicable environment, health, and safety requirements. The observation of work and the correction of non-compliances and unsafe behaviors are intended to reinforce desired behaviors and conditions and correct unsafe behaviors and conditions.
   5. Day to day noncompliance issues that can be quickly addressed may be handled verbally. If corrected on the spot, no written record is required except for issues resulting in an imminent danger to personnel or the environment.
   6. LBNL personnel perform work observations that are documented in a database for the purpose of tracking, trending, and improving job safety (see Work Process Q).
   7. LBNL expects a small amount of minor non-compliances to arise due to misunderstandings, differences of opinion, misapplication of rules, poor judgment, and worker errors. LBNL expects these non-compliances to be identified and corrected with no documentation and little consequence.
   8. High-risk offenses that put workers or the environment in imminent danger of serious harm will be stopped and recorded in writing. This action will be followed by meetings as needed between the responsible subcontractor supervisor, subcontractor superintendent, and LBNL PM or LBNL CM until an agreement is reached that the noncompliance has been sufficiently addressed and the work can be restarted.
   9. Some moderate and most high-risk offenses require reporting to the DOE via the DOE Occurrence Reporting and Processing System (ORPS) or the DOE Non Compliance Tracking System (NTS). Each subcontractor must cooperate with LBNL to gather and report the facts when ORPS or NTS reporting criteria are met.
2. Safety Citation Procedure for Addressing Egregious Noncompliance
   1. When partnering fails to achieve a high level of safety performance, LBNL may implement the Safety Citation Procedure. The intent of this procedure is to enforce compliance, correct repetitive noncompliance issues, or to address non-compliances in which a subcontractor has failed to adequately address the issues raised by LBNL or the subcontractor’s own personnel.
   2. The Berkeley Lab PM and CM have sole authority in the execution of the Safety Citation Procedure, but intend that it only be implemented after other efforts to improve job-site safety compliance fail to result in satisfactory performance.
      1. Safety Citation: At the recommendation from LBNL construction safety personnel or at the discretion of the LBNL CM or PM, a written safety citation may be issued by the LBNL PM to the general contractor (GC). The issuance of a safety citation may be based on the severity of a single noncompliance or a trend of identified non-compliances that the subcontractor has inadequately addressed. The safety citation puts the GC on notice that effective corrections must be implemented immediately and identifies any potential consequences. Consequences may include, but are not limited to, simple work process adjustments, stop work actions, removing subcontractor workers from LBNL sites, financial penalties, and termination of the subcontract.

Work Process Q. Work-Site ES&H Observations

1. General
   1. EHS Division Construction Safety Engineers and Facilities Division Construction Management conduct routine observations of construction work sites to identify and correct unsafe workplace conditions and behaviors.
   2. Both “at risk” and “safe” conditions and behaviors are identified during the observations.
   3. These conditions are recorded in a construction safety observation database that is used to track and report trends in construction-safety performance.
2. Determining Classification of At-Risk Observations
   1. The observer classifies each at-risk condition or behavior as de minimis (e.g., insignificant), low, medium, or high, and enters it into the construction safety observation database.
   2. Classification of at-risk observations are assigned by the observer based on a risk-assessment methodology that uses a 4×4 matrix of impact and probability.
   3. The risk-assessment table is based on the Risk Registry Risk Assignment Matrix found in Appendix P of the Berkeley Lab Facilities Division, Construction Projects Department, Project Management Manual.

At-Risk Observation Classification Risk Assessment Table

	No Injury	First Aid	Medium Severity	High Severity
High Probability	De minimis	Medium	High	High
Medium Probability	De minimis	Low	Medium	High
Low Probability	De minimis	Low	Low	Medium
No Probability	De minimis	De minimis	De minimis	De minimis

3. Construction Safety Observation Relationship to the Occurrence Reporting and Processing System (ORPS) and Noncompliance Tracking System (NTS) Reporting. All medium-risk and high-risk construction safety observations are reported to the appropriate responsible individuals for review as possible ORPS or NTS reportable events.

10.8 Source Requirements

Subcontractors must comply with requirements; in case of conflict or overlap of the references below, the most stringent provision must apply.

Source Requirements Documents

• ANSI/SAIA A92.20, A92.22, and A92.24-2018 MEWP Standards
• ANSI/ASSP A10.8-2019 Scaffolding Safety Requirements
• California Occupational Safety and Health Act (Cal/OSHA)
• Title 8 CCR, Subchapter 7, General Industry Safety Orders, California Department of Industrial Relations
• Title 8 CCR, Subchapter 4, Construction Safety Orders, California Department of Industrial Relations
• 10 CFR 851, Worker Safety and Health Program
• 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses
• 29 CFR 1910 Occupational Safety and Health Standards and ACGIH Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices
• National Electrical Safety Code, ANSI C2
• National Fire Protection Association (NFPA) 51B, Fire Prevention During Welding, Cutting, and Other Hot Work (2014 edition)
• NFPA 70 National Electrical Code; and (h) NFPA 70E Standard for Electrical Safety in the Workplace (version referenced in the LBNL ES&H Manual [PUB-3000])
• NFPA 241, Safeguarding Construction, Alteration, and Demolition Operations (2013 edition).
• Lawrence Berkeley National Laboratory Requirements and Policies Manual, Construction Health & Safety policy
• Lawrence Berkeley National Laboratory Construction Safety Manual
• Lawrence Berkeley National Laboratory Electrical Safety Manual
• 40 CFR Part 763, Asbestos
• Clean Air Act
• Clean Water Act
• Resource Conservation and Recovery Act
• Toxic Substances Control Act
• American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values for Chemical Substances and Physical Agents (most current version)

Other Driving Requirements
California Code of Regulations: 

• Bay Area Air Quality Management District (BAAQMD) Rules, Regulations, and Manual of Procedures, including Diesel Vehicle Idling Rules, On- and Off-Road Diesel Vehicle Regulations, and CEQA Guidelines
• California Department of Public Health
• East Bay Municipal Utility District Ordinances 40 CFR Parts 122 through 125, National Pollutant Discharge Elimination System (i.e., water quality).  California’s General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit), as specified in the State Water Resources Control Board (SWRCB) Order No. 2009-0009-DWQ (as amended by 2010-0014-DWQ and 2012-0006-DWQ) and California’s General Permit for Storm Water Discharges Associated with Industrial Activities excluding Construction Activities, as specified in the SWRCB Order No. 2014-0057-DWQ
• California Fire Code (2010 edition)
• Title 8, Division 1, Chapter 4, Industrial Safety Article 15
• Title 13, Division 2, Chapter 6, Hazardous Materials for Transportation by Commercial Carriers
• Title 17, Division 3, Air Resources
• Title 19, Public Safety
• Title 22, Divisions 4 and 4.5, Hazardous Waste;
• Title 23, Division 3, Water Quality
• Title 23, Division 5, Hazardous Materials
• ANSI Z359 Fall Protection
• ANSI Z88.2 Respiratory Protection
• ANSI Z136.1 Safe Use of Lasers
• ANSI Z49.1 Welding, Cutting, and Allied Processes

10.9 Reference Documents

Document Number	Title	Type
07.07.011.001	Chapter 8 Electrical Safety Program	Program
07.07.020.001	Chapter 18 Lockout/Tagout	Program
07.11.001.001	Chapter 12 Fire Prevention and Protection	Program
07.07.024.001	Chapter 19 Personal Protective Equipment	Program
07.07.008.001	Chapter 27 Cranes, Hoists, and Rigging Safety	Program
07.07.008.001	Chapter 28 Forklifts and Other Powered Industrial Trucks	Program
07.07.014.001	Chapter 30 Fall Protection Protection Program	Program
07.07.006.001	Chapter 34 Confined Spaces	Program
07.07.002.001	Chapter 36 Asbestos Hazards and Controls	Program
07.07.019.001	Chapter 37 Lead Hazards and Controls	Program
07.07.001.000	Chapter 35 Mobile Elevating Work Platforms — Aerial Work Platforms, Ladders, and Scaffolds	Program

 

10.10 Appendix A. LBNL Construction Safety Manual

Click here to download a PDF of the LBNL Construction Safety Manual.

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