Subcontractor Environmental,Health and Safety (EHS) PlanMarch 2014NOVO Construction, Inc.

Table of ContentsGENERAL SAFETY . 4PROJECT ENVIRONMENT, HEALTH & SAFETY PLAN. 4Introduction. 4Project Environment, Health and Safety Plan Elements . 4Project Environment, Health and Safety Plan Administration . 4Responsibilities . 5Program Requirements . 5ENVIRONMENT, HEALTH AND SAFETY SURVEILLANCE POLICY AND PROCEDURES . 7Surveillance Policy . 7Violation Notification Procedures . 7Abatement . 8Notice to Employee of Safety and Health Violation . 9Tagging Equipment Out of Service . 9PROJECT ENVIRONMENT, HEALTH AND SAFETY PROGRAM OPERATION . 9Project Environment, Health and Safety Program Manual . 9Project Construction Coordination Meetings . 9Accident/Incident Reporting . 9OSHA Inspection Procedures . 10FIRE PROTECTION . 10Responsibilities . 10Reporting Fires . 10SPECIFIC REQUIREMENTS. 11First Aid . 11Tours and Site Visitors . 11Site Access Control . 11Job Hazard Analysis (JHA). 12Housekeeping . 13Ground Fault Protection. 14Hazardous Material (HM) . 14Onsite Storage and Dispensing of Flammable and Combustible Liquids . 14Fall Protection . 14Scaffold Tagging Procedures . 15Confined Space Entry Procedure. 16Trenching and Excavation Notice . 17Barrier Tape Identification System . 17Welding and Cutting Permit . 18Steel Erection . 18DEMOLITION-RELATED HAZARDOUS MATERIALS PROTECTION PROGRAM . 20General . 20Worksite-Specific Procedure. 20Demolition-Related Hazardous Materials Protection Program Awareness Training. 20Pretask Activities . 20Emergency Response. 21Identification of Demolition-Related Hazardous Materials . 21LOCKOUT/TAGOUT CLEARANCE PROCEDURES . 24Requirements. 24i

PROJECT ENVIRONMENT, HEALTH AND SAFETY RULES . 24Policy . 24Mandatory Project Environment, Health and Safety Rules . 24SAFETY POLICY MEMORANDUM. 24EMERGENCY PROCEDURES . 25PROJECT EMERGENCY RESPONSE PROCEDURES . 25Introduction. 25Medical Emergency Response . 25Fire and Hazardous Material Response Plan. 26Large Scale Catastrophic Events . 27SPECIFIC ITEMS . 27Fire / Hazardous Materials Evacuation Muster Points . 27Major Catastrophes Evacuation Muster Points. 27Bomb Threat Evacuation Muster Points . 27In all cases: . 27APPENDIX A . 28FIGURES . 28NOVO Construction Project EHS Documentation Submission Requirements . 28ii

General SafetyProject Environment, Health & Safety PlanIntroductionThis Project Environment, Health and Safety (EHS) Plan provides an administrative structure withinwhich contractors present on the project site shall provide both for the health and safety of theiremployees and other individuals affected by their activities and for the protection of property and theenvironment. The Project EHS Plan does not relieve contractors of any of their traditional or specificlegal responsibilities with respect to occupational health and safety or the protection of property andthe environment. Instead, the Project EHS Plan provides for consistency among the variouscontractors’ individual programs; monitoring of contractors’ conformance with their individualprograms, the Project EHS Program, and the NOVO Construction Environment, Health and SafetyContractor Requirements; initiation of corrective actions when nonconformances are identified; andadministration and reporting to reveal the effectiveness of the Project EHS Program.Project Environment, Health and Safety Plan ElementsThe Project EHS Plan includes the following major elements: A Project EHS Plan that will establish safety, health and environmental guidelines andrequirements. Identification of the minimum requirements for individual contractors’ environment,health and safety programs. Review of each contractor’s environment, health and safety program for conformancewith the minimum requirements of a contractor’s EHS Program. Monitoring of the contractors’ activities for general compliance with the Project EHSPlan and the Contractors’ EHS Program requirements. Procedures for advising contractors of environment, health and safety violations andissuance of violation notices. Procedures for initiating corrective action and back charges to the contractor if he/shedoes not comply with environment, health and safety violation notices. Weekly construction coordination meetings that contractors are required to attend. Monthly safety and health reports. All NOVO Construction safety forms or Contractor’s equivalent shall be used to ensurecompliance with all aspects of this EHS Plan.Project Environment, Health and Safety Plan AdministrationNOVO Construction shall administer and have such authority as described in this Project EHS Plan,to the Contractor’s Environment, Health and Safety Responsibilities and Program Requirements1

ResponsibilitiesThe Project EHS Plan is designed to provide consistent environment, health and safety efforts duringconstruction. The Project EHS Plan does not relieve a contractor of his/her contract responsibilitiesfor Environment, Health and Safety, or for complying with any applicable governmental regulations.Contractors shall be responsible for the health and safety of all persons and property affected by thecontractors’ performance of the work, including work performed by their contractors. Thisrequirement shall apply continuously during the entire contract period and shall not be limited just toonormal working hours. Contractors shall be responsible for implementation of a written EHSProgram (Contractors’ Safety Program) to prevent their employees from working under conditionswhich are unsanitary or dangerous to their health and safety. Contractors’ conformance with therequirement to initiate and maintain such a program is mandatory under the provisions of theirconstruction contract.Contractors shall also be responsible for the administration of the Contractors’ Safety Programs andthe Project EHS Plan for their contractors. Documentation required by this program includes, but isnot limited to, that summarized in Appendix A. Appendix A presents a Form Submittal Matrix thatidentifies the specific Form and the required timing for submittal to NOVO Construction.Program RequirementsContractors’ Safety and Health Programs shall meet the minimum applicable requirements of theOccupational Safety and Health Act of 1970, as amended and/or the California Department ofIndustrial Relations – Occupational Safety and Health Administration (Cal-OSHA). In addition, tomeet the minimum requirements of the Project EHS Plan, the following additional requirements shallbe a mandatory part of each contractor’s EHS Program: Deliver one copy of the Contractor’s EHS Program to NOVO Construction for review.The contractors shall designate competent person(s) for each area listed that isapplicable to their work. Occupational Safety and Health Administration(OSHA) defines a competent person as:“One who through training and experience is capable of identifyingexisting and predictable hazards in the surroundings or workingconditions which are unsanitary, hazardous, or dangerous to employeesand who has authorization to take prompt corrective measures toeliminate them.” Conduct contractor/subcontract prequalification measures Deliver the contractor/subcontractor orientation program which will be presented duringcraftworker initiation. Monthly Safety Metrics submittals requirements. Incident/accident submittal requirements.The contractors’ competent persons shall be the competent persons for each lower tier contractorunless that lower tier contractor identifies an alternate competent person. Participate in the weekly construction coordination meetings. Cooperate with NOVO Construction, state, federal, and local agencies concerning safety,health, environmental and property damage matters. Participate in the implementation of fire control measures as may be appropriate for theprotection of individuals and property.2

Provide and document training and education to the contractor’s employees in therecognition, avoidance, and prevention of unsafe working conditions and unsafe workpractices, and in the implementation of emergency procedures. Maintain accurate environment, health and safety records and statistics, and submit toNOVO Construction by the first of each month. Provide a system for ensuring that reports required by the Project EHS Plan are submittedto NOVO Construction in a timely manner. Provide a system for immediately reporting all injuries, accidents, illnesses, fires,hazardous material spills, and unsafe conditions and procedures to the contractor’s safetyrepresentative and NOVO Construction. Hold and document a system of weekly “toolbox” safety meetings for all contractoremployees. Establish a system to prevent the use of unsafe or defective equipment, tools, materials,or machinery, which includes procedures for tagging and/or locking out and renderinginoperable such unsafe items. Provide a system for ensuring that only employees who are qualified by training orexperience are allowed to operate equipment, tools, and machinery. Designate a qualified representative to be responsible for rigging and heavy lifting. AJHA shall be required prior to all lifts. All lifts over 10 tons, multiple crane lifts, and liftsover 75 percent of the crane’s rated capacity, will be considered critical lifts with theappropriate planning and approvals. ALL CRANES TO HAVE LOAD/MOMENTUMINDICATORS INSTALLED AND WORKING.The following items shall be included in the report: Make and model number of the crane or hoist. Lift radius, boom angle, and boom length, if applicable. Lifting capacity of the crane or hoist for the particular configuration. Size and capacity of all rigging. Weight of object being lifted and associated rigging. Diagram of lift layout.Such reports shall be submitted to NOVO Construction for review seventy-two (72) hoursprior to the lift. Establish a documented hazard communication program for the protection of employeeswho are required to handle or use flammable liquids, gases, toxic materials, poisons,caustics, and other harmful substances. The objectives of the program will be to createan employee awareness of the potential hazards of such substances, the recommendedpersonal hygiene for those exposed to such hazards, the personal protective measures anddevices required, and the emergency notification procedures to be used in the event of anaccident.Establish a documented program of instruction for employees who are required to enterconfined or enclosed spaces. Instructions shall include the nature of the hazardsinvolved, the necessary precautions to be taken, and the proper use of required protectiveand emergency equipment. The contractor’s program shall include a permit system asoutlined in Subsection 1.6.9 of this plan.3

Establish a documented program for protecting employees from occupational healthhazards resulting from airborne dusts, mists, vapor, or fumes; noise; and radiation(ionizing and nonionizing), with emphasis on materials such as lead, asbestos, cadmium,arsenic, or silica. A Job Hazard Analysis (JHA) (refer to Subsection 1.6.1) shall beperformed to determine the appropriate steps to control the hazard. The contractor shalluse engineering controls wherever possible to eliminate the hazard. If engineeringcontrols are not effective, administrative controls or personal protective equipment (PPE)shall be used.Provide a written program for employees who require, because of the hazards of the workbeing performed, the use of PPE.Establish a system that provides for monthly, documented inspections of all equipment inaccordance with applicable federal, state, and local regulations.Provide written disciplinary procedures equal to or greater than those discussed inSubsection 1.3.2 of this Project EHS Plan. This procedure must include enforcementresponsibilities of all supervisory personnel.Provide appropriate first aid/medical coverage for their employees and submit monthlyInjury/Incident Logs to NOVO Construction.If steel erection activities are being performed as described in CFR 1926.750, develop asite-specific steel erection program that meets OSHA Subpart R 1926.750-761requirements in addition to specific steel erection requirements set forth in this manual(Subsection 1.6.14).Develop, document, and implement evacuation/emergency plans for medicalemergencies, fire, and hazardous material spills. Contractors’ programs shall be incompliance with NOVO Construction and the owner requirements.Develop and implement a Drug Testing Program and background verification as requiredby the contract documents.Conduct weekly work area environment, health and safety inspections with writtenreports shall be made available for audit at any time. Included in the reports shall bedeficiencies detected and corrective action taken.Environment, Health and Safety Surveillance Policyand ProceduresSurveillance PolicyContractors are responsible for the enforcement of their respective Contractors’ Safety Programs, theProject EHS Plan and owner requirements. NOVO Construction will provide surveillance ofcontractors’ activities to observe whether such activities are in compliance with the Project EHS Plan.Violation Notification ProceduresIf an apparent violation of a safety or health standard occurs, NOVO Construction will advise thecontractor of the violation and direct that the violation be