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Health & Safety Plan Cook Tract Walsh Construction (TPD1111009)

Section 1

1.1          Policy Statement

The principles of safety and loss control reflect a determination by Walsh Construction Company to prevent injuries to persons and to prevent damage to property and equipment.

Accidents that result in personal injury and damage to property and equipment represent needless waste and loss.

Planning for safety shall start with  award  of  the  project  and  continue  through  purchasing,  fabrication,  and construction of the “Cook Tract”.  All practical steps shall be taken to maintain a safe place to work.


1.2          Foreword

This manual has been compiled to present Safety and Loss Control activities and guidelines to establish criteria for the Health and Safety Plan for the Cook Tract.

The information and suggestions summarized in these guidelines cannot be assumed to include every loss potential, code violation, or exception to good practice, and therefore, its completeness cannot be guaranteed. Nonetheless, every effort has been made to develop a comprehensive manual.

As with all other aspects of the work, Walsh Construction’s selection of means and methods is his own. Suggestions sustained in this plan are representative of the types of techniques and practices which Walsh Construction may choose to employ on this project.


1.3          Policy Objective

The objective of this policy is to establish throughout the entire process of constructing the Cook Tract, the concept that the prevention of accidents, minimizing claims costs and protection of property is most important, and therefore, shall receive top priority, support, and participation.


1.4          Program Objectives

Safety and Loss Control Programs for the Cook Tract should meet the following objectives:

•              Coordinate the elimination and reduction of hazards and risks associated with construction projects.

•              Prevent accidents and reduce employees’ injuries.

•              Protect the public and prevent damage to property.

•              Promote maximum efficiency and effect savings by the reduction of unplanned business interruptions.

•              Assist in locating and abating unsafe conditions and practices.

•              Monitor the education of the staff concerning:

1.            New hire orientations to promulgate safety.

2.            Job hazard analysis

3.            Weekly site safety (toolbox) meetings.

4.            Required competent person safety training (i.e. Scaffolding Safety, Trenching Safety, Confined Space Entry, etc.)

•              Enforce personal protective equipment (PPE) programs.

•              Use accident investigation information to abate deficiencies and eliminate additional losses.


Section 2

Loss Control Responsibilities

2.1          Walsh Construction

Each subcontractor of any tier  acknowledges  that  it  has inspected the project  site,  has become familiar  with the site limitations and the conditions under which the work will be performed and has made all allowances for such conditions. The subcontractor will be required to submit to Walsh Construction within ten (10)      days after Notice of Award, but not later than the Pre-Construction Conference, a copy of the subcontractor’s safety program, together with Material Safety Data Sheets for any hazardous chemicals or materials your company anticipates using on this project. Additionally, they are to develop a project specific written fall protection plan that addresses identifies, evaluates and prevents any employee from fall exposure of six (6) feet or more, to include scaffolding and ladders.


2.2          Orientation and Indoctrination Program

A review of the Field Employee Safety Orientation shall be required for each new employee prior to that employee starting to work on the job.

This orientation is for each employee assigned to a job site for the first time, regardless of how long the employee has been employed by the company. The orientation should include but not be limited to:

•              Safety Responsibilities

•              General Project Safety Rules

•              Safety Enforcement


2.3          Employee Training

Walsh Construction’s safety program must insure that the on-site qualified person conducts training to ensure awareness by all construction workers regarding specific construction hazards on the Cook Tract jobsite.

All training must be relayed in a way that all employees, regardless of language or reading skills, can understand. All formal safety training is to be documented.


2.4          Job Hazard Analysis

Job hazard analysis is a method for systematically identifying conditions inherent to or associated with the safety, quality, and efficiency of the work performed by employees and developing a step-by-step procedure to eliminate or minimize these conditions. The analysis is a method of studying a job to develop the safest, most effective way to accomplish it.

The analysis relies on two basic principles or strategies:

•              Determine the potential cause of the problem.

•              Eliminate the potential cause of the problem.

Job hazard analysis is a management technique that carries out the basic strategies of accident prevention, quality assurance, and productivity enhancement.

Walsh Construction’s safety program encourages that the on-site Safety Manager, Superintendent, and/or the Project Manager create a job hazard analysis for major tasks or scopes of work. Alternative comprehensive planning methods for major scopes of work will be an acceptable alternative to the JHA process.


2.5          OSHA Inspections

If an OSHA Compliance Officer approaches anyone, they will refer him or her to the Walsh Construction’s Site Safety manager. In the absence of the Site Safety Manager, the OSHA Compliance Officer will be referred to the following in the order listed:

1.            Project Manager

2.            General Superintendent

3.            Project Construction Manager

4.            Owner’s Safety Manager

Note: Walsh Construction’s Corporate Safety Director shall be notified immediately.


2.6 Walsh Construction Project Manager

The duties of Walsh Construction’s Project Manager shall include:

•              Planning and execute all work so as to comply with the Safety Program.

•              Complying with all the provisions of the contract dealing with safety and accident prevention.

•              Complying with federal, state and local safety codes and regulation.

•              Cooperating with Walsh Construction’s Safety Manager

•              Supporting a program of returning injured employees back to work in full or transitional duty position.

•              Authorizing necessary immediate action to correct sub-standard safety conditions.

•              Attend weekly Safety Talks


2.7          Walsh Construction’s Safety Manager

Walsh Construction’s Safety manager duties shall include:

•              Conducting frequent and regular safety inspections of jobsite and taking necessary immediate corrective action to eliminate unsafe acts and conditions. Document all inspections utilizing a checklist, which will be available for the Walsh Construction Safety Manager’s review on the job site.

•              Maintaining the OSHA 300 Form.

•              Reviewing accident and incident reports and, where appropriate, recommend immediate corrective action to the project staff.

•              Providing appropriate material for use in conducting weekly Safety Talks

•              Managing the injured employee, property damage, and public liability claim handling process through meetings and communication with Walsh Construction and the insurance carrier

•              Assisting in the preparation of the accident investigation and reporting procedures

•              Initiating and administer the injured employee’s transitional duty program

•              Implementing training programs for supervisors and employees as they apply to their specific responsibilities

•              Encouraging programs for recognition of individual employee’s safety efforts and their contribution toward improved work methods

•              Monitoring the availability of the necessary safety equipment, including employee’s personal protective equipment

•              Hold regular conferences with Walsh Construction and subcontractor’s Project Managers to discuss safety concerns and recommendations following each job site safety audit.

•              Assist Walsh Construction in the investigation of accidents and incidents and make appropriate recommendations.

•              Assist Walsh Construction in determining environmental health hazards and recommend appropriate industrial hygiene surveys.

•              Provide assistance with OSHA Construction Safety Requirement interpretations.


2.8          Walsh Construction’s Project Superintendent

Walsh Construction’s Project Superintendent’s duties shall include:

•              Planning and execution of all work as to comply with stated objectives of Walsh Construction’s Safety Program.

•              Assisting the Safety Manager to assure the effectiveness of the safety program.

•              Making frequent and regular documented Job Site Safety inspections.

•              Take immediate action to correct unsafe practices or employee work conditions.

•              Understanding Walsh Construction’s reporting requirements for smooth field implementation.


2.9          Walsh Construction’s General Foreman

The Foreman’s responsibilities shall include:

•              Instructing workers, under their supervision, in safety work practices and work methods at the time of work assignments.

•              Supplying and enforce the use of proper protective equipment and suitable tools for the jobs being performed.

•              Making daily documented job site safety inspections to see that no unsafe practices or conditions are allowed to exist in any part of his work area.

•              Acquainting workers with all applicable safety requirements and enforce them.

•              Places transitional work employees into productive positions within their physical limitations.

•              Participating in the investigation of accidents and incidents to determine facts necessary to take corrective action.

•              Supplying information for completion of the Accident Report and Investigation Form.

•              Attend or conduct safety meetings and discuss observed unsafe work practices or conditions, last week’s problems and corrective action taken, review the accident experience, encourage safety suggestions and report them to the Safety Manager.

•              Seeing that prompt first aid and medical treatment is administered to injured employees.

•              Reporting immediately any violations of project safety that cannot be corrected.


2.10       Walsh Construction’s Employees

Each employee’s responsibilities shall include:

•              Learning and complying with all safety rules and regulations that applies to their assigned tasks.

•              Using appropriate guards and personal protective equipment.

•              Reporting all injuries and near misses to the immediate supervisor as soon as possible and in no case later than the end of the workday in which the injury or close call occurred.

•              Comply with all site specific safety policies established for this project


2.11       Subcontractor of any Tier Work Relationship

The Subcontractors Superintendent, who is designated as the Safety Manager, shall be on the site to monitor the work of their Sub-contractors whenever the Subcontractors are working on site.


Section 3

Construction Safety Requirements and Procedures


3.1          Local Laws and Requirements

Walsh Construction will be required to comply with all Federal, State, City and County regulations governing this project site.


3.2          Protecting the General Public

Walsh Construction uses precaution to prevent injury to pedestrians or damage to the property of others.    The public shall be considered, as any persons not employed by the Walsh Construction. Among the precautions to be taken should be the following:

•              Work is to be performed in public area only when specified by the Contract or Walsh Construction in writing.

•              Every step necessary must be taken to protect and maintain work areas that interface with public sidewalks, building entrances (lobbies, corridors and aisles), stairways and roadways.

•              All travel ways, access and egress points must be maintained clear of obstructions at all times.

•              Warning signs are to be conspicuously positioned and a flag person shall be assigned when moving equipment that may encounter pedestrians or private vehicles.

•              Barricades to protect the general public or public roadways must be secured against accidental displacement and in place at all times. When barricades must be temporarily removed, a flag person shall be assigned to control the unprotected area.

•              If a permanent sidewalk must be obstructed or removed, a temporary alternative pedestrian walkway must be provided. Guardrails must be installed on both sides of any temporary walkway with a fall exposure.


3.3          Work Performed Near Existing Operating Right–Of–Way

For all construction equipment (such as cranes, concrete pump trucks, backhoes, etc.) that could encroach into the general public right-of-way, a review of the plan by Walsh Construction’s General Superintendent prior to beginning the operation is necessary.


3.4          Group Tours and Site Visitors

It is particularly important that a high degree of protection be afforded all persons on authorized tours of construction work sites. The following instructions must be included in Walsh Construction’s safety procedures and shall be complied with, as applicable, by those responsible for arranging such tours:

•              Walsh Construction will be advised of any tour in a timely manner prior to the tour-taking place.

•              Group tours must be cleared through Walsh Construction and Construction Manager

•              Walsh Construction, in conjunction with the owner, will coordinate the following with the individual    or organization requesting the tour:

1.            Number of Visitors – Tour groups in non-hazardous areas will be limited to no more than twenty-five (25) persons per tour guide.

2.            Clothing – Visitors will be required to wear pants or slacks, shirt or blouse, and leather or work shoes.  Sneakers, high-heeled shoes, and open toed shoes are prohibited.

3.            Minors – Persons under 18 years of age are not permitted on project tours (unless permitted by insurance carrier).

4.            Protective Equipment – Hardhats, eye protection, earplugs, and other protective devices will be required as necessary.

5.            Visitors shall comply with Walsh Construction and / or the subcontractor’s safety requirements, which will meet or exceed those, required by the Construction Manager.

3.5          Drug and Alcohol-Free Workplace Program

In the interest of promoting a safer, healthier and more productive environment, Walsh Construction has adopted the policy that all employees must be drug free in the workplace. That is, employees must be free from detectable amounts of controlled substances, other mind-altering substances, or their metabolites without regard to apparent impairment. Walsh Construction has also adopted the policy that all employees must not be impaired by alcohol while on the job. To ensure that this program is effective Walsh Construction Company requires all employees to submit to the following testing requirements:

•              Pre – employment – Prior to employment, new hires are required to pass a pre – employment drug screen.

•              Post Accident/ Post Incident – Any employee involved in an accident which results in injury to the employee or a fellow employee or which causes property damage. Involved in a life threatening situation or participating in unsafe acts that could cause injury or property damage.

•              Testing for Cause – Any employee is subject to testing based upon reasonable suspicion, such as the influence of controlled substance or alcohol while present on the company’s property.

•              Random Testing – Random testing will comply with Walsh Construction’s drug policy.


Walsh Construction Company’s procedure for administering drug testing is as follows:

•              A CLIA Waived rapid urine-screening test that is administered by a trained and certified Walsh Management employee to be used as an initial screen.

•              If the sample is negative, the sample is disposed of and employment is offered to the individual.

•              If the individual sample is non-negative, a security seal will be applied to the sample and the sample is sent to an independent laboratory for further testing. Employment is denied until the results are verified by the independent laboratory.


This policy is applicable to all Walsh Construction employees while working at the Cook Tract.

The jobsite Heath & Safety Manager shall have the authority to immediately dismiss any employee who is in violation of Walsh Construction’s Drug and Alcohol-Free Workplace Program.


3.6          New-Hire Orientation

Prior to start of work, each Walsh Construction and / or the subcontractor of any tier employee shall receive site- specific safety training.   The training shall orient the employee in the project safety requirements, proper     use of personal protective equipment, training and safe work practices. To verify that the employee has received and understands this orientation, the employees must sign an acknowledgement of receipt of the project safety rules, which Walsh Construction will keeps on file. Non-English speaking employees will receive these same instructions in a language that they understand. Upon completion of the orientation, a numbered decal will be issued to the employee for his hard hat to indicate that the training was completed.

Since the safety requirements vary from project to project, every employee shall go through the indoctrination, regardless of their prior experience on other Walsh Construction projects.


3.7          Disciplinary Policy

Walsh Construction’s Safety Manager, Superintendent, and Project Manager and foreman will monitor the construction safety performance of all Walsh Construction and subcontractors. Should a subcontractor continually be in non-compliance with Safety and Health Regulations, Walsh Construction (at  subcontractor’s expense) may stop work operations, until all concerns are abated. Persistent non-compliance may result in termination of the subcontractor.

An employee of any Walsh Construction and / or the subcontractor who is observed in violation of the Project Safety Guidelines or safety requirements for this project:

1.            First Offense – Written warning.

2.            Second Offense – Written reprimand with 3 – Day Suspension without Pay

3.            Third Offense – Termination or Permanent Removal from Job Site

Note: At the discretion of the Contractor, Owner, Construction Manager, or Owner’s Safety

Manager, an employee can be permanently removed from the job site or given a three day suspension without written  warning  for  committing  a  severe  violation  of  the  safety  requirements  as outlined in this Safety Manual.


3.8          Work Areas

Walsh Construction will provide a safe work area for its employees. When unsafe conditions do exist, immediate abatement will be required, which may include stopping work until safety standards are met.


3.9          Work Practices

The supervisor of any crew of Walsh Construction and their suppliers are responsible for supervising their crew for safe work practices and use the appropriate personal protective equipment.


3.10       Job Site Safety Inspections and Audits

Walsh Construction’s Safety Manager will be required to make frequent and regular inspections of each of the work areas (including storage, office and shop facilities) to ensure compliance with safety regulations, these guidelines and OSHA requirements.

If an OSHA Compliance Officer approaches anyone, they will refer him or her to Walsh Construction Company Site Safety Manager. In the absence of the Site Safety Manager, the OSHA Compliance Officer will be referred to the following in the order listed

1.            Project Manager – Brian Neckermann

2.            Senior Superintendent –   Mike LaSalle

3.            Site Safety Manager – John Graffeo

Note: Walsh Construction’s Corporate Safety Director shall be notified immediately.


3.11       First Aid and Medical Facilities

Walsh Construction shall, as required by OSHA, provide 2 CPR Certified First Aid representatives on each job site. Walsh Construction will maintain a copy of the First Aid Representative’s qualifications in the field  office for review.

First aid supplies are available in the jobsite office and in each of Walsh Construction Foremen’s trucks or Conex for emergency needs.

All staff and foreman assigned a company vehicle employed by Walsh Construction shall maintain current first aid/ CPR certification. It is our goal to have this accomplished within the first 2 months of assignment.


3.12       Bloodborne Pathogen Exposure Control Plan

Universal Precautions shall be observed to prevent contact with blood or other potentially infectious materials. All body fluids shall be considered potentially infectious materials. All employees shall receive training to make them aware of Bloodborne Pathogens and their associated hazards.

Only Authorized Personnel shall have access to the contents of the First-aid kit to minimize the potential of first aid supplies becoming contaminated with an injured person’s body fluids. Mouthpieces / barriers shall be available in the project first aid kits for performing CPR. In addition, a Bloodborne Pathogen spill kit will be kept with each kit. Any injured employee will report to the project office trailer and be provided with the first-aid materials for minor injuries.

In the event, an injured person requires assistance for treatment of the minor injury; the person rendering aid shall wear a pair of rubber medical-type gloves. Upon completing treatment of any injury, both the people providing assistance/treatment and the injured person will wash thoroughly with soap and water to remove all traces of blood or other body fluids from their skin. If clothing is contaminated with blood or body fluids, it shall be removed prior to continuing work to minimize the potential of additional distribution and contamination of other persons, materials, tools, etc. Place soiled clothing in a plastic bag. Discard clothing if contaminated with another person’s blood. It shall be at the discretion and responsibility of the individual whose clothing was/is contaminated with their own blood to either clean or dispose of the clothing, as they deem appropriate. Should a serious injury be incurred to an employee on the job site, which results in extensive bleeding, and another employee comes to the injury’s assistance and is contaminated with the injury’s blood, this employee will also be offered the hepatitis B vaccination.

Any tool, material, or equipment to be contaminated with human blood or other body fluids shall be cleaned / decontaminated prior to being put back into service. Any soil, material or other items, which cannot be cleaned or decontaminated, shall be disposed of in an appropriately approved manner. A simple disinfectant / decontamination solution may be made of 1 part household Bleach and 5 to 10 parts of water. For large areas of contamination, use the Universal Precaution Spill Kit kept with every First Aid kit, while wearing the personal protective equipment included in the kit.

Sprinkle the provided powder over spilled area; allow solidifying to a gel. Remove gelled material with the scoop and scraper provided. Carefully place material in red bag provided. Clean away remaining solids and disinfect with the bleach solution or the enclosed germicidal (germ killing) cloth in kit. Place all contaminated articles including gloves in the red plastic bag. Seal the red bag and contact the Health and Safety Department for proper disposal of spill kit. Promptly wash hands with soap and water. If antiseptic hand cleaners or towelettes are used, hands should be washed with running water as soon as possible.

If on the job site, an area is encountered that has been contaminated with blood or body fluids report the situation immediately to the Project Manager or Superintendent. Do not proceed into the area of possible exposure. Contaminated broken glass should never be picked up directly with the hands, even if wearing gloves. Use a brush and dustpan to clean up broken glass. All contaminated sharps must be discarded in the designated sharp container. These containers will be on those job sites where there is potential for exposure to sharps. The sharp containers are to be closeable, puncture resistant, and leak proof, red in color or appropriately labeled with a biohazard tag. The sharp containers will be kept in the trailers. Never manually open, empty, or clean contaminated sharps containers. Any other items contaminated with potentially infectious material will be disposed of in a properly designated container. Any material contaminated with potentially hazardous material is regulated waste and  must  be  discarded  according  to  federal,  state  and  local  regulations.  All equipment and work surfaces will be decontaminated after contact with blood or other potentially infectious materials. Work surfaces will be cleaned with a disinfectant wearing gloves, or whatever other personal protective equipment is necessary. The personal protective equipment is in the universal spill kit, which is kept with the first aid kit.

The Hepatitis B vaccine and vaccination series shall be made available to employees, who have the potential for occupational exposure to bloodborne pathogens. If any employee becomes exposed to bloodborne pathogens who have not received the Hepatitis B vaccine, it must be made available to them within 24 hours of exposure. Employees exposed to bloodborne pathogens will have medical evaluation at the time of the exposure and be placed on post-exposure follow up by a licensed physician as specified by Walsh Construction.  The employee may decline Hepatitis B vaccinations. If routine boosters of the Hepatitis vaccine are recommended by the U.S. department of Public Health, the booster shots will also be available to the employee, and administered by a licensed physician as specified by Walsh Construction.

An employee exposure report form is to be completed as soon as possible after direct contact with blood or body fluids without protective equipment or not covered by protective equipment. An Incident Investigation Form is to be completed by the Project Manager or designee. The Company for the duration of employment, plus thirty years will keep all exposure reports. All medical records will be made available to anyone having the written consent of the subject employee or OSHA representatives. Should it become known to the project supervisory personnel that a person who had received first-aid medical treatment on the Project was confirmed to be infected with HIV or HBV, then the person(s) involved in that incident shall be provided the prescribed follow-up treatment. Management shall make immediately available to the exposed employee a confidential medical evaluation and follow-up.


3.13       Emergency Procedures

Walsh Construction shall establish procedures to manage emergencies that may occur at any time in the following categories to be considered:

•              Fire

•              Employee injury

•              Pedestrian injury due to work activity of any kind

•              Property damage and damage to various utilities (e.g., electrical, gas, sewerage, water, telephone or public roadways)

•              Flood, wind, lightening, hail


Emergency Procedures will be made part of Walsh Construction Safety Program submittal. It is recommended that the following provisions shall be included in the emergency procedures:

•              The highest-ranking supervisor automatically becomes responsible for handling any emergency that occurs during his/her working hours;

•              On a regular basis, at both supervisory and “weekly Tool Box meetings”, employees are to be instructed and updated in emergency courses of action;

•              Established teams to handle each of the various emergencies;

•              Establish an emergency ranking of on-site personnel to:

1.            Secure the area as expediently as possible; and

2.            Provide access and an account of the emergency to Walsh Construction.

3.            Questions from the media should be referred to Walsh Construction.

•              Post a list of emergency phone numbers, along with information to be transmitted in such emergencies.

•              Review and, update the Emergency Procedures as required. The updated procedures shall be submitted to the Walsh Construction Safety Manager for review.


Emergency Response Procedures:


A.            Off – Site Transportation to medical facility

1.            If an emergency requires the presence of an ambulance, the Fire Department or Police, including nights, weekends  and  holidays,  then  Walsh  Construction  and/or  the  subcontractor shall  call 911 and then Walsh Construction’s Safety Manager.

2.            Walsh Construction’s site Safety Manager will contact the designated Emergency Response Facility to arrange for an emergency transportation vehicle.

B.            Inclement Weather – Unsafe or hazardous

1.            Walsh Construction’s will monitor the area by use of the internet.

2.            If weather conditions warrant the stoppage of work, Walsh will notify all affected contractors   and subcontractors.

3.            In the event of a tornado, all personnel will be expected to evacuate to a designated evacuation area. Walsh Construction and / or the subcontractor, project managers, superintendents, and foreman will be responsible for obtaining a “head count” of those workers under their direct supervision.

4.            If the  project  is  shut  down  due  to  severe  /  inclement  weather  conditions,  Walsh Construction Project manager, Superintendent or Safety Manager will notify all affected contractors and subcontractors when it is safe to return to the work area.

C.            Emergency Evacuation

1.            Walsh Construction’s Project manager, Superintendent or Safety Manager shall notify all affected contractors and subcontractors of the need to evacuate the Project Site.

2.            When an evacuation signal is given, all contractors and subcontractors shall Immediately stop work! Equipment shall shut down and secured as quickly as possible. Personnel shall then exit the site to the designated evacuation area. The method of notification shall be a long blast from a hand held air horn followed by verbal instructions. The designated assembly area at present shall be the Walsh lay down area adjacent to the existing bridge. This shall change as the project expands.

3.            Each contractor, subcontractor, project manager, superintendent, and foreman will be responsible for obtaining a “head count” of those workers under their supervision. The head count shall be performed by the crew foreman since he is familiar with members of his crew. They will report any missing individuals immediately to Walsh Construction Site Safety manager.

4.            No Walsh Construction employee will re–enter the site until Walsh Construction Project Management gives the “All Clear” signal.

3.14       Accident Investigations

When a reported  accident  or  near  miss  occurs,  Walsh  Construction’s  Project  Manager  and  Supervisor  of the crew involved will be required to perform an accident investigation and make recommendations to preclude future occurrences. Reports of all accident and near miss investigations will be furnished to Walsh Construction’s Safety Manager for review, within twenty-four (24) hours of the incident.


3.15       Record Keeping and Reporting

Walsh Construction shall provide a Worker’s Comp. First Report of Injury and / or Foreman’s Report of Accident and Injury within 24 hours of accident and / or injury. Walsh Construction will maintain an Injury and Illness Log with accurate monthly man-hours, as well as the OSHA Form 300. It will be Walsh Construction’s responsibility to obtain this same information from all Sub-Contractors of any tier. The OSHA 300 Form shall be submitted to Walsh Construction for review no later than ten (10) days after the end of the month.


3.16       Construction Safety, Health and Training

Walsh Construction will provide Safety and Competent Persons Training for employees. This training must be documented. In addition, Walsh Construction will be required to provide copies of all employee-training programs to the Construction Manager, if requested. Any program found to be inadequate shall be revised / upgraded to meet standards set by OSHA.


3.17       Hazardous Communication (HAZ-COM)

This program has been prepared to comply with the requirements of the Federal OHSA standard 1926.59 (1910.1200) and to insure that information necessary for the safe use, handling and storage of hazardous chemicals is provided to and made available to employees.

This program includes guidelines on identification of chemical hazards and the preparation and proper use of container labels, placards and other types of warning devices.


Chemical Inventory

1.            Walsh Construction Company maintains an inventory of all known chemicals in use on the worksite.   A chemical inventory list is available from the Project Superintendent.

2.            Hazardous chemicals brought onto the worksite by Walsh Construction Company will be included     on the hazardous chemical inventory list.


Container Labeling

1.            All chemicals on site will be stored in their original or approved containers with a proper label attached, except small quantities for immediate use. Any container not properly labeled should be given to your supervisor for labeling pr proper disposal.

2.            Workers may dispense chemicals from original containers only in small quantities intended for immediate use. Any chemical left after work is completed must be returned to the original container or your supervisor for proper handling.

3.            No unmarked container of any size, are to be left in the work area unattended.

4.            Walsh Construction Company will rely on manufacture applied labels whenever possible, and will ensure that these labels are maintained. Containers that are not labeled or on which the manufacturer’s label    has been removed will be relabeled.

5.            Walsh Construction Company will ensure that each container is labeled with the identity of the hazardous chemical contained and any appropriate hazard warnings.


Material Safety Data Sheets (MSDS)

1.            Employees working with Hazardous Chemicals may request a copy of the material safety data sheet (MSDS). Requests for MSDS’s should be made to Project Superintendent.

2.            MSDS should be available and standard chemical reference may also be available on the site to provide immediate reference to chemical safety information.

3.            An emergency procedure to gain access to MSDS’s information will be established.


Employee Training

Employees will be trained to work safely with hazardous chemicals. Employee training will include:

1.            Methods that may be used to detect a release of hazardous chemical(s) in the workplace,

2.            Physical and health hazards associated with chemicals,

3.            Protective measures to be taken,

4.            Safe work practices, emergency responses and use of personnel protective equipment.

5.            Information on the Hazard Communication Standard including

•              Labeling and warning systems, and

•              An explanation of Material Safety Data Sheets.

Personnel Protective Equipment (PPE)

Required PPE is available from your supervisor. Any employee found in violation of PPE requirements may be subject to disciplinary actions up to and including discharge.


Emergency Response

1.            Any incident of over exposure or spill of a hazardous chemical substance must be reported to the Project Superintendent at once.

2.            The foreman or the immediate supervisor will be responsible for insuring that proper emergency response action is taken in leak / spill situations.


Hazards of Non–Routine Tasks

1             Supervisors will inform employees of any special tasks that may arise which   would involve possible exposure to hazardous chemicals.

2. Review of safe work procedures and use of required PPE will be conducted prior to start of such tasks. Where necessary, areas will be posted to indicate the nature of the hazard involved.


Informing Other Employers

1.            Other on site employers are required to adhere to the provisions of the Hazard Communication Standard.

2.            Information on hazardous chemicals known to be present will be exchanged with other employers. Employers will be responsible for providing necessary information to their employees.

3.            Other on site employers will be provided with a copy of Walsh Construction Company hazard communication program.



Walsh Construction Company has posted information for employees at this job site on the Hazard Communication Standard. This information can be found at the jobsite office.


3.18       Personal Protective Equipment

All personnel, without exception, are required to wear PPE.  Among these are:

•              Hard hats – 100 % of the time on the site

•              High visibility safety vest – ANSI class 3

•              Hearing protection – where the operations create noise above 85 dBA

•              Eye protection – safety glasses are required 100 % of the time on the site. Additional eye protection will be required when:

1.            Welding, burning, or cutting with torches

2.            Using abrasive wheels, grinders, or files

3.            Chipping concrete, stone or metal

4.            Working with any material subject to scaling, flaking, or chipping

5.            Drilling or working under dusty conditions

6.            Sand or water blasting

7.            Waterproofing

8.            Using explosive actuated fastening or nailing tools

9.            Working with compressed air or other gases

10.          Working with chemicals or other hazardous materials

11.          Using chop saw, chain saw, machine saws or other similar equipment

12.          Working near any of the operations listed above

13.          Performing or working near operations where additional eye protection is deemed necessary by the Walsh Construction’s Safety manager and / or the owner’s Safety Manager.

•              Hand Protection – Gloves will be worn when handling objects or substances that could cut, tear, burn or other injures to the hand.

•              Safety Harness / Lanyard Assemblies – will meet ANSI Standards and be worn by employees who are exposed to any fall exposure six feet (6’) or more in height that cannot be properly guarded with rails or other means

•              Shoes – shall have hard soles and be made of leather or approved materials.

•              Shirts with min. 4” sleeves are required; no tank tops or mesh shirts

•              Long pants are required, no shorts or cut-off jeans.


Respirator Program


The purpose of this operating procedure is to ensure the protection of all employees from respiratory hazards, through proper use of respirators. Respirators are to be used only where engineering control of respirator hazards is not feasible, while engineering controls are being installed, or in emergencies.


Walsh Construction shall be responsible for all facets of this program and has full authority to make necessary decisions to ensure success of this program. This authority includes hiring personnel and equipment purchases necessary to implement and operate the program. The Safety manager will develop written detailed instructions covering each of the basic elements in this program, and is the sole person authorized to amend these instructions.

Walsh Construction has expressly authorized the Safety manager to halt any operation of the company    where there is danger of serious personal injury. This policy includes respiratory hazards.

Respiratory Protection Program Elements

1.            Walsh Constructions shall utilize established written standard operating procedures governing the selection and use of respirators, using the NIOSH Respirator Decision Logic as a guideline. Outside consultation, manufacturer’s assistance, and other recognized authorities will be consulted if there is any doubt regarding proper selection and use. These detailed procedures will be included as appendices to this respirator   program.

2.            Respirators will be selected on the basis of hazards to which the worker is exposed. The Safety manager will make all selections. Only OSHA / NIOSH certified respirators shall be selected and used.

3.            The user shall be instructed and trained in the proper use of respirators and their limitations.  Both supervisors and workers will be so instructed by the Safety manager. Training should provide the employee an opportunity to handle the respirator, have it fitted properly, test its facepiece-to-face seal, wear it in normal air for a long familiarity period and finally to wear it in a test atmosphere. Every respirator wearer shall receive fitting instructions, including demonstrations and practice in how the respirator should be worn, how to adjust it, and how to determine if it fits properly.

4.            Respirators should not be worn when conditions prevent a good face seal. Such conditions may be a growth of beard, sideburns, and a skullcap that projects under the facepiece or temple pieces on glasses. No employees of Walsh Construction, who are required to wear respirators, may wear beards. The worker’s diligence in observing these factors will be evaluated by periodic checks. To assure proper protection, the wearer each time the wearer puts on the respirator shall check the facepiece fit. Following the manufacturer’s facepiece fitting instructions shall do this.

5.            Where practicable, the respirators will be assigned to individual workers for their exclusive use.

6.            Respirators are regularly cleaned and disinfected. Those issued for the exclusive use of one worker will be cleaned after each day’s use, or more often if necessary. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use. The Safety manager shall establish a respirator cleaning and maintenance facility and develop detailed written cleaning instructions.

7.            The central respirator cleaning and maintenance facility will store respirators in a clean and sanitary location.

8.            Respirators used routinely will be inspected during cleaning. Worn or deteriorated parts shall be replaced. Respirators for emergency use such as self-contained devices will be thoroughly inspected at least once a month and after each use.

9.            Appropriate surveillance of work area conditions and degree of employee exposure or stress will be maintained.

10.          There will be regular inspection and evaluation to determine the continued effectiveness of the program. The Safety manager will make frequent inspections of all areas where respirators are used to ensure compliance with the respiratory protection program.

11.          Persons will not be assigned to tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. Walsh Construction physician will determine what health and physical conditions are pertinent. The respirator user’s medical status will be reviewed annually.

12.          Certified respirators shall be used.


3.19       Water Protection Equipment

Employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard-approved life jacket or buoyant work vests. Ring buoys shall be provided and readily available for emergency rescue operations. At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.


3.20       Hazardous Materials Program

In the event that Walsh Construction should encounter materials reasonably believed to be asbestos, lead, polychlorinated biphenyl (PCB), or any other hazardous material which has not been rendered harmless, Walsh Construction and subcontractor shall immediately stop work in the affected area and report the condition to Walsh Construction in writing. The work in the affected area shall not resume except by written agreement. Once the written agreement is received, work in the affected area shall be resumed.


3.21       Hazardous Waste Operations

All employees involved with the removal operations shall be fully trained as to the hazards involved with handling the hazardous material, the preventative measures to be taken to limit exposure, and steps to be taken should an accidental exposure occur. Said employees shall receive a medical examination prior to and after the removal of hazardous materials, and receive health surveillance during the removal operations.

Walsh Construction Company does not anticipate being involved in any type of hazardous waste operations while performing work on this project. If this changes, Walsh Construction shall:

•              Ensure proper training and record keeping are performed

•              If required respirator fit testing will be performed and documented

•              If required obtain a lead abatement permit


Asbestos Safety Program

It is the intent of Walsh Construction to provide a safe working environment for all Walsh Construction employees on all Walsh Construction jobsites.

Asbestos is not as common of a construction material as it was years ago. Therefore, contact with asbestos containing materials will be generally during renovations of buildings that were built before 1975.

The typical areas where asbestos containing materials are found are:

•              Plumbing and mechanical pipe insulation

•              Floor and ceiling tile

•              Floor and ceiling tile glues and adhesives

•              Asbestos lined pipes, typically used in underground situations

These  areas  require  special  attention  and  demolition  by  authorized  personnel  only.   The   superintendent of each jobsite should contact Walsh Construction if asbestos containing materials are detected or thought to be detected in a building under construction, demolition, or renovation.

Prior to any work being performed on the jobsite, an approved testing company must perform a survey of    the jobsite for asbestos containing materials. The owner of the property typically performs this, and a copy of the results is forwarded to Walsh Construction.

The following is a list of precautions that should be followed when asbestos containing materials are found in small quantities only. An abatement contractor who is fully licensed and insured for asbestos removal should remove large quantities.

1             A negative pressure environment must be placed around the asbestos containing material to prevent loose particles of asbestos from entering the atmosphere.

2.            No sawing, cutting, chipping, grinding, or any other procedure that will cause loose particles of asbestos to enter the atmosphere is permitted.

3.            Air purifying respirators, gloves, and disposable coveralls will be required for employees who are required to work with and remove asbestos containing materials.

4.            When a small quantity of asbestos containing material is to be removed, trash bags that are capable of being sealed airtight and marked ASBESTOS CONTAINING MATERIAL must be used. The trash bags must be taken to an approved landfill.

5.            Employees are to be provided a hand washing station and an area to change clothes before entering the work area. An area must be provided for breaks. There shall be NO SMOKING OR EATING in work areas.

6.            Proper training of employees that are to work with asbestos containing material is to be performed     by the superintendent of the jobsite or the Safety Director before the work begins.

7.            If at any time the superintendent of the jobsite is not satisfied that the OSHA Standards for Safe Removal of Asbestos Containing Material can be met, an abatement contractor must be used.


8.            Negative pressure fans containing HEPA filters shall be used in large areas to ensure that there are no asbestos particles leaving the containment area.


9.            HEPA filters shall be used in all vacuum cleaners that are used to collect loose materials, and the contents of the vacuum cleaners are to be disposed of in sealed and clearly marked trash bags.



Lead Safety Policy


The following describe the procedures and precautions to be adopted on this jobsite in which employees could receive significant exposures to lead dust or fumes. Lead fumes are generated from welding or cutting on steel, girders, or other metals coated with lead based paint, soldering to join copper pipe, radiator repair, construction activities with fume exposures in aluminum, brass, or bronze foundries, electronics or battery plants, and glass and ceramic facilities. Lead dusts are commonly associated with the disturbance of contaminated ground, sandblasting or abrasive action on surfaces with lead paint, demolition of interior walls painted with lead paint, and decontamination of certain manufacturing operations.



1.            Prior to any demolition or retrofit, a competent person to determine existing and predictable lead hazards will survey all work areas. It is the responsibility of the overall superintendent of each jobsite to ensure that the survey is conducted.

2.            Appropriate material samples will be taken and sent to an OSHA approved laboratory to determine the lead content in each material under question. Paints, coatings, and alloys with lead in concentration of 0.4% or more shall be considered a lead source.

3.            Where a potential exposure to lead dust exists, spray-misting equipment shall be used for dust control.

4.            In an enclosed area, during welding or cutting on surfaces with lead containing paints, local exhaust ventilation will be used to remove the fumes. The ventilation shall be evaluated periodically to maintain its effectiveness. If local exhaust is not possible, then the paint will be stripped away from the surface to be welded or cut a distance of 6″ on each side.

5.            In an open-air setting, for welding and cutting on lead-contaminated surfaces, respiratory protection is mandatory with respirators approved for fumes by NIOSH.


Initial Determination

1             For potential lead exposures that cannot be eliminated through engineering means, personal air samples shall be conducted to determine the extent of exposure. The samples shall be for a complete shift and represent each potentially exposed job classification in each work area for the shift with the highest potential exposure. Until sample results are available, workers in the immediate area shall be required to wear respirators according to the established   exposure/activity table:

2.            Until sampling results are available, employees shall be provided with appropriate protective clothing, suitable change areas, hand washing facilities, and blood sampling for analysis of blood lead and zinc protoporphyrin (ZPP) levels.


Negative Results

1 If the initial personnel samples on each exposed job category show that the airborne lead concentrations are below 30 micrograms per cubic meter (Ug/M3), the result is negative. A written record must be documented that shows:

•              Date

•              Location

•              Job activity

•              Name

•              Social security number

The name of the person who made this determination should also be included. No further testing is required unless the nature of the activity changes.

2.            All surfaces shall be kept free of accumulations of lead dust or fumes. Vacuums with HEPA filters shall be used for cleanup. Compressed air cleaning is forbidden.

3.            Hand washing facilities will be provided. Where showers are not available, employees will be required to wash their hands and face at the end of a work shift, and before taking breaks, eating, smoking, etc. If disposable coveralls and foot protectors are provided, they will be disposed of in approved containers before the employee leaves the work area.


Action Level

1             Within five days, each employee will be notified in writing of the test results that represent that employee’s exposure. Records of air monitoring and medical evaluation tests shall be kept for five years.

2.            If any samples show job categories above the 30 ug/m³ action level but below the 50 ug/m³ permissible exposure limit (PEL), follow-up samples must be taken at least every six months on each employee classification, which has a potential lead exposure.

3.            Initial medical examinations, including lead and zinc ZPP blood level tests, are required for anyone who must work in an area or activity in which the airborne concentration of lead exceeds the 30 ug/    m³ action limit. If the test results show blood lead concentrations greater than 40 ug/dL, additional blood tests shall be conducted every two months. For employees with exposures above the action level for any thirty days in a twelve month period, tests for lead and ZPP levels in the blood will also be conducted at two month intervals. Samples will be taken under the direction of a licensed physician and analyzed by an OSHA approved laboratory. Follow-up blood tests must be conducted within two weeks of notification for employees with blood concentrations greater than 50 ug / dL, and the employee will be removed from any work places with potential lead exposures.

4.            Training in addition to that described in Section 4 under “Negative Results” will be provided and will include:

•              The contents of the lead standard

•              Specific nature of operations that could lead to lead overexposures

•              Proper use of respirators

•              Medical surveillance program Engineering controls

•              Lead exposure control program

•              Employees’ right of access to records

•              Suitable work practices


Exceeding the PEL

1.            If initial air test results show that employee exposure concentrations exceed the permissible

limit (PEL), a written notice shall be provided to the employee advising him or her that the exposure was above the PEL and giving a description of the corrective action to be taken to bring concentrations within acceptable limits.  Additional air test must be conducted on at least a quarterly basis.

2.            Engineering and work practice controls will be used to bring employee exposure concentrations below the PEL. When mechanical ventilation is used, the performance of the system shall be evaluated and documented on a daily basis.

3.            For locations or activities for which respiratory protection is mandatory, the use of respirators will conform to the company’s respiratory protection program, including the provisions for selection, medical evaluation, fit testing, maintenance, and training.

4.            Where employees are subject to airborne lead concentrations in excess of the PEL or where they may come into contact with lead compounds that could cause skin or eye irritation, employees will be required to wear protective clothing such as coveralls, hats, protective footwear, and/or face shields or goggles. Protective clothing shall be cleaned and provided on at least a weekly basis.

5.            Food, beverage, and tobacco products are not allowed in areas where airborne lead exposures exceed the PEL. Clean change areas are to be provided, including separate lockers for work clothing and street clothing, shower facilities, and lead free eating facilities. Employees are required to wash both hands and face prior to eating, drinking, smoking, or applying cosmetics. No employees from high lead concentration areas may enter an eating facility unless vacuuming or other cleaning method that collects lead dust has removed surface lead dust. Adequate hand washing facilities will be provided.

6.            The requirements for blood tests and ZPP are the same as in Section 3 under “Action Level”.

7.            The training requirements are the same as those in Section 4 under “Action Level”.

8.            Warning signs must be posted in areas where the PEL is being exceeded. The signs will read:









Regulated areas will be established and roped off. Non-essential workers will be routed around these areas.


Exposure Control

1             The following controls will be used to keep airborne lead concentrations below the action level of 30 ug/m³3:


Soft demotion/interior walls (lead based paint)

Area cleanup lead contaminated dust Welding or cutting – coatings with lead (enclosed space) Welding or cutting – coatings with lead (open air)

Abrasive blasting/lead coatings       Spray painting/lead content


Mist drywall prior to sawing or breaking HEPA vacuum

Local exhaust ventilation

or clean metal for four inches Respiratory protection

or clean metal for four inches Supplied air respirators

Use paint with no lead content

2.            For each activity in which lead is emitted, a description will be provided including:

The activity:          The nature of the lead source; Equipment in use; Engineering and other

controls; Crew size; Work practices and procedures; Maintenance practices

Any engineering plans or studies used to select the controls should also be documented.

3.            A competent person will provide frequent and regular inspections at the jobsites.

4.            Copies of all air monitoring tests, which identify airborne lead concentrations, will be attached to   this program.

5.            A detailed schedule of equipment procurement, construction contracts, and other plans for implementation of the protection program will also be attached.



These procedures and precautions are the framework for offering significant protection to employees who must work in situations in which hazardous lead dusts or fumes could be generated. It is everyone’s responsibility to provide additional safeguards to these procedures when they are needed.


3.22       Employee Exposure and Medical Records

If any employee is exposed to a regulated chemical, notify Walsh Construction immediately, and obtain the material safety data sheet for that chemical for the appropriate chemical exposure procedure. Exposed employee shall immediately receive a medical examination and continuing surveillance as necessary. Written documentation of the exposure shall be submitted to Walsh Construction within 24 hours of exposure.


3.23       Environmental Testing and Equipment

Walsh Construction will be required to provide a trained individual, capable of properly operating industrial hygiene equipment to perform the following tests as needed:

•              Combustible gas

•              Oxygen deficiency

•              Sound level testing (noise)

•              Toxic gas concentrations (CO, CO2 and NO + NO22)

•              Lighting

The cost of providing testing equipment is solely the responsibility of Walsh Construction. Tests must be performed as often as necessary to afford protection to employees and the general public.

No Walsh Construction operation shall omit or discharge any substance into the environment in violation of the Environment Protection Agency (EPA), OSHA or other regulatory agency requirements. Walsh Construction must assign an employee to be responsible for all environmental monitoring, testing, and compliance. When an accidental discharge occurs immediately, take steps to minimize the discharge, and resultant environmental impact and notify Walsh Construction’s Safety Manager.


3.24       Safe Work

Safe work permits will be required when performing certain specified operations. These specified operations include the following:

•              Welding, cutting, or soldering in any area containing flammable liquids, combustible materials, coal dusts and/or explosive gases, including welding on tanks or vessels that contain or have contained such materials.

•              Entering any tank, vessel, tunnel, manhole, shaft, or other similar confined space. This includes working on top of any tank that contains, or has contained, a toxic substance.

•              Personnel hoisting with a crane.

•              Use of special protective equipment.

•              Handling and using explosives.

•              Trenching and excavation work.

Walsh Construction’s Safety manager shall issue or endorse the Safe Work Permit when required, monitor the permitted work activities in order to assist in the implementation of the safe work procedures and precautions, perform or direct any necessary special environmental testing or monitoring, and maintain records of all permits issued.

Safe work permits are to be issued prior to starting the work activity requiring such permits. Complete         all sections of the permit. If a procedure or precaution does not apply, indicate this in the appropriate column. When possible, give Walsh Construction’s Safety Manager notice prior to requesting special  and  /  or oxygen deficiency monitoring. No work may begin until this monitoring has been completed and evaluated by Walsh Construction’s Safety Manager.


3.25       Permit Required Confined Space Plan

Procedures for Entering a Confined Space Area

•              Have adequate ventilation and lighting in place.

•              Always check oxygen, explosive and toxic gases levels with certified testing equipment.

•              Wear proper personal protective equipment necessary for task at hand.

•              Have safety “attendant” in place at all times.

•              Wear full body harness with lifeline attached when necessary for work that generates toxic fumes.

•              Take frequents breaks and come up for fresh air.


Emergency Procedures for Injured Man

•              Follow normal procedures for injured man and fire (call 911, etc.).

•              Never enter without testing oxygen, explosive and toxic gases levels.

•              Wear proper personal protective equipment necessary.

•              The man basket and/or full body harness shall be used for retrieval of the injured worker.

•              Never enter the area without assistance and a safety “attendant” in place.

•              If you are not sure of the situation, wait for the proper emergency medical personnel.


Confined Space Entry Plan

Before entering the confined space, make sure that there is adequate ventilation and lighting. Oxygen     levels, explosive levels and toxic fume levels should be checked before entering and periodically while         in the confined space. The proper personal protective equipment (safety glasses, hard hats, hard soled shoes, proper respirator required for task at hand, etc.) should be worn AT ALL TIMES.

The safety “attendant” shall be in place at all times while work is being performed. If the safety “attendant” should leave his area for any reason, the alternate safety “attendant” shall be in place before work continues.

Anyone required to work in a confined space where welding, waterproofing, grinding of concrete, or any other related activity that generates toxic fumes occurs will be required to wear a full body harness with life line attached AT ALL TIMES.

Before entering the confined space area, the following procedures must be reviewed and understood by each employee and all safety “attendants”.



The atmosphere must be tested each time before entering a confined space, especially during times when the task at hand creates toxic fumes and / or could cause an oxygen enriched or depleted environment.

A.            The normal oxygen level is 21%. The minimum oxygen level to enter a confined space without a self-contained breathing apparatus is 19.5%. If the oxygen level is greater than 23.5 %, the environment is oxygen enriched, and flammables and combustibles bum more violently and can ignite more rapidly.

B.            Only a trained, qualified person should test the atmosphere for oxygen, explosives and gases. The following gases are typical gases that may be found in a confined space:

•              Hydrogen sulfide

•              Carbon monoxide

•              Methane

•              Carbon dioxide

C.            Always test the bottom, middle, and top of the confined space area. Some gases are lighter or heavier than others and settle at different elevations.



A.            Ensure that there is adequate ventilation and lighting.

B.            Maintain ventilation and lighting AT ALL TIMES.

C.            NEVER uses pure oxygen to ventilate an atmosphere.

D.           If the oxygen level is below 19.5%, you will experience rapid fatigue.

E.            If the oxygen level is above 23.5%, the atmosphere becomes extremely flammable and combustible.  If a fire should develop, everything will burn or ignite rapidly.



A.            A safety “attendant” shall be within voice and/or radio contact with all workers inside the confined space AT ALL TIMES. The safety “attendant” should not leave his position for any reason.

B.            The safety “attendant” should be trained in the jobsite emergency plans for fire and injured man, as well as have radio contact with the jobsite 911 contact person for an emergency.

C.            The safety “attendant” may not perform any other duties other than to monitor the workers inside the confined space.

D.           The safety “attendant” should have a fire extinguisher on hand at all times.

E.            The safety “attendant” should be highly distinguishable from the other workers in the area.


Respiratory Protection


A.            The proper respirator must be worn to match the task at hand.

B.            The workers must be properly trained in how to correctly wear and inspect the respirator they are required to wear.

C.            Any welding, cutting, brazing, painting, grinding, waterproofing, etc., which may produce toxic gases and / or deplete or enrich the oxygen levels in the confined space require that all workers inside the confined space wear full body harness with a life line attached in the event of an emergency with retrieval necessary. These operations may also create a combustible atmosphere, which will also require the full body harness with the lifeline attached.

D.           If any operation causes an oxygen level of less than 19.5% and/or creates a combustible atmosphere where proper ventilation cannot increase the oxygen to acceptable levels, a self-contained breathing  apparatus may be required to be worn by all workers.  If  a  self-contained  breathing apparatus  is worn, then proper training will be required for all workers, including the safety “attendant”.


Confined Space Entry Team

A.            “Entrant”

All workers / entrants of the confined space shall be thoroughly trained in the Confined Space program.

B.            “Attendant”

All worker / entrants shall be constantly monitored by an attendant trained in the Confined Space program.

C.            “Entry Supervisor”

Entry Supervisors shall supervise all Confined Space operations. Entry Supervisors shall be trained in the Confined Space program.

All employees who are required to enter confined spaces shall be properly trained   and that training shall be documented.


3.26       Locating Utilities

Prior to any underground work being performed, all utilities within the area of work must be located.

•              The utility companies shall be contacted either through a One Call System or contacted directly and have all utilities within the area of work located and marked.

•              The contract specifications and drawings will be reviewed by Walsh Construction and / or the subcontractor for notations of utility companies that may not be a member of an underground service alert group. Those not members of an underground service alert group must be contacted directly

•              All calls to the utility companies will be logged and retained by Walsh Construction.

•              Walsh Construction will visually check the area for signs indicating the possibility of recent underground relocation work by an outside entity.

•              Walsh Construction’s Superintendent will notify at least seventy-two (72) hours in advance to alert him and his staff to the upcoming underground work.

•              Walsh Construction will take all necessary steps to protect the utilities from damage.


3.27       Overhead Power Lines

Walsh Construction safety program will include the following:

•              All overhead wires will be considered to be energized unless and until the person owning such line or operating officials of the electrical utility supplying the line assures that it is NOT ENERGIZED and      it has been visibly grounded.

•              Operations adjacent to overhead lines are prohibited unless at least one of the following conditions         is satisfied:

1.            Power has been shut off and positive means taken to prevent the lines from being energized,       or

2.            Equipment, of any part, does not have the capability of coming within the minimum clearance from energized overhead lines as specified, or

3.            The equipment has been positioned and blocked to assure no part, including cables can come within the minimum clearances as specified. The minimum required clearances shall be posted at the operator’s position.


3.28       Excavations

Any cut, cavity, trench or depression in the earth surface formed by earth removal must comply with the OSHA Regulations. It is required, that Walsh Construction will train those employees who will work in and around excavations concerning the hazards, daily inspections, soils testing, soils classifications and protective or support systems.

1.            Trenches and excavations as described below in which employees are exposed to danger from moving ground or cave-ins shall be guarded by proper sloping, a shoring system,

or other equivalent means.

•              Trenches in unstable material 5’-0” or more in depth.

•              Excavations for building footings in unstable material in excess of 5’-0” in depth.

•              Excavations for manholes, vaults, and other underground facilities in excess of 5’-0” in dept

2.            Conditions immediately adjacent to a trench or excavation, such as trees, boulders, slides, banks, or building foundations, shall be examined and proper precautions taken.

3.            Site conditions, such as surface water drainage and vibration from blasting, traffic, or machinery,     shall be considered in planning the excavation.

4.            The competent person at least daily shall inspect Trenches and excavations in which associates are working and more frequently as made necessary by rainstorms, freezing and thawing conditions, and other hazard increasing occurrences.

5.            Excavated and other material shall be kept at least 2′-0″ from the edge of any trench or excavation. Where this requirement cannot be met, effective barriers or retaining devices shall be used.

6.            When employees are required to enter a trench or excavation 4′-0″ deep or more, approved ladders of proper length and location shall be used and shall be within 25′-0″ of travel distance at all times.

7.            Heavy machinery or material should not be placed near the edge of excavations unless necessary precautions are taken to prevent a cave-in. A distance of at least 2′-0″ should be   maintained.

8.            Where an oxygen deficient, explosive, or toxic atmosphere hazardous to employees may be present in a trench or excavation, proper tests shall be made. Work in a hazardous area shall continue only after necessary and proper measures make it safe to do so.

8.            Before and during an excavation, effort shall be made to discover the position of and To prevent damage to underground facilities, such as pipelines, storage tanks, cables, Etc.  Proper measures shall be taken to protect employees from hazards resulting from exposed facilities.

9.            A competent person shall inspect the trench or excavation daily and document the inspection in the foreman’s work book. The competent person shall be present during dewatering activities.


3.29       Access and Egress for Work Areas

The risk of falls by employees entering and leaving the work areas must be prevented. Walsh Construction must use OSHA approved ladders for all ladders that are required to access their work. Use permanent stairs and elevators or personnel hoists as the primary means of access or egress to and from all work areas as soon as possible. Stairs, elevators and personnel hoists shall meet OSHA Regulations.


3.30       Ladders

All ladders will be secured with a rope or other substantial device. Ladders used on this project will be considered work platforms.

All ladders shall be inspected prior to each use, and broken or damaged ladders shall be removed from service immediately and appropriately repaired or destroyed. All ladders must conform to OSHA standards.

All straight ladders shall be set on firm, level foundations at a four (4) to one (1) pitch, have clear access at the top and bottom, extend at least 36 inches above the landing, and be secured against movement while in use. Safety feet shall be used on all straight ladders. Portable metal ladders shall not be used for electrical work or where it might contact electrical conductors. Single portable ladders over 24 feet in length shall not be used.   Stepladders must be erected according to the   manufacturer recommendations.


3.31       Earth Moving Equipment and Trucks

Walsh Construction’s program will include the following earth moving equipment requirements:

•              All trucks shall be marked with all company name

•              All earth moving equipment will be maintained in safe working condition and will be appropriate and adequate for the intended use.

•              Only authorized personnel will operate equipment. Operators of equipment, machinery or vehicles  will be qualified and properly licensed for the operation involved.

•              Equipment maintenance is to be performed only by qualified mechanics.

•              Equipment operators and truck drivers will make a pre-shift walk around safety inspection of their equipment, and any conditions that effect safe operation will be corrected before further use.

•              Equipment will not be operated unless all required safety devices are in place and functioning properly.

•              Careless, reckless or otherwise unsafe operation or use of equipment will result in discipline and may constitute grounds for dismissal.

•              Before performing any service or repair work, all equipment will be stopped and positively secured against movement or operation, locked and tagged out of service, unless it is designed to be serviced while running, following the manufacturer’s instructions.

•              When equipment is serviced or repaired, the operator will dismount until the service or repair is completed and then makes a complete walk-around and safety check before remounting and restarting the equipment.

•              All bi-directional earth moving equipment and motor vehicles with an obstructed view to the rear will be equipped with a warning horn and an automatic back-up alarm that can be heard above and distinguished from the surrounding noise level.

•              All off-highway earth moving equipment and trucks such as loaders, dozers, scrapers, motor graders, rock trucks, tractors, rollers and compactors will be equipped with rollover protective structures (ROPS) and seat belts.

•              Seat safety belts will be installed on and used by the operators of equipment provided with ROPS.

•              Mobile equipment will not be left unattended unless parked securely to prevent movement, with all ground engaging tools lowered to the ground, brakes set and the engine off.

•              Equipment parked at night will be lighted, barricaded or otherwise clearly marked where exposed to traffic.

•              Personnel will not be transported or ride on equipment or vehicles that are not equipped with seats for passengers.

•              When fueling equipment or vehicles with gasoline or liquefied petroleum gas (LPG) the engine will be shut down.

•              All equipment and vehicles will be equipped with appropriate fire extinguishers or fire suppression system.

•              Haul roads will be designed, constructed and maintained for safe operation consistent with the type of haulage equipment in use. Standard traffic control signs will be used where necessary.

•              Elevated roadways will have axle high beams or guards maintained on their outer banks.

•              Equipment, tools and materials hauled on pickups and flat bed trucks will be secured to prevent them from falling onto the road.

•              Equipment, pickups and passenger vehicles not necessary for performing the work should be parked in a location as established by the Project Superintendent, away from the work area to reduce congestion and avoid collisions.

•              Equipment is to be inspected upon arrival to the project to ensure safe operation.


3.32       Hand and Power Tools

All hand, power tools, and similar equipment, whether furnished by the employer or the employee, shall be maintained in a safe condition.

Tools and equipment must be in good condition and well maintained. Only qualified, trained persons may use tools and equipment. Tools, guards, and protective devices must not be altered. Tools are only to be used for their designed purpose.   All personal tools as well as company tools are subject to inspection at anytime. Personal tools shall conform to the same safety requirements


3.33       Powder-Actuated Tools

Low-velocity  tools  with  a  pistol  grip  shall  be  used  in  all  cases where applicable.    High velocity tools shall be only used for those applications where low-velocity tools will not meet job requirements.

Powder-actuated tools shall be used operated, repaired, serviced, and handled only by authorized personnel, who have been trained and certified by the manufacturer. Tools will be tested daily and all defects corrected before use.

Tools shall not be loaded until immediately before use.  Loaded tools shall not be left unattended.

The appropriate signage must be posted at all entrances to the work area, when using the powder- actuated tool


3.34       Electrical Work

All electrical work must be performed in accordance with the National Electric Code (NEC) and OSHA.

Walsh Construction will utilize Ground Circuit Interrupters for all temporary power.


3.35       “Lockout”/ “Tagout” Clearance Procedure

Walsh Construction will have a written “Lockout”/ “Tagout” Procedures Program. The program shall meet OSHA 1926 Requirements and provide for training so that all employees regardless of language/ reading skills can understand the program and can identify what tags and locks are to be used.



Lockout is the preferred method of isolating machines or equipment from energy sources. To assist employers in developing a procedure, which meets the requirements of the standard, however, the following simple procedure is provided for use in both lockout and tagout programs. This procedure may be used when there are limited numbers or types of machines or equipment or there is a single power source. For more complex systems, a more comprehensive procedure will need to be developed, documented, and utilized.



This procedure establishes the minimum requirements for the lockout or tagout of energy isolating devices. It shall be used to ensure that the machine or equipment is isolated from all potentially hazardous energy and locked out or tagged out before employees perform any servicing or maintenance activities where the unexpected energization, start-up or release of stored energy could cause injury.



Appropriate employees shall be instructed in the safety significance of the lockout or tagout procedure.   Each new or transferred employee who is affected and other employees whose work operations are or may be in the area shall be instructed in the purpose and use of the lockout or tagout procedure.



Make a survey to locate and identify all isolating devices to be certain which switch (es), valve(s), or other energy isolating devices apply to the equipment to be locked or tagged out. More than one energy source (electrical, mechanical, or others) may be involved.



1.            Notify all affected employees that a lockout or tagout system is going to be utilized and the reason therefore. The authorized employee shall know the type and magnitude of energy that the machine or equipment utilizes and shall understand the hazards thereof.

2.            If the machine or equipment is operating, shut it down by the normal stopping procedure (depress stop button, open toggle switch, etc.).

3.            Operate the switch, valve, or other energy isolating device(s) so that the equipment is isolated from its energy source(s). Stored energy, such as that in springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc., must be dissipated or restrained by methods such as repositioning, blocking, bleeding down, etc.

4.            Lockout and/or tagout the energy isolating devices with assigned individual lock(s) or tag(s).

5.            After ensuring that no personnel are exposed and as a check on having

disconnected the energy sources, operate the push button or other normal operating controls to make certain the equipment will not operate.

CAUTION: Return operating control(s) to “neutral” or “off” position after the test.

6.            The equipment is now locked out or tagged out.



1             After the servicing and/or maintenance is complete and equipment is ready for

normal production operations, check the area around the machines or equipment to ensure that no one is exposed.

2.            After  all  tools  have  been  removed  from the  machine  or  equipment,  guards have been reinstalled, and employees are in the clear, remove all lockout or tagout devices to restore energy to the machine or equipment.



In the preceding steps, if more than one individual is required to lockout or tagout equipment, each shall place his / her own personal lockout device or tagout device on the energy isolating devices(s). When an energy- isolating device cannot accept multiple locks or tags, a multiple lockout or tagout device (hasp) may be used. If lockout is used, a single lock may be used to lockout the machine or equipment with the key being placed in a lockout box or cabinet which allows the use of multiple locks to secure it. Each employee will then use his/her own lock to secure the box or cabinet. As each person no longer needs to maintain his or her lockout protection, that person will remove his/her lock from the box or cabinet.



All equipment shall be locked out or tagged out to protect against accidental or inadvertent operation when such operation could cause injury to personnel. Do not attempt to operate any switch, valve, or other energy-isolating device where it is locked or tagged out.


3.36       Welding and Cutting

In addition to strictly following the provisions of OSHA and NFPA, Walsh Construction and / or the subcontractor’s safety program will also require the following:

•              Indoctrination in the safe handling, storage and use of compressed gas cylinders.

•              Supply proper personal protective equipment (Gloves, Proper eye protection, Combination hard

– hat and proper clothing) as well as instructions in its proper use when performing welding and cutting operations.

•              Use regulators for fuel gas and oxygen cylinders that are in good working order and have either an anti- flashback or check valve securely attached.

•              Direction to keep at least a 10-pound, properly rated, dry chemical fire extinguisher in the immediate vicinity of each work operation.

•              Instructions to use fuel and O2 cylinders only in a secured and upright (vertical) position.

•              Positive means shall be taken to confine the heat, sparks, and slag and protect immovable fire hazards from them.

•              Inspect all equipment prior to each use for wear and tears


3.37       Compressed Gas Cylinder Storage

Oxygen cylinders shall be separate from fuel gas cylinders. This separation shall be either a minimum distance of 20 feet or created by a fire resistive wall / partition with a one-hour fire rating and a minimum of five feet (5’) in height. All cylinders shall be stored in a vertical position.

Empty cylinders will not be stored with full cylinders and the valves of the empty cylinders shall be in the closed position.

All cylinders shall be stored where they are protected from the direct rays of the sun. When not in use, cylinders shall have their protective caps in place and is hand tightened.


3.38       Fire Prevention Program

It is the responsibility of the superintendent to maintain temporary fire protection by use of portable fire extinguishers and temporary standpipes with weekly inspections. All workers of all employers will be trained in the use of portable fire extinguishers and emergency plans and evacuations. All local fire departments, ambulance services, and emergency medical personnel shall be contacted prior to mobilization to advise  them of the job location, key contact personnel and to be advised of the jobsite emergency plans for fire, injured man and confined space areas if applicable.


Temporary Fire Extinguishers

•              All workers shall be trained in the proper use of fire extinguishers

•              A 20-pound BC fire extinguisher shall be kept no less than 25 feet and no greater than 75 feet from all fuel storage areas, which include gasoline, diesel, propane, oxygen and acetylene.


Fuel Storage Areas

All fuel storage tanks used for gasoline and diesel fuel shall have a berm installed around the tank at least 1 foot in height and adequate enough in size to contain all the contents of the fuel tanks or the utilization of double walled fuel tanks will be used.

All fuel storage areas shall be at least 25 feet from all building and temporary structures or separated by a 1 hour rated firewall.

•              All cylinders shall be kept upright and secured at all times

•              All fuel tanks shall be marked as to their type of fuel and “Flammable – No Smoking”.


Temporary Heating

•              All temporary heaters shall be kept at least 5 feet from all flammable materials such as wood, paper, plastic, tarps, etc.

•              Solid Fuel salamander type heaters shall not be used.

•              Fuel for temporary heaters shall not be stored in 55 gallon drums within the building or temporary buildings unless these areas are specifically designed and ventilated for fuel storage.

•              All purpose portable heaters shall be kept at least 5 feet from the propane storage cylinders

•              All propane storage cylinders shall be kept upright and secured at all times.

•              No LPG storage inside buildings.


3.39       Structural Steel Work

General requirements

•              100 % fall protection is mandatory for any employee exposed to a fall 6 feet or greater.

•              Containers shall be provided for storing or carrying rivets, bolts, and drift pins, and secured against accidental displacement when aloft.

•              Pneumatic hand tools shall be disconnected from the power source, and pressure in hose lines shall be released, before any adjustments or repairs are made.

•              Airline hose sections shall be tied together except when quick disconnect couplers are used to join sections.

•              Eye protection shall be provided in accordance with OSHA requirements and this Manual.



•              When bolts or drift pins are being knocked out, means shall be provided to keep them from falling.

•              Impact wrenches shall be provided with a locking device for retaining the socket.

•              Bolts, nuts, washers and pins shall not be thrown. They shall be placed in bolt baskets or other approved containers and raised or lowered by using a line.



•              Connections of the equipment used in plumbing-up shall be properly secured.

•              The turnbuckles shall be secured to prevent unwinding while under stress.

•              Plumbing-up guys related equipment shall be placed so that employees can get at the connection points.

•              Plumbing-up guys shall be removed only under the supervision of a competent person.

•              Wood planking shall be of proper thickness to carry the working load, but shall be not less than 2 inches thick full size undressed, exterior grade plywood, at least 3/4-inch thick or equivalent  material.

•              Metal decking of sufficient strength shall be laid tight and secured to prevent movement.

•              Planks shall overlap the bearing on each end by a minimum of 12 inches.

•              Wire mesh, exterior plywood, or equivalent, shall be used around columns where planks do not fit tightly.

•              Provisions shall be made to secure temporary flooring against displacement.

•              All unused openings in floors, temporary or permanent, shall be completely planked over securely or guarded to prevent employees falling and the holes must be labeled “Danger – Hole Do Not Remove” or equivalent markings.

•              Employees shall be provided with safety harnesses in accordance with 1926.104 and the Fall Protection section of this manual when they are working on float scaffolds.

•              Safety nets shall be provided when workplaces are more than 25 feet above the ground or water surface, or other surfaces where the use of ladders, scaffolds, catch platforms, temporary floors, safety lines, or safety harnesses is impractical.

•              Where safety net protection is required by this part, operations shall not be undertaken until the net is in place and has been tested.

•              Nets shall extend 8 feet beyond the edge of the work surface where employees are exposed and shall be installed as close under the work surface as practical but in no case more than 25 feet below such work surface. Nets shall be hung with sufficient clearance to prevent user’s contact with the surfaces or structures below. Such clearances shall be determined by impact load testing.

•              It is intended that only one level of nets be required for bridge construction.

•              The mesh size of nets shall not exceed 6 inches by 6 inches. All new nets shall meet accepted performance standards of 17,500 foot-pounds minimum impact resistance as determined and certified by the manufacturers, and shall bear a label of proof test. Edge ropes shall provide a minimum breaking strength of 5,000 pounds.

•              Forged steel safety hooks or shackles shall be used to fasten the net to its supports.

•              Connections between net panels shall develop the full strength of the net.



•              When connectors are working together, only one person should give the signals. That person should make sure that the partner or others working on the job are in the clear. Each employee should select a position to avoid being struck by a swinging load.

•              When connectors are working in pairs, one end of the piece should be bolted before going out to connect the other end and then only one connector shall go out to bolt the other end.

•              Tag lines shall be used for controlling loads.

•              At no time shall connectors or other employees be allowed to ride the headache ball, hook or load. Other means of access shall be provided.


General Safety Requirements

•              100 % fall protection is mandatory for any employee exposed to a fall 6 feet or greater.

•              Suitable eye protection shall be provided for reaming, drilling, welding, cutting and the driving of wedges, shims or pins.

•              Containers shall be provided for storing or carrying bolts, drift pins and other loose objects and shall be secured against falling when aloft.

•              At no time shall any employee be working beneath or exposed to suspended loads.


Air Tools

•              Pneumatic hand tools shall be disconnected from the power source and pressure in hose lines shall be released before any adjustment or repairs to the tools are made.

•              Airline hose sections shall be tied together by safety cords, wire, etc.

•              Air hoses located on roadways shall be bridged or otherwise protected to prevent damage by  vehicles.

•              Impact wrenches shall be provided with a locking device for retaining the socket.


Drilling and reaming

•              Drilling and reaming machines are to be secured to the structure by rope or cable in addition to normal magnetic or clamp methods.



•              All employees performing structural steel erection shall be trained in the hazards associated with this type of work prior to work commencing. Training shall be done by “Tool-box” safety meetings, or hands on    task demonstration by the supervisor.

•              Training topics shall include but not be limited to the Fall Protection system(s) to be used; the steel erection procedure that is to be followed on this project, OSHA steel erection requirements as well as any client specific safety procedures.

•              The erection of structural steel is a unique and challenging trade. Therefore, this work should be done by experienced ‘Ironworkers”

•              Walsh Construction will be sub contracting steel erection on the Cook Tract


3.40       Cranes and Crane Safety

The following crane safety requirements must be included in Walsh Construction safety program:

•              All cranes and crane usage will meet the requirements OSHA 1926.

These requirements are summarized as follows additional requirements may apply and be imposed:

•              Walsh Construction must submit a copy of the crane certification and documentation of the most recent annual inspection prior to crane use to the authority for review.

•              A daily and monthly inspection must be performed while cranes are in use on this project. The reports must be made available for review to the representative.

•              All cranes shall be de-rated to 90% of the manufacturer’s capacity as indicated by the manufacturers load chart.

•              All cranes must have the appropriate load chart in the cab at all times, if the correct load chart is not available then the machine will be taken out of service.

•              ALL crane operators must be certified to operate the specific crane that they are assigned to. They must be in possession of a current CCO license (Certified Crane Operator) valid for the type of crane intended to be used.

•              Any crane lift exceeding 75% of the cranes rated capacity or multiple crane lifts shall be considered to be a critical lift. All guidelines of 10 cfr 1926 shall be adhered to.

•              If two cranes are working in the same area, a procedure shall be established and submitted explaining coordination  between  the  two  cranes  to  ensure  the  possibility  of  collision  is prevented.

•              Mobile cranes shall only be used when outriggers are fully extended unless manufacturer’s specification permits otherwise.

•              If supporting ground is soft, the lift shall not be made until firm bearing is provided to include crane mats if necessary. No crane lift shall be made if the crane is not level.

•              If the full range of the lift is not visible to the operator, signalmen or radio communication must be provided.

•              All signal persons will:

1.            Receive proper signaling training.

2.            Never allow a suspended load to pass over or come within 20 feet of power lines.

3.            Never allow a suspended load to pass over any individual, nor any individual to pass under a suspended load.

4.            Be in constant eye, hand or radio communication with the crane operator.

•              All rigging equipment (i.e., slings, softeners, bridles, blocking cables, etc.) will be in good and serviceable condition, properly identified as to capacity and properly stored when not in use.

•              For multiple crane lifts, the cranes rated capacity must be reduced by 25%.


3.41       Signaling and Rigging

One person on the crew shall be appointed as the signal person, and will be the only one permitted to give signals to the crane operator. The signal person shall not order the crane operator to move a load until all members of the crew are ready. Each worker must be in the clear before the signal person gives the command to move the load. Check for overhead obstructions and maintain a minimum of 20 feet clearance from the power lines.

Care must be taken to try to position  the  hook  as close the load center as possible.  Employees should never place themselves between the load and other stationary objects to avoid being caught between. Employees should not be near any stacked materials that might be knocked over by a swinging load.    Never work or pass under a load that is lifted.


3.42       Use of Man Cages and Suspended Work Platforms

Walsh Construction prior to using a crane to lift / lower and / or suspend personnel in man cages or work platform must:

•              Review with Walsh Construction’s Corporate Safety Director and Safety manager why the crane must be used, its intended use with either a man cage or work platform.

•              Establish a work plan to be submitted to and reviewed by Walsh Construction’s Safety manager.

•              Review requirements above with Walsh Construction’s Safety manager prior to using work platforms  or man cages.

•              The Walsh Construction work plan will include:

1.            The crane location, number of personnel in platform, types of work being performed and travels distance of platform, both horizontal and vertical.

2.            A description of existing conditions and why the present methods of operations require the use of a crane to suspend a work platform or man cage.

3.            A description of the crane to be used and the manufacturer’s recommendations and  requirements when using the crane to lift / lower and / or suspend personnel on work platforms or in man cages.

4.            Drawings of the work platform or man cage suspension bridle and other components with computations used in the design.

5.            A copy of the most recent annual inspection report, as well as the latest monthly inspection report.

•              Walsh Construction is responsible for complying with the most stringent crane and work platform       or man cage provisions of the OSHA regulations and ANSI guidelines.

•              Walsh Construction will also be aware of ANSI guidelines when using a crane for lift / lowering and / or suspending personnel on a work platform or in man cages.

•              Walsh Construction will have the following features installed and operating prior to using a crane to lift / lower and / or suspend personnel on work platforms or in man cages:

1.            Power-up and power-down load line.   Power will not be disengaged while handling    personnel.

2.            Automatic braking (dead-man control). Ensure the load stops when an operator releases his controls.

3.            Anti-two blocking devices will be provided, capable of preventing damage to the hoist rope or other crane components.

4.            Boom angle indicator.

5.            All telescoping crane booms will be marked to indicate to the crane operator their extended length.

6.            Only modifications authorized in writing by the crane manufacturer will be performed on the crane.

3.43       Material / Overhead Hoists

Know the weight of loads to be lifted. Select the hoist that has the capacity for the load. Do not leave an unsecured or unattended load hanging on a hoist or chain fall. Use lashing, blocking, or other equivalent methods if loads must be left unattended or hanging. Be sure that the hoist and load are in a straight line; do not put at an angle. Inspect all hoists, hooks, and chains prior to use for damage. Never operate a malfunctioning hoist.


3.44       Fall Protection Requirements

Walsh Construction and / or the subcontractors will implement a Fall Protection Program. The program shall meet OSHA 1926 Requirements.

The components of Walsh Construction Fall Protection include but not limited to:

1.            No person will be permitted to be exposed to a fall hazard greater than six feet.

2.            If personal fall arrest systems are needed they shall meet OSHA Subpart M.

3.            All fall arrests systems shall be installed and used in accordance with the manufacturer’s specifications.

4.            If a fall arrest system is not designed by a manufacturer, Walsh Construction will submit design and load calculations performed by a professional engineer who is registered in the state of Pennsylvania to the authority for review.


3.45       Floor Openings and Stairways

Provisions shall be made at all unprotected floor openings and stairways for barriers and toe boards. These shall remain in place until the openings have been closed or permanent stairs installed. When Walsh Construction and / or the subcontractor must remove said barriers in the performance of their work, they are responsible for replacing the barriers so as to provide protection at all times. Never, under any circumstance, cover a floor opening with plywood, sheet rock, or other unsuitable material. All floor coverings must be secured, and support a minimum of 500 lbs. or twice the intended load. Each covering must be marked “HOLE” or “COVER”.


3.46       Use of Wire Rope Guardrails

The following will be required when using wire rope guardrails:

•              Wire rope will be 3/8-inch aircraft cable or ½ inch diameter IWRC.

•              Connections will be in the form of eyes, and no less than two wire rope clips will be used for each. Wire rope ends must not be overlapped and clamped together. Single tuck splices to form an eye are prohibited.

•              Anchor points or supports for wire rope guardrails will be capable of supporting a minimum dead weight of 5,000 pounds per person.

•              Turnbuckle-type devices may be used to prevent a wire rope guardrail from sagging more than three inches (3”) when 200 pounds of force is applied to no lower than 39 inches. Turnbuckles must be a minimum of

¾ inch diameter.

•              The top rail shall be flagged at 6 foot intervals to delineate to cable location.

•              Should other means of supporting and fastening the wire rope guardrails be used, manufacturer’s data showing that the 5,000-pound dead weight support requirement will be met, must be approved by the Project Manager.


3.47       Scaffolding

Scaffolds must be designed, built, and inspected by competent persons.  The use of makeshift platforms   will not be allowed. Each application must be carefully planned to ensure that scaffolding is used where required and that such scaffolding conforms to the applicable scaffolding erection requirements.

Scaffold safety will include the following:

•              Scaffolds will not be used for the storage of material except for immediate use.

•              Materials will only be placed over cross members.

•              All scaffolds must be adequately designed to carry, without failure, four (4) times the maximum intended load.  At no time shall scaffold be overloaded.

•              All scaffolds shall be maintained in safe condition with all pins and safety locks in place and scaffolds damaged or weakened, from any cause, shall be immediately replaced.

•              Scaffolding or staging more than six (6) feet above the ground or floor, suspended from an overhead support, or erected with stationary supports, and mobile scaffolds shall have standard guardrails and toe- boards properly attached.

•              Guardrails must meet OSHA requirements as a minimum. OSHA regulation state that guardrails shall be two inches by four inches (2” x 4”) or the equivalent, approximately 42 inches high with a midrail. Supports shall be at intervals not to exceed eight feet (8’). Toe boards shall be at least tree and one-half inches high from the top edge of the toeboard to the level of the walking /working surface. Planking shall be cleated or otherwise secured to prevent displacement. All platforms will be the complete width of the scaffold being erected.

•              Scaffolds shall be braced and tied off both horizontally and vertically at intervals specified in the pertinent regulations.

•              Supported scaffold poles, legs, posts, frames and uprights shall bear on base plates and mudsills or other firm foundation.

•              Mobile scaffolding will be equipped with outriggers; all casters will be locked.  Mobile scaffolding will  be  guarded  with  standard  railing  regardless of height.          Also,  no  mobile  scaffolding will be constructed or used where there is a change of elevation in the floor level.

•              No employee will be transported or moved on a mobile scaffold.


3.48       Concrete and Masonry Construction

Employers must not place construction loads on a concrete structure or portion of a concrete structure unless the employer determines, based on information received from a person who is qualified in structural design, that the structure or portion of the structure is capable of supporting the intended loads.

Employees (except those essential to the post-tensioning operations) must not be permitted to be behind the jack during tensioning operations. Signs and barriers must be erected to limit employee access to the post- tensioning area during tensioning operations.

Employees must not be permitted to ride concrete buckets. Employees must not be permitted to work under concrete buckets while the buckets are being elevated or lowered into position. To the extent practicable, elevated concrete buckets must be routed so that no employee or the fewest  employees  possible  are  exposed to the hazards associated with falling concrete buckets.

Employees must not be permitted to apply a cement, sand, and water mixture through a pneumatic hose unless they are wearing protective head and face equipment.

Formwork must be designed, fabricated, erected, supported, braced, and maintained so that it will be capable of supporting without failure all vertical and lateral loads that might be applied to the formwork. Forms and shores (except those used for slabs on grade and slip forms) must not be removed until the employer determines that the concrete has gained sufficient strength to support its weight and superimposed loads.

Drawings and plans, including all  revisions  for  the  jack  layout,  formwork  (including  shoring  equipment), working decks and scaffolds, must be available at the jobsite. All shoring equipment (including equipment used in re-shoring operations) must be inspected prior to erection to determine that the equipment meets the requirements specified in the formwork drawings. Damaged shoring equipment must not be used. Erected shoring equipment must be inspected immediately prior to, during, and immediately after concrete placement. Shoring equipment that is found to be damaged or weakened after erection must be immediately reinforced. Re-shoring must be erected, as the original forms and shores are removed, whenever the concrete is required to support loads in excess of its capacity. Re-shoring must not be removed until the concrete being supported has attained adequate strength to support its weight and all loads in place upon it.

Any impalement hazard to include protruding reinforcing steel, onto and into which employees could fall, must be guarded to eliminate the hazard of impalement. Reinforcing steel for walls, piers, columns, and similar vertical structures must be adequately supported to prevent overturning and collapse. Employers must take measures to prevent unrolled wire mesh from recoiling. Such measures may include, but are not limited to, securing each end of the roll or turning over the roll.

Precast concrete wall units, structural framing, and tilt-up wall panels must be adequately supported to prevent overturning and to prevent collapse until permanent connections are completed. Lifting inserts that are embedded or otherwise attached to tilt-up wall panels must be capable of supporting at least two times the maximum intended load applied or transmitted to them; lifting inserts for-other pre-cast members must be capable of supporting four times the load.

Only essential employees are permitted under pre-cast concrete that is being lifted or tilted into position.

Whenever a masonry wall is being constructed, employers must establish a limited access zone prior to the start of construction. The limited access zone must be as follows:

•              Equal to the height of the wall to be constructed plus 4 feet, and shall run the entire length of the wall;

•              On the side of the wall that will be un -scaffold;

•              Restricted to entry only by employees actively engaged in constructing the wall; and

•              Kept in place until the wall is adequately supported to prevent overturning and collapse unless the height of wall is more than 8 feet and unsupported; in which case, it must be braced. The bracing must remain in place until permanent supporting elements of the structure are in place.


3.49       Abrasive Blasting

Every component of an abrasive blasting setup must be checked out and its proper operation function    assured before any attempt is made to put the unit into service. Although the process of abrasive blasting is commonly referred to as “sandblasting”, Walsh Construction’s policy is to use non-silica based abrasive materials, such as copper slag. When removing coatings and cleaning certain metals, hazardous  materials  may be released into the air. Respiratory protection may be required. Each sandblast machine shall be equipped with a dead man switch / valve. It is NEVER permissible to block the wobble stock of an electric dead man switch sandblasting. The switch must be manually depressed and held in during blasting. Each employee performing abrasive blasting shall be supplied with and required to wear the appropriate respiratory protection.


3.50       Silica Dust Control

Silica dust safety precautions must be implemented for exposures that:

•              Might endanger the health of employees.

•              Create a nuisance to the general public.

Protection for those exposed to silica dust must be provided:

•              When grading, cutting or using a hammer – drill all surfaces should be wet to control dust.


3.51       Housekeeping

A clean job is a safe and efficient job site. All trash and debris will be placed in proper containers, properly stacked or removed from the job site. Rags and flammable debris will be removed or stored in proper containers to eliminate fire hazards.

All employees shall clean up continuously as they work. Tools shall be kept in a job box while they are not being used, so they are out of the way and easy to find. They shall remove or bend over nails, and keep materials stacked neatly, out of the way, to maintain a clear path for traffic.


3.52       Earthwork and Dust Suppression Plan

The proper and safe execution of any Earthwork operation requires detailed planning and close coordination with all stake holders. Daily coordination and safety meetings will be held onsite or at the project yard before work begins, these meetings incorporate the THA and the work plan for the day. Any inspection staff is welcome to participate in this meeting.

Specific to the earthwork operation associated with the Cook Tract Development we offer the following plan:

1)            Personnel Protection – All employees are required to where reflective vests and hard hats for visibility. All spotters, as needed, will be specifically trained for the operation. Also refer to section 3.18

2)            Temporary Facilities – Temporary sanitary facilities and potable water will be available to all employees on the site and within walking distance.

3)            One-Call/Utility Mark Out – A current One Call Ticket will be on hand at the project office. The ticket will be updated in accordance with state law. Any utilities marked out within the work area will be investigated prior to the commencement of production operations in that same vicinity. The method of investigation will be hand digging and/or hydro excavation. During any investigation specific effort will be made to have the utility owner onsite to witness operations and discoveries. All discoveries will be documented and maintained in the field office.  Also refer to section 3.26

4)            Competent Person – As defined by OSHA, all excavation operations will be monitored by a competent person. All operators of equipment will be specifically trained for the equipment and the operation being done.

5)            Equipment – All equipment will be equipped with basic industry standard safety devices. This includes flashing beacons, horns, backup alarms, and lights as needed. Earthwork conducted at night will be done so with the assistance of temporary light plants. Light plants will be positioned to provide the optimum amount of light to safely execute the work.  Also refer to section 3.31

6)            Spills – In preparation for an accidental spill, spill kits are available at the project yard. Personnel onsite will be trained in the proper use of the kits. Any accidental spills will be cleaned up promptly and legally. The owner or owner’s representative will be promptly informed as well.

7)            Haul Routes – As a part of daily safety meetings, an established haul route will be determined to minimize the amount to trucks reversing. Drivers will be informed of the route and delineation tools will be utilized as needed. No Township roads may be traversed during fill delivery operations related to the Cook Tract project. In addition, all construction access to the Cook Tract site for the park project shall be from the Turnpike haul road.

8)            House Keeping and Dust Control – The site will be maintained in a clean and organized fashion. Any materials stored or staged onsite will be kept in good order. Debris will be legally disposed of offsite. Proper Rock Construction Entrances will be maintained to minimize the tracking of dirt onto any public roadway. The generation of dust will be closely monitored by onsite staff, physical dust control will be achieved using a water truck outfitted with the appropriate spray bars and wash down nozzles. Should the water not act as an effective enough dust suppression agent, an additive such as Durasoil® or SynTech 2112 HS® will be utilized to maintain proper dust suppression. All performed in accordance with typical construction practices.  Also refer to section 3.51

9)            Site Access – Site access will only be granted to individual persons by Walsh Construction or Whitpain Township. To deter individuals from accessing the site during construction, large NO TRESPASSING signs mounted on Type III barricades, pictured here, will be placed in prominent locations around the site. In between the large signs, smaller NO TRESPASSING signs will be mounted to trees along the property line. In addition, barricades and/or gates will be placed at the rock construction entrances to deter individuals from entering the site during non-working hours. If any safety or security issues arise due to unauthorized individuals accessing the project work zones, Walsh Construction Company will install orange construction fencing in appropriate areas to deter access to the work areas by unauthorized individuals. No Township roads may be traversed during fill delivery operations related to the Cook Tract project.  In addition, all construction access to the Cook Tract site for the park project shall be from the Turnpike haul road. Also refer to section 3.2, 3.4

10)          Nighttime setback line delineation – To insure that equipment and trucks do not travel on the Western side of the nighttime setback line, light plants utilized to illuminate the work area will be placed along this line and faced towards the work area.  In addition, cones or vertical panels will be used to delineate this line. Prior to work at night, the setback line will be marked in the field and clear reference points will be established for continual delineation. Walsh Construction shall, to the maximum extent practicable, limit back- up alarms during nighttime operations related to the Cook Tract park project.

11)          Revisions – This document may need to be revised in the future to address any unforeseen issues that may arise from this project. Any revisions to the HSE plan will be submitted to Whitpain Township for review and approval.

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Subcontractor Safety Awareness Statement


I, as an authorized representative of _________________________________________________certify that my company will adhere to the safety rules and policies that are outlined within this program.  I agree to ensure that all of our employees follow these recommended practices.


I understand that I am responsible for my own safety as well as the safety of my fellow employees. I will bring to Walsh Construction’s attention any unsafe conditions, which, if gone unreported, could lead to accident occurrence.




Company Name: _______________________________________________

Safety Manager’s Name: ________________________________________

Project Manager’s Signature: _____________________________________

Date: ______________________________________________________

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