SAFETY PLANNING
Job Hazard Analysis
Prior to starting work each day on this project, each worker will participate in a Job Hazard Analysis (JHA) for their scope of work. The JHA must identify and outline each work component or activity, list the potential safety hazards, and provide safety controls, PPE, tools, and equipment that will be implemented and required to mitigate the recognized hazards and safely complete each activity.
SAFETY INSPECTIONS
Each subcontractor performing work will be responsible for conducting regular self-safety inspections of their work area, tools, and equipment in accordance with their safety program requirements. The following inspections will be required as applicable to ongoing work activities.
General Worksite Safety Inspections
Each subcontractor will perform a visual general safety inspection of their work area where their employees and subcontractors are working daily.
Daily Inspections
Subcontractors using the below equipment or performing the specific type of work will designate a competent person to inspect and document each day prior to use.
Scaffolds, trenches, cranes, forklifts, aerial lifts, material handling and hoisting equipment, rigging, ladders and hand and power tools.
Notes: All rigging equipment shall be inspected and certified by the hoisting employer competent person prior to use and at a minimum monthly.
Each subcontractor who requires their employees to wear personal fall arrest systems (PFAS) shall inspect harnesses and lanyards as required. Workers engaged in steel working activities shall inspect harnesses and lanyards daily. All others shall inspect harnesses and lanyards at a minimum monthly (or as required by manufacturer).
SAFETY TRAINING
Safety and health training are a requirement and mandatory for all employees and subcontractor workers assigned to this project.
Safety Orientation:
All workers who perform duties on this site shall complete the appropriate safety orientation training and will not be allowed to start work until they have attended. Safety orientations can be found at the following link:
Subcontractors: Subcontractor Safety Orientation www.iws.support/training
Employees: Safety Orientation and Annual Basic Safety Awareness Training: www.iws.support/training
Upon conclusion thereof, all personnel will receive a verification email with their test score and an outline of the training they completed.
GENERAL SAFETY GUIDING PRINCIPLES
Clean and safe working conditions are essential for achieving an Incident and Injury Free Environment. Everyone must demonstrate and maintain a strong personal desire to think and act safely.
The following Safety Guiding Principles will be used to guide all work activities on this site and to help foster a culture of ensuring that all workers go home safely to their families each day.
- Everyone is responsible for safety and health
- We look out for each other
- Safety is planned into every aspect of our work
- All injuries are preventable
- All recognized deficiencies will be resolved immediately
- We are all responsible for our own safety
- Everyone must complete their assigned training
- Working safely is a condition of employment
- We measure safety performance
- Every worker is responsible to stop at risk conditions
EMERGENCY ACTION PLAN
A site-specific emergency action plan (EAP) will be written and stored on the safety support center in the Emergencies tab. All employees and subcontractors have been trained on the EAP when they attended the respective safety orientation.
The EAP determines the proper access/egress of emergency equipment and/or personnel into or out of the site in case of emergency.
- Supervisors will direct responders to key locations on the site to assist in an emergency.
- Employees are expected to follow the direction of supervisors and cooperate in any emergency action effort.
- Personnel should evacuate the site in an orderly fashion if instructed to do so by supervisors.
- If you become aware of an emergency or an injury, notify a supervisor immediately.
Personnel are strictly forbidden to discuss project conditions, incidents, or emergencies with the media, press or any person not associated with the project.
FIRST AID POLICY
In the event an employee is injured on the job, first aid kits are available for the employee to treat their own injuries. First aid kits will be in the vicinity of the work area and contents of the kit inspected when brought on site. Subcontractor Foreman will notify project superintendent or his representative if employees use first aid items. In the event of a serious injury, 911 will be called.
No employee is required to treat another person’s wounds. However, in the event “Good Samaritan” assistance is rendered, the exposed employee and victim will be evaluated by a medical clinic or doctor for Blood Borne Pathogens exposure control within 24 hours. The exposed employee will receive general blood borne pathogen training pursuant to OSHA 1910.1030 requirements.
HEAT STRESS
Workers should consume adequate liquids and take necessary rest breaks to help prevent heat disorders. Water is recommended over carbonated beverages or sport drinks like Gatorade or Red Bull. More information is located in the Heat Illness Prevention procedure located at: https://iws.support/procedures-1
Heat Disorders and Health Effects
Heat stroke: Occurs when the body temperature rises to critical levels, Heat stroke is a medical emergency. Do not send worker home or leave them unattended.
Heat Exhaustion: Symptoms often are non-specific and may be sudden in onset. These symptoms often resemble a viral illness. It is caused by dehydration where a large loss of body fluid causes a slowing of the circulatory system.
Heat Cramps: Usually caused by performing hard physical labor in a hot environment. They are caused by an electrolyte imbalance or by too little or too much salt.
HAZARDOUS COMMUNICATION/SDS
All subcontractors will submit Safety Data Sheets (SDS) to Integrated Water Services using the SDS Request Form located at the following link: https://iws.support/safety-data-sheets.
Each subcontractor must adequately supervise employees under their direct supervision for proper training and proper precautions prior to the hazardous chemical’s introduction to the jobsite. The following information will assist in understanding OSHA Hazardous Communication requirements:
List of Hazardous Chemicals
IWS does maintain a master library of all hazardous chemicals used on all company locations in the SDS library. This library will be maintained at: https://iws.support/safety-data-sheets.
Safety Data Sheets (SDS’s)
Each subcontractor must provide SDSs for all chemicals they bring to the project site. The SDS/s must be submitted using the following electronic form located in the safety support center: https://iws.support/safety-data-sheets.
Each subcontractor will ensure all containers on the site have proper, up-to-date labels.
Training
Each subcontractor is responsible for the proper training of their employees.
FALL PROTECTION
All individuals will take all practical measures to eliminate, prevent, and control fall hazards. All work will be planned with the intent to eliminate identified and potential fall hazards. IWS fall prevention policy and OSHA 29 CFR 1926.500 Subpart M govern the requirements to protect workers exposed to falls. Additionally, Integrated Water Service’s fall prevention policy requires 100% fall protection when a worker is six (6) feet off the ground or six (6) feet above a lower level and unprotected by guardrails. The use of conventional fall protection systems (passive preferred) shall be utilized to protect workers from falls to lower levels. Workers wearing personal fall arrest systems shall not free fall more than six (6) feet without restraint.
Acceptable fall protection systems include the following conventional systems: guardrails, safety netting, floor and wall hole covers, positioning device systems, fall restraint systems, protection from falling objects and personal fall arrest systems.
Workers exposed to fall hazards shall be uniformly equipped, trained, and given periodic refresher training in fall protection at specific intervals to minimize the adverse effects of accidental falls. Fall protection training records will be maintained in a location so as to be readily available within 4 hours of a request from IWS.
Flat Roof fall protection program: Warning line systems:
There are times when a warning line is necessary. The roofers shall place the warning line as close as six (6) feet from the edge. For the other trades working on a roof the warning line must be 15 feet from the edge.
Anyone outside of the warning line system is required to wear personal fall protection.
General fall protection requirements:
Workers are not required to tie off on properly constructed scaffolds, elevated decks and elevated platforms that have proper perimeter guardrail systems. Personal fall arrest systems will be required if the perimeter guardrail system must be removed.
Any subcontractor that creates a floor hole or penetration larger than 2 inches will be responsible for protecting that opening and properly marking it with the words “HOLE-DO NOT REMOVE” or “COVER-DO NOT REMOVE” in languages that the workers speak most prevalently.
SCAFFOLDS AND AERIAL LIFTS
All subcontractors shall identify a Competent Person responsible for the erecting and dismantling of all scaffolds according to OSHA regulations (29 CFR 1926 subpart L- Scaffolds) and Codes of Safe Practice (Scaffold Industry Association). Records will be maintained for scaffold training and be available for review by any member of the Integrated Water Services team. The Competent person shall submit to Integrated Water Services Superintendent or his representative a fall protection plan for erecting and dismantling scaffolds.
Employees working on scaffolds 6 feet above a lower level shall be protected from falling by either a standard guardrail system or personal fall arrest system. Any use of a personal fall arrest system used on a scaffold shall be approved by a member of the Integrated Water Services team and the IWS safety manager. The subsequent specific scaffold requirements shall be followed:
- All scaffolds shall be erected under the supervision of a competent person and inspected daily. Scaffold tags or equivalent shall be used to document the inspection. Green Tags - Approved ready for use. Yellow Tags - Caution if restrictions are required. Red Tags – Scaffold unsafe do not use. Narrow span scaffolds (Baker scaffolds) are required to be inspected and tagged.
Aerial Lifts
- All subcontractors are required to ensure that their workers are properly trained in the use and operation of aerial lifts, including any manufacturer specific requirements and OSHA requirements of 29 CFR 1926 subpart L.
- Workers must wear their personal fall arrest system while working on any mobile elevated working platforms.
PERSONAL PROTECTIVE EQUIPMENT
All personal protective equipment (PPE) shall meet applicable standards of the American National Standards Institute (ANSI), American Society for Testing and Materials (ASTM) and properly used in accordance with the manufactures’ recommendations. Each employer shall furnish their employees approved PPE that fits to size and provide training in the selection, use and care of such, retraining to be performed as necessary. All workers must maintain their PPE in good sanitary condition, if defective or showing signs of excessive wear PPE must be replaced. All workers entering the jobsite will, as a minimum, wear the following personal protective equipment at all times in the designated work area while on this project (except in office and lunch areas).
Head Protection
An approved hard hat must always be worn.
Eye and Face Protection
- Safety glasses (Z87.1) with side shields must always be worn.
- Workers that wear prescription safety glasses may do one of the following:
- Obtain prescription safety glasses (Z87.1) with rigid side shields.
- Wear over- the- glass safety glasses.
In addition, the following eye/face equipment must be worn when performing the following work activities:
Arc welding |
Welding hood with proper shading* |
Burning |
Burning goggles with proper shading |
Grinding or cutting metals |
Face shield* |
Drilling (rock) |
Face shield* |
Chemical handling |
Face shield* |
Molten materials |
Face shield* |
Corrosive liquids |
Face shield* |
Concrete pouring |
Face shield* |
Note: * Safety glasses will be worn in conjunction with face shields and welding hoods.
Foot Protection
Hard soled safety boots/shoes without steel of the toes showing through must always be worn. Safety footwear must conform to ASTM F2412-05 & ASTM F-2413-05.
Work attire
- Shirt sleeves will have a minimum length of 4 inches. No shorts, tank tops, or cut-off shirts are permitted.
- All personnel shall wear reflective vests or high visibility clothing while in the designated work zone.
- Long pants that fit properly around the waist and of a proper length so as not to create a trip hazard
- Long hair must be contained so as not to create a hazard of getting caught.
Respiratory Protection
Site management teams are required to determine if hazards exist that require respiratory protection. If so, the PM or Superintendent must submit a Safety Support Ticket (SST) located at the safety support center in the Forms tab. Complete the SST with as much information as possible and then click Submit. The safety department will follow-up and provide safety support through the entire process to make sure your team is trained, prepared, and they have the right equipment and PPE. Respiratory protection would be required if OSHA permissible exposure limits are exceeded, and no means of engineering controls could be used. If there is any question as to whether respiratory protection is required, please call a member of the HSE team for assistance.
Use of Respirators
Prior to using respiratory protection to protect against an atmospheric hazard, the team must first consider any available and effective primary means of preventing or minimizing exposures by using source controls such as substitution, automation, enclosed systems, local exhaust ventilation or wet methods.
Hearing Protection
Approved hearing protection will be worn as specified in posted areas and while working with or around high-noise level producing machines, tools, or equipment. A good rule to follow is: When you must raise your voice to be heard, you need hearing protection. Exposure to impulsive or impact noise must not exceed 140dB noise level.
Hand Protection
Workers will wear an appropriate level of hand protection as necessary and as determined by the Competent Person to prevent hand and finger injuries.
Additional Protections
Specific activities may require that additional personal protective equipment be worn such as working on energized circuits. Site managers and their Competent Persons shall evaluate the need for additional protection based on their job Hazard Assessment.
Hand and Power Tools
All hand and power tools will be operated, kept in good condition, and regularly maintained per manufacturer’s recommendations. Workers working 6 feet or greater above a lower level while using handheld tools and or power tools that may be subject to dropping shall tether those tools or barricade the fall zone area to prevent the tool from hitting unsuspected workers below.
HOUSEKEEPING AND ORDERLINESS
All IWS projects shall always maintain their work locations in an orderly and clean manner. Daily and regular cleanup of work areas is mandatory for all trades on site. The first indicator of site management competency is determined by the housekeeping and orderliness of their site.
Integrated Water Services Cleanliness Standard
Dumpsters for general trash will be provided at project sites. Subcontractors shall provide trash containers on site for their general trash and debris. All miscellaneous trash generated by workers shall be deposited in a container or in the back of pickup trucks daily. Do not throw bottles, food wrappers, cups, construction waste, broken boards and pallets, or any other types of trash on the floor or ground. Subcontractors, as required by contract, will provide their own dumpsters or garbage receptacles for their specific waste materials, and allocate adequate resources to ensure this housekeeping standard is maintained throughout their time on the project. The project management team shall address this housekeeping standard with all subcontractors prior to beginning work.
General Housekeeping Requirements:
Housekeeping is an important part of our daily work. All materials, equipment, etc. brought on site shall be organized and stored in areas designated by the IWS project team. Trade partners are responsible for organizing material, equipment, and tools so they do not create tripping hazards or impede/block exits. Trade partners are responsible for the daily cleanup of excess material and debris which shall be deposited in appropriate containers throughout the day. When work is completed in a room or area all excess material and debris shall be removed and broom cleaned at the end of each day.
LADDER SAFETY
Integrated Water Services requires all portable ladders to be rated heavy duty Type 1, 1A, or 1AA. Type II or Type III Ladders (<225 Lbs.) and all types of aluminum ladders are prohibited. Job made ladders shall comply with ANSI A14.4 1979 and 2009 as well as OSHA 29 CFR 1926 Subpart X. Subcontractor Competent Person shall evaluate the use of personal fall protection systems while on ladders greater than 6 feet above the finished floor the ladder sits on.
Refer to manufacturer’s specifications for the proper use of all ladders.