Consigli Project # 1758
Emergency Response Plan
ALL EMERGENCIES SHOULD BE REPORTED BY CALLING 9-1-1
This Emergency Response Plan (E.R.P.) is specifically developed for Consigli Construction work associated with the Alexandria Real Estate Equities – project # 1758
The construction site is located at 161 First St Cambridge MA 02142. The location for the project field office will be in the 161 First St Cambridge MA 02142 location (in existing building) (notifications of any changes will be provided). If otherwise determined, the field office will become the Emergency Operations Center (EOC).
The following situations are considered emergency response actions and should be handled in accordance with the procedures outlined in this plan.
- Serious Injury/Fatalities
- Structural Damage/Collapse
- Weather or Geological Event Classified as an Act of God
- Environmental Incident
- Traffic Disruption
- Utility Damage
- Illegal Activity
- Labor Problems
- Bomb Threats/Military Ordinance Unearthing
- Acts of Terrorism
When reporting an emergency, please provide the following:
• Your location, phone number, and name;
• The location of the incident (building name, floor and room number);
• Nature and extent of the incident (injury, accident, spill, smoke/fire, damage, etc.);
• The safest route to the incident
Crisis Response Protocol:
- Attend to the injured
- Immediately contact Dan Della-Giustina (508) 686-6008
- Post person at front gate, only allow access to emergency responders
- Record names/addresses of witnesses
- Do not allow media on site
- Refer all media inquiries to home office (See “Crisis Response Cards”)
A Consigli designated individual shall wait at the Langdell Hall site entrance to escort Emergency Services personnel as they arrive.
The following is a list of the Chain of Command/Call Hierarchy on the project for establishing lines of succession during communication involving all emergencies.
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Emergency Contact Names and Numbers
1. First call: 911 Fire or Police
2. CCC Superintendent: AJ Boucher (508)902-7359
3. CCC General Superintendent: Gabe Mater (774)573-4892
4. CCC Project Manager: Paul Ryan (857)295-5044
5. CCC PX: Ryan Jennette (508)328-2279
6. CCC Project Safety: Dan Della-Giustina Jr. (774)462-1481
7. Corporate Safety: Bryan Kingsbury (508)808-9359
Dig Safe 811
National Grid-electric (508)897-5500
NSTAR Gas Co. (800)592-2000
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MA General or Boston Medical. This level injury will require transport my EMS ambulatory travel.
Typical Clinic or Injury Facility
Directions to Occ. Med. Consulting
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Site Safety Plan
Project Specific Loss Exposures and Controls
Scope of Proposed Operations: Alexandria Real Estate is proposing to restore the historic 161 First St Building. This will include a masonry restoration of the exterior design. This will include energy efficient windows as well as a repointing to the brick façade.
The interior brick will be preserved, and the building will maintain an open timber design. The building was formally used as a factory in 1907. A hazardous materials report has been written to identify hazardous building materials such as asbestos or lead. There are also trace amounts of TCE found in the basement soils. All building materials will be tested by an Industrial Hygienist and the report generated will be considered during the planning phases of demolition. Demolition and product removal will be done in accordance with all the AHJ laws and regulations.
New features to the roof will also be added. Such as a roof deck, new mechanical units and an aesthetic redesign. To accommodate safe access and maintain compliance with fire code the elevator will extend past the roof top and an egress stair will be added.
The above drawing highlights the mechaincal units that will be added to the roof.
The project will begin with exterior masonry. Hazards will include working on an industrial aerial work platform which will be an large industrial scissor lift. Silica controls will also be used when removing the existing mortar from between the brick. After masonry work is complete windows will be added.
Interior demolition and abatement will last for roughly 1 month. Demolition and material removal will include drywall, patricians and equipment from the previous lab space.
Interior redesign will accommodate a new office space that is currently under design.
Adjacent Properties: 161 First St sits on the corner of First and Binney at a very busy intersection. Pedestrian sidewalks will remain open directly out front of the building. It is expected that employees from the project will not interact with adjacent properties or pedestrians in any way. Should an employee be approached by non-project personnel Consigli should be notified immediately.
All egress and travel paths to either building are to remain open and unimpeded at all times. Any challenge with coordination shall be brought to Consigli’s attention.
PURPOSE: The purpose of this Site-Specific Safety and Health Program is to illustrate Consigli’s approach to identifying project specific hazards and controls and how said risk is managed through a comprehensive Safety and Health Program.
S.A.F.E.: Staying Accident Free Every Day is the Safety Mission that forms the very foundation of the Consigli Safety Culture. The S.A.F.E. mission, which is supported by technology, (Predictive Solutions internal auditing instrument which identifies and defines leading indicator related information); Leadership (Empowering our team members to assure safe projects); Humanization (Protect the ones you love by protecting yourself); Jobsite Gym (Morning warm-ups, stretch and flex); Training (Integrating sub-contractors into the Consigli Safety Culture); and Lean (nothing hit the ground), is the driving force behind Consigli’ s drive to our vision – ZERO. ZERO is the philosophy that all accidents are preventable, and that no accident is acceptable. The S.A.F.E. mission is the guiding force to achieving the Consigli Safety Vision which is ZERO.
Identify the specific route in and out of the construction site (Traffic Management): For this project all deliveries and waste removal shall enter using the designated entrance which may be subject to change and be coordinated with the Consigli Superintendent, Jeff Costa. Also only permitted truck routes will be used, all contractors will be responsible for adhering to truck routes and restrictions plan which will be made available to all sub-contractors. Because of Site Work and Parking lot construction coordination with Jeff will be crucial.
Personnel Protective Equipment (PPE): All workers will wear hard hats and safety glasses at all times. High visibility vest will be worn when exposed to vehicular/equipment hazards/ traffic. All personnel performing work with their hands shall be required to wear gloves that are appropriate to the task. When not performing actual work with their hands workers will be required to have them available for immediate use… Face shields will be required for all personnel who are performing overhead work, using metal chop saw or any type of metal grinding. All welders will be required to have hard hats with integral welding shields.
Designated work hours (any work outside these hours must have prior CCC approval): All material host related work shall take place during regular business hours of, Monday – Friday 7:00am to 3:30pm. Any work which may need to take place outside of these hours will need to be approved by the CCC Superintendent. All deliveries must be coordinated with the CCC superintendent, at least 48 hours’ notice.
Evacuation Plan (RACE, and Routes of Egress): Please refer to the Evacuation Plans below. All Consigli employees shall attend the Project Safety Orientation. Consigli Construction’s Job Safety Manager will conduct a safety orientation talk to each employee and subcontractor to site specific fire safety protocols.
Emergency Management Response: In the event of an Emergency the construction workers shall leave the building immediately. Point of assembly/muster shall be as defined in the attached Evacuation plan. In the event of a disaster, the Superintendent or Safety director shall instruct the construction workers to leave the site or remain in place and await further instruction.
When reporting an emergency, please provide the following: This information will be outlined to employees during the orientation process. See next page.
• Your location (161 First St Cambridge, MA) phone number, and name: First St Park
• The location of the incident (building, floor and room number);
• Nature and extent of the incident (injury, accident, spill, smoke/fire, damage, etc.);
• The name and amount of the material spilled (if applicable); and
• The safest route to the spill (if applicable).
** Please review chapter 8 for additional details.
Pre-task Plans: Pre-task Plans or Job Safety Analyses shall be conducted prior to all and any operation. Said plan to be reviewed initially with all involved personnel performing that particular task, signed by all workers, including their supervisor, and filed on site.
Activity Hazard Analysis (AHA): An AHA, depending on level of hazard, shall be conducted for each identifiable feature of work to be performed. The AHA shall be submitted to Consigli superintendent for review. AHA’s shall be reviewed with all personnel weekly and shall be signed by all involved personnel performing that particular task, including their supervisor.
Excavations: All required permitting will be obtained before any excavating is to begin. If necessary, tabulated data/engineering for shoring and shielding systems will be obtained and available on site always when said systems are in use. All excavations will be inspected by a competent person daily. Written excavation inspections will be done if the excavation exceeds 5’.
- Dig Safe Notification – dig safe number will be obtained and posted in the site office.
- Jackie’s Law (520CMR 14.00) will be strictly adhered to and permits must be obtained. A copy will be posted in construction office.
- Copies of shoring engineering and tabulated data sheets for all trench boxes or other shoring/shielding systems brought on site will be provided to CCC and be kept in construction office.
**Review Chapter 19 for more detail**
Demolition: Prior to the start of demo operations, the contractor preforming demo will confirm that all utilities leading into the area have been made safe. The electrician will disconnect and lock out all electrical, the plumber will do the same with any plumbing lines, and the HVAC subcontractor will do the same on the HVAC piping and duct work. Lock out tag out will be reviewed during the pre-construction safety meetings to assure disconnect and responsibility for protection of existing utilities is safe for any construction activities to commence. In spaces where some electrical or mechanical must remain live, a color coding system will be utilized for easy identification of live utilities that must stay active and utilities that must be removed. Any and all utilities spray painted Red are not to be touched and are need to be protected during all operations. Utilities spray painted Green are to be removed as part of the selective demolition process only after lock-out/tag-out has been confirmed and utilities tested. If any utilities are unmarked, they shall be considered live. The demo contractor will be responsible for completing CCC demo checklist prior to the start of any work in their target areas
Fall Protection: All workers exposed to a fall of 6′ or greater shall be protected by guardrails, safety nets, or personnel fall arrest systems. This includes, but is not limited to, steel erection, roofing, scaffold erection and dismantling, overhand brick laying and pre-cast concrete related work. Holes greater than 2” will be covered with acceptable material (3/4 plywood ½ steel) which will be secured and marked hole (cover must be able to withstand two times the intended load). Covers will stay in place until the hole/penetration has been filled. Building perimeters will be protected with some form of fall protection if fall is greater them 6 feet. Cable guard rail systems (if used) will be provided with turnbuckles installed for all straight runs and any straight run over 100 feet in length. Holes greater than 2” will be covered with acceptable material (3/4 plywood ½ steel) which will be secured and marked hole. Covers will stay in place until the hole/penetration has been filled. At no time are cross braces on scaffold allowed to be used as fall protection. The use of safety Monitors is prohibited.
**Review Chapter 13 for more detail**
Work on Ladders: All work on step ladders/straight ladders will be done correctly per manufacturer’s recommendations. Any worker who is on a step/straight ladder shall maintain 3 points of contact at all times or will be required to tie off. Step ladders will not be used as a form of access to a walking /working level, also all straight ladders will be tied of when installed for use. Only ladders with a rating Type 1A or 1AA will be allowed on Consigli projects.
Roof Work: Before any work is to begin on the roof it must be determined what method of fall protection will be implemented. Use of “safety monitors” is not allowed. The roof will be made water tight by the end of each shift.
Scaffold and Elevated Work Platforms/Material Hoists: All scaffolding and material hoists shall be inspected daily, by a competent person – designated by each contractor – before each shift. Said inspection shall be documented on installed scaffold tags. Said Scaffold Inspection Tags shall be located at the stair tower/access point to each section. A scaffold inspection guide will be provided to each designated persons (upon request) by Consigli Construction to aid them with their inspection. All contractors erecting or dismantling scaffolding shall provide CCC with certification/qualification of scaffold erection training as well as an erection/dismantling plan. Fall protection is required at all times during erection/dismantling operations. Overhead protection will be provided for all access points to any buildings located under any form of scaffolding/material hoist.
Aerial Lifts/Scissor lifts: Area and ground conditions in the intended work area will be inspected for overhead power lines and underground structures. Aerial lift platforms and scissor lifts shall be inspected daily before each shift by a competent person designated by the contractor using it. Inspection shall be documented on Inspection tags for each machine in use. Completed inspection tags shall be filed in the site office. All contractor employees performing work from an aerial lift shall exhibit documented proof of training. Steel plates or equipment mats will be placed on the ground above any utility/ steam tunnel/underground vault if there will be Aerial lifts operating on them. Workers shall be tied off at all times when using an aerial lift!!
Haz Com/Global Harmonization: All contractors bringing materials/chemicals on site shall provide Safety Data Sheets to the Consigli project team.
- SDS sheets shall be kept on file in Consigli Construction’s project office
- All SDS sheets shall be readily accessible.
Fire Protection: Code Red Consultants have prepared a Construction Fire Safety Program for the project (attached as addendum) in compliance with NFPA 241 and 527 CMR. Said plan has been submitted to the Cambridge Fire and Building Dept. In the program, Erik Johnson, has been designated as the Fire Protection Program Manager. The plan addresses equipment with internal combustion engines, combustible material storage, hot work, fire watch protocol, flammable storage, and fire protection during construction, to include an impairment plan for fire protection systems during construction.
In addition to the Code Red plan, Consigli will look to enforce it own hot work permit program, which will be implemented for all hot work to be conducted on the project on a daily basis.
**Review Chapter 17 for more details**
Electrical: The electrician will be responsible for all temp power and any temp lighting that may be needed. They will coordinate all lock out tag out procedures regarding electricity during the “make safe” operation prior to demo. There are no overhead power lines in any of the intended work areas. All electrical tools, cords and equipment must be in good working order. To that end, all electrical tools and components must be visually checked on a daily basis. Any tools with damaged cords or damaged cords must be taken out service immediately. All cords must be equipped with a ground pin. Flat three wire cords are not allowed. Only SJO and SJT, or other similarly rated cords, shall be used. Cords must be 12 gauge or better. The electrician shall be responsible for all temp power and any general temp lighting that may be needed. Subcontractors will be responsible for task lighting in the event that lighting above the OSHA standard is required for a particular work task. The electrician will coordinate all lock out tag out procedures. All temporary power for the project will be installed on protected and dedicated circuits with 100% GFCI protection. GFCI will be tested by the electric contractor to assure proper function with a log book filed with CCC monthly. No live electrical work shall be conducted
Cranes: Cranes will be used in a number of operations; structural steel erection, RTU installations, etc. All subcontractors will be required to submit comprehensive pick plans prior to use. Location and set up will be reviewed with crane operator prior to set up and pick. All lifting operations will require that the operator and any involved contractors follow the steps listed below as well as in CCC Crane Safety policy
1. All Hoisting equipment will have an up to date 3rd party inspection certificate with the equipment which will be copied and filed in the office trailer.
2. All lattice boom cranes will have an independent 3rd party inspection completed each time one is set up on the project.
3. All workers working with the crane shall have all appropriate signalmen/rigging qualifications.
3. All equipment operators will be required to have in their possession all appropriate licensing and training as required by OSHA and the State of Mass.
4. NCCO certification will be required for all crane operators who will be operated on site for 5 or more continuous days.
5. All underground vaults and existing utilities will be marked before any excavation can begin as well as before any crane is set up.
6. Cribbing for outriggers shall be at minimum 3X the area width of outrigger floater. (Cranes only)
Confined Space: A written plan will be needed to work in any tanks/vaults and crawl spaces designated as permit required confined spaces by CCC. Said plan shall include air monitoring.
** Please review chapter 21 for additional details**
Designated First Aid Plan: Consigli Construction shall follow Site Safety Plan for first Aid. A list of first aid/CPR trained people shall be posted on site. Report any incidents to the Safety Director.
Lean Requirements: No materials shall be delivered to the site earlier than 3 days before said materials are to be installed/put into place. If materials have to be delivered before that 3 day time period, subcontractor shall get prior approval from Consigli Superintendent. Because of this, notification / scheduling is required for all deliveries to the site. Subcontractors must notify Contractor at least 24 hours in advance. Contractor has the right to refuse any deliveries not properly scheduled or due to logistical constraints as necessary. All subcontractors delivered materials shall be placed on wheeled carts, wheeled racks or in wheeled bins so as to necessitate easy relocation in the event materials need to be moved. Carts, racks, or dollies shall not exceed manufacturers intended weight loads. Materials/tools can be delivered and stored on pallets only if pallet jacks are delivered simultaneously with said delivery to provide for ready mobility. Additionally, pallet jacks need to remain in immediate area. Each subcontractor will need to supply their own pallet jacks for their own materials and keep their pallet jack within reasonable distance at all times. All work stations shall be provided with wheeled trash bins for immediate placement of all debris produced as a part of the subcontractor’s operations.
All trash will be immediately placed in wheeled containers provided by Consigli. All subcontractors shall use rubber wheeled carts when moving material or removing trash from a building. . No trash or materials shall be left on the floor. Subcontractors shall, where feasible, elevate all electrical extension cords, hoses, or cables – removing them from all walking/working surfaces. Electrical Cords, when elevated shall be supported or suspended in a manner that does not subject them to damage. Storage of delivered materials in cardboard containers shall be discouraged. When materials must stay in cardboard containers, said containers shall be removed from the projects immediately after product is unpacked.
Subcontractor will participate in schedule development meetings as required by Consigli
Restricted Areas: Contractors are prohibited from entering adjacent occupied areas unless work has been previously authorized and scheduled. Only designated workers will be allowed into the occupied areas. No exceptions.
Steel Erection: Iron workers will be required to use fall protection at 6′. Consigli will release documentation when column footings reach 75% of breaking strength. The steel erection sub will be required to submit a detailed erection sequencing plan that illustrates crane locations and capacity of cranes at those locations. Decks will only be turned over for general use after they have undergone an inspection by a member of the CCC safety department.
The steel erection sub will be required to submit a detailed erection sequencing plan that illustrates crane locations and capacity of cranes at those locations. Fall protection will be determined for connectors after pre-construction meeting with sub is held. Fall protection will be required at 6’, at all times during steel erection
Once decking is complete and all required fall protection is installed, CCC will walk the area with the steel erection subcontractor. Provided all required elements of fall protection are in place, CCC will complete and give a copy of the “custody of fall protection” form to the steel erection subcontractor. Maintenance and overall responsibility of the fall protection system in place will fall to CCC at that point in time.
Materials Management: Getting materials into and out of the project will be a challenge that needs to be adequately planned. All deliveries are to be scheduled with the CCC Superintendent. A comprehensive Activity Hazard Analysis shall be done on all materials that will be hoisted and placed into or on the building. Only materials which will be used/installed in a reasonable amount of time will be delivered to the site. Attention must be paid to structural analysis in regards to loading of existing floors with material and equipment.
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Environmental Emergency Contact and Management Response
Environmental Issues: A hazardous material report has been created for the project by the company listed above. This report will be on site at all times and available for review at any time.
A copy of the hazardous material report will be made available on site upon request. Due to various pre-existing conditions of the lot trace amounts of lead cells have been identified. A further comprehensive analysis is being performed on relevant hazards the work force may be exposed to.
Mercury: All fluorescent lamps/thermostats are presumed to contain mercury vapor, which is a hazardous substance. Mercury-containing lamps associated with fluorescent light fixtures in areas designated to be renovated will be treated accordingly. All florescent bulbs removed during renovation will be collected, stored properly on site and giving to Stoughton High School so as to be recycled or disposed of properly.
Freon/Glycol: All Freon/Glycol materials will be removed from equipment and stored per manufacturer’s recommendations before it is disturbed. All workers who will be working with the above mentioned materials must provide CCC with certifications or qualifications. If not re-used, a disposal manifest will be provided to CCC.
Silica: Any activity which can produce silica dust will use engineering controls to keep dust to a minimum. There will be no dry cutting of any masonry material allowed; if water can not be used then a dustless vacuum system consisting of a HEPA dustless vacuum system shall be used. An exposure assessment shall be required of any worker involved initially in grinding, demoing or cutting masonry so as to establish the silica exposure level. No respirators will be issued without the express consent of the Consigli Safety department. Nuisance mask like an N95, if used, will be on a voluntary basis and at no time will these types of mask be issued to the workers.
Mold: Mold issues are not anticipated to be prevalent on this project, however if mold is discovered Consigli’s mold remediation policy will be implemented and followed.
Noise: Noise exposure will also be a concern so all deliveries must be coordinated with CCC Superintendent to limit their impact on the surrounding areas. Normal working hours will be between 7am and 3:30pm; any contractor who may need to work late must first seek approval from the CCC Superintendent. Interior work will take place between 7pm -3am. Noise levels will be monitored if high levels of noise are found to exist or could be expected to assure that noise levels do not exceed acceptable OSHA levels. Consigli permissible noise policy and procedures will be followed
Equipment issues: All operators will be required to have in their possession all appropriate licensing and training as required by OSHA and the State of Mass. All safety devices and warning alarms must be in good working order and all leaks are to be repaired immediately. All equipment will be used in accordance with the manufacturer’s recommendations for safe usage and have its operators manual as well as an extinguisher with it at all times.
Exposure to the Visitor: During the first phase of construction sidewalks and road ways will be active. Any means of exposure from any form of overhead hazard from the building which finds itself under any type of work will be provided with overhead protection. An emergency egress route through the job site will be established and maintained during construction. At no time is any worker allowed to enter any area in which they are not working.
Utility Exposures All utilities entering the site will be cut and prior to the start of demolition. There are no overhead power line hazards. Written notification of this work will be provided to CCC prior to commencement of Demolition work.
Planning: The project team as well as CCC safety department will meet with each subcontractor, before they start to review their Site Specific Safety and Health Program and all project specific Job Hazard Analyses. The project team shall be an integrated mix of owner, architect, engineer and Consigli Construction personnel. If, after reviewing programs and meeting with the individual subcontractor, the team is satisfied with the risk control direction, they will be permitted to begin work.
Prior to stat of any work, all personnel involved in the project, including project managers must be:
- Trained and orientated by Consigli Construction. Stickers will be issued and displayed on hard hats
2. All workers will provide Consigli with an OSHA 10 card.
3. All project workers shall participate in mandatory drug screening.
4. A safety Committee will need to be formed and shall meet monthly minimally
5. Principles Council’s meeting dates will need to be established and communicated to all subcontractor’s Principles. Said meetings shall be scheduled quarterly.
6. Consigli shall designate a full-time safety manager to manage safety and the CCIP and said safety manager shall have no alternate duties.
All emergency telephone numbers will be posted in the superintendent’s office.
EXHIBIT “J” TO
CONSIGLI CONSTRUCTION CO., INC.
MASTER SUBCONTRACT AGREEMENT
CONTRACTOR CONTROLLED INSURANCE PROGRAM
- 100% Six Foot Fall Protection. Contractor has adopted a 100% Six Foot Fall Protection policy on this Project. All work over six feet in height will have a fall protection system in place. Instances where fall protection may create an unsafe condition will be dealt with on a case-by-case basis. Subcontractors shall include in the scope of their work compliance with 100% Six Foot Fall Protection standards for all work activities as detailed in Contractor’s Site Specific Safety Manual, which is incorporated by reference in this Subcontract.
- Drug Testing. Prior to being allowed on site, all on-site employees of any Subcontractor shall fulfill the requirements of the Consigli Construction substance abuse testing program, which is subject to modification only to meet the requirements of a collective bargaining agreement to which any Subcontractor may be a party, in which case substance abuse testing will be conducted to the fullest extent allowed by such collective bargaining agreement. All Subcontractors shall be responsible for the costs associated with the drug testing of their employees. Should a drug test result in an inconclusive finding, the Subcontractor will be responsible for any alleged wage loss or cost associated with the employee’s down time.
- Jobsite Gym-Daily warm-up program. Contractor has adopted a morning stretch warm-up program on this project. All project personnel are required to participate in Consigli’s “Jobsite Gym” warm-up/stretch program.
- Return to Work Program. As required by the CCIP, Enrolled Subcontractors shall implement a “Return To Work” (RTW) program to assist workers who are temporarily disabled due to an injury or illness. The RTW Program will provide a modified or alternate duty position for an employee who has sustained a work-related injury or illness and is medically unable to perform all or any part of his / her normal duties during all or any part of the normal workday or shift, but who can perform some type of work. Subcontractor shall coordinate with Contractor to insure that injured or ill employees are treated by an authorized or cooperating medical treatment facility. The authorized or cooperating medical facility shall be utilized for initial treatment and evaluation of all injured employees. Follow-up care will be provided in accordance with applicable Workers’ Compensation laws. In the event of an injury or illness for a work-related illness or injury, the affected party shall be taken to the authorized or cooperating medical facility for examination and/or treatment. If the doctor determines that the employee qualifies for return to work on an alternate or modified duty basis, the doctor will complete appropriate forms indicating the restrictions and conditions for transitional work. The Subcontractor shall provide alternate or modified work until the employee is able to resume regular duties. All alternate or modified work is temporary in nature and is designed to facilitate a return to regular duties as soon as possible. In no case shall an injured employee be laid-off or terminated from an alternative or modified work position, unless first discussed with Contractor or the OCIP Administrator. Subcontractor shall participate as requested in claims review meetings related to workers receiving Workers Compensation benefits. Failure to provide reasonable accommodations will result in a liquidated damages assessment of $500 per day until the injured worker is returned to work. Contractor and the CCIP administrator shall determine reasonable accommodations.
- Activity Hazard Analysis (“AHA”). Before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or sub-subcontractor is to perform the work, the Subcontractor performing that work activity shall prepare an AHA using the AHA Form attached as Exhibit J-1. In addition, all operations, materials and equipment shall be evaluated to determine the presence of hazardous environments or if hazardous or toxic agents could be released into the work environment.
a. AHA shall define the activities being performed and identify the work sequences, the specific anticipated hazards, site conditions, equipment, materials and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk.
b. Work shall not begin until the AHA for the work activity has been accepted by the Contractor and discussed with all engaged in the activity, including the other subcontractor(s).
c. The names of the Competent/Qualified Person(s) required for a particular activity (for example, excavations, scaffolding, fall protection, other activities as specified by OSHA and this manual) shall be identified and included in the AHA. Proof of their competency/qualification shall be submitted to the Contractor for acceptance prior to the start of that work activity.
d. The AHA shall be reviewed and modified as necessary to address changing site conditions, operations or change of competent/qualified person(s).
(1) If more than one Competent/Qualified Person is used on the AHA activity, a list of names shall be submitted as an attachment to the AHA. Those listed must be Competent/Qualified for the type of work involved in the AHA and familiar with current site safety issues.
(2) If a new Competent/Qualified Person (not on the original list) is added, the list shall be updated (an administrative action not requiring an updated AHA). The new person shall acknowledge in writing that he or she has reviewed the AHA and is familiar with current site safety issues.
1.21 Designated Safety Representative. Subcontractor shall designate an onsite safety representative to participate in the project safety committee, which will meet on a periodic basis. This representative shall have authority to take action on any safety-related issues that are concluded by the committee.
1.22 Dedicated On-Site Safety Staff. Any time that a Subcontractor (either by itself or in conjunction with a sub-subcontractor) has a headcount of thirty (30) or more workers on-site, a dedicated, full time, safety manager shall be employed by the Subcontractor (or its sub-subcontractor) and shall be on-site full time. Should a Subcontractor (either by itself or in conjunction with a sub-subcontractor) reach a headcount of one hundred (100) or more workers on site, a second dedicated, full time, safety manager will be employed by the Subcontractor (or its sub-subcontractor) and shall be on-site full time.
1.23 Weekly Safety Inspection. Subcontractor’s designated safety representative shall conduct a weekly safety inspection, to include all of the Subcontractor’s work areas. Documentation confirming completion of such inspections shall be forwarded within 24 hours to the Contractor’s Site Safety Manager and/or Project Superintendent.
1.24 Personal Protective Equipment.
Hard Hats. All Subcontractor personnel on site shall wear hard hats at all times per ANSI Z89.1.
Gloves. All Subcontractor personnel performing work with their hands shall be required to wear gloves that are appropriate to the task. When not performing actual work with their hands, employees will be required to have gloves available for immediate use.
Footwear/Clothing. All Subcontractor personnel on site shall wear sturdy work boots and appropriate clothing (shirts with sleeves and long pants) at all times.
Protective Eyewear. All Subcontractor personnel on site shall wear 100% eye protection per ANSI Z87.1.
Hearing Protection. All Subcontractor personnel on site shall use appropriate hearing protection in areas where noise levels exceed 90 DBA, where exposure to 85-90 DBA exceeds eight (8) hours per day, or where posted.
Respirators. All Subcontractor personnel on site must wear personal respiration equipment when required per OSHA standards.
1.25 OSHA 30 Hour Training. All of Subcontractor’s foremen/supervisory personnel shall have, at a minimum, an OSHA 30 Hour Construction Safety Outreach training certification and shall exhibit documentation of training.
1.26 OSHA 10 Hour Training. All of Subcontractor’s workers shall have, at a minimum, an OSHA 10 Hour Construction Safety training certification and shall exhibit documentation of training.
1.27 Incident Reporting. Subcontractor or any sub-subcontractor must report all injuries, occupational-related illnesses or property damage to Contractor’s Site Safety Manager and Superintendent immediately. Subcontractor shall instruct its personnel to report, in writing, within 24 hours of all Accidents and Occurrences (as defined in the Insurance Manual) of any type to Contractor’s Site Safety Manager and Superintendent. Subcontractor and any responsible sub-subcontractor shall be assessed liquidated damages of $2,500 for the submission of a late Accident or Occurrence report or the failure to file a report.
1.28 Additional Safety Requirements. Should a subcontractor have an Experience Modification Rating (MOD) of 1.20 or greater, the following will be required:
A full-time dedicated Safety Representative with no alternate duties will be required on site at all times.
Subcontractor is to develop a written (2) Week Safety Look Ahead to be conducted by the subcontractor supervisor or designated safety representative. The developed safety look ahead shall list all major work activities for the subcontractor’s scope of work for that 2 week time frame.
A written “Activity Hazard Analysis/Pre-task Plan” that identifies hazards and control measures for each of the major activities listed shall be developed. (This shall be submitted to Consigli Superintendent and Safety Manager before starting work on site).
The subcontractor supervisor or designated safety representative shall conduct daily “Pre Task Planning Sessions” with the field crew. The written Activity Hazard Analysis/Pre-task Plan shall be signed by the crew members after the review is completed.
All Safety Responsibilities shall be assigned to an onsite supervisor or designated safety representative for the purpose of:
a. Conducting a daily documented safety inspection
b. Assigning corrective measures taken, to dedicated subcontractor personnel.
1.29 3rd Party Safety Inspections for Subcontractors with Experience Modification Ratings (MOD) between 1.01 to 1.19: It is mutually understood and agreed that this Subcontractor currently has a lower than acceptable Consigli safety rating and/or experience modification rating (MOD). Therefore, in order to heighten and monitor the safety of the Subcontractor’s personnel while on site, the Subcontractor shall be required to hire a third party safety consultant to make bi-monthly visits to the project site. This consultant shall be required to report to the Subcontractor and Contractor in writing after these periodic reviews are conducted. Any apparent safety deficiencies shall be addressed by the Subcontractor within 24 hours of the finding. All cost associated with accommodating this requirement, has been included in the Subcontract price. Reports are due into Consigli Construction Site Superintendent within 24 hours of site visit.
Substance Abuse Testing Program
Consigli Construction Company Inc. (CCCI), and all subcontractors (“Parties”) to the CCCI Contractor Controlled Insurance Program(CCIP) for the construction project will participate in a Drug-Free Workplace Program, (the “Program”) which states that the use of illegal drugs or the abuse of alcohol, prescription or controlled substances on or off duty by persons working on/employed, or seeking employment, on this CCCI project, is inconsistent with a safe, healthy and productive work environment.
This Substance Abuse Program (“the Program”) is established by CCCI in response to the directive as recited above and supersedes any pre-existing ·programs.
CCCI project managers on the project covered by the CCIP will require that this Program be applied to all Contractor-employed personnel working on the project site and to all applicants for such positions.
The intention of this Program is to establish the project as a drug and alcohol free workplace with due regard for the personal privacy interests of project employees. It is not the intention of CCCI project managers to intrude on off-duty activities of project employees away from the project site, unless those activities have a job-related impact. The circumstances permitting alcohol and drug testing on the project have been carefully defined. The CCCI project managers will retain oversight over the Program and will monitor test procedures for consistency and policy compliance.
The Parties acknowledge and agree on the importance of appropriate education, assistance, and treatment for all employees to combat the potential or actual influence of illegal/controlled drugs and alcohol. The Parties therefore encourage the utilization of the educational, assistance and treatment programs which have been established by Unions and/or Contractors as an important component of the overall Substance Abuse Program on Project sites.
The CCCI Construction Substance Abuse Program establishes minimum standards of testing on a consistent, standardized basis for the safety, productivity and economy of all parties and personnel working on this project. · The Program will apply to all project workers, employees and applicants for employment on this covered project site and to all project Contractors at all tiers. The Construction Manager CCCI will regularly review with all Parties concerned the effective implementation and enforcement of the Program, and will require appropriate action by any and all Parties who are not fully committed to and involved in the application of the Program.
This Program shall be subordinate to the Department of Transportation Regulations or any other federal or state drug testing mandates which shall prevail and apply only to those classes of employees and applicants subject to the mandatory drug test regulations currently in effect, as amended or established in the future by the Federal Highway Administration, the U.S. Coast Guard, the Research and Special Programs Administrative of the Department of Transportation or any other federal or state agency with appropriate jurisdiction.
I. PROJECT WORKERS/JOB APPLICANTS
1. Prior to commencing work, all project workers, and job applicants for positions on the project will be required to satisfactorily complete a drug test, unless such applicant provides acceptable documentation that he/she has tested drug free within the preceding six months by a NIDA/SAMSHA certified laboratory. Specimens will be collected during in-processing on the Project site or at a designated off-site location and tests will be conducted in accordance with Section III, herein and the Project Substance Abuse Prevention Program Implementation Procedure. Applicants who report to the in-processing site who display reasonable cause to suspect they may be impaired by alcohol may be subject to alcohol testing as set forth in Section III.
2. If the point of collection (POC) test results are inconclusive, the applicant will not be permitted access to the Project site, until test results have been verified in accordance with Section III-2. If the POC test results are proven negative, the employee will be paid for orientation time as described below and will be paid straight time hours for the missed work on the project, provided the employee is not referred to or is not engaged on an alternate work assignment while test results are pending. If the applicant tests positive, he or she will be barred from this project. However, such applicants shall be paid two hours of straight time for participating in the orientation program. If participation in the orientation program requires more than two hours of the applicant’s time, such applicant shall be paid a maximum of four hours of straight time. There shall be no pyramiding of orientation time and missed work payments under this section.
3. Any applicant or conditional employee barred from this project under Section I-2 may be considered for reemployment on this project provided the employee satisfactorily completes a drug test conducted by a NIDA/SAMSHA certified laboratory or an approved drug rehabilitation program at the employee’s expense not less than sixty days following the initial disqualification. Upon the successful completion of such a program, the applicant will be eligible for project employment providing, as a condition of continuing employment, the employee voluntarily agrees in writing to submit to substance testing, at the project manager’s request, for a period of six months.
4. Refusal on the part of any applicant to comply with the testing procedure will disqualify the applicant from consideration for employment on this CCIP until such time as the applicant certifies, in writing, a willingness to comply with this Program
II. ACTIVE EMPLOYEES
1. Disciplinary Rules: This project does recognize that employees have a right to privacy and that any adverse action taken against an employee for off-duty conduct shall take into account the employee’s right to privacy and the impact of the employee’s conduct on his/her job performance and job site safety. The project’s disciplinary rules for drug related conduct will be as follows:
- Possession of illegal drugs on the job or in a job status – Permanent bar from the project.
- Use of illegal drugs on the job or in a job status – Permanent bar from the project
- Selling, aiding and abetting the sale or conspiring to sell illegal drugs or prescription drugs on the job or conviction for such activity off the job -Permanent bar from the project
- Bodily system presence of illegal drugs or alcohol on testing at a limit specified herein on the job -Immediate bar from the project. The employee may be considered for reemployment on the project after sixty days and certification as drug or alcohol-free as confirmed by a NIDA/SAMSHA licensed laboratory or an approved drug rehabilitation program, provided that as a condition for reemployment on the project the employee agrees to be subject to testing at the request of the project’s project manager for a period of up to six months. Any second offense involving an on-the-job bodily system presence of illegal drugs or alcohol will result in a permanent bar from employment on the project.
- Possession, use or bodily system presence of prescription drugs without a valid prescription or alcohol on the job may result in a temporary or permanent project bar. The severity of the sanction will be determined on a case-by-case basis following investigation concerning the use of the drug. It is the intent of the project that recreational use or abuse of prescription drugs will be treated the same as use of illegal drugs.
- These disciplinary rules supplement and do not supersede other rules and regulations duly promulgated by any contractor. In no event shall the application of these rules or the use of illegal drugs or alcohol be construed as a defense to other employment related discipline.
2. Testing: Employees will be subject to drug and alcohol testing only under the following circumstances:
- Pre-Placement / Pre-Employment.
- Post-Accident: Any employee who is directly involved in an accident on the job site or in the course of job duties which involves use of vehicular equipment, heavy equipment, power tools or other dangerous instrumentality or working conditions and which results in a need for off site medical care or substantial property damage (generally in excess of $1000) shall be referred for a substance test. A substance test will not be required if the project safety manager, representative in consultation with others, determines that the employee did not contribute to the cause of the accident or could not have avoided it. The test must be conducted by a NIDA/SAMSHA certified laboratory as soon as practical following the accident. Such test shall be undertaken prior to and as a condition of returning to work.
- Reasonable Cause: A substance test may be required where there is reasonable cause to suspect that an employee has an in-system presence of intoxicants or drugs on the job or in a job status (such as on contractor or owner-provided transportation). An employee will not be tested under this paragraph unless employee conduct or other related circumstances provide a reasonable basis to believe that the employee may have ingested an intoxicating substance and/or is suffering from impairment of some sort while on the job site. Such observation must be confirmed by a second member of Contractor supervision, or by a project manager’s representative, wherever possible. For Contractors signatory to the Agreement, observation shall also be discussed with the Union steward, provided a steward is readily available. Finally, before an employee is referred for reasonable cause testing, the action must be approved by a senior member of contractor management (above foreman/supervisor) or by a project safety representative. All management representatives responsible for making such observations and/or referrals shall be required to attend a Department of Transportation (DOT) approved training program in order to be authorized to make such observations or referrals.
Employees removed from duty for post-accident
testing will remain off-duty until test results are received. If the employee tests negatively, the employee will receive full back pay for the time missed. If the employee tests positively, the employee will be barred from the project effective the date and time of the specimen collection. Any employee so barred will be eligible for consideration for reemployment on the project after a period of not less than sixty days. Before being rehired, any such employee must pass a drug test conducted by a NIDA/SAMSHA certified laboratory at the employee’s expense and must agree, as a condition of reemployment, to submit to substance use testing at the CCIP project manager’s request, for a period of six months.
III. DRUGS TO BE TESTED AND TEST PROCEDURES
- Test Standards: Drugs to be tested, specimen collection, chain of custody and threshold and confirmation test levels shall comport with the Mandatory Guidelines for Federal Workplace Testing Programs established by the U.S. Department of Health and Human Services. Drug tests shall be conducted as described in Part III, 2 below. Any alcohol testing will be conducted by devices and under procedures approved by Massachusetts law.
- Test Procedures: Drug testing will be conducted in three phases by urine testing.
- Phase 1- Point of Collection (POC) Immunoassay Screen using the icup/instant test, or its equivalent. If the POC test is ”inconclusive”, the specimen shall be split and will be sent by overnight courier to a NIDA/SAMSHA laboratory for Phase 2 and Phase 3 testing if necessary.
- Phase 2 – Immunoassay screening and specimen integrity testing by EMIT or equivalent. If the specimen is unacceptable, the employee or applicant will be requested to provide a fresh specimen. If the Phase 2 screen reads positive, it will be forwarded for Phase 3 confirmation testing.
- Phase 3 – Confirmation testing by Gas Chromatography/Mass Spectrometry (GC/MS). Positive test results will be forwarded to the Medical Review Officer (MRO) to be reviewed with the specimen provider and reported to the 50 Rogers St Project’s Safety Manager.
- Alllaboratory testing shall be conducted only by laboratories licensed and certified by the U.S. Department of Health and Human Services and shall be conducted in accordance with the Mandatory Guidelines for Federal Workplace Testing Programs, as amended.
- Pre-employment analysis will test for the following drugs. The threshold level for a positive test for each drug is as indicated:
Description Screening Level Confirmation Level
Benzoylecgonine-Cocaine Metab 150 ng/ml 100 ng/ml
Marijuana Metabolite 50 ng/ml 15 ng/ml
Amphetamines 500 ng/ml 250 ng/ml
Opiates 2000 ng/ml 2000 ng/ml
Phencyclidine 25 ng/ml 25 ng/ml
The following panel of drugs will be included in post-accident testing:
Description Screening Confirmation Level
6-Acetylmorphine 10.0 ng/ml 10.0 ng/ml
Barbiturates 300 ng/ml 200 ng/ml
Benzodiazepines 300 ng/ml 200 ng/ml
Methadone 300 ng/ml 200 ng/ml
Methylenedioxymethampetamine 500 ng/ml 250ng/ml
Alcohol- An employee shall be presumed to be under the Influence of alcohol with a breath alcohol level equal to or greater than .08 percent alcohol.
In the event that the Department of Health and Human Services changes the screen or confirmation threshold cutoffs or adds new drugs or procedures to the list of drugs to be tested and the prescribed test procedures, or the Commonwealth of Massachusetts amends the presumption levels for alcohol impairment, this policy shall be automatically amended to accommodate such change, addition or amendment.
- Retests: In the event of a positive result, there is an automatic confirmation test (GC/MS) performed by the drug testing laboratory at no cost to the employee. In addition, the drug test laboratory shall preserve a sufficient aliquot specimen as to permit independent confirmatory testing and follow-up retesting at the request of the employee or by the project at its expense. The laboratory shall endeavor to notify the employee/applicant and the Safety Manager of positive test results within three working days after receipt of the specimen. The employee/employer may request a re-test within three working days from notice of a positive test result. Costs of re-tests will be paid in advance by the requesting party. In the event the initial test is proven to be a false positive, costs for any retests shall be reimbursed.
- The drug test laboratory and the specimen collection facility must establish and maintain a forensically acceptable chain of custody. It will be the burden of Consigli Construction as the Construction Manager to establish, in any case arising from a positive test result, that the appropriate chain of custody has been maintained.
- Employees must execute any documentation necessary to release report of test results to the Project Safety Manager. Failure to execute the appropriate release forms or to comply with testing procedures, (including adulteration of test specimens) will result in a permanent bar from the Project.
REVISIONS OR AMENDMENTS
This Substance Abuse Program may be amended, from time-to-time, in writing.
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