Site Specific Safety and Health Program

Emergency Response Plan

IN CASE OF EMERGENCY, CALL:  (202)224-0911 When reporting an emergency, please provide the following:
  • Your location, phone number, and name
  • Your company’s 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 Andrew Kolodziejczak (202)815-9925
  • Post person at closest public location
  • Record names/addresses of witnesses
  • Do not allow media on site
  • Refer all media inquiries to AOC (See “Crisis Response Cards”)
The Consigli designated individual shall wait at the main entrance to escort Emergency Services personnel as they arrive. The Consigli Superintendent shall serve as the designated individual. Should they not be present, the Consigli Assistant Superintendent or Foreman shall fill this role. 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. Back End of Emergency Response Plan

Emergency Contact Names and Numbers

USCP:   (202)224-0911

DC Emergency: 911 Fire or Police

CCC General Superintendent: Rob Soper  (202)578-3702

CCC PM: Saman Ali  (202)924-2732

CCC PX: Jim Christian (202)253-3418

Corporate Safety: Dan Della-Giustina (508)686-6008

Safety Manager: Andrew Kolodziejczak (202)815-9925

Note: This sheet will be posted on-site

Back End of Emergency Contact Names and Numbers

Medical Facilities

Medics USA 


1700 17th St NW A, Washington, DC 20009

Directions to Medics USA 

Directions to George Washington University Hospital

Back End of Medical Facilities

Site Safety Plan

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); 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.

Section 1 – Job Safety Analysis & Accident Prevent Plan

Activity Hazard Analysis (AHA): AHA will be provided by the contractor to the COTR in advance of the scheduled preparatory meeting for review. AHA’s will be submitted through email for approval. During the preparatory meeting the AHA will be reviewed to ensure that applicable safety requirements are met and that the Safety Data Sheet (SDS) are submitted and incorporated. AHA’s must be submitted in PDF form and be printed and kept on site. All SDS sheets will also be printed and kept on site. Work shall not begin until the AHA with Overall Risk Assessment Code (RAC) has been accepted by the COTR. AHA’s shall at a minimum:
  1. Define the steps being performed within the activity or task.
  2. Identify the work sequences.
  3. Identify specific anticipated hazards, site conditions, equipment, materials and/or personnel.
  4. Identify the control measures to be implemented.
  5. Identify Risk Assessment Code (RAC) for each step after the controls have been implemented.
  6. Have an assigned overall RAC that cannot be lower than the highest step RAC.
  7. Identify the name of the Competent Person(s) and/or Qualified Person(s) required for a  particular activity as specified by OSHA.
  8. Be reviewed and modified as necessary to address changing site conditions, operations or change to CP(s)/QP(s).
  9. Be in the possession of workers/crew while work is being performed.
Job Site Analysis (JSA) will be provided by the foreman when work conditions change during the work shift. They will review the work task, determining the work hazards and creating control measures. See Exhibit (A).  Section 2 – Safety & Health Standards procedures. Orientations will be held at the project field office. Consigli’s Superintendent will be responsible for ensuring the plan is being followed in the field and retraining workers if necessary. Please see Exhibit N for written Safety Orientation plan. All workers will be required to comply with Consigli safety policy and be oriented with the workings of the project site prior to starting work. Subcontractors will be required to hold safety meetings each morning and will be made aware of any changing site conditions by Consigli’s Superintendent. There are limited identified hazardous materials associated with this Project; some selective demolition/abatement is anticipated to be necessary. All workers shall be made aware of relevant hazardous materials and shall be trained upon this potential exposure at individual safety orientation. No workers shall interface with any hazardous material as identified through hazardous materials survey, unless that worker is the holder of appropriate certifications, and that worker is completing tasks in accordance with approved Abatement plan for the proper abatement, handling, and removal of hazardous materials. The emergency evacuation plan will be posted throughout the project site and will also be reviewed with all workers during the Contractor Safety Orientation. Please see Exhibit B for the Emergency Evacuation plan for the project site. OSHA Standards Contractor is meeting;
  1. OSHA 1926 – All subparts are applicable with the exception of Subpart N, Subpart S, Subpart U, Subpart W, Subpart Y, Subpart AA, Subpart CC,
  2. OSHA 1910 – All subparts not covered by 1926 or to supplement 1926 such as; Subpart A, B, D, E, F, G, H (For materials applicable to this construction project such as flammables, acetylene, oxygen), I, J, K, L, M, N, P, Q, S, Z (if encountered)

Section 3 – Protection of Public and Means of Egress

All workers for the project will be briefed on the Emergency Action and Evacuation plan shown on Exhibit B.  The plan details the means of egress for the workers on the Project.  There will be limited impact to the public egress paths from the building and the proposed plan of action is outlined below. Protection of the Public This project will have minimal impact to the public as the bulk of the work will be done in the MER1 equipment room which is non-occupied. The public, however, will be impacted during the crane lift (see Attachment Q for traffic plan). The new generator will be hoisted over the existing sidewalk on Constitution Ave NE. In order to protect the public, the sidewalk will be closed during this operation and pedestrians detoured to the other side of the street. Consigli’s Superintendent will walk the site daily and perform inspections. Inspections shall be documented in the Daily Log and will be provided to AOC as a regular submittal through the approved submittal process for this project. Additional PPE (Hardhat, glasses, etc.) will be made available on site for progress walks with A/E, Owner, etc.

Section 4 – Means of Protection

Storage:  It is prohibited to store, position, or use equipment, tools, materials, scraps, and trash in a manner likely to present a hazard to the public or building occupants by its accidental shifting, ignition, or other hazardous qualities. Storing of combustible or flammable liquids shall be in accordance with the current edition of the National Fire Code for Flammable and Combustible Materials (NFPA 30). Joint sealants and any other flammable materials will be brought to site on an as-needed basis. Any flammable materials that must remain on site overnight will be stored in a locked flammable cabinet. Compressed gases shall be stored in accordance with Compressed Gas Associations (CGA) guidelines. Compressed gases and flammable liquids will not be stored within enclosed structures. Should compressed gases be needed for any of the work, they will be brought on-site on an as-needed basis. Obstructions: No corridor, aisle, stairway, door, or exit shall be obstructed or used in such a manner as to encroach upon routes of ingress or egress utilized by the public or building occupants, or to present an unsafe or unhealthy condition to the public or building occupants. No fences or barricades will be erected as part of this work. The job site is secluded from the public and thus does not necessitate any temporary barriers. Housekeeping:  Workers are responsible for daily and continual clean-up, to include dust elimination/minimization during and upon completion of work activities and shall leave the work area broom swept.  Housekeeping practices shall be in conformance with OSHA 29 CFR 1926.25; 29 CFR 1926.62; and 29 CFR 1926.1101. Electrical Safety: In addition to complying with applicable standards as noted in this section, refer to Division 1 requirements for “Temporary Facilities and Controls”. Installation of temporary electricity and lighting must comply with 29 CFR 1926 Subpart K. Temporary electricity must be protected by ground fault circuit interrupter (GFCI). GFCI breakers and outlets shall be tested prior to in service and periodically and record of the tests and services maintained. Electrical cords shall be managed in a way to avoid creating tripping hazards or in areas where the cord will be damaged. Suspended cords must be secured with a nonconductive material. Provide compliant electrical supply, overload/ground fault protection, lighting, and signage/notification systems. Mechanical Systems: Mechanical systems, equipment, and the components thereof, shall be arranged and installed to provide ready accessibility and ease of lock and tag application during lockout/tagout procedures for Architect’s employees post construction. Hot Work: Minimal hot work is expected during the piping installation. Contractor will solder the pipe joints. Noise is expected to be minimal needing no further protection. A fume extractor (i.e. smoke eater) will be available if fumes are generated beyond an acceptable level. Protection of the Public and Federal Employees:  The main portion of the work will be performed in a secluded area that is not occupied by the public or Government employees (See Exhibit P). During this operation, The Contractor shall comply with requirements set forth in ANSI A10.34-2001: work area will be clearly marked, and alternate pedestrian paths delineated as necessary; construction material, tools, debris, waste, equipment or other items will be contained away from pedestrian path and cleared off prior to the end of every shift; when lifting materials overhead, area will be monitored to ensure that it remains clear while the load is suspended. Fences and Barricades:  The space is secluded from the public and therefore there will be no temporary barriers or fences.

Section 5 – Contractor Safety Manager

Consigli’s full time safety representative will be the Project Superintendent or Project Manager. All safety issues on the site should be referred to:    Rob Soper – Gen. Superintendent           Saman Ali – Project Manager   Email:                    Email:          Phone: (202)578-3702 (cell)                     Phone: (202)924-2732 (cell) Consigli’s DC Safety manager is Andrew Kolodziejczak. He can be reached at (202)815-9925.

Section 6 – Specialized Training and Experience

Certifications : During the site orientation process, all subcontractors shall be required to provide proof of training for relevant certifications as deemed necessary per OSHA. All subcontractors will also submit a Competent Person form for all applicable job tasks.  The copies of their certifications will be kept in a binder with each respective Competent Person forms on the job site.   The list of required certifications for the project is as follows:
  1. Forklift operation
    1. Forklift operator certificate (as deemed necessary; no forklift use is anticipated on the project at this time)
  2. Scissor lift operation
    1. Scissor lift training (as deemed necessary; no  scissorlift use is anticipated on the project at this time)
  3. Aluminum framed entrances and storefronts
    1. Manufacturer certified installer
  4. Fall protection
    1. Fall protection training for workers who will use harness and SRL (as deemed necessary; no work above 6’ is anticipated on the project at this time)
  5. Respiratory
    1. Respirator use training
    1. Fit testing and Clearance for Use of Respirator
  6. Welding Certifications
    1. Contractors and Employee Training Certifications (as deemed necessary per the work scope)
  7. Crane operation
    1. Crane operator certificate
    1. Qualified rigger certificate

Section 7 – Protective Equipment & Work Procedures

PPE : In accordance with Consigli’s Safety Policy all personnel entering the work site must wear hardhats, eye protection, work boots, and safety vests (as applicable) as noted on 29 CFR 1926.95. Vests shall be required when exposed to vehicular and heavy equipment traffic. All employees performing work with their hands must wear gloves that are appropriate to the task. When not performing actual work with their hands, workers will be required to have gloves 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 hardhats with integral welding shields. Hearing Protection : When noise generating operations are in progress ear protection shall be worn if noise produced exceeds 85dB. During demolition, grinding, or any high noise operations, hearing protection will be required for anyone in the vicinity – both members of the general public as well as those on the Consigli jobsite – as  appropriate per OSHA approved Noise Levels. See Table D-2:
The work procedures that will require protective equipment include, but are not limited to: grinding, demolition, and other noise producing work.  During the daily JSA reviews, the Superintendent and/or Foreman will discuss the work activities with personnel onsite and identify areas that may require hearing protection.  Hearing protection will be readily available onsite for workers to utilize.
Fall protection : Potential falls on this project are limited to ladder usage. There is no exposure to a fall greater than 6’ anticipated on this project. See above Hazard Matrix for Consigli ladder usage requirements (p.14). Respiratory : During the demolition of concrete (tile grout, core drilling, etc.), workers (and anyone onsite in the immediate vicinity), OSHA Silica Table 1 will indicate what, if any, respiratory protection will be required. Wherever practicable, dust control will be accomplished through use of other means (wet methods, HEPA vacuums as appropriate per OSHA). Consigli’s Superintendent will review the work in the field and ensure work is compliant with the site specific Silica Control Plan (Exhibit L). A specific Silica Control Plan shall be developed for each applicable scope of work. Hot work: Consigli shall submit a Hot Work permit application to the AOC for approval prior to any hot work taking place. Consigli’s Superintendent will monitor the work in the field to ensure proper PPE is utilized during the work procedures that require special protections. CCC will also ensure fire watch is maintained during all hot work and for 30 minutes after the end of the work. All appropriate lockout/tagout procedures shall be approved with Senate Superintendent through the Hot Work permitting process prior to commencing any hot work to ensure all appropriate protections have been installed. All flammable gasses shall be stored in secure fire cabinet/cages with lock. Consigli Superintendent shall have a copy of this key/padlock. See Exhibit C for hot work permitting procedures Electrical: All electrical tools, cords and equipment must be in good working order. All electrical tools and components will be visually checked on a daily basis.  Any damaged cords or equipment/tools with damaged cords must be taken out service immediately.  All cords must be equipped with a grounding pin – flat three wire cords are not allowed.  Cords will be 12-gauge or greater. Consigli will be responsible for all temporary power and any general temporary lighting to meet OSHA standards. Consigli will ensure that the electrician follows all lock out/tag out procedures per CFR 1926.417 (See below section for “Lock Out/Tag Out” Plan and Exhibit D for example of tags). All temporary power for the project will be installed on protected and dedicated circuits with 100% GFCI protection. GFCI will be tested to ensure proper function with a log book filed with CCC monthly.  No live electrical work will be conducted per NFPA 70E. The work procedures Consigli shall use to check electrical safety daily are as follows: Consigli’s Superintendent performs daily safety walks, documents electrical safety items in the daily log, deficient items are removed from service immediately. During the daily safety walk, the Superintendent checks for electrical safety items such as damaged or unprotected cords, temporary outlets being properly secured, live electrical parts not being exposed, GFCI’s being used, bulbs on temp lighting are protected, etc.

Section 8 –Safety Data Sheets (SDS) and Material Use/Disposal/Storage

All materials and chemicals used on-site will be properly and conspicuously identified, labeled, and communicated with all workers, and AOC COTR/CM in compliance with 29 CFR 1910.1200, Appendix E. All SDS’s will be provided before materials are brought onsite and must be reviewed by the architect.
  • All SDS’s shall be readily accessible for workers, and AOC COTR/Construction Manager at their request.
  • The SDS’s will be submitted per specification section with each product for AOC Approval.
Usage: No chemical or product will be used without first understanding the hazards and safety measures. The SDS’s will be reviewed by the supervisors and discussed with the workers to ensure everyone is aware of the hazards. Disposal: Disposal of any toxic or hazardous materials will be in accordance with the SDS and regulations.  Consigli anticipates the need to remove some fuel oil from the existing day tank/generator. A specialty contractor will be used, and hazardous material will be disposed in accordance to local environmental policies. Unauthorized personnel will be strictly prohibited to handle hazardous materials. Spills: There will be an emergency response phone list posted at the jobsite office. There will be an emergency response company assigned to the project and that company will deal with any hazardous spills or releases of hazardous materials. The Consigli staff for each project   will have a contact person from that company that will be available on a 24-hour 7-day a week  basis. A number that can be called for these types of emergencies will be posted on site. Storage: Combustible flammable liquids and compressed gases will be stored in accordance with 29 CFR 1910.101. Compressed gas cylinders, if used, will be marked with the company’s name for easy identification and must identify their contents. Cylinders will have their regulators removed and protective caps replaced at the end of each working day. Cylinders will be set up in hand carts during work hours and separated by 20 feet at the end of the working day. These shall also be stored securely in either a fire cabinet or fire cage and locked. All SDS binders will be kept onsite and will be accessible to all workers at the jobsite.

Section 9 – Phasing Requirements

There are no special phasing requirements for this project, however, noise generating work will occur during the nightshift to minimize disturbances to building occupants.

Section 10 – Emergency Procedures

In case of an emergency, follow the emergency action plan and call the emergency numbers as listed in Emergency Call Hierarchy. USCP emergency number will always be the first call. All injuries or damage to Government property will be reported to the CCC Superintendent and Lead Safety Officer, as well as the AOC COTR/Construction Control Representative within 24 hours. The Consigli Accident Report will be filled out and submitted whenever a Subcontractor’s employee is injured (See Exhibit H). A fully stocked first aid kit and blood borne pathogens kit will be maintained on-site.  Only properly trained personnel will administer first aid. First aid services will be made available per 29 CFR 1296.23. Back End of Site Safety Plan

Environmental Emergency Contact and Management Response

In the event of an emergency the construction workers shall leave the building(s) immediately and proceed to the muster point indicated in the evacuation plan.  In the event of a DISASTER, the Superintendent shall instruct the construction workers to leave the site or remain in place and await further instruction.  The following steps should be taken in the event of an emergency:

Emergency Lock Down and Shelter in Place Response

In the event of a US Capitol Police-issued “lock down” or “shelter in place” order, the CCC superintendent or CCC on site personnel shall immediately stop all construction activities and direct workers to gather in a central location depending on active construction activities and await further instruction from USCP or AOC personnel. All workers currently engaged in activities on the project will immediately proceed to the shelter in place location to be identified by USCP. AOC will inform CCC of the shelter in place location for the project and CCC’s Superintendent will ensure all workers are aware of the location. When reporting an emergency, the following shall be provided:
  • Individual’s location, phone number, and name;
  • The location of the incident (building name, floor and unit 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).
Consigli will report the accident to AOC within 24 by telephone and provide a copy of the accident report (filled out by Consigli’s Superintendent) no later than 7 days after occurrence. Emergency Procedures for Handling Accidental Spills & Releases Chemical’s SDS shall be consulted to determine proper method of clean-up and containment. The SDS contains the information on what to do if a spill causes inhalation hazards or if the chemical penetrates the eyes. Consigli will review and approve all spill containment systems prior to construction. Each company shall be required to maintain appropriate spill containment materials as necessitated by products used for their Work on the jobsite. Consigli will ensure that the appropriate spill kit is present and in useable condition as part of the daily safety inspection. The spill containment system must be capable of containing 100 % of the volume of the largest container of hazardous material. The Consigli Superintendent shall follow the same procedure for reporting accidents as noted above. Once the spill/release has been mitigated, the Accidental Discharge Notification Form (see Exhibit I) must be filled out. The disposal of spills that are treated off-site must be logged. The following information shall be documented: date and time of material spilled that was removed; material identity; quantity (volume); cause of spill; method of disposal (including transferring to off-site treatment system); and corrective action implemented to prevent spills from reoccurring. Materials shall never be flushed to the sewer. In the event of an accidental airborne release, AOC will be notified immediately. Consigli shall appropriately address the spill as dictated by the SDS and Manufacturer recommendations. Primer for the torch applied membrane is the only anticipated airborne release hazard to be used on this job. If any silica dust is released due to improper work methods or tool failure, workers will stop work immediately.  The area will be cleaned with water as needed to clear the area of all dust and the effluent shall be vacuumed with a wet shop vacuum. If dust is released outside of the project (i.e. inside of the building), a HEPA vacuum will be used to clean the dust.  Consigli’s Superintendent and the Foreman will monitor the work and controls to ensure proper Silica containment procedures are used. Potential Exposures :  While there are no identified hazardous building materials in the scope of this project, there is the potential for exposure should a previously unknown condition be uncovered. If hazardous materials are discovered, all employees will stop work immediately and notify the Consigli Superintendent, who will then notify the AOC Construction Representative and COTR. Work shall be stopped until appropriate measures have been taken to mitigate the hazardous condition found.

Section 11 – Subcontractor Interface

The primary subcontractor interface will take place in the daily stand up meetings held by Consigli’s Superintendent.  Consigli’s Superintendent will utilize the daily standup meeting to coordinate all work on the site with subcontractors and work on any potential conflicts that may present safety, quality, or schedule issues.  In addition to daily stand up meetings, Consigli’s team shall utilize additional Subcontractor interface methods as outlined below:

Pre-Construction Safety Meeting  

The project team, as well as the Consigli safety department, will meet with each subcontractor before beginning work to review the 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. After reviewing the programs and meeting with the individual subcontractor, if the team is satisfied with the risk control direction, they will be permitted to begin work.

Safety Orientations 

All subcontractor’s employees shall attend the Consigli Construction Project Orientation prior to starting on-site.  Consigli Construction’s Job Supervisor will conduct a safety orientation for each employee and subcontractor to discuss site specific safety protocols. See Exhibit N. Once completed, employees will sign acknowledging they have undergone this orientation and will be issued a hardhat sticker. All personnel will have completed the required AOC onboarding procedures including background checks and badging.


All jobsite superintendents and competent persons will meet with the Consigli Superintendent once a week to discuss project updates and safety. Weekly “Toolbox” meetings as well as AHA review will be held by each company field supervisor and their crew. The signed documentation will be provided to the Consigli Superintendent and copies of these forms will be filed by the Superintendent as part of standard recordkeeping.

Restricted Areas

Workers are prohibited from entering any areas outside of the designated work area unless work has been previously authorized and scheduled.  All workers must limit their impact on surrounding work areas to the smallest extent feasible.  All construction personnel working on the job site will be required to obtain AOC Congressional badges. Consigli Construction has a non-fraternization policy with the public. All workers on-site will abide by this and avoid talking to any parties not related to the work.

Substance Abuse, Weapons, and Violence

Workers will be prohibited from using, possessing, concealing, transporting, promoting, and/or selling any controlled substances, not limited to alcoholic beverages, drugs, and non-prescribed medication. This policy will also be enforced for firearms, weapons, ammunition, and contraband. Consigli Construction has a zerotolerance policy for workplace violence. Any act or threat of physical violence, harassment, intimidation, or other threatening or disruptive behavior will be grounds for immediate dismissal from the project.

Inter-Subcontractor Coordination and Communication

Consigli will facilitate all inter-subcontractor communication for drawing and document management.  All on site communication will be disseminated at weekly subcontractor foremen and PM meetings in addition to a daily 15-minute stand-up meeting at a time to be determined by the Consigli Superintendent.  The daily meeting will consist of reviewing current construction activities, reviewing the construction look ahead, confirming all deliveries to be made within the next 72 hours as well as any other constraints. Consigli conducts daily stand-up meetings with all trades to discuss the plan for the day with all trades.  The stand-up meeting provides all trades an opportunity to discuss work scopes for the day and any potential conflicts they see with other trades. Consigli’s Superintendent will lead the meeting with the trades and help resolve any potential logistical or safety conflicts.

Other means

Work plans in accordance with the contract documents for all work impacting building infrastructure systems (life safety, plumbing, HVAC, etc) are required prior to the start of work.  The work plans are reviewed by Consigli’s Superintendent and Project team for compliance before submitting to AOC. AHA’s will be reviewed on the first work day of the week with the work crews. If additional workers join the work site, the AHA will have to be reviewed and signed by that individual. Weekly tool box topics shall be reviewed in the field with and signed by all workers and submitted for record to Consigli.  These records shall be maintained on the Consigli Job site. Some other forms that Consigli shall require from subcontractors are: Hot Work permits, Confined Space Entry permits (not applicable to this Contract), crane plans (not applicable), out of service request forms, etc. The ultimate responsibility for all of these forms lies with Consigli.

Section 12 – Testing and Demonstration

Testing will be required for many of the items installed under this project including but not limited to;
  1. Pressure and leak test of fuel oil pipes
  2. Operation testing of new generator
  3. Integration test for generator system
  4. Testing of electrical system per NETA acceptance testing specification

Validation Requirements 

1. No validation requirements exist on this project.

Section 13 – Hazardous Communication Plan

All companies working on-site are required to submit a copy of their HAZCOM program, with all applicable SDS’s, and a company safety manual to Consigli’s Superintendent. These will be kept on-site with the Consigli Superintendent. HAZCOM plans will be required per 29 CFR 1910.1200. Whenever a product is first brought on-site, after it has already been approved through the submittal process, it must have a valid SDS, and a copy of the SDS is placed in with that companies’ respective SDS log. HAZCOM Plans shall have an index of SDS’s to facilitate timely location of said product in case of emergency. It is the Site Superintendent’s responsibility to update the SDS for all products used on-site. No new product containing a hazardous chemical will be purchased or used without first reviewing the corresponding SDS to determine the extent of the hazard and how to properly protect employees. The SDS log will be on site at all times for all personnel to review.


Consigli will ensure labels are clearly written or printed on containers that contain hazardous chemicals. These labels must be prominently displayed and have the chemical identity and appropriate hazard warning information, including the target organ(s), if available.


Consigli will ensure all employees who work with hazardous chemicals or have the potential of being exposed to hazardous chemicals have received HAZCOM training. These employees will have an understanding of the requirements of the HAZCOM standard per 29 CFR 1910.59; be able to read and interpret an SDS and warning label; take appropriate protective measures and know the identity and location of hazardous chemicals on the project site.

Hazard Analysis

All job hazards will either be identified in the Job Hazard Analysis (JHA) or the Activity Hazard Analysis (AHA). The JHA (as seen in Exhibit J) will allow the Consigli Superintendent to identify the hazards and controls related to the commonly performed tasks on the project. This form will need to be completed every week and include the hazards, required PPE, and a Safe Plan of Action. If a particular task requires a complexity not covered under the JHA, then an AHA will need to be completed (see Exhibit A). The activity and risk level will be provided. For this project, it is not expected that any activity will surpass the rating of “M = Moderate Risk”. The hazard control measure section will need to be filled out to provide information on the protective equipment. This form shall be provided to the Consigli Superintendent prior to commencing the activity. Before the start of each work day, competent persons will ensure that their workers are aware of hazardous chemicals that they may be exposed to. The information to be shared includes protective and safety measures to take and measures the employees can take to reduce the hazard.


IDENTIFICATION AND CONTROLS  SILICA: Consigli will provide a site specific written exposure control plan. Consigli will establish and implement a written exposure control plan that contains at least the following elements:
  1. A description of the tasks in the workplace that involve exposure to respirable crystalline silica;
  2. A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task;
  3. A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica;
  4. A description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other employers or sole proprietors;
The written exposure control plan will be reviewed and updated as necessary. Consigli will make the written exposure control plan readily available for examination and copying, upon request, to each employee covered by this section, their designated representatives, the AOC and USCP. Consigli, and all subcontractors, will designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan. Reference Exhibit L LEAD: Lead containing materials have not been found in any of the planned work areas. It is understood that any painted surfaces from pre-1978 should be assumed as lead-based paint. Consigli will not be disturbing any such areas on the project and does not anticipate this being an issue. However, if lead containing paint is uncovered, Consigli will notify the AOC and follow Consigli’s safety policy as it relates to lead work. See Exhibit O. ASBESTOS: Asbestos has not been identified to be present on the jobsite per AOC inspection, however, further tests will be performed by Consigli prior to start of work. No worker shall be allowed to interface with any identified friable asbestos, unless certified and licensed to handle such materials and all proper PPE and asbestos handling is performed in accordance with applicable standards. If any suspected ACM (asbestos containing material) is uncovered throughout the work process (as not previously identified through Hazardous Materials Survey) Consigli will stop work in that area until the materials in question can be tested for asbestos.  After the ACM testing of suspected materials has been completed, work can proceed provided the testing proved the material is negative for asbestos. If the material is determined to contain asbestos, a licensed ACM contractor will be brought to the project to remove the ACM in accordance with Specification Section 028213 ASBESTOS REMEDIATION. NOISE EXPOSURE : PERMISSIBLE NOISE EXPOSURE POLICY Consigli Co. Inc.’s safety policy requires that hearing protection be worn in work areas exceeding 85 dBA. Training will be provided for any employees who may be exposed to noise above the action level to ensure they recognize and wear the necessary hearing protection to reduce the noise level. This training will be conducted via Consigli’s “Culture of Safety” Tool Box Talks. If employees must shout to be heard at a distance of 4 feet, the sound level most likely exceeds 85 DBA. Should noise levels be of concern, decibel readings will be taken multiple times (at least 4) per day during that activity. After enough historical data has been recorded for a specific task(s), dBA readings will drop to two recordings a day. This will be determined by the Site Safety and Health Officer (SSHO) designated by Consigli. All readings will be recorded, and records will be maintained in the SSHO’s office. Wherever it is not feasible to reduce the noise levels or duration of exposures to those specified in Table D-2, Permissible Noise Exposures, in 1926.52; ear protective devices shall be provided and used (Table D2 is the same as EM 385-1-1 Table 5-3). Any areas that exceed these noise level limits shall be considered a noise hazard area and will be marked with caution signs. These signs will indicate that hearing protection is required. Ear protective devices inserted in the ear shall be fitted or determined individually by a qualified person(s) and shall protect the individual to the attenuation protection factor provided by the manufacturer. Plain cotton is not an acceptable protective device. When noise levels exceed 115 dBA the combination of earplugs and earmuffs will be required. Any employees that will be on a single project with exposure to consistent levels of noise at 85 dBA for six months or more shall be tested and a baseline audiogram established. All requirements associated with establishing baseline audiograms (14-hour non-exposure time prior to test being conducted being one requirement) shall be observed. Any deviation in the baseline conducted on the annual audiogram will result in notification within 21 days, with re-evaluation and refitting of hearing protection and, if necessary, further medical evaluation. Records shall be kept on all testing. If logging noise levels is necessary, the Consigli Safety Department will provide sound level meters and a noise level log to record and follow decibel readings for historical and documentation purposes. TABLE D-2


Duration Per Day/Hours              Sound Level dBA Slow Response
8 90
6 92
4 95
3 97
2 100
1 ½ 102
1 105
1/2 110
1/4 or less 115


PCB’s are not suspected in any of our planned work surfaces/task. At no time shall a worker disturb any material he/she cannot readily identify.  If they come across a material he/she cannot confirm as PCB free, they shall notify their supervisor immediately. All finished suspected to contain PCB which test for more than 50 ppm will be considered PCB containing material and will be disposed of in accordance with all local, state and federal regulations. Polychlorinated Biphenyls (PCBs) are a class of organic compounds with 1 to 10 chlorine atoms attached to biphenyl, which is a molecule composed of two benzene rings. In construction, they are commonly found in transformers, hydraulics, light ballasts, cable insulation, adhesives/tapes, paint, caulking and floor finishes. If PCBs have been identified on site, they must be tested to determine the PCB content. Any bulk PCB containing material greater than 50 ppm must be abated. Residual building materials (any concrete, mortar, or materials that abut known bulk PCB materials) that contain PCBs that are ≥ 1 ppm and are adjacent to bulk PCB materials must also be abated.

Section 14- Trenching & Shoring Plan

There is no trenching or excavation associated with this project.

Section 15 – Confined Spaces

There are no confined spaces associated with this project.

Section 16 – Scaffolding Plan

Scaffold use is not anticipated on this project based on the scope of work.

Section 17 – Fall Protection Plan

Not Required on this project at this time. Elevated work shall be limited to ladder-based activities.

Section 18 – Means of Access

All construction employees will be limited to work areas as denoted in the Project Documents unless specifically coordinated otherwise with AOC. Personnel will access the Hart Senate Office Building through 24-hour security checkpoint in Dirksen Senate Office Building.  Jobsite access for all deliveries will be made through the Hart Senate Garage; Please see Exhibit P for jobsite access layout.

Section 19 – Multi-Employer Worksite Plan

This project will follow the OSHA Directive CPL 02-00-124, “Multi-Employer Citation Policy”. Per this directive, four employer categories will be established: controlling, creating, exposing, and correcting. Consigli Construction will, unless otherwise noted, serve as the controlling employer overseeing all activities within this scope of work. Should an incident occur on-site between Consigli’s major trade contractors, one or more of these will be identified as the creating employer(s) while the remainder will be identified as the exposing employer(s). If the exposing employer also caused the scope violation, then they will be held accountable. The exposing employer will be held accountable if it did not take safety measures to protect its employees. Finally, the contractor that takes corrective actions to remedy the violation will be identified as the correcting employer. Each company will ensure that their employees are trained to properly use PPE and perform safe means and methods while also communicating on-site about potential hazardous from other contractor’s work.

Section 20 – Demolition

Prior to the start of demolition, Consigli shall identify any potential equipment requiring “make safe” before the relocating, supporting, or removing of any lines that interfere with the Scope of Work. The electrician will “make safe” all items that may be damaged during relocation/removal process. Consigli have been provided existing utility drawings and these will be consulted in designing the demolition work plan. Consigli will then confirm that all utilities leading into the area have been made safe. Lock-out/tag-out and live equipment will be reviewed with subsequent subcontractors during the pre-construction safety meetings as required to ensure protection of existing utilities and site conditions are safe for construction activities to commence. The lock-out/tag-out tag procedure is attached as Exhibit D. In the event any utilities, electrical sources, etc. need to remain live to facilitate demolition, a color coding system will be utilized for easy identification of live utilities.  Any utilities painted Red are live, not to be touched, and need to be protected during all operations. Utilities painted Green are to be removed as part of the selective demolition process (after lock-out/tag-out has been confirmed and utilities tested).  If any utilities are unmarked, they shall be considered live. Consigli will be responsible for completing the Consigli demo checklist prior to the start of any new work. Temporary protection, if needed, will consist of either hard barrier walls or full poly walls.  Sweeping compound will be used daily for dust control. Debris from any demolition will be removed through the work day and working surfaces will be kept free and clear of debris at all times.

Section 21 – Crane Plan

Please refer to Appendix Q for Crane Lift and Traffic Plan. The crane will be setup on Constitution Ave NE and the new generator will be lowered into generator room through the air shaft. A road closure will be needed during this operation. The crane selected is a Link-Belt HTC 6110 with 48,600lbs in counterweight, lifting at 51% capacity. Backup crane will be a Grove GMK5165-2 with 40,700lbs in counterweight, lifting at 64% capacity. Neither scenario constitutes as a critical lift since cranes will be operating at below 75% capacity. Crane inspection reports are also attached in Appendix Q. A certified crane operator and qualified rigger will be provided by WO Grubb for this operation.

Section 22 – Incident Investigation Plan

Emergencies:  In the event of a catastrophe or major accident occurring on a project, the USCP emergency number will be called first. Following that, the call hierarchy identified on the Emergency Action Plan will be followed. Consigli’s Corporate Safety Director (Dan Della-Guistina) must be notified as soon as physically possible. AOC COTR/Construction Representative shall be contacted immediately thereafter. Every assistance will be rendered in completing and filing the appropriate reports with the insurance carrier and other agencies. In the event of a serious bodily injury occurring to any individual working on a Consigli Construction Project the Project Superintendent, as appropriately first-aid trained, shall:
  1. Call an Ambulance
  2. Administer First Aid
  3. Secure the Accident Scene
  4. Contact Owner/Client representative
  5. Complete an Incident Investigation Form
  6. Call OSHA within 8 hours for any job-related fatality or within 24 hrs. after the inpatient hospitalization of 1 or more employees and within 24 hrs. of Employee’s amputation or loss of an eye. The incident reporting hierarchy shall be followed.
Injury to Consigli Employee:  Supervisor or Consigli personnel shall immediately be notified for chain of command. Near Miss : A near miss is a potential hazard or incident that has not resulted in any personal injury or property damage. Unsafe working conditions, unsafe employee work habits, improper use of equipment or use of malfunctioning equipment have the potential to cause work-related injuries. It is everyone’s responsibility to report and/or correct these potential accidents/incidents immediately. Following any near miss or event resulting in an injury damage to property or the environment, AOC may request a meeting be held with all involved parties to discuss the incident or issue in greater detail. All parties involved shall be expected to attend and participate in the investigation, discussion, and development of an action plan.

General Program

  • Any employee can fill out a near miss report and forward it to the Superintendent to submit to the Safety Department. Photographic documentation is encouraged.
  • Each jobsite is to investigate and report all near misses.
Incident Reporting: Contractor is responsible to immediately notify the AOC COTR of all incidents to include personal injuries and illnesses, project property losses or damages, and incidents involving the public or AOC property. The Contractor is to provide a preliminary written incident report within two (2) hours of the first notification.
  1. The contractor is required to investigate all incidents, near misses or property damage  cases and provide the AOC a written incident investigation report within 24 hrs. of the occurrence. This report is to include direct, indirect and root cause analysis and corrective action measures. This report will be submitted using the management software identified by the Contracting Officer.Upon request, parties involved in the incident shall participate in incident review  meetings. Near Misses shall be reported on the contractor’s daily report.
Emergency Incident Review:  Following any emergency incident impacting the construction site and/or employees, the COTR may request a meeting be held with all involved parties to discuss the response to the incident in greater detail. All parties involved shall attend and participate in the discussion on updating programs, policies, and protective measures. Injury to Public:  Immediately complete the “Incident Investigation Report” and forward to the Safety Director. Damage to Company Vehicles: Any company owned vehicle accident involving personal injury must be verbally reported immediately to Consigli’s Corporate Safety Director. The accident must be reported on the Registry of Motor Vehicles operator’s report and sent to the main office along with police reports, witness statements, photographs, etc. within 48 hours of the accident. Any instances of fire, major theft or vandalism to a company vehicle shall be verbally reported to the Corporate Safety Director. OSHA Record Keeping:  Every job site office shall have the OSHA 300 form posted on the wall to record any injuries to Consigli employees that may occur at that site during the current calendar year. Each January federal OSHA laws require accidents and illnesses of company employees be summarized for the previous year and posted in the project site offices from February 1 thru April 30th (OSHA 300A Form). The OSHA 300A “Summary of Work Related Injuries and Illnesses” for all years with copies of Consigli employee accident reports will be kept in the Safety Department Corporate files indefinitely. Said form will highlight musculoskeletal related strains and sprains. Consigli Record Keeping: All incidents will be logged in the company’s “Loss Runs” and a separate file kept for each incident, to include, General Liability, Workers Compensation, and property related incident. All occurrences shall be investigated thoroughly. The proper investigation of a “near miss” will substantially reduce the chance of a re‐occurrence and the possibility of an injury or an additional insurance claim. Investigations will not be limited only to bodily injury accidents. An accident is an unwanted, unplanned event that interrupts the normal flow of scheduled activity. Investigated properly, the cause can be determined, corrected, and a reoccurrence diminished. Superintendents shall utilize the “Superintendent’s Incident Investigation Report Formfor investigation of all incidents. The following activities shall be conducted by the Consigli Construction Superintendent in the Accident Investigation process:
  • The Project Superintendent shall investigate and provide a written report of all accidents. Investigate the accident. Find out WHO, WHAT, WHEN, WHERE, and HOW. Have a tape measure available to measure any distance information necessary to the investigation. o Follow emergency procedure until the accident situation is stabilized. The Superintendent shall take photographs of the accident scene and the surrounding area. Indicate on the back of photographs the date photograph was taken, date of incident, what the photograph depicts, and who took it.
  • Contractors who have an automobile accident on jobsite property, involving their company‐owned vehicle, must provide Consigli’s Superintendent with a completed automobile accident report within 24 hours of the accident. State Motor Vehicle procedures for reporting automobile accidents will be complied by Consigli and their Sub‐contractors.
  • Draw diagrams, mark‐up drawings. o Identify, assess, and secure all evidence to preserve for future reference.
  • Record status of construction at the scene at the time of accident. Indicate what work was in place and what work was taking place.
  • Determine how many subcontractors were working in the area, how many workers each subcontractor had on site, and what activity(ies) they were performing.
  • Identify witnesses and attempt to obtain telephone numbers. Record their names and employers. Try to interview them in private regarding accident description and cause. Ask them to sign a statement of description and cause.
  • Obtain copies of reports by others (police, fire department, subcontractors, doctors, etc.).
  • Immediately identify and outline all corrective actions taken to prevent re‐occurrence. As a “lessons learned” the superintendent shall complete an “IT HAPPENED TO US” and forward to the Safety Director.
  • Provide written report as described to the Corporate Safety Director.
  • A copy of all reports including hospital, fire, police etc., must be forwarded to the Corporate Safety Director within twenty‐four (24) hours of occurrence.
Back End of Environmental Emergency Contact and Management Response