Site Specific Safety and Health Program

180 City Point #2484

180 Third Ave. Waltham MA 02451



Emergency Response Plan




The following situations are considered emergency response actions and should be handled in accordance with the procedures outlined in this plan.

  • Fire/Explosion
  • Serious Injury/Fatalities
  • Structural Damage/Collapse
  • Weather or Geological Event
  • Environmental Incident
  • Utility Damage
  • Illegal Activity
  • Labor Problems
  • Bomb Threats/Military Ordinance Unearthing/Acts of Terrorism

In the event of an emergency the following policy will be adhered to for the safe evacuation of the Project. An immediate call will be made to Emergency 911.  Project information for the call is – 180 Third Ave. Waltham MA 02451 (Note:  If calling from a cell phone you may reach the State Police and not the Local Police)

EMERGENCY PROCEDURES: A Consigli representative will be dispatched to the entrance to the project at 180 Third Ave.  Gate A to meet the responding Emergency Personnel and advise the individual in charge of the location of any chemicals or hazardous substances that may be present on any of the floors. SDS’s will be readily available if needed by the City of Waltham Fire Dept.

In the event of a serious injury requiring the assistance of City of Waltham Fire/EMS the injured worker will be kept as comfortable as possible.  Emergency first aid, if necessary, may be administered.  Under no circumstances will the injured person be moved unless the workers life is in danger because of fire or calamity. 

In the event an evacuation is required all personnel at this job site will assemble outside of the work area at the designated Muster Point, 103 Fourth Ave lot by Consigli site trailer. The foreman for each company will meet at that location and take a count of their staff.  If for some reason a worker is unaccounted for, the fire department will be notified of the last location where the worker was observed.

The following is a list of the Chain of Command/Call Hierarchy on the project for establishing lines of communication for all emergencies.

Back End of Emergency Response Plan



Emergency Contact Names and Numbers

First call: 911 Fire or Police

2nd Call: Consigli Project Superintendent: William Hayes (774)737-6042     

3rd Call: Consigli PM: John Viscariello (774) 573-9836

Consigli Assistant PM: Justin Pollard (774)573-5693

4th Call: Consigli Project Engineer: Nicole Roman (774)573-9906

5th Call: Consigli Safety Director: Bryan Kingsbury (508)808-9359


Consigli Project Executive: John Lehane (617)799-4566

Consigli General Superintendent: Steven O’Toole (617)293-6007

Consigli Safety Manager: Tim Cuddahy (508)509-1233


Fire Department Non-Emergency (781)893-4105

Police Department Non-Emergency (781)893-3700

Back End of Emergency Contact Names and Numbers



Medical Facilities

Newton-Wellesley Hospital

2014 Washington St. Newton MA 02462


OHS Total Care Medical Center

1340 Soldiers Field Rd. Brighton, MA



Back End of Medical Facilities



Site Safety Plan

Scope of Proposed Operations:  This project will be under a Contractor Controlled Insurance Program (please see exhibit J attached).

Boston Properties is proposing the construction of a six-story office building and a five-level, pre-cast parking garage, located at 180 Third Ave. Waltham, MA. The project consists of 270,000 square feet of office and amenity areas, along with associated landscaping, utilities and parking.

The project will begin with the demolition of two existing buildings located at 214 Third Ave. followed by tree clearing, blasting and excavation of the future building and parking garage footprint. Pre-cast parking garage will be erected simultaneously. The façade of the building will consist of a glass curtainwall system.

Mobilization will begin April 20, 2021 and the project completion for the core and shell will be March of 2023.

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.

Post Incident Review: Any incident that results in a recordable injury will require a post incident review. The worker who was injured along with their foreman/Safety Personnel/PM/Sup/etc. will need to fill out Appendix section R (Superintendent Report) and attend this meeting.  At this meeting they will re-emphasize their commitment to safety, determine chronology of events, identify contributing factors, identify root cause, provide improvement plan to prevent reoccurrence and discuss disciplinary actions taken (if any). Findings from this meeting will be shared/disseminated with all contractors on site to prevent reoccurrence.

Substance Abuse: As a condition of employment, ALL PERSONNELL on this project are required to submit to a urinalysis test for determination of the presence of illegal substances.  A positive result will disqualify the applicant for employment on this project.

Personnel Protective Equipment (PPE):  All workers will wear hard hats, safety glasses, and hi-vis clothing/vests at all times. All personnel performing work with their hands shall be required to wear gloves that are appropriate to the task and with the proper cut resistance. A minimum of ANSI level 6 Cut resistance will always be required . When not performing actual work with their hand’s 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 with at least 48 hours notice.

Pretask Plans: A JSA shall be conducted for each work task to be performed on a weekly basis.  JSA’s shall be reviewed initially with all involved personnel performing that task, signed by all workers including their supervisor and filed on site. Tool box talk meetings will also be required to be done on a weekly basis and handed into Consigli.

Site Access / Parking:  A logistics plan has been created for the project that details delivery routes, employee access, and parking. 
Demolition: Prior to the start of demo operations, all subcontractors are required to review the hazardous material report. The demo contractor will be responsible for completing CCC demo checklist prior to the start of any work in their target areas. During demolition and construction activities all personnel will wear all required protective equipment. Engineering controls will be used for any activity which may cause dust.

**Review Chapter 4 for more detail

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 include, but is not limited to, steel erection, roofing, scaffold erection and dismantling, overhand brick laying and pre-cast concrete related work. Wire guardrails will be used for all perimeter and shaft protection.  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 four 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 system (if used) with turnbuckles to be installed for all straight runs and any straight run over 100 feet.  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 four times the intended load).  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 and could be exposed to a fall greater than the height of their work on the ladder 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 off when installed for use. Only ladders with a rating Type 1A or 1AA will be allowed on Consigli projects.

**Review Chapter 4 for more detail

Scaffold and elevated work platforms: All scaffolds/material hoist supported frame, pipe staging and baker staging will be inspected daily before each shift by a competent person designated by each individual contractor who will be using it. It will be documented on Inspection tags located at the stair tower/access point to each section. If installed a scaffold/material hoist inspection checklist will be completed prior to the beginning of each shift and filed in the site office.  This will be completed by the designated person from each individual contractor. They must complete an inspection every day the scaffold/material hoist is used by his/her employees.  A scaffold inspection guide will be provided to each designated person (upon request) by Consigli Construction to aid them with their inspection. All contractors who will erect scaffolds will provide CCC with Certification/Qualification of scaffold erection training as well as an erection/dismantling plan.  Fall protection is required 100% during erection/dismantling. Peery bakers are not allowed on this site. Overhead protection will be provided for all access points to any buildings located under any form of scaffolding/material hoist.

** Please review chapter 14 for additional details.  

Aerial/Scissor Lifts: Area and ground conditions in the intended work area will be inspected for overhead power lines, sink holes, covers, or any other unsafe condition which causes the potential for an incident.  Aerial and scissor lift platforms will be inspected daily before each shift by a competent person designated by each individual contractor who will be using it.  All contractors who will be performing work from an aerial lift will show documented proof of training for all workers who will be using said lift.  Workers will always be tied off  when using an aerial lift.

**Review chapter 24 for more detail

Global Harmonization: All Materials and chemicals used on-site will have a Safety Data Sheet (SDS)provided before being brought onsite.

  • SDS sheets on file in Consigli Construction’s Site Safety Plan
  • All SDS sheets shall be readily accessible.

** Please review chapter 20 for additional details.  

Fire Protection: A detailed NFPA 241 plan will be created for the project and updated as required.  All hot work to be conducted on this project will be done with the Consigli hot work permit program fully implemented. This will be coordinated through Consigli as well as the local Fire Department (if required). All hot work will stop one hour before the regular end of the day work stoppage.  20lb extinguishers of ABC rating will be positioned accordingly throughout the project.  Flammables will not be stored inside the building or left overnight on the scaffold.  All combustible or flammable materials will be stored in an appropriately rated lockable cabinet located no closer than 50 feet from the nearest structure. Fire department access will be maintained and kept open for emergency responders. Workers will always comply with NFPA 241 fire protection plan and NFPA hot work permit requirements .

**Review Chapter 17 for more detail.

Electrical: All electrical tools, cords and equipment must be in good working order. To that end, all electrical tools and components must be visually checked daily.  Any tools with damaged cords or damaged extension cords must be taken out service immediately. All cords must be equipped with a ground pin, flat three wire cords are not allowed.  SJO and SJT or other similarly rated cords only shall be used. Cords must be 12 gauge or better.  The electrician will be responsible for all temp power and any general temp lighting that may be needed. Subcontractors will be responsible for task lighting if lighting above the OSHA standard is required for a 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 will be conducted.

**Review Chapter 26 for more detail

Utility Exposures/Excavations:  Utility locations shall be determined by Dig-Safe and private survey as well as any “as-built” drawings prior to any excavation work conducted on the property.  The site contractor will assure that all utilities that enter site are cut and capped prior to any excavation activities. All required permitting will be obtained before any excavating is to begin, tabulated data/engineering for shoring and shielding systems will always be on site  when in use. Written excavation inspections will be done daily.

            1. Dig Safe Notification.

            2. City/town (dpw or town hall) or campus permits requirements if needed.

            3.  Jackie’s law permitting has been obtained.

            4.  All road plates the will be in pedestrian walkways will be slip resistant.

If an excavation nears identified utility lines, hand digging methods must be used to find the exact location of the utility in question. 

Confined Space:  A written plan will be needed to work in any tanks/vaults and crawl spaces during this project which have been designated permit confined spaces by CCC, this plan must include air monitoring.

** Please review chapter 21 for additional details.  

Designated First Aid Plan: All injuries must be reported to Consigli Site Safety Manager, regardless of severity.  CCC will then report all injuries to the Consigli Safety Director and Claims Manager. A fully stocked first aid kit and blood borne pathogens kit shall be maintained on the project site.  Only properly trained personnel will administer first aid.  A list of first aid trained personnel shall be posted in the office.

** Please review chapter 1 and 27 for additional details.  

Steel Erection: All workers working above 6ft must be protected from fall hazards by utilizing PFAS, guardrails, or wire rope guard rails. Any subcontractor associated with the structural steel erection will comply with the following. Provide proof of training of subpart R training as well as fall protection training for all workers will be required before start. Consigli will release documentation when column footings reach 75% of breaking strength.  Once this has been achieved, CCC will furnish to the steel erector the “approval to begin steel erection form”. 

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 will fall to CCC.

Evacuation Plan (RACE, and Routes of Egress): Please refer to the Evacuation Plans attached.  All contractors’ employees shall attend the Consigli Construction Project Orientation.  Consigli Construction’s Project Superintendent/Safety Manager shall conduct safety orientation training with each employee and project subcontractors.  Training will involve site specific safety and evacuation protocol.

Emergency Management Response: In the event of an Emergency the construction workers shall leave the site immediately. Point of assembly/muster shall be on the site 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

When reporting an emergency, please provide the following:

• Your location: phone number, and name:
• Site Address: 180 Third Ave. Waltham MA 02451

• 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.  

Restricted Areas:  Contractors are prohibited from entering any areas outside of the project unless work has been previously authorized and scheduled.  All workers must limit their impact on surrounding areas to the largest extent feasible.  All immediate deliveries will be made at Gate B, off Third Ave. Deliveries for stored materials will use laydown area at Gate G, 103 Fourth Ave. lot. 

Lean requirements/Materials Management/Housekeeping: 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 the building. Only materials which will be used/installed within three days’ time will be delivered to the site. All materials stored on site will be on dunnage, pallets (pallet jack must be on site), bins, pipe racks (on caster wheels). Trash barrels and bins must be readily available for all contractors to use. Generated debris and trash must be removed daily. Attention must be paid to structural analysis regarding loading existing floors with material and equipment.

**Review chapter 4 for more details

Back End of Site Safety Plan



Environmental Emergency Contact and Management Response

Environmental Issues: An initial soil pre-characterization was performed. Please refer to this document for more information on the initial soil testing. Appropriate dust control monitoring will be required.

IAQ (indoor air quality): If this project will occur in an occupied building, a baseline survey of the air quality will be completed.  Dust control, housekeeping, and frequent monitoring will ensure no impact on the air quality for the existing building occupants.  

** Please review chapter 29 for additional details

Asbestos: IT IS THE RESPONSIBILITY OF ALL SUBCONTRACTOR FOREMEN TO REVIEW THE HAZARDOUS MATERIAL REPORT & CORRESPONDING ABATEMENT REPORT WITH THEIR WORKERS.  A copy of the hazardous Material/abatement report will always be on site  and available upon request. All work and disposal will be done in compliance with state and federal regulations and standards. If any suspect building product is not identified on the hazardous materials report, follow-up sampling must be conducted.

Environmental Emergencies/Response:

Consigli’s identified Emergency Response Subcontractor:         

Name: Cyn Environmental Services, Inc. (781)341-1777

100 Tosca Drive, Stoughton MA 02072

Lead:  All Safety Orientations will include lead awareness and review of the hazmat report.

** Please review chapter 29 for additional details

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 cannot be used then a dustless vacuum system consisting of a HEPA dustless vacuum system will be used in conjunction with an exposure assessment if table 1 cannot be complied with. Prior to the project going full scale an exposure assessment of a worker grinding ,demolition and cutting masonry while using HEPA system will be done to establish the silica exposure level if water cannot be used to eliminate or table 1 complied with.  No respirators will be issued to CCC workers 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. A written exposure plan must be developed for all silica producing tasks that clearly defines the following:

 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.

Polychlorinated Biphenyl’s (PCBs):  Light ballast unless labeled “No PCB’S” will be designated PCB containing, All PCB containing material shall be removed and disposed of in accordance with all local, state (MEMEP Special waste management rules 06-096-CMR 400) and federal regulations. All other inquiries or locations about PCB containing material can be in the Hazardous Material survey. If identified on any of the materials to be impacted, PCB‘s will be abated. All PCB remediation will be performed by a licensed /qualified contractor

Mold: If mold is discovered, Consigli’s mold remediation policy will be implemented and followed.

** Please review chapter 22 for additional details

Noise:   Noise exposure will also be a concern, so all deliveries must be coordinated with the Superintendent to limit their impact on the surrounding areas.  Normal working hours will be between 7:00 am and 3:30 pm Mon-Fri.  Any contractor who may need to work late must first seek approval from the Superintendent. Consigli permissible noise policy and procedures will be followed.

** Please review chapter 29 for additional details

Heavy Equipment:  All operators will be required to have in their possession all appropriate licensing and training as required by OSHA and the Commonwealth of MA. 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 operator’s manual as well as an extinguisher with it at all times. All contractors with equipment on site must have spill-kits readily available in the case of an unforseen leak or spill.

** Please review chapter 24 for additional details

Adjacent Property: All efforts will be made to ensure that property and roadways adjacent to the work, area remains un-impacted.  It is anticipated that all work will be in the designated work areas within the site fence.  Any deviation from that will require consultation with the Superintendent. 

Exposure to Street Traffic: All immediate deliveries will be made at Gate B, off Third Ave. Deliveries for stored materials will use laydown area at Gate G, 103 Fourth Ave. lot (see attachment).

All speed limits will be obeyed, and deliveries will be made as to coincide with working hours. Fire dept. access will be maintained and kept open for emergency responders.

 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.

Additional Controls: Prior to start of any work, all personnel involved in the project, including project managers must be:

1. 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 worker will complete mandatory drug screening.

The SDS sheets associated with any hazardous substances to be used will be maintained by the superintendent in a marked three ring binder.

Site Safety Meetings will take place at the beginning of the project and at least once every week thereafter. These meetings will consist of toolbox talks with Consigli Construction Co., Inc. personnel on site. Sub-contractors will be responsible for their own safety meetings. Superintendent will complete a daily site safety walk to identify and correct potential hazards.

All emergency telephone numbers will be posted in the superintendent’s office and throughout the site.

Safety Spot Recognition Plan: The purpose of this plan is to instantly recognize workers “on the spot” for working safely and to reward those workers immediately. This will assist CCC reduce the complacency of workers on all projects. This shall be completed at a minimum of twice a week. It is required that different field staff take turns in issuing the cards to workers in the field. Also required will be the communication of who is recognized to other sub-contractors/workers through foreman meetings and daily stand ups.

Management Loss Exposures and Controls: Program implementation and management will be measured in Predictive Solutions Monthly Management Audit. Loss related exposures will involve, cuts, scrapes, and strains related to work being placed. Controls will involve use of gloves and materials handling equipment. Fall protection related hazards will be limited to working on roofs, scaffold, window openings, aerial lifts and access upper elevations.  This will be controlled through use of well-maintained and inspected PFAS, scaffolding and ladders as well as training on proper Aerial lift use. 

Fraternization between construction employees and project owners, staff, or visitors will not be permitted.  Loud and profane language or clothing with offensive language will not be allowed on the jobsite. Extra efforts must be made to keep noise to a minimum.

  • ZERO TOLERANCE for ANY damage caused to the building or its surroundings.





  1. 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.

  1. 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.    

  1. 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.

  1.   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 ensure 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.

  1. 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 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 always wear hard hats  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 always wear sturdy work boots and appropriate clothing (shirts with sleeves and long pants) .

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 always be required on site .

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 looks 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 Coniglio 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: 

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, 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:  THE POLICY


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 the applicant certifies, in writing, a willingness to comply with this Program.


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 consider 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:

  1. Possession of illegal drugs on the job or in a job status – Permanent bar from the project.
  2. Use of illegal drugs on the job or in a job status – Permanent bar from the project
  3. 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
  4. 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.
  5. 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.
  6. 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:

  1.  Pre-Placement / Pre-Employment.  
  2. Post-Accident: Any employee who is directly involved in an accident on  the job site or during 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 more than $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.
  3. 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 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.


  1. 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.

  1. 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.

  1. 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.

  1. 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 Sanofi – Parcel H Project’s Safety Manager.

  1. 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.
  2. 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


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

Fentanyl                                                          10.0 ng/ml                                    10.0 ng/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.

If 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.

  1. 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 enough 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.
  2. 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.
  3. 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.


This Substance Abuse Program may be amended, from time-to-time, in writing.

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