Site Specific Safety and Health Program

Project #2687 – US Navy Academy – McDonough Hall

102 U.S. Naval Academy, Annapolis MD 21402

Emergency Response Plan



This Emergency Response Plan (E.R.P.) is specifically developed for Consigli Construction work associated with the MacDonough Hall Project


The construction site is located U.S. Naval Academy, MacDonough Hall, Building 102 U.S. Naval Academy, Annapolis MD 21402.When determined, the field office will become the Emergency Operations Center (EOC).


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

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

Consigli Construction Company, Inc.

When reporting an emergency, please provide the following:

  • Your location, phone number, and name.
  • The location of the incident (building name, floor, and room number).
  • Nature and extent of the incident (injury, accident, spill, smoke/fire, damage, etc.).
  • The safest route to the incident

Crisis Response Protocol:

  • Attend to the injured
    • Immediately contact Bryan Kingsbury (508)808.9359
    • Post person at front gate, only allow access to emergency responders
    • Record names/addresses of witnesses
    • Do not allow media on site
    • Refer all media inquiries to home office (See “Crisis Response Cards”)

A Consigli designated individual shall wait at the building site entrance to escort Emergency Services personnel as they arrive.

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

Consigli Construction Company, Inc.

Back End of Emergency Response Plan

Emergency Contact Names and Numbers

Sr. Superintendant: Dean Archambault (508)958-0138

Sr. Project Manager: Steve Wood (202)236-6632

Project Executive: Chad Adams (202)578-2285

General Superintendent: Rob Soper (202)578-3702

Corporate Safety: Bryan Kingsbury (508)808-9359

SSHO: Dave Eddy (202)308-8547

ET: B.Graff/B. Herberger – (410)725-1570/(443)531-7293

CMs: C.Poet/LTJG Hague – (202)369-1173/(804)433-9302

Tom Trulli – (443)966-1561

*Whoever is reached first will call the NAVFAC Team in the order defined above. Repeated attempts will be made until the message can be relayed directly to a member of the team (voicemails/emails do not satisfy the requirement). Calls to NAVFAC should take place as soon as practicable, but no more than 24-hours after any accident and no more than 4-hours in the event of a Load Handling Equipment (LHE) or rigging mishap, and immediately in the event of a fatality.

Annapolis Police Department- Non-Emergency (410)268-9000
Annapolis Fire Department Station 35- Non-Emergency (410)263-7975
Anne Arundel County Dept. of Public Works (410)222-8400
  BGE Gas   (877)778-7798 or (800)685-0123
BGE Power (877)778-2222  

Environmental Consultant

Stanley Consultants


6836 Austin Center Boulevard Austin, Texas 78731

Back End of Emergency Contact Names and Numbers

Medical Facilities

Patients First Primary and Urgent Care-Annapolis (For injuries that do not require emergency care)

2051 West St. Annapolis MD 21401

Hours: 8am to 8pm Everyday. (443)603-0758

MedStar Health: Urgent Care at Annapolis (For injuries that do not require emergency care)

2114 Generals Highway Annapolis, MD 21401

Hours: 8am to 8pm Everyday (855)910-3278

Anne Arundel Medical Center

2001 Medical Pkwy, Annapolis, MD 21401

Hours: 24/7 (443)481-1000

Back End of Medical Facilities

Site Safety Plan

Emergency Response and Rescue

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 (410)293-3333. Project information for the call is –MacDonough Hall, Building 102, US Naval Academy, Annapolis MD. (Note: If calling from a cell phone you may be reaching the State Police and not the local emergency response)

A Consigli representative will be dispatched to the Main entrance of the building (or work area, as necessary) 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. Safety Data Sheets will be provided if needed by the Fire Dept. Upon mobilization, Consigli will reach out to EMS/USNA Fire Department to offer a tour of the site and a meeting to discussed plans and materials expected to be on site. If EMS/USNA Fire Department accept this offer, NAVFAC team will be invited to any such tour and/or meeting.

In the event of a serious injury requiring the assistance of EMS the injured worker will be kept as comfortable as possible. Emergency first aid, if necessary, will be administered.

Under no circumstances will the injured person be moved unless the worker’s life is in danger because of fire or calamity. A worker will be assigned to meet the medical personnel at the above location to direct them to the location of incident.

In the event an evacuation is required all personnel at this job site will follow the building/site evacuation plan and meet at the designated Muster Point located on the sidewalk on Second Street on the west elevation of the site. (See Exhibit B – Evacuation and Muster Plan). The foreman for each company will meet at that location and take a head count of their staff and report to Consigli Superintendent. 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 SSHO shall monitor weather, checking at least twice a day, prior to or upon arriving at the jobsite and at or around the mid-point of the day. If inclement weather where lightning, high winds, heavy rain, or snow is expected, the SSHO shall monitor the weather regularly. In the event of inclement weather, the SSHO shall advise Consigli’s on-site staff, who will work together to communicate to the contractor foremen in person or via telephone. The contractor foremen are then expected to communicate with each worker in person or via telephone. In the event of lightning which is within 10-miles of the construction site, all work using LHE’s, scaffolding or elevated platforms, and work on the roof or other open areas will cease. Workers will be directed to shelter inside the building until at least 30-minutes after the lighting is last within the 10-mile perimeter. High winds, heavy rain, and heavy snow may also require suspension of outside work activities. Decisions on sheltering in place in those situations, cancelling work, or making other accommodations will be made on a case- by-case basis by the SSHO, Consigli Superintendent and PM, and subcontractor foremen.

Consigli reserves the right to call for cancellation of work or shelter-in-place even if subcontractor foremen are opposed. Consigli will not countermand a call for cancellation of work or shelter-in-place made by a subcontractor foreman. Due to the nature of this project, the designated shelter-in-place location may change over the course of time. Designated shelter-in-place locations will be identified by signage posted in the locations assigned.

This Contractor Accident Prevention Plan describes the procedures to be used by Consigli Construction Co., Inc. to minimize potential risks to Consigli and subcontract personnel performing construction activities at MacDonough Hall.

This Plan has been developed in accordance with the requirements of:

  • Occupational Safety and Health Act (OSHA) Standard 29 CFR 1926.- “Safety and Health Regulations for Construction”.
  • Occupational Safety and Health Act (OSHA) Standard 29 CFR 1910.120 “Hazardous Waste Operations and Emergency Response”; and
  • U.S. Army Corps of Engineers Engineering (USACE) Manual 385-1- 1, November 30, 2014, Appendix A.

This Plan applies to project team personnel, including personnel from Consigli, subcontractors, and authorized Site visitors who may potentially be exposed to safety and/or health hazards associated with the site activities.

It is the responsibility of Consigli to make this Plan available to project field personnel, subcontractors, and authorized Site visitors. A copy of the Plan will be maintained on Site during the field implementation phase of the project. Employees engaged in site activities will be instructed in the requirements of this plan to ensure that the work is performed safely and within the prescribed task sequence. Consigli is committed to the health and safety of all workers on our jobsite.

Chapter 8 of Consigli’s Corporate Safety Plan may be referenced for general policies for emergency preparedness (see Exhibit N). The above information is specific to the MacDonough Hall project. A copy of the Corporate Safety Plan will be kept on-site for reference. Where the Corporate Safety Plan may differ from this Site-Specific Accident Prevention Plan, the Site-Specific Plan will supersede the Corporate Plan.

Project Posting Information

Consigli will maintain the Site-Specific Accident Prevention Plan information in the jobsite trailer. Additionally, a Safety and Occupational Health (SOH) Bulletin Board will be posted in a commonly accessible area though protected from the elements and unauthorized removal. The information will be posted in clear view and include:

  • Map showing the route to the nearest hospital (pages 5-7 above)
  • Emergency phone numbers – Emergency planning will be coordinated with on-site personnel and off-site municipal emergency support (pages 2-4 above)
  • Location of the Contractor Accident Prevention Plan – The Contractor Accident Prevention Plan will be reviewed and modified as necessary during execution of the project to address changes in Site conditions, operations, or personnel. An up-to-date version will be available at the site. The SOH will clearly identify where this printed copy of the plan can be found in the Consigli Trailer.

  • Location of Current Activity Hazard Analyses – The Activity Hazard Analyses will be reviewed and modified as necessary during execution of the project to address changes in Site conditions, operations, or personnel. The SOH will clearly identify where the current AHA’s can be found in the Consigli Trailer.
  • Location of Current SOH Deficiency Tracking Log in the Consigli Trailer.
  • Location of the Current Hazardous Material Inventory in the Consigli Trailer.
  • Current Confined Space Entry Permit (if applicable).
  • Current Hot Work Permit(s).
  • Current OSHA 300A Summary of Work-Related Illnesses and Injuries (Exhibit D).
    • Form 300 will be a living document maintained by the SSHO. It will be made available to NAVFAC upon request.
  • Number of hours worked since last lost workday accident.
  • Date of last lost workday injury and date of last OSHA recordable injury.
  • OSHA Safety and Health Protection-on-the-Job Poster.
  • Safety and Health Warning Posters.
  • No-Smoking Sign.

EM 385-1-1 REQUIREMENTS: Consigli acknowledges that it is familiar with the US Army Corps of Engineers Safety and Health Requirements Manual as published November 2014. The subcontractor hereby agrees to conform with the requirements of EM 385-1-1 and/or OSHA whichever requirements are more stringent. All EM 385-1-1 report of injury/incident/equipment/rigging/ etc. forms will be used. All workers will cease any and all activities and face the flag raising ceremony every day at 8am without exception.

This Accident Prevention Plan is a living document and will be updated throughout construction. Changes to this plan will be initiated by the Site Safety and Health Officer and must be confirmed by the Superintendent and Quality Control Manager before incorporation into this plan. When revisions are made, an updated submittal shall be sent to the Government and a recap of change(s) publicly posted on the Jobsite Safety Board for a period of no less than fourteen (14) days. An updated copy of the APP will be available on site in the Jobsite Trailer. All subcontractor foremen shall be provided access to, and will be expected to be familiar with, the Site-Specific Accident Prevention Plan. The SSHO will provide and maintain a log of signatured by each subcontractor foreman, attesting that they have read and understand the APP. The SSHO will ensure the current version of the APP, along with this log, is available is a clearly identified location for use by any subcontractor and NAVFAC.


Project Background: MacDonough Hall, on the campus of the US Naval Academy, was originally built in 1903. It has been renovated several times, with the most recent renovation in 1982. The building is used as a center for the Physical Education Department of the Academy and supports boxing and swimming among other sports. Additionally, the building houses some offices and is the center for Physical Readiness Testing of midshipmen preparing to take on their roles as Navy and Marine Corps Officers.

Scope of Work: The project includes selective demolition of the existing pool and deck (including underslab rail system), all MEP’s, and parts of the Fire Protection system. Additionally, there will be demolition of some slab on grade, slab on deck, and walls along with select partitions and doors. Abatement activities must be coordinated with demo activities and will include removal and safe disposal of asbestos (pipe insulation, fire doors, tile, mastic), mercury (poured floor system), lead paint (all paint is assumed lead), mold (ACR, brick), and PCS’s (light ballasts and lamps). In addition to demolition and abatement, there will be salvage of operable partitions, A/V projectors and screens, basketball hoops, and in-place protection of one boxing ring.

Structural work includes new helical piles, foundations, a steel structure, and slab on deck supporting the 2nd level fitness area. Other new work includes new steel structures at the 3rd level for foam pits and mezzanine. Reinforcement work includes the strengthening of hanging rods and precast planks at the historic to remain pool mezzanine. Modifications of the mechanical penthouses to support the new HVAC units and new lintels where larger openings in the existing structure must be made to accommodate the MEP’s. There will also be a brand-new pool and pool equipment installed.

MEP’s will be almost completely new while tying into some existing services. This includes new sprinklers for the existing service; new plumbing systems to connect to existing sanitary and water connections; all new HVAC systems, ductwork, and controls; power and lighting systems connecting to existing service (new panels and subpanels); a new fire alarm and fire alarm control system; new low voltage systems (telephone, data, and paging systems) while retaining existing CCTV and A/V.

Interior scope includes new CMU and GWB partitions. New doors, frames, and hardware (reuse of select elements) and fire shutters. New interior glazing, metal screens, metal railings, flooring, tile (walls and floors), paint walls and exposed roof trusses, minor casework, specialties, bleachers and reinstallation of operable partitions, some lockers, exercise equipment, and FF&E currently stored in Dahlgren, Halsey, and other on-campus locations).

Exterior SOW includes the restoration of the historic masonry façade, doors and windows (off-site) and window frames. Additionally, there will be repairs made to the historic copper roof, and replacement of the translucent panels at the clerestory. There is limited site work to Consigli Construction Company, Inc. include replacing the concrete at the entrance and installation of an ADA ramp, replacement of mulch, and new bike racks installed.

Purpose: The purpose of this Site-Specific Accident Prevention Plan 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 ensure 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 strategy behind Consigli’s drive to our safety goal – 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.

Lines of Authority: It is Consigli policy that all Consigli employees are responsible for safety. To that end, any Consigli employee has the right, and the responsibility, to stop work in the interest of safety. On this project, the SSHO shall be responsible for all safety-related paperwork and preparations. They shall be responsible for tracking the SOH Deficiency Log, AHA’s, Competent Persons (and qualifications), as well as regular safety inspections and hazardous weather monitoring. The Superintendent shall assist with safety inspections and will partner with the SSHO during Safety Preop meetings. The QC Manager shall likewise participate in reviewing paperwork and work plans for completeness and adherence to the specifications. When performing in-field inspections, they shall also keep an eye out for any safety concerns they may encounter. The Project Management team (PM, APM, PE) shall be responsible for a daily safety walk. If they see any items of concern, they may elect to address it directly or may elevate it to the Superintendent and/or SSHO if the issue seems systemic or if they are unsure of the best way to address a concern.

Accountability is important to ensuring safety remains a top priority. Project teams are sent periodic analyses of how well they are doing at meeting the requirement of making at least one safety observation a day. The safety scores from Predictive Solutions are automatically included in the monthly report the project team must present to Consigli Executives. Low scores, or scores that are trending down, must be addressed by the project team. If a project receives a monthly aggregate score of less than 96%, the team must generate a safety improvement plan with actionable items to lead to improvement on the job. The Executives follow up on this at the monthly presentations as well. Additionally, in the case of a near miss or accident on site, the Superintendent is responsible for writing an “It Happened to Us” report to be shared company wide as a lesson’s learned for all teams. The project team is also responsible for a root-cause analysis which is utilized in the “It Happened to Us” report and in the safety improvement plan.

Badging Requirements: Academy access badges/sign in will be obtained/completed by all identified key personnel prior to working on this project, as needed. Badges will be worn so they are visible at all times. All personnel will comply with Academy security requirements. Prior notification and authorization will be required for work impacting occupied spaces.

Site-specific Safety Orientation: All persons working on the jobsite, whether in the field or in the office, shall be required to undergo on-site safety orientation. This orientation will include all emergency evacuation procedures, including introduction to the location of the muster point. All persons who have completed the on-site orientation shall receive a numbered hard hat sticker that confirms they have been orientated. They will also sign a form acknowledging that they will abide by the safety protocols of the site.

In addition to this orientation, workers shall participate in evacuation drills during Consigli’s annual Safety Week to ensure the plans are effective and efficient. The SSHO or Site Superintendent may elect to hold additional, unannounced, evacuation drills at any time.

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 Consigli’s Superintendent’s Incident/Accident Report and the Government provided Contractor Incident Report System (CIRS) form and attend the post incident review 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. An incident that does not cause a recordable injury (a “Near Miss”) will require a project team member to fill out Consigli’s Near Miss It Happened to Us form, which is reviewed with all workers on site and distributed company-wide and NAVFAC’s Initial Contractor Mishap Notification Report. A copy of each of these forms is included in Exhibit C and will be made available in editable format to all parties.

Safety Qualifications of Subcontractors: All potential subcontractors are required to pre-qualify prior to being hired for the project. This pre-qualification includes a review of their safety record and collection of their EMR and DART rate (Consgili utilizes the Pantera Software). EMR’s above 1.10 and DART rates above 3.4 require Contracting Officer special consideration and acceptance. All sub-tier subcontractors will also be required to meet these thresholds. Written requests for additional considerations to the Contracting Officer shall be considered on a case-by-case basis and Consigli nor its direct subcontractors shall not assume a subcontractor will be approved until the CO makes their decision. Consigli will keep records of subcontractor EMR and DART rates and shall provide them upon request to the Government.

Subcontractors and suppliers are required to provide all PPE for their workers on site. They are also required to provide safety training to their employees and training for Competent Persons in order to maintain their credentials. Subcontractors are responsible for providing a site and work-specific AHA to be reviewed with all workers and submitted to Consigli and NAVFAC. Some subcontractors have additional safety plans depending on their particular scope of work. Subcontractors responsible for these plans shall be required to include any certifications and mandatory training required for such work.

If a subcontractor has a safety incident on site, they are required to hold a safety stand-down with Consigli and encouraged to do an additional stand-down with their whole company. A review of the AHA, and revisions, if necessary, are a part of this stand-down. Additionally, Consigli reserves the right to have a subcontractor’s Safety Officer come to the site for a meeting, investigation, or the like or to require a subcontractor to hire outside safety support to ensure their field teams are working safely.

Contractor Orientation: Along with the review of Academy security requirements and Consigli Site Specific Safety Orientation, all workers on-site will also be required to attend Consigli construction worker orientation. As part of the orientation, workers will be reminded that no work may take place on site without a designated Competent Person and/or the SSHO being on-site and that this is a non-smoking workplace. Subcontractor foremen shall be provided a copy of this Site Specific Safety plan for their review and acknowledgement. All workers shall be informed of the location of this plan and shall be encouraged to review the plan at any time.

Safety Violations Management: All workers will have the safety violations management system explained to them during orientation. All safety violations are documented in Consigli’s project management software, Procore. When a violation occurs, the worker is asked to ameliorate the condition and a record is generated in the daily log within this software. The logged items are sent to the company office for the contractor involved. A second violation will be logged if the offense is repeated and the worker with the repeat violation will be sent home and no longer allowed on the jobsite. We reserve the right to dismiss anyone for a safety violation at any time. For a copy of the site-specific safety orientation, please see Exhibit E. The Site Safety and Health Officer will perform weekly safety inspections utilizing the Predictive Solutions software. Any open violations from Procore shall be incorporated in the weekly Predictive Solutions report. The report from Predictive Solutions will be the official Safety and Occupational Health Deficiency Tracking Log.

Traffic Control: For this project all deliveries and waste removal shall enter using designated access point and be coordinated with the General Contractor. Also, only permitted truck routes will be used, all contractors will be responsible for adhering to truck routes and restrictions plan which will be made available to all sub-contractors. The Traffic Control plan has been submitted under separate cover. Copies of the approved plan will be made available to all subcontractors prior to their mobilizing to the site.

Personal Protective Equipment (PPE): All workers will wear hard hats, safety glasses, appropriate safety shoes, and a Class II hi-vis clothing/vests at all times (Class III if exposed to vehicular traffic). All personnel performing work with their hands shall be required to wear gloves that are appropriate to the task. When not performing actual work with their 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. Hearing protection shall be worn in areas where noise levels exceed 90 DBA, where exposure to 85-90 DBA exceeds (8) hours per day, where 140 dBA impact levels are expected, or where posted. Double protection shall be required at 115 dBA continuous levels. Failure to wear hearing protection when required may result in a $500.00 fine for each violating employee, assessed to the Subcontractor. Respiratory protection will be required if conditions on site reach the following exposure limits

Additionally, silica exposure that cannot be controlled with engineering and work practice control methods, shall follow OSHA 1926.1153 Table 1 guidance on respiratory protection. Some materials may also require respiratory protection, which would be noted in their SDS/MSDS forms. Whenever any subcontractor’s work will expose workers to a respiratory exposure requiring protection, they will be required to submit a Respiratory Protection Plan which shall meet the requirements of EM385-1-1 05.G.03 as part of their pre-mobilization safety planning. This shall be submitted to Consigli and, once approved, to NAVFAC and will be reviewed during the safety pre-op meeting. It shall be incorporated into the subcontractor’s AHA’s and reviewed with all workers at the start of each activity.

Designated Work Hours: 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. Any work required prior to 7 am, after 5 pm, on the weekend or a Federal Holiday will need to be requested fifteen (15) calendar days in advance to the Contracting Officer. Any such requests will need to be accompanied by the specific dates, hours, locations, type of work to be performed, contract number and project title, and the justification for the request. Utility cutovers are expected to require an off-hours request to the Contracting Officer. Though unlikely, an FMP shall be required whenever work hours exceed 10-hours a day for more than 4 consecutive days; exceed 50 hours in a 7-day workweek; exceed 12-hours a day for more than 3 consecutive days; or exceed 58-hours a week for sedentary work, to include work in the office. All deliveries must be coordinated with the CCC superintendent with at least 48-hours’ notice.

Exposure to the Visitors, Staff, and Students: During all phases of construction, the adjacent buildings and pedestrian will be open and occupied. Some areas of project will be under construction at different times; the phasing plan must be followed by all workers. Access routes used by the workers for moving materials and debris will be communicated to the workers and naval authorities and updated as needed. At no time is any worker allowed to enter any of the adjacent occupied spaces unless they have received approval from CCC. Non-fraternization with staff, visitors, public or midshipmen will be stressed with all subcontractor personnel during orientations.

Activity Hazard Analysis (AHA): An AHA shall be prepared for each Definable Feature of Work to be performed (see Exhibit F for the DFoW list for this project and a sample AHA). If a contractor is performing multiple, related DFoW’s, for example demolition and pool shell demolition, a combined AHA for all related work may be provided. If multiple subcontractors are performing activities that fall under one DFoW, each subcontractor must provide its own AHA. The AHA shall be submitted to Consigli’s SSHO 20 workdays prior to the start of work. The Subcontractor’s Foreman and Competent Person (if different than the Foreman) must sign the AHA prior to submission. A subcontractor may list multiple Competent Persons, but qualifications must be provided for anyone so listed. A qualified Competent Person must be present, on site, whenever the activity is being performed. Consigli’s SSHO, Superintendent, and QC Manager shall all review, approve, and sign the AHA prior to submittal to the Government. The Government shall be given 15 workdays to review the AHA. Consigli will also list the Designated Representative for the activity represented by the AHA who will be responsible for safety if the SSHO is absent for a period of not more than 24-hours during the task. If the SSHO will be absent for longer than 24-hours, the Alternate SSHO will be responsible for all duties normally carried out by the SSHO. No work shall take place without either the SSHO, Designated Representative, or Alternate SSHO being present on the job site and aware that work is happening.

AHA’s shall be reviewed at the Safety Preconstruction meeting. Safety Preconstruction Meetings will not take place without an approved AHA. No work shall take place without a Safety Preconstruction Meeting. Additionally, the AHA shall be reviewed with personnel involved in performing that particular task and signed by all workers, including their supervisor. A copy of the signed and dated AHA must be filed in the CCC field once completed. Construction activities, materials, and special equipment use requiring AHA’s are identified in the following pages. The subcontractors for the following DFoW’s/Activities are not known at this time, but additional information will be submitted to the APP for acceptance prior to the start of any activities listed. AHA’s shall be made available to all other subcontractors whose workers will be exposed to the dangers involved. Work shall be sequenced to minimize impact of one subcontractor’s work on the employees of another subcontractor. Hazards that may impact multiple subcontractors shall also be discussed at the daily stand-up meeting held by the Superintendent and attended by the SSHO whenever possible.

Once a week, while the activity covered by an AHA continues, the subcontractor must review the contents of the AHA with all workers. They must provide a dated copy of the AHA signed by all workers that week. Alternately, as long as the activity continues to follow the AHA precisely, a JSA signed by all the workers may be submitted instead. It is the responsibility of the subcontractor’s Competent Person to ensure that any new workers to the job are familiarized with the content of the AHA on their first day on the job. Subcontractors should not wait until the weekly review to do this. During work, if the work activity changes in any way, or if the hazards change for any reason, a new/revised AHA shall be submitted and reviewed with Consigli, NAVFAC, and the subcontractor’s workers.

Hazardous Materials Tracking Log: Any materials which may be considered hazardous must have an MSDS on file prior to being brought onto the jobsite. Consigli has submitted a preliminary “Contractor Hazardous Material Inventory Log” under separate cover with general materials we expect may be on this jobsite. As submittals are approved, additional materials will be added to the log and MSDS will be collected. The log and all MSDS will be available in a clearly marked location in the Consigli trailer. This will be accessible to both NAVFAC and any worker on site. It is the right of every person on the jobsite to review the MSDS for any material they may be exposed to during their work. The Hazardous Material Inventory Log shall be organized by subcontractor. Wherever one or more subcontractors use the same material, the material will be listed on each subcontractor’s Log. The current Log and MSDS shall be formally submitted to NAVFAC at least once a year, no later than January 31st. 30-days prior to final acceptance, a final submission will be made that also includes the maximum quantity of the material present at any one time, the dates the material was present, the amount of material used on the project, and how the material was used.

Temporary Facilities: The Site Logistics Plan, submitted under separate cover, identifies the location of all temporary facilities to include Consigli’s field trailer, site fencing, dumpster locations, etc. A copy shall be included in this plan once finalized. All pre-engineered trailers, whether used for office space or storage shall be anchored to the ground in such a manner that they resist expected wind loads. Any job-built storage facilities shall consider dead/live loads, soil and hydrostatic pressures, wind, rain, snow, flood, and ice loads, and seismic forces. Temporary fences shall be 6’ tall with openings of less than 2”. Support shall be provided such that they remain rigid/taut when a minimum of 200lbs of force is exerted on the fencing with a acceptable deflection of less than 4”. Construction area signage shall be posted at regular intervals (not more than 150’ apart) on the fence to warn the public of construction dangers and requiring unauthorized persons to remain outside the construction area. Examples of some of the signage commonly used appears below.

Demolition: Prior to the start of any demo operations, the contractor preforming demo will confirm that all utilities leading into the area have been made safe. The electrician will disconnect and lock out all electrical, the plumber will do the same with any plumbing lines, and the HVAC subcontractor will do the same on the HVAC piping and duct work. Lock out/tag out will be reviewed during the pre-construction safety meetings to ensure disconnect and responsibility for protection of existing utilities is understood by all parties. Prior to any demolition requiring a utility outage (rather than a localized shutdown), the Utility Outage Request Procedures per 01 35 26 -3.2 and 3.3 shall be followed. No utility outage shall take place without NAVFAC outage request approval. All utilities will be made safe prior to any

construction activities commencing. In spaces where some electrical or mechanical must remain live, a color-coding system will be utilized for easy identification of live utilities that must stay active and utilities that must be removed. All utilities spray painted Red are not to be touched and/or need to be protected during all operations. Utilities spray painted Green are to be removed as part of the selective demolition process only after lock-out/tag-out has been confirmed and utilities tested. If any utilities are unmarked, they shall be considered live (red). The demo contractor will be responsible for completing CCC demo checklist prior to the start of any work in their target areas (see Exhibit G for this checklist). During demolition and construction activities all personnel will wear all required protective equipment. Engineering controls will be used for any activity which may create dust. A written Demolition Plan shall be submitted by the subcontractor performing the work under separate cover. This plan must include the training and certification requirements for workers.

Fall Protection

All workers exposed to a fall of 6′ or greater shall be protected by guardrails, safety nets, or personnel fall-arrest systems. These tasks include, but are not limited to, steel erection, roofing, scaffold erection and dismantling, overhand brick laying and pre-cast concrete related work. Holes greater than 2” will be covered with acceptable material (3/4 plywood or ½ steel) which will be secured and marked “hole”. Material used must be capable of supporting 2x the intended load (cover must be able to withstand 2x times the intended axle load). Covers will stay in place until the hole/penetration has been filled with duct or pipe riser which extends above the deck. Building perimeters where the façade is removed are to be protected with a cable guard rail system with turnbuckles to be installed for all straight runs. Before any work is to begin on the roof it must be determined which method of fall protection will be implemented All workers working on a roof with a slope greater than 4 to 1 and exposed to a fall greater than 6 feet will have fall protection 100%of the time spent in this location. Workers on a roof with a slope less than 4 to 1 may put flagging (six feet for roofers-15 feet for everyone else) lines up, whenever roofers and any other trade are on the same roof then the flagging must be pulled back to the maximum distance. All subcontractors will be responsible for barricading/taping off areas below their elevated work. The use of safety Monitors is not allowed!!! Each subcontractor shall be responsible for providing a written Fall Protection Plan for their employees. This plan shall also be incorporated into their AHA’s. This plan must include the training and certification requirements for workers. Fall Protection Plans meeting the requirements of EM 385-1-1 21.D shall be submitted under separate cover.

Chapter 13 of Consigli’s Corporate Safety Program contains information on filling out forms used by subcontractors to track their fall protection equipment inspections and the rare process of allowing fall protection to be temporarily removed.

Work on Ladders: All work on step ladders/straight ladders will be done correctly per manufacturer’s recommendations. Any worker who is 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.

Roof Work: Before any work is to begin on the roof it must be determined what sections of the roof will be worked and what method of fall protection will be implemented. Attention will be paid to any access points located below elevated work. If present, they will be protected. Consigli requires 100% tie off, installation of guard rails, or flagging. The use of safety monitors is not allowed.

Scaffold, Shoring, Elevated Work Platforms & Material Hoists: All scaffold, elevated work platforms, and 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. Signature will be documented on inspection tags located at the stair tower/access point to each section. Toe boards are required on all fixed scaffolding. If installed, a scaffold/material hoist inspection checklist will be completed prior to the beginning of each shift and filed in the site office. The designated person from each individual contractor must complete an inspection every day that the scaffold/material hoist is used by their employees. A scaffold inspection guide will be provided to each designated person (upon request) by Consigli Construction to aid them with their inspection. Shoring shall be inspected prior to erection to ensure the equipment meets the requirements specified in the engineered formwork drawings. Defective equipment shall be removed from the jobsite. Drawings must be submitted for review and approval prior to erection. A detailed work plan for both erection and removal of shoring must be provided by the contractor. This plan must include the training and certification requirements for workers. Shoring may not be removed until the Competent Person signs off.

All contractors who will be erecting scaffold 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. Overhead protection will be provided for all access points to any buildings located under any form of scaffolding/material hoist. Guard rails required at four feet on all mobile scaffolds. Any mobile scaffold with a work platform to base width ratio greater than two to one will need outriggers. Corporate policies with regards to the erection and use of scaffolding provided by Consigli, and scaffolding provided by contractors for their own use is available in Chapter 14 of the Corporate Safety Program. These policies meet or exceed OSHA requirements.

Aerial/Scissor Lifts: Area and ground conditions in the intended work area will be inspected for overhead power lines, underground structures/sink holes, covers or any other unsafe condition which cause an incident. Aerial lift platforms/scissor lifts will be inspected daily before each shift by a competent person designated by each individual contractor who will be using it. This inspection will be documented on inspection tags for each individual piece, filed in the site office. All contractors who will be performing work from an aerial lift will show documented proof of training (MEWP A92) for all workers who will be using the lift. Steel plates or equipment mats will be placed on the ground above any utility/ steam tunnel/underground vault if there will be Aerial lifts operating on them. Workers will be tied off with a lanyard at all times when using aerial and scissor lifts. Self-Retracting Lifelines (SRL) are not permitted to be used on lifts.

Fire Protection and Prevention: Fire protection that is not slated for demolition will be protected during work. Sprinkler heads will be turned up when the ceiling is removed, and the existing smoke detectors will be replaced with heat detectors. Limited hot work is anticipated, and efforts will be made to reduce the need for on-site hot work. For any hot work which is required, the Consigli hot work permit program will be implemented. A Hot Work Permit (see Exhibit H) will be required for this project. Permits may be provided daily, weekly, or monthly depending on the tasks to be completed and the discretion of the on-site safety personnel. This will be coordinated through Consigli Construction, building staff and the USNA Fire Department.

When planning hot work, EM 385-1-1, the contract specifications, and the Hot Work Permit shall all be reviewed with regards to the specific work. Whichever is most strict will be followed. All hot work will stop one hour before the regular end of the on-site work. A fire watch (trained in NFPA 51B) will be assigned during this time. Flammables will not be stored inside the building or left overnight on the scaffold or in the building. All combustible or flammable materials will be stored in an appropriately rated, lockable cabinet located no closer than 50 feet from the nearest structure.

At least two (2) 20-pound 4A:20 BC rated fire extinguishers shall be present at the site of normal hot work. Extinguishers must be under a current inspection and must contain their safety pin and tamper resistant seal. Fire extinguishers will be provided for every 3,000 square feet. They will be installed on job-made stands and conspicuously located throughout. At no time shall a fire extinguisher be used as a door stop, weight, or for any purpose other than designed. They will be part of the daily inspection with extinguisher log completed monthly (see Exhibit I for this log). Storage of any acetylene cylinders will be done in a secure and upright area, with good ventilation. This will be a strict no smoking project. All penetrations leading outside of the construction area will be fire stopped using approved fire rated material prior to the end of each shift. All workers who pull a Hot work permit with CCC in the states that require an NFPA hot work permit will need to provide it. Additionally, common sense efforts such as checking on electrical equipment, including cords, maintaining good housekeeping, proper refueling procedures, and fire watches shall be implemented. Report any fire, no matter how small, to the responsible USNA Fire Department immediately.

Electrical: The electrician will be responsible for all temporary power and any temporary lighting that may be needed. There are no overhead power lines in any of the intended work areas. All electrical tools, cords and equipment must be in good working order. To that end, all electrical tools and components must be visually checked on a daily basis. Any tools with damaged cords or damaged plugs 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. Subcontractors will be responsible for task lighting if needed for a particular work task. The electrician will coordinate all lock out/tag out procedures. All temporary power for the project will be installed on protected and dedicated circuits with 100% GFCI protection. GFCI will be tested by the electric contractor to assure proper function with a logbook filed with CCC monthly. No live electrical work will be conducted. Arc Flash Hazard Analysis shall be the responsibility of the Electrical contractor. Once completed, it will be submitted under separate cover. This plan must include the training and certification requirements for workers.

Hazardous Energy Control Plan: There are two types of energy isolating devices: those capable of being locked (lock-out) and those that cannot be locked out (tag-out). Lockout is a more reliable method of de- energizing equipment than tag-out and is the preferred method. When, however, the energy- isolating device cannot be locked out, subcontractors can, after consultation with Consigli, adopt the use of a managed tag-out system.

  •   Electrical/Mechanical/Equipment Subcontractors are responsible for planning a deliberate energy control program to ensure that machines and equipment are isolated and inoperative before any employees perform servicing or maintenance. This plan must include the training and certification requirements for workers. They shall also be responsible for Periodic inspections to assure that energy control procedures (locks and tags) continue to be implemented properly and that employees are familiar with their responsibilities under these procedures. The project Superintendent shall certify that the periodic inspections have been performed.
  • Consigli Superintendent to be included in all electrical coordination issues.
  •   Subcontractor Supervisor/Foreman is responsible for training their personnel, and all peripherally affected personnel working for Consigli, NAVFAC, or other subcontractors, on dealing with the equipment, type(s) of energy, and hazard(s) specific to this particular jobsite. All training shall be documented and signed by attendant employees.
  •   Retraining shall be required when there is a change in job assignments, in machines, when there is a change in the energy control procedures, or a new hazard is introduced.

  •   Supervisor/Foreman will be responsible for obtaining the appropriate lock-out- tag- out devices.
  •   Authorized Employee is responsible for implementing the energy control procedures, installing locks and tags and performing the service or installation. Each Authorized Employee shall have his/her name on locks/tags accordingly.
  •   Authorized Employees have primary responsibility for a set number of employees working under the protection of a group lockout or tagout device.
  •   Affected Employee/Other Employees: Responsible for recognizing when the control procedure is being implemented and understanding the purpose of the procedure and the importance of not attempting to start up or use the equipment that has been locked or tagged out.

Procedures for shutting down specific pieces of equipment (pumps, boilers, air handing equipment, etc.) are only to be done by approved and competent subcontractors working for Consigli Construction Co., Inc. Installation, start-up, and servicing are outlined in the Installation and Operation and Maintenance Manuals that accompany each piece of equipment at shipment and should be followed. Additionally, work that involves the transmission and distribution systems for gas, steam, water or petroleum products need to be part of all discussions regarding lock-out/ tag-out as well. The procedure for applying energy controls by contractors includes the following elements and actions that need to be planned and implemented in sequence:

  • Preparation for shut down.
    • Shut down of energy to any machine or equipment.
    • Application of the lockout or tag out device by responsible contractors
    • Assuring all stored or residual energy is released safely
    • Verify the location and de-energization of the machine or equipment.

Before lock-out or tag-out devices are removed, the Authorize Employee(s) shall take the following actions or observe the following procedures:

  •   Inspect the work area to ensure that non-essential items have been removed and that machine or equipment components are intact and capable of operating properly;
  •   Check the area around the machine or equipment to ensure that all employees have been safely positioned or removed;
  •   Notify all Affected Employees immediately before removing locks or tags and before starting equipment or machines
  •   Make sure that locks or tags are removed ONLY by those employees who attached them.

  •   Follow the manufacturer’s start-up procedures outlined in the Installation Manuals and Operations and Maintenance Manuals which accompany each piece of equipment at shipment.

Lighting Evaluation: Proper illumination of workspaces & project sites is imperative to a safe working environment. It is significant in the prevention of slips and falls. A review of the lighting requirements for specific tasks or operations shall be evaluated as part of the activity hazard analysis (AHA) provided by each subcontractor for the activities on site.

Lamps and fixtures will be guarded and secured to preclude injury to personnel. Open fluorescent fixtures will be provided with wire guards, lenses, tube guards and locks, or safety sockets that require force in the horizontal axis to remove the lamp. Additionally, lamps for general illumination shall be protected from accidental contact or breakage.

  • Protection shall be provided by elevation of at least 7 ft (2.1 m) from normal working surface where possible, suitable fixture or lamp holder with a guard.
    • Open fluorescent fixtures will be provided with wire guards, lenses, tube guards or other means to prevent damage to the bulb.
    • Lighting levels shall be as follows:

Bulbs attached to temporary lighting strings and extension cords shall be protected by guards unless the bulbs are deeply recessed in a reflector. Additionally, unless designed for suspension, temporary lights shall not be suspended by their electric wire. Any exposed empty light sockets and broken bulbs shall be replaced immediately, and portable electric lighting used in wet and/or other conductive locations (e.g., drums, tanks, vessels, sumps, scroll cases, etc.) shall be rated and operated at 12 volts or less.

Non-metallic sheathed cable may be used as allowed by the NEC and as follows:

  • Along studs, joists, or similar supports closely following the building finish or running boards when 7 ft-8 in (2.3 m) or more above the floor;
  • When firmly attached to each cabinet, box fitting, or fixture by means of a cable clamp.
  • Non-metallic sheathed cable may not be used when precluded by the NEC nor as portable extension cords, lying on the ground subject to any type of traffic, where subject to frequent flexing, or as service entrance cable.

Temporary lighting circuits shall be separate from electric tool circuits. Receptacle circuits shall be dedicated to either temporary lighting or electric tools and shall be labeled “LIGHTS ONLY” or “TOOLS ONLY,” as applicable.

Utility Exposures: MacDonough Hall does not have any overhead power lines to work around. All sidewalks will be protected if equipment is to be driven over them. All existing concrete slabs will be scanned prior to any task (drilling, chipping, sawing, etc.) that may impact them. The unit used for scanning uses radio waves to identify the location of rebar and/or any other embedded items in the slab.

Crane: There will be some tasks that require the use of a crane onsite during the course of the project. Crane work plans must be submitted to the CCC Safety Department prior to crane mobilization on-site. This plan must include the training and certification requirements for workers. Upon review and approval, it will be shared with NAVFAC for their review and approval. All crane plans shall be submitted under separate cover. This work plan must also include the FAA criteria letter of determination with regards to crane proximity to flight lines/helipads. Up to date DOT health card, NCCCO or equivalent certificate, evaluation letter, rigging and hand signaling certificates. assemblymen and assembly plan are required for all crane operations. All picks are to be done by a licensed operator. As previously mentioned, a detailed pick plan will be required to ensure that no picks are critical in nature. Critical picks are defined as those involving 2 cranes lifting simultaneously, a pick that is over 75% of capacity, a pick that involves the lifting of a man basket, over an occupied area or any other lift that is deemed to involve special conditions. Location and set up will be reviewed with crane operator prior to set up and pick. All lifting operations will require that the operator and any involved contractors follow the steps listed below as well as in CCC Crane Safety policy.

  1. All Hoisting equipment will have an up-to-date 3rd party inspection certificate with the equipment. This will be copied and filed in the office trailer.
  2. All lattice boom cranes will have an independent 3rd party inspection completed each time one arrives on the project, during assembly, and prior to operation.
  3. All equipment operators will be required to have in their possession all appropriate licensing and training as required by OSHA and Maryland. Copies must be provided as part of the lift plan submittal.
  4. All underground vaults and existing utilities will be marked before any crane is set up.
  5. Rigging equipment inspections will be documented and filed with CCC.
  6. Daily crane inspections will be documented and filed with CCC weekly.
  7. Rigger and hand signalman training documentation will be provided.
  8. Letter from the owner of the crane stating that the worker has been evaluated and they are competent in the operation of the crane they will be using on site.

See Chapter 24 of Consigli’s Corporate Safety Program for additional requirements from Consigli with regards to the pick plan.

Confined Space: We do not anticipate confined space work on this project. Should the need arise, a written plan will be required of any contractor needing to work in any tanks/vaults and crawl spaces. This plan must include the training and certification requirements for workers and air monitoring requirements and protocols. CCC will perform its assessment prior to or upon mobilization and will inform any contractors who it is determined will need a permit. Any potential space must be thoroughly analyzed for confined space hazards and a plan created if entry is required.

Consigli’s Corporate Safety Plan (Chapter 21) identifies the roles and responsibilities of the Safety Manager, the Superintendent, the Subcontractor, and the Entrant should a permit- required confined space be identified. Should such a space be identified on this project, the corporate plan will be adapted to this site specifically and included in a revision. We do not, at this time, anticipate encountering a permit-required confined space.

Steel Erection: Any subcontractor associated with structural steel erection will comply with proof of OSHA subpart R and fall protection training for all workers. 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” (See Exhibit J). Prior to use, fall protection equipment will be inspected by the SSHO and the subcontractor’s foreman and an equipment inspection log will be generated (see Exhibit K). Any failed equipment will need to be removed from the jobsite or thrown away immediately.

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. This plan must meet the requirements of EM 385-1-1 28.B and will be submitted under separate cover. This plan must include the training and certification requirements for workers. Fall protection will be determined for connectors after the subcontractor pre-construction meeting 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 (see Exhibit J). Maintenance and overall responsibility of the fall protection system will fall to CCC.

The scope of steel erection on this project is limited. However, Consigli’s Corporate Safety Program requirements for steel erection will be followed in full. Please see Chapter 16 of the program for more information.

Precast Concrete Erection: Erection of precast concrete shall be designed by an RPE and shall include detailed instructions and sketches guiding the erection. This plan shall be submitted for review by the contractor for review and approval. This plan must include the training and certification requirements for workers. Members must be supported during erection to prevent collapse. Lifting inserts must have a rating that is 2-4 times that maximum intended load depending on whether they are tilt-up or hoisted into place and all lifting hardware shall have a rating 5 times the maximum intended load. No one shall stand under the load at any time except those required and certified for erection.

Excavation: Prior to any excavation work, the contractor(s) performing such work shall have designated “competent persons” assigned and approved by the Project Superintendent and SSHO. Excavation on this project is limited to the area in front of the entrance. Helical pile work is not expected to require trenching or excavation. For the excavation work that will be performed, the contractor must provide a work plan, AHA, and Excavation Checklist (see Exhibit G) specific to this project. Plans must meet the requirements of EM 385-1-1 21.D and 25.A.01 and will be submitted under separate cover. This plan must include the training and certification requirements for workers. Ground Penetrating Radar, electromagnetic, or sonar equipment shall be used to identify any utilities or other below-ground improvements prior to excavation work. Excavation is expected to be shallow, however, the plan must address mitigation of any hazards that may be encountered during the work.

Back End of Site Safety Plan

Environmental Emergency Contact and Management Response

Environmental Issues: Stanley Consultants completed a hazardous materials report of the MacDonough Hall facility. Their report has been provided to Consigli. Copies of the Hazmat report is available for review upon request at the Consigli Field Office.

Asbestos: It is the responsibility of each subcontractor foreman to review the hazardous material report with their workers. Copies of the hazardous material report will always be on site and available to anyone request it. Just because the report did not show an area or material is ACM, does not mean that asbestos could not still be found there. Caution must be used when working. If at any time a worker comes across a material, they cannot confirm is asbestos free, or if a material was previously hidden behind a wall, they shall notify their supervisor immediately. The supervisor shall immediately inform Consigli’s Superintendent of any suspected ACM. The Superintendent, along with the SSHO, will then determine if the area needs to be secured and additional testing performed. They will also immediately inform the NAVFAC team of the presence of suspected asbestos.

All asbestos containing material will be fully removed by a licensed and regulated contractor under an asbestos removal plan which must be submitted and approved. This plan must include the training and certification requirements for workers. All disposals will be done in compliance with State and Federal Regulations. Clearances will be provided to Consigli by a certified Industrial Hygienist prior to any non-abatement workers entering the area.

According to the Hazardous Material Report provided by the Government, the following materials tested positive or are assumed to be Asbestos Containing Materials:

-9” square floor tile and associated black mastic in the swimming pool hallway

-Dark gray spray-applied fireproofing on structural support columns throughout the building.

-Roofing system (assumed ACM)

-ACM mastic at unit ventilators

-Black mirror mastic

-Window glazing and frame sealant (tested or assumed ACM)

-Pipe and fitting insulation (assumed ACM)

-Fire doors (assumed ACM)

Table 1 – Asbestos Sample Results

M1-1 West elev., window Black exterior sealant None Detected
M1-2 West elev., window Black exterior sealant None Detected
M1-3 West elev., north metal panel at stone Green exterior sealant None Detected
M1-4 West elev., south metal panel at stone Green exterior sealant None Detected
M1-5 West elev., metal panel White exterior sealant None Detected
M1-6 West elev., metal panel White exterior sealant None Detected
M2-7 South side flashing at elevated walkway White exterior sealant None Detected
M2-8 South side flashing at elevated walkway White exterior sealant None Detected
M2-9 South side at door stone columns White exterior sealant None Detected
M2-10 South side at door stone columns White exterior sealant None Detected
M2-11 South side window White exterior glazing None Detected
M2-12 South side window White exterior glazing None Detected
M2-13 South side window, exterior Frame sealant None Detected
M2-14 South side window, exterior Frame sealant None Detected
M2-15 South side door, exterior Frame sealant None Detected
M2-16 South side door, exterior Frame sealant < 1% Chrysotile
M1-17 Lobby area ceiling Textured surfacing material None Detected
M1-18 Lobby area ceiling Textured surfacing material None Detected
M1-19 Lobby area ceiling 2’x 2′ CT None Detected
M1-20 Lobby area above ceiling, HVAC duct with FG insulation Tan HVAC mastic None Detected
M1-21 Lobby area above ceiling GWB None Detected
M1-22 Lobby area above ceiling Grey spray applied fireproofing None Detected
M1-23 Lobby area above ceiling Joint compound None Detected
M1-24 Telephone Room 106 Blue floor tile and mastic None Detected
M1-25 Telephone Room 106 Blue covebase and mastic None Detected
M1-26 Telephone Room 106, wall Plaster None Detected

NO. SAMPLE LOCATION SAMPLE MATERIAL % & TYPE OF ASBESTOS M1-30 Telephone Room 102 Blue floor tile and mastic None Detected   M1-31   Telephone Room 102   Blue covebase and mastic None Detected   M1-32   Telephone Room 102   Plaster None Detected   M1-33   Vestibule Room 103A, ceiling   GWB None Detected   M1-34   Room 110, wall above ceiling   Joint compound None Detected   M1-35   Room 119 above ceiling   White spray applied fireproofing None Detected   M1-36   Room 119, ceiling   2′ x 4′ CT None Detected   M1-37   Room 119, cold water pipe, above ceiling   Mastic None Detected   M1-38   Room 119, cold water pipe, above ceiling   Mastic None Detected   M1-39   Room 119   Tan 12″ floor tile and mastic None Detected   M1-40   Room 119   Tan 12″ floor tile and mastic None Detected   M1-41   Room 104 ceiling   2’x 2′ CT None Detected   M1-42 Pool filtration, Room 121, exterior pool wall   Plaster None Detected   M1-43 Pool filtration, Room 121, exterior pool wall   Plaster None Detected   M1-44   Room 126, wall panels   acoustical panel None Detected   M1-45   Room 126, wall panels   acoustical panel None Detected   M1-46   127, stairs   stair tread mastic None Detected   M1-47   127, stairs   stair tread mastic None Detected   M1-48   Room 132 ceiling   2′ x 4′ ceiling tile None Detected   M1-49   Room 132D   Tan 12″ floor tile and mastic None Detected   M1-50   Room 132C   Tan 12″ floor tile and mastic None Detected   M1-51   Room 132E   Tan covebase and mastic None Detected   M1-52   Room 132E   2′ x 4′ ceiling tile None Detected   M1-53   Room 132E above ceiling tile   Tan HVAC mastic None Detected   M1-54   Room 132E   Tan covebase and mastic None Detected   M1-55   Room 132D above ceiling tile   Tan HVAC mastic None Detected    

NO. SAMPLE LOCATION SAMPLE MATERIAL % & TYPE OF ASBESTOS M1-57 Mech. Room, Storage Room 133, CWS pipe insulation White mastic None Detected   M1-58 Mech. Room, Storage Room 133, CWR pipe insulation   White mastic None Detected   M1-59   Mech. Room, Storage Room 133, CWR   Black wrap None Detected   M1-60   Mech. Room, Storage Room 133, CWS   Black wrap None Detected   M5-61   East Mech. Room 507, ceiling   Plaster, white top coat None Detected   M5-62   East Mech. Room 507, ceiling   Plaster, brown base coat None Detected   M5-63   East Mech. Room 507, ceiling   Plaster, white top coat None Detected   M5-64   East Mech. Room 507, ceiling   Plaster, brown base coat None Detected   M5-65   South catwalk, ceiling top of gym   White spray applied fireproofing None Detected   M5-66   North catwalk, ceiling top of gym   White spray applied fireproofing None Detected   M5-67   South catwalk, ceiling top of gym   White spray applied fireproofing None Detected   M5-68   South catwalk, ceiling top of gym   White spray applied fireproofing None Detected   M5-69   North catwalk, ceiling top of gym   White spray applied fireproofing None Detected   M5-70   North catwalk, ceiling top of gym   White spray applied fireproofing None Detected   M5-71   East Mech. Room 505, north ceiling   GWB None Detected   M5-72   East Mech. Room 505, south ceiling   GWB None Detected   M5-73   East Mech. Room 505, AHU-3 duct   Lagging and tape None Detected   M5-74   East Mech. Room 505, AHU-3 duct   Lagging and tape None Detected   M5-75   East Mech. Room 505, AHU-1 duct   Lagging and tape None Detected   M5-76   East Mech. Room 505, AHU-1 duct   Lagging and tape None Detected   M4-77   Room 406, fencing storage   Tan 12″ floor tile and mastic None Detected   M4-78   Room 406A, fencing storage   Tan 12″ floor tile and mastic None Detected   M79   Roof   Underlayment None Detected   M80   Roof   Underlayment None Detected   M81   Roof   Window glazing 2% Chrysotile M82 Roof Window glazing 2% Chrysotile    

Lead Paint: All paint located on the building exterior/interior is classified as containing lead. Workers may need to disturb this paint by drilling, sawing, demolition, fastening, or carpentry. This may require the use of saws, drills, screw guns, impact wrenches, sawzalls, hand wrenches, adzes, crowbars, hammers, and other hand tools. Consigli possesses historical data showing that drilling, sawing, light demo, installation of hangers, hanging sheetrock, fastening, and carpentry do not put the employee above the action level for lead exposure. However, additional monitoring will still be done. An exposure assessment shall be done for any task on painted surfaces prior to the work taking place. If, at any time, workers need to work on the areas mentioned below, they will first need to obtain Lead Awareness training. All lead abatement work will be performed by a licensed and regulated contractor under a lead abatement plan which must be submitted and approved. This plan must include the training and certification requirements for workers.

According to the Hazardous Material Report provided by the Government, the following materials tested positive or are assumed to contain Lead Based Paint:

-White wood interior window casing – Room 107

-Tan and white metal window casing – Rooms 203 and 305

-White wood interior windowsills – Room 107

-Yellow wood window apron – Room 107

-Green wood exterior windowsills and casings – Throughout exterior

-White concrete interior windowsills – Room 107

-Beige, black and tan metal I-beams – Rooms 312, 507, and 502

-Beige metal structural steel – Rooms 305, 306, 312, and 507

-White wood window sash – Room 227

-White wood window mullion – Room 227

-White wood walkway ceiling – Swimming pool

-Blue metal I-beam supports – Swimming pool

-Blue metal newel post – Swimming pool

-Tan and green plaster walls and ceilings -Throughout building

-Gold and white brick walls – Room 507

-Black concrete wall – Room 121

-Green wood door casing – 6th floor roof access

-White porcelain sinks – Rooms 121 and 241

Table 2 – Paint Sample Results

MP-1 West elev., wooden facade at windows Green exterior paint 0.046 0.0011 0.00022
MP-2 South side door, exterior Green paint 8.7 0.13 0.0017
MP-3 Room 306, heavy bags, arch beam Flesh paint 0.98 0.0067 0.0029
MP-4 Telephone Room 102, above ceiling tile White paint 0.19 0.0096 0.0016
MP-5 Vestibule 103A, brick wall Yellow paint 0.096 0.0029 0.001
MP-5A Room 122 ceiling White paint 0.017 0.00037 0.0013
MP-6 Pool filtration, Room 121, structural steel Yellow paint 0.28 3.8 0.0042
MP-7 Pool filtration, Room 121, exterior pool wall Blue paint 17 0.031 0.0072
MP-8 Room 128, metal door frame Grey paint 0.066 0.0045 0.00072
MP-9 East Mech. Room #505, catwalk stairs Tan paint 0.019 0.034 0.0006
MP-10 Stair #4, Room 506, brick wall Yellow paint 0.95 0.00078 0.0013

BOLD results indicate the sample is Lead Based Paint (LBP). All samples exceeded the laboratory reporting limit (RL).

Polychlorinated Biphenyl’s (PCBs): At no time, shall a worker disturb any material he/she cannot readily identify as PCB-free. If they come across a material they cannot confirm, they shall notify their supervisor immediately. All suspect PCB containing finishes which test for more than 50 ppm it will be considered PCB containing material and will be disposed of in accordance with all local, state, and federal regulations.

Light ballast that are not labeled “NO PCB’s” will be considered PCB containing. It is expected that both light ballasts and lamps on this jobsite contain PCB’s. 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.

A hand wash station will be established and maintained for the project duration. All workers on this project must have completed PCB awareness training prior to starting on this project.

Mercury: All fluorescent lamps/thermostats are presumed to contain mercury vapor, which is a hazardous substance. Mercury-containing lamps associated with fluorescent light fixtures in areas designated to be renovated will be treated accordingly. All florescent bulbs removed during renovation will be collected, stored properly on site and giving to WHCC so as to be recycled or disposed of properly.

Freon/Glycol: All Freon/Glycol materials will be removed from equipment and stored per manufacturer’s recommendations the equipment is demolished. All workers who will be working with the above-mentioned materials must provide CCC with certifications or qualifications. If not re- used, a disposal manifest will be provided to CCC, which in turn will be provided to the Government.

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 nor Table 1 complied with, then a HEPA dustless vacuum system will be used in conjunction with an exposure assessment. Prior to the project going full force, an exposure assessment of a worker grinding, demolishing, and cutting masonry while using the HEPA system will be done to establish the silica exposure level. 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. Contractor workers requiring respirators must provide fit test and medical clearances prior to the use of any respirator. A written exposure plan must be developed for all silica producing tasks that clearly defines the following:

  1. A description of the tasks 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.
  5. Training and certification requirements for workers.

Abrasive Blasting: Microabrasive blasting will be performed on this job as a method of cleaning the exterior stone. Prior to any blasting work being scheduled, the contractor shall be required to provide a full blasting plan for review and approval by the SSHO and NAVFAC which meets the requirements of EM 385-1-1 06.I. At minimum, the plan shall identify the additional PPE needed for blasting (expected to include special gloves, garments, face shields, and potentially respirators) as well as the environmental controls to be utilized to control the abrasive materials in their outdoor location and prevent infiltration into other areas of the campus. This plan must include the training and certification requirements for workers.

Mold: Mold has been identified in several locations of the building. Mold remediation will be performed by a qualified 3rd party firm specializing in the work. The firm will be required to provide evidence of 2-day certification program for all technicians from a qualified environmental training organization, documentation of completion of mold remediation training courses, and documentation of professional certifications or licenses held. The Subcontractor performing mold abatement shall provide a written Mold Remediation Plan for review and approval by the SSHO, CIH, and NAVFAC. This plan must include the training and certification requirements for workers. It shall be submitted under separate cover. Prior to any remediation, a Certified Industrial Hygienist shall sample the mold and assess its make up and environmental controls that will be required to safely perform the work. They may also be asked to review the contractor’s mold remediation plan. Once approved, the Quality Control Manager will ensure that environmental controls are installed and maintained during the course of remediation. Upon completion of remediation activities, the CIH will take new samples to ensure the mold has been completely removed and it is safe to remove the environmental controls.

Noise: Noise exposure will also be a concern, so all deliveries must be coordinated with CCC Superintendent to limit their impact on the surrounding areas. Normal working hours will be between 7 am and 3:30 pm; any contractor who may need to work late must first seek approval from the CCC Superintendent. Noise levels will be monitored. If high levels of noise are found to exist or could be expected, PPE and/or environmental controls will be implemented to ensure that noise levels do not exceed acceptable OSHA levels. Consigli permissible noise policy and procedures will be followed. This policy may be found in Chapter 29 of the Corporate Safety Program.

Equipment Issues: All operators will be required to have in their possession all appropriate licensing and training as required by OSHA. 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. Operator’s manual as well as an extinguisher must always be in place. Equipment checklists are required to be filled out daily and submitted to Consigli project team. Each piece of equipment will be thoroughly inspected prior to it being allowed on site.

Global Harmonization: All Materials and chemicals used on-site will have SDS provided before being brought onsite.

  • SDS sheets on file in Consigli Construction’s Jobsite Trailer
  • SDS sheets shall be readily accessible.

Each contractor will be responsible for providing an index of their SDS forms in the Hazardous Material Inventory Log provided by the Government. An editable version of this form will be provided to each contractor and will be utilized to track the totality of hazardous materials on site. A preliminary Inventory will be submitted with materials generally present on Consigli jobsites. A revised submittal will be provided at least once a year for the duration of the project. A final version will be submitted once the project is complete with historic quantities of the materials used.

More information regarding corporate requirements for internal tracking of Hazardous Materials is available in the Corporate Safety Program, Chapter 20.

Designated First Aid Plan: All injuries no matter how minor must be reported to Consigli Superintendent of Safety Manager immediately. The superintendent or safety manager will then report all injuries to the CCC Safety Director and the Contracting Officer. Two 250-person fully stocked first aid and blood borne pathogens kit shall be maintained on the project site. Only properly trained personnel will administer first aid. Consigli Construction shall follow the Emergency Response Plan found at the start of this Accident Prevention Plan for first Aid. Report all incidents to the Consigli Safety Director and NAVFAC.

Consigli’s maintains a robust corporate policy with regards to safety. Every Consigli employee; Foremen, Superintendents, Assistant Superintendents, Project Managers, Assistant Project Managers, and Project Engineers are responsible for safety. To that end, every Consigli employee holds, at minimum, the OSHA 30-Hour Construction Safety Outreach Training (see Exhibit M). Due to COVID, this training is being hosted by online partner “Click Safety”. See Chapter 3 of the Corporate Safety Program for further information about periodic safety and health training for Consigli supervisors and employees. Additionally, all Field Personnel are certified in First Aid and CPR. As these individuals have the potential to be exposed to blood or other body fluids while delivering aid, the Blood Borne Pathogen Exposure Control Plan shall be in effect. See Chapter 8 of Consigli’s Corporate Safety Program for further information on Emergency Preparedness training. This project shall have, at all times, a minimum of two (2) CPR certified employees on site during every shift. CPR certificates will be provided upon mobilization.

  • All employees must wear PPE (gloves, eye protection, mouth-to-mouth shield, etc.) if they may be exposed to potential pathogens.
    • Employees shall wash their hands and other skin with soap and water if exposure is suspected or confirmed.
    • Equipment coming into contact with potential contaminants shall be decontaminated as soon as possible with a Sodium Hypochlorite solution left on the equipment for 30 minutes.
    • Hepatitis B inoculation shall be made available to any exposed employee within 4- hours of exposure.

Consigli Construction Company, Inc.

For further details of the post-exposure follow-up, please see the Corporate Safety Program (Exhibit N).

Substance Abuse: As a condition of employment, all Consigli personnel 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. Contractors working under Consigli are informed of our zero-tolerance policy prior to award. Additionally, each worker is advised of this policy when they are orientated at the start of their time on the project. However, due to the opioid epidemic, Consigli has elected to include Narcan in its First Aid kits on site. All Consigli employees are trained in the determination if the use of Narcan is necessary and in its administration.

Evacuation Plan (RACE, and Routes of Egress): Please refer to the Evacuation Plan and Muster Point Plan provided in Exhibit B. All Consigli employees shall attend the Project Safety Orientation. Consigli Construction’s Job Supervisor will conduct a safety orientation talk to each employee and subcontractor to site specific fire safety protocols. Building Evacuation Plans shall be updated as demolition and rebuilding alter egress routes or monthly, whichever is sooner.

Fatigue Management Plan: Work hours are not expected to exceed requirements in 385-1-1 on this project. Should this change, a full Fatigue Management Plan will be provided to include identification of workers affected, management’s responsibilities, training, and controls. As a standard measure, equipment operators will not be allowed to work more than 12-hours within any 24-hour work period and will be provided with a minimum of 8-hours of rest time between shifts. Vehicle operators will not be allowed to operate vehicles for more than 10-hours in a 24-hour period. Neither shall they be allowed to operate a moving vehicle if they have been in a duty status for more than 12-hours during the previous 24-hours.

Heat/Cold Stress: During hot and cold weather, measures must be taken to prevent, identify, and treat heat or cold stress.

Hot Climate Monitoring Plan

Take into consideration the influence of environmental conditions, workload, and personal factors when hot/dry or hot/humid environments are forecasted. During hot weather, all contractors are required to provide adequate quantities of potable water for their employees. A Toolbox Talk identifying signs of heat stress, including heat exhaustion and heat stroke signs to look out for, is required during hot weather. Additionally, workers are encouraged to

drink water regularly and avoid consuming coffee and alcohol during hot weather periods. Consigli recommends implementing a buddy system. This allows workers to not only monitor themselves, but also be alert to changes and the symptoms of their co-workers. When possible, work should be scheduled for cooler periods during the day. Consider exacerbation of heat related injury and illness based on various types of clothing, including general work clothing, semi-permeable and non-permeable clothing, arc flash clothing, and other protective clothing which reduces the evaporation rate.

Signs of heat-related illnesses are as follows:

  • Heat Cramps – Painful muscle spasms in the arms, legs, back, and stomach.

  • Heat Exhaustion or Shock – Fatigue, headache dizziness when standing, loss of appetite, nausea, abdominal distress, vomiting, shortness of breath, flushing of face and neck, pulse rate over 150 beats/minute, glazing eyes and mental confusion, such as lack of emotion or concern, poor judgment and irritability, which usually precedes fainting.

  • Heat Stroke or Sun Stroke – Hot dry skin, no sweat, unconsciousness, red face and neck, pupils are dilated. This is an extreme medical emergency – call for an ambulance immediately.

If signs of heat-related illnesses are experienced or observed, the employee will need to take an immediate break to cool down. Taking breaks inside the building where it is cooler is also encouraged and anyone showing signs of heat exhaustion or stroke shall be brought to the Consigli site trailer where there is air conditioning for monitoring and potential treatment until emergency services can arrive.

In order to prevent heat exhaustion and/or heat stroke, the following water and shade breaks will be implemented.

Heat Index Water and Shade Breaks
100° F 5 minutes per hour
105° F 8 minutes per hour
110° F 10 minutes per hour

Cold Climate Monitoring Plan

Though the mid-Atlantic region has relatively mild winters, cold weather protections shall still be enacted. These include ensuring workers are wearing appropriate layers for the temperatures and monitoring for any abnormally low temperatures. Extreme temperatures with or without wind can cause a cold weather injury (CWI). Even temperatures at or below 28° F may subject workers to frostbite, especially to exposed skin or extremities. Work in cold environments shall take into consideration heat loss from wind speeds (e.g., when air temperature or wind chill could drop below 40°F (4.4°C); the SSHO will ensure that air temperature and wind speed readings are taken at least every 4 hours when the temperature drops below 20°F (-6°C) and wind speed exceeds 5 mph (8 kmph). Alternately, broadcasted wind chill factors may be used if the reading is within 10 miles of the location.

Signs and symptoms of frostbite or cold weather injury are:

  • Skin (exposed or unexposed) is blue or ash gray
  • Numbness or tingling to the frozen area
  • Inability to speak or slurred speech
  • Unconscious, with no manifested symptoms

First Aid:

  • Transport to a medical facility immediately

Without adequate shelter, such as a make-shift tent, structure, or plastic barrier (with or without heat), when ambient air temperatures reach -20° F, work-rest ratios will be established. Workers cannot be continuously exposed to extreme temperatures, below -20° F. Using a standard wind-chill chart, the following parameters will be established. Alternately, work may be canceled for the day.

Temperature Work/Rest Ratio (minutes per hour) Actions
-20° F 50/10 Reduce wind velocity
-24° F 40/20 Provide shelter
-27° F 30/30 Provide shelter
-30° F 0/0 Provide heated shelter

NOTE: The wind chill will be determined by the SSHO, or by the Senior Manager on site. If the temperature and wind velocity is unknown at the site location, consult the local weather service or internet for wind chill temperatures.

Provided rest shelters should be at or above 32° F. Buildings can be utilized for warming, however, rapid heating after cold exposure increases the chance of shock. For that reason, workers should warm up slowly and should avoid immediate use of cafeterias and administrative buildings for warming. During extended breaks/rest periods over 20 minutes, clothing layers should be removed before entering heated areas, such as cafeterias, heated vehicles, or heated trailers. Un-climatized workers are the most susceptible to frostbite or a cold weather injury in extreme temperatures; therefore, they should be closely monitored for 2-3 days of cold weather exposure. Please note, frostbite may occur, even with proper work/warmth ratios. Workers should closely monitor their exposed skin, feet, and hands.

Boots/shoes should be removed when entering shelter for long periods of time. Workers should work in pairs to monitor each other during cold weather exposure.

Consigli Construction Company, Inc.

Materials Management/LEAN/Housekeeping: Materials management, getting materials into and out of the project, will be a challenge that needs to be adequately planned. Activity Hazard Analyses shall be prepared by the responsible contractor for all materials that will be hoisted into or out of the building. They will be reviewed by the Safety and QC Managers prior to work taking place. Only materials which will be used/installed within three days’ time will be delivered to the site. Attention must be paid to structural analysis in regard to loading existing floors with material and equipment. Movement of all materials over 8ft. will require 2 workers.

A Traffic Control and delivery plan will be Coordinated with Consigli Superintendent and submitted separately. All contractors will be required to follow the traffic control and delivery plan for work on this site. This project will utilize the LEAN management system for material handling. This includes:

  • No materials shall be delivered to the site earlier than 3 days before said materials are to be installed/put into place. If materials must be delivered before that 3-day time period, subcontractor shall get prior approval from Consigli Superintendent. Because of this, notification/scheduling is required for all deliveries to the site. Subcontractors must notify Contractor at least 24-hours in advance. Contractor has the right to refuse any deliveries not properly scheduled or due to logistical constraints as necessary.

  • All subcontractors’ delivered materials shall be placed on wheeled carts, wheeled racks or in wheeled bins to facilitate easy relocation in the event materials need to be moved. Materials on carts, racks, or dollies shall not exceed manufacturers intended weight loads. Materials/tools can be delivered and stored on pallets only if pallet jacks are delivered simultaneously with said delivery to provide for ready mobility. Additionally, pallet jacks need to remain in immediate area. Each subcontractor will need to supply their own pallet jacks for their own materials and keep their pallet jack within reasonable distance at all times.

  • All workstations shall be provided with wheeled trash bins for immediate placement of all debris produced as a part of the subcontractor’s operations. All trash will be immediately placed in wheeled containers provided by Consigli.

  • All subcontractors shall use rubber wheeled carts when moving material or removing trash from a building. No trash or materials shall be left on the floor.

  • Subcontractors shall, where feasible, elevate all electrical extension cords, hoses, or cables – removing them from all walking/working surfaces. Electrical Cords, when elevated shall be supported or suspended in a manner that does not subject them to damage.

  • Storage of delivered materials in cardboard containers shall be discouraged. When materials must stay in cardboard containers, said containers shall be removed from the project immediately after product is unpacked.

Consigli Construction Company, Inc.

  • Subcontractor will participate in schedule development meetings as required by Consigli.

Spill Mitigation: Any contractor with a significant potential to discharge RESTRICTED materials is required to obtain, install, and maintain an adequate spill containment system. Any contractor that may accidentally discharge any material, treated or otherwise, will be required to follow the spill mitigation policy laid out in the Corporate Safety Program (Chapter CCC) or their own, whichever is more stringent. If a contractor is following their own plan, an emergency response plan must be included as a part of the plan. This plan must include the training and certification requirements for workers.

Spill containment systems must be capable of containing 100 percent of the volume of the largest container of Restricted material. If a portion of the containment volume is occupied by other tanks, equipment, and/or standing liquids, this displaced volume must be subtracted from the total spill containment volume. Spill containment systems exposed to rainfall or runoff must be capable of storing an additional six inches of rainfall over the exposed area.

Acceptable containment systems include diking for single shell tanks using concrete blocks/berming, or another permanent structural barrier. Portable spill containment trays or pallets are also acceptable. No valves, gates, or openings may be present in the containment. Utility pipes may be approved if opening is properly sealed to keep containment watertight. Double shell tanks are considered self-containing and do not require additional spill containment measures as long as:

  • Shells are independent of each other.
    • There is not a significant chance of overflow.
    • Outer shell is capable of containing all leakage from inner shell.
    • Air gap of 1” exists between shells.
    • Top of inner shell is >1” lower than outer shell.
    • No valves in other shell.
    • Area between shells remains dry.

Fuel tanks are not allowed on site.

If a spill is suspected or confirmed, follow the call hierarchy established on page 4 of this plan. Please note, spills are considered a critical emergency. Contact must be made with Emergency services, Consigli, and the NAVFAC team within 15 minutes of the discovery of a spill. Follow up verbal communications with written documentation within 20-days of a spill.

Appropriate spill kits for the type of hazardous or non-hazardous material present on site shall be required as part of the spill protection plan submitted by any subcontractor working with potentially spillable materials. Spill kits must be within ready access of the location of the material. In situations where material is spread out over a large distance, multiple spill

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kits may be required. Cleanup of a spill must commence immediately after discovery during notification and documentation. No spill shall be permitted to remain longer than 1-hour without cleanup efforts.

Refueling Operations: Onsite refueling of equipment and machinery may be necessary. Subcontractors shall be required to provide a written refueling plan prior to bringing any such equipment or machinery onto the jobsite. At minimum, the refueling plan will confirm:

  • Fuel-operated equipment will be shut down and allowed to cool before refueling commences.
  • Caution shall be taken during all refueling activities.
  • A 2A 10lb ABC Fire Extinguisher shall be located within 10’ of refueling activities in the case of a fire.
  • Only UL listed cans shall be permitted.
  • Fueling within the confines of the building is prohibited.
  • Fuel supply shall be limited to, at most, a two-day supply. Exact quantities of fuel stored on site shall be reviewed and confirmed with Consigli and NAVFAC prior to delivery to site. Permits for fuel storage will be coordinated with Consigli, NAVFAC, and the USNA Fire Department.
  • Fuel containers must be properly labeled.
  • This is a strictly no smoking site. No smoking signs must be placed near refueling locations. Anyone caught smoking near a refueling location will immediately be banned from the jobsite and contractual fines/penalties for such a violation shall be assessed.
  • Containment must be installed such that refueling activities take place within the confines of the containment (see section above).
  • A spill kit appropriate to the type and quantity of fuel to be used is present within ready access to refueling activities.
  • Training and certification requirements for workers.

Oily Wastes: Any substance which is or has been mixed with used oil and has become separated from said oil or a is a biproduct of oil use, must be disposed following best practices, EPA, State, and local regulations. Maryland has adopted the federal used oil management standards. Any used oils or oily wastes shall be disposed of through contract with a company with a valid MDE permit in accordance with COMAR by owners and operators of COMAR used oil collection centers, used oil transportation facilities, and/or oil processing/rerefining facilities.

Consigli Construction Company, Inc.

Health Hazard Control Program: The requirements of this plan are covered within this Site-Specific Accident Prevention Plan.

Process Safety Management Plan: The requirements of this plan are covered elsewhere within this Site-Specific Accident Prevention Plan with the exception of potentially contaminated soils. Once demolition is completed, the soils shall be categorized and tested for contaminants. If contaminants not otherwise addressed in this plan are present, an amendment to this plan will address the issue.

Site Safety and Health Plan: The requirements of this plan are covered within this Site-Specific Accident Prevention Plan.

Radiation Safety Plan: We are not anticipating any radioactive materials on the jobsite. As such, a Radiation Safety Plan is not applicable.

IAQ Management Plan: Monitoring for Carbon Dioxide and VOC levels to meet the requirements of 01 45 00.0020-1.17 shall follow the IAQ plan submitted under separate cover.

Chromium Exposure Evaluation: This plan is not required for the work of this project.

Wild Land Fire Management: This plan is not required for the work of this project.

Naval Architectural Analysis: This plan is not required for the work of this project. Man Overboard/Abandon Ship & Float Plan This plan is not required for the work of this project.

Rope Access Plan: This plan is not required for the work of this project.

Underground Construction Fire Prevention and Protection Plan: This plan is not required for the work of this project.

Compressed Air Plan: This plan is not currently expected to be required for the work of this project. Should this change, a revision will be provided to address EM385-1-1 27.E. This plan would include the training and certification requirements for workers.

Lift Slab Plan: This plan is not required for the work of this project.

Masonry Bracing Plan: This plan is not required for the work of this project.

Explosives Safety Site/Blasting Plan: This plan is not required for the work of this project.

Underwater Dive Operations Plan: This plan is not required for the work of this project.

Tree Felling/Maintenance Plan: This plan is not required for the work of this project. Aircraft/Airfield Safety & Phasing Plan This plan is not required for the work of this project. Exposure to the Visitors and Staff

Non-fraternization with staff, midshipmen or visitors will be stressed with all subcontractor personnel during orientations. 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. Direct any questions regarding the project or jobsite to the Consigli Superintendent.

Adjacent Property: All steps will be taken to limit the effects of the project on the surrounding buildings. Special attention will be paid to the access point of each building so as not to impede access. Parking, in particularly, will be clearly reviewed with each worker. A Site Logistics plan will be created by Consigli project team and submitted separately. This logistics plan will be shared with all subcontractor employees during their orientation period.

Exposure to Street Traffic: All deliveries will be made at a designated location unless otherwise directed by Superintendent. There will be limited exposure to live vehicular traffic from the areas of the parking lot not captured for the job. All speed limits will be obeyed, and deliveries will be made so they don’t coincide with other scheduled deliveries. All traffic control signage (if needed) will meet CCC and town requirements before being installed. Coordination with CCC will be required when any equipment will be set up/used in the parking lot. Fire department 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 work 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. Exhibit E contains a checklist of items which must be in place prior to this meeting in order to be reviewed during the meeting. Additionally, subcontractors shall provide names and qualifications for Competent Persons as per OSHA 29 CFR 1926.32. A duly appointed Competent Person must be on site at any time the work activity for which they serve as CP is being performed. Their credentials, including photo id, are scanned and saved within the Procore software program. If at any time the CP is not present during work, Consigli will enact its legal rights to fine the subcontractor for default. This is explained when a subcontractor first starts on site and is periodically mentioned during daily stand-up meetings, weekly subcontractor PM meetings, and other communications with subcontractors. See Exhibit E for a copy of the Competent Person Form and Consigli’s minimum requirements for someone filling that role on this project. This form is required to be provided prior to the safety meeting. As Competent Persons are identified, this APP will be updated with their names and filed in Exhibit E (each subcontractor has their own form based on their SOW). At the end of the project, a For Record copy of the Accident Prevention Plan will have the full record of Competent Persons from this project.

In addition to the minimum requirements listed on the form, Competent Persons for the following activities shall require further scrutiny:

  • Confined Space Entry – Follow all procedures listed in EM 385-1-1, Appendix Q
  • Scaffolding – Certification of minimum 8-hours scaffold training for the specific type of scaffold being used.
  • Fall Protection – Training must have been performed by a Competent Person Trainer or Qualified Person Trainer as per ANSI/ASSE Z359.2. A minimum of 24-hours of classroom and practical training are required. CP must also follow all protocols listed in EM 385-1-1 21.B.03.
  • Crane Operators/Signal Persons – Meets requirements as states in EM 385-1-1 16.B which may not otherwise be covered by their Maryland License(s).
  • Riggers – Must be at least 18 years of age; be able to communicate effectively with all parties; and must have at least a basic knowledge and understanding of the equipment-operating characteristics, capabilities, and limitations proven via training and experience.

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 and Foreman/Supervisor with an OSHA-30.
  3. Activities requiring certifications or licensure must have valid certifications presented prior to work occurring on site.

The SDS sheets associated with any hazardous substances to be used will be maintained by the superintendent in a marked three ring binder. An index of each subcontractor’s hazardous materials will be included and will utilize the Hazardous Material Inventory Log provided by the Government.

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 in reducing the complacency

Consigli Construction Company, Inc.

of workers on all projects. Members from the CCC and owner project team (Supers, PM, APM, PE, OPM, Architect, Owners, etc..) will be provided with $5 gift cards (place to be determined) prior to their walk on site. They are to present these cards to workers who are working safely and or those taking additional steps to work safely. After issuing the card, the name and hard hat sticker number of the worker as well as a brief description of what they were doing will be documented in a log that will be maintained in the field office. 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 be recognized to other sub-contractors/workers through foreman meetings and daily stand ups. At the end of the project the sub-contractor who has had the most workers recognized will receive an appropriate acknowledgment from CCC as well as some type of reward that is to be determined by CCC field staff.

Management: Program implementation and management will be measured in Predictive Solutions Monthly Management Audit. This system is used as the Safety and Health Observation Deficiency tracking system for the project. Loss related exposures will involve, cuts, scrapes, and strains related to window and roof material installations. 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. Observations in Predictive Solutions remain open until addressed, confirmed by the SSHO, and closed. A daily email is sent to each subcontractor with open items in the Predictive Solutions System.

Additionally, Consigli’s SSHO will fill out the Contractor Safety Self-Evaluation Worksheet Provided by the Government on a monthly basis. This worksheet will be included as part of the monthly requisition and can be found in Exhibit L.

The Site Safety and Health Officer must be on site while work is performed. Should the SSHO need to be absent for a period of less than 24 hours, a Designated Representative (DR), as identified in the AHA, may cover for the SSHO. Should an absence of longer than 24-hours be necessary, the Alternate SSHO (see Exhibit A for resume) shall cover and perform all of the same roles and responsibilities as the primary SSHO.

All Consigli project team members, when on the jobsite, are responsible for performing daily safety walks. This is in addition to the safety reviews of the SSHO. The PE (Jaya Washington), APM (Naomi Doddington), PM (Steve Wood), Assistant Superintendent (TBD), and Superintendent (Dean Archambault) are each responsible for logging at least one safety observation in Consigli’s project management software daily when they are on site. Observations may be of corrections needed or safety being managed well (in conjunction with the Safety Spot Recognition Plan described above). See Exhibit M for a list of items reviewed by the project team during these daily safety walks, the weekly inspections checklist is utilized by the Superintendent at least once a week as well. Minor safety items are handled in the field and resolution is obtained immediately. Major violations may result

Consigli Construction Company, Inc.

in a warning or immediate dismissal from the job. Please see the Site-Specific Orientation (Exhibit E) for a detailed description of how violations are handled precisely as it is communicated to all personnel. All Consigli project team members hold OSHA-30 cards and have the right and responsibility to correct or bring a halt to any work happening in an unsafe

Working Safely with COVID 19PleasereferencesitespecificCovid-19plan,submittedunderseparatecover. As per DFARS 252.233-7999: Ensuring Adequate COVID-19 Safety Protocols for Federal Contractors, all contractor and subcontractor personnel shall be vaccinated for COVID-19 and shall follow all current

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