Old Rhinebeck AD AVRO Hangar Rep Project
Project # 2732
Emergency Response Plan
ALL EMERGENCIES SHOULD BE REPORTED BY CALLING 911
This Emergency Response Plan (E.R.P.) is specifically developed for Consigli Construction Management work associated with the Rhinebeck Aerodrome.
Memo from the CEO
FROM: Anthony Consigli, CEO
TO: Employees and Subcontractors
SUBJECT: Job Safety
Over the past several years we have made significant improvements to our occupational health and safety program. These improvements have resulted in fewer employee injuries, fewer OSHA citations and an exemplary safety image within the construction industry. Through the combined efforts of our staff and employees we have become more competitive and in turn, we have provided more jobs for all our employees.
As employees and subcontractors to Consigli Construction, you represent all of us in the workplace and we need your pro-active support to continue making safety improvements and continue expanding our market share. Therefore, we are asking all employees and subcontractors to read, understand and practice the enclosed Health and Safety principles and guidelines. This means routinely training employees, conducting weekly toolbox meetings, wearing appropriate personal protective equipment, using fall protection when necessary and practicing all other safety-related items listed in the Safety and Health Handbook. Even more importantly it means developing a safety-conscious attitude.
We take safety very seriously and we expect you to do the same. If you have any questions, call me or ask the Site Superintendent at your worksite.
The construction site is located at 9 Norton Rd, Red Hook, NY 12571 .The location for the project field office is currently at the Project jobsite (notifications of any changes will be provided). 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
- Structural Damage/Collapse
- Weather or Geological Event Classified as an Act of God
- Environmental Incident
- Traffic Disruption
- Utility Damage
- Illegal Activity
- Labor Problems
- Bomb Threats/Military Ordinance Unearthing
- Acts of Terrorism
When reporting an emergency, please provide the following:
• Your location, phone number, and name;
• The location of the incident (building name, floor and room number);
• Nature and extent of the incident (injury, accident, spill, smoke/fire, damage, etc.);
• The safest route to the incident
Crisis Response Protocol:
- Attend to the injured
- Immediately contact Edwin Robinson (Safety Manager) (845)518-4897
- Contact Project team and Rhinebeck Aerodrome project team hierarchy list in this plan
- 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 Old Rhinebeck AD AVRO Hangar Rep Project site entrance of Gate 1 to escort Public Safety & Security and all 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.
Back– End of Emergency Response Plan
Emergency Contact Names and Numbers
- First call: 911 Fire or Police
- Consigli Superintendent: James Clarke (845)260-2835
- Consigli PM: Kevin Johnson (845)417-3184
- Consigli PX: Scott Cruikshank (845)235-6519
- Consigli PE: Dakota Pulver (845)243-4712
- Corporate Safety: Edwin Robinson (845)518-4897
- Gen. Superintendent: Sean Hynes (845)902-8395
Consigli Director of Safety: Bryan Kingsbury (508)808-9359
State Police Rhinebeck (845)876-4033
DC Sheriff’s Office (845)486-3800
Rhinebeck Fire Department (845)876-3133
Mid-Hudson Regional Hospital (Poughkeepsie) (845)483-5000
In case of emergency a Consigli representative will be dispatched to the Main entrance of the building to meet the responding Emergency Personnel and advise the individual in charge of the location of any chemicals or hazardous substances that may be present on any of the floors. SDS/SDS sheets will be readily available if needed by the Rhinebeck Fire Department.
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 assemble next to the pedestrian walkway located in the rear building area facing the Soccer Field. The foreman for each company will meet at that location and take a head count of their staff and report to the Consigli Superintendent. If for some reason a worker is unaccounted for, Rhinebeck Fire Department will be notified of the last location where the worker was observed.
Back– End of Emergency Contact Names and Numbers
Northern Dutchess Hospital
Back– End of Medical
Site Safety Plan
PURPOSE: The purpose of this Site-Specific Safety and Health Program is to illustrate Consigli’s approach to identifying project specific hazards and controls and how said risk is managed through a comprehensive Safety and Health Program.
Minimum Site Safety Requirement for the Old Rhinebeck AD AVRO Hangar Rep:
All Consigli workers, and any subcontractors, shall have, at a minimum, an OSHA 10 Hour Construction Safety Outreach training certificate and shall provide documentation of training. All forklift operators, scissor lift and aerial lift operators shall also possess a copy of training and certification and supply copy of same to the Consigli project team.
In addition, at a minimum, the following site safety regulations will be adhered to throughout the project duration with a ZERO TOLERANCE for non-compliance. (See Logistics Plan Below).
- All workers shall follow the posted airway warning signs.
- Airplane rides do occur. When rides are being performed they tend to be between 15 – 30 min in duration. All workers shall inquire so as to no when to cross airstrip at the appropriate safe time.
- All workers shall only cross airstrip on designated roadways. NO SHORTCUTS.
- All workers shall, prior to crossing airstrip, look up and both ways to ensure there are no aircraft approaching or in process of landing.
NOTE: this is a “Non-Smoking, Non-Vaping” Project. All workers are always required to abide by this requirement.
Working Safely With COVID 19
- Employees experiencing any symptoms (runny nose, headache, cough, sore throat and/or fever) shall stay home and contact your Supervisor. Supervisors should immediately communicate any individuals reporting symptoms to the Consigli Superintendent.
- Any employee that has had contact with someone that has a presumed positive for COVID-19 or someone awaiting testing COVID-19 should stay home and contact their supervisor. Supervisors should immediately communicate any individuals reporting potential contact to the Consigli Superintendent.
- Any individuals that have traveled outside of the United States should stay home and contact their supervisor. Supervisors should immediately communicate individuals reporting foreign travel to the Consigli Superintendent to discuss authorization to work on site.
** This Screening Protocol will be, maintaining proper 6’ spacing, with everyone on site at the start of every shift. **
The following GUIDELINES need to be followed
- Consigli Project Team shall communicate with our customer to confirm we are in compliance with all facility work rules.
- All subcontractor’s Project Managers, Assistant PM’s, Safety Officers, etc. should work remotely.
- Any site visits by non-essential personnel should be discussed with the Consigli project team.
- All meetings will be done via Skype or conference calls.
- All vendors and delivery drivers are prohibited from entering the site. When deliveries arrive near the site, contact the Consigli Superintendent for direction.
- Avoid cafeterias and high activity areas.
- When possible eat outside or in isolated area.
- As much as possible avoid intermingling with other crews or groups
- Prohibit all food and drink inside the work areas
- Any lunch rooms within the work areas should be closed
- Wash or sanitize hands frequently
- Always before and after any lunch period or break time
- Maintain social distancing when practical
- Preferably maintain at least 6’ between yourself and others
- If working with a partner is required assure proper hygiene practices are followed.
- Disinfect frequently touched objects and surfaces, such as tools, keyboards, light switches and tables at least twice per day. Most household cleaners, such as bleach wipes or alcohol, will kill the virus.
- Utilize proper etiquette when coughing or sneezing
- Discontinue the use of community water, coffee, or food
S.A.F.E.: Staying Accident Free Every Day is the Safety Mission that forms the very foundation of the Consigli Safety Culture. The S.A.F.E. mission, which is supported by technology, (Predictive Solutions internal auditing instrument which identifies and defines leading indicator related information); Leadership (Empowering our team members to assure safe projects); Humanization (Protect the ones you love by protecting yourself); Jobsite Gym (Morning warm-ups, stretch and flex); Training (Integrating sub-contractors into the Consigli Safety Culture); and Lean (nothing hit the ground), is the driving force behind Consigli’ s drive to our vision – ZERO. ZERO is the philosophy that all accidents are preventable and that no accident is acceptable. The S.A.F.E. mission is the guiding force to achieving the Consigli Safety Vision which is ZERO.
Identify the specific route in and out of the construction site (Traffic Management): All construction traffic, deliveries and waste removal shall be done using the entrances designated on the site-specific logistics plan (See Page 9). Key areas on the logistic plan are as follows:
- Aircraft, staff and public guests of Old Rhinebeck AD AVRO Hangar Rep will be given the right of way at all times. Parking will not be designated on site.
- Strict adherence to posted signage for active aircraft landing and taking off as well as posted speed limits and parking locations is required.
Designated work hours (any work outside these hours must have prior Consigli approval): All work shall take place during business hours, 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 Consigli Superintendent.
Services: Any compromises to Old Rhinebeck AD AVRO Hangar Rep Project site during the work performed will be handled accordingly.
- During weekly project meetings, if needed upcoming work that may compromise service or impact the public shall be talked about with Site Superintendent and scheduled for off shift if the group decides it will be needed.
- The on-site superintendent shall perform weekly inspections of all adjacent establishments and businesses for the duration of the project to ensure minimal construction impact.
PROJECT SITE LOGISTICS PLAN
Post Incident Review: Any incident that results in a recordable injury will require a post incident review. The worker who was injured along with their foreman/Safety Personnel/PM/Sup/etc… Will need to fill out Appendix?? (Post incident review form) and attend this meeting. At this meeting they will re-emphasize their commitment to safety, determine chronology of events, identify contributing factors, identify root cause, provide improvement plan to prevent reoccurrence and discuss disciplinary actions taken (if any). Findings from this meeting will be shared/disseminated with all contractors on site to prevent reoccurrence.
Safety Spot Recognition Plan :The purpose of this plan is to instantly recognize workers “on the spot” for working safely and to reward those workers immediately. This will assist CCC reduce the complacency of workers on all of our projects.
Members from the CCC and owner project team (Supers, PM, APM, PE, OPM, Architect, Owners, etc…) will be provided with Dunkin Donut gift cards 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.
Activity Safety Analysis (ASA)/Toolbox Talks: An ASA/JSA depending on level of hazard shall be conducted for each identifiable feature of work to be performed by all subcontracted organizations. The ASA/JSA shall be submitted to Consigli superintendent/supervisor prior to the commencement of any work. ASA/JSA shall be reviewed weekly, signed by all workers including their supervisor, with all involved personnel performing that particular task.
Subcontractors under their contract shall be responsible for drafting and reviewing all AHA/JSA’s with their workers each Monday as well as toolbox talks that address the work that they will be performing and that which is relative to safe work practices. Any second tier subcontractors under all subcontractors contractually responsible under Consigli shall be responsible for providing the JSA/ASA to all workers under their respective contracts.
Demolition Scope: Existing Building Demolition:
- Demolish existing 2-story wood structure and existing foundation
- Remove existing entryways
Live utilities will be running through the building prior to building scheduled demolition. It is for this reason that Consigli will require that all MEP subcontractors perform a pre-demolition survey to ensure that the work areas are made-safe for demolition work to commence.
From this survey, the competent person from each trade will relay back any unsafe conditions to the Consigli Superintendent. At no time shall demolition work commence without Consigli Superintendent having all documented “Make Safes” provided by the responsible MEP subcontractors that confirm the isolation of all utilities feeding the construction area.
Interim Life Safety Measures – ILSM Control Plan during Demolition
During all demolition work the following processes are to be implemented, maintained and monitored as they are crucial to ILSM compliance:
- Emergency egress from all construction areas are to be maintained at all times and communicated to all Consigli personnel and subcontracted workers. For Old Rhinebeck AD AVRO Hangar Rep facility, Consigli will follow the established evacuation procedures.
- All fire alarm pull stations will be identified prior to work
- Access through occupied areas will not be impeded upon. A daily egress inspection will be conducted by Consigli’s Superintendent to ensure unobstructed means of egress through the area is consistently maintained.
- Fire alarm and suppression systems are not to be impaired when at all possible. However, should it be the case that the systems must be protected or taken off line due to the work process, a permit from Consigli Construction and the local fire department having jurisdiction may be required.
- In addition, material storage is not permitted in the occupied spaces of Old Rhinebeck AD AVRO Hangar Rep facilities. Added materials may cause obstructions in main egress ways in the event of an evacuation or other emergency.
Pre-Demolition Make Safe
Prior to the start of demo operations, the contractor preforming demo will confirm that all utilities leading into the area have been made safe. This project may require select demolition of the existing MEP. The electrician will disconnect and lock out all electrical, the plumber will do the same with any plumbing lines, and the HVAC subcontractor will do the same on the HVAC piping and duct work. Lock out tag out will be reviewed during the pre-construction safety meetings to assure disconnect and responsibility for protection of existing utilities is safe for any construction activities to commence. Old Rhinebeck AD AVRO Hangar Rep Facilities Engineer will be contacted in the case of any required LO/TO and their locks will be installed first and removed last. Subcontractor coordination and completion of the safe work permit shall be through the Consigli Superintendent. In spaces where some electrical or mechanical must remain live, a color-coding system will be utilized for easy identification of live utilities that must stay active and utilities that must be removed.
Any and all utilities spray painted (or otherwise marked) Red are not to be touched and 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 until they are marked. Any existing walls shall be removed using hand tools until investigation shows what mechanical systems are present behind the wall. The demo contractor will be responsible for completing CCC demo checklist prior to the start of any work in their target areas.
Lockout/Tagout, scheduling shutdowns
It is vitally important that all required shutdowns are scheduled so that demolition work does not interfere with any building life safety equipment, medical gases that are in use, electrical systems that are supplying power to life support equipment, etc. These requirements will be established in the ILSM meetings prior to the demolition work taking place. All mechanical, electrical, plumbing, etc. systems that require work to be performed on them shall be effectively LOTO to a de-energized state. These procedures shall follow in strict accordance with the OSHA requirements in 1910.147 – Control of Hazardous Energy, NFPA 70E, NFPA 99, etc. Old Rhinebeck AD AVRO Hangar Rep Facilities may have procedures already established for this work. In every case, shutdowns of all types are required to be coordinated with Old Rhinebeck AD AVRO Hangar Rep Management team and Facilities Staff. At no time will work be performed on any system prior to this meeting taking place.
Excavations: Excavation will be limited to initial building footprint, exterior infrastructure installation of a new underground utilities and new storm water drainage system. These excavations are to be limited to less than five feet in depth and will not be open for any length of time. Written excavation plan and inspections will be done if the excavation exceeds 5’. All required permitting will be obtained before any excavating is to begin. If necessary, tabulated data/engineering for shoring and shielding systems will be obtained and available on site at all times when in use. All excavations will be inspected by a competent person on a daily basis. All roadway work shall be performed with all local municipal permit requirements in place and closures pre-planned.
- Dig Safe Notification – dig safe number (If needed) will be obtained and posted in the site office.
- Copies of shoring engineering and tabulated data sheets for all trench boxes or other shoring/shielding systems brought on site will be provided to Consigli and be kept in construction office.
- Designated flagman will be utilized during all work that directly or may indirectly effect the public and Old Rhinebeck AD AVRO Hangar Rep staff. Equipment operation outside the construction area will require 100% flagman operations, No Exceptions.
**Review Chapter 19 of Consigli’s Safety & Health Program for more detail
Fall Protection: All workers exposed to a fall of 6′ or greater shall be protected by guardrails safety nets or personnel fall arrest systems. this include, but is not limited to, all overhand brick laying and pre-cast concrete related work for all exterior work, structural steel work and scaffold erection and dismantling for Old Rhinebeck AD AVRO Hangar Rep project.
Holes greater than 2” will be covered with acceptable material (3/4 plywood ½ steel) which will be secured and marked hole and 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 (to be protected with cable guard rail system with turnbuckles to be installed for all straight runs and any straight run over 100 feet. Before any work is to begin on the Old Rhinebeck AD AVRO Hangar Rep it must be determined what method of fall protection will be implemented all workers working on the Old Rhinebeck AD AVRO Hangar Rep upper levels and exposed to a fall greater than 6 feet will have fall protection 100% of the time spent in this location. Workers on a walking working level with an uncontrolled leading edge must be protected by Personal Fall Arrest System (PFAS) or Guardrail systems as flagging is prohibited and can only be utilized during roofing work.
All access/egress points to attic or upper level areas to which workers must perform work shall be made safe with guardrail systems. All ladder access/egress shall extend 3’ above work area walking surface and be secure from displacement. All material will need to be kept a minimum of 6’ from all leading edges, any materials that may be displaced off upper floors shall be removed or relocated.
The use of safety Monitors is not allowed!!!
NOTE: All work performed at 6’ or above will require a written fall protection plan by the subcontractor performing the work and shall be communicated to all affected workers prior to start of work.
**Review Chapter 13 of Consigli’s Safety & Health Program for more detail
Dropped Objects Prevention and Planning: Stop the Drop!
The purpose of the Consigli dropped object prevention and control program is to assure that, whenever the potential exists for objects falling from heights, said exposure is adequately planned with controls identified and implemented.
Consigli will implement the planning necessary to protect all workers from dropped objects by focusing on eliminating or protecting anyone working below operations overhead. This program will be enhanced through planning, training, auditing, and enforcement.
Site specific fall protection plans developed by the project team – in conjunction with the Safety Department – shall include a section that addresses dropped object protection. It shall also be included in all Job Safety Analyses.
Dropped Object Controls:
- Coordination of overhead work with operations below.
- Barricade hazardous areas and post warning signs. Use of caution or danger tape shall not allowed. Use rope or chain.
- Use toe boards, screens on guardrails or scaffolds to prevent falling objects.
- Use debris nets, catch platforms or canopies to catch or deflect falling objects
- Securing tools, materials, and PPE (Hard Hats) by use of a tether, pouch or lanyard. When selecting attachment points consider the following:
- The location or type of tool. The attachment point should not increase the potential risk of dropping the tool.
- Anchor attachment points should be selected in order of preference: 1) structure, 2) waist, and 3) wrist.
- Choose the shortest tool tether possible
- Know and adhere to tool tether weight limits. Standard for dropped objects understanding ANSI/ISEA 121-2018.
- All dropped object solutions shall be inspected before each use and replaced immediately if found to be damaged or otherwise compromised.
Dropped Object Management and Control
Consigli Safety will audit Dropped Object controls in the field to assure compliance and effectiveness of implementation. Site specific fall protection and dropped objects applications will be discussed as part of the internal pre-construction safety meeting at the beginning of the project. Foreman will be briefed on weekly dropped object protection issues as part of the weekly “Job Safety Analysis” and prepare and plan accordingly.
Work on Ladders: All work on step ladders/straight ladders will be done correctly per manufacturer’s recommendations. Any worker who is on a step/straight ladder and could be exposed to a fall greater than the height of their work on the ladder will be required to install a form of fall protection. Step ladders will not be used as a form of access to a walking /working level. Only ladders with a rating Type 1A or 1AA will be allowed on Consigli projects.
All ladders shall be inspected prior to each shift. All ladders found defective or damaged shall be removed from service immediately. All ladders shall be fiberglass railed type. No Aluminum railed ladders shall be used on Old Rhinebeck AD AVRO Hangar Rep Project.
Scaffold and elevated work platforms: All scaffolds supported frames, pipe and staging platforms will be inspected daily before each shift by a competent person designated by each individual contractor who will be using it, which will be documented on Inspection tags located at the stair tower to each section. A scaffold checklist guide will be provided to Consigli by each sub-contractor designated persons to document daily inspection.
All contractors who will be erecting scaffold will provide Consigli 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 at any buildings which are located under any form of scaffolding.
The installation of protection is required at 6’ on all scaffolds, on mobile scaffold fall protection is required at 4’. Mobile staging with a work platform with a height to base ratio greater than two to one will require outriggers. All scaffolding that is procured by Consigli and is over 15’ in height will require that the Consigli Safety Department review the scaffold prior to it being turned over for use by tradesmen.
**Review Chapter 14 of Consigli’s Safety & Health Program for more detail
AERIAL/SCISSOR LIFTS: (CONSIGLI PROGRAM APPENDIX HH – SCISSOR LIFT INSPECTION FORM, APPENDIX JJ – AERIAL LIFT INSPECTION FORM)
Aerial and Scissor lifts used on the Old Rhinebeck AD AVRO Hangar Rep project will require consistent monitoring of construction operations to ensure workers operate such elevated platforms under the safest site conditions. This will include at a minimum the following;
1. Area and ground conditions in the intended work area will be inspected for overhead power lines, sink holes, covers, or any other unsafe conditions.
2. Aerial and scissor lift platforms, if utilized, will be inspected daily before each shift by a competent person designated by each individual contractor utilizing them.
3. All contractors who will be performing work from an aerial lift will show documented proof of training for each worker using said lifts.
4. If necessary, steel plates, or equivalent, will be placed on the ground above known underground structures if lifts will be operating on them. Workers will be tied off at all times when using an aerial lift.
5. Required fall arrest systems for the type of work platform lift utilized is supplied and used by each worker operating or using lift. Fall arrest equipment required shall be supplied by the subcontractor employer.
6. Elevated platforms shall be used as per the manufacture’s recommendations. All operators’ manuals shall be kept with each piece of equipment utilized.
7. All manufacturer Safety Warnings on the elevated platforms shall be in good condition and legible.
8. When determining safe operation of aerial/scissor lifts during wind conditions, the “Beaufort Scale of Wind Force” chart detailed on Page 14 shall be referenced.
** Please review chapter 14 of Consigli’s Safety and Health Program for additional details
Equipment issues: All operators will be required to have in their possession all appropriate licensing and training as required by OSHA and the NYS Department of Labor. All safety devices and warning alarms must be in good working order and all leaks are to be repaired immediately. All equipment will be used in accordance with the manufacturer’s recommendations for safe usage and have its operator’s manual as well as an extinguisher with it at all times.
Subcontractors who will have equipment on site will be responsible for having a spill kit available at all times. Superintendent shall designate the location of parked equipment following the end of each work day.
** Please review chapter 24 of Consigli’s Safety and Health Program for additional details
|Beaufort scale of Wind Force|
An aerial lift can be very dangerous. Operating an aerial lift when it’s windy can be a deadly mistake. You must be able to determine if the wind force is too dangerous to safely operate your aerial lift. Below is a chart to help you determine the wind speed and if you should or should not be working. The Beaufort Scale of Wind Force is accepted internationally and used in communicating weather conditions. It consists of number 0 – 12, each representing a certain strength or velocity of wind at 33 feet (10m) above ground or in the open. This should be used to assess when it is safe to operate your powered access equipment.
|Description of wind||Specification for use on land||MPH|
|0 Calm||Calm, smokes rises vertically||< 1|
|1 Light Air||Direction of wind shown by smoke drift but not by wind vanes||1 – 3|
|2 Light Breeze||Wind felt on face; leaves rustle; ordinary vanes moved by wind||4 – 6|
|3 Gentle Breeze||Leaves and small twigs in constant motion; wind extends light flag||7 – 10|
|4 Moderate Breeze||Raises dust and loose paper; small branches are moved||11 – 16|
|5 Fresh Breeze||Small trees in leaf begin to sway; crested wavelets form on inland waters
YOU SHOULD STOP MOST POWERED ACCESS PLATFORM & BOOM WORK UNDER THESE WIND SPEEDS
|17 – 21|
|6 Strong Breeze||Large branches in motion; umbrellas used with difficulty||22 – 27|
|7 Near Gale||Whole trees in motion; inconvenience felt when walking against wind||28 – 33|
|8 Gale||Breaks twigs off trees; generally impedes progress||34 – 40|
|9 Strong Gale||Slight structural damage occurs, slate blows off roofs||41 – 47|
|10 Storm||Seldom experienced on land, trees broken or uprooted, “considerable structural damage”||48 – 55|
|11 Violent Storm||Generally not experienced on land. On the water: Exceptionally high (37-52 ft.) waves, foam patches cover sea, visibility more reduced||56 – 63|
|12 Hurricane||Rarely experienced on land. On the water: Air filled with foam, waves over 45 ft., sea completely white with driving spray, visibility greatly reduced||> 64|
6 feet subtract 30 percent, 10 feet subtract 20 percent, 20 feet subtract 10 percent, 50 feet add 10 percent, and 100 feet add 25 percent
Workers will be tied off at all times when using an aerial lift.
Crane: Crane use does not appear to be scheduled for work on this project. If there is a change to the project scope all cranes will require most recent independent annual 3rd party inspections and will be utilized for operation only after detailed lift plans are submitted. It is anticipated that these cranes will be hydraulic. In the event that a lattice boom crane is utilized, then the crane must get an on-site 3rd party inspection once the crane is assembled, prior to operation.
There is a requirement to assure that certified riggers, signalmen, and crane assemblymen are utilized. All picks are to be done by a licensed operator. As previously mentioned, a detailed pick plan will be required to assure 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, 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 Consigli Crane Safety policy.
- All Hoisting equipment will have an up to date 3rd party inspection certificate approved by Consigli Safety Department with the equipment which will be copied and filed in the office trailer.
- All lattice boom cranes will have an independent 3rd party inspection completed each time one is set up on the project, after assembly and prior to operation.
- All equipment operators will be required to have in their possession all appropriate licensing and training as required by OSHA and the NYS Department of Labor.
- All underground vaults and existing utilities will be marked before as well as before any crane is set up.
- Documented rigging equipment inspections.
- Documented daily crane inspections filed with Consigli weekly.
- Documented rigger and hand signalman training will be provided.
- Documented verification of property “High Voltage” Power line identification.
**Review Chapter 24 of Consigli’s Safety & Health Program for more detail
Chemical and Materials: All Materials and chemicals used on-site will have SDS/SDS sheets provided before being brought onsite.
- SDS/SDS sheets on file in Consigli Construction’s Site Safety Plan
- All SDS/SDS sheets shall be readily accessible.
**Review Chapter 20 of Consigli’s Safety & Health Program for more detail
FIRE PROTECTION: (CONSIGLI PROGRAM APPENDIX OO – HOT WORK PERMIT)
Consigli construction will be adopting NYS Building Fire Code, Chapter 14 “Fire Safety during Construction” and maintaining compliance of the aforementioned fire code throughout construction. It is for this compliance requirement that at a minimum one of the following shall be supplied;
- Public Fire Alarm/Call box shall be readily available at a designated location outside the project site gate (North Gate 1) or,
- Instructions shall be posted near the call box that identifies;
- 911/Fire department direct telephone number
- Address of the project site
Consigli’s hot work permit program (Appendix OO) shall be implemented for all hot work to be conducted on the project. This work shall be coordinated and executed through Consigli’s Superintendent. The following additional policies shall be incorporated during all Hot Work on Old Rhinebeck AD AVRO Hangar Rep Project;
- If required by the nature of the work and campus regulations, the Consigli Superintendent shall obtain from the Campus “Confined Space Permits” or “Hot Permits”.
- Consigli shall perform all hot work in accordance with the Fire Code of New York State and the Hot Work Program approved for the work.
- Consigli Superintendent shall take all reasonable precautions against fire and provide all temporary plans, programs, equipment, labor and material required for compliance.
All hot work will be attended by trained “fire watch” and shall stop one half hour before the regular end of the day work. All combustible or flammable materials will be stored in an appropriately rated lockable cabinet located no closer than 50 feet from the nearest structure.
Fire extinguishers will be provided for every 3000 square feet of building area and maintained during construction. In addition;
- All extinguishers shall be installed on job made stands and conspicuously located throughout the project.
- All extinguishers shall be part of the daily inspection with extinguisher log completed monthly.
- Storage of any oxygen or acetylene cylinders will be done in a secure and upright area, with good ventilation.
- Old Rhinebeck AD AVRO Hangar Rep project will strictly enforce “No Smoking” outside the Designated Smoking location set forth in the site logistics plan.
- Noncombustible materials (metal or fire-retardant material) for scaffold, trash chutes, forms, shoring, bracing, temporary stairs, ramps, platforms and boxes shall be used when such items are required during the work.
- Temporary fuels used for temp heat or equipment filling shall have minimum 20lb. ABC multi-purpose extinguisher mounted/located a minimum of 20 feet with identification signage.
- Temporary fuels shall have barricade protection
- Temporary fuels shall have signage indicating “No Open Flames” and “No Smoking”.
- Each temporary heating unit shall have its own designated multi-purpose extinguisher rated no less than 10lb. ABC.
** Please review chapter 17 of Consigli’s Safety and Health Program for additional details
Electrical Requirements: All electrical tools, cords and equipment must be in good working order. Old Rhinebeck AD AVRO Hangar Rep project will require that exit lighting and interior stairway and corridor lighting be illuminated 24 hours a day 7 days a week. To that end, all electrical tools and components must be visually checked on a daily basis and include the following;
1. Any tools with damaged cords must be taken out service immediately.
2. Allcords must be equipped with a ground pin, flat three wire cords are not allowed.
3. SJO and SJT or other similarly rated cords only shall be used.
4. All cords used must be 12 gauge or better.
5. The electrician will be responsible for all temp power and any general temp lighting that may be needed.
6. Temp lighting strings with cages designed to protect bulbs from damage must be wire tied closed to prevent accidental opening.
7. Any exposed electrical temp lighting or empty sockets shall be repaired by electrical subcontractor immediately upon notice.
8. Subcontractor electrician shall conduct weekly inspection of all temp lighting strings for deficiencies.
9. Subcontractors will be responsible for task lighting in the event that lighting above the OSHA standard is required for a particular work task.
10. 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.
11. GFCI will be tested by the electric contractor to assure proper function with a log book filed with CCC monthly.
12. No live electrical work will be conducted per NFPA 70E.
13. All portable generators/welding generator systems shall be equipped with GFCI protection.
14. If systems are not equipped with GFCI protection, all workers utilizing system for temporary power shall utilize plug-in type GFCI devices to protect all workers from electrical shock.
15. Consigli Construction (CCC) reserves the right to disable any flexible cord on site when cord is found to be in non-compliance with this section. Disabling means of all non-compliant flexible cords is at the discretion of Consigli Construction up to and including cutting of cap and plugs to ensure flexible cord cannot be utilized to create a greater hazard.
**Review Chapter 26 of Consigli’s Safety & Health Program for more detail
Utility Exposures: High Voltage identification shall be communicated to every subcontractor prior to use of any equipment which may come in to contact with them. All sidewalks will be protected if equipment is to be driven over them. All street work shall have a separate written plan that accounts for protection of the public.
Confined Space: If confined space work is to be performed a written plan will be needed to work in any tanks/vaults and crawl spaces during this project which have been designated permit confined spaces by Consigli, this plan must include air monitoring.
All certifications of training as well as field monitor calibration shall be supplied in the plan prior to commencement of work. Preconstruction meeting shall be scheduled prior to any confined space work to review the plan and make any corrections to the plan prior to such work.
**Review Chapter 21 of Consigli’s Safety & Health Program for more detail
Designated First Aid Plan: All injuries no matter how minor must be reported to Consigli Superintendent immediately. The superintendent will then report all injuries to the Consigli Safety Manager Edwin Robinson. A fully stocked first aid kit and blood borne pathogens kit shall be maintained on the project site. Only properly trained personnel will administer first aid. Consigli Construction Management shall follow Site Safety Plan for first Aid. Report any incidents to the Safety Manager.
IMPORTANT: All eyewash stations shall be maintained in a clean condition throughout the projects scheduled completion date.
**Review Chapters 1 & 27 of Consigli’s Safety & Health Program for more detail
Evacuation Plan (RACE, and Routes of Egress): Please refer to the Evacuation Plans attached. All Consigli employees and subcontractors shall attend the Project Site Specific Safety Orientation. Consigli Construction’s Project Superintendent will conduct a safety orientation talk to each employee and subcontractor to site specific Safety & Conduct protocols.
Evacuation/Muster plan shall be posted in the site office as a means of ensuring all workers are made aware of the location of any emergency evacuation. The superintendent shall provide an overview of the emergency evacuation plan at the time of the site-specific orientation with all workers.
The amount of sanitary facilities required shall be based on the total number of workers employed on the Project and shall be in accordance with OSHA’s provisions outlined in Table D-1 of 1926.51(c)(1). At a minimum the following shall apply in order to maintain the highest level of sanitary conditions during and up to completion of construction;
- Maintain all units in a clean and sanitary condition.
- At the minimum, clean on a weekly basis, and more often as required by the applicable OSHA sanitary standards for number of workers on the project site.
- Provide all toilet supplies as required, including toilet paper, soap, paper towels, and waste receptors.
Substance Abuse: As a condition of employment, all 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.
Emergency Management Response: In the event of an Emergency the construction workers shall leave all 3 of the building immediately. Point of assembly/muster shall be located East Parking lot located on the south side of Plaza Road. In the Event of a DISASTER, the Superintendent or Safety Manager shall instruct the construction workers to leave the site or remain in place and await further instruction. The following steps should be taken in the event of an emergency;
When reporting an emergency, please provide the following:
• Your location (Old Rhinebeck AD AVRO Hangar Rep, 9 Norton Rd, Red Hook, NY 12571) 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 name and amount of the material spilled (if applicable); and
• The safest route to the incident site (if applicable).
**Review Chapter 8 of Consigli’s Safety & Health Program for more detail
Minimum PPE Requirements
Project Superintendents shall be responsible for assuring that all workers comply with the Personal Protective Equipment requirements. The Site Safety Manager will periodically audit for field compliance. The Minimum Personal Protective Equipment requirements are as follows:
- All workers will be thoroughly indoctrinated by their respective employer and trained in the proper use of required protective equipment. Defective or unacceptable PPE will be removed immediately from service
- The Old Rhinebeck AD AVRO Hangar Rep project shall be a Mandatory Hard Hat Job.
- All workers will require 100% eye protection. All overhead work will require the use of either a face shield or pair of goggles in conjunction with safety glasses.
- All workers manually manipulating materials are required to wear gloves that are appropriate to the material manipulating task. Exceptions include lunch, restroom breaks, and office work. In addition to utilizing gloves, the subcontractor employer shall be responsible for training workers into proper use and limitations of the gloves utilized.
- Subcontractors JSA’s need to document hand and finger hazards, and glove selection and use for protecting against said hazard.
- Employees shall be provided with face protection equipment when power tools, machines or operations present potential eye or face injury from physical, chemical, or radiation agents.
- Hearing protection against the effects of noise exposure shall be worn when sound levels exceed 85 dba as calculated by the Safety Manager on site. Each subcontractor supervisor shall make available at all times, the proper hearing protection for each worker.
- Respirators/nuisance masks, when needed for sweeping or other dusty conditions are to be provided by each subcontractor supervisor under the OHSA regulation 1910.134 for voluntary use only.
- Impermeable rubber or any impenetrable protection shall be worn to prevent skin contact with any acid, chemical, creosote, coal tar, fuel oil or concrete. This is especially true for Concrete workers and masons.
- 100% High visibility vests shall be worn by workers at all times.
- Metatarsal guards will be used by workers handling tools capable of causing Metatarsal injury.
- Non-skid soles will be worn on safety shoes.
- Long pants are required at all times while on site. They shall be appropriate to the task being performed. Examples of acceptable pants include denim jeans, khakis, twill pants, or work pants. Examples of unacceptable pants include, but are not limited to sweat pants, nylon jogging/wind pants, pajama pants, flannel pants, etc.
- IMPORTANT NOTE: Personnel protective equipment for visitors shall include hard hats, high visibility vest and safety glasses as required.
PPE Training: Necessity, use, limitations, care and maintenance of all provided PPE by a subcontractor supervisor will be conducted upon issue. Said training is to be documented as part of the subcontractor’s toolbox talk meeting process. Retraining of employees by the subcontractor supervisor shall be conducted anytime site conditions change, PPE requirements change, or employee demonstrates improper use or lack of knowledge.
Personal protective equipment, which has been changed in any manner so as to reduce its effectiveness, shall be repossessed, repaired or destroyed. Personal protective equipment worn or used previously by a worker shall not be issued to another employee until the article has been cleaned and sterilized.
NOTE: All subcontractor employers shall be responsible for training all workers on site with the proper use and application of required Personal Protective Equipment.
Contractors are prohibited from entering any adjacent areas or buildings of the Old Rhinebeck AD AVRO Hangar Rep unless work has been previously authorized and scheduled by the Consigli Site Superintendent.
It is important that workers do not park on site, in/in front of adjacent driveways or block business and residential access driveways during construction. All workers will make every effort to limit their impact on surrounding campus and residential areas.
Lean requirements/Materials Management/Housekeeping: Getting materials into and out of the project will be a challenge that needs to be adequately planned. All deliveries are to be scheduled with the CCC Superintendent. A comprehensive Activity Hazard Analysis shall be done on all materials that will be hoisted and placed into the building. 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.
Listed below are additional Lean requirements
- No materials shall be delivered to the site earlier than 3 days before said materials are to be installed/put into place. If materials have to be delivered before that 3-day time period, subcontractor shall get prior approval from Consigli Superintendent. Because of this, notification / scheduling is required for all deliveries to the site.
- Subcontractors must notify Contractor at least 24 hours in advance. Contractor has the right to refuse any deliveries not properly scheduled or due to logistical constraints as necessary.
- All subcontractors’ delivered materials shall be placed on wheeled carts, wheeled racks or in wheeled bins so as to necessitate easy relocation in the event materials need to be moved. Carts, racks, or dollies shall not exceed manufacturers intended weight loads. Materials/tools can be delivered and stored on pallets only if pallet jacks are delivered simultaneously with said delivery to provide for ready mobility. Additionally, pallet jacks need to remain in immediate area. Each subcontractor will need to supply their own pallet jacks for their own materials and keep their pallet jack within reasonable distance at all times.
- All work stations shall be provided with wheeled trash bins for immediate placement of all debris produced as a part of the subcontractor’s operations. All trash will be immediately placed in wheeled containers provided by Consigli. All trash bins shall be covered when not in use.
- The wheel of rolling carts and bins shall receive be disinfected prior to entry into any clean environments.
- All subcontractors shall use rubber wheeled carts when moving material or removing trash from a building. Any damage caused by the Subcontractor shall be repaired at the cost of the Subcontractor. Back charges will be appropriately assessed for the cost of the repairs. No trash or materials shall be left on the floor.
- Subcontractors shall, where feasible, elevate all electrical extension cords, hoses, or cables – removing them from all walking/working surfaces. Electrical Cords, when elevated shall be supported or suspended in a manner that does not subject them to damage.
- Storage of delivered materials in cardboard containers shall be discouraged. When materials must stay in cardboard containers, said containers shall be removed from the projects immediately after product is unpacked.
- Subcontractor will participate in schedule development meetings as required by Consigli.
Back– End of Site Safety Plan
Environmental Emergency Contact and Management Response
Consigli identified Emergency Response Subcontractor;
Name: Quality Environmental Solutions and Technologies (Quest) (845)298-6031
Asbestos: A Hazardous Materials report shall be prepared by the owner (Old Rhinebeck AD AVRO Hangar Rep) and all hazardous material will be abated prior to work commencing in affected areas. This does not mean that asbestos could not still be found in other areas, caution must be used when working and if any workers identify any potentially hazardous substances then they should stop and notify their supervisor immediately. All identified asbestos will be fully abated by a licensed and regulated asbestos abatement contractor under a formal plan to be written, submitted and in accordance with the NYSDOL.
IT IS THE RESPONSIBILITY OF ALL SUBCONTRACTOR FOREMEN TO REVIEW THE HAZOUDOS MATERIAL REPORT & CORRESPONDING ABATEMENT REPORT WITH THEIR WORKERS. A copy of the hazardous Material/abatement report will be on site at all times and available to anyone request it. Due to the fact that some asbestos may remain in place and not be abated during construction all workers will need to have at a minimum Asbestos awareness training.
NOTE: All work and disposal will be done in compliance with state and federally regulated and standards
Silica: Where applicable, Consigli Superintendents shall ensure that all related construction activities with potential for Silica exposure will be consistent with OSHA’s Construction Standard Table 1 (APPENDIX DDD).
Superintendents are to ensure that each employee and subcontractor engaged in a task identified on OSHA’s Construction Standard Table 1 have fully and properly implemented the engineering controls, work practices, and respiratory protection specified for the task on Table 1.
Competent Person Requirements
All subcontractor employers shall identify a competent person to inspect and manage all activities with potential airborne silica exposure. Subcontractors working on projects within the scope of this Program shall appoint a competent person capable of managing and executing the duties described herein. The competent person must have training in the inspection of work areas and equipment and in the determination of safe working conditions.
This person shall have a working knowledge of the 1926.1153 standards, shall be capable of identifying airborne silica hazards, shall determine the need for initial and additional exposure monitoring, shall recommend and implement engineering and work practice controls as outlined in Table 1, shall establish levels of PPE, and shall have the authority to take action to eliminate hazards and correct incidences of noncompliance.
Lead: A Hazardous Materials report has been completed and has not identified lead paint on existing exterior building properties to be demolished. If found during construction, Consigli workers who will need to perform work on these painted surfaces may need to disturb this paint by drilling, sawing, demo, fastening, or carpentry.
In doing so they will use saws, drills, screw guns, impact wrenches, reciprocating saws, hand wrenches, ads, crowbars, hammers, and other hand tools. Consigli Construction does retain historical data to show that drilling, sawing, light demo, installation of hangers, hanging sheetrock, fastening, and carpentry do not put the employee above the action level. Despite this additional monitoring will be done. An exposure assessment will be done by all subcontractors for all task prior to when the full scale of this work is to take place. This does not mean that lead could not still be found in other areas, caution must be used when working and if any workers identify any potentially hazardous substances then they should stop and notify their supervisor immediately.
All workers on this must have completed Lead Awareness training prior to starting on this project. Hand wash stations will be provided to ensure proper hygiene during the project. An exposure assessment will also be done for any task to which lead containing material surfaces will be disturbed.
Mold: Mold issues are not anticipated to be prevalent on this project, however if mold is discovered Consigli’s mold remediation policy will be implemented and followed.
**Review Chapter 22 of Consigli’s Safety & Health Program for more detail
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 7:00 am and 4:00 pm Mon-Fri. Any contractor who may need to work outside the contracted work hours specified in this section must first seek approval from the CCC Superintendent.
Noise levels will be monitored when high levels of noise could be expected to assure that noise levels do not exceed acceptable OSHA levels. Consigli permissible noise policy and procedures will be followed. All subcontractors will be required to have and maintain a written hearing conservation program at the time of work that outlines control measures designed to mitigate and control worker noise exposure. At a minimum the following shall be part of the subcontractor’s safety and health noise management program;
- Consigli superintendent shall coordinate with Old Rhinebeck AD AVRO Hangar Rep on all excessive noise levels in order to minimize the impact to any surrounding facilities.
- Subcontractor supervisor shall protect workers from exposure to noise when such exposure has the potential to exceed OSHA’s Permissible Exposure Limits outlined in Table D-2 of 1926.52(d)(1).
- Subcontractor supervisor shall upon competent evaluation of a worker’s exposure to noise ensure that the worker is monitored and protected and that all engineering and administrative controls necessary to protect worker from hazardous noise levels are implemented.
- Subcontractor employer shall be responsible for supplying proper hearing protection where and when required.
- Subcontractors shall ensure all tools and equipment being operated on the project site are equipped with the appropriate manufacturer’s recommended noise reduction device(s), including a muffler and jacket, free from air or exhaust leaks.
- Subcontractor employer shall be responsible for ensuring all workers are trained in the proper use of personal protective equipment designed to protect employees from noise levels that exceed those outlined in OSHA’s Table D-2 described in this section.
**Review Chapter 29 of Consigli’s Safety & Health Program for more detail
Exposure to the Visitors, Staff and Residents: During all phases of construction pedestrian walkways around the project will be open and occupied. Some areas of project will be opened for construction at different times. Any pedestrian walkway under any type of scaffold or overhead hazard will be provided with overhead protection as per Consigli’s Safety and Health Program requirements. At no time is any worker allowed to enter any of the adjacent buildings of the Aerodrome Property. Non-fraternization with staff, and guests will be stressed with all subcontractor personnel during site specific orientations.
Additional Controls: Prior to start of any work, all personnel involved in the project, including project managers must be:
- Trained and orientated by Consigli Construction. Stickers will be issued and displayed on hard hats
Planning: (Consigli Program Appendix E – Competent Person ID Form)
The project team, as well as CCC safety department, will meet with each subcontractor before they start to review their Site-Specific Safety and Health Program and all project specific Job Hazard Analyses. The project team shall be an integrated mix of Old Rhinebeck AD AVRO Hangar Rep Staff and Consigli Construction personnel.
After reviewing the programs and meeting with the individual subcontractor, if the team is satisfied with the risk control direction, they will be permitted to begin work. Elements of the pre-planning safety meetings shall include at a minimum;
- Scope of work performed by the subcontractor
- Number of employees that the subcontractor will need to fulfill the contracted work
- Scheduled start date
- Review of potentially hazardous conditions associated with the contracted work
- Safety measures subcontractor will implement to protect workers and workers of other trades.
- Required licensing and training requirements
- Copy of subcontractors written safety and health program
- Review by Consigli’s safety department of required written safety programs specific to high hazard work processes.
- Identification of subcontractors Competent Person (Appendix E)
Consigli’s Project Superintendent must be verbally notified by the subcontractor’s supervisor immediately that an accident has taken place and that one or more of his employees has been injured. Any injury, even minor in nature, requiring a visit to an outpatient medical clinic for treatment, must be reported, by the Consigli Superintendent, on the Consigli “Incident Investigation Report” (APPENDIX R).
The Consigli Superintendent must verbally notify the Corporate Safety Manager of any Injury Incident as soon as possible and submit the aforementioned written investigation reports within 24 hours. Maintain a copy of all accident reports on file at the jobsite
Damage to Property: Any property damage accident, whether project property or non-project property, must also be reported on the Consigli Incident Investigation Report Form” (APPENDIX R) as well.
The Consigli Superintendent must verbally notify the Corporate Safety Manager of any damage to property as soon as possible and submit the aforementioned written investigation reports within 24 hours. Maintain a copy of all accident reports on file at the jobsite
A near miss is a potential hazard or incident that has not resulted in any personal injury or property damage. Unsafe working conditions, unsafe employee work habits, improper use of equipment or use of malfunctioning equipment have the potential to cause work related injuries. It is everyone’s responsibility to report and/or correct these potential accidents / incidents immediately.
- Any employee can fill out a near miss report (APPENDIX GG) and forward it to the Superintendent to submit to the Safety Department. Please include photographic documentation.
- Each jobsite is encouraged to investigate and report all near misses.
- Near Miss IHTUs will be reviewed at each Quarterly Safety Meeting.
OSHA Reporting Requirements
All OSHA related reporting requirements shall be coordinated through the Regional Safety Manager. OSHA has outlined basic mandated reporting requirements under section 1904 addressing all of the following Accidents;
- Within 8 hours for any job-related fatality
- Within 24 hours following in-patient hospitalization of 1 or more employees within 24 hours of employee amputation or loss of an eye
NOTE: Incidents involving worker injury or property damage must be reported to Consigli’s Safety Department immediately by the project team.
** Please review chapter 9 of Consigli’s Safety and Health Program for additional details
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