The Safety Professionals Guide to Planning and Executing Capital Projects

Transcription

1 The Safety Professionals Guide to Planning and Executing Capital Projects Steven M. Hochstadt, P.E., CSP Sr. Environmental, Health & Safety Manager Bay Area Safety Symposium American Society of Safety Engineers

2 Introduction Responsibilities of EHS Managers Regulatory Compliance Program Development Audits & Inspections Hazard Control Claims Management Plan Review - Projects Safely Planning & Executing Capital Projects 2

3 Capital Projects: Definitions A long-term investment made in order to build upon, add to or improve on a capital-intensive project. A capital project is any undertaking which requires the use of notable amounts of capital, both financial and labor, to undertake and complete. Capital projects are often defined by their large scale and large cost relative to other investments requiring less planning and resources. (Investopedia) Safely Planning & Executing Capital Projects 3

4 Definitions (con t) Screening - is the investigation of a great number of something (for instance, potential EHS issues) looking for those with a particular problem or feature. Capital Projects Requires investment of >$10M. Screening Tools Used to identify critical EHS aspects or risks of a project. Safely Planning & Executing Capital Projects 4

5 Types of Projects New building construction Building demolition Major lab renovations (exhaust, waste systems, new equipment) Seismic & safety retrofits (ADA, Code Updates) Installation, or replacement, of key building systems (fire prevention, alarms, security) Site improvements (café, fitness, conference) Safely Planning & Executing Capital Projects 5

6 Project Teams Capital projects are usually delivered using a prescribed process by a project-specific cross functional team of stakeholders, including: Business unit/end user (Customer) Project Management/Engineering Facilities Planning & Services Risk Management & Compliance Finance Reliability, Validation, QA EHS Consultants & Contractors Safely Planning & Executing Capital Projects 6

7 Screening Tools EHS screening checklist can vary depending on size & complexity of project Small (non-capital) projects may require a quick review of general EHS categories Capital projects require a more comprehensive review of all EHS aspects & risks Usually completed by EHS & Project Manager during Basic or Conceptual Design Phase. Safely Planning & Executing Capital Projects 7

8 Use of Screening Checklists Used to identify various EHS aspects of the project. Will help Project Manager budget for the EHS items identified. Will require planning & follow-up by EHS Project Manager to assure proper permits are obtained and compliance achieved. Used to determine EHS strategy & plan and for project documentation. Safely Planning & Executing Capital Projects 8

9 EHS Aspects All projects are evaluated for potential EHS impacts & risks during Conceptual Design including: Fire/Life Safety fire/gas detection, alarms, egress Physical Safety electrical, noise, eqpt, ergonomic layout Hazardous Materials storage & distribution systems Chemical/Industrial Hygiene lead, asbestos, chemical, bio, radiation exposures and exhaust ventilation Environmental hazardous wastes, emissions, soil, GW, SPCC, storm water & wastewater Process Safety hazard control, eqpt review Sustainability energy, recycling, refrigerants Safely Planning & Executing Capital Projects 9

10 You have the List, Now What? Use the aspects identified on the list to: Determine EHS Strategy How am I going to mitigate the issues, keep the project on schedule, within budget and obtain all permits? Are consultants needed? What type? Who? Is in-house support available (SMEs)? Which permits are needed? What data is required? Which agencies need to be contacted? Contractor Selection: Skills Required, Safety Record. Safely Planning & Executing Capital Projects 10

11 EHS Project Support Plan Review Contractor Selection & Audits Site Inspections Accident/incident investigations Site permits & agency inspections Equipment review & commissioning Program development & training Safely Planning & Executing Capital Projects 11

12 Plan Review Fire code alarms, pull stations, exits, signage Gas & fire detection smoke, O2, NH3, explosion Safety eqpt shower/eye wash, first aid, rescue, fire extinguishers, PPE & spill cabinets. Haz mat & waste storage, classifications Safety railings, barriers, signage Waste collection & treatment Ergonomics & material handling Environmental spill containment Safely Planning & Executing Capital Projects 12

13 Contractor Selection Need to do your due diligence Services available to provide review criteria for a fee IIR, Xmod, OSHA history Insurance coverage & certificates IIPP & Written Safety Programs Organizational Structure, Policies & Staff Experience on similar projects Safely Planning & Executing Capital Projects 13

14 Contractor Safety Plan Review Review their plans & written programs: Is their IIPP site & project specific? Are the written programs adequate & applicable to the project? Does their Emergency Plan address reasonable contingencies for location? Do they have proper training & records? Are inspection records maintained? Job safety analyses for all hazardous tasks? Yes, subcontractors must be included! Safely Planning & Executing Capital Projects 14

15 Written Safety Programs IIPP project specific, most important Job Safety Task Analyses & hazard controls Training Program Emergency Plan site specific, first aid, fire, injuries Hazard Communication with MSDSs on-site Fall prevention, confined space, PPE, excavation, ladders/scaffolds, hot work, subs, LOTO, fire prevention, industrial trucks, injury reporting, and many more as applicable to project ****Review, and if NOT satisfactory, request revisions, as these written programs are the Contractors Commitment to Safety Safely Planning & Executing Capital Projects 15

16 Inspections Auditing the Contractors Commitment to Safety Review the implementation of their written plans Check inspection, training, incident & JHA records Perform site inspection with Contractor s Safety Rep Observe behaviors, as well look for hazards Use checklist for documentation & forward to Safety Rep Request corrective actions & follow-up Provide praise as needed, as construction sites are full of potential hazards & contractors have key investment in project s safety. Safely Planning & Executing Capital Projects 16

17 Inspection Checklist Must meet Construction Safety Orders: 29 CFR 1926 & CCR Title 8, Subchapter 4 Look for the following, indicate S, U or N/A: PPE, what s required & are they wearing it? Emergency/first aid eye wash, first aid kits, fire extinguishers, exits marked & not blocked, postings with emergency phone #s Hazardous materials MSDSs, storage, labels, flam liquids, spill eqpt, compressed gases, gas monitoring Ladders, stairs, scaffolds, floor openings, power tools Permits (site & regulatory) excavations, hot work, lifts, industrial trucks, confined spaces Electrical GCFI, grounding, cords, LOTO, panel labeling Housekeeping Not a clean room. Clear egress. ID hazards. Safely Planning & Executing Capital Projects 17

18 Construction Safety Training The OSHA Outreach Training Program: Training on the recognition, avoidance, abatement, and prevention of safety and health hazards in the construction industry. Voluntary program, does not meet training requirements for any OSHA standards. Reviews key sections of CFR. Delivered by OSHA-authorized trainers. The 10-hour class is intended for entry level workers, The 30-hour class is more appropriate for supervisors or workers with some safety responsibility. Classes offered at ASSE PDCs & NSC Congresses Safely Planning & Executing Capital Projects 18

19 Consultants Why Do you Need Them? How Do You Select Them? Preparing RFQ/SOW & Reviewing Quotes. Who s Doing the Work? Do s & Don ts. Checking on Progress. Deliverables. YOU ARE Responsible for your Consultants! Safely Planning & Executing Capital Projects 19

20 The Safety Professionals Guide to Planning and Executing Capital Projects Case Study # 1 Construction of a New Research Building Safely Planning & Executing Capital Projects 20

21 EHS Screening Checklist Project Description Project Title Location Project Manager Project Team Members Funding Approval Estimated Start & Finish dates Brief Description Planned use, square footage, acreage, number of floors, etc. Safely Planning & Executing Capital Projects 21

22 Project Scope Are contractors needed? Is GC selected? Yes GC TBD. Several sub contactors to be used. Is demolition needed for existing structures? NA. Is building or space to be remodeled? NA. Will there be soil excavation? Yes. Soil to be tested prior to disposal. Will fire alarms, suppression system or walls be impaired? NA. New building. Will new property be purchased or leased? Yes. Property purchased. Check prior usage. Phase I ESA? Safely Planning & Executing Capital Projects 22

23 Hazardous Materials Will hazardous materials be used during project? Yes, as needed for construction. HMBP submitted by GC. Will hazardous materials be added after project? Yes, as needed for research. HMBP submitted by EHS. Will hazardous wastes be generated during or after project? Yes. EPA Generator ID# for research wastes. Will project change hazardous materials used in existing processes? NA. Safely Planning & Executing Capital Projects 23

24 Equipment Will existing utility systems (drains, piping, electrical, HVAC) be altered? No. New building. Will removing existing equipment require hazardous waste disposal? NA. Is new equipment added for exposure control or haz mat containment? Yes. Exhaust vents, hoods. Will new eqpt added create hazards? Yes. Evaluate. Will sewer or storm systems be modified? Yes. New sewer connections to be made. Will permanent safety equipment be added? Yes. Fire extinguishers, first aid kits, shower/eye wash, AEDs. Safely Planning & Executing Capital Projects 24

25 Physical Hazards Will new energy sources be involved? Yes. Eqpt & processes require steam, heat, pressure & electricity. LOTO. Will there be hot work (welding, brazing, grinding)? Yes. Hot work permit required. Off hours construction, noise, dust concerns? Yes. As typical in construction. Few neighbors in area. Use controls. Confined space entry required? Yes. Excavations. Fall protection needed? Yes. Unprotected elevations. Overhead work? Yes. Cranes, lifts & ladders. Will changes be made to exits or egress routes? NA. New building. Safely Planning & Executing Capital Projects 25

26 Environmental Will there be discharge of industrial wastewater? Yes. Use process knowledge to characterize discharge. Apply for permit. Will there be air emissions (VOCs, Toxics)? Yes. Review eqpt specs. Hire air consultant. Apply for permits from AQMD. Will there be generators or boilers? Yes. Special permitting & monitoring requirements. Source testing required per AQMD. Will there be haz wastes requiring disposal? Yes. Typical lab wastes. Apply for EPA ID #. Hire waste handling & disposal contractor. Will there be haz mat storage in tanks? Yes. Gases, fuel & treatment chemicals. Add to HMBP, SPCC. Will haz mats be handled near storm drains? Yes. Need containment, spill control plan (SPCC) & SWPP. Will lead or asbestos be disturbed? NA. New construction. Safely Planning & Executing Capital Projects 26

27 EHS Issues Hazardous Materials & Waste Permits HMBP filed with County, multiple inspections Secondary containment required in utilities area Typical lab quantities & hazard classes (FL, CL, NFG, Corr) ABTs for fuel and cryogenic liquid storage Waste storage room with secondary containment, gas detectors, alarms, emergency eqpt EPA Generators ID# obtained for site Emergency Response Plan prepared & Team formed Waste collections & inspections performed by contractor Safely Planning & Executing Capital Projects 27

28 EHS Issues Waste Water Permit Strict discharge limits due to Regional GW issue Concerns with ph, salinity, minerals, temp, flow Process, sanitary & industrial waters modeled for discharge, using various conditions Treatability study to select neutralization system Application submitted, amended, negotiated Interim permit granted. Flow limitations. Extended sampling program. Flow meter issues. Safely Planning & Executing Capital Projects 28

29 EHS Issues Air Permits Boilers, heaters, generators Consultant used to file permit applications Risk Assessment & Air Dispersion Model - contours Initial & Annual Source Testing (CO, NOX, O2, CO2) AQMD site inspection during source testing Permit issued with conditions Annual reporting & testing (operating hours, gas use) Safely Planning & Executing Capital Projects 29

30 EHS Issues SPPC & SWPP Oil and fuel tanks present (>55 gal) Spill prevention plan written (CA APSA) Site inspection & training programs Fueling, drainage & spill procedures Shut off valves & covers for storm drains Catchment drains at loading docks Storm water runoff to private basin No permit reqd. Lease agreement controls (BMPs) Safely Planning & Executing Capital Projects 30

31 The Safety Professionals Guide to Planning and Executing Capital Projects Case Study # 2 Demolition of Old Research Building Safely Planning & Executing Capital Projects 31

32 EHS Screening Checklist Project Scope Are contractors needed? Is GC selected? Yes. GC TBD. Several sub contractors to be used. Support selection process. Is demolition needed for existing structures? Yes. Structures & utilities to be demolished. Select demo contactor. Is building or space to be remodeled? Yes. Site to be used for parking lot. Will there be soil excavation? Yes. Test soil prior to disposal. Will fire alarms, suppression system or walls be impaired? Yes. At some point, system to be disconnected. Will new property be purchased or leased? NA. Safely Planning & Executing Capital Projects 32

33 Hazardous Materials Will hazardous materials be used during project? Yes. Labs & eqpt to be decontaminated using various cleaning solutions. Will hazardous materials be added after project? No. Will hazardous wastes be generated during or after project? Yes. Decontamination wash waters, lab wastes and surplus chemicals to be collected for off-site hazardous waste disposal. Will project change hazardous materials used in existing processes? NA. Safely Planning & Executing Capital Projects 33

34 Equipment Will existing utility or eqpt systems (drains, piping, electrical, HVAC) altered? Yes. All utilities to be removed. Will removing existing equipment require hazard waste disposal? Yes. All equipment to be decontaminated. Is new equipment added for exposure control or hazardous materials containment? NA. Will new eqpt added create hazards? NA. Will sewer or storm systems be modified? Yes. Cap. Will permanent safety equipment be added? NA. Safely Planning & Executing Capital Projects 34

35 Physical Hazards Will new energy sources be involved? No. Will there be hot work (welding, brazing, grinding)? Yes. Cutting. Hot work permit required. Off hours construction, noise, dust concerns? Yes. Adjacent building occupied. Controls to be implemented. Confined space entry required? Yes. Trenches. Nonpermit. Fall protection needed? Yes. Eqpt required while on roof. Overhead work? Yes. Cranes, lifts & ladders. Will changes be made to exits or egress routes? Yes. Changes made during various phases of demolition. Safely Planning & Executing Capital Projects 35

36 Environmental Will there be discharge of industrial wastewater? No. Terminate existing discharge permit. Will there be air emissions (VOCs, Toxics)? No. Asbestos. Will there be generators or boilers? Yes. Clean, remove & dispose. Terminate air permits. Will there be hazardous wastes requiring disposal? Yes. Decontamination wastes & lab surplus chemicals to be collected & disposed. Will there be haz mat storage in tanks? Yes. Drain, clean & remove above ground fuel tanks. Will haz mats be handled near storm drains? Yes. Cover drains. Prepare storm water plan for construction project. Will lead or asbestos be disturbed? Yes. Hire licensed contractors to sample and test, and to remove and dispose. File permit. Safely Planning & Executing Capital Projects 36

37 EHS Issues Haz Mat Decontamination SOW. Quotes from qualified contractors. Decontamination and Health & Safety Plans prepared. All eqpt drained & surfaces to be decontaminated. Hoods & ducts cleaned or removed as hazardous waste. Chemical & biological hazards. Surplus chemicals & contaminated supplies collected. Decontamination rinse waters collected for disposal. Wipe samples taken for analysis (ph, CAM 17 metals). Site inspections by CUPA. Closure report sent to CUPA. Permits retired. Safely Planning & Executing Capital Projects 37

38 EHS Issues Asbestos & Lead Present in older buildings (pre 1970s). Must be abated prior to demolition permit issued. Survey performed, samples taken by certified sampling contractor (CAC). Analysis at approved lab. Abatement report with results, locations & estimated quantities. Bid documents for abatement contractor. Abatement by licensed asbestos removal contractor. Permit required. Warning signs posted at site. PPE. Containment required. Disposal at Class 1 or 2 landfill. Approved hauler. Manifest to be included in final report. Safely Planning & Executing Capital Projects 38

39 EHS Issues Soil Sampling Soil data needed due to excavation, disposal & worker exposure needs, and to determine prior spills. Required for site HMBP closure. Potential sources fuel tanks, lab waste discharge. Contractor with subsurface sampling experience hired. Borings made around all sides of bldg. Samples at multiple depths. Analyzed for VOCs, metals, etc. No contamination found. No further action needed. Report provided to CUPA. Safely Planning & Executing Capital Projects 39

40 EHS Issues Equipment Disposal Much eqpt, tools & supplies left as surplus. If contaminated, clean, or dispose as hazardous waste. Tools & supplies distributed to depts & ee s. Larger eqpt gets sold to brokers, dealers. Many require certificate of decontamination. Sales contracts reviewed by Legal Dept. Buyer to transport. Assure eqpt is safe off. Safely Planning & Executing Capital Projects 40

41 The Safety Professionals Guide to Planning and Executing Capital Projects Conclusions EHS has a key role in Capital Projects. EHS is involved with Project Team early in design. EHS evaluates risks by screening project. EHS develops plan to mitigate risks. EHS obtains all permits & works with all agencies & inspectors. EHS assists with project turnover. EHS works with the Project Team & all contractors to assure project s safety & success. Safely Planning & Executing Capital Projects 41

42 The Safety Professionals Guide to Planning and Executing Capital Projects Q&A? Thank you for attending. Steven M. Hochstadt, P.E., CSP Safely Planning & Executing Capital Projects 42