underground division safety policy manual

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Underground Division Safety Policy Manual

January 2020

McMillen Jacobs Associates ii January 2020

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McMillen Jacobs Associates iii January 2020

Message from the President The McMillen Jacobs Associates Underground Division values its employees, and places a priority on ensuring that they work in a safe and healthy environment. We realize that with healthy, safe working conditions the productivity and quality of our work is greatly increased, and our employees can take these experiences and extend the benefits to their family and friends at home.

All of our operations are to be conducted in compliance with the Underground Division Safety Policy (which is contained in this manual and its appendices), Federal Occupational Safety and Health regulations, and/or rules and regulations of any federal, state, or local agency having jurisdiction.

The effective implementation of the Underground Division Safety Policy and our employees’ commitment to a safe and healthy work environment for all contribute to our successful future.

Our goals are simple:

To continue to develop and implement a safety culture through the organization by incorporatingthese principles

To involve all our employees—our greatest asset—in safety training, and in development,promotion, and performance of safe work procedures

To empower our employees to eliminate or reduce hazardous work conditions and acts to thegreatest extent possible

This Underground Division Safety Policy Manual is an update of the 2017 Safety and Health Management Program, and has been renamed to more accurately reflect the division’s goals and its employees’ commitment to a safe working environment. Since 2017, two appendices have been updated. The footwear policy was updated in Appendix A (Minimum Requirements for Personal Protective Equipment). Also, Appendix E (Fall Protection and Rope Access Safety Work) was substantially revised by the addition of Attachments B through G to address rope access job safety analysis and training.

The success of our Safety Policy requires the dedication, commitment, involvement, and participation of all personnel working together. Accordingly, I ask that each of you take the time to implement these goals, and assist those around you to do the same.

If you have questions, comments, or ideas on how to improve our safety performance, please contact the Corporate Environmental Health and Safety Director, the Underground Division Safety Committee, or the Underground Division Human Resources Department.

Dan Adams President McMillen Jacobs Associates


McMillen Jacobs Associates iv January 2020



McMillen Jacobs Associates v January 2020

Acronyms and Abbreviations AED Automated external defibrillator AL Action level ANSI American National Standards Institute APR Air purifying respirator ASAP As soon as possible ATC Air Traffic Controller (Belay Device) BAT Breath Alcohol Technician(s) bhp Brake horsepower BNSF Burlington Northern Santa Fe Railway Cal/OSHA California Division of Occupational Safety and Health C/TPA Consortium/Third Party Administrator CAZ Controlled access zone CCOHS Canadian Centre for Occupational Health and Safety CCR California Code of Regulations cfm Cubic feet per minute CFR Code of Federal Regulations CHP California Highway Patrol CM Construction Management, Construction Manager CO Carbon monoxide CO2 Carbon dioxide CPR Cardiopulmonary resuscitation CSHO Certified Safety and Health Official CSA Canadian Standards Association (formerly) CSO Construction Safety Order DAC Drug and Alcohol Counselor dB Decibel dBA Decibels A weighted DER Designated Employer Representative DHHS Department of Health and Human Services DOT U.S. Department of Transportation DRPGM Direct reading portable gas monitor EAP Employee Assistance Professional EIC Employee in Charge ESLI End-of-service-life indicator EMT Emergency Medical Technician FAQs Frequently Asked Questions


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FRA Federal Railway Administration GHS Globally Harmonized System for Classification and Labelling of Chemicals H2S Hydrogen sulfide H&S Health and Safety HAZMAT Hazardous material HCHO Formaldehyde HCP Hearing Conservation Program HEPA High efficiency particulate air HHS U.S. Department of Health and Human Services HIPPA Health Insurance Portability and Accountability Act hp Horsepower HPD Hearing protection device HR Human Resources IDLH Immediately Dangerous to Life or Health JHA Job Hazard Assessment JSA Job Safety Analysis JTA Job Task Assessment LEL Lower Explosive limit LOTO Lock-Out/Tag-Out MIS Management Information Systems MOW Maintenance-of-Way MRO Medical Review Officer MSHA Mine Safety & Health Administration MUTCD Manual on Uniform Traffic Control Devices NA, N/A Not applicable; nonapplicable NHISA National Highway Traffic Safety Administration NIOSH National Institute for Occupational Health NO2 Nitrogen dioxide NRR Noise reduction rating NSW New South Wales O2 Oxygen (dioxygen) OSHA Occupational Safety and Health Administration PAPR Powered air-purifying respirator PEL Permissible exposure limit PF Protection factor PFD Personal flotation device PPE Personal protective equipment PPM Parts per million


McMillen Jacobs Associates vii January 2020

PRCS Permit-Required Confined Space Program PTA Pretask assessment RE Resident Engineer RPE Respiratory protective equipment RTD/FU Return-to-duty and follow-up SAMHSA Substance Abuse and Mental Health Service Administration SAP Substance Abuse Professional SAR Supplied air respirator SASE Slope Access Safety Evaluation SCBA Self-contained breathing apparatus SCSR Self-contained self-rescuer SDS Safety Data Sheet SO2 Sulfur dioxide SOE Support of Excavation SSM Site Safety Manager STS Standard threshold shift TWA Time-weighted average UNECE United Nations Economic Commission for Europe UPRR Union Pacific Railroad


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McMillen Jacobs Associates ix January 2020

Table of Contents Message from the President ..................................................................................................................... iii

Acronyms and Abbreviations .................................................................................................................... v

1.0 Introduction........................................................................................................................................ 1

1.1 Underground Division Safety Policy Principles .................................................................................. 1

1.2 Underground Division Safety Policy Objectives................................................................................. 1

1.3 Underground Division Safety Policy Implementation ......................................................................... 2

1.4 Code of Safe Work Practices for Underground Division Employees ................................................. 3

1.5 Definitions .......................................................................................................................................... 4

2.0 Prevention .......................................................................................................................................... 7

2.1 Overview ............................................................................................................................................ 7

2.2 Employee Responsibilities ............................................................................................................... 10

2.2.1 Underground Division Safety Committee .......................................................................... 10

2.2.2 Underground Division Corporate Management ................................................................ 10

2.2.3 McMillen Jacobs Associates’ Environmental and Health Safety Director ......................... 11

2.2.4 Underground Division Construction Project Superintendent or Site Safety Manager (SSM) ................................................................................................................................ 11

2.2.5 Foreperson and Field Crew .............................................................................................. 13

2.2.6 Subcontractor .................................................................................................................... 13

2.2.7 Underground Division Resident Engineers/Construction Managers, Project Managers, and Superintendents ......................................................................................................... 15

2.2.8 Underground Division Supervisors and Office Managers ................................................. 16 2.2.9 All Underground Division Employees................................................................................ 17

2.3 Site Safety Inspection ...................................................................................................................... 19

2.4 Vehicle Operation ............................................................................................................................ 19

3.0 Response ......................................................................................................................................... 21

3.1 Overview .......................................................................................................................................... 21

3.2 Underground Division Employees ................................................................................................... 21

3.2.1 Underground Division Project Managers and Superintendents ........................................ 22

3.2.2 Underground Division Supervisors/Superintendents, Office Managers, and REs/CMs ... 22 3.2.3 All Underground Division Employees................................................................................ 22

4.0 Monitoring and Reporting .............................................................................................................. 24

4.1 Overview .......................................................................................................................................... 24


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4.2 Employee Responsibilities ............................................................................................................... 24 4.2.1 Environmental Health and Safety Director ........................................................................ 24

4.2.2 Underground Division Safety Committee .......................................................................... 25

4.2.3 Supervisors ....................................................................................................................... 25

List of Appendices Appendix A Minimum Requirements for Personal Protective Equipment

Appendix B Safety Hazard Escalation Procedures

Appendix C Permit-Required Confined Space Safety Plan

Appendix D Hazard Communication Plan

Appendix E Fall Protection and Rope Access Work Safety Plan

Appendix F Hearing Conservation Program Handbook

Appendix G Respiratory Protection Program Handbook

Appendix H Lock-Out/Tag-Out Safety Plan

Appendix I Roadway Worker Protection / On-Track Railroad Safety Plan

Appendix J Forms

Appendix K Examples

List of Additional Resources Health and Safety Training Guidelines

Record Keeping Requirements

Technical Safety Requirements


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Distribution To: Employees McMillen Jacobs Associates Underground Division Office Managers McMillen Jacobs Associates Underground Division From: Dan Adams McMillen Jacobs Associates Revised By: Bill Mitchell, Environmental Health and Safety Director McMillen Jacobs Associates Safety Committee: Ted DePooter, Sarah Wilson McMillen Jacobs Associates Underground Division Reviewed By: Carol Ravano, Julie McCullough McMillen Jacobs Associates Underground Division

Revision Record Revision Date Updated By

2020 January 2020 Bill Mitchell, Ted Depooter, Sarah Wilson 2017 August 2017 Bill Mitchell, Ted Depooter 2010 July 2010 Blake D. Rothfuss 2008 July 2008 Blake D. Rothfuss 2007 September 2007 Blake D. Rothfuss 2001 August 2001 Bob Rodgers 1999 February 1999 Bob Rodgers


McMillen Jacobs Associates xii January 2020



McMillen Jacobs Associates 1 January 2020

1.0 Introduction The McMillen Jacobs Associates Underground Division has made a commitment to maintain work environments that are as safe as possible. Safety is a primary focus in every aspect of our operation. Although many of our employees work where conditions can be hazardous, we do not accept accidents as a part of doing business. Our focus on working safely is shared by the underground industry, as evidenced by the emphasis placed on safety in most engineering codes of ethics. This Underground Division Safety Policy Manual addresses division-wide safety policies and procedures, including safety goals and objectives, prevention of and responses to safety issues, and monitoring and reporting. This manual is intended for Underground Division offices and construction sites where the contractor has primary responsibility for the safety of the site and the Underground Division is responsible for the safety of its workers. Specific safety issues where McMillen Jacobs Associates is a contractor or subcontractor are addressed in the Construction Safety Policy Manual, found on the company intranet.

1.1 Underground Division Safety Policy Principles We desire to have all of our employees conclude the work day as healthy as they were when they began their shift. The Safety Policy Manual is structured around the following principles. We can achieve a zero incident rate when they are followed:

Each employee holds himself/herself accountable to work safety and prevent workplace accidents.

We realize that safety is an equal partner with production, cost, and quality of work.

We are trained and empowered to avoid hazards and mitigate the hazards.

We train to work safely.

We practice working safely, both on the job and at home.

1.2 Underground Division Safety Policy Objectives Because we work in such diverse environments and face so many different hazards, this Safety Policy Manual establishes a comprehensive division-wide Safety Policy. The objectives of this policy are as follows:

1. To provide safe and healthy working conditions to the maximum extent possible.

2. To achieve zero incidents within the division.

3. To develop in personnel a recognition that:

° The prevention of injuries is significant and important to the accomplishment of all corporate goals, not just safety.

° Safety performance of each operation will be considered, along with other criteria, when management and superintendent performance evaluations are given.

° Employee accidents add directly to company costs, whether on-the-job (worker’s compensation) or off-the-job (group insurance plans, sick pay benefits, etc.). The same is true



of accidents involving employees’ dependents who are covered under the company insurance plan.

4. To carry out the company’s and the divisions obligations under federal, state, and local safety and health laws and regulations.

5. To achieve the lowest possible level of on- and off-the-job injuries.

1.3 Underground Division Safety Policy Implementation The Underground Division Safety Policy is designed as a three-pronged tool: Accident Prevention; Responding to Accidents; and Monitoring and Reporting.

The policy:

1. Assigns responsibilities and accountabilities for managing the Safety Policy.

2. Assigns individual accountability to division staff, project managers, superintendents, and all field employees.

3. Sets forth the division policy on safety and standard procedures that will be practiced by all its employees. These procedures will be directed toward the common goal of preventing personal injury as well as equipment/property damage.

Employees need to be aware that any conduct that adversely affects or is detrimental to the safety and interests of McMillen Jacobs Associates may result in disciplinary action, whether or not such conduct is specifically prohibited by the Underground Division Safety Policy (as contained in this manual).

Because of the varied nature of our business, our employees work:

In traditional office buildings that may or may not be managed by Underground Division staff.

In temporary field office trailers managed by the Underground Division, our clients, or other entities.

On active construction sites around diverse construction equipment and processes.

At owners’ facilities around operating equipment; chemical processes; live railroad and transit lines; water and wastewater treatment, storage, and conveyance facilities; confined spaces; and heavy equipment.

In the field at investigation sites where drill rigs and other equipment are working and moving, or in tunnels and pipelines.

On construction sites where we are managing others, or actively performing the construction.

As such, employees’ work practices are subject to a variety of safety requirements, laws, and jurisdictions. For example, Underground Division employees working on a construction site on a railroad right-of-way (1) must adhere to the Underground Division’s’ Roadway Worker Protection / On-Track Railroad Safety Plan (see Appendix I); (2) must adhere to the railroad’s safety requirements; and (3) must adhere to the contractor’s jobsite safety requirements. All employees are required to consult the particular jurisdiction and regulations that cover the location of their offices, and jobsites. The most stringent requirement will be followed when compared to this policy manual and a particular jurisdiction.



Because of the diversity of our work environments, it is not practical for one document to provide detailed instructions for working safely under all of these conditions. Accordingly, the McMillen Jacobs Associates Underground Division supplements its Safety Policy with additional specific safety plans describing safety practices for particular situations. These additional plans, at a minimum, shall be utilized to address the following issues:

Office Emergency Procedures

Pre–Field Work Safety Risk Assessments; Safety on a Construction Site

Site-Specific Safety Plans (plans are prepared for each site at the start of the project and revised as necessary)

Railroad Worker Protection/On-Track Railroad

Permit Required Confined Space Entry

Lock-Out/Tag-Out

Additional safety procedures will be developed as appropriate to help prevent workplace injuries and illnesses.1

This document sets out the Underground Division Safety Policy, and each employee working outside of a McMillen Jacobs Associates office MUST be aware of the task-specific job hazards and take the appropriate precautions to safely perform the assigned tasks.

This version of the Underground Division Safety Policy Manual supersedes all previous versions. The program will be reviewed annually by the company’s Environmental Health and Safety Director (Safety Director) and updated as required to address new safety issues and comply with applicable laws and regulations. Employees will be notified of revisions to the Safety Policy Manual.

The standards of the Safety Policy will govern over any lesser standard requirements of an agency’s or owner’s standard safety plan. However, employees are expected to follow the safety plan adopted by an agency or owner that is of a higher standard than the Underground Division Safety Policy.

1.4 Code of Safe Work Practices for Underground Division Employees All Underground Division employees will follow safe work practices, rendering every possible aid to accomplish safe operations, and report all unsafe conditions or practices to the appropriate persons. Employees should internalize these safety statements:

I always put safety first. I look for and act to resolve unsafe situations. I help and encourage others to act safely.

1 This Underground Division Safety Policy Manual is available on the company intranet site. Also available on the company intranet site are safety forms and documents contained in the appendices to this document and supplemental safety plans as they become available.



Anyone known to be under the influence of controlled substances or intoxicating substances that impair the employee’s ability to safely perform his or her assigned duties shall not be allowed on the job while in that condition.

Horseplay, scuffling, and other acts that tend to have an adverse influence on the safety or well-being of the employees shall be prohibited.

No employees shall knowingly be permitted or required to work while their ability or alertness is so impaired by fatigue, illness, or other causes that they might unnecessarily expose themselves or others to injury.

Employees shall be responsible for reviewing, understanding, and adhering to all safety-related documents and requirements (OSHA, other government agencies, and project specific) that apply to their work assignment. If it is not clear which safety requirements apply, employees shall ask their supervisor or site safety manager (SSM) for guidance.

No employees shall be permitted to enter access holes, underground vaults, chambers, tunnels, or other similar places that receive little or no ventilation, unless the tunnel safety representative has determined that it is safe to enter.

All injuries shall be reported immediately to the immediate supervisor so that arrangements can be made for medical or first-aid treatment. Where life or limb is jeopardized or upon serious injury, employees shall first attempt to contact medical emergency services by dialing 911.

Employees shall maintain all personal protective equipment (PPE) in such a way as to ensure equipment continues to provide the degree of protection for which it is designed. Any piece of equipment should be replaced when it is no longer serviceable (e.g., thin-soled work boots).

Employees shall openly communicate about safe work practices and injury prevention.

Employees shall maintain their offices and work areas in safe operating condition.

1.5 Definitions Confined Space is generally recognized as a space that has limited or restricted means of entry or exit; is large enough for a person to enter to perform tasks; is not designed or configured for continuous occupancy; and has the potential for a significant hazard to be present (see Appendix C: Permit-Required Confined Space Safety Operations Plan).

Construction Management (CM) is a professional service that provides project owner(s) with effective management of the project's schedule, cost, quality, safety, scope, and function.

Emergency Communication Plan is a written plan listing a specific site’s emergency contacts and phone numbers.

Environmental Health and Safety Director (Safety Director) is responsible for the preparation, implementation, enforcement, and continuous improvement of this Safety Policy within the Underground Division. This individual is the prime mover of all safety-related issues in the organization.



Hearing Conservation Program (HCP) provides specific requirements to conserve an employee’s hearing (Appendix F).

IDLH is an acronym for Immediately Dangerous to Life or Health, and is defined by the U.S. National Institute for Occupational Safety and Health (NIOSH) as exposure to airborne contaminants that is “likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment.” Examples include smoke or other poisonous gases at sufficiently high concentrations.

Internalize is to make (attitudes or behavior) part of one’s nature by learning or unconscious assimilation.

Job Hazard Assessment (JHA) is a task- or activity-specific analysis and identifies hazards that threaten an employee’s safety or health. The JHA has various formats but normally includes (at a minimum) tasks or activities, a list of potential hazards, a list of administrative or engineering controls, and the person responsible for mitigating the hazards. A JHA may also be referred to as a Job Safety Analysis (JSA) or Job Task Assessment (JTA).

OSHA-10-Hour Training Program for Construction Industry provides training for entry-level workers and employers on the recognition, avoidance, abatement, and prevention of safety and health hazards in workplaces in the construction industry. The program also provides information regarding workers’ rights, employer responsibilities, and how to file a complaint. Note that this program, when required by Occupational Safety and Health Administration (OSHA) standards, requires additional training on the specific hazards of the job.

OSHA-30-Hour training is used to train workers and supervisors on hazard recognition and OSHA safety standards. Training covers specific OSHA regulations and requirements as they apply to the general industry, and teaches safety awareness to help each worker recognize and reduce the risks of jobsite hazards. This training is intended as a comprehensive look at OSHA standards for employers and employees, and is generally for those in a more supervisory position.

Pretask Assessment (PTA): See Job Hazard Assessment.

Project Safety Risk Assessment Worksheet is filled out at the start of a project. It assesses the project’s safety hazards and means of mitigating the risk. (See Appendix J for a form; Appendix K for an example of a filled-out form.)

Responsible Person refers to the Underground Division employee responsible for supervising or directing company employees to perform specific work activities. The Responsible Person may or may not be an employee’s supervisor.

Supervisor refers to the Underground Division employee responsible for supervising and conducting performance reviews of a company employee. Every Underground Division employee has one identified supervisor.

Safety Moment is a brief discussion on a safety-related topic to remind employees about safe practices and issues related to safety.



Safety Risk Assessment is to be performed before a project moves into the field to assess the hazards and document the methods used to mitigate the risks.

Site Safety Committee is composed of members selected from project staff, and must have at least one employee representative. A Site Safety Committee is required on all projects in Canada with more than 20 workers.

Site Safety Manager (SSM) is a qualified and competent employee working on site and is responsible for implementation, enforcement, and continuous improvement of the site-specific safety plan.

Site-Specific Safety Plan describes a site’s procedures for any nonstandard work elements not addressed by the Underground Division Safety Policy, as well as procedures for responding to defined emergency incidents and should cover the following threats and emergencies: fire, explosion, earthquake, security, weather, and medical.

Tailgate (or Toolbox) Safety Meeting is a weekly safety meeting in which there is one main topic for discussion in addition to the normal daily discussion of the pending work activities.

Underground Division Corporate Management or Underground Division Management refers to the McMillen Jacobs Associates Underground Division regional managers and practice leaders.

Underground Division Corporate Safety Committee or Underground Division Safety Committee is composed of members selected by Underground Division Corporate Management, and will have at least one employee representative. Duration of appointment will be for at least one year.

Underground Division Safety Policy Manual describes the McMillen Jacobs Associates Underground Division Safety Policy.



2.0 Prevention 2.1 Overview It is crucial that every division employee take responsibility for helping to prevent unsafe conditions from developing in the workplace. To prevent safety problems, the Underground Division has established the following objectives for its employees:

Plan the work for safe completion, work the plan to completion

Maintain safe work environments

Share knowledge about safe work practices

Whenever Underground Division employees are planning to perform work in a new environment, assessing the workplace hazards must be part of the job work plan. A safety risk analysis identifies the possible hazards associated with specific work tasks expected on the project. The safety risk analysis also describes the necessary precautions needed to perform the work safely. An example of a job safety risk analysis is available in Appendix K (Field Risk Assessment Briefing Checklist).

In all cases, employees are responsible for exercising common sense and good judgment, and asking for any resources they need to complete their work in a safe manner.

The McMillen Jacobs Associates Underground Division provides resources and leadership to establish safe work environments for our employees. Responsible Persons identify and address safety requirements for work assignments, while employees are responsible for adhering to guidelines and adopting practices that maintain a safe environment.

To keep employees informed about safety issues, the Underground Division provides opportunities for sharing knowledge about safe practices. Underground Division Management communicates with employees about safety issues and incidents, provides training on safe work practices, and monitors employees’ work and work environments to ensure safety. All employees are empowered and encouraged to openly discuss their safety concerns with supervisors and Underground Division Management without fear of consequences.

To accomplish these objectives as a firm, the Underground Division will:

Comply with Safety Regulations and Laws. The Underground Division provides employees with guidelines for working safely and identifies laws that apply to our work. Each employee is informed of the safety guidelines and laws that apply to his or her work, and is responsible for complying with them. This information may come in the form of written documents such as this Safety Policy Manual, through training sessions, or by other methods.

Allocate Resources. McMillen Jacobs Associates commits to providing necessary resources, PPE, and maintaining safe work environments.

Provide Training. Several types of safety training are provided to promote safe work practices. In addition, underground construction has mandatory requirements—see 29 CFR Part 1926.800(d). Safety training includes the following:



1. Safety Orientation: Employees are given a safety orientation (either individually or at the next staff meeting) when they are hired or move to a new office location or jobsite. Visitors to McMillen Jacobs Associates offices should be given an abbreviated safety orientation, as appropriate. This should be part of the initial remarks at large meetings and should include evacuation locations, nearest hospital, and how to call 911 if necessary.

2. Safety Update Meetings: Safety meetings are held annually for office employees and more often, if needed, for employees who regularly work in the field. Topics and specific areas of training are decided by Underground Division Management based on work being performed and identified needs.

3. Underground Construction Instruction: As outlined in CFR 1926.800 (d), instruction in the recognition and avoidance of hazards associated with underground construction activities include, where appropriate, the following subjects: air monitoring; ventilation; illumination; communications; flood control; mechanical equipment; personal protective equipment; explosives; fire prevention and protection; and emergency procedures, including evacuation plans and check-in/check-out systems.

Note: Tunnel work in California requires compliance with the tunnel safety orders, and requires the employer to designate an on-site safety representative who is qualified to recognize hazardous conditions and is certified by the California Division of Occupational Safety and Health (Cal/OSHA). This person shall have the authority to correct unsafe conditions and practices, or stop the work if an imminent hazard exists. This person shall be responsible for directing the required safety and health program. Based on the project classification (potentially gassy, gassy, extrahazardous) by the Cal/OSHA mining and tunneling unit, Cal/OSHA requires a certified Gas Tester to be utilized for testing for gas either periodically or continuously anytime workers are underground.

4. Job-specific Safety Training: On a job, specific training is provided as needed to equip employees to deal with particular conditions or hazards— fall and rope access work protection (see Appendix E); hearing conservation (see Appendix F); respirable dust (see Appendix G); lock-out/tag-out (see Appendix H).

5. Tool Box Safety Meetings: Field employees must participate regularly in Tool Box Safety Meetings. These meetings are typically held once a week and shall be held by McMillen Jacobs Associates employees when the company is the contractor so that our employees remain engaged with the site-specific safety plan and are apprised of current and potential hazards. Where work is controlled by a contractor other than McMillen Jacobs Associates, and McMillen Jacobs Associates staff members are present, attendance at the contractor’s tool box safety meetings (or equivalent) is mandatory for all McMillen Jacobs Associates field staff.

6. OSHA 10-hour Training: At least nine states now require formal OSHA 10-hour training. These are: Connecticut (Sec. 31-53b), Missouri (Sec 292.675), Massachusetts (Chapter 30: Section 39S), New Hampshire, New York State (A02721), Nevada (Bill No. 148), Pennsylvania (P.A. 06-175, S.1), Rhode Island (04-593), and West Virginia. The Underground Division recommends that all its employees who will be in the field at one time or another receive OSHA-10-hour training. All Underground Division forepersons will have a valid OSHA-10-hour training.



7. OSHA 30-hour Training: The Underground Division requires OSHA 30-hour training for all supervisory and field superintendent positions where the supervisor is overseeing field work. Every attempt will be made to complete OSHA 30 certification before the field assignment starts.

8. Hazard Identification Training: Such training is recommended for all who have or will have a field position.

9. Client-required Certificated Training: Some clients require specific training for their contractors/consultants prior to beginning work at their facilities (e.g., railroad projects, hazardous waste sites, in-service pipelines and tunnels).

10. Hazard Communication Plan: A Hazard Communication Plan has been established to ensure all employees are trained and are knowledgeable on where to find the information about the dangers of all hazardous chemicals used by the Underground Division. See Appendix D for the Hazard Communications Plan.

See Additional Resources: Health and Safety Training Guidelines.

Communicate openly about safety issues. Underground Division Management communicates promptly and openly about safety issues, incidents, and lessons learned to employees. Some forms of communication are:

° Safety Bulletins: Safety bulletins raise awareness about general health and safety amongst staff.

° Accident Bulletins: Accident bulletins are issued when an employee is injured at work or on a jobsite.

° Incident Bulletins: Incident bulletins (sometimes referred to as near misses) are issued after safety Incidents that do not result in injury.

° Safety Assessments: The Safety Director may prepare quarterly and annual safety assessments that document workplace safety performance. These reports are kept on file and are available to employees upon request.

Safety bulletins, incident bulletins, and safety assessments can be prepared by anyone, but will be reviewed and distributed through the Safety Director. It is expected that these bulletins will be issued within a week of an incident, typically by e-mail.

Establish and maintain an Underground Division Safety Committee. Underground Division Management empowers an Underground Division Safety Committee, which is appointed by Underground Division Management Board for a term of at least one year. Guidelines for this committee are:

° Determine meeting time, place, and posting location so that employees as well as members will be informed of upcoming meetings.

° Maintain, distribute, and post written minutes of the Underground Division Safety Committee meetings.



° Maintain and post a current list of Underground Division Safety Committee members by name and department. This list shall indicate dates of the committee members’ terms of tenure.

Project-specific safety committees may be established for larger projects, and will be established in Canada if a project has over 20 workers.

2.2 Employee Responsibilities Employees in different roles have responsibilities unique to their role for helping to prevent safety problems. The actions employees should take to prevent safety problems are listed below by job title/role.

2.2.1 Underground Division Safety Committee

The Underground Division Safety Committee is expected to:

1. Review and implement the Underground Division Safety Policy.

2. In cooperation with supervisors, branch managers, and REs/CMs, develop work practices and procedures that comply with said Safety Policy, applicable laws and regulations, and jobsite plans.

3. Review new health and safety standards and regulations for applicability to Underground Division work environments.

4. Identify any deficiencies and establish procedures to eliminate those deficiencies, including on-site inspection programs.

5. Inform employees of any changes to work practices and procedures that are required to maintain compliance.

6. Review and make recommendations to management regarding safety suggestions and/or recommendations from individual employees.

2.2.2 Underground Division Corporate Management

To help prevent safety problems, Underground Division Corporate Management must:

1. Provide a safe work environment. McMillen Jacobs Associates’ Underground Division is committed to providing adequate and appropriate safety training and education to its employees. The division provides a Safety Orientation Program and ongoing education to keep employees well informed of the safest and most efficient work practices for each respective work area. The safety training programs mainly emphasize accident/injury prevention in various phases of operation.

2. Provide appropriate safety training. Safety training and education programs are summarized in Additional Resources: Health and Safety Training Guidelines.

3. Provide vision, allocate resources, and lead by example in health and safety matters.

4. Review safety performance reports generated by the Safety Director.

5. Listen to and address safety concerns raised by employees.



2.2.3 McMillen Jacobs Associates’ Environmental and Health Safety Director

McMillen Jacobs Associates’ Safety Director is responsible for the environmental and health safety of the Underground Division. Duties can include:

1. Review accidents and make recommendations for immediate prevention measures and control of hazards.

2. Analyze accident reports to determine:

a. Trends in frequency or severity of accidents that indicate a need for added safety education;

b. Problem areas or operations that need increased attention; and

c. Accident repeat offenders who may need additional training and supervision.

3. Evaluate accident investigations to determine if reported unsafe conditions and acts have been adequately identified and corrected.

4. Meet as needed to discuss the reports described above. Information that is to be relayed to employees will be addressed in the weekly project safety meeting and will be posted on the safety bulletin board. Evaluate and maintain compliance documentation.

5. Identify training needs and manage training programs.

6. Coordinate the preparation of safety bulletins.

7. Issue accident/incident bulletins companywide based on accident/incident reports.

8. Cooperate with OSHA on all inspections or investigations of McMillen Jacobs Associates workplaces.

9. Generate safety performance reports.

10. Retain Underground Division corporate safety records. See Additional Resources: Record Keeping Requirements.

2.2.4 Underground Division Construction Project Superintendent or Site Safety Manager (SSM)

Although Underground Division Management always has a safety responsibility, at the project level, the primary responsibility for safety and the results of that program reside with the project superintendent or site safety manager (SSM) This person’s responsibility is to ensure all policies contained within the Underground Division Safety Policy are carried out operationally. These policies will be implemented through direct managerial support. Superintendents or SSMs will be accountable for the following:

1. Ensure all employees follow the policies of the Safety Policy. Employees violating ANY safety policy or procedure are subject to discipline.

2. Provide guidance and resources to forepersons and work crews for the implementation and maintenance of a proactive Safety Policy.

3. Ensure that the superintendent/SSM fulfills his/her responsibilities for accident prevention outlined in superintendent and foreperson responsibilities contained in this document.



4. Ensure the contractor’s site safety plan will be drafted and reviewed prior to project startup to be sure site safety hazards have been addressed. Meetings with the project manager, practice leader and site safety manager will take place to discuss plans implemented to mitigate safety concerns.

5. Ensure that all hazard analysis training will be documented as to content and those in attendance. Copies will be kept on site and at the corporate office.

6. Ensure forepersons and field crews are provided with the necessary resources, training, and other loss control tools to effectively and proactively administer the Underground Division Safety Policy. This will be accomplished by utilizing corporate and Underground Division safety resources, outside consultants, and seminars, as well as other proactive safety training.

7. Actively demonstrate their commitment to the safety and health of all employees and express support for the Safety Policy. This will be accomplished by demonstrating follow-through and feedback to the employees on all safety issues brought to their attention.

8. Have the authority and responsibility to stop unsafe work/practices.

9. Be responsible for employee safety and quarterly inspections.

10. Ensure that, prior to the start of each project, the SSM, project manager, and forepersons review the contractor’s site safety plan, ,which covers known and potential hazards associated with the project scope of work and the plans that will be utilized to mitigate those hazards.

11. Implement hazard mitigation plans, and site-specific and division safety rules that will be enforced and monitored for all Underground Division and subcontractor personnel throughout the project to ensure a safe work environment and safe work practices that comply with the Underground Division Safety Policy, applicable laws, and regulations. A partial list of technical safety requirements for sites is listed in Additional Resources: Technical Safety Requirements.

12. Provide and document jobsite training based on the site-specific hazards addressed in the pre-project hazard analysis and safety responsibility spreadsheet.

13. Conduct and document jobsite safety and operations training to new employees and to workers given new assignments utilizing the Employee Safety Orientation Checklist.

14. Maintain all required safety-related documentation at the jobsite until the project is complete and then forward documents to the corporate office for archiving.

15. Document safety meetings, actions, and incidents in daily report.

16. Conduct and document a weekly jobsite safety inspection using a jobsite safety checklist form, contained herein (Appendix J: Forms). Document any deficiencies found and correct as soon as possible (ASAP).

17. Order, inspect, maintain, and store tools and equipment for each project.

18. Provide and ensure use of proper personal protective equipment for all personnel on-site as required.

19. Conduct and document a weekly safety meeting. Discussion should include the following: review of all company near misses and incidents for the previous week, changes in work or new scope of work, known or potential hazards, hazard mitigation, and introduction of new employees and subcontractors on site.



20. When a near miss, accident, injury, or blood-borne pathogen exposure occurs, notify the SSM immediately. Inform the Safety Director of all accidents as soon as possible. Investigate all accidents, start accident investigation reports (see Appendix J: Forms), and ensure proper corrective actions have been taken immediately. Forward all accident investigation reports to the Safety Director within 24 hours.

21. Contact the SSM immediately if medical treatment is required beyond first aid.

22. Forward written reports to the Safety Director.

23. Discuss the incident, investigation, at weekly jobsite safety meeting or stand-down meeting.

24. Address disciplinary action.

25. Assign/monitor, in conjunction with the Safety Director, all temporary modified tasks for injured employees who are working while recovering from an injury. Tasks must match limits as defined by attending physician. Keep the Safety Director informed regarding employee’s progress, attendance, and other relevant matters.

26. Maintain required training and current First Aid/AED/CPR certification as required by regulation.

2.2.5 Foreperson and Field Crew

The foreperson and field crew are responsible for the following:

1. Ensure employees follow the division safety policies and procedures. Employees violating any safety policy or procedure will be disciplined and/or discharged depending on circumstances.

2. Inform the superintendent/SSM of all accidents as soon as possible. Investigate all accidents. For each accident, start an accident investigation report and ensure proper corrective actions have been taken, all within the shift the accident occurred. Forward all accident investigation reports to the superintendent/SSM within 24 hours.

3. Observe employee work procedures and correct unsafe practices when found.

4. Instruct employees in proper job safety procedures.

5. Ensure identified unsafe conditions are corrected by completion of a weekly inspection checklist. All known unsafe conditions will be corrected immediately. Actions taken will be documented and included in the project files.

6. Conduct and document toolbox safety meetings at least every week with all field employees, unless the contractor is conducting these meetings and providing documentation of everyone’s attendance. Topics covered in the meeting and a list of its attendants will be included in the project documents and stored at the jobsite office.

7. Stimulate and motivate employees to work in a safe manner through skillful leadership, documented training and retraining on safe work practices. Lead by example.

2.2.6 Subcontractor

Our subcontracts should be written so that the assignment of responsibility for safety flows down to the subcontractors.



1. The subcontractor is required to adhere to and comply with Underground Division policies and procedures, and national, state, and local regulations.

2. The subcontractor is required to instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his/her work environment, as well as control or eliminate any hazards or other exposure to illness or injury.

3. The following violations are grounds for IMMEDIATE REMOVAL of subcontractor’s personnel from a jobsite:

Disregard of safety and health rules and regulations, repeated violations, or refusal to follow safety and health regulations.

Fighting (physical contact), horseplay (rough, boisterous play), or gambling.

Theft.

Drugs or alcohol (possession or under the influence).

Willful destruction of property.

Possession of unauthorized firearms or explosives.

Any act or omission that could inflict or result in bodily harm or death.

4. The subcontractor will conduct/attend a weekly safety meeting with its personnel discussing their particular risks and hazards. A copy of the written minutes and attendance of each meeting will be given to the Underground Division’s representative (refer to Section 2.3 below).

5. When necessary, the subcontractor will complete a JHA form and return it to the project superintendent prior to commencing that portion of the work.

6. When required by Underground Division policies and/or CFR 29 1926, the subcontractor will submit a copy of any certification, support of excavation (SOE) design by registered professional engineer, proof of certification, or proof of competent person to the Underground Division representative.

2.2.6.1 Subcontractor’s Preconstruction Meeting

A preconstruction safety meeting will be held before a subcontractor and its lower tier subcontractors begin work. This meeting will be held with McMillen Jacobs Underground Division project representatives and the contractor’s key site representatives, such as the job superintendent and job foreperson. Discussion will center on the project safety manual and requirements. At that time, the subcontractor will present:

1. A copy of the subcontractor’s written company safety program.

2. A copy of the subcontractor’s written company hazardous communication program.

3. Name of the subcontractor’s on-site safety coordinator.

4. Name of the competent person when required by federal and state regulations for, for example, excavations and scaffolding.

5. A copy of the crane annual inspection (if applicable).



6. Proof of qualification for operators of, for example, dozers and cranes, and as required by federal, state, and local laws.

7. Any additional items as required by contract documents.

8. Job hazard analysis as required for each element of work.

9. A copy of certified drawing of, for example, scaffolding and excavation shoring (if applicable).

10. Equipment and safety certifications.

The McMillen Jacobs Associates Underground Division policy is to never “approve” a subcontractor’s plan; we refer to it as a “review” of content.

2.2.6.2 Subcontractor Safety Violation Notification

If an Underground Division manager, superintendent, project manager, or foreperson notifies the subcontractor or its lower tier subcontractor of any noncompliance with the Underground Division Safety Policy and/or OSHA safety regulations, the subcontractor will immediately correct the deficient conditions. If the subcontractor fails to comply promptly with the directive, the division representative may stop all or any part of the work of the subcontractor. In this event, when satisfactory corrective action is taken by the subcontractor, a start order is issued by the Underground Division representative. No part of the time lost because of any safety violation is subject to claim of extension of time or for excess costs or damage by the subcontractor or its lower tier subcontractor. Note: Always enforce compliance through the contract provisions. Don’t say: “It’s unsafe,” or “It’s an OSHA violation.” Say, “It is not in accordance with the contract.”

Subcontractors are required to discipline and/or remove from the work site employees who violate established rules and regulations.

2.2.7 Underground Division Resident Engineers/Construction Managers, Project Managers, and Superintendents

To help prevent safety problems, resident engineers/construction managers, and project managers are expected to:

1. Inform visitors and guests of basic office/site safety procedures (e.g., emergency exit procedures, known hazards).

2. Have all site visitors sign a Visitor Acknowledgment form and an Assumption of Risk and Release of Liability form with hold harmless language. (Samples of these forms are part of Appendix K and are available on the company’s intranet site. These forms should be tailored for site-specific site conditions and reviewed by legal.)

3. Verify that site employees and visitors under their control have the required personal protective equipment and have received training on how to use it properly.

4. Provide brief safety training for visitors where project, cardinal safety rules, and code of safe practices are reviewed and explained.



5. Act in cooperation with supervisors, SSMs, the Safety Director, and the Underground Division Safety Committee to implement work practices and procedures that comply with the Underground Division Safety Policy, applicable laws and regulations, and jobsite plans.

6. Provide a copy of the requisite site-specific safety plan to all employees and review the site safety precautions and emergency response procedures with employees.

7. Maintain, or have access to, all assigned employees’ emergency contact information sheets.

8. Act in cooperation with supervisors and SSMs to apply information from accident/incident bulletins to minimize or eliminate hazards.

9. Coordinate with the SSM or designated employee to prepare Job Hazard Assessments (JHAs) for all new work and any “unusual” or “nonroutine” work that may be required, even when it crops up during normal operations.

10. Confirm that each Underground Division subcontractor has a safety and health program in effect before contracts are executed.

11. Confirm that each Underground Division subcontractor adheres to the Underground Division safety requirements if the subcontractor’s safety plan is less stringent than the Underground Division Safety Policy.

12. Confirm and document that staff personnel of each Underground Division subcontractor have been trained annually in accordance with the subcontractor’s safety and health program. Note that subcontractor shall conduct or attend the weekly safety tailgate meetings at project sites.

13. Conduct or attend weekly tailgate (or toolbox) safety meetings.

14. Conduct “Safety Moment” at the beginning of every formal meeting.

15. Should the work assignment change or require modification during the shift, the weather or other conditions change, or personnel change, stop working immediately and prepare a new JHA or revise the existing one to reflect the changed conditions. Only then continue with the modified work plan per the JHA.

16. Monthly meetings with supervisory personnel and forepersons shall be held for a discussion of safety problems and accidents that have occurred. A record of such meetings shall be kept, stating the meeting date, time, place, supervisory personnel present, subjects discussed, and corrective actions taken, if any, and maintained for record keeping purposes.

17. Schedule, conduct, or attend “All Hands” or “Stand Down” safety meetings as appropriate to review safety inspections, findings, and corrective actions taken; discuss critical safety procedures and recent workplace incidents; and celebrate safety milestones.

18. Conduct periodic office safety reviews and resolve significant findings immediately (see Appendix J: Forms).

19. For CM projects, resident engineers/construction managers (REs/CMs) will have a yearly general safety meeting. Call-in meetings may be done more often.

2.2.8 Underground Division Supervisors and Office Managers

To help prevent safety problems, supervisors and office managers, or their designees, are expected to:



1. Implement work practices and procedures that comply with this Safety Policy, applicable laws and regulations, and jobsite plans. This includes development of the site or office evacuation plan, ensuring walkways are clear and fire extinguishers current, posting required posters and OSHA 300A forms, scheduling first aid training, and reviewing the Hazard Communication Plan (Appendix D) on an annual basis (e.g., at a brown bag or lunch and learn meeting).

2. Conduct an initial safety orientation for new and transfer employees, temporary employees, and visitors. The safety orientation may be delegated and should include a review of this Policy, applicable safety plans, and office emergency procedures. Have new employees complete the emergency notification form and forward copies to the Underground Division HR Manager and local office manager.

3. Ensure that all new Underground Division employees have access to a copy of the Underground Division Safety Policy Manual on their first day of employment.

4. Provide a project or office tour to identify areas of danger; hazardous materials; and location of exits, fire extinguishers, and first-aid facilities.

5. Provide instructions on specific actions to take in the event of an emergency. This will include where to go and what to do, along with instructions for documenting an accident when the employee is in a position to do so.

6. Instruct new employees to notify their immediate supervisor/superintendent when an accident has occurred and to contact emergency services by calling 911 and/or the appropriate posted number(s). Employees will be briefed on each jobsite as to the appropriate emergency number.

7. Provide instruction for new employees as to how, where, and when to report any unsafe conditions or practices.

8. Inform visitors and guests of basic office/site safety procedures (e.g., emergency exit procedures, known hazards).

9. Prepare a Job Hazard Assessment (JHA) and review it with the employee(s) before starting any new “unusual” or hazardous tasks.

10. Provide appropriate safety training and any PPE equipment to their employees before they begin an assignment.

2.2.9 All Underground Division Employees

To help prevent safety problems, in addition to any responsibility above, all Underground Division employees are expected to:

1. Intervene immediately in any work or task they feel is an immediate danger to a coworker’s life or health (IDLH).

2. Bring up to their supervisor any activity they see that they think has the potential to endanger life or property.

3. Comply with applicable safety regulations and laws having jurisdiction where the employee is working.

4. Follow the Underground Division Safety Policy, as established by this Safety Policy Manual, and referenced additional safety plans.



5. Be aware of the Underground Division Emergency Communication Plan (Appendix K).

6. Abide by the Underground Division’s Code of Safe Work Practices (see Section 1.4).

7. Prepare or participate in a Job Hazard Assessment and have it reviewed by their supervisor before starting any field work.

8. Be familiar with the field procedures and operations before beginning an assignment requiring field presence.

9. Have and correctly use all personal protective equipment (PPE) that is required for safe performance of their jobs (see Appendix A). In addition, employees may not use any PPE that has not been authorized by the company for the employee’s use (e.g., partial or full-faced respirators).

10. Participate in applicable safety training, maintain all safety licenses and certifications required for their work, and notify their supervisor before recertification training is required.

11. Notify their supervisors when additional task-specific safety training is needed BEFORE the field assignment begins (see Additional Resources: Health and Safety Training Guidelines).

12. Maintain order in their workspace; practice “good housekeeping.” Ensure that materials and equipment required to do their jobs are maintained in good working order.

13. Maintain open communication with their supervisors about work safety.

14. Feel empowered to initiate safety bulletins and submit to the Safety Director for review and distribution.

15. Attend and participate in the daily safety tailgate (or toolbox) meetings at project sites and document that attendance.

16. Should the work assignment change during the shift, or should weather or other conditions change, document any changes in a revised JHA.

Long-term Assignments: Depending on the role, employees may be requested to do the following (including participating in, taking the lead in developing, or reviewing):

1. Complete the Field Risk Assessment Briefing Checklist (see Appendix J: Forms) and review the worksheet with their supervisor and/or the SSM.

2. Prepare a Site-Specific Safety Plan that addresses the specific hazards that may be encountered at the project.

3. Prepare and provide a brief safety orientation to all visitors and have them sign a standard release form (visitor’s acknowledgment [see Appendix K for a sample form]) for the Underground Division in addition to owner’s or contractor’s release forms.

4. Immediately notify the SSM of any requests for Occupational Safety and Health Administration (OSHA) inspections or investigations. Follow the procedures for coordinating unscheduled OSHA visits. During these visits, be professional and courteous, communicate with the Certified Safety and Health Official (CSHO) through a management representative only, inspect the CSHO’s credentials, and find a place for the CSHO and management representative to talk.

5. Attend weekly or monthly safety meetings at project sites and document attendance.



2.3 Site Safety Inspection An Underground Division representative (superintendent, SSM, supervisor, or designated person) will conduct general and detailed weekly inspections of the jobsite. Each subcontractor will also conduct frequent and regular inspection of its work area to assure that safety requirements and practices are being enforced. These inspections include, as a minimum, the following:

1. Site conditions

2. Tools

3. Materials

4. Equipment

5. Work practices

6. Task performance

7. Any areas that may compromise the safety of individuals or property

Discussion of all safety deficiencies and corrective action(s) will be noted at the weekly site safety meeting.

2.4 Vehicle Operation We each have a responsibility to not only protect ourselves when on the road but also to protect those around us. Underground Division employees who are required to drive a company car, rental car, or a privately owned vehicle while on company business will be expected to consistently apply and follow all the procedures below. The policy for project-assigned company vehicles is further detailed in the Construction Safety Policy Manual available on the company intranet.

Obey traffic laws such as adherence to posted speed limits or other signage, use of turn signals, etc.

All employees are expected to avoid confrontational or offensive behavior while driving.

All employees are expected to wear seat belts at all time while in a moving vehicle being used for company business, whether they are the driver or a passenger.

Employees must have a valid operator’s license for the type of vehicle they are operating.

Use of handheld cell phones, smart phones, or hands-free technology, whether personal or business-owned, to make calls while behind the steering wheel of an operating vehicle being used on company business is strictly prohibited. If a call must be made, find the nearest safe place to pull over and make the call.

Texting is strictly prohibited while driving.

The use of hands-free technology is strongly discouraged, but if there is an unusual incoming call, please politely hang up, finish driving, and call the person back. In unusual or emergency circumstances, ask the caller to wait while you find the nearest safe place to pull over and complete the call. If you are unable to pull over safely, you must tell the caller that you will call back when it is safe to do so and hang up.



Engaging in other distracting activities including, but not limited to, eating, putting on makeup, reading or changing radio stations or music, is also strongly discouraged while driving, even when in slow-moving traffic.

Use of alcohol, drugs, or other substances, including certain over-the-counter cold or allergy medications that in any way impair driving ability, is prohibited.

Transportation of alcohol and drugs in vehicles being used on company business is prohibited.

Do not operate a vehicle if you are drowsy or fatigued. Do not drive significantly beyond your normal working hours.

Employees should never allow anyone to ride in any part of the vehicle not specifically intended for passenger use and/or in any seat that does not include a working seat belt.

Employees who drive commercial vehicles or who are otherwise subject to separate rules and regulations such as those dictated by state or federal law are also expected to adhere to all policies and regulations associated with the appropriate law or regulation that applies.

A fire extinguisher is to be mounted in each company vehicle.

A first-aid kit is to be installed in every company vehicle.

An accident reporting kit is to be installed in each vehicle.

Failure to adhere to these prevention procedures may result in disciplinary action per company policy.



3.0 Response 3.1 Overview When safety problems occur, employees need to be prepared to take action. The Underground Division’s procedures in this document inform employees on which actions to take in the event of a safety problem or incident, and employees are expected to generally follow these procedures. Some elements of our response plan are:

Emergency response: Each Underground Division office and jobsite has an established site-specific emergency plan that should be followed. The site-specific emergency plan describes the procedures employees should follow in the event of an emergency.

Accident/incident investigations: Incidents and accidents are investigated by an Underground Division team that typically includes the immediate supervisor, SSM, resident engineer or office manager, and practice leader in charge or project manager. Outside experts may be brought in if needed. The team does the following:

° Informs the HR and legal departments and the Safety Director as soon as the location where the accident occurred is safe;

° Reviews available incident/accident documentation;

° Interviews witnesses and individuals involved in the accident/incident;

° Visits the location if necessary;

° Thoroughly documents how the accident/incident occurred;

° Prepares an accident/incident report identifying the causes of the accident/incident and stating recommendations for avoiding similar accidents/incidents;

° Cooperates with national safety and health organizations and law enforcement investigators as necessary.

3.2 Underground Division Employees Employees in different roles have different responsibilities for helping to respond to safety problems. The actions employees should take to respond to safety problems are listed below by job title/role.

In response to safety problems, in coordination with the HR and legal departments, the Safety Director (or designee) is expected to:

1. Lead or participate in accident/incident investigation teams as appropriate.

2. Issue company-wide accident/incident bulletins based on accident/incident reports.

3. Assist any employee with the prompt resolution of safety issues.

4. Cooperate with regulatory agencies (e.g., OSHA) on all inspections or investigations of McMillen Jacobs Associates workplaces.

5. Follow up on incidents to see if corrective action was implemented and documented.

6. Investigate for cause, but not to assign blame or fault.



3.2.1 Underground Division Project Managers and Superintendents

In response to safety problems, project managers and superintendents are expected to:

1. Participate in accident/incident investigation teams as appropriate, evaluate project conditions for potential reoccurrence, and adjust work assignments.

3.2.2 Underground Division Supervisors/Superintendents, Office Managers, and REs/CMs

In response to safety problems, supervisors/superintendents, office managers, and REs/CMs are expected to:

1. Post current emergency communication plans where employees routinely gather (see Appendix K).

2. Immediately report all Underground Division employee injuries to the Safety Director and the Underground Division HR Manager. See Appendix J (Accident Investigation Report form). A near miss report must be filled out (on the Accident Investigation Report form or in a format that provides the same information) if medical advice (such as from an EMT) has been provided in the event there is no injury. Near miss reports should be filled out for all incidents even if there is no injury or damage.

3. Commence accident/incident investigations within three working days.

4. Participate in accident/incident investigation teams as appropriate.

3.2.3 All Underground Division Employees

1. Employees should immediately report to their supervisor as well as any affected employees in the area of any unsafe conditions (see Appendix D and Appendix E), practices, or hazards if they cannot be corrected by the observer. Additionally, these conditions, practices, or hazards should be reported to the jobsite supervisor, office or regional manager, an Underground Division practice leader in charge, or the Safety Director if they are not corrected immediately or are reoccurring conditions.

2. Evaluate an emergency situation (Appendix B) and confirm the scene is secure before responding to an injured employee, activate the site-specific emergency response plan, then provide first aid to the limits of their individual training and comfort.

3. Immediately report all injuries to their supervisor or regional manager. Workers’ compensation issues will be addressed by HR in conjunction with the Safety Director.

4. Initiate applicable emergency communication plans (Appendix K). Handle the personal information of fellow employees in accordance with applicable confidentiality agreements and requirements.

5. Cooperate with regulatory agencies (e.g., Jurisdiction Authority, OSHA, Cal/OSHA, WorkCover Authority of New South Wales [WorkCover NSW]), law enforcement, and internal McMillen Jacobs Associates investigators as requested.

6. Every Underground Division employee has the right and responsibility to stop work when there is immediate danger to life or health.



7. If you are involved in a vehicular accident notify your supervisor immediately. Follow vehicle accident reporting procedures.



4.0 Monitoring and Reporting 4.1 Overview The McMillen Jacobs Associates Underground Division monitors employee safety performance to identify training needs and ensure that employees are working in a manner that is safe for themselves and others. Records of performance are maintained for legal, insurance, and contractual purposes.

Our monitoring and reporting program includes several elements of the Underground Division Safety Policy. These records are collected by the supervisors and kept by the Safety Director.

Employee feedback: Employees are required to immediately report all unsafe conditions, work practices, and hazards that are not corrected immediately to their supervisors. Recurring conditions or practices should be reported to their supervisor. Employees may also call or e-mail the Safety Director.

Individual performance reviews: Employees’ annual performance reviews include a review of their safety performance. Individual safety training and certification needs are identified and tracked via the standard performance review process.

Office safety reviews: These reviews are conducted to identify and correct unsafe work conditions in office environments. Records include the name of the person conducting the review, location, date of review, any hazards or deficiencies identified, and actions taken to correct such issues. Such reviews should be done continually, but a formal evaluation should be performed once a year.

Jobsite safety reviews: These reviews are conducted to identify and correct hazards, unsafe conditions, or improper work methods on a jobsite. They are conducted by the REs/CMs to confirm that our employees are not exposed to hazardous jobsite conditions. If the RE/CM is not a McMillen Jacobs Associates employee, the supervisor(s) of the on-site McMillen Jacobs Associates employees are responsible for conducting the review. This should be done continually, but a formal evaluation should be performed quarterly.

Accident/incident bulletins: These bulletins are prepared during accident/incident investigations with input from applicable Underground Division personnel, as described in Section 3.1, and then reviewed and issued by the Safety Director, as described in Section 2.0.

Safety training: Records include attendee names and signatures, certificates, instructor(s), date, location, an outline of content, and any available handouts.

4.2 Employee Responsibilities The Environmental Health and Safety Director is responsible for overseeing the safety performance monitoring programs, but superintendents, forepersons, supervisors, and branch/office managers play key roles in monitoring performance.

4.2.1 Environmental Health and Safety Director

1. Maintains compliance documentation.

2. Retains corporate Safety Records. See Additional Resources: Record Keeping Requirements.



3. Evaluates and coordinates office and jobsite safety reviews conducted by supervisors, branch managers, and REs/CMs.

4. Prepares a company safety performance report annually (or more frequently if needed).

4.2.2 Underground Division Safety Committee

1. Maintains and updates this Safety Policy Manual, as needed.

4.2.3 Underground Division Supervisors

Underground Division Supervisors have an ongoing and direct responsibility for safety and must:

1. Monitor the safety behaviors of their reports to ensure compliance with the Underground Division Safety Policy and other applicable rules and regulations.

2. Identify training and development needs of their reports, develop plans for addressing these needs, allocate appropriate resources, and continue to monitor behaviors and provide feedback. At a minimum, safety discussions should occur annually during performance reviews.

3. Address or escalate issues of employee noncompliance with applicable safety guidelines and laws.

4. Review forms and JHAs.

To monitor safety performance, project managers, resident engineers, construction managers, and branch/office managers have an ongoing and direct responsibility for safety and are expected to:

1. Continually monitor or evaluate their site for safety issues.

2. Determine the root cause for an incident FIRST. It could be a procedure that does not fit the work or conditions.

3. Resolve significant findings immediately with the contractor’s safety officer/representative.

4. Encourage employees with any current health issues, allergies, or mobility limitations to communicate those conditions so that IF a health emergency does arise, first aid can be more effectively applied.

5. Retain health and safety program files, including meeting minutes, training records, job safety analyses, jobsite audits, accident/incident reports, etc., for at least three years. Maintain all files in compliance with Health Insurance Portability and Accountability Act (HIPPA) regulations.

6. Provide any safety records required for retention to the Safety Director. See Additional Resources: Record Keeping Requirements.

7. Continue monitoring the project’s safety performance.

Employees are required to inform their supervisor, and stop operating any vehicle while on company business if they do not have a valid driver’s or operator’s license for that type of vehicle they are operating.


McMillen Jacobs Associates January 2020

Appendix A Minimum Requirements for Personal Protective Equipment

Underground Division

Minimum Requirements for Personal Protective Equipment


Introduction The McMillen Jacobs Associates Underground Division will provide the listed required Personal Protective Equipment (PPE) at no cost to the employee and maintain it in a sanitary and reliable condition or provide maintenance and care training for individual employees to maintain their assigned PPE in a sanitary and reliable condition. Selected Personal Protective Equipment will be properly fitted for each affected employee. PPE shall be inspected prior to each use to ensure its condition, its proper fit to the user, and that it to meets protection purposes as set forth in OSHA 1910.132 and other required regulations. Employee-owned PPE is not allowed to be worn on the jobsite. Specific PPE requirements for each employee reflect hazards that are present, or are likely to be present, and are addressed in Site Specific Safety Plans, jobsite safety orientations, and our signed daily pre-task assessment (PTA) or Job Hazard Analysis (JHA).

PPE training will include selection, and proper donning and doffing of selected PPE. Training will be provided and documented. Retraining of employees is required when the scope of work changes; the type of PPE changes; or an employee demonstrates a lack of use, improper use, or insufficient skill or understanding.

Subcontractor employees and visitors to an Underground Division jobsite are required to be in accordance with the McMillen Jacobs Associates Underground Division Safety Policy and are therefore subject to the same requirements for PPE, at the cost of the subcontractor.

Any damaged or defective PPE shall immediately be taken out of service and tagged “OUT OF SERVICE.” Repairs can only be made per manufacturer’s specification; otherwise damaged or defective PPE will be destroyed immediately and shall be replaced with undamaged PPE.

At a minimum employees and visitors in the field shall wear short sleeve shirts with minimum 3-inch-long sleeves, long pants, and protective footwear. Tank tops, muscle shirts, and shorts are not acceptable for work at any construction site. The following is a list of the minimum PPE issued by McMillen Jacobs Associates. Basic PPE is required to be worn on McMillen Jacobs jobsites 100% of the time.

In order to determine necessary PPE, a written hazard assessment (PTA or JHA) shall be conducted to determine the hazards present and the adequacy of the corrective measures to be taken with regard to all required personal protective equipment.

Other specialized equipment may be required for the performance of specific jobs and could require additional PPE.

Visitors shall turn in any PPE loaned to them and check out at the field office prior to leaving the job site.

Underground Division Safety Policy Manual Minimum Requirements for PPE


Required PPE Head Protection. Selected and worn in accordance with OSHA 1910.135. Head protection (hard

hats) will meet the requirements of American National Standards Institute (ANSI) Z89.1-2014, Type 1 Classes C, G, E. Hardhats are not required when operating heavy equipment that has an enclosed cage that protects the operator from overhead hazards. Employees operating this equipment are still required to have their hardhat with them. Upon leaving the machine, employees are required to wear their hardhat.

Eye Protection / Face Protection. Eye and any face protection will meet the requirements of ANSI Z87.1-2015. Different conditions will require different levels of protection. When required face protection is necessary, eye protection shall also be worn under the face shield. All eye protection must include side protection. Corrective lenses will be safety glass conforming to ANSI Z87. Nonconforming standard prescription eye wear must be protected with goggles or face shields. Prescription safety glasses may be supplied by the Underground Division with the approval of the supervisor. To encourage employee responsibility for maintenance of PPE equipment, resupply of eye protection requires a trade-in process, whereby the employee turns in used glasses in order to receive new glasses. This is at no cost to the employee. A “wipe station” or cleaning supplies will be provided for each site for the purpose of cleaning safety glass lenses.

Vests or High-visibility Shirts. Shall be worn at all times on jobsites. Any employees required to work in an area where they are exposed to the movement of heavy equipment and vehicular traffic on any construction site (and anybody working underground) will be provided with a high-visibility safety vest or shirt (Class 2). Night work or exposure to vehicle speeds in excess of 50 mph shall require the provision of a vest with additional highly reflective markings (Class 3). Tear-away vests for underground, scaffolding, reinforcing steel work, etc., should be utilized where practical.

Hearing Protection. Hearing protection shall be provided to all employees who are exposed to noise levels that could go above 85 decibels. Training in the use of the selected protection device(s) shall be provided. Ear plugs of varying types are available for every employee or visitor to the site. A Hearing Conservation Program (HCP) is detailed in Appendix F, and any employee who will be working in an environment where the time-weighted average (TWA) of 90 dBA is exceeded will be enrolled in the HCP. We encourage employees to carry at least one pair of ear plugs in their pocket at all times so that hearing protection, when needed, is close at hand.

Foot Protection. Protective footwear shall be selected and worn in accordance with OSHA 1910.136. Substantial work footwear (boots) shall be made of leather or equally firm material and have soles and heels made of material and kept in a condition that will not create a slip hazard. Boots should provide puncture protection (resistance) and toe protection to best protect the employee from hazards likely to be present at the worksite. This footwear shall conform to ASTM F2413-11 – Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear, or be demonstrably as effective, and provide ankle support and toe protection (either steel or composite toe). The above policy is for the purpose of protecting employees from jobsite hazards “likely” to be present. Employees should consult with jobsite management for other/further requirements regarding foot protection. The appropriate boot should then be purchased in accordance with the above, and any additional/special requirements as they pertain to a specific jobsite requirement. Certain specialized boots (e.g., muck-type boots for inside



tunnel work) are subject to current approved reimbursement amount and require Supervisor approval. Work shoes, sneakers, athletic shoes, canvas topped shoes, dress/work shoes, and sandals are not to be worn on jobsites.

Hand Protection. Selected and worn in accordance with OSHA 1910.138. The Underground Division jobsites are supplied with appropriate gloves for the work, and employees shall have ready access to the appropriate gloves and shall wear gloves providing appropriate hazard protection. Considerations for selection of appropriate gloves include skin absorption of harmful substances, cuts, abrasions, punctures, chemical burns, thermal burns, and temperature extremes, both hot and cold. Cut rated gloves of Level 3 or greater shall be used for working with sharp edges. Gloves are required for all work unless the work cannot be performed with gloves or if the gloves themselves pose a safety hazard. Operators of heavy equipment do not have to wear gloves while operating their equipment. Gloves must be worn upon exiting the machine. To encourage employee responsibility for maintenance of PPE equipment, resupply of work gloves involves a trade-in process whereby the employee turns in used gloves in order to receive new gloves. This is at no cost to the employee.

Specialty PPE Specialty PPE will be utilized on an as-needed basis:

Fall Protection. Training in fall protection systems shall be performed, lanyards, harnesses and attachment devices, shall be used as required. PPE for fall protection will be provided for by the Underground Division when the project requires the use of fall protection. Our Fall Protection Plan is found in Appendix E.

Respiratory Protective Equipment. As directed by the site safety manager (SSM), respiratory protection equipment (Appendix G) will be worn when engineering controls are not sufficient, or it is clearly impractical, to remove harmful dusts, fumes, mists, or vapors from the air employees breathe. Employees will be trained in the use and care of the particular equipment. Training will be conducted on health hazard equipment and procedures to be used, with initial issue of equipment and whenever there is a change in equipment. Properly fitted equipment will be supplied to the employee at no cost where projects require this specific PPE. The employee is required to maintain and care for the supplied respiratory equipment. Records of training and fit testing must be developed and maintained. The respiratory protection policy is found in Appendix G.

Self-Contained Self-Rescuer (SCSR). Tunnel emergency self-rescue gear will be available according to the applicable safety regulations. Training in the use and limitations of the device shall be conducted before beginning work, and it is recommended that SCSR refresher training be taken frequently by those employees whose job requires them to have them available for use.

Personal Flotation Devices (PFD). Any employee working on, over, or adjacent to water shall be provided with and shall wear approved personal flotation devices (PDFs). PDFs shall be per job-specific requirements.

Leg Protection. In addition to long pants, any employee required to use a chainsaw shall be required to wear, and will be provided with, “chainsaw chaps” to protect the vulnerable parts of



the legs. Employees working in areas of brush where snakes are known to exist shall be issued snake chaps.

Electrical Protection. Normally, Underground Division employees are not present or operating the electrical equipment or switchgear where electrical PPE is required. If a special instance occurs, electrical PPE will be provided per the job-specific requirement.

Safety and bodily protection are of the utmost importance to the Underground Division; therefore, this policy is designed to increase the safety and health of our employees. McMillen Jacobs Associates’ Underground Division believes that to maintain this objective, all individuals on our jobsites shall be required to wear adequate personal protective equipment (PPE).



Appendix B Safety Hazard Escalation Procedures


McMillen Jacobs Associates August 2017


Safety Hazard Escalation Procedures



Escalation Procedure for Immediate Danger to Life and Health

Safety Hazard Escalation Procedures



Escalation Procedure for Non-Life-Threatening Condition



Appendix C Permit-Required Confined Space Safety Plan


Permit-Required Confined

Space Safety Plan

January 2020

Underground Division Safety Policy Manual Permit-Required Confined Space Safety Plan


Table of Contents 1.0 Applicability and Overview .................................................................................................................. 1

2.0 Authority .............................................................................................................................................. 1

3.0 Definitions ............................................................................................................................................ 1

4.0 General Requirements ........................................................................................................................ 4

5.0 Underground Division PRCS Program ................................................................................................ 9

5.1 Program Implementation .......................................................................................................... 9

5.2 Permit Management ............................................................................................................... 11

5.3 Permit Requirements ............................................................................................................. 12

5.4 Employee Training ................................................................................................................. 13

5.5 Tunnel and Confined Space Entry ......................................................................................... 13

5.5.1 Duties of Authorized Entrants ................................................................................. 13

5.5.2 Duties of Attendants ................................................................................................ 14 5.5.3 Duties of Entry Supervisors ..................................................................................... 15

5.5.4 Rescue and Emergency Services ........................................................................... 16

5.5.5 Procedures for Atmospheric Testing ....................................................................... 17

6.0 References ........................................................................................................................................ 20

Attachments Attachment A Permit-Required Confined Space Entry Permit




Revision Log Revision No. Date Updated By

2 January 2020 Bill Mitchell, Ted Depooter, Sarah Wilson 1 August 2017 Bill Mitchell, Ted Depooter 1 June 2014 Blake Rothfuss, Rachael Martin 0 June 2012 Blake Rothfuss



1.0 Applicability and Overview This safety plan1 is applicable to all McMillen Jacobs Associates Underground Division employees and its subcontractors working in confined spaces or permit-required confined spaces. The plan contains requirements for practices and procedures to protect employees from the hazards of entry into permit-required confined spaces.

The Underground Division, as an employer, does not own or operate any spaces meeting the requirements of a confined space or permit-required confined space.

The Underground Division may be contracted with to provide professional services within confined spaces or permit-required confined spaces.

To perform field investigations, inspections, condition assessments and construction resident engineering, Underground Division employees are asked to work in confined spaces. Confined spaces may include: in-service water, wastewater, storm-water, and irrigation water tunnels; pits, troughs, and trenches; pipelines and penstocks; pits and shafts; and other spaces satisfying the definition of a confined space or permit-required confined space.

2.0 Authority Permit-Required Confined Space Operations are regulated by the 29 CFR Subpart AA 1926.1200 in the United States and multiple state-specific safety regulations. In Canada, Australia, and New Zealand, each country, state, and province have similar but specific safety regulations for confined space operations.

The Fed-OSHA, state-OSHA, and other regulatory agencies are able to levy fines against both an employee and the company if said agency finds that the employee has not been adequately trained, does not possess the proper knowledge, or does not utilize appropriate safe guards when working in confined spaces.

3.0 Definitions Acceptable entry conditions: The conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

Attendant: An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant’s duties assigned in the employer’s permit space program.

1 The Permit-Required Confined Space Safety Plan is Appendix C of the McMillen Jacobs Associates Underground Division’s Safety Policy Manual. The plan is available in the common areas of each office/worksite for review by any interested employee and on the company’s intranet site.



Authorized entrant: An employee who is authorized by the employer to enter a permit space.

Blanking or blinding: The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.

Confined space: A space that:

Is large enough and so configured that an employee can enter bodily and perform assigned work.

Has limited or restricted means for entry or exit. For example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.

Is not designed for continuous employee occupancy.

Double block and bleed: The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.

Emergency: Any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants.

Engulfment: The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.

Entry: The action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.

Entry permit (permit): The written or printed document that is provided by the employer to allow and control entry into a permit space and that contains the required information.

Entry supervisor: The person (such as the employer, chief inspector, or supervisor) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section. Note: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this section for each role he or she fills. Also, the duties of entry supervisor may be passed from one individual to another during the course of an entry operation.

Hazardous atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL).



Airborne combustible dust at a concentration that meets or exceeds its LFL. Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.5 m) or less.

Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent.

Atmospheric concentration of any substance for which a dose is published in Cal/OSHA’s Group 14 for Radiation and Radioactivity or a permissible exposure limit is published in Cal/OSHA Section 5155 for Airborne contaminants and which could result in employee exposure in excess of its dose or permissible exposure limit; Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.

Any other atmospheric condition that is immediately dangerous to life or health. Note: For air contaminants for which a dose is not published in the referenced safety regulations or a permissible exposure limit is not published in the referenced safety regulations, other sources of information such as: Safety Data Sheets (SDSs), published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.

Hot work permit: The employer’s written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.

Immediately dangerous to life or health (IDLH): Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit space. Note: Some materials—hydrogen fluoride gas and cadmium vapor, for example—may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12 to 72 hours after exposure. The victim “feels normal” from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be “immediately” dangerous to life or health.

Inerting: The displacement of the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible. Note: This procedure produces an IDLH oxygen-deficient atmosphere.

Isolation: The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such: as: Blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

Line breaking: The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure or temperature capable of causing injury.

Non-permit confined space: A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.

Oxygen deficient atmosphere: An atmosphere containing less than 19.5 percent oxygen by volume.



Oxygen enriched atmosphere: An atmosphere containing more than 23.5 percent oxygen by volume.

Owner/Operator: A business entity with legal jurisdiction over a confined space or permit-required confined space (host employer), and to which the Underground Division has agreed to provide professional services.

Permit-required confined space (permit space): A confined space that has one or more of the following characteristics:

Contains or has a potential to contain a hazardous atmosphere;

Contains a material that has the potential for engulfing an entrant;

Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; or

Contains any other recognized serious safety or health hazard.

Permit-Required Confined Space Program (PRCS): The employer’s overall program for controlling, and, where appropriate, for protecting employees from permit space hazards and for regulating employee entry into permit spaces.

Permit system: The employer’s written procedure for preparing and issuing permits for entry and for returning to the permit space to service following termination of entry.

Prohibited condition: Any condition in a permit space that is not allowed by the permit during the period when entry is authorized.

Rescue service: The personnel designated to rescue employees from permit spaces.

Retrieval system: The equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for nonentry rescue of persons from permit spaces.

Testing: The process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. If electronic or thermal equipment is used to perform such tests, and the possibility exists of an explosive substance or a hazardous atmosphere due to flammable gases and vapors, then the testing equipment must be approved for use in such explosive or flammable conditions. Note: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry.

4.0 General Requirements (1) The Owner/Operator shall evaluate the workplace to determine if any spaces are permit-required

confined spaces.



(2) If the workplace contains permit spaces, the Owner/Operator shall inform the Project Manager and all exposed employees and other employees performing work in the area, by posting danger signs or by any other equally effective means, of the existence, location of, and the danger posed by the permit spaces. Note: A sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or the use of similar language would satisfy the requirement for a sign.

(3) If the Owner/Operator decides that its employees, contractors, and other employees performing work in the area will not enter permit spaces, the Owner/Operator shall inform the McMillen Jacobs Associates Project Manager and the Owner/Operator shall take effective measures to prevent all such employees from entering the permit spaces and shall comply with General Requirements paragraphs (1), (2), (6), and (8).

(4) If the Owner/Operator decides that its employees and contractors will enter permit spaces, the Owner/Operator shall inform the McMillen Jacobs Associates Project Manager and shall confirm that all employees and contractors will work under the Owner/Operator’s written permit space program. In the absence of an Owner/Operator written permit space program, the McMillen Jacobs Associates Permit-Required Confined Space Program shall be used (see Section 5.0). The written Permit-Required Confined Space Entry Program shall be available for inspection by employees, contractors, and their authorized representatives. Employers must consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program. Employers must make available to each affected employee and his/her authorized representative all information required to be developed by this standard.

(5) An Owner/Operator may use the alternate procedures specified in General Requirements paragraph (5)(B) for entering a permit space under the conditions set forth in below in paragraph (5)(A).

(A) An Owner/Operator whose employees or contractors enter a permit space need not comply with the permit entry requirements provided that:

1. The Owner/Operator can demonstrate that the only hazard posed by the permit space is an actual or potential hazardous atmosphere.

2. The Owner/Operator can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry.

3. The Owner/Operator develops monitoring and inspection data that support the demonstrations required by subparagraphs (5)(A) 1 and 2 above.

4. If an initial entry of the permit space is necessary to obtain the data required by subparagraph (5)(A) 3, the entry must be performed in compliance with the PRCS Program.



5. The determinations and supporting data required by General Requirements subparagraphs (5)(A) 1, 2, and 3 are documented by the Owner/Operator and are made available to each employee and contractor who enters the permit space under the terms of General Requirements paragraph (5) or to that employee’s authorized representative.

6. Entry into the permit space under the terms of General Requirements paragraph (5)(A) is performed in accordance with the requirements of General Requirements paragraph (5)(B).

(B) The following requirements apply to entry into permit spaces that meet the conditions set forth in General Requirements paragraph (5)(A) above.

1. Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed.

2. When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect each employee working in the space from foreign objects entering the space.

3. Before an employee enters the space, the internal atmosphere shall be tested in accordance with the Procedures for Atmospheric Testing in Section 5.5.5 below, with a calibrated direct-reading instrument, for the following conditions in the order given:

a. Oxygen content

b. Flammable gases and vapors

c. Potential toxic air contaminants

4. There may be no hazardous atmosphere within the space whenever any employee is inside the space.

5. Continuous forced air ventilation shall be used, as follows:

a. An employee or contractor may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere.

b. The forced air ventilation shall be so directed as to ventilate the immediate areas where an employee or contractor is or will be present within the space and shall continue until all employees or contractors have left the space.

c. The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space.



6. The atmosphere within the space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere.

7. If a hazardous atmosphere is detected during entry:

a. Each employee shall leave the space immediately.

b. The space shall be evaluated to determine how the hazardous atmosphere developed.

c. Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place.

8. The employer shall verify that the space is safe for entry and that the pre-entry measures required by paragraph (5)(B) have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification shall be made before entry and shall be made available to each employee entering the space or to that employee’s authorized representative.

9. Any employee or contractor who enters the space, or that employee’s authorized representative, shall be provided an opportunity to observe the pre-entry testing required by General Requirements subparagraphs (5)(B) 3 and 6.

(6) When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the Owner/Operator shall notify the McMillen Jacobs Associates Project Manager and the Owner/Client shall reevaluate that space and, if necessary, reclassify it as a permit-required confined space.

(7) A space classified by the Owner/Operator as a permit-required confined space may be reclassified as a non-permit confined space under the following procedures:

(A) If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the nonatmospheric hazards remain eliminated.

(B) If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed in accordance with a PRCS program. If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated. Note: Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards.

(C) The Underground Division Project Manager and Owner/Client shall document the basis for determining that all hazards in a permit space have been eliminated through a



certification that contains the date, the location of the space, and the signature of the person making the determination. The certification shall be made available to each employee entering the space or to that employee’s authorized representative.

(D) If hazards arise within a permit space that has been declassified to a non-permit confined space, each employee in the space shall exit the space. The McMillen Jacobs Associates Project Manager and Owner/Client shall then reevaluate the space and determine whether it must be reclassified as a permit space.

(8) When an Owner/Operator (host employer) arranges to have the Underground Division (contractor) or employees of another employer (contractor) perform work that involves permit space entry or confined space entry, the Owner/Operator shall do the following:

(A) Inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of Cal/OSHA Section 5158.

(B) Apprise the Underground Division Project Manager, in writing, of the elements—including the hazards identified and the host employer’s experience with the space—that make the space in question a permit space.

(C) Apprise the contractor of any precautions or procedures that the host employer has implemented for the protection of employees in or near permit spaces where contractor personnel will be working.

(D) Coordinate entry operations with the contractor, when both host employer personnel and contractor personnel will be working in or near permit spaces, as required by the Permit-Required Confined Space Program (Section 5.0 below).

(E) Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

(9) In addition to complying with the permit space requirements that apply to all employers, each contractor who is retained to perform permit space entry operations shall do the following:

(A) Obtain any available information regarding permit space hazards and entry operations from the Owner/Operator (host employer).

(B) Coordinate entry operations with the Owner/Operator (host employer), when both Owner/Operator (host employer) personnel and contractor personnel will be working in or near permit spaces, as required by the Permit-Required Confined Space Program (Section 5.0 below).

(C) Inform the Owner/Operator (host employer) of the permit space program that the contractor will follow and of any hazards confronted or created in permit spaces, either through a debriefing or during the entry operation.



5.0 Underground Division PRCS Program In the event that the Owner/Operator’s Permit-Required Confined Space Program (PRCS or permit space program) is not used, the Underground Division permit space program shall be used, as described below.

5.1 Program Implementation

(1) Implement the measures necessary to prevent unauthorized entry.

(2) Identify and evaluate the hazards of permit spaces before employees enter them and document them on the permit.

(3) Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including but not limited to, the following:

(A) Specifying acceptable entry conditions;

(B) Isolating the permit space;

(C) Purging, inerting, flushing, or ventilating the permit space as necessary to eliminate or control atmospheric hazards;

(D) Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; and

(E) Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry.

(4) Provide the following equipment at no cost to employees, maintain that equipment properly, and ensure that employees use that equipment properly:

(A) Testing and monitoring equipment needed to comply with PRCS paragraph (5);

(B) Ventilating equipment needed to obtain acceptable entry conditions;

(C) Communications equipment appropriate for the entry and to maintain communication between the attendant(s) and authorized entrants;

(D) Personal protective equipment insofar as feasible engineering and work practice controls do not adequately protect employees;

(E) Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly in an emergency;

(F) Barriers and shields to prevent unauthorized entrants from accessing the space;

(G) Equipment, such as ladders, needed for safe ingress and egress by authorized entrants;



(H) Rescue and emergency equipment except to the extent that the equipment is provided by rescue services; and

(I) Any other equipment necessary for safe entry into and rescue from permit spaces.

(5) Evaluate permit space conditions as follows when entry operations are conducted:

(A) Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin. The exception is if isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing shall be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions shall be continuously monitored in the areas where authorized entrants are working.

(B) Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations.

(C) When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, and then for toxic gases and vapors.

(D) Provide each authorized entrant or that employee’s authorized representative an opportunity to observe the pre-entry and any subsequent testing or monitoring of permit spaces.

(E) Reevaluate the permit space in the presence of any authorized entrant or that employee’s authorized representative who requests that the employer conduct such reevaluation because the entrant or representative has reason to believe that the evaluation of that space may not have been adequate.

(F) Immediately provide each authorized entrant or that employee’s authorized representative with the results of any atmospheric testing.

(6) Provide at least one attendant outside the permit space into which entry is authorized for the duration of entry operations. Note: Attendants may be assigned to monitor more than one permit space, provided the duties can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside the permit space to be monitored as long as the duties can be effectively performed for each permit space that is monitored.

(7) If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant`s responsibilities.

(8) Designate the persons who are to have active roles (e.g., authorized entrants, attendants, entry supervisors, and persons who test or monitor the atmosphere in a permit space) in entry operations, identify the duties of each such employee, and provide each such employee with the required training.



(9) Develop and implement procedures for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, for summoning additional rescue and emergency services, and for preventing unauthorized personnel from attempting a rescue.

(10) Develop and implement a system for the preparation, issuance, use, and cancellation of entry permits.

(11) Develop and implement procedures to coordinate entry operations when employees of more than one employer are working simultaneously as authorized entrants in a permit space, so that employees of one employer do not endanger the employees of any other employer.

(12) Develop and implement procedures (such as closing off a permit space and canceling the permit) necessary for concluding the entry after entry operations have been completed.

(13) Review entry operations when the Owner/Operator has reason to believe that the measures taken under the permit space program may not protect employees and revise the program to correct deficiencies found to exist before subsequent entries are authorized. Note: Examples of circumstances requiring the review of the permit space program are: any unauthorized entry of a permit space, the detection of a permit space hazard not covered by the permit, the detection of a condition prohibited by the permit, the occurrence of an injury or near-miss during entry, a change in the use or configuration of a permit space, and employee complaints about the effectiveness of the program.

(14) Review the permit space program, using the canceled permits retained, within 1 year after each entry and revise the program as necessary to ensure that employees participating in entry operations are protected from permit space hazards. Note: Employers may perform a single annual review covering all entries performed during a 12-month period. If no entry is performed during a 12-month period, no review is necessary.

5.2 Permit Management

All Underground Division employees and contractors shall manage a Permit-Required Confined Space Entry Permit (Attachment A) prior to entry in accordance with the following.

(1) Before entry is authorized, document the completion of measures required by the PRCS Program by preparing an entry permit.

(2) Before entry begins, the entry supervisor identified on the permit shall sign the entry permit to authorize entry.

(3) The completed permit shall be made available at the time of entry to all authorized entrants or their authorized representatives, by posting it at the entry portal or by any other equally effective means, so that the entrants can confirm that pre-entry preparations have been completed.

(4) The duration of the permit may not exceed the time required to complete the assigned task of job identified on the permit.

(5) The entry supervisor shall terminate entry and cancel the entry permit when:



(A) The entry operations covered by the entry permit have been completed; or

(B) A condition that is not allowed under the entry permit arises in or near the permit space.

(6) The Underground Division Project Manager shall provide the terminated permit to the McMillen Jacobs Associates Safety Director, who shall retain each canceled entry permit for at least 1 year to facilitate the review of the permit space program. Any problems encountered during an entry operation shall be noted on the pertinent permit so that appropriate revisions to the permit space program can be made.

5.3 Permit Requirements

All Underground Division employees and contractors shall utilize a Permit-Required Confined Space Entry Permit (Attachment A) to document compliance with the PRCS Program. The permit shall identify the following:

(1) The permit space to be entered;

(2) The purpose of the entry;

(3) The date and the authorized duration of the entry permit;

(4) The authorized entrants within the permit space, by name or by such other means (for example, through the use of rosters or tracking systems) as will enable the attendant to determine quickly and accurately, for the duration of the permit, which authorized entrants are inside the permit space;

(5) The personnel, by name, currently serving as attendants;

(6) The individual, by name, currently serving as entry supervisor, with a space for the signature or initials of the entry supervisor who originally authorized entry;

(7) The hazards of the permit space to be entered;

(8) The measures used to isolate (LOTO) the permit space and to eliminate or control permit space hazards before entry including the lockout or tagging of equipment and procedures for purging, inerting, ventilating, and flushing permit spaces;

(9) The acceptable entry conditions;

(10) The results of initial and periodic tests accompanied by the names or initials of the testers and by an indication of when the tests were performed;

(11) The rescue and emergency services that can be provided on-site and additional services, such as the equipment to use, and the numbers to call for summoning those services;

(12) The communication procedures used by authorized entrants and attendants to maintain contact during the entry;



(13) Equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment to be provided for compliance with this section;

(14) Any other information whose inclusion is necessary, given the circumstances of the particular confined space, in order to ensure employee safety; and

(15) Any additional permits, such as for hot work, that have been issued to authorize work in the permit space.

5.4 Employee Training

(1) The Underground Division shall provide to the employee, at no charge, training both in a language and with a vocabulary such that all employees working within the PRCS Program acquire the understanding, knowledge, and skills necessary for the safe performance of their assigned duties.

(2) Training shall be provided to each affected employee:

(A) Before the employee is first assigned PRCS duties;

(B) Before there is a change in assigned duties;

(C) Whenever there is a change in permit space operations that presents a hazard for which an employee was not previously trained;

(D) Whenever the employer has reason to believe either that there are deviations from the permit space entry procedures or that there are inadequacies in the employee’s knowledge or use of these procedures.

(3) The training shall establish employee proficiency in the assigned duties and shall introduce new or revised procedures, as necessary.

(4) The Underground Division shall certify that the required training has been accomplished. The certification shall contain each employee’s name, the signatures or initials of the trainers, and the dates of training. The certification shall be available for inspection by employees and their authorized representatives.

5.5 Tunnel and Confined Space Entry

5.5.1 Duties of Authorized Entrants

The Underground Division shall ensure that all authorized entrants:

(1) Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.

(2) Properly use equipment.



(3) Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space when necessary.

(4) Alert the attendant whenever:

(A) The entrant recognizes any warning sign or symptom of exposure to a dangerous situation; or

(B) The entrant detects a prohibited condition;

(5) Exit from the permit space as quickly as possible whenever:

(A) An order to evacuate is given by the attendant or the entry supervisor;

(B) The entrant recognizes any warning sign or symptom of exposure to a dangerous situation;

(C) The entrant detects a prohibited condition; or

(D) An evacuation alarm is activated.

5.5.2 Duties of Attendants

The Underground Division shall ensure that each attendant:

(1) Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.

(2) Is aware of possible behavioral effects of hazard exposure in authorized entrants.

(3) Continuously maintains an accurate count of authorized entrants in the permit space and ensures the means used to identify authorized entrants within the permit space is accurate.

(4) Remains outside the permit space during entry operations until relieved by another attendant.

(5) Communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space in an emergency.

(6) Monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions:

(A) If the attendant detects a prohibited condition;

(B) If the attendant detects the behavioral effects of hazards exposure in an authorized entrant;

(C) If the attendant detects a situation outside the space that could endanger the authorized entrants; or



(D) If the attendant cannot effectively and safely perform all the required duties.

(7) Initiates on-site rescue procedures and, if necessary, summons additional rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards.

(8) Takes the following actions when unauthorized persons approach or enter a permit space while entry is underway:

(A) Warns the unauthorized persons that they must stay away from the permit space;

(B) Advises the unauthorized persons that they must exit immediately if they have entered the permit space; and

(C) Informs the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.

(9) Performs non-entry rescues or other rescue services as part of the employer’s on-site rescue procedure.

(10) Performs no duties that might interfere with the attendant’s primary duty to monitor and protect the authorized entrants.

5.5.3 Duties of Entry Supervisors

The Underground Division shall ensure that the Entry Supervisor(s):

(1) Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.

(2) Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.

(3) Terminates the entry and cancels the permit as required.

(4) Verifies that rescue services are available and that the means for summoning additional services are operable.

(5) Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations.

(6) Determines, whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed within the space, that entry operations remain consistent with the terms of the entry permit and that acceptable entry conditions are maintained.



5.5.4 Rescue and Emergency Services

The Underground Division shall ensure that at least one standby person at the site is trained and immediately available to perform rescue and emergency services. This standby person shall meet all necessary regulatory requirements.

(1) Underground Division employees shall not provide rescue services.

(2) Employee participation in and understanding of the development, purpose, and implementation of all aspects of the permit-required confined space are required.

(3) The Owner/Operator or the Underground Division shall arrange to have persons other than the Owner/Operator (host employer) or Underground Division employees perform permit space rescue, and shall:

(A) Evaluate the rescuer’s ability to respond in a timely manner when summoned.

(B) Evaluate the rescuer’s ability to function appropriately in tasks and be proficient in the use of equipment while rescuing entrants.

(C) Once the rescue team is selected based on evaluation, ensure that the team has the ability to reach the victim, and is proficient in and equipped for the needed rescue services for the space.

(D) Agree to notify the Owner and the Underground Division immediately if the rescue team becomes unavailable.

(E) Inform the rescue team of the hazards it may confront when called on to perform rescue at the host employer’s facility

(F) Provide the rescue service with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

(G) Verify that the rescue service:

1. Meets the necessary regulatory requirements

2. Provides all equipment and training at no cost to employees

3. Provides each affected employee with appropriate PPE needed to conduct permit-space rescues.

4. Ensures its employees complete the training required, comprehend it, and have a proficiency as authorized entrants.

5. Trains each affected employee in basic first aid and CPR.



6. Ensures at least one person on the rescue team is trained in and holds current certification in first aid/ CPR.

7. Ensures affected employees practice simulated permit space rescues at least every 12 months and before any actual rescue.

(4) To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements.

(A) Each authorized entrant shall use a chest or full body harness, with provisions for a retrieval line to be attached at a suitable point so that when rescued, the entrant presents the smallest possible profile (for example at the center of the entrant’s back near shoulder level, or above the entrant’s head). Wristlets may be used in lieu of the chest of full body harness if the employer can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.

(B) The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet (1.5 m) deep.

(5) If an injured entrant is exposed to a substance for which a Safety Data Sheet (SDS) or other similar written information is required to be kept at the worksite, that an SDS or written information shall be made available to the medical facility treating the exposed entrant.

5.5.5 Procedures for Atmospheric Testing

5.5.5.1 General Procedures

Operators use direct reading portable gas monitors (DRPGMs) to detect the presence and concentration of toxic and combustible gases, as well as oxygen deficiency or oxygen enrichment (which is a fire and explosion hazard). Workers must not rely solely on their sense of smell to alert them to these hazards. Employers should ensure that workers use these instruments when working in areas with potential hazardous atmospheres.

“Calibration” refers to an instrument’s measuring accuracy relative to a known traceable concentration of test gas. DRPGMs compare the sensor’s response to a known concentration of the test gas. To confirm the validity of this comparison, it is important to ensure the calibration gas has not expired (always check the expiration date of the gas before usage). The instrument’s response to the calibration gas serves as the reference point.

The responsiveness of sensors will vary with workplace environmental conditions, such as temperature and humidity. Therefore, to the degree possible, operators should calibrate sensors in environmental



conditions that are the same as (or similar to) the actual workplace conditions. Follow the manufacturer’s guidelines for proper calibration.

Standard procedures for regular calibration that conform to the manufacturer’s instructions, internal company policy, and/or the appropriate regulatory agency guidelines will help to ensure that calibration procedures are readily followed by the DRPGM operators, and that the instruments are operable and accurate when used. Employers should keep calibration records for the life of each instrument. This record enables operators to quickly identify a DRPGM that has a history of excessive maintenance/repair, or is prone to erratic readings, and to track drift of the sensors to determine when they need replacement.

(1) Bump Test (or Function Check): This is a qualitative function check in which a challenge gas is passed over the sensor(s) at a concentration and exposure time sufficient to activate all alarm settings. The purpose of this check is to confirm that gas can get to the sensor(s) and that all the instrument’s alarms are functional. The bump test or function check does not provide a measure of the instrument’s accuracy. When performing a bump test, the challenge gas concentration should trigger the DRPGM’s alarm(s).

(2) Calibration Check or Full Calibration: There are two methods for verifying DRPGM accuracy: a calibration check and a full calibration. Each method is appropriate under certain conditions. A calibration check verifies that the sensors and alarms respond within the manufacturer’s acceptable limits by exposing the instrument to a test gas. The operator compares the reading to the test-gas concentration (as indicated on the cylinder containing the test gas). If the instrument’s response is within the acceptable range of the test-gas concentration (typically ± 10 to 20% of the test-gas concentration), then the calibration check has verified the instrument’s accuracy. Note: OSHA recommends that operators check with the instrument’s manufacturer for the acceptable tolerance ranges. An operator should “zero” an instrument (reset the reference point; in some cases “zero air” gas may be needed) before conducting the calibration check to ensure that the calibration check results are accurate. When a calibration check is performed, the test-gas concentration should be high enough to trigger the instrument’s alarms. If the calibration check results are not within the acceptable range, the operator should perform a full calibration. A full calibration adjusts the instrument’s reading to coincide with a known concentration (i.e., certified standard) of test gas. Test gas used for calibration gas should always be certified using a standard traceable to the National Institute of Standards and Technology.

(3) When to Perform a Bump Test and When to Perform a Full Calibration: A bump test or calibration check of portable gas monitors should be conducted before each day’s use in accordance with the manufacturer’s instructions. If an instrument fails a bump test or a calibration check, the operator should perform a full calibration on it before using it. If the instrument fails the full calibration, the employer should remove it from service. The manufacturer should then be contacted for assistance or service.

5.5.5.2 Calibration Rules

The following are a few basic calibration rules for DRPGMs:



(1) Follow the manufacturer’s guidelines for proper calibration. Operators cannot perform any job, including DRPGM calibration, properly or safely without the right tools. The type and concentration of calibration test gas, sample tubing, flow regulators, and calibration adapters are key links in the calibration chain. Operators should conduct any testing to verify the operation of the gas monitor in an environment that is the same as (or similar to) the working conditions (e.g., temperature, humidity, atmospheric pressure).

(2) Only use a certified traceable test gas, and do so before its expiration date. The instrument can only be as accurate as the test gas used to calibrate it. Be certain that the supplier can provide a certificate of analysis for every test-gas cylinder. The concentration of the test gas, particularly reactive gases such as hydrogen sulfide and chlorine, will only remain stable for a limited period of time. Never use a test gas after its expiration date.

(3) Train DRPGM operators on the proper methods of calibration. Most instruments are designed to be field calibrated with detailed instructions provided in the manufacturer’s user manual, training videos, or computer-based training modules. Employers should train and test everyone responsible for performing DRPGM calibration.

5.5.5.3 Atmospheric Testing

Atmospheric testing is required for two distinct purposes: evaluation of the hazards of the permit space, and verification that acceptable entry conditions for entry into that space exist.

(1) Evaluation Testing: The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise, so that appropriate permit entry procedures can be developed and acceptable entry conditions stipulated for that space. Evaluation and interpretation of these data, and development of the entry procedure, should be done or reviewed by a technically qualified professional (e.g., Cal/OSHA consultation service, certified industrial hygienist, registered safety engineer, certified safety professional, certified marine chemist) based on evaluation of all serious hazards.

(2) Verification Testing: The atmosphere of a permit space that may contain a hazardous atmosphere should be tested for residues of all contaminants identified by evaluation testing using permit-specified equipment to determine that residual concentrations at the time of testing and entry are within the range of acceptable entry conditions. Testing results (i.e., actual concentration, etc.) should be recorded on the permit in the space provided adjacent to the stipulated acceptable entry condition.

(3) Duration of Testing: Measurement of values for each atmospheric parameter should be made for at least the minimum response time of the test instrument specified by the manufacturer.

(4) Testing Stratified Atmosphere: When monitoring for entries involving a descent into atmospheres that may be stratified, the atmospheric envelope should be tested a distance of approximately 4 feet (1.2 m) in the direction of travel and to each side. If a sampling probe is used, the entrant’s rate of progress should be slowed to accommodate the sampling speed and detector response.



(5) Order of Testing: A test for oxygen is performed first because most combustible gas meters are oxygen dependent and will not provide reliable readings in an oxygen deficient atmosphere. Combustible gases are tested for next because the threat of fire or explosion is both more immediate and more life threatening, in most cases, than exposure to toxic gases and vapors. If tests for toxic gases and vapors are necessary, they are performed last.

6.0 References United States

29 CFR Subpart AA 1926.1200 – Permit Required Confined Spaces: https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf.

Canada

Canadian Centre for Occupational Health and Safety (CCOHS) – Confined Space Fact Sheets: http://www.ccohs.ca/oshanswers/hsprograms/confinedspace_intro.html.

Australia

Australian Standard 2865 – Safe Working in a Confined Space:

https://infostore.saiglobal.com/en-au/Standards/Product-Details-123622_SAIG_AS_AS_274657/?ProductID=123622_SAIG_AS_AS_274657

New Zealand

WorkSafe NZ: Planning Entry and Working Safely in a Confined Space (refers to AS 2865 – Safe Working in a Confined Space): http://www.worksafe.govt.nz/worksafe/information-guidance/all-guidance-items/confined-spaces-planning-entry-and-working-safely-in-a-confined-space

https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

http://www.ccohs.ca/oshanswers/hsprograms/confinedspace_intro.html



http://www.worksafe.govt.nz/worksafe/information-guidance/all-guidance-items/confined-spaces-planning-entry-and-working-safely-in-a-confined-space

http://www.worksafe.govt.nz/worksafe/information-guidance/all-guidance-items/confined-spaces-planning-entry-and-working-safely-in-a-confined-space



Permit-Required Confined Space Entry Permit


Permit-Required Confined Space Entry Permit Includes shafts, pits, adits, trenches, and pipelines

McMillen Jacobs Associates Underground Division 1 January 2020

FACILITY NAME: DATE:

STREET ADDRESS TIME:

DESCRIPTION OF TUNNEL or CONFINED SPACE PHONE:

PURPOSE: Inspection/ Maintenance Construction

Permit # and Agency:

Nongassy Tunnel Potentially Gassy Tunnel Gassy Tunnel Confined Space Permit Required Confined Space Non-Permit Confined Space Trench or Pit Trench or Pit

Hazards Assessment Check off items as they are considered. Indicate “N/A” for nonapplicable tasks.

Task Hazard Control Addressed by

Environment Hazardous pneumatic energy? Moving machinery or equipment? Drowning or engulfment or entrapment? Hot or corrosive materials?

Complete LOTO

Painting work? Postpone entry until vapors are eliminated

Hot work? Ventilate work area

High ambient noise? Shutdown noise generator Wear hearing protection

Entry Dangerous entry site or location? Falling objects? Fall or slipping potential?

Barricade Head and eye protection Fall protection

Working pressure > ambient? Follow at-pressure work rules

Oxygen deficient atmosphere? Potential for toxic or flammable atmosphere?

Monitor air supply Continuous monitoring Agree on alarm/evacuation limits

Multiple entries or exits? Barricade Illuminate primary EXIT

Slips and falls Provide primary & backup lights Use walking sticks or safety lines Wear proper footwear Wear gloves Wear harnesses Walk at a careful pace Illuminate primary egress route

Hypothermia or extreme heat? Wear synthetic clothing Review symptoms Monitor buddy

Getting disoriented Identify EGRESS direction Illuminate primary egress route




Hazards Assessment (cont.) Check off items as they are considered. Indicate “N/A” for nonapplicable tasks.

Emergency Situation

Injured or ill entrant Provide bleeding control, sprain treatment, C-collar

Treat for hypothermia & shock Carry extra water. Carry whistle or signaling device Immediately evacuate

Exit Dangerous entry site or location? Falling objects? Fall potential?

Barricade Head and eye protection Fall protection

Communication Plan EMERGENCY CONDITION: “MAN DOWN”

EMERGENCY SIGNAL = HORN---HORN---HORN OR WHISTLE---WHISTLE---WHISTLE

EMERGENCY DISPATCH 911 RADIO CHANNELS:

LOCAL RESCUE DISPATCH DIRECT DIAL PHONE #: INCIDENT COMMANDER CALL SIGN:

LOCAL EMS DISPATCH DIRECT DIAL PHONE #: LANDING ZONE LAT-LONG:

ADDRESS -- TRAUMA CENTER / HOSPITAL / HYPERBOLIC CHAMBER LANDING ZONE LAT-LONG:

Clearance Points (lock-out/tag-out control points) CONTROL #1 DESCRIPTION:

PERSON WHO VERIFIED LOTO & TIME

CONTROL #2 DESCRIPTION:









Pre-Entry Checklist Check off items as they are completed. Indicate “N/A” for nonapplicable tasks.

Reconnoiter site Complete hazards assessment Complete emergency contacts Forecast weather Confirm helicopter LZ coord. Confirm first aid & response ready Make notifications Review objectives Review work assignments

Review entry & exit conditions Review Emerg. Resp. Plan Review termination events Review evacuation actions Review Communication Plan Complete tailboard Complete lock-out/tag-out Cross check PPE Complete Entry Permit

Entry Authorization Permit Termination

I CERTIFY THAT ALL PRE-ENTRY CONDITIONS LISTED ON THIS PERMIT HAVE BEEN MET, THAT ALL INFORMATION ON THIS PERMIT ACCURATELY REFLECTS ANTICIPATED CONDITIONS, AND THAT THE ENTRANTS ARE PREPARED TO ENTER THIS SPACE.

I CERTIFY THAT ALL ENTRANTS, MATERIALS, & EQUIPMENT HAVE EXITED THIS SPACE.

ENTRY SUPERVISOR SIGNATURE DATE/TIME INITIALS DATE/TIME

SAFETY OFFICER. SIGNATURE DATE/TIME INITIALS DATE/TIME

WORK SITE SUPV. SIGNATURE DATE/TIME INITIALS DATE/TIME




Entrants (Identify “buddies”) Name Entry Exit Entry Exit Entry Exit Entry Exit

1

2

3

4

5

6

7

8

9

10

Personal Protective Equipment Head protection Eye protection Hearing protection Foot protection Hand protection Fall protection Respirators Radios PFDs Flashlights & backup Air monitors Velometer




Atmospheric Monitoring TUNNEL OR CONFINED SPACE DESCRIPTION DATE TIME

LOCATION

TEST PERMISSIBLE EXPOSURE LIMIT

EXTERIOR CALIB. RDG.

INITIAL INTERIOR RDG.

Temperature none

O2 19.5% < > 23.5%

LEL < 10%

CO < 25 PPM

CO2 < 5000 PPM

H2S < 10 PPM

NO2 or SO2 < 2 PPM

HCHO < 0.75 PPM

“Working” Air Flow

200 cfm x number of people 100 cfm x total bhp

NOTES




OPERATIONAL SCHEMATIC



Appendix D Hazard Communication Plan


Hazard Communication Plan

January 2020

Underground Division Safety Policy Manual Hazard Communication Plan


Table of Contents 1.0 Underground Division Safety Policy .................................................................................................... 1

2.0 Authority .............................................................................................................................................. 1

3.0 Container Labeling .............................................................................................................................. 2

4.0 Safety Data Sheets ............................................................................................................................. 2

5.0 Employee Training and Information .................................................................................................... 2

6.0 Hazardous Nonroutine Tasks .............................................................................................................. 3

7.0 Other Employers/Contractors .............................................................................................................. 3

8.0 List of Hazardous Chemicals............................................................................................................... 4

8.1 Proposition 65 List of Chemicals (only for California offices) .................................................... 4

9.0 References .......................................................................................................................................... 4



Distribution To: Employees McMillen Jacobs Associates Underground Division Office Managers McMillen Jacobs Associates Underground Division From: Dan Adams McMillen Jacobs Associates Revised By: Bill Mitchell, Environmental Health and Safety Director McMillen Jacobs Associates Corporate Safety Committee: Ted DePooter, Sarah Wilson McMillen Jacobs Associates Underground Division Reviewed By: Carol Ravano, Julie McCullough McMillen Jacobs Associates Underground Division


2 January 2020 Bill Mtichell, Ted Depooter, Sarah Wilson 1 August 2017 Bill Mtichell, Ted Depooter 0 April 2014 Blake Rothfuss, Rachael Martin



1.0 Underground Division Safety Policy This Hazard Communication Plan is applicable to all McMillen Jacobs Associates Underground Division employees and its subcontractors. It is our policy to take every reasonable precaution in the management of our work environment to:

Protect the health and safety of employees and the general public

Prevent property damage

Ensure protection of environmental resources

Promote Occupational Health and Safety Awareness within the company

This Hazard Communication Plan has been established to ensure that information about the dangers of all hazardous chemicals used by the Underground Division is known by all affected employees. Under this plan, you will be informed of the contents of the OSHA Hazard Communications standard, the hazardous properties of chemicals with which you work, and safe handling procedures, safe storage, and measures to take to protect yourself from these chemicals. This plan assumes that all employees understand and speak the English language.

This plan applies to all work operations in our company where you may be exposed to hazardous chemicals under normal working conditions or during an emergency situation. All work units of this company will participate in this Hazard Communication Plan.1

The McMillen Jacobs Associates Environmental Health and Safety Director (Safety Director) is the plan coordinator, with overall responsibility for it, including reviewing and updating this plan as necessary. Locally, the office manager, resident engineer, construction manager, or field superintendent at each office and worksite is responsible for implementation of the plan, and is referred to herein as the Site Coordinator. These Site Coordinators are responsible for documenting the training received by their employees, and reporting the names of these individuals to the Safety Director for record-keeping purposes.

2.0 Authority In the United States, hazard communication is regulated by 29 CFR 1910.1200 and multiple state-specific safety regulations. In Canada, Australia, and New Zealand, each country, state, and province have similar but specific safety regulations for hazard communication. See Section 9.0 for a list of relevant references.

1 The Hazard Communication Plan is Appendix D of the McMillen Jacobs Associates Underground Division’s Safety Policy Manual. The plan is available in the common areas of each office/worksite for review by any interested employee and on the company’s intranet site.



The federal OSHA and state OSHA agencies are able to levy fines against both an employee and the company if they find that the employee has not been adequately trained, and/or does not possess the proper knowledge regarding hazard communication.

3.0 Container Labeling Each Site Coordinator will verify that all containers received for use are clearly labeled as to the contents, include the appropriate hazard warning, and list the manufacturer’s name and address.

The Site Coordinators will also ensure that all secondary containers (any container other than the original, labeled container, such as a beaker or bottle) are labeled with either an extra copy of the original manufacturer’s label or with labels marked with the identity and the appropriate hazard warning. Care shall be taken to ensure that all labels are neither defaced nor removed from either primary or secondary containers. Site Coordinators will instruct all workers in this practice and assist with procedures if labels are defaced or removed. For further labeling assistance, contact the McMillen Jacobs Associates Safety Director.

4.0 Safety Data Sheets The Safety Director is responsible for monitoring and revising the company Hazard Communication Plan, including the Safety Data Sheets (SDSs). The Safety Director will ensure that procedures are developed so that each site obtains the necessary SDSs. Each Site Coordinator will review incoming SDSs for new or significant health and safety information. The Site Coordinator will see that any new information is communicated to all affected employees. If an SDS is not received at the time of initial shipment, the Site Coordinator is responsible for obtaining the SDS, either online or by contacting the manufacturer of the chemical.

Copies of SDSs for all hazardous chemicals to which employees are exposed or could be exposed will be kept in a common area of each office and worksite (SDS binder). Each Site Coordinator is responsible for ensuring that each worker in the office or worksite is informed of the location of the SDS binder containing this information.

SDSs will be readily available to all employees during each work shift. If an SDS is not available, employees can contact the Site Coordinator, who will find a copy and place it in the binder.

The SDS binder shall be kept current. When revised SDSs are received, the Site Coordinator will replace the old SDS in the SDS binder with the new one.

5.0 Employee Training and Information The Safety Director will ensure that all elements of the Hazard Communication Plan are carried out. The Site Coordinators are responsible for ensuring that the plan elements are carried out at the individual work sites.



Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training on the hazard communication standard and this plan before starting work. Each new employee will attend a health and safety orientation that includes the following information and training:

An overview of the OSHA hazard communication standard

The hazardous chemicals present at his/her work area and their locations

The physical and health risks of the hazardous chemicals

Symptoms of overexposure

How to determine the presence or release of hazardous chemicals in the work area

How to reduce or prevent exposure to hazardous chemicals through use of control procedures, work practices, and personal protective equipment

Cleanup procedures in the event of a chemical spill or leak, and protective measures to be taken during cleanup

Steps the company has taken to reduce or prevent exposure to hazardous chemicals

Procedures to follow if employees are overexposed to hazardous chemicals

How to read labels and SDSs to obtain hazard information

Location of the SDS binder and written Hazard Communication program

Prior to introducing a new chemical hazard into any company office or worksite, the Site Coordinator will provide each employee in that location with information and training.

6.0 Hazardous Nonroutine Tasks Periodically, employees are required to perform nonroutine tasks that are hazardous. Prior to starting work on such projects, each affected employee will be given information and training by the Site Coordinator, project manager, or other competent person about the hazardous chemicals he or she may encounter during such activity. This information will include specific chemical hazards, protective and safety measures the employee should use, and steps the company is taking to reduce the hazards.

7.0 Other Employers/Contractors It is the responsibility of the Site Coordinator to provide other employers and contractors with information about hazardous chemicals that their employees may be exposed to at an Underground Division office or worksite and suggested precautions for employees.

Underground Division employees sometimes work at sites maintained by other employers. It is the responsibility of each employee working at these locations to obtain safety information, including information about hazardous chemicals, from the managing employer at these sites. If an employee is unable to obtain safety information at a site managed by another employer, the employee can contact the McMillen Jacobs Associates Safety Director for assistance.



8.0 List of Hazardous Chemicals A list of all known hazardous chemicals used by our employees is maintained by each Site Coordinator and is available in the SDS Binder at each company office and worksite. This list includes the name of the chemical, the manufacturer, the work area in which the chemical is used, dates of use, and quantity used. Further information on each chemical may be obtained from the SDSs, also located in the SDS Binder.

When new chemicals are received, this list is updated (including the date the chemicals were introduced) within 30 days. It is the responsibility of the Site Coordinator to ensure that any new chemical is to the list added in a timely manner.

8.1 Proposition 65 List of Chemicals (only for California offices)

The Site Coordinator is responsible for obtaining updates of Proposition 65–listed chemicals and providing new information to affected employees. In the case of newly added chemicals to the Proposition 65 list, the necessary warning will take effect 12 months from the date of listing.

9.0 References United States Code of Federal Regulations, Title 29, Standard 1910.1200:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099

Each State: Refer to specific state regulations as required.

Canada Environmental and Workplace Health:

https://www.canada.ca/en/health-canada/services/environmental-workplace-health.html

Australia Safe Work Australia:

http://www.safeworkaustralia.gov.au/sites/swa/model-whs-laws/model-whs-regulations/pages/regulations

New Zealand and Other Countries United Nations Economic Commission for Europe (UNECE): GHS Implementation:

http://www.unece.org/trans/danger/publi/ghs/implementation_e.html

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099

https://www.canada.ca/en/health-canada/services/environmental-workplace-health.html

http://www.safeworkaustralia.gov.au/sites/swa/model-whs-laws/model-whs-regulations/pages/regulations

http://www.unece.org/trans/danger/publi/ghs/implementation_e.html



Appendix E Fall Protection and Rope Access Work Safety Plan


Fall Protection and Rope Access Work

Safety Plan

January 2020

Underground Division Safety Policy Manual Fall Protection & Rope Access Work Safety Plan


Table of Contents 1.0 Objective ............................................................................................................................................ 1

2.0 Policy ................................................................................................................................................. 1

3.0 Definitions .......................................................................................................................................... 1

4.0 Assignment of Responsibility ............................................................................................................. 6

4.1 Employer ................................................................................................................................ 6

4.2 Plan Manager ......................................................................................................................... 6

4.3 Employees .............................................................................................................................. 6

5.0 Training .............................................................................................................................................. 6

6.0 Controlled Access Zones and No Access Zones .............................................................................. 7

7.0 Excavations ....................................................................................................................................... 8

8.0 Rope Access Work ............................................................................................................................ 8

8.1 Basic Requirements ............................................................................................................... 8

8.2 Rock Access Work Training Requirements ............................................................................ 9

8.3 High Angle Slope or Structure Inspections .......................................................................... 10 8.3.1 Slope Inspections (General) .................................................................................... 10

8.3.2 Single Rope Slope Inspections ............................................................................... 10

8.3.3 Two-Rope Slope Inspections .................................................................................. 11

8.3.4 Two-Rope Structure Inspections ............................................................................. 11

9.0 Fall Protection Systems ................................................................................................................... 11

9.1 Covers .................................................................................................................................. 11

9.2 Guardrail Systems ................................................................................................................ 12

9.3 Personal Fall Arrest Systems (PFAs) ................................................................................... 12

9.4 Positioning Device Systems ................................................................................................. 13

9.5 Safety Monitoring Systems................................................................................................... 14

9.6 Safety Net Systems .............................................................................................................. 14

9.7 Warning Line Systems ......................................................................................................... 14

10.0 Tasks and Work Areas Requiring Protection................................................................................... 15

10.1 Framework and Reinforcing Steel ........................................................................................ 15

10.2 Hoist Areas ........................................................................................................................... 15

10.3 Holes .................................................................................................................................... 15



10.4 Leading Edges ..................................................................................................................... 15

10.5 Overhand Bricklaying and Related Work ............................................................................. 15

10.6 Precast Concrete Erection ................................................................................................... 16

10.7 Roofing ................................................................................................................................. 16 10.7.1 Low-Slope Roofs ..................................................................................................... 16

10.7.2 Steep Roofs ............................................................................................................. 16

10.8 Wall Openings ...................................................................................................................... 16

10.9 Ramps, Runways, and Other Walkways .............................................................................. 17

11.0 Protection from Falling Objects ....................................................................................................... 17

12.0 Accident Investigation ...................................................................................................................... 17

13.0 Rescue ............................................................................................................................................. 17

14.0 Changes to the Plan ........................................................................................................................ 18

List of Tables Table 1. Recommended Minimum Requirements for Rope Access Work. .................................................. 8

Attachments Attachment A Project Fall Protection Plan (EXAMPLE)

Attachment B Rope Access Job Safety Analysis (Single Rope)

Attachment C Rope Access Job Safety Analysis (Two-Rope)

Attachment D Rope Access Job Safety Analysis (Dams and Structures)

Attachment E Slope Access Safety Evaluation (SASE)

Attachment F Rock Climbing and Limited Rope Access Training Course (EXAMPLE)

Attachment G Rope Access Training (EXAMPLE)



Distribution To: Employees McMillen Jacobs Associates Underground Division Office Managers McMillen Jacobs Associates Underground Division From: Dan Adams McMillen Jacobs Associates Revised By: Bill Mitchell, Environmental Health and Safety Director McMillen Jacobs Associates Safety Committee: Ted DePooter, Sarah Wilson McMillen Jacobs Associates Underground Division Rope Access Safety Group: William Gates, Dale Moore McMillen Jacobs Associates Underground Division Reviewed By: Carol Ravano, Julie McCullough McMillen Jacobs Associates Underground Division

Revision Log Revision No. Date Reviewed By

2 January 2020 Bill Mitchell, Ted Depooter, Sarah Wilson, William Gates, Dale Moore

1 April 2018 William Gates, Dale Moore (Rope Access Work) 0 August 2017 Bill Mitchell, Ted Depooter (First Issuance)



1.0 Objective The objective of the McMillen Jacobs Associates Underground Division Fall Protection and Rope Access Work Safety Plan1 is twofold:

1. To identify and evaluate fall hazards to which employees will be exposed and to provide specific training to those exposed to a fall hazard, as required by the Occupational Safety and Health Administration (OSHA) Fall Protection Standard, 29 CFR 1926, Subpart M.

2. To provide the basic requirements of rope access work for difficult-to-access sites with fall hazards; the levels of training needed; and the types of inspection work that necessitate such preparation.

2.0 Policy It is the Underground Division’s policy to protect its employees from occupational injuries by implementing and enforcing safe work practices and appointing competent person(s) to manage the Fall Protection Plan. The Underground Division Fall Protection and Rope Access Work Safety Plan shall comply with OSHA requirements (see Attachment A for an example of a Project Fall Protection Plan for use on Underground Division projects). A copy of the OSHA Fall Protection Standard shall be made available to all employees, and may be obtained from the Underground Division competent person on-site.

3.0 Definitions Anchorage: A secure point of attachment for lifelines, lanyards, or deceleration devices.

Access Zone: The area in which people are at risk of falling. (e.g., while on rope or close to a vertical drop of more than 6 feet).

Anchor: A fixed attachment point, or series of points, on a structure that supports the rope systems and other connections to personnel. A critical anchor is an anchor in which failure would result in serious consequences to the safety of the climber or integrity of the system.

Belay: A method or system used to manage the slack in the safety rope, which provides fall protection to a rope access operative in the event of a fall or failure in the main support system.

1 The Fall Protection and Rope Access Work Safety Plan is Appendix E of the McMillen Jacobs Associates Underground Division’s Safety Policy Manual. The plan is available in the common areas of each office/worksite for review by any interested employee and on the company’s intranet site.



Body harness: Straps that may be secured about the person in a manner that distributes the fall-arrest forces over at least the thighs, pelvis, waist, chest, and shoulders with a means for attaching the harness to other components of a personal fall arrest system.

Brow: The top of a slope where rope access technicians typically access a rope access project and where anchors are constructed for rappelling.

Competent Person (Rope Access): An employee who can demonstrate training in Level II slope access techniques or better from a recognized training program; and who can identify inherent geologic hazards associated with the slope.

Competent Person (Construction Fall Protection): An individual who can identify fall hazards associated with the job and identify solutions to fall protection, arrest, restraint, and prevention.

Connector: A device that is used to couple (connect) parts of a personal fall arrest system or positioning device system together.

Controlled Access Zone: A work area designated and clearly marked in which certain types of work overhead may take place without the use of conventional systems to protect the employees working in the zone. Area below is either controlled access or no access during and after tasks are performed.

Deceleration Device: Any mechanism—such as a rope-grab, rip-stitch lanyard, specially woven lanyard, tearing or deforming lanyards, and automatic self-retracting lifelines/lanyards—which serves to dissipate a substantial amount of energy during a fall arrest, or otherwise limits the energy imposed on an employee during fall arrest.

Deceleration Distance: The additional vertical distance a falling person travels, excluding lifeline elongation and free fall distance, before stopping, from the point at which a deceleration device begins to operate.

Edge Protection: Rope access equipment that mitigates the risk of sharp edge contact with ropes used in rope access work.

Fall Arrest: A system designed to stop a person already falling with a safe stop so as to prevent injury.

Fall Protection: A term used generally to describe any system designed to prevent personnel from falling or sustaining an injury resulting from a fall.

Fall Restraint: A system designed to prevent a person in a fall hazard area, from falling by either wearing fall restraint equipment (e.g. fall restraint lanyards) or Restraint systems in place (e.g., guard rails).

Guardrail System: A barrier erected to prevent employees from falling to lower levels or to prevent entry to certain areas.



Hole: A void or gap 2 inches (50 mm) or more in the least dimension in a floor, roof, or other walking/working surface.

High Angle Inspection: An inspection or project-related work requiring rope access techniques to safely complete the inspection.

Job Hazard Analysis: A written evaluation produced by the Rope Access Technician of the hazards likely to be encountered while performing a work project, and how those hazards are best mitigated by planning, precautions, equipment use, and PPE. The document will describe how a particular job or series of jobs will be performed to minimize the risks to the safety of workers and public.

Job Safety Analysis (JSA): An official document used to evaluate the hazards associated with a rope access project scenario. A JSA must be completed for each individual project, or as project conditions change.

Lanyard: A flexible line of rope, wire rope, or strap that generally has a connector at each end for connecting the body harness to a deceleration device, lifeline, or anchorage.

Leading Edge: The edge of a floor, roof, or formwork for a floor or other walking/working surface (such as a deck) that changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed.

Level 1 Rope Access Technician: An employee who has the following minimum skill level in rope access training:

Working knowledge of climbing knots, anchors, rope handling, belaying techniques, and self-rescue techniques

Working knowledge of anchor suitability and construction for rappelling

Working knowledge of rappelling and ascending techniques

Demonstrated safe working practices.


Working knowledge and ability to function as a Level 1 rope access technician

Ability to assess the quality and suitability of anchors for a work crew

Ability to execute a rescue with a victim in descent

Ability to participate in a rescue where the victim is pulled to safety from above


Working knowledge and ability to function as a Level 1 or a Level 2 rope access technician



Ability to manage all aspects of a complicated rope access project, including challenging access, sharp edges, multiple ropes, and no access from the base of the slope or work area

Ability to supervise and proficiently execute victim rescues in any circumstance

Trained in advanced first aid

Ability to recognize abilities of personnel in order to properly staff a project.

Lifeline: A component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), that serves as a means for connecting other components of a personal fall arrest system or restraint system to an anchorage.

Low Slope Roof: A roof having a slope less than or equal to 4 inches of vertical rise for every 12 inches of horizontal length (4:12) (100 mm vertical for every 305 mm horizontal).

Opening: A gap or void 30 inches (760 mm) or higher and 18 inches (460 mm) or wider in a wall or partition, through which employees can fall to a lower level.

Personal Fall Arrest System: A system including but not limited to an anchorage, connectors, and a body harness used to restrain or arrest an employee in a fall from a working level.

Positioning Device System: A body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning backwards. Used as positioning only.

Rescue: The act of moving injured or incapacitated worker(s) from the Access Zone to an area where more definitive medical care can be administered.

Rescue Plan: A clear and simple approach to rescue of a suspended worker following a fall arrest event or other rope access complication (injury, gear malfunction, etc.) All workers should be familiar with the rescue plan and competent to implement it. The rescue plan should be discussed during the JSA.

Rope Access Technician: An employee trained in rope access safety work, and who possesses a working knowledge of climbing knots, belaying techniques, rappelling and ascending techniques, and anchor suitability and construction.

Rope Access Work: Any work where access to the site is difficult and where potentially fatal fall hazards exist.

Rope Grab: A deceleration device that automatically travels by friction on a lifeline, engages the lifeline, and locks to restrain or arrest a fall.

Rope Damaging Hazard: Any physical hazard or condition that poses a risk of damaging a rope used in a rope access project.



Safety Monitoring System: A controlled access zone and safety system in which a competent person is responsible for recognizing and warning employees through direct voice contact of fall hazards in this exclusive zone.

Self-Retracting Lifeline/Lanyard: A deceleration device containing a drum-wound line that can be slowly extracted from, or retracted onto, the drum under minimal tension during normal employee movement and that, after onset of a fall, automatically locks the drum and arrests the fall.

Slope Access Safety Evaluation (SASE): The purpose of the SASE form is to produce an initial record of the slope conditions by a competent person (see above for definition of competent person). An SASE competent person is a senior engineering geologist or geotechnical engineer who can identify the inherent geologic hazards and safety issues on the slope. In addition, the competent person can demonstrate recent certification in Level 2-Slope Access techniques (or better) from a recognized training program such as the Underground Division’s Rope Access Safety Training.

Snaphook: A connector consisting of a hook-shaped member with a normally closed keeper, or a similar arrangement, that may be opened to permit the hook to receive an object and, when released automatically, closes to retain the object.

Steep Roof: A roof having a slope greater than 4 inches of vertical rise for every 12 inches of horizontal length (4:12) (100 mm vertical for every 305 mm horizontal).

Toeboard: A low floor level protective barrier that prevents material and equipment from falling to lower levels and that protects personnel from falling objects.

Unprotected Sides and Edges: Any side or edge (except at entrances to points of access) of a walking/working surface (e.g., floor, roof, ramp, or runway) where there is no wall or guardrail system at least 42 inches (1,065 mm) high (plus or minus 3 inches [75 mm] allowed).

Walking/Working Surface: Any surface, whether horizontal or vertical, on which an employee walks or works, including but not limited to floors, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel. Does not include ladders, vehicles, or trailers on which employees must be located to perform their work duties.

Warning Line System: A barrier designed and erected on a roof by a Competent Person to warn employees that they are approaching an unprotected roof side or edge and that designates an area in which roofing work may take place without the use of guardrail, body harness, or safety net systems to protect employees in the area.



4.0 Assignment of Responsibility 4.1 Employer It is the responsibility of the Underground Division to provide fall protection and rope access work training and equipment to affected employees, and to ensure that all employees understand and adhere to the procedures of this plan and follow the instructions of the Underground Division competent person.

4.2 Plan Manager The Fall Protection & Rope Access Safety Plan Manager is the Underground Division competent person who implements this plan. That person’s responsibilities are:

3. Performing routine safety checks of work operations;

4. Enforcing Underground Division safety policy and procedures;

5. Correcting any unsafe practices or conditions immediately;

6. Training employees and supervisors in recognizing fall hazards and the use of fall protection systems;

7. Maintaining records of employee training, equipment issue, and fall protection systems used at Underground Division jobsites; and

8. Investigating and documenting all incidents that result in employee injury.

4.3 Employees All employees have the following responsibilities:

1. Read, ask questions about, understand, and adhere to the procedures outlined in this Fall Protection & Rope Access Safety Plan;

2. Follow the instructions of the Underground Division competent person on-site;

3. Bring to management’s attention any unsafe or hazardous conditions or practices that may cause injury to either themselves or any other employees; and

4. Report any incident that causes injury to an employee, regardless of the nature of the injury as quickly as possible.

5.0 Training All Underground Division employees who may be exposed to fall hazards or who work at difficult-to-access sites are required to receive training in how to recognize such hazards, how to minimize their exposure to them, and how to safely access the work sites. Employees shall receive training as soon after initial employment as possible, and must receive training before they are required to work in areas with difficult access or where fall hazards exist. Employees will be retrained if deficiencies in training or deficiencies in employee practices pertaining to fall protection are noticed; if any changes to the



workplace are noticed; or if systems or equipment are changed that render any previous training obsolete. Normally scheduled retraining and review will occur annually.

A documented record of employees who have received training and their training dates shall be maintained by the senior Underground Division employee on-site and a copy sent to the Underground Division Human Resources Manager for logging into the division training record. Training of employees by the Underground Division competent person on-site shall include:

1. Nature of fall hazards employees may be exposed to;

2. Correct procedures for erecting, maintaining, disassembling, and inspecting fall protection systems;

3. Use and operation of controlled access zone, guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems;

4. Role of each employee in the Safety Monitoring System (if one is used);

5. Limitations on the use of mechanical equipment during roofing work on low-slope roofs (if applicable);

6. Correct procedures for equipment and materials handling, and storage and erection of overhead protection;

7. Role of each employee in alternative Fall Protection Plans (if used);

8. Requirements of the OSHA Fall Protection Standard, 29 CFR 1926, Subpart M; and

9. Underground Division requirements for reporting incidents that cause injury to an employee.

6.0 Controlled Access Zones and No Access Zones These zones are identified by signage and delineation as “Controlled Access Zone,” or “No Access Zone.” Only authorized employees are permitted to enter Controlled Access Zones and areas from which guardrails have been removed. All other workers are prohibited from entering Controlled Access Zones. All employees are prohibited from entering No Access Zones.

Controlled Access Zones and No Access Zones shall be defined by signage and by control lines consisting of ropes, wires, tapes, or equivalent material, with supporting stanchions. These zones shall be:

1. Flagged with a high-visibility material at 6-foot (1.8 m) intervals.

2. Rigged and supported so that the line is between 39 (990 mm) and 50 inches (1,270 mm), including sag from the walking/working surface.

3. Strong enough to sustain stress of at least 200 pounds (90 kg).

4. Extended along the entire length of an unprotected or leading edge.

5. Parallel to the unprotected or leading edge.

6. Connected on each side to a guardrail system or wall.



7. Erected between 6 feet and 25 feet (1.8 m and 7.6 m) from an unprotected edge, except in the following cases:

a. When working with precast concrete members between 6 feet and 60 feet (1.8 m and 18.3 m), or half the length of the member being erected, whichever is less, from the leading edge; or

b. When performing overhand bricking and related work between 10 feet and 15 feet (3.0 m and 4.6 m) from the working edge.

7.0 Excavations Fall protection will be provided to employees working at the edge of an excavation that is 6 feet or deeper. Underground Division employees in these areas are required to use the fall protection systems as designated in their fall protection plan.

1. Excavations that are 6 feet or deeper shall be protected by guardrail systems, fences, barricades, or covers.

2. Walkways that allow employees to cross over an excavation that is 6 feet or deeper shall be equipped with guardrails.

8.0 Rope Access Work 8.1 Basic Requirements Rope access work consists of project work that requires rope access techniques to access a site and complete the work. Rope access techniques are typically necessary for rock slope, bridge, and dam inspections, where access to the site is difficult and includes falling hazards that can lead to fatal injuries.

When project work requires rope access techniques, specialty training and fitness levels are required. An employee assigned to rope access–related work, whether it be inspecting rock slopes or structures, must complete an annual training or refresher course to ensure competency in rope access techniques.

Employees assigned to rope access projects must have a minimum level of conditioning to participate in the work. Additionally, mental aptitude and awareness of physical limitations must be considered before participation in rope access work is granted. Table 1 below summarizes the minimal mental and physical requirements for rope access work, as well as additional recommended employee criteria for rope access work.

Table 1. Recommended Minimum Requirements for Rope Access Work. Mental Physical Limitations/Concerns

• Ability to work in a harness and at height

• Healthy respect for heights • Consistent safety attitude

o Willingness to learn and improve

• Capable of working in climatic extremes

• Ability to work while suspended in harness for extended periods of time

• Good strength-to-weight ratio

• Heart disease or hypertension • Epilepsy, seizures, or blackouts • Dizziness or impaired balance • Severe allergic reaction to insect

bites (anaphylactic shock) • Brittle or uncontrolled diabetes



Mental Physical Limitations/Concerns o Team orientation

• Ability to perform physically and mentally demanding work under adverse conditions

• Ability to analyze and solve unforeseen changes in rope work plans

o Body weight: 220 lb (99.8 kg) max for individual 6 ft tall (1.8 m)

o Ability to climb, lift, and hold body weight

• Ability to lift and carry heavy objects o 55 lb for 165 ft (25 kg for 50

m) o Average to good cardio

fitness o Climb 50 stairs without

physical distress or prolonged elevated heart rate (Reference: Harvard Step Test)

• Healthy joints and full function of extremities (especially hands)

• Capable of completing o 1 Chin up o 20 Sit ups

• Peripheral Vascular Disease (poor blood circulation to extremities)

• Bleeding disorders • Medication that affects

alertness, balance, judgment, or vision

• Psychiatric Illness • Extreme sunlight sensitivity • Severe tendonitis or arthritis • Severe back, neck, or shoulder

problems • Severe hearing loss • Body size/weight • Extreme fear of heights

It should be noted that some rope access jobs may require a much higher level of fitness to complete. For this reason, the Level 3 technician supervising the work has the discretion to select rope access team members who are qualified, and have the necessary level of physical fitness to meet the demands of the project.

8.2 Rock Access Work Training Requirements In addition to the safety training discussed in Section 5.0 for fall hazards and difficult-to-access sites, employees participating in rope access work must have completed a rope access work training / refresher course within 6 months of the beginning of the project. This ensures the employee will have the minimum competency level required for rope access–related work. The Underground Division provides three levels of rope access certification. Typically, a rope access project requires that one individual be a Level 3 rope access technician, and one or more employees have at least a Level 1 certification to partner in the work. The minimum skill requirements for Level 1 through Level 3 rope access technicians are described below.

Level 1:

° Working knowledge of climbing knots, anchors, rope handling, belaying techniques, and self-rescue techniques

° Working knowledge of anchor suitability and construction for rappelling

° Working knowledge of rappelling and ascending techniques

° Demonstrated safe working practices.

Level 2:

° Working knowledge and ability to function as a Level 1 rope access technician



° Ability to assess the quality and suitability of anchors for a work crew

° Ability to execute a rescue with a victim in descent

° Ability to participate in a rescue where the victim is pulled to safety from above

Level 3:

° Working knowledge and ability to function as a Level 1 or a Level 2 rope access technician

° Ability to manage all aspects of a complicated rope access project, including challenging access, sharp edges, multiple ropes, and no access from the base of the slope or work area

° Ability to supervise and proficiently execute victim rescues in any circumstance

° Trained in advanced first aid

° Ability to recognize abilities of personnel in order to properly staff a project.

8.3 High Angle Slope or Structure Inspections When the employee must access a slope or structure (dam, bridge, etc.) to complete project-related work, the requirements in Sections 8.1 and 8.2 must be met before the project begins. Slope inspections are typically initiated after a rock fall or slope failure event or when project design work requires a detailed understanding of the geologic conditions of an area. Structure inspections are periodically required to verify that important components are in safe working condition. Because the nature of high angle inspection work is hazardous, and each project has new and unique hazards requiring a case-by-case assessment, a Job Safety Analysis (JSA) shall be completed before beginning work on any new high angle slope or structure inspection.

8.3.1 Slope Inspections (General)

Slope inspections are necessary when soil or rock instability creates hazards to public or business infrastructure or personnel, or when design work requires such inspections. The work environment can be hazardous and unstable. For this reason, it is necessary to evaluate the hazards expected during the work before beginning a slope inspection. For slope inspections, the Underground Division has two Job Safety Analyses (Attachment B and Attachment C), one for single rope scenarios and one for situations where two ropes are necessary. In addition to completing a JSA, the employee must complete a Slope Access Safety Evaluation (SASE) (Attachment E) before beginning the work.

8.3.2 Single Rope Slope Inspections

A slope inspection may be completed with a single rope when the following conditions exist.

The brow of the slope contains no sharp edges, or sharp edges are easily mitigated with typical edge protection.

Performing this work on-slope, while generally maintaining feet in contact with the slope.

Limited lateral movement (up to 20 feet [6 m] each side of the fall line) is required when the employee is on the slope.

Limited rope damaging hazards are expected on the slope.



The Level 3 rope access technician overseeing the work shall determine if a single rope is acceptable for the slope conditions, and shall lead the Single Rope JSA (Attachment B) and supervise the completion of the SASE (Attachment E) before beginning the work.

8.3.3 Two-Rope Slope Inspections

A slope inspection requiring two ropes to access may be required when the following conditions exist.

The brow of the slope has numerous rope-damaging sharp edges requiring that multiple edge protection measures be deployed.

Slope conditions may damage the rope while the employee is completing the work.

Slope has multiple overhangs such that performing this work on-slope, while maintaining feet on the ground is difficult or more dangerous.

Extensive lateral movement (> 20 feet each side of the fall line) is required to complete the work, and this movement could damage the rope.

The client requires two-rope access certification.

The Level 3 rope access technician overseeing the work shall determine if a two-rope system is required for the slope conditions, and shall lead the Two-Rope JSA (Attachment C) and supervise the completion of the SASE (Attachment E) before beginning the work.

8.3.4 Two-Rope Structure Inspections

Inspections of structures—including bridges, dams, and other man-made buildings pose—a unique challenge to rope access technicians. Typically, anchors have sharp edges and are man-made, requiring a working knowledge of anchor-bearing capacity and suitability as an anchor for rappelling. Additionally, the edges that the rope contacts during the work are typically angled and pose a legitimate risk of cutting the rope. For these reasons, a two-rope access system is required to safely complete structure inspection–related work.

The Level 3 rope access technician overseeing the work shall have a working knowledge of hazards typical of structure inspections with rope access techniques. A Two-Rope JSA for dams and structures (Attachment D) shall be led by the Level 3 rope access technician responsible for the work before project work begins.

9.0 Fall Protection Systems 9.1 Covers

1. All covers shall be secured to prevent accidental displacement.

2. Covers shall be color-coded or bear the markings “HOLE” or “COVER.”

3. Covers located in roadways shall be able to support twice the axle load of the largest vehicle that might cross them.



4. Covers shall be able to support twice the weight of employees, equipment, and materials that might cross them.

9.2 Guardrail Systems Guardrail systems shall be erected at unprotected edges, ramps, runways, or holes where it is determined by the Underground Division competent person on site that erecting such systems will not cause an increased hazard to employees. The following specifications will be followed in the erection of guardrail systems. Toprails shall be:

1. At least 2 inches by 4 inches (51 x 102 mm) for wood using qualifying required stress grade construction lumber, see 29 CFR 1926 Sub M App. (B) (use of all banding materials is unacceptable);

2. Flagged every 6 feet (1.8 m) or less with a high visibility material if wire rope is used;

3. Inspected by the Underground Division competent person on site as frequently as necessary to ensure strength and stability;

4. Forty-two (42) inches (1,065 mm), plus or minus 3 inches (75 mm), above the walking/working level; and

5. Adjusted to accommodate the height of the stilts, if they are in use.

Midrails, screens, mesh, intermediate vertical members, and solid panels shall be erected in accordance with the OSHA Fall Protection Standard. Midrail requirements can be the same as toprail requirements for type used and specifications. Height for installation of midrail is one-half as high as toprail (for example: 42-inch toprail = midrail at 21 inches). Midrail materials must withstand at least 150 pounds (68 kg) of outward and downward force. Panels of screen, mesh, or solid panels must withstand at least the same amount of force.

To prevent access, gates or removable guardrail sections shall be placed across openings of hoisting areas or holes when they are not in use.

9.3 Personal Fall Arrest Systems (PFAs) Personal fall arrest systems shall be issued to and used by employees as determined by the Underground Division competent person on site and may consist of anchorage, connectors, body harness, deceleration device, lifeline, or suitable combinations. PFAs shall:

1. Limit the maximum arresting force to 1,800 pounds (817 kg);

2. Be rigged so an employee cannot free fall more than 6 feet (1.8 m) or contact any lower level;

3. Bring an employee to a complete stop and limit the maximum deceleration distance traveled to 3.5 feet (1.1 m);

4. Be strong enough to withstand twice the potential impact energy of foreseeable force of an employee free falling 6 feet (or the free fall distance permitted by the system, whichever is less);

5. Be inspected prior to each use for damage and deterioration; and

6. Be immediately removed from service if any damaged components are detected.



All components of a fall arrest system shall meet the specifications of the OSHA Fall Protection Standard, and shall be used in accordance with manufacturer’s instructions.

1. The use of nonlocking snaphooks is prohibited.

2. D-rings and locking snaphooks shall:

a. Have a minimum tensile strength of 5,000 pounds (2,268 kg); and

b. Be proof-tested to a minimum tensile load of 3,600 pounds (1,633 kg) without cracking, breaking, or suffering permanent deformation.

3. Lifelines and their systems shall be:

a. Installed and used under the supervision of the Underground Division competent or qualified person;

b. Designed, manufactured, purchased by approved Underground Division competent person and appropriate qualified person;

c. Protected against cuts and abrasions; and

d. Equipped with horizontal lifeline connection devices capable of locking in both directions on the lifeline when used on all work platforms that have horizontal lifelines that may become vertical lifelines.

4. Self-retracting lifelines and lanyards must have ropes and straps (webbing) made of synthetic fibers, and in some cases steel and shall:

a. Sustain a minimum tensile load of 3,600 pounds (1,633 kg) and limit free fall distance to 2 feet (0.6 m); or

b. Sustain a minimum tensile load of 5,000 pounds (2,268 kg), includes ripstitch, tearing, and deforming lanyards).

5. Anchorages must support at least 5,000 pounds per person attached and shall be:

a. Installed and used under the supervision of the Underground Division competent or qualified person;

b. Designed, manufactured, and purchased by approved Underground Division competent person or appropriate qualified person;

c. Capable of supporting at least twice the weight expected to be imposed on it; and

d. Independent of any anchorage in use to support or suspend platforms.

9.4 Positioning Device Systems Body harness systems shall be worn with a positioning device and shall be designed so that an employee can free fall no farther than 2 feet (0.6 m) and be anchored to approved design or be able to sustain a shock load of 5,000 pounds. Positioning device worn with PFAS shall be anchored to a separate supporting anchor device that can support twice the expected load, or 3,000 pounds, whichever is greater.



9.5 Safety Monitoring Systems In situations where no other fall protection can be implemented by the Underground Division qualified person, a designated Underground Division employee shall monitor the safety of employees in these work areas. The designated employee on-site shall be:

1. Competent in the recognition of fall hazards;

2. Capable of warning workers through direct voice of fall hazard dangers;

3. Operating on the same walking/working surfaces as the employees and able to see them;

4. Close enough to work operations to communicate orally with employees; and

5. Free of other job duties that as they can distract from the monitoring function.

No employees other than those engaged in the work being performed under the Safety Monitoring System shall be allowed in the area. All employees under a Safety Monitoring System are required to promptly comply with the fall hazard warnings of the designated employee.

9.6 Safety Net Systems 1. Safety net systems must be installed no more than 30 feet (9 m) below the walking/working

surface with sufficient clearance to prevent contact with the surface below, and shall be installed with sufficient vertical and horizontal distances as described in the OSHA Fall Protection Standard.

2. All nets shall be inspected at least once a week for wear, damage, or deterioration by a competent person. Defective nets shall be removed from use and replaced with acceptable nets.

3. All nets shall be in compliance with mesh, mesh crossing, border rope, and connection specifications as described in the OSHA Fall Protection Standard.

4. When nets are used on bridges, the potential fall area from the walking/working surface shall remain unobstructed.

5. Objects that have fallen into safety nets shall be removed as soon as possible, and at least before the next working shift.

9.7 Warning Line Systems Warning line systems consisting of supporting sanctions and ropes, wires, or chains shall be erected around all sides of roof work areas.

1. Lines shall be flagged at no more than 6-foot intervals with high-visibility materials.

2. The lowest point of the line (including sag) shall be between 34 and 39 inches (865 and 990 mm) from the walking/working surface.

3. Sections of warning line systems shall be capable of resisting at least 16 pounds (7.3 kg) of force.

4. Ropes, wires, or chains must have a minimum tensile strength of 500 pounds (227 kg).

5. Warning line systems shall be erected at least 6 feet from the edge, except in areas where mechanical equipment is in use. When mechanical equipment is in use, warning line systems



shall be erected at least 6 feet from the parallel edge and at least 10 feet (3 m) from the perpendicular edge.

10.0 Tasks and Work Areas Requiring Protection Unless otherwise specified, the Underground Division competent person on-site shall evaluate the worksite(s) and determine the specific type(s) of fall protection to be used in the following situations.

10.1 Framework and Reinforcing Steel Fall protection will be provided when an employee is exposed to an edge, is climbing, or is moving at a height of over 6 feet (1.8 m).

10.2 Hoist Areas Guardrail systems or personal fall arrest systems will be used in hoist areas when an employee may fall 6 feet or more. If guardrail systems must be removed for hoisting, employees are required to use a personal fall arrest system.

10.3 Holes Covers or guardrail systems shall be erected around holes (including skylights) that are 6 feet or more above lower levels. If covers or guardrail systems must be removed, employees are required to use a personal fall arrest system.

10.4 Leading Edges Guardrail systems, safety net systems, or personal fall arrest systems shall be used when employees are exposed to or constructing a leading edge that is 6 feet or more above lower levels. An alternative Fall Protection Plan shall be used if the Underground Division competent person on-site determines that the implementation of conventional fall protection systems is infeasible or creates a greater hazard to employees. All alternative Fall Protection Plans for work on leading edges shall:

1. Be written specific to the particular jobsite needs;

2. Include an explanation of how conventional fall protection is infeasible or creates a greater hazard to employees;

3. Explain what alternative fall protection will be used for each task;

4. Be maintained in writing at the jobsite by the Underground Division competent person;

5. Be sent to Underground Division Rope Access Safety Group; and

6. Meet the requirements of 29 CFR 1926.502(k).

10.5 Overhand Bricklaying and Related Work Guardrail systems, safety net systems, personal fall arrest systems, or controlled access zones shall be provided to employees engaged in overhead bricklaying or related work 6 feet or more above the lower



level. All employees reaching more than 10 inches (255 mm) below the walking/working surface shall be protected by a guardrail system, safety net system, or personal fall arrest system.

10.6 Precast Concrete Erection Guardrail systems, safety net systems, or personal fall arrest systems shall be provided to employees working 6 feet or more above the lower level while erecting or grouting precast concrete members. An alternative Fall Protection Plan shall be used if the Underground Division competent person determines that the implementation of conventional fall protection systems is infeasible or creates a greater hazard to employees. All alternative Fall Protection Plans for precast concrete erection shall:

1. Be written specific to the particular jobsite needs;

2. Include an explanation of how conventional fall protection is infeasible or creates a greater hazard to employees;

3. Explain what alternative fall protection will be used for each task;

4. Be maintained in writing at the jobsite by the Underground Division competent person; and

5. Meet the requirements of 29 CFR 1926.502(k).

10.7 Roofing

10.7.1 Low-Slope Roofs

Fall protection shall be provided to employees engaged in roofing activities on low-slope roofs with unprotected sides and edges 6 feet or more above lower levels. The type(s) of fall protection needed shall be determined by the Underground Division competent person, and may consist of guardrail systems, safety net systems, personal fall arrest systems, or a combination of a warning line system and safety net system, warning line system and personal fall arrest system, or warning line system and safety monitoring system. On roofs 50 feet (15 m) or less in width, the use of a safety monitoring system without a warning line system is permitted.

10.7.2 Steep Roofs

Guardrail systems with toeboards, a safety net system, or a personal fall arrest system will be provided to employees working on a steep roof with unprotected sides and edges 6 feet or more above lower levels, as determined by the Underground Division qualified and competent person.

10.8 Wall Openings Guardrail systems, safety net systems, or a personal fall arrest system will be provided to employees working on, at, above, or near wall openings when the outside bottom edge of the wall opening is 6 feet or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (990 mm) above the walking/working surface. The type of fall protection to be used will be determined by the Underground Division competent person.



10.9 Ramps, Runways, and Other Walkways Employees using ramps, runways, and other walkways 6 feet or more above the lower level shall be protected by guardrail systems.

11.0 Protection from Falling Objects When guardrail systems are in use, the openings shall be small enough to prevent passage of potential falling objects. The following procedures must be followed by all employees to prevent hazards associated with falling objects.

1. No materials (except masonry and mortar) shall be stored within 4 feet (1.2 m) of working edges.

2. Excess debris shall be removed regularly to keep work areas clear.

3. During roofing work, materials and equipment shall be stored no less than 6 feet from the roof edge unless guardrails are erected at the edge.

4. Stacked materials must be stable and self-supporting.

5. Canopies shall be strong enough to prevent penetration by falling objects.

6. Toeboards erected along the edges of overhead walking/working surfaces shall be:

a. Capable of withstanding a force of at least 50 pounds (22.7 kg); and

b. Solid, with a minimum 3.5-inch height (90 mm) and no more than a 0.25-inch (6 mm) clearance above the walking/working surface.

7. Equipment shall not be piled higher than the toeboard unless sufficient paneling or screening has been erected above the toeboard.

12.0 Accident Investigation All incidents that result in injury to workers, as well as near misses, regardless of their nature, shall be reported and investigated. Investigations shall be conducted as soon after an incident as possible to identify the cause and means of prevention to eliminate the risk of reoccurrence.

In the event of such an incident, the Fall Protection Plan (and alternative Fall Protection Plans, if in place) shall be reevaluated by the Underground Division competent person to determine if additional practices, procedures, or training are necessary to prevent similar future incidents.

13.0 Rescue The best way to ensure prompt, effective rescue if an employee falls is to develop and preplan the emergency response before an incident occurs. Specific rescue plan requirements will be addressed in Site-Specific Safety Plans, in jobsite safety orientation, and during daily pretask assessment (PTA) or Job Hazard Analysis (JHA).



Daily preshift meetings shall include a discussion and plan for emergency rescue if a fall occurs:

1. Establish emergency-response procedures using an Emergency Action Plan ( EAP): a. Person to call 911. b. Team to deploy on-site rescue including location and type of equipment available for

rescue. c. Employee to escort emergency medical services into jobsite area.

2. Establish the use and type of any self-rescue equipment being worn by the employees. 3. Identify critical resources, including location of first aid kit and those employees trained in first

aid/CPR.

14.0 Changes to the Plan Any changes to the Fall Protection Plan (and alternative Fall Protection Plans, if in place) shall be approved by the Underground Division competent person, and shall be reviewed by a qualified person as the job progresses to determine additional practices, procedures, or training needs necessary to prevent fall injuries. Affected employees shall be notified of all procedure changes, and trained if necessary. A copy of this plan, and any additional alternative Fall Protection Plans, shall be maintained at the jobsite.



Attachment A Project Fall Protection Plan (EXAMPLE)


Project Fall Protection Plan (EXAMPLE)


Memorandum

Project Name:

Project Location: Project No.:

Date Plan Prepared: Date Plan Modified:

Plan Prepared By:

Plan Approved By:

Plan Supervised By:

1.0 Statement of Company Policy

The McMillen Jacobs Associates Underground Division is dedicated to the protection of its employees from occupational injuries. All employees of the company have the responsibility to work safely on the job. The purpose of this plan is to supplement our existing Fall Protection Plan and to ensure that every employee who works for the Underground Division recognizes workplace fall hazards and takes the appropriate measures to address those hazards.

This Fall Protection Plan addresses the use of conventional fall protection at a number of areas on the project, and identifies specific activities that require nonconventional means of fall protection. During the construction of residential buildings under 48 feet in height, it is sometimes infeasible or creates a greater hazard to use conventional fall protection systems at specific areas or for specific tasks. Such areas or tasks include, but are not limited to:

Setting and bracing of roof trusses and rafters

Installation of floor sheathing and joists

Roof sheathing operations

Erecting exterior walls

In these cases, conventional fall protection systems may not be the safest choice for this project. This plan is designed to enable employees to recognize fall hazards associated with this job and to establish safe procedures to prevent falls to lower levels through holes and openings in walking/working surfaces.

2.0 Assignment of Responsibility

2.1 Employer

1. Ensures that all employees understand and adhere to the procedures of this plan and the instructions of the crew supervisor or foreperson.

2. Assigns a competent person to be responsible for managing this Fall Protection Plan.

Project Name / Project No. [Project Location]


3. Provides appropriate fall protection to employees as detailed in this plan.

2.2 Employee

1. Brings to the attention of Underground Division management any unsafe or hazardous conditions or practices that may cause injury to themselves or other employees.

2. Reports any incident that causes injury to self or a coworker.

3. Each employee will be trained in these procedures and will be expected to strictly adhere to them except when doing so would expose him/her to a greater hazard. If, in the employee’s opinion, the procedures in this plan pose a risk, the employee is to notify the Underground Division competent person on site and have his/her concern addressed before proceeding with work.

2.3 Plan Manager

The Underground Division competent person on site shall function as manager of this Fall Protection Plan and has the following responsibilities:

1. Implements this Fall Protection Plan.

2. Performs continual observational checks of work operations to identify hazards.

3. Enforces the company safety policy and the procedures of this plan.

4. Coordinates with crew supervisors or forepersons to immediately correct any unsafe practices or conditions.

5. Provides training on this plan to all affected employees before work begins on this project.

3.0 Fall Protection to be used on This Job

Installation of roof trusses/rafters, exterior wall erection, roof sheathing, floor sheathing, and joint/truss activities will be conducted by employees who are specifically trained to do this type of work and are trained to recognize fall hazards. The nature of such work normally exposes employees to fall hazards for a short period of time. This plan details how the Underground Division will minimize these hazards.

3.1 Controlled Access Zones

When using this plan to implement the fall protection options available, workers must be protected through limited access to high hazard locations. Before any nonconventional fall protection systems are used as part of this plan, a controlled access zone (CAZ) shall be clearly defined by the Underground Division competent person as an area where a recognized hazard exists. The demarcation of the CAZ shall be communicated by the competent person in a recognized manner, either through signs, wires, tapes, ropes, or chains.

The Underground Division shall take the following steps to ensure that the CAZ is clearly marked or controlled by the competent person.

1. All access to the CAZ shall be restricted to authorized entrants only.



2. All workers who are permitted in the CAZ must be listed in the appropriate attachment to this plan (or be visibly identifiable by the competent person prior to implementation).

3. The competent person shall ensure that all protective elements of the CAZ are implemented prior to the beginning of work.

3.2 Installation of Roof Truss or Rafter Erection

1. During the erection and bracing of roof trusses/rafters, conventional fall protection may present a greater hazard to workers. On this job, safety nets will not provide adequate fall protection because the nets will cause the walls to collapse. In addition, there are also no suitable attachment or anchorage points for guardrails or personal fall arrest systems.

2. Requiring employees on this job to use a ladder for the entire installation process will cause a greater hazard because the worker must stand on the ladder with his or her back or side to the front of the ladder. While erecting the truss or rafter, the worker will need both hands to maneuver the truss and therefore cannot hold onto the ladder. In addition, ladders cannot be adequately protected from movement while trusses are being maneuvered into place. Employees may experience fatigue because of the increased overhead work with heavy materials, which can also lead to a greater hazard.

3. Exterior scaffolds cannot be utilized on this job because the ground, after recent backfilling, cannot support the scaffolding. In most cases, the erection and dismantling of the scaffold would expose workers to a greater fall hazard than the erection of the trusses/rafters.

4. On all walls 8 feet or less in height, employees will install interior scaffolds along interior walls below the location where the trusses/rafters will be erected. “Sawhorse” scaffold constructed of 46-inch-tall sawhorses and 2 foot by 10 foot planks will often allow workers to be elevated high enough to allow for the erection of trusses and rafters without working on the top plate of the wall.

5. In structures that have walls higher than 8 feet and where the use of scaffolds and ladders would create a greater hazard, safe working procedures will be used when working on the top plate, which will be monitored by the designated responsible person. During all stages of truss/rafter erection, the stability of the trusses/rafters will be ensured at all times.

6. The Underground Division shall take the following steps to protect workers who are exposed to fall hazards while working from the top plate installing trusses/rafters:

a. Only trained and approved workers will be allowed to work on the top plate during roof truss or rafter installation. A list of approved employees will be maintained by the senior Underground Division employee on site as an attachment to this plan.

b. Employees shall have no other duties to perform during truss/rafter erection procedures.

c. All trusses/rafters will be adequately braced before any worker will be permitted to use the truss/rafter as a support.

d. Employees will remain on the top plate using the previously stabilized truss/rafter as a support while other trusses/rafters are being erected.

e. Employees will leave the area of the secured trusses only when it is necessary to secure another truss/rafter.



f. The first two trusses/rafters will be set from ladders leaning on side walls at points where the walls can support the weight of the ladder.

g. An employee will climb onto the interior top plate via a ladder to secure the peaks of the first two trusses/rafters being set.

7. Employees responsible for detaching trusses from cranes and/or securing trusses at the peaks traditionally are positioned at the peak of the trusses/rafters. There are also situations where workers securing rafters to ridge beams will be positioned at the top of the ridge beam. The Underground Division will take the following steps to protect workers who are exposed to fall hazards while securing trusses/rafters at the peak of the trusses/ridge beam:

a. Only trained and approved workers will be allowed to work at the peak during roof truss or rafter installation. A list of approved employees will be maintained by the senior Underground Division employee on site as an attachment to this plan.

b. Once truss or rafter installation begins, workers not involved in that activity shall not stand or walk below or adjacent to the roof opening or exterior walls in any area where they could be struck by falling objects.

c. Employees shall have no duties other than securing/bracing the trusses/ridge beams.

d. Employees positioned at the peaks, in the webs of trusses, or on top of the ridge beam shall work from a stable position. For employees, a stable position will be either sitting on a “ridge seat” or other equivalent surface that provides additional stability, or positioning themselves in previously stabilized trusses/rafters and leaning into and reaching through the trusses/rafters.

e. Workers shall not remain on or in the peak/ridge any longer than necessary to safely complete the task.

3.3 Roof Sheathing Operations

1. Workers typically install roof sheathing after all trusses/rafters and any permanent truss bracing are in place. Because roof structures are unstable until some sheathing is installed, workers installing roof sheathing cannot be protected from fall hazards by conventional fall protection systems until it is determined that the roofing system can be used as an anchorage point. At that time, employees shall be protected by personal fall arrest systems.

2. Trusses/rafters are subject to collapse if a worker falls while attached to a single truss with a belt/harness. Net could also cause collapse, if there is insufficient structure to attach net to guardrails.

3. All employees will ensure that they have secure footing before they attempt to walk on the sheathing, and will clean their shoes/boots of mud or other slip hazards.

4. To minimize the time workers must be exposed to a fall hazard, materials will be staged to allow for the quickest installation of sheathing.

5. The Underground Division will take the following steps to protect workers who are exposed to fall hazards while installing roof sheathing:



a. Once roof sheathing installation begins, employees not involved in that activity shall not stand or walk below or adjacent to the roof opening or exterior walls in any area where they could be struck by falling objects.

b. The senior Underground Division employee on site shall determine the limits of this area, which shall be clearly communicated to workers prior to placement of the first piece of roof sheathing.

c. The senior Underground Division employee on site may suspend work on the roof for brief periods as necessary to allow other workers to pass through such areas when this would not create a greater hazard.

d. Only trained and approved workers will be allowed to install roof sheathing. A list of approved employees will be maintained by the senior Underground Division employee on site as an attachment to this plan.

e. The bottom row of roof sheathing may be installed by workers standing in truss webs.

f. After the bottom row of roof sheathing is installed, a slide guard extending the width of the roof shall be securely attached to the roof. Slide guards will be at least 4 inches in height and capable of limiting the uncontrolled slide of workers. Workers shall install the slide guard while standing in truss webs and leaning over the sheathing.

g. Additional rows of sheathing may be installed by workers positioned on previously installed rows of sheathing with slide guards.

h. Additional slide guards shall be securely attached to the roof at intervals not to exceed 13 feet as successive rows of sheathing are installed. For roofs with pitches in excess of 9 feet vertical to 12 feet horizontal (9:12), slide guards will be installed at 4-foot intervals.

i. When wet weather conditions (rain, snow, or sleet) are present, roof sheathing operations shall be suspended unless safe footing can be assured for those workers installing sheathing.

j. When strong winds (over 40 miles per hour) are present, roof sheathing operations shall be suspended unless wind breakers are erected.

3.4 Installation of Floor Joists and Sheathing

The Underground Division will take the following steps to protect workers who are exposed to fall hazards while installing floor joists or floor sheathing:

1. Only trained and approved workers will be allowed to install floor joists and floor sheathing. A list of approved employees will be maintained by the senior Underground Division employee on site as an attachment to this plan.

2. Materials for this work shall be conveniently staged to allow for easy access to workers.

3. The first-floor joints or trusses will be rolled into position and secured either from the ground, ladders, or sawhorse scaffolds.

4. Each successive floor joist or trust will be rolled into place and secured from a platform created from a sheet of plywood laid over the previously secured floor joists or trusses.



5. Except for the first row of sheathing, which will be installed from ladders or the ground, employees shall work from the established deck.

6. Any employees not assisting in the leading edge construction while leading edges still exist (i.e., cutting the decking for installers) shall not be permitted within 6 feet of the leading edge under construction.

3.5 Erection of Exterior Walls

The Underground Division will take the following steps to protect workers who are exposed to fall hazards during the construction and erection of exterior walls:

1. Only trained and approved workers will be allowed to construct and erect exterior walls. A list of approved employees will be maintained by the senior Underground Division employee on site as an attachment to this plan.

2. A painted line 6 feet from the perimeter will be clearly marked prior to any wall erection activities to warn of the approaching unprotected edge.

3. Materials for operations shall be conveniently staged to minimize fall hazards.

4. Workers constructing exterior walls shall complete as much cutting of materials and other preparation as possible away from the edge of the deck.

4.0 Enforcement

Constant awareness of and respect for fall hazards, as well as compliance with all safety rules, are considered conditions of employment with the Underground Division. The crew supervisor or foreperson, as well as the senior Underground Division employee on site or company management, reserve the right to issue disciplinary warnings to employees, up to and including termination, for failure to follow the guidelines of this plan.

5.0 Accident Investigations

All incidents that result in injury to workers and near misses, regardless of their nature, shall be reported and investigated. All incidents shall be investigated as soon as possible to identify the cause and means to prevent future occurrences.

In the event of such an incident, this Fall Protection Plan shall be reviewed to determine if additional practices, procedures, or training should be implemented to prevent similar incidents in the future.

6.0 Changes to the Plan

Any changes to this Fall Protection Plan will be made by the senior Underground Division competent person. This plan shall be reviewed as the job progresses to determine if additional practices, procedures, or training are needed to improve or provide additional fall protection. Affected employees shall be notified of changes to this plan, and retrained, if necessary. A copy of this plan and all approved changes shall be maintained at the jobsite.



Attachment B Rope Access Job Safety Analysis (Single Rope)


Rope Access Job Safety Analysis (Single Rope)


Job Description: Project Date:

Office Location: Date Created:

Development Site: Revision Date:

Development Team: Review Team:

Table 1. Minimum Required Personal Protective Equipment (PPE)

Hi-Vis Reflective Vest ☐ Gloves ☐ Filter Cartridge Respirator

☐ Sturdy Climbing Shoes ☐ Other ☐

Hard Hat ☐ Face Shield ☐ Supplied Air Respirator ☐ Weather Appropriate Clothing

☐ Other ☐

Climbing Helmet ☐ Steel-toed Boots ☐ Air Purifying Respirator ☐ 10 Essentials ☐ Other ☐

Full Body Harness ☐ Hearing Protection ☐ Protective Clothing ☐ Other ☐ Other ☐

Sport Harness ☐ Flashlight / Headlamp

☐ PFD ☐ Other ☐ Other ☐

Table 2. Minimum Required Rope Access Equipment (Single Rope)

Full Body Harness ☐ ATC ☐ Locking Carabiners (10) ☒ 1-in. Webbing Anchors ☐

Climbing Helmet ☐ Shunt ☐ Ascenders (1 Pair) ☐ Kernmantle Static Climbing Rope (150 ft)

☐

Rappelling Gloves ☐ Third Hand ☐ Pulleys (2) ☐

Daisy Chains (3) ☐ Prussic Slings (2+) ☐ Progress Capture Pulley (1) ☐

Rescue-8 ☐ 1 in. Webbing Slings (1+) ☐ 8 mm Accessory Cord (30 ft) ☐

Table 3. Safety Assessment by Job Scope

Job Scope Hazards Assessment

Safe Work Practices Incident Response (Alpha-Bravo-Charlie) *

Working in construction work areas

General construction hazards: trips, falls, drags, high noise, impingements

Always wear PPE while on-site. Participate in construction safety tailgate.

As warranted by incident.

Rope access equipment inspection

Equipment failure Use authorized Rope Access Trained Personal and Team Protective Equipment.

Prior to use, the lead climbing safety officer will inspect the team and personal protective equipment.

Safety officer will inspect ropes, webbing, cord, and harnesses for excessive wear and fray marks.

Climbing helmets will be inspected for cracks in the helmet and wear in the chin strap.

Mechanical equipment will be inspected for broken parts, jammed locking mechanisms, and excessive wear.

Additional equipment will be stocked on site to replace worn or defective equipment.

Replace defective or damaged equipment.

Setting up for high angle rope work

Trips & falls Vectors

All personnel conducting or tending climbers for vertical scan line mapping using rope access techniques will participate in a rope access safety training and proficiency course conducted by McMillen Jacobs.

First aid as applicable. If worker free-falls & is

restrained by ropes: Alpha/Bravo Response.

[Project Name] Single Rope Access JSA




Mechanical impingement & pinches

Burns

Wear PPE while mobilizing to anchorage area and setting up rigging systems.

All personnel working at the road level will wear reflective vests and hard hats.

If worker free-falls to ground: Charlie Response.

Rigging anchors for fall protection system

Anchor system failure

Rigging system failure

Only rope access trained personnel will rig anchors for the fall protection and rappelling system.

Prior to selection of rappelling locations and rigging anchors, loose rock and other debris will be moved to a secure location.

Each rappel station will be rigged for one rope per climber.

Each rappel station will be rigged with one anchor to secure the rappel line and belays for one climber. Anchor points may consist of large stable trees, stable boulders, guardrails, or mechanical anchors attached directly into fractures of the rock by pitons, locking cams and jam nuts.

Anchor straps will consist of approved 1-inch flat or tubular climbing webbing. If two or three anchors are used, the straps will be rigged to each anchor to equalize the load.

Anchors, knots, and locking carabineers will be rechecked prior to starting the rappel.

If possible, edge protection will be provided at the brow of the rock slope or sharp edges for all lines transitioning over the edge of the rock slope.

All personnel working between the anchors and the edge of the slope will be tied off to the anchors with appropriate lanyards, and wear all required PPE and rope access equipment (Tables 1 & 2).




Climbing / rappelling / high angle rope work

Trips High angle falls Vectors Mechanical

impingement & pinches

Burns

Only rope access trained personnel will rig, tend ropes, and climb.

All personnel will be free of impairment that may limit their ability to evaluate actual conditions and work safely.

Radio communication will be maintained between the climbing crew, ground crew, & traffic control at all times.

Mechanical ascending and descending equipment and prussic cords will be attached to safety harness with locking carabineers.

Rappelling device will be attached to the safety harness by locking carabineer. Climber and rappelling device will be backed-up with a mechanical (Petzl shunt), prussic safety cord, or a 3rd Hand should the climber become incapacitated from falling debris. The climber will insure the ropes are protected from rockfall.

At the anchor locations and along the rappel line, rock and other debris will be carefully cleaned, stabilized, or removed.

At all times when on rappel or at each mapping location, the backup device (shunt or prussic cord) must be engaged.

As a backup, mechanical ascenders may be attached to the rope as back-up belays while mapping.

Personal safety equipment will be worn while completing vertical line mapping.




Debris scaling Rock and debris impacts to workers

Trips & falls

Only rope access trained personnel will scale rock and debris from the site.

First aid as applicable.





The first climber on rappel will carefully clean and scale the slope.

Ground support crew will observe climbers from an area outside the rock debris fall zone and maintain radio contact with the climbers and tenders.

Any head injury or lapse of consciousness: Charlie Response.

Mapping at the base of Slopes (not on a rope)

Overhead hazard from rock or debris fall

Only rope access trained personnel will work at the base of a high angle slope.

Notify nearby staff that work is being conducted at the base of slope to prevent rock and debris from being kicked down slope.

Wear climbing helmet to protect head from falling rock and debris.

First aid as applicable Any head injury or lapse

of consciousness: Charlie Response.

Mapping near Slope Edge

Slips Trips Falls near slope

edge

Only rope access trained personnel will work near the slope edge of a high angle slope.

Notify ground support crew that work is being conducted at the top of the slope and to stand clear of the slope.

All personnel working between the anchors and the edge will be tied off to the anchors with appropriate lanyards, and will wear all required PPE and rope access equipment (Tables 1 & 2).

All personnel working outside the anchorage system and along the slope edge must remain at least 12 feet back from the rock slope edge unless they are tied off with appropriate lanyards to the fall protection anchorage system.





Working in Traffic Areas

Rock and debris impacts to vehicles

Vehicle vs worker collision

Develop a traffic control plan. Place traffic warning signage and flagmen in accordance

with the approved traffic control plan. All personnel must wear Hi-Vis apparel. Maintain radio communication among ground support

crew, traffic control supervisor, and the lead climber on the rock.

First aid as applicable If worker hit by vehicle:

Alpha/Bravo Response.

Working Outdoors

Vector bites Allergic reactions to

vegetation or bites from insects

Potentially dangerous animals

Avoid hand holds and foot holds where vectors could be a resident.

Watch walk paths for vectors. Use insect repellent; If working in areas with high

vegetation, tuck pant legs into boots and tape off to avoid potential bites from ants and ticks.

If allergic to any insects, notify Work Supervisor and coworkers of allergy and what to do should you be bitten/stung.

Watch surroundings carefully and listen for warning signs; do not approach these animals.

Wear snake chaps if there is a high probability of poisonous snake inhabitation.

First aid as applicable. Any breathing or airway

impairment either by allergic reaction or direct contact: Charlie Response.


Any poisonous snake bite: Charlie Response.

Environmental Factors

Heat stress All personnel will be familiar with heat stress symptoms, preventions, and treatments.

Rehydrate frequently and thoroughly. Avoid direct sunlight. Consider adding electrolytes to fluids. Do not take salt

tablets unless specifically prescribed by your physician.

First aid as applicable. If significant heat stress

reaction: Bravo Response.

Any heat stroke or loss of consciousness: Charlie Response.






Cold stress All personnel will be familiar with the symptoms of cold stress/hypothermia, preventions, and treatments.

Cold stress may be a concern during the winter months. Cold injury (hypothermia) and impaired ability to work are hazards at low air temperatures or when the wind-chill factor is low.

To guard against cold injury, wear appropriate clothing, schedule work and rest periods, and take breaks in warm areas whenever possible.

First aid as applicable. If hypothermic, assist

impaired climber to ground (or worker), treat for shock; Bravo Response.

Any loss of consciousness: Charlie Response.

* Incident Response Definitions: • Alpha Response: Non-life-threatening injuries requiring on-site treatment. • Bravo Response: Serious, but non-life threatening requiring urgent rescue / emergency medical response. • Charlie Response: Potentially life threatening requiring immediate rescue / emergency medical response.



Attachment C Rope Access Job Safety Analysis (Two-Rope)


Rope Access Job Safety Analysis (Two-Rope)










☐ Other ☐





Table 2. Minimum Required Rope Access Equipment (Single Rope)

Full Body Harness ☐ ATC or Rescue-8 ☐ Locking Carabiners (10) ☐ 1-in. Webbing Anchors ☐

Climbing Helmet ☐ Shunt ☐ Ascenders (1 Pair) ☐ Kernmantle Static Climbing Rope (150 ft) (2)

☐

Rappelling Gloves ☐ Third Hand ☐ Pulleys (2) ☐ Petzl Industrial Descender (ID) ☐

Daisy Chains (3) ☐ Prussic Slings (2+) ☐ Progress Capture Pulley (1) ☐ Petzl ASAP-LOCK Fall Arrest Device

☐

Rescue-8 ☐ 1 in. Webbing Slings (1+) ☐ 8 mm Accessory Cord (30 ft) ☐ Edge Protection ☐


Job Steps Hazards Assessment

Safe Work Practices Incident Response (Alpha-Bravo-Charlie)*



Always wear PPE while on site. Participate in construction safety tailgate.



Equipment failure

Use authorized rope access equipment (Petzl ID & ASAP or Shunt & Rescue-8) designed for two rope systems.






Replace defective or damaged equipment.

Setting up for high angle rope work


All personnel conducting or tending climbers for vertical scan line mapping using two-rope access techniques will participate


[Project Name] Rope Access JSA (Two Rope)





Burns

in a two-rope access safety training and proficiency course organized by McMillen Jacobs.

Always wear PPE while mobilizing to anchorage area and setting up rigging systems.

All personnel working at the road level will wear reflective vests and hard hats.

If worker free-falls & is restrained by ropes: Alpha/Bravo Response.


Rigging anchors for fall protection system



Only rope access trained personnel will rig anchors for the fall protection and rappelling system.

Prior to selection of rappelling locations and rigging anchors, loose rock and other debris will be moved to a secure location.

Each rappel station will be rigged for two ropes per climber. Each rappel station will be rigged with two anchors to secure

the rappel lines and or/belays for one climber. Anchor points may consist of large stable trees, stable boulders, guardrails, or mechanical anchors attached directly into fractures of the rock by pitons, locking cams and jam nuts.

Anchor straps will consist of approved 1-inch flat or tubular climbing webbing. If two or three anchors are used per rope, the straps will be rigged to each anchor to equalize the load.

Anchors, knots, and locking carabineers will be rechecked prior to starting the rappel.

If possible, edge protection will be provided at the brow of the rock slope or sharp edges for all lines transitioning over the edge of the rock slope.

All personnel working between the anchors and the edge of the slope will be tied off to the anchors with appropriate lanyards, and wear all required PPE and rope access equipment (Tables 1 & 2).




Climbing / rappelling / high angle rope work



Burns

Only rope access trained personnel will rig, tend ropes, and climb.




Rappelling device will be attached to the safety harness by locking carabineer. Climber and rappelling device will be backed-up with a mechanical (Petzl shunt) or prussic safety cord should the climber become incapacitated from falling debris.

At the anchor locations and along the rappel line, rock and other debris will be carefully cleaned, stabilized, or removed.

At all times when on rappel or at each mapping location, the backup device (shunt or prussic cord) must be engaged.

As a backup, mechanical ascenders may be attached to the rope as backup belays while mapping.





Debris scaling Rock and debris impacts to workers

Trips & falls

Only rope access trained personnel will scale rock and debris from the site.

The first climber on rappel will carefully clean and scale the slope. Ground support crew will observe climbers from an area outside

the rock debris fall zone and maintain radio contact with the climbers and tenders.

First aid as applicable. Any head injury or lapse

of consciousness: Charlie Response.

Mapping at the base of

Overhead hazard from rock or debris fall

Only rope access trained personnel will work at the base of a high angle slope.






Slopes (not on a rope)

Notify nearby staff that work is being conducted at the base of slope to prevent rock and debris from being kicked down slope.

Wear climbing helmet to protect head from falling rock and debris.


Mapping near Slope Edge

Slips Trips Falls near slope

edge

Only rope access trained personnel will work near the slope edge of a high angle slope.

Notify ground support crew that work is being conducted at the top of the slope and to stand clear of the slope.

All personnel working between the anchors and the edge will be tied off to the anchors, and will wear all required PPE and rope access equipment (Tables 1 & 2).

All personnel working outside the anchorage system and along the slope edge must remain at least 12 feet back from the rock slope edge unless they are tied off with appropriate lanyards to the fall protection anchorage system.





Working in Traffic Areas

Rock and debris impacts to vehicles

Vehicle vs worker collision

Develop a traffic control plan. Place traffic warning signage and flagmen in accordance with the

approved traffic control plan. All personnel must wear Hi-Vis apparel. Traffic will be held for XX minute windows when scaling or

working on the rock slope. Maintain radio communication among ground support crew, traffic

control supervisor, and the lead climber on the rock.

First aid as applicable. If worker hit by vehicle:


Working Outdoors

Vector bites Allergic reactions

to vegetation or bites from insects

Potentially dangerous animals

Avoid handholds and footholds where vectors could be a resident. Watch walk paths for vectors. Use insect repellent; If working in areas with high vegetation, tuck

pant legs into boots and tape off to avoid bites from ants and ticks.

If allergic to any insects, notify work supervisor and coworkers of allergy and what to do should you be bitten/stung.

Watch surroundings carefully and listen for warning signs; do not approach these animals.

Wear snake chaps if there is a high probability of poisonous snake inhabitation.

First aid as applicable. Any breathing or airway

impairment either by allergic reaction or direct contact: Charlie Response.


Any poisonous snake bite: Charlie Response.


Heat stress All personnel will be familiar with heat stress symptoms, preventions, and treatments.

Rehydrate frequently and thoroughly. Avoid direct sunlight. Consider adding electrolytes to fluids. Do not take salt tablets

unless specifically prescribed by your physician.

First aid as applicable. If significant heat stress

reaction: Bravo Response.












Attachment D Rope Access Job Safety Analysis (Dams and Structures)


Rope Access Job Safety Analysis (Dams and Structures)










☐ Other ☐





Table 2. Minimum Required Rope Access Equipment for Dams and Structures (Two Rope) Full Body Harness ☐ ATC or Rescue-8 ☐ Locking Carabiners (10) ☐ 1-in. Webbing Anchors ☐

Climbing Helmet ☐ Shunt ☐ Ascenders (1 Pair) ☐ Kernmantle Static Climbing Ropes (150 ft) (2)

☐

Rappelling Gloves ☐ Third Hand ☐ Pulleys (2) ☐ Petzl Industrial Descender (ID) ☐

Daisy Chains (3) ☐ Prussic Slings (2+) ☐ Progress Capture Pulley (1) ☐ Petzl ASAP-LOCK Fall Arrester ☐

Rescue-8 ☐ 1 in. Webbing Slings (1+) ☐ 8 mm Accessory Cord (30 ft) ☐ Edge Protection ☐


Job Steps Hazards Assessment Safe Work Practices Incident Response (Alpha-Bravo-Charlie)*



Wear PPE always while on-site. Participate in construction safety tailgate.



Equipment failure Use authorized rope access equipment (Petzl ID & ASAP) designed for two rope systems.






Replace defective on damaged equipment.

Setting up to inspect dams and/or structure


All rope access personnel conducting or tending climbers for dam / structure inspections using two-rope access techniques will participate in a two-rope access safety training and proficiency course organized by McMillen Jacobs.


restrained by ropes:

[Project Name] Rope Access JSA (Dams & Structures)




Burns

Always wear PPE while mobilizing to anchorage area and setting up rigging systems.

All personnel working at the crest of the dam or top of structure will wear reflective vests and hard hats.



Rigging anchors for dam and structure inspection



Only rope access trained personnel will rig anchors for two rope access to dam / structure inspections.

Prior to selection of rappelling locations and rigging anchors, loose material and other hazards at the top of the structure should be removed or mitigated.

Each rappel station will be rigged for two ropes per climber. Each rappel station will have edge protection in place to protect ropes from damage.

Each rappel station anchor shall have a minimum 5,000 pound bearing capacity per rope.

Rappel anchors shall be approved by the lead climbing safety officer.

Anchor straps will consist of approved 1-inch flat or tubular climbing webbing. If two or three anchors per rope are used, the straps will be rigged to each anchor to equalize the load.

Anchors, knots and locking carabineers will be rechecked prior to starting the rappel.

All personnel working between the anchors and the edge will be tied off to the anchor using appropriate lanyards, and wear all required PPE and rope access equipment (Tables 1 &2 ).




Rappelling / high angle rope while inspecting dams and structures



Burns

Only rope access trained personnel will rig, tend ropes, and inspect with rope access techniques.



Climbers will rappel on two ropes, descending on one rope with a Petzl ID, with the other rope functioning as a safety backup employing a Petzl ASAP LOCK fall arrester.


Rappelling device (Petzl ID) will be attached to the safety harness by locking carabineer. The inspector shall have in place an ASAP Absorbica (fall arrest device) on the safety backup line.

The inspector will place a short prussic sling (3rd Hand) below the Petzl ID as an additional backup.

The inspector will insure the ropes are protected from damage while climbers are rappelling.

At the anchor locations and along the rappel line, sharp edges shall be covered and debris removed.





Debris scaling Loose debris impacts to workers

Trips & falls

Only rope access trained personnel will scale loose debris from the dam / structure.

The first climber on rappel will carefully clean and scale the inspection area if necessary.

Support crews will observe climbers from an area outside the debris fall zone and maintain radio contact with the climbers and tenders.

First aid as applicable. Any head injury or

lapse of consciousness: Charlie Response.




Inspecting near the edge of the dam / structure

Slips Trips Falls near slope edge

Only rope access trained personnel will work near the edge of a dam / structure.

Notify ground support crew that work is being conducted at the top of the structure and to stand clear.

All personnel working between the anchors and the edge will be tied off to the anchors with appropriate lanyards, and wear all required PPE and rope access equipment (Tables 1 & 2).

All personnel working outside the anchorage system and along the slope edge must remain at least 12 feet back from the rock slope edge unless they are tied off to the fall protection anchorage system.






Heat stress All personnel will be familiar with the symptoms of heat stress, preventions, and treatments.

Rehydrate frequently and thoroughly. Avoid direct sunlight. Consider adding electrolytes to fluids. Do not take salt tablets

unless specifically prescribed by your physician.

First aid as applicable. If significant heat

stress reaction: Bravo Response.












Attachment E Slope Access Safety Evaluation (SASE)


Slope Access Safety Evaluation (SASE) Form

McMillen Jacobs Associates Underground Division January 2020

Shop Location (HWY/RR & MP):

Competent Person: Date:

Weather:

Last Training Date: Any Training/Practice within 1 year: Yes ☐ No ☐

SLOPE DESCRIPTION EQUIPMENT CHECKLIST

Cut Slope ☐ Natural Slope ☐ Recent/Old Slide ☐ Level D, Safety ☐ Slope Materials Helmet, Climbing ☐ Soil ☐ Soil & Rock ☐ Rock ☐ Harness, Body ☐ Slope Condition Ascenders: 2 ☐ Numerous Detached Blocks ☐ Some Detached Blocks ☐ Few Detached Blocks ☐ N/A ☐ Descender & Safety ☐ Slope Height Safety Carabiner: 10 ☐ < 50 ft ☐ < 100 ft ☐ < 150 ft ☐ < 200 ft ☐ > 200 ft ☐ Daisy Chains: 3 ☐ Slope Weight: W = ___________________________ Rope, Static: 150 ft ☐ Slope Angle Prussic Slings ☐ 35 to 45º ☐ > 45 to 70º ☐ > 70 to 90º

☐ 35 to 45º ☐ Overhanging ☐ If yes: < 5 ft ☐ >5 ft ☐ Assorted Slings ☐

Rock Block Size S (< 1 ft) ☐ M (1–3 ft) ☐ L (3–6 ft) ☐ XL (> 6 ft) ☐ N/A ☐ Average: ____________________ Maximum: ____________________ Is there loose rock on the slope brow? Yes ☐ No ☐ Danger of rockfall from above during assessment? Low ☐ Medium ☐ High ☐ NA ☐ Danger of rockfall onto highway below during assessment? Low ☐ Medium ☐ High ☐ NA ☐ Are other personnel at toe of slope: Yes ☐ No ☐

ANCHOR & ACCESS DESCRIPTIONS Access Retreat: Easy ☐ Difficult ☐ Rock Outcrops: No ☐ Yes ☐ If yes, Many ☐ Few ☐ Angle: Flat ☐ Moderate ☐ Steep ☐ Other Anchors: Type ________________________ Vegetation: Trees ☐ Shrubs ☐ None ☐ Mechanical Anchors Needed: No ☐ Yes ☐ Type ___________

SLOPE DIAGRAMS

Cross Section Sketch Front View Sketch (entry, exit, emergency access, chutes, etc., locations)

Comments, Additional Considerations: ____________________________________________________________________________

[Project Name] Slope Access Safety Evaluation (SASE) Form




Attachment F Rock Climbing and Limited Rope Access Training Course (EXAMPLE)


Rock Climbing and Limited Rope Access Safety Training Course (EXAMPLE)


The McMillen Jacobs Associates Underground Division conducts a three-day rigorous course in rock climbing and limited rope access safety training including aerial buddy rescue for the geotechnical professional. Accessing high angle slopes is regularly required in the occupational activities of the geotechnical professional. These activities include but are not limited to site investigations, monitoring, construction, and on-slope inspection of geologic conditions that can reflect varying stages of stability. Our training incorporates a single rope for each climber on the slope, used with a rappelling device for positioning and a safety backup as fall protection. While not excluding additional ropes or belays where warranted, the single rope technique considers the primary need to have mobility and avoid additional encumbering equipment that could slow down an individual’s movement on-slope during an emergency. The course focuses on the following:

Daily safety review including introduction to the Rope Access Job Safety Analysis (JSA) Form for rock work on high angle slopes

Appropriate climbing and anchor knots Anchor systems including static and self-equalization single, double, and triple anchors using

various anchor points and equipment Belaying techniques using devices such as the Münter friction knot and ATC including safety tie-

off using the Mule hitch Single rope rappelling techniques using a Rescue-8 and a 3rd hand safety backup and ATC with

Petzl Shunt safety backup Rope ascending techniques using three points of contact: two mechanical ascenders and a running

safety friction knot Passing the knot or changing to ascenders while on rappel Self-rescue techniques while on rappel or ascending the rope Z-Pulley hoist and rescue system Aerial buddy rescue two-person system using Rescue-8 and Prussic 3rd hand backup safety

Day 1 and Day 2 training is conducted at the Spire Rock Training area, Spanaway, WA, and Day 3 is at Deception Crags at Exit 38, North Bend, WA. Spire Rock is an artificially constructed rock designed for practicing rock climbing and rescue techniques. Deception Crags is a natural rock slope used for practice and sport climbing. Students who attend the three-day course receive a certificate of completion including 24 professional development hours (PDHs), which are required for some state professional registrations in geology or engineering.

Course Outline

Day 1: Spire Rock Training, Spanaway, WA (attached directions)

1. Daily safety review including introduction to the Rope Access Job Safety Analysis (JSA) Form for rock work on high angle slopes

Project Name / Project No. Rock Climbing & Limited Rope Access Safety Training Course (EXAMPLE)


2. Knot tying review of key knots using the following references a. Animated Knots by Grog (enclosed) b. Other references

i. Mountaineering, The Freedom of the Hill, 8th Edition ii. Climbing Self-Rescue, Improving Solutions for Serious Situations; Tyson &

Loomis, 2006 iii. CALTRANS Bank Scaling & Rock Climbing, V9.0

http://www.dot.ca.gov/hq/esc/geotech/references/Rockfall_References/13_Caltrans_Bank_Scaling_and%20Rock_V9.1_02-14-14.pdf

3. Belay and rappel anchors a. Climbing rope

i. Clove hitch ii. Double Figure-8

b. Anchor systems including static and self-equalization single, double, and triple anchors using various anchor points and equipment

4. Belay techniques with climber a. Body belay b. Belay devices

i. Münter friction knot ii. ATC

c. Mule hitch for tying off belays 5. Rappel techniques: 1 rope system

a. Rescue-8 with Prussic backup 3rd hand b. ATC with Petzl Shunt safety backup c. Fireman’s belay for rappeler

6. Rope ascending practice with three points of contact (mechanical ascenders)

Day 2: Spire Rock Training, Spanaway, WA

1. Daily safety review including the Rope Access Job Safety Analysis (JSA) Form for rock work on high angle slopes

2. Rappel techniques: 1 rope system a. Rescue-8 with Prussic backup 3rd hand b. ATC with Petzl Shunt backup

3. Rope ascending practice with three points of contact (mechanical ascenders) 4. Passing the knot or changing to ascenders while on rappel 5. Rescue techniques

a. Self-rescue





b. Z-pulley system c. Aerial buddy rescue two-person system

Day 3: Exit 38, North Bend, WA (attached directions)

1. Daily safety review including the Rope Access Job Safety Analysis (JSA) Form for rock work on high angle slopes

2. Belay and rappel anchor set up practice a. Climbing rope b. Static and self-equalization single, double, and triple anchor systems

3. Belay technique practice using the Münter hitch or ATC 4. Climbing and belaying practice 5. Rappel practice:1 rope system

a. Rescue-8 and Prussic 3rd hand backup safety 6. Rope ascending practice with three points of contact (mechanical ascenders) 7. Passing the knot or changing to ascenders while on rappel. 8. Rescue practice

a. Self-rescue b. Z-Pulley hoist and rescue system c. Aerial buddy rescue two-person system using Rescue-8 and Prussic 3rd hand backup

safety

Climbing Knots

For knot tying review go to Animated Knots by Grog. Just Google “Animated Knots.” http://www.animatedknots.com/indexclimbing.php?LogoImage=LogoGrog.jpg&Website=www.animatedknots.com. Click on climbing knots.

Focus on the following knots as a minimum and have your crew practice them.

1. Figure 8 a. Figure 8 loop for single anchor b. Figure 8 follow loop (rewoven) for harness tie-in c. Figure 8 bend (join two ropes) d. Figure 8 double loop “bunny ears” for two-point anchor system

2. Bowline knot 3. Butterfly loop knot 4. Girth hitch 5. Clove hitch 6. Friction knots

http://www.animatedknots.com/indexclimbing.php?LogoImage=LogoGrog.jpg&Website=www.animatedknots.com

http://www.animatedknots.com/indexclimbing.php?LogoImage=LogoGrog.jpg&Website=www.animatedknots.com



a. Prusik knot b. Klemheist knot c. Münter hitch and Münter Mule

7. Double fisherman 8. Water knot for flat webbing 9. Chain Sinnet

Suggested Equipment

Personal Equipment

1. Safety a. Sturdy climbing safety boots b. Climbing helmet with chin strap c. Safety vest d. Safety glasses as needed e. Fingerless climbing-belay gloves

2. Standard climbing gear (individual) a. Harness (body or sport climbing) b. Ascenders (right and left) with 36 in. daisy chain for each attached to harness

i. Daisy chains should be full loops like Metolius (not sewn) or tied with 9/16 in. flat webbing.

c. Carabiners (6 regular and 10 locking), used on harness and for anchors d. Rappel device (Rescue-8 with ears or ATC) e. Petzel shunt and 30 in. daisy chain f. Etrieres (rope ladders), two each g. One flat 1 in. webbing sling (self-rescue) tied from a 6 ft length of webbing. h. One 7 mm sling (self-rescue or prussic bac-up) tied from a 6 ft length of cord i. 30 ft of 7 mm rope (anchors)

3. Team gear (minimum) a. Two 200 ft static Kernmantel rope b. Nylon webbing

i. At least 100 ft of 1 in. cut in 30 ft lengths for anchors ii. 20 ft of 9/16 in. cut into various lengths

c. Double-ended rope bag for each 200 ft rope with shoulder straps or loop so you can bring rope down with you in the brush

d. Rope protection guards for sharp edges e. Pitons and rock bolts as needed.



SPIRE Rock

About SPIRE Rock

SPIRE Rock is a man-made rock formation located at Sprinker Recreation Center.

Directions

From the North / South: From I-5, take exit 127 following the Mt. Rainier / Puyallup signs to Highway 512 going east.

Take the second exit (Parkland/Spanaway-Pacific Ave) and at the stoplight turn right onto Pacific Avenue (SR 7). Head south for 2.7 miles then turn right onto Military Road (152nd St). Sprinker Center is 1-1/2 blocks down on the right.

From the East: Go west on Highway 512. Take the Mt. Rainier / Highway 7 exit and follow the off ramp around

to your left. At the stoplight turn left onto Pacific Avenue. Go south on Pacific Avenue for 2.7 miles and turn right onto Military Road (152nd St.). Sprinker Center is 1-1/2 blocks down on the right.

As you enter the parking lot, SPIRE Rock is located to the far left of the facility between the ball fields and Breseman Forest.



Exit 38

Nearest town or city: North Bend.

Directions

Drive north from Olympia to the Highway 18 exit to Auburn and North Bend and then to I-90. On I-90 travel east until you reach Exit 38. Get off the freeway and make a right at the end of the off-ramp. Keep going until you reach the large gravel parking area, just before the road crosses Change Creek. The trail ascends along the creek to the Iron Horse trail and climbing area. The area that we use is about 1/2 mile east of the trail junction from the main climbing area at Hall Creek Bridge.

Practice area at Hall Creek, Iron Horse Trail



Attachment G Rope Access Training (EXAMPLE)


Rope Access Training (EXAMPLE)


Project Name

Date: 03/17/2017 Project Manager: Bill Gates

Client Owner: McMillen Jacobs Associates

Emergency Contacts near SPIRE Rock – March 17, 2017 EMERGENCY RESPONDER CONTACTS

Responder Agency Address Telephone Est. Response Time Medical St. Clare Hospital 11315 Bridgeport Way SW,

Lakewood, WA 98499 911 (253) 985-1711 (nonemergencies)

15–30 minutes

Fire Central Pierce Fire & Rescue

17520 22nd Ave E, Tacoma, WA 98445

911 (253) 538-6400 (nonemergencies)

15–30 minutes

Police Parkland-Spanaway Precinct of Pierce County Sheriff’s Department

495 Shandon Wright Way S, Tacoma, WA 98444

911 (253) 798-4840 (nonemergencies)

10–20 minutes

JA Staff Mobile # In Case of Emergency

Bill Gates (206) 496-4829 CPR Certified Thomas Pallua (206) 551-0840 Designated 911 Caller Dale Moore (360) 737-4762 Director of Emergency Vehicle Luke Ferguson (503) 871-4563 Lynette Sla (509) 670-2589 Morgan Vane (206) 484-1295 Robert Long (360) 719-8022 Julia Irizarry (910) 723-7703 Elizabeth Carnogursky

Rope Access Training Project Location

On March 17, 2017, training will be held at SPIRE Rock, located in the Sprinker Recreation Center in Tacoma, Washington.

Directions:

From the North / South:

° From I-5, take Exit 127 following the Mt. Rainier / Puyallup signs to Highway 512 going east. Take the second exit (Parkland/Spanaway – Pacific Ave.) and at the stop light turn right onto Pacific Avenue (SR 7). Head south for 2.7 miles, then turn right onto Military Road (152nd St). Sprinker Center is 1 1/2 blocks on the right.

Project Name / Project No. Rope Access Training (EXAMPLE)


From the East:

° Go west on Highway 512. Take the Mt. Rainier / Highway 7 exit and follow the off-ramp around to your left. At the stoplight, turn left onto Pacific Avenue. Go south on Pacific Avenue for 2.7 miles and turn right onto Military Road (152nd St.). Sprinker Center is 1-1/2 blocks down on the right.

As you enter the parking lot, SPIRE Rock is located to the far left of the facility between the ball fields and Breseman Forest.

Job Site Safety Analysis (JSA)

Primary hazards at the training site include trips, slips, and falls on and around the spire rock. All members should exercise proper climbing safety techniques, be alert at all times, and ensure knots and anchors are secure. Refer to Attachment 1: Jobsite Safety Analysis (JSA).*

Site Evaluation and Slope Assessment

Refer to Attachment 2: Site Evaluation and Slope Scaling Assessment.*

Safety Equipment

Employees must use approved and appropriate safety equipment during training. The following safety equipment is required:

Climbing helmet

Climbing harness

Properly locking carabiners

Shirts & long pants

Belay gloves

10 essentials

ATTENDANCE FOR HEALTH AND SAFETY PLAN BRIEFING

Please sign below to confirm that you have seen and been presented the Safety Policy Manual.

PRINT NAME SIGNATURE DATE

* Not included in this example.



Appendix F Hearing Conservation Program Handbook


Hearing Conservation Program

Handbook

January 2020

Underground Division Safety Policy Manual Hearing Conservation Program Handbook


Table of Contents 1.0 Introduction .......................................................................................................................................... 1 2.0 Standard Overview .............................................................................................................................. 2 3.0 Program Elements ............................................................................................................................... 4

3.1 Exposure Monitoring ................................................................................................................ 4 3.2 Medical Surveillance ................................................................................................................ 4 3.3 Employee Training ................................................................................................................... 5 3.4 Record Keeping ....................................................................................................................... 5

3.4.1 Hazard Inventory Form ................................................................................................. 6 3.4.2 Noise Exposure Records .............................................................................................. 6 3.4.3 Audiometric Test Records ............................................................................................ 6 3.4.4 Employee Training Records ......................................................................................... 6

4.0 Program Responsibilities ..................................................................................................................... 7 4.1 Employees ............................................................................................................................... 7 4.2 Supervisors .............................................................................................................................. 7 4.3 Safety Manager ........................................................................................................................ 7

5.0 Hearing Protection ............................................................................................................................... 8 5.1 Hearing Protection Devices ..................................................................................................... 8 5.2 Warning Signs .......................................................................................................................... 8

List of Tables Table 1. OSHA Noise Exposure Limits ......................................................................................................... 4 Table 2. Examples of Loud Equipment ......................................................................................................... 8

List of Figures Figure 1. Decision Tree for Determining Participation in the Hearing Conservation Program ..................... 3 Figure 2. Signs to be Posted in Noise Hazard Area or on Loud Equipment ................................................. 8

Attachments Attachment A Employee Notification – Hearing Retest Attachment B Employee Notification – Hearing Loss Attachment C Employee FAQs Attachment D Employee Training Handout





1 January 2020 Bill Mitchell, Ted DePooter, Sarah Wilson 0 August 2017 Bill Mitchell, Ted DePooter (First Issuance)



1.0 Introduction Employee hearing protection at the McMillen Jacobs Associates Underground Division is considered an important objective in overall worker health. Occupational noise exposure is the most significant health hazard present in the modern industrial workplace.

In an effort to maintain effective hearing protection for Underground Division employees, the Hearing Conservation Program has been established. This handbook1 provides an overview of the program, the program elements, and the responsibilities of both employees and supervisors. Also provided is information on hearing protection. The primary objective of the Hearing Conservation Program is to eliminate employee hearing loss as a result of job-related noise exposure. This program includes the following requirements for those employees exposed to a time weighted average (TWA) “action level” of 85 decibels A weighted (dBA):

An ongoing program of monitoring, identification, and evaluation of noise hazards

Annual hearing test (audiograms) of employees

Employee training concerning the effects of noise on hearing and proper use and care of hearing protection

Appropriate follow-up procedures for those individuals who have experienced a standard threshold shift (STS)

Employees participating in the Hearing Conservation Program will be required to wear hearing protection devices, as needed, to reduce noise exposure levels below 90 dBA TWA. Employees who have experienced an STS will have noise exposure levels attenuated below 85 dBA TWA.

It is the Underground Division’s policy that any worker exposed to elevated noise levels wear hearing protection.

1 The Hearing Conservation Program Handbook is Appendix F of the McMillen Jacobs Associates Underground Division’s comprehensive Safety Policy Manual. It is available in the common areas of each office/worksite for review by any interested and on the company’s intranet site.



2.0 Standard Overview Occupational noise exposure is regulated by Occupational Safety and Health Administration (OSHA) Standard 1910.95 (29 CFR 1910.95). The standard essentially implements a three-pronged approach to addressing industrial noise. The basic components are recognition, evaluation, and control. Additionally, training and record keeping are used to support each of the standard’s basic components. The importance of these elements cannot be underestimated.

Within the standard are two allowable noise exposure levels measured in decibels (dB). An action level (AL) is 85 dB and a permissible noise level is 90 dB. These noise levels are each the TWA of an employee’s exposure throughout an eight-hour work shift. Noise levels from 80 dB to 130 dB are measured in calculating a TWA. If a TWA is above 85 dB, inclusion in the Underground Division Hearing Conservation Program is required. Hearing protection is required if the TWA noise level exceeds 90 dB. Hearing protection devices (HPDs) must attenuate or reduce an employee’s noise exposure to <90 dBA TWA. Changes in a noise exposure time or noise-producing equipment may require additional noise evaluation. Any employee has a right to observe noise monitoring being conducted and will be notified if he or she works in areas where noise is ≥85 dB TWA.

Another aspect of 1910.95 is an audiometric testing program. This program is available to all employees with a noise exposure of ≥85 dBA TWA, at no cost to the employee. A baseline audiogram must be taken within six months after the employee is exposed to noise levels ≥85 dBA TWA. An employee must be aware that high noise levels (≥ 85 TWA) must be avoided 14 hours prior to examination (HPDs may be used). An annual audiogram is required for all employees in the program. The annual audiogram will be compared to the employee’s baseline audiogram, to determine if an STS has occurred. Hearing testing is performed by a licensed professional or certified technician (certified by the Council of Accreditation in Occupational Hearing Conservation). Figure 1 illustrates how to determine an employee’s participation in the Hearing Conservation Program.

An STS is a reduction in several frequencies of the many that an ear can hear. If an STS is diagnosed, an employee will be notified within 21 days and notified within 30 days if a retest is necessary. Employees with an STS must be refitted and trained again on the use of hearing protection. If further examination is necessary, the physician must be provided pertinent information. For employees with an STS, noise attenuation with an HPD must be <85 dBA TWA.

A training program is mandatory for all employees exposed to noise ≥85 dBA TWA. Training shall be repeated annually and includes the effects of noise on hearing and the correct use and purpose of hearing protection (advantages, disadvantages, types, selection, fitting, use, and care). Also included in the training shall be information on the purpose of audiometric testing and an explanation of the test procedures.

Record keeping is also a requirement of the standard. Files must be kept on exposure measurements, audiometric tests, and measurements of background sound pressure levels in audiometric testing rooms. This information must be made available to the employee and the Assistant Secretary of Labor (upon request). Noise exposure records must be retained for two years. Audiometric test records are retained for the duration of an affected employee’s employment.



Figure 1. Decision Tree for Determining Participation in the Hearing Conservation Program



3.0 Program Elements The program elements of the Hearing Conservation Program include exposure monitoring, medical surveillance, employee training, and record keeping. Specific details about each program element follow.

3.1 Exposure Monitoring Monitoring employee exposure to potential noise hazards will be conducted by an Underground Division supervisor. Employee noise exposure monitoring will be initiated:

Through routine noise hazard surveys (i.e., general surveys, inquiries, etc.)

When a change in an activity or process occurs that potentially increases the noise hazard to a level of 85 dBA or above (i.e., supervisor initiated)

When a potential “noise” problem is indicated on the Physician’s Examiners Report or Jobsite Safety Review form

If a potential noise hazard is identified in the initial exposure monitoring using a sound level meter, a more detailed investigation may follow, using a sound dosimeter to determine whether an employee should be included in the Hearing Conservation Program. A noise dosimeter will monitor an employee’s noise exposure for an entire shift. All employees who are exposed to an action level of 85 dBA TWA or higher will be notified of the noise hazard by the Underground Division and included in the Hearing Conservation Program.

Noise exposure limits, as specified by the Occupational Safety and Health Administration (OSHA), are shown in Table 1. The table shows the maximum time period allowable for the noise exposure level listed. The acceptable sound level (limit) is a TWA value. Impulsive or impact noise exposures above 140 dBA are not allowed by OSHA.

Table 1. OSHA Noise Exposure Limits

Time (Hours) Acceptable Sound Level (dBA) Time Weighted Average (TWA)

16.00 85 8.00 90 4.00 95 2.00 100 1.00 105 0.5 110

0.25 or less 115

3.2 Medical Surveillance Medical surveillance is the responsibility of the Underground Division, and will be coordinated with the worker and a local provider.



Specific sections of the OSHA standard (29 CFR 1910.95) are listed below for easy reference.2

Audiometric testing by a certified technician

A baseline audiogram must be provided within six months of initial employment, for all employees with noise exposures greater or equal to 85 dB TWA. Also, an annual audiogram is required.

An audiogram is evaluated to determine if an employee has an STS. A standard threshold shift (STS) is a change in hearing threshold relative to the baseline audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. In determining whether an STS has occurred, allowances may be made for the contribution of aging (presbycusis) to the change in hearing level by correcting the annual audiogram according to the procedure described in 29 CFR 1910.95 Appendix F: Calculations and Application of Age Corrections to Audiograms. [29 CFR 1910.95(g)(10)(ii)]. An employee must be notified of an STS within 21 days and must be re-tested within 30 days. A physician will then determine if a referral for a clinical audiological evaluation is necessary.

Audiometer and audiometric booth evaluations

Perform or secure daily, acoustic, and exhaustive calibrations as required.

3.3 Employee Training Specific issues will be addressed in the training, including the effects of noise on hearing. The purpose and an explanation of audiometric testing procedures will also be reviewed. An overview of hearing protection devices will be discussed, explaining their purpose, advantages, disadvantages, attenuation provided, and instructions on selection, fitting, use, and care.

Supervisors are required to conduct employee training at their work site. That training must orient the worker to:

Noise hazard areas and operations

The availability and location of hearing protection devices

Any warning signs or labels indicating the need for wearing hearing protection

A satisfactory location where hearing protection devices can be cleaned, if applicable

3.4 Record Keeping Records pertaining to the Hearing Conservation Program are categorized and filed as follows.

2 The OSHA Hearing Conservation Standard (29 CFR 1910.95) is available in its entirety on the Occupational Safety and Health Administration website at https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95.

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95



3.4.1 Hazard Inventory Form

A Job Hazard Analysis (JHA) or Job Safety Analysis (JSA) must include the risk to the employee and mitigation measures for employees exposed to loud noise sources.

3.4.2 Noise Exposure Records

The records are maintained on the employee’s jobsite, and are also filed and maintained by the Underground Division HR Department.

3.4.3 Audiometric Test Records

The records are filed by the audiometric technician and maintained by the Underground Division HR Department. The file shall include the employee’s name and job classification, date of examinations, examiner’s name, date of acoustic or exhaustive calibrations and the background sound pressure level of the audiometric testing booth.

3.4.4 Employee Training Records

The records are filed and maintained by the Underground Division HR Department.



4.0 Program Responsibilities In the McMillen Jacobs Associates Underground Division, a shared employee responsibility is required for ensuring workplace safety and meeting the requirements of the Hearing Conservation Program. These responsibilities are summarized below. The Site Safety Manager works in conjunction with the Underground Division Safety Committee, to facilitate and maintain the Hearing Conservation Program.

4.1 Employees Employees have responsibility for completing the Hazard Inventory Form and ensuring that they wear HPDs when required.

4.2 Supervisors Supervisors are responsible for implementing the Hearing Conservation Program requirements. A supervisor must report to the Site Safety Manager any potential noise hazards and ensure that employees wear their hearing protection when required. Training employees on their workplace noise hazards and providing Hearing Protection Devices (HPDs) to employees are two other areas of supervisory responsibility. Also, a supervisor must ensure that noise hazard areas or equipment requiring hearing protection have signs or are labeled.

4.3 Site Safety Manager The Site Safety Manager is responsible for maintaining Occupational Medicine record files for those employees in the Hearing Conservation Program. The Site Safety Manager will also route and maintain Hazard Inventory and Hazard Information Request forms, physician’s reports, and noise monitoring memos. Conducting exposure monitoring, notifying an employee’s supervisor of noise hazards, and maintaining noise exposure records are also the responsibility of the Site Safety Manager .



5.0 Hearing Protection It is the supervisor’s responsibility to make hearing protection devices accessible to employees, ensure they are used as required, and post “Hearing Protection Required” signs in a noise hazard area or “Hearing Protection Required” labels affixed to noise hazard equipment (see examples below).

5.1 Hearing Protection Devices Employees working with loud equipment or in noise hazard areas at or above 90 dBA TWA are required to wear hearing protection devices. Appropriate hearing protection must be provided to the employee free of charge. Several types of hearing protection meet acceptable protection criteria and are available at Central Stores, in the General Services Building.

5.2 Warning Signs Equipment generating noise levels >90 dBA and noise hazard areas must be identified through the sign(s) shown in Figure 2, which are to be posted in a noise hazard area or posted on loud equipment. Examples of loud equipment are included in Table 2.

Figure 2. Signs to be Posted in Noise Hazard Area or on Loud Equipment

Appropriate area warning signs and equipment stickers are available through the Site Safety Manager. Any modification in wording must be approved by Site Safety Manager .

Table 2. Examples of Loud Equipment

Air chisels Air hammers

Air nozzles Air wrenches

Compressor pumps Vacuum systems

Electric and power saws High pressure washers

Power lawn mowers Electric drills (hammer drills)

Garden tractors Power week trimmers

Grinding and emery wheels Heavy equipment



Attachment A Employee Notification – Hearing Retest

Employee Notification – Hearing Retest



To: From: Hearing Conservation Program Date: Subject Notification of Hearing Retest

The results of the recent hearing test you received at [location] indicate your hearing ability has changed from previous measurements. This hearing loss may have been caused by unusual noise exposure, current medication, common cold, or other conditions that affect hearing. Your hearing must be retested to determine whether your hearing change is persistent.

Your hearing retest has been scheduled for [date] at [time]. Call [contact name] to confirm this appointment ([contact number]).

It is important that you be in a quiet area for at least 14 hours prior to the hearing examination. If you must be in a noisy area (≥85 dBA),* it will be necessary for you to wear hearing protection.

Your supervisor should tell you if you need to wear hearing protection at work.

cc: [Supervisor]

* If you need to “raise your voice” in order to be heard by another person who is within 3 feet of you, the sound is probably above 85 dBA.

Hearing Conservation Program Handbook Employee Notification: Hearing Retest





Attachment B Employee Notification – Hearing Loss

Employee Notification – Hearing Loss



To: From: Hearing Conservation Program Date: Subject Notification of Hearing Loss (Standard Threshold Shift)

The results of the recent hearing screening you received at [location] indicate your hearing ability has changed from previous measureme4nts. Hearing loss was noted in: � left, � right, � both ear(s) (appropriate response checked). Your average hearing loss is [loss] decibels (dBA) and represents what is known as a permanent Standard Threshold Shift (STS). This degree of hearing loss is categorized as: � slight, � moderate, � high (appropriate response checked).

It is very important that you minimize your exposure to elevated noise levels. (If you have to raise your voice to be heard by another person who is within 3 feet of you, this would be considered an elevated noise level.)

You are required to wear hearing protection devices when measured noise levels exceed 85 dBA. Wearing hearing protection devices such as earplugs and/or earmuffs will reduce on-the-job noise levels to within acceptable limits and should minimize further loss of your hearing ability. Hearing protection devices are available from your supervisor and/or the site safety manager.

Please contact your supervisor, site safety manager, or the Safety Director if you have any questions related to the Hearing Conservation Program.

cc: [Supervisor]

Hearing Conservation Program Handbook Employee Notification: Hearing Loss





Attachment C Employee FAQs


Employee FAQs Hearing Conservation Program


A. What are the reasons for wearing a hearing protection device (HPD)?

1. Compliance with standards. Various locations and job assignments have been designated as “noise hazard” areas.

2. Noise exposure in the work area may damage hearing over a given time.

3. People with a known hearing loss may accelerate the loss rate if hearing protection is not worn.

4. Many employees notice a reduction of anxiety and fatigue at the end of the work day.

B. How do you ensure earplugs and/or earmuffs fit properly?

1. Different types are available.

2. Comfort and effectiveness are important (but if the earplugs or earmuffs are not effective, comfort means nothing).

3. Your voice will sound “muffled” or “hollow” (similar to how voice sounds when talking into a hollow tube).

4. Insertion technique:

a. Allow time for foam plugs to expand after insertion. See instructions on package.

b. The earmuff cushion should fit comfortably (make sure it is always flexible and forms a good seal around the ear).

C. What is the proper cleaning and care of the hearing protection device (HPD)?

1. Expandable foam: Dispose of when dirty.

2. Preformed: Wash with warm water and mild soap.

3. Earmuffs: Clean cushions with damp cloth rinsed in mild soapy water.

4. Do not tamper with plugs or earmuffs: Drilling or poking holes in them destroys their effectiveness. Remember, it is your hearing that will suffer.

D. Who do you contact when you have problems or need replacements?

Hearing Conservation Program Handbook Employee FAQs


1. Immediate supervisor (for replacement of hearing protection devices).

2. Site safety manager (for changes in procedure, equipment, or other noise-related problems; replacement of hearing protection devices). The designated person coordinating the Hearing Conservation Program is the Safety Director.

3. Doctor (for hearing problems or discomfort/persistent ear pain, drainage, dizziness, or ringing in the ears). Site safety manager (for changes in procedure, equipment or other noise-related problems). The designated person coordinating the Hearing Conservation Program is the Safety Director.

E. What happens if you fail to wear HPDs as required:

1. Disciplinary action will be taken as required (flagrant and purposeful violation may lead to termination).



Attachment D Employee Training Handout


Employee Training Handbook Hearing Conservation Program


The following points of review are included in employee training for the Hearing Conservation Program.

A. The Effects of Noise on Hearing

Hearing can be damaged by loud noise. Noise can destroy tiny “hair cells” inside your inner ear that cannot be replaced. The noise does not have to be a constant sound to damage hearing. Short loud bursts are damaging as well. Your supervisor should tell you which work areas may cause hearing damage. If you have not been informed, ask. You should protect your hearing by wearing earplugs or earmuffs in noisy areas.

B. Hearing Protection Devices (HPDs)

1. Advantages and Disadvantages of the Different Types

Earmuffs are simple to wear and are fairly comfortable. They are easy to clean. However, eyeglass bars, hair, and other obstructions reduce protection provided because they break the seal between the head and the earmuff.

Earplugs also provide hearing good protection. However, they must be inserted correctly. For some, slight wearing discomfort may be expected until the person becomes accustomed to the fit.

2. Types of Hearing Protection Provided

HPD attenuation or the ability to reduce noise from entering the ear is defined as a noise reduction rating (NRR). The higher the NRR, the better the HPD. Earplugs and earmuffs are available from your supervisor or the Safety Manager and have different NRRs (depending on the brand). Check with your supervisor or the Safety Manager if you have any questions about the appropriate HPD to wear in your workplace.

3. Selection and Fitting of Hearing Protection Devices

HPDs are available through your supervisor or from the Safety Manager. Follow the manufacturer’s specific instructions to ensure a proper fit. If you experience difficulty in fitting or wearing an HPD, contact the Safety Manager.

General Instructions:

EARMUFFS

Earmuffs should be placed over the ears such that a good seal is formed between the head and the earmuff cushion.

Hearing Conservation Program Handbook Employee Training Handbook


PLUGS

To insert earplugs, reach over the head with your opposite hand and pull the ear up and outward to open the ear canal. Holding the plug between thumb and forefinger of the hand, insert the plug into the ear with finger pressure and a slight turning motion until a seal is made. (Expandable “foam” plugs will need to be “rolled” prior to insertion into the ear canal and held in place for about 30 seconds while the foam expands).

4. Proper Use and Care of HPDs

Clean your hands prior to inserting plugs into the ear canal. Reusable plugs should be washed after each use. Mildly warm, soapy water will suffice. Rinse with clean water. Disposable plugs must be discarded if they become dirty. Do not tamper with the design of a plug or earmuff.

Store plugs and earmuffs in their original container or a clean plastic bag. Contact the Safety Manager if you experience continued difficulty in HPD use and/or care.

C. Audiometric Testing

1. Purpose of Hearing Test

The test is conducted to determine if your ability to hear has changed since your last examination. In other words, it is a way to ensure adequate steps are being taken to protect your hearing. Report any hearing-related problems to your supervisor and the Safety Manager.

2. Explanation of Testing Procedures

During the test, an “audiometer” is used to produce special frequencies of sound. The sound that you hear in the earphones will vary in loudness and “pitch.” The machine records when an employee indicates that he or she “hears” the sound. A record (audiogram) is made of the lowest level (threshold) of hearing. A comparison of this record is made with an average person’s hearing. All test records for an employee are kept and compared to see if a change in hearing has occurred from year to year. You will be notified if any significant changes occur in your hearing ability.



Appendix G Respiratory Protection Program Handbook


Respiratory Protection Program Handbook

January 2020

Underground Division Safety Policy Manual Respiratory Protection Program Handbook


Table of Contents 1.0 Introduction ...................................................................................................................................... 1

2.0 Purpose of Program ......................................................................................................................... 1

2.1 Responsibilities ...................................................................................................................... 1

3.0 Use of Respiratory Protective Equipment ........................................................................................ 2

4.0 Training ............................................................................................................................................ 3

5.0 Respiratory Safety ............................................................................................................................ 4

6.0 Medical Determination ..................................................................................................................... 5

6.1 Additional Medical Evaluations .............................................................................................. 6

6.2 Administration of the Medical Questionnaire and Examinations ............................................ 6

7.0 Respirator Selection ......................................................................................................................... 6

7.1 Air Purifying Respirators (APRs) ............................................................................................ 7

7.2 Supplied Air Respirators (SARs) ............................................................................................ 8 7.2.1 Protection Factors.................................................................................................... 9

7.2.2 Respirator Leakage ................................................................................................. 9

7.2.3 Filter Obstruction ................................................................................................... 10

8.0 Respirator Fit Testing ..................................................................................................................... 10

8.1 Fit Checks ............................................................................................................................ 10

9.0 Identification of Filters and Cartridges ........................................................................................... 10

9.1 Respirator Filter and Canister Replacement ........................................................................ 11

9.2 Cartridge and Filter Change Schedule ................................................................................. 11

10.0 Procedures for IDLH Atmospheres ................................................................................................ 12

11.0 Cleaning and Disinfecting .............................................................................................................. 12

12.0 Respirator Inspection ..................................................................................................................... 13

13.0 Respirator Storage ......................................................................................................................... 13

14.0 Program Evaluation ........................................................................................................................ 14

15.0 Recordkeeping ............................................................................................................................... 14

16.0 Specific Exposures ......................................................................................................................... 14

List of Figures Figure 1. Air Purifying Respirator (half mask) ............................................................................................... 7



Figure 2. Powered Air Purifying Respirator ................................................................................................... 7

Figure 3. Supplied Air Respirators ................................................................................................................ 8

Figure 4. Cartridges and Filters .................................................................................................................. 11

Attachments Attachment A Potential Exposures Common within McMillen Jacobs Associates’ Scope of

Operations



Distribution To: Employees McMillen Jacobs Associates Underground Division Office Managers McMillen Jacobs Associates Underground Division From: Dan Adams McMillen Jacobs Associates Prepared By: Bill Mitchell, Environmental Health and Safety Director McMillen Jacobs Associates Safety Committee: Ted DePooter, Sarah Wilson McMillen Jacobs Associates Underground Division Reviewed By: Carol Ravano, Julie McCullough McMillen Jacobs Associates Underground Division


1 January 2020 Bill Mitchell, Ted DePooter, Sarah Wilson 0 August 2017 Bill Mitchell, Ted DePooter (First Issuance)



1.0 Introduction The McMillen Jacobs Associates Underground Division has developed the following Respiratory Protection Program,1 in compliance with Title 8 of the California Code of Regulations (T8 CCR), General Industry and Construction Safety Orders (CSO §§1528, 1529, 1530, and 1531), and OSHA 1910.134, CSA Standard Z94.4.

Proper respirators are required in an atmosphere that could contain less than 19.5% or more than 23.5% oxygen, and in atmospheres that could contain dusts, fibers, mists, fumes, gases, or vapors at harmful concentrations.

2.0 Purpose of Program In the Respiratory Protection Program, hazard assessment and selection of proper respiratory protective equipment (RPE) is conducted in the same manner as for other types of personal protective equipment (PPE). In the control of those occupational illnesses and diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution with less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used.

2.1 Responsibilities McMillen Jacobs Associates’ Environmental Health and Safety Director (Safety Director) is the designated Program Administrator and is responsible for establishing the Underground Division Respiratory Protection Program. Responsibilities include implementation of the program and coordination of the following:

1. Required medical evaluations of employees required to use respirators (medical surveillance)

2. Coordination of the selection and acquisition of respirators

3. Coordination of respirator face-piece fit tests and face-piece seal fit checks

4. Cleaning and sanitizing requirements

5. Storage, inspection, maintenance, and replacement of respirators

6. Enforcement of all provisions of this program

7. Training for affected employees

1 The Respiratory Protection Program Handbook is Appendix G of the McMillen Jacobs Associates Underground Division’s Safety Policy Manual. The handbook is available in the common areas of each office/worksite for review by any interested employee and on the company’s intranet site.



8. Monitoring the effectiveness of the program

All employees will be responsible for following the requirements of the Respiratory Protection Program.

The Underground Division will obtain the services of a designated medical provider to meet the medical requirements of this program. The firm will cover the costs associated with these services.

The services of a designated/qualified provider will be used for meeting the requirements for fit testing, assisting with selection of equipment, and documentation of the fit test and equipment used.

3.0 Use of Respiratory Protective Equipment Respiratory protective equipment is used only when it is clearly impractical to use engineering and administrative controls for reducing employee exposure to acceptable levels, or while engineering controls are being installed, maintained, or repaired, or in emergency situations.

The Program Administrator shall authorize voluntary use of respiratory protective equipment as requested by all other (other = those not required to wear respiratory protective equipment under this plan) workers on a case-by-case basis, depending on specific workplace conditions and the results of medical evaluations.

The Program Administrator will provide all employees who voluntarily choose to wear the above respirators with a copy of Appendix D of the OSHA Respiratory Protection Standard. (Appendix D details the requirements for voluntary use of respirators by employees.) Employees who choose to wear a half-mask face-piece APR must comply with the procedures for the Medical Evaluation, Respirator Use, Cleaning, Maintenance, and Storage portions of this program.

Appendix D to Sec. 1910.134 (Mandatory) Information for Employees Using Respirators When Not Required Under the Standard

Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.

You should do the following:

1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations.



2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you.

3. Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.

4. Keep track of your respirator so that you do not mistakenly use someone else's respirator.

[63 FR 1152, Jan. 8, 1998; 63 FR 20098, April 23, 1998]

Only authorized, medically evaluated, fitted and trained employees may use respirators. These employees may only use the brand, type and size of respirator they have been authorized, trained, and properly fitted for.

A preauthorization/certification by a qualified physician will be required and maintained. Any changes in an employee’s health or physical characteristics must be reported and evaluated by a qualified physician.

4.0 Training Effective training for employees who are required to use respirators is essential. The training must be understandable. Training will be provided before requiring the employee to use a respirator in the workplace. Respirator training must cover:

1. Appropriate hazard communication: Why a respirator is needed, the nature of the hazard, possible consequences if respirators are not used, and the requirements of the Respiratory Protection Program.

2. Limitations for the type of respirator being used.

3. Procedures for respirator inspection, maintenance, donning, wearing, and removing, and performing fit checks.

4. Qualitative or quantitative fit test procedures, as appropriate.

5. How to sanitize and store respirators to prevent deterioration and contamination.

6. Opportunities to practice wearing respiratory equipment: In normal air for an adequate familiarity period, and also in a test atmosphere, such as one generated by smoke tubes or isoamyl acetate.

7. How to use the respirator effectively in emergency situations, including situations in which the respirator is not working properly.



8. How to recognize medical signs and symptoms that may limit the employee from wearing a respirator.

Training should also include:

1. Why engineering controls are not feasible or not adequate to control the hazard, and what efforts are being made to reduce the need for respirator use.

2. An opportunity for employees to demonstrate that they fully comprehend the information presented.

Training is required before initial use, or when work assignments change and have different hazards and respirator requirements. Retraining is required at least every 12 months thereafter. This annual retraining will refresh employees’ memory on the information and skills they need to use a respirator correctly. It also gives them a chance to don the respirator, and ask questions and discuss worksite-specific respirator use with the instructor.

The employee is responsible for correctly using a respirator and making sure it remains in good condition. Any defects or damage noted must be reported to the supervisor or management immediately.

The Underground Division may utilize the services of a qualified provider to assist with training and documentation requirements. Records will be maintained by the Underground Division as required.

5.0 Respiratory Safety The following guidelines are established to help ensure the safe use of respiratory equipment:

Wear only the respirator you have been fitted for and instructed to use.

Wear the correct respirator and filters for the particular hazard.

Check the respirator for a good fit before each use. Positive and negative fit checks should be conducted.

Check the respirator for deterioration before and after use. Do not use a defective respirator.

Recognize indications that cartridges and canisters are at their end of service. If in doubt, change the cartridges or canisters before using the respirator.

Practice moving and working while wearing the respirator so that you can get used to it.

Clean the respirator after each use, thoroughly dry it, and place the cleaned respirator in a sealable plastic bag.

Store respirators carefully in a protected location away from excessive heat, light, and chemicals.

Only the proper prescribed respirator or self-contained breathing apparatus (SCBA) may be used for the job or work environment. Air cleansing respirators may be worn in work environments when oxygen levels are between 19.5 and 23.5 percent and when the appropriate air-cleansing canister—as determined by the manufacturer and approved by the National Institute for



Occupational Health (NIOSH) or the Mine Safety & Health Administration (MSHA)—for the known hazardous substance is used. SCBAs will be worn in oxygen deficient and oxygen rich environments (below 19.5 percent or above 23.5 percent oxygen).

Only SCBAs will be used in oxygen deficient environments, environments with an unknown hazardous substance or unknown quantity of a known hazardous substance, or any environment that is determined “Immediately Dangerous to Life or Health” (IDLH).

Employees with respirators loaned on “permanent checkout” will be responsible for their sanitation, proper storage, and security. Respirators damaged by normal wear will be repaired or replaced by the company when returned.

All respirators will be stored in a clean, convenient, and sanitary location.

A “buddy system” detail will be used in the event employees must enter a confined space, work in environments with hazardous substances dangerous to life or health should respiratory protective equipment (RPE) fail (a SCBA is required in such an environment), and/or conduct a hazardous material (HAZMAT) entry. The buddy system requires a Safety Watchman with constant voice, visual, or signal line communication. Employees will follow the established site-specific Emergency Response Program and/or Confined Space Entry Program when applicable.

Management will establish and maintain surveillance of jobs and work place conditions and degree of employee exposure or stress to maintain the proper procedures and to provide the necessary RPE.

Management will establish and maintain safe operation procedures for the safe use of RPE, with strict enforcement and disciplinary action for failure to follow all general and specific safety rules.

6.0 Medical Determination Even with the appropriate equipment provided and adequate training given, an employee’s health status must be considered before allowing respirator fit testing and use. Medical conditions—such as pulmonary deficiencies, hearing diseases, anemia, hemophilia, and vision correction needs—may affect an employee’s ability to wear and work with a respirator. No employee will be assigned work requiring a respirator without the employee first receiving a physical examination and approval by a licensed physician.

The firm will assist the employee in finding a physician in the event that his or her normal primary care giver is not available. The employee will be provided a medical questionnaire by this physician, and the physician will determine the medical criteria that apply to the employee who must wear the respirator. Upon request, a copy of this Respiratory Protection Program Handbook will be provided to the physician for reference.

The Underground Division will obtain a written recommendation from the physician regarding the employee's ability to use the respirator. The following medical information will be obtained:



Any limitations on respirator use related to the medical condition of the employee, or related to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator.

The need, if any, for follow-up medical evaluations.

A statement that the physician has provided the employee with a copy of the physician’s written recommendation.

If the respirator is a negative pressure respirator and the physician finds a medical condition that may place the employee’s health at increased risk if such a respirator is used, the firm shall provide an air purifying respirator (APR, see Section 7.1 below). This is only if the physician’s medical evaluation finds that the employee can use such a respirator. If a subsequent medical evaluation finds that the employee is medically able to use a negative pressure respirator, then the firm is no longer required to provide an APR.

6.1 Additional Medical Evaluations At a minimum, additional medical evaluations will be required if:

An employee reports medical signs or symptoms that are related to the ability to use a respirator.

A physician, supervisor, or the Program Administrator informs management that an employee needs to be reevaluated.

Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation.

A change occurs in workplace conditions (e.g., physical work effort, protective clothing, and temperature) that may result in a substantial increase in the physiological burden placed on an employee.

6.2 Administration of the Medical Questionnaire and Examinations The medical questionnaire and examinations shall be administered confidentially during the employee’s normal working hours. The medical questionnaire shall be administered in a manner that ensures that the employee understands its content. The employee will be provided an opportunity to discuss the questionnaire and examination results with the physician.

7.0 Respirator Selection The type of respirator selected is dependent upon the type of work being performed, the airborne hazard, and the available oxygen. All selected respirators are NIOSH-certified.

The Underground Division may utilize the services of a qualified consultant to assist with identification of potential hazards and the type of respirators required.

Respirators are typically classified into two basic groups: air purifying respirators (APRs) and supplied air respirators (SARs).



7.1 Air Purifying Respirators (APRs) One type of APR removes particles of dust, fibers, fume, or mist from the air as the contaminant moves through a filter. Another type of APR removes certain vapors and gases by absorbing or reacting with the contaminant, and lets clean air enter the face piece. Combination APRs remove both particulates and vapors.

Contaminated air may be drawn through the APR filter by two different means. The most common means relies on the respirator wearers to use their own breathing to cause the air to pass through the filter, by creating a negative pressure inside the respirator face piece (Figure 1). The other method is to use an air pump that delivers air at a slight positive pressure through the filter to the inside of the face piece (Figure 2). This type of APR is a powered air-purifying respirator (PAPR).

Figure 1. Air Purifying Respirator (half mask)

Figure 2. Powered Air Purifying Respirator

The kind of filter used in an APR depends upon the contaminant it is designed to remove. For example, a filter designed to remove organic vapors usually contains activated charcoal in a cartridge or canister attached directly or by a breathing tube to the respirator face piece. A filter designed to remove metal fumes can constitute the entire face piece, or be attached directly, or by breathing tubes to the respirator face piece.



Some APRs have an end-of-service indicator for when the filter system is expended and the filter must be changed.

APRs have limitations and are not approved for the following uses:

When the contaminant has poor warning properties and is not easily recognized by taste, smell, or irritation at or below its permissible exposure limit.

In oxygen deficient or enriched atmospheres. APRs do not supply oxygen, or filter out high levels of oxygen or other gases.

When the contaminant concentration exceeds the NIOSH/MSHA maximum designated use concentration for the respirator.

When the service life indicator shows that the filter system is expended and the filter must be changed, or the shelf-life date for the filter has expired.

In atmospheres that could become immediately dangerous to life or health—where a short exposure could cause death, injury, illness or delayed reaction.

7.2 Supplied Air Respirators (SARs) Supplied air respirators (SARs) provide regulated breathing air from a source other than the air in the contaminated work area. An SAR consists of a face piece and equipment for supplying the breathing air by compressors or pressurized cylinders.

An air-line SAR provides regulated air to the face piece through a hose by means of a remotely located pressurized cylinder or compressor (Figure 3, left). Another type of SAR provides breathing air from a self-contained breathing apparatus (SCBA), which is a pressurized cylinder worn by the respirator wearer (Figure 3, right).

Figure 3. Supplied Air Respirators

One type of SCBA cylinder—such as a 30-minute air pack—provides enough air to the user for entry into and exit from a contaminated atmosphere to perform work. A special type of SCBA is for escape purposes only, and may contain enough air for five to ten minutes. The SCBA approved for escape only must never be used to enter a contaminated area to perform work, or to enter an area for rescue. SCBAs (or air-line SARs) with auxiliary escape SCBA attached are the only respiratory protective equipment approved for entry into an atmosphere that is immediately dangerous to life and health, such as a confined space, or atmospheres of unknown content or concentration.



No respirator is approved for use in an atmosphere containing more that 25 percent of the contaminant’s lower explosive limits.

7.2.1 Protection Factors

Different respirators offer different levels of protection. NIOSH has established protection factors for every type of respirator to indicate how much protection a specific respirator type provides.

The respirator protection factor (PF) is the ratio of contaminant concentration level outside the respirator to the expected possible concentration inside the respirator. The higher the PF value for a respirator, the less contaminant leakage into its face piece is expected. There is a variety of PFs for different types of respirators. PFs are approximate values and apply only when the wearer has been properly fitted, tested, and trained, and when the respirator is correctly worn and kept in proper operating condition.

As a general rule, when a contaminant has a specific permissible exposure limit (PEL) listed in the regulatory standard, the maximum contaminant level at which a respirator may be used is the lower value of the PEL multiplied by the PF for the respirator, or the maximum use concentration specified on the NIOSH/MSHA approval label.

7.2.2 Respirator Leakage

For negative pressure APRs (see Section 7.1), the user causes air to enter the filter with each breath. Thus, every time the wearer inhales, the pressure created inside the face piece is negative in relation to the contaminated atmosphere outside the face piece. If there are leaks around the face seal, the negative pressure inside the respirator can draw contaminated air into the face piece. When the respirator wearer begins to taste, smell, or experience irritation from contaminated air, this indicates that leakage or a breakthrough has occurred.

In the case of an APR, a breakthrough may mean that the filter, canister, or cartridge needs replacing; there is mechanical failure of the respirator valves; a breathing tube connection is loose; or there is a leak at the face piece seal.

In the case of an SAR, breakthrough may mean a failure of valves, regulators, hoses, breathing tubes or fittings, loose connections, or a leak at the face piece seal.

A poor face seal may be the reason for leakage of contaminants into the face piece of any APR or SAR. A poor face seal may be caused by weight gain or loss that changes the physical features of the wearer's face.

Leakage can also be caused by debris and dirt buildup, excessive perspiration, use of Vaseline, a growth of beard or other facial hair, or wearing any item that interferes with the face piece seal.

Missing, worn, or deteriorated respirator parts, such as missing exhalation valves or insufficiently tightened cartridges, may cause leakage of a contaminant into the face piece.

Contaminant leakage into the face piece of an SAR may be due to cracked, deteriorated, or loose connections between hoses and breathing tubes, or to malfunctioning regulators or improperly seated face



piece lenses. Additional leakage of contaminants into the face piece may occur if the wearer over breathes the regulated air supply, thereby creating a negative pressure inside the face piece.

7.2.3 Filter Obstruction

All APRs for dust, fume, and mist have filters that become obstructed or clogged by particulates, and which must be changed when it becomes hard to breathe through the filter.

PAPRs have the same use limitations as negative pressure or nonpowered air purifying respirators. One disadvantage in using PAPRs is that the constant flow of air through purifying filters decreases the amount of time the filter can be used. This is because the greater air flow and collection of contaminants on the filter cause greater loading on the filter.

8.0 Respirator Fit Testing The Underground Division utilizes the services of a licensed third party to perform certified fit testing annually to make sure its employees wear respirators in a test atmosphere to achieve proper face fit. Employees are required to conduct a fit check before each respirator use (see Section 8.1, below).

Respirator face pieces are made in a variety of sizes to fit a wide range of face shapes. Some employees, however, are not able to achieve a good fit, and they cannot be permitted to use respirators. Facial scars, beards, whiskers, sideburns, large moustaches, and weight gains/losses interfere with proper fit of a respirator face piece seal. This problem is especially acute for negative pressure respirators.

8.1 Fit Checks With the exception of hoods and certain powered air purifying respirators, a fit check must be conducted by the wearer every time he or she puts the respirator on. A point-of-use fit check must be made to determine whether respirator valves are working properly, and how well the face piece fits and seals out contaminants. Positive pressure and negative pressure fit checks are indicators of respirator operability and face piece fit.

Fit checks are conducted during initial selection and training, and every time an employee puts on a respirator before entering a contaminated atmosphere. The employee must not use a respirator unless the checks have been satisfactorily completed.

9.0 Identification of Filters and Cartridges All filters and cartridges shall be labeled and color-coded with the NIOSH-approved label. The label is not removed and must remain legible (Figure 4).



Figure 4. Cartridges and Filters

9.1 Respirator Filter and Canister Replacement An important part of the Respiratory Protection Program is identification of the useful life of canisters and filters used on air-purifying respirators. End-of-service life occurs when a respirator no longer works correctly. It is when the filtering medium can no longer provide the expected level of protection from harmful air contaminants, has reached its capacity for capture and retention of the contaminant, when breathing while wearing the respirator becomes too difficult, or when the respirator becomes damaged or contaminated, or the integrity of the respirator is no longer intact.

End-of-service-life indicators: Some cartridges have indicators, while with others like the N95 filter the “indicator” may be the appearance, whether the respirator is damaged, contaminated with visible blood or body fluids, or misshapen. For other types of respirators there are specific indicators integrated into the device. All self-contained breathing apparatuses have an alarm that tells the wearer that he/she is going to run out of air from the cylinder and that the wearer must leave the contaminated area. Some gas- and vapor-removing air-purifying respirators are also equipped with end-of-service-life indicators (ESLIs). The ESLIs are usually specific to only one contaminant. An ESLI gives the wearer an indication, often a color change, that the contaminant will no longer be able to be removed by the cartridge or canister and that the cartridge or canister should be replaced.

9.2 Cartridge and Filter Change Schedule A stock of spare filters and cartridges shall be maintained to allow immediate change when required or desired by the employee. Cartridges and filters shall remain in their original sealed packages until needed for immediate use.

Cartridges shall be changed based on the most limiting factor below:

Prior to expiration date

Manufacturer’s recommendations for use and environment

After each use

When requested by employee

When contaminant odor is detected

When restriction to air flow has occurred as evidenced by increased effort by user to breathe normally

Filters shall be changed based on the most limiting factor below:

Prior to expiration date



Manufacturer’s recommendations for the specific use and environment

When requested by employee

When contaminant odor is detected

When restriction to air flow has occurred, as evidenced by increased effort by user to breathe normally

When discoloring of the filter media is evident

NIOSH has developed a computer tool for estimating breakthrough times and service lives of air-purifying respirator cartridges manufactured to remove toxic organic vapors from breathed air. This tool can be used with the cartridge/canister manufacturer’s recommendations for multi-gas use of the specific canister/cartridge being used. Because of the complexity of factors involved in determining canister change-out schedules, the user must consult the Safety Director for assistance.

10.0 Procedures for IDLH Atmospheres For all IDLH atmospheres, the firm shall ensure that:

One employee—or when needed more than one employee—is located outside the IDLH atmosphere.

Visual, voice, or signal line communication is maintained between the employee(s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere.

The employee(s) located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue.

The firm or designee is notified before the employee(s) located outside the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue.

The firm or designee authorized to do so by the firm, once notified, provides necessary assistance appropriate to the situation.

Employee(s) located outside the IDLH atmospheres will be equipped with:

o Pressure demand or other positive pressure SCBAs, or a pressure demand or other positive pressure supplied-air respirator with auxiliary SCBA; and either

• Appropriate retrieval equipment for removing the employee(s) who enter these hazardous atmospheres where retrieval equipment would contribute to the rescue of the employee(s) and would not increase the overall risk resulting from entry; or

• Equivalent means for rescue where retrieval equipment is not required.

11.0 Cleaning and Disinfecting Respirators must be maintained in a clean and sanitary condition to ensure that contaminants do not cause deterioration or malfunction of parts, and to prevent dermatitis developing among employees using the



equipment. A respirator must not be used by another employee until it has been thoroughly cleaned and sanitized. Procedures for cleaning a cartridge-type respirator are:

Remove the cartridge, gaskets, valves, and straps from the respirator.

Wash the respirator body in a mild soap solution or the cleaning solution recommended by the manufacturer.

Thoroughly rinse the respirator to remove any residue. Failure to remove soap and properly sanitize the respirator may cause dermatitis and/or eye irritation.

Air dry the respirator in an area away from contaminants. Do not dry respirator at temperatures above manufacturer’s recommendation.

12.0 Respirator Inspection All respirators will be inspected before use. Damaged respirators will be replaced. Respirators shall be inspected as follows:

All respirators used in routine situations shall be inspected before each use and during cleaning.

All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer’s recommendations, and shall be checked for proper function before and after each use.

Emergency escape-only respirators shall be inspected before being carried into the workplace.

Respirator inspections include the following:

A check of respirator function, tightness of connections, and the condition of the various parts, including, but not limited to, the face piece, head straps, valves, connecting tube, and cartridges, canisters or filters.

13.0 Respirator Storage Respirators are to be stored as follows:

All respirators shall be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the face piece and exhalation valve.

Emergency respirators shall be:

Kept accessible to the work area.

Stored in compartments or in covers that are clearly marked as containing emergency respirators.

Stored in accordance with any applicable manufacturer instructions.



14.0 Program Evaluation Evaluations of the workplace are necessary to ensure that the Underground Division Respiratory Protection Program, as laid out in this handbook, is being properly implemented. This includes consulting with employees to ensure that they are using the respirators properly. Evaluations shall be conducted as necessary to ensure that the provisions of the current version of the program (as referenced by the date of this handbook and the latest date in the Revision Log of this Handbook) are being effectively implemented and that the Respiratory Protection Program continues to be effective. Program evaluation will include discussions with employees required to use respirators to assess the employees’ views on program effectiveness and to identify any problems. Any problems that are identified during this assessment shall be corrected. Factors to be assessed include, but are not limited to:

Respirator fit (including the ability to use the respirator without interfering with effective workplace performance)

Appropriate respirator selection for the hazards to which the employee is exposed

Proper respirator use under the workplace conditions the employee encounters

Proper respirator maintenance

15.0 Recordkeeping The Underground Division will retain written information regarding medical evaluations, fit testing, and the Respirator Protection Program. This information will facilitate employee involvement in the program, assist the Underground Division in auditing the adequacy of the program, and provide a record for compliance determinations by OSHA.

16.0 Specific Exposures Refer to Attachment A for information on potential exposures common within the scope of operations performed by Underground Division.



Attachment A Potential Exposures Common within the Underground Division’s Scope of Operations

Underground Division Safety Policy Manual Potential Exposures Common within the Underground Division’s’ Scope of Operations




Potential Exposures Common within the Underground Division's

Scope of Operations


The following information is designed to identify and address the potential exposures common within the scope of operations performed by the Underground Division.

Lead:

The permissible exposure limits (PELs) for airborne lead are 0.05 milligram per cubic meter of air (mg/m3) and an action level of 0.03 mg/m3, both are as an 8-hour time-weighted average (TWA).

When lead is present in a work environment, the following is required:

1. Lead dust must be controlled by HEPA vacuuming, wet cleanup, or other effective methods.

2. Washing facilities must be accessible (supplied with clean water and soap).

3. Training is mandatory. If you have not been trained to work with lead, advise your supervisor immediately.

4. Use of appropriate PPE is mandatory. Do not work in an environment where lead is present, unless properly equipped and trained to do so.

Trigger tasks are certain highly hazardous tasks that carry the presumption of airborne exposure above the PEL. They require special protective measures until it is determined that worker airborne exposures to lead are below the PEL.

Trigger tasks include:

Level 1: Manual demolition; spray painting; manual scraping or sanding; using a heat gun; and power-tool cleaning with dust collection system. Minimum Respirator Requirement: A half-mask respirator with N-100, R-100, or P-100 filters.

Level 2: Using lead-containing mortar; burning lead; rivet busting, cleaning power tools without a dust collection system; using dry, expendable abrasives for clean-up procedures; moving or removing an abrasive blasting enclosure. Minimum Respirator Requirement: A full-face mask respirator with N-100, R-100, or P-100 filters; an air-supplied hood or helmet; or a loose-fitting hood or helmet with a powered air-purifying respirator with N-100, R-100, or P-100 filters.

Level 3: Abrasive blasting; welding, cutting; or torch burning on structures. Minimum Respirator Requirement: A half-mask, supplied air respirator (SAR) operated in a positive pressure mode.

Protective requirements for all trigger tasks and any other task that may cause a lead exposure above the PEL include the following:

1. Respirators, protective equipment, and protective clothing

2. Clothing change areas and a shower

3. Initial blood tests for lead and zinc protoporphyrin

Respiratory Protection Program Handbook Potential Exposures Common within the Underground Division’s Scope of Operations


4. Basic lead hazard, respirator, and safety training

5. Establishment of a regulated area and warning sign

Silica Dust:

Construction work that involves exposure to airborne sand and rock dust can expose employees to crystalline silica. Exposure has been shown to cause silicosis (lung disease).

Hazardous activities include abrasive blasting with sand and loading, dumping, chipping, hammering, cutting, and drilling of rock, sand, or concrete.

Before beginning work that could expose employees to crystalline silica, the following must be performed:

Measure and establish method to control exposure to airborne contaminants.

Provide workers with training materials and information on exposures.

Operations in which employees may be repeatedly exposed to rock dust or sand should be evaluated by a qualified industrial hygienist.

When performing abrasive blasting, employees will be required to use a respirator appropriate for required protection, including head, neck and shoulder protection.

In accordance with NIOSH recommendations, the following measures to reduce exposures will be adhered to:

o Recognize when silica dust may be generated and plan ahead to eliminate or control the dust at the source.

o Wet sawing and drilling will be used as an engineering control to protect the employee, and adjacent workers, from exposure.

o Routinely maintain dust control systems to keep them in good working order.

o Practice good personal hygiene to avoid unnecessary exposure to other worksite contaminants such as lead.

o Wear disposable or washable protective clothes at the worksite.

o Shower (if possible) and change into clean clothes before leaving the worksite to prevent contamination of cars, homes, and other work areas.

o Post “Keep Out” signs to mark the boundaries of work areas contaminated with respirable crystalline silica.



Appendix H Lock-Out/Tag-Out Safety Plan


Lock-Out/Tag-Out

Safety Plan

January 2020

Underground Division Safety Policy Manual Lock-Out/Tag-Out Safety Plan


Table of Contents 1.0 Introduction .......................................................................................................................................... 1

1.1 Application .............................................................................................................................. 1

1.2 Authority ................................................................................................................................. 1

1.3 Roles and Responsibilities ..................................................................................................... 1

2.0 Definitions ............................................................................................................................................ 2

3.0 Requirements ...................................................................................................................................... 3

3.1 Training Required Prior to On-Site Work ............................................................................... 3

3.2 Planning the Work .................................................................................................................. 4

3.3 Field Work .............................................................................................................................. 4

4.0 References .......................................................................................................................................... 4





3 January 2020 Bill Mitchell, Ted DePooter, Sarah Wilson 2 August 2017 Bill Mitchell, Ted DePooter 1 June 2014 Blake D. Rothfuss 0 June 2013 Blake D. Rothfuss



1.0 Introduction To perform field investigations, inspections, condition assessments, and construction resident engineering, McMillen Jacobs Associates Underground Division employees are asked to work in confined spaces. Such work often requires the temporary isolation of the confined space from stored energy system/devices, machinery, and equipment. The Lock-Out/Tag-Out (LOTO) program of contractors and owners in use on a jobsite affects Underground Division employees working on that jobsite. It is required that this program be compliant with the jurisdictional authority for the operation. Consultation with contractors or owners is required so that our employees can obtain any preparations for shutdown; inspection procedures and results of last inspection; machine or equipment isolation; and any device, machine, or structure that might store energy or has the potential for energy accumulation. Further discussion of the contractor’s or owner’s program should include a verification that the devices used are affixed in a safe “off” position and locked. Tag-out devices are affixed at the same point as the lock-out devices, and when that is not possible, they are in an obvious position as close to the tag-out device as possible. The purpose of this consultation is to make Underground Division employees as fully aware as possible of procedures and methods used in a LOTO area that are not specifically performed by them, before they enter the LOTO area.

1.1 Application This Lock-Out-Tag-Out Safety Plan1 is applicable to all Underground Division employees and its subcontractors working in or around energized machinery or equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm an employee. It may also be referred to as Control of Hazardous Energy Releases and Lock-Out/Tag-Out/Block-Out Procedures.

1.2 Authority Permit-Required Confined Space Operations are regulated by the 29 CFR 1910.147 in the United States and multiple state-specific safety regulations. In Canada, Australia, and New Zealand, each country, state and province have similar but specific safety regulations for confined space operations.

The Fed-OSHA and state-OSHA agencies are able to levy fines against both an employee and the company if they find that the employee has not been adequately trained, does not possess the proper knowledge, or does not utilize appropriate safeguards to provide adequate isolation between workers and equipment and machinery.

1.3 Roles and Responsibilities The Underground Division Practice Lead or the Practice Lead’s representative is responsible for maintaining this safety plan.

1 This Lock-Out/Tag-Out Safety Plan is Appendix H of the McMillen Jacobs Associates Underground Division’s Safety Policy Manual. The plan is available in the common areas of each office/worksite for review by any interested employee and on the company’s intranet site.



The Responsible Person is assigned by the Practice Lead and is responsible for implementing this safety plan.

The Authorized Employee is an assigned senior staff person who has primary responsibility for the set number of employees working under the protection of a group Lock-Out or Tag-Out device.

The McMillen Jacobs Associates Environmental Health and Safety Director (Safety Director) is responsible for quality assurance of Lock-Out-Tag-Out Safety Plan and shall provide for a periodic inspection, to be conducted and documented at least annually, to ensure that procedures and requirements are being followed.

2.0 Definitions Affected Person: An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lock-out or tag-out, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed.

Authorized Person: A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee’s duties include servicing or maintenance covered under this section.

Capable of being locked out: An energy isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy isolating devices are capable of being locked out, if lock-out can be achieved without the need to dismantle, rebuild, or replace the energy isolating device or permanently alter its energy control capability.

Energized: Connected to an energy source or containing residual or stored energy.

Energy isolating device: A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices.

Energy source: Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.

Hot tap: A procedure used in the repair, maintenance and services activities which involves welding on a piece of equipment (pipelines, vessels, or tanks) under pressure, in order to install connections or appurtenances. It is commonly used to replace or add sections of pipeline without the interruption of service for air, gas, water, steam, and petrochemical distribution systems.



Lock-out: The placement of a lock-out device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lock-out device is removed.

Lock-out device: A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.

Normal production operations: The utilization of a machine or equipment to perform its intended production function.

Servicing and/or maintenance: Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

Setting up. Any work performed to prepare a machine or equipment to perform its normal production operation.

Tag-out: The placement of a tag-out device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tag-out device is removed.

Tag-out device: A prominent warning device, such as a tag and a means of attachment, which can be securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tag-out device is removed.

3.0 Requirements All employees working in areas where lock-out/tag-out (LOTO) is necessary, including all permit-required-confined space entries, must:

Be currently certified in advanced first aid and CPR

Have been trained in LOTO procedure

3.1 Training Required Prior to On-Site Work There is complete LOTO training available through various venues to employees at no cost. Training will include specific LOTO requirements and procedures. Additionally, employees may need to be trained in first aid/CPR. Employees should check with the Underground Division Project Manager or Site Safety Manager (SSM) to ascertain training availability and if any additional training is required. Employees shall not enter a confined space until necessary training is completed.



Retraining is required when any employee’s performance evidences a need for such retraining; there is a change in qualifying job assignments, equipment, or energy control procedures; or if any new hazard is introduced.

All training and retraining will be documented, signed, certified, and sent to both the jobsite office and the Underground Division’s Human Resources Department for filing.

3.2 Planning the Work If it is necessary for employees to work in an area requiring LOTO to protect themselves or others from machinery, equipment, or stored-energy systems, the Underground Division Project Manager will:

Advise the Practice or Deputy Practice Lead of the need to perform the work.

Contact the client/owner’s project manager to schedule a site walkthrough. The Underground Division Project Manager will advise the employee of the specific site safety requirements and if it is necessary to be escorted to the site.

Confirm the identity and qualifications of the Authorized Person who is responsible for installing the LOTO isolation devices.

Confirm that each employee has a personalized lock-out device to be used when entering the area subject to this LOTO procedure.

Assign an “Authorized” employee the primary responsibility of any employees working under the protection of a group LOTO device.

3.3 Field Work Immediately prior to entering the area subject to the LOTO procedures, Affected Persons will:

Familiarize themselves with the equipment, machinery, and stored-energy systems and how each has been isolated from the work area.

Hang their own personal locking device in the LOTO gang box or isolation devices, securing the locking device to prevent unauthorized removal.

Remove their own personal locking device after exiting the work area subject to LOTO procedures.

4.0 References United States

29 CFR 1910.147 – The Control of Hazardous Energy (lockout/tagout): https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804

Canada

Canadian Standard CSA Z460-13 – Control of Hazardous Energy – Lockout and Other Methods

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804



Canada Occupational Health and Safety Regulations: http://laws-lois.justice.gc.ca/PDF/SOR-86-304.pdf

Provinces

British Columbia Regulations: http://www2.worksafebc.com/publications/OHSRegulation/Home.asp

Alberta Regulations: http://www.qp.alberta.ca/1266.cfm?page=2003_062.cfm&leg_type=Regs&isbncln=9780779776221&display=html

Saskatchewan Regulations: http://www.qp.gov.sk.ca/documents/English/Regulations/Regulations/O1-1R1.pdf

Manitoba Regulations: http://www.manitoba.ca/labour/safety/

Ontario Regulations: http://www.labour.gov.on.ca/english/hs/laws/regulations.php

Quebec Regulations: http://www.csst.qc.ca/en/Pages/en_legislation.aspx

New Brunswick Regulations: https://www.worksafenb.ca/policy-and-legal/legal/acts-and-regulations/

Nova Scotia Regulations: http://www.gov.ns.ca/lae/healthandsafety/pubs.asp

Newfoundland Regulations: http://www.assembly.nl.ca/Legislation/sr/Regulations/rc120005.htm

Prince Edward Island Regulations: http://www.gov.pe.ca/law/regulations/pdf/O&1-01G.pdf

Australia

National code of safe practices does not address lock-out/tag-out yet, but local states or territories have regulations: https://www.worksafe.vic.gov.au/

New Zealand

Health and Safety in Employment Act: http://legislation.govt.nz/act/public/1992/0096/latest/DLM278829.html

http://laws-lois.justice.gc.ca/PDF/SOR-86-304.pdf

http://www2.worksafebc.com/publications/OHSRegulation/Home.asp

http://www.qp.gov.sk.ca/documents/English/Regulations/Regulations/O1-1R1.pdf

http://www.qp.gov.sk.ca/documents/English/Regulations/Regulations/O1-1R1.pdf

http://www.manitoba.ca/labour/safety/

http://www.labour.gov.on.ca/english/hs/laws/regulations.php

http://www.csst.qc.ca/en/Pages/en_legislation.aspx

http://www.gov.ns.ca/lae/healthandsafety/pubs.asp

http://www.assembly.nl.ca/Legislation/sr/Regulations/rc120005.htm

http://www.gov.pe.ca/law/regulations/pdf/O&1-01G.pdf

http://legislation.govt.nz/act/public/1992/0096/latest/DLM278829.html



Appendix I Roadway Worker Protection / On-Track Railroad Safety Plan


Roadway Worker

Protection / On-Track Railroad

Safety Plan

January 2020

Underground Division Safety Policy Manual Roadway Worker Protection / On-Track RR Safety Plan


Table of Contents 1.0 Introduction .......................................................................................................................................... 1

1.1 Application .............................................................................................................................. 1

1.2 Authority ................................................................................................................................. 1

1.3 Roles and Responsibilities ..................................................................................................... 1

2.0 Requirements ...................................................................................................................................... 2

2.1 Prior to On-Site Work ............................................................................................................. 2 2.1.1 All Employees on Active Railroad Projects ............................................................ 2

2.1.2 All MOW Workers................................................................................................... 2

2.1.3 Site Investigation Preparation ................................................................................ 2

2.2 Field Work .............................................................................................................................. 3

Attachments Attachment A Federal Railway Administration (FRA) Control of Alcohol and Drug Use: Model Part

219 Railroad Contractor Compliance Plan (January 31, 2020)

Attachment B Verification – Roadway Worker Protection / On-Track Railroad Safety Plan





3 January 2020 Bill Mitchell, Ted DePooter, Sarah Wilson 2 August 2017 Bill Mitchell, Ted DePooter 1 June 2011 Blake D. Rothfuss 0 June 2010 Blake D. Rothfuss



1.0 Introduction This Roadway Worker Protection / On-Track Railroad Safety Plan is applicable to the McMillen Jacobs Associates Underground Division employees working on railroad projects in the United States regulated by the Federal Rail Administration (FRA). On these sites, Underground Division employees are considered “guest workers,” and therefore must abide by the safety regulations of the host railroad, as mandated by the FRA. Employees who are considered Maintenance-of-Way (MOW) workers (working within 25 feet of an active railroad line) must comply also comply with the requirements of 49 CFR Part 219 (FRA Control of Alcohol and Drug Use: Model Part 219 Railroad Contractor Compliance Plan [Attachment A]). At any time, an FRA inspector may visit a construction or field investigation site and inquire about this Underground Division employee safety plan.

1.1 Application This safety plan1 is applicable to all Underground Division employees and its subcontractors working on or near railroad property. The Part 219 Drug and Alcohol Program is applicable to all Underground Division employees working within 25 feet of an active railroad line.

1.2 Authority The FRA can levy fines against both an employee and the company if it finds that the employee has not been adequately trained or does not possess the proper knowledge of the current on-track safety regulations on the project they are currently working. Authority rests in the Roadway Worker Protection Final Rule (49 CFR 214) and Control of Alcohol and Drug Use (49 CFR 219).

1.3 Roles and Responsibilities The Practice Lead or Deputy Practice Lead is responsible for maintaining this safety plan.

The Responsible Person is assigned by the Practice Lead and is responsible for implementing this Roadway Worker Protection / On-Track Railroad Safety Plan (Roadway / On-Track Railroad Safety Plan).

The Environmental Health and Safety Director is responsible for the quality assurance of this Roadway / On-Track Plan.

MOW employees must notify Underground Division Human Resources prior to and after completion of applicable field activities.

1 This Roadway Worker Protection / On-Track Railroad Safety Plan is Appendix I of the McMillen Jacobs Associates Underground Division’s Safety Policy Manual. The plan is available in the common areas of each office/worksite for review by any interested employee and on the company’s intranet site.



2.0 Requirements 2.1 Prior to On-Site Work

2.1.1 All Employees on Active Railroad Projects

Must undergo an E-Rail Safe background check and carry a current card indicating enrollment in the program. The employee should contact the Underground Division Human Resources Department for information on fulfilling these requirements.

Must be currently trained in accordance with the railroad owner’s safety training program and carry s valid Contractor Orientation Card. The railroad owner’s safety program is available on-line through the Contractor Orientation website or provided in person by the railroad.

Must comply with the Underground Division Safety Policy, including the provisions in this appendix.

Must sign and submit the Verification: Roadway Worker Protection / On-Track Railroad Safety Plan (Attachment B) stating they understand their responsibilities as outlined herein.

2.1.2 All MOW Workers All MOW workers must comply with the requirements of the Part 219 Drug and Alcohol Program (see Attachment A), which states that the following activities are prohibited: Being in possession of illegal substances and/or under the influence of alcohol while on duty or

within four hours of reporting for regulated service.

Using illegal substances at any time on or off duty.

There are exceptions to these requirements, which can be found in Attachment A, page 15 (“Prescription Drugs [40 CFR 219.103]”).

The 40 CFR 219 regulation also states that applicable employees must be subject to random drug testing. Underground Division has an existing random drug testing program in place, which will include those employees who will be performing regulated work as stated above and will consist of the following:

1. Random urine screens to detect the presence of marijuana, cocaine, opioids, phencyclidine, and amphetamines

2. Random breath alcohol tests to detect the unauthorized use of alcohol

3. Breath, urine, blood, and tissue testing after qualifying FRA post-accident events

2.1.3 Site Investigation Preparation

If it is necessary to enter railroad property for a site investigation, the Underground Division Project Manager will:

Advise the Underground Division Practice or Deputy Railroad Lead of the need to enter railroad property.



Contact Human Resources prior to commencement of work for a drug test screening and inclusion in the random drug testing pool.

Contact the Railroad Project Manager to schedule a site walkthrough. The Underground Division Project Manager will advise the Underground Division obs employee of the specific site safety requirements and if it is necessary to be escorted to the site.

Confirm that no utilities conflict with the planned work by calling the toll-free “Call Before You Dig” phone number. It is also necessary to check with the Railroad Project Manager to determine if there are any railroad utilities in the area.

Confirm that all Underground Division employees and subcontractors are properly railroad safety trained.

Confirm that there will be proper track protection at the site for the duration of the field work.

Confirm that all Underground Division employees and subcontractors have the proper personal protective equipment (PPE) prior to arriving at the site. The minimum required PPE includes:

° Hard hat

° Safety glasses

° An ANSI Level II or III orange safety vest or jacket

° Well-fitting gloves

° Lace-up or zip-up steel-toed boots (no slip-ons)

° Hearing protection (on board)

° Appropriate thermal protection

° Long pants and shirt with sleeves at all times

Perform other tasks necessary to provide a safe work environment

2.2 Field Work While Underground Division employees or subcontractors are working on railroad property or within 25 feet of the track centerline, they will:

Meet with the railroad’s Employee in Charge (EIC), who is responsible for coordinating the Underground Division assigned work activities to establish a project-specific strategy for addressing roadway worker protection/on-track safety requirements.

Obtain the following information from the EIC and be able to provide answers to an FRA safety inspector on said information. If the employee is unable to do so, the employee, not the Underground Division, may incur a monetary fine.

° The name of the EIC, the anticipated locations of the EIC during the work, and the method of communication among the workers, the Underground Division employees, flagger, and the EIC.

° A description of the type and limits (both in time and distance) of “track protection” being used at the site.



° A description of the method of communication among the workers, the Underground Division employee, and the on-site EIC.

Participate in a safety briefing to discuss site safety hazards and the appropriate mitigations.

If the Underground Division employee arrives on site after the EIC or safety briefing has concluded, the Underground Division employee must be briefed by the EIC or the site superintendent and obtain this information before beginning work.

Confirm that all workers are using the proper personal protective equipment (PPE).

Maintain a current copy of the site-specific safety plan at the worksite.

Follow the on-track safety and site-specific safety procedures.

Notify the railroad’s EIC when the work no longer requires on-track safety.

Refrain from being in possession of illegal substances and/or under the influence of alcohol while on duty or within four hours of reporting for regulated service.

Refrain from the use of illegal substances at any time on or off duty.

Be subject to random drug testing, as outlined above.



Attachment A Federal Railway Administration (FRA) Control of Alcohol and Drug Use: Model Part 219 Railroad Contractor Compliance Plan (January 31, 2020)


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FEDERAL RAILROAD ADMINISTRATION

CONTROL OF ALCOHOL AND DRUG USE

(49 CFR PART 219)

MODEL PART 219 RAILROAD CONTRACTOR

COMPLIANCE PLAN

McMillen Jacobs Associates

January 31, 2020


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I. Policy Statement McMillen Jacobs Associates recognizes the problem of substance abuse in today’s society. This problem poses particular concerns to an employer who is subject to governmental regulations and seeks to promote the safety of the general public. McMillen Jacobs Associates has a concern for the safety, health and wellbeing of its employees as well as an obligation to comply with the United States Department of Transportation (DOT) and Federal Railroad Administration (FRA) regulations. McMillen Jacobs Associates will comply with all statutes and regulations administered by the FRA in implementing the required Part 219 Drug and Alcohol Program. Programs have been established on McMillen Jacobs Associates which require regulated employees to demonstrate their safety posture through complying with: 1. Urine screens to detect the presence of marijuana, cocaine, opioids, phencyclidine

and amphetamines (See 49 CFR § 40.85 and 49 CFR § 40.87); 2. Breath alcohol tests to detect the unauthorized use of alcohol; and 3. Breathe, urine, blood and tissue (fatality) testing after qualifying FRA post-

accident events. In accordance with the applicable Federal regulations, McMillen Jacobs Associates prohibits persons who perform work regulated by the Federal Hours of Service Laws (see 49 U.S.C. §§ 21101-21108) and performing duties as Maintenance-of-Way (MOW) workers as described in the definition of “Roadway Worker” in § 214.7 from being under the influence and/or possession of illegal substances and/or under the influence of alcohol or marijuana while on duty or within four hours of reporting for regulated service. Additionally, illegal substance use is prohibited at any time on or off duty, except as allowed in 49 CFR § 219.103.

II. Identifying Information. Note: If any of the following personnel or entities change, the company is obligated to send FRA a change notice.

Company: Name: McMillen Jacobs Associates Address: 49 Stevenson St. San Francisco, CA 94105 Phone: (781) 852-0463 E-Mail: [email protected]


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Designated Employer Representative: Name: Greta Miller Address: 1471 Shoreline Drive, Ste 100

Boise, ID 83702 Phone: (781) 852-0463 E-Mail: [email protected] Assistant Designated Employer Representative: Name: Julie Riegel Address: 1011 Western Ave, Ste 706 Seattle, WA 88104 Phone: 206.225.2255 E-Mail: [email protected] Medical Review Officer: Name: Dr. Stephen Kracht Address: 8140 Ward Parkway

Suite 275 Kansas City, MO 64114

Phone: (855) 355-7058

Testing Laboratory (must be on HHS list of certified labs):

Alere Toxicology 450 Southlake Blvd. Richmond, VA 23200 (804) 378-9130 Alere Toxicology 1111 Newton St. Gretna, LA 70100 (800) 433-3823

Substance Abuse Professional (SAP): Name: Carolyn Powley Address: 2208 Northwest Market Street, Ste 430A Seattle, WA 98107 Phone: (206) 380-6445


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III. Scope This policy applies to all Company personnel (including sub-contractors and volunteers) who perform regulated duties subject to either the Federal Hours of Service Laws “Covered Service” and/or performing Maintenance-of-Way (MOW) duties covered by the definition of “Roadway Worker” in § 214.7. McMillen Jacobs Associates provides personnel who perform regulated service for the UPRR & BNSF railroad (if multiple railroads attach Appendix with listings at end of this plan) for the following regulated service (functions) positions: Construction Inspection The total number of regulated employees performing “Covered Service” at the time of this submission is: 0. The total number of regulated employees performing “Roadway Worker” duties at the time of this submission is:3 The total number of all regulated employees (both covered service and roadway workers) at the time of this submission is: 3. NOTE: (Include any subcontracted regulated service employees.) Previous Employer Checks: McMillen Jacobs Associates is required to check on the drug and alcohol testing record of employees it is intending to use to perform regulated duties. McMillen Jacobs Associates will, after obtaining an employee’s written consent, request information from DOT-regulated employers who have employed the employee during any period during the two years before the date of the employee’s application or transfer into regulated service. See 49 CFR 40.25. An employee must also be asked whether he or she tested positive (or refused to test) on any Federal pre-employment drug or alcohol test administered by a DOT employer to which the employee applied for, but did not obtain, regulated service work during the past two years. With respect to any employee who violated a DOT drug and alcohol regulation, documentation of the employee’s successful completion of DOT return-to-duty requirements (including Federal follow-up tests) must be provided to McMillen Jacobs Associates.


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IV. Testing Programs There are numerous situations when Federal drug and/or alcohol tests must be administered for the railroad contractor to be in compliance with 49 CFR Part 219. Personnel performing functions listed in Section III of this policy will be required to submit to a drug and/or alcohol test in the instances set forth, as follows: 1) Pre-Employment Drug Testing – (49 CFR 219.501). Applicants will be

informed that all individuals McMillen Jacobs Associates will use for regulated service must be drug-free. This does not mean that a drug test is required prior to beginning employment at the company. Rather, it means that passing a Federal “pre-employment” drug test is a condition prior to performing the regulated service duties on a project for a railroad. If an applicant refuses to submit to the drug test, or tests positive on the drug test, the applicant will not be considered qualified to perform regulated service and will not be offered a position in regulated service.

Federal Pre-Employment Alcohol Testing (Optional) – (49 CFR 219.502) Authorized but not required. McMillen Jacobs Associates chooses to conduct Federal alcohol pre-employment testing? Place an “X” in one of the following boxes: Yes No

2) Federal Reasonable Suspicion Testing – (49 CFR 219.301). Regulated service personnel will be required to submit to a Federal drug and/or alcohol test whenever a properly trained supervisory employee of this railroad contractor has reasonable suspicion that a regulated employee is currently under the influence of or impaired by a controlled substance or alcohol. Reasonable suspicion must be based on specific, contemporaneous personal observations the supervisor can articulate concerning the employee’s appearance, behavior, speech, body odor, chronic effects or withdrawal effects. Part 219.11(g) requires supervisory employees to have education and training on alcohol misuse and controlled substance use. The training will cover the physical, behavioral, speech and performance indicators of probable alcohol misuse and use of controlled substances. It will also prepare the supervisors to make the decisions necessary in reasonable suspicion and FRA post-accident situations (i.e., what is a qualifying event and who is to be tested). The observation for alcohol must be made by at least one qualified supervisory employee who has received proper training in the signs and symptoms of alcohol use per 219.11(g). Documentation of this decision must be maintained, as required by Part 219 Subpart J.

X


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The observation for drugs must be made by at least two qualified supervisory employees, one of which has received proper training in the signs and symptoms of drug use/misuse per 219.11(g). One qualified supervisor must be on-site, but the supervisor trained per 219.11(g), although preferred does not have to be the supervisor on-site. Documentation of this decision must be maintained, as required by Part 219 Subpart J. If operating on tracks of a railroad, this railroad contractor will coordinate with the host railroad and decide how the supervisor on the site will immediately communicate and coordinate decisions to test and who will administer the necessary testing. In all reasonable suspicion cases, the supervisor will ensure that the regulated service person is transported immediately to a collection site for a timely collection of a urine and/or breath specimen. If the regulated service person is deemed not fit to return to work, the supervisor will arrange transportation for the person. This is not a Federal requirement, but safety will be better assured if accomplished. Supervisors must document their observations that led them to decide there was a “reasonable suspicion” to have the regulated service person subjected to Federal drug and/or alcohol testing.

3) Federal Reasonable Cause Testing – (49 CFR 219.401) Authorized but not

required. A company must designate whether or not they conduct Federal drug and alcohol Reasonable Cause testing. If a company selects to conduct Federal Reasonable Cause testing, then the company cannot perform company testing for any event described in 219.403. If a company selects to conduct company (non-DOT) Reasonable Cause testing only, then the railroad contractor cannot perform DOT testing for any event described in 219.403.

McMillen Jacobs Associates chooses to conduct only Federal Reasonable Cause drug and alcohol testing for all train accident/incidents and rule violations that meet the criteria of 49 CFR 219.403. Please check the appropriate box: Place an “X” in one of the following boxes: Yes No A Federal reasonable cause drug and/or alcohol test may be required (employer’s decision) when a regulated service employee:

1. Was involved in a qualifying train accident/incident per 219.403 (a) and a supervisor has a reasonable belief based on specific and articulable facts that the regulated service person’s acts or omissions contributed to the occurrence or severity of the accident/incident; or

2. Committed a rule violation described in 219.403 (b).

X


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If operating on tracks of a railroad, McMillen Jacobs Associates will coordinate with the host railroad and decide how the supervisor on the site will immediately communicate and coordinate decisions to test and who will administer the necessary testing. In all reasonable cause cases, the supervisor will ensure that the regulated service person is transported immediately to a collection site for a timely collection of a urine and/or breath specimen. If the regulated service person is deemed not fit to return to work, the supervisor will arrange transportation for the person. This is not a Federal requirement, but safety will be better assured if accomplished. Supervisors must document their observations that led them to decide there was a “reasonable cause” to have the regulated service person subjected to Federal drug and/or alcohol testing.

4) FRA Post-Accident Drug/Alcohol Testing – (49 CFR 219.201) FRA regulations require blood and urine specimens from all surviving regulated service personnel when they are directly involved in a qualifying accident or incident. Tissues are also collected, in addition to urine and blood from any fatality involving an on-duty railroad employee (direct or “regulated service” contractual employee). Events requiring FRA post-accident testing include (note regulatory exceptions will be followed):

1. Major Train Accident involving any rail equipment accident with reportable damages in excess of the current calendar year reporting threshold under 49 CFR Part 225 and one or more of the following:

a. A fatality (any fatality). b. A release of hazardous materials from railroad “lading” that results

in an evacuation or reportable injury caused by the hazmat release. c. Damage to railroad property of $1.5 Million or more.

2. Impact Accident involving reportable damage in excess of the current

reporting threshold that results in:

a. A reportable injury; or b. Damage to railroad property of $150,000 or more.

3. Fatal Train Incident involving any on-duty railroad employee or regulated contractor employee where damages do not exceed the current reporting threshold.


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4. Passenger Train Accident with a reportable injury to any person in a train accident involving damage in excess of the current reporting threshold that involves a passenger train.

5. Human-Factor Highway-Rail Grade Crossing Accident/Incident

meeting one of the following criteria:

i. Regulated employee interfered with the normal functioning of a grade crossing signal system, in testing or otherwise, without first providing for the safety of highway traffic that depends on the normal functioning of such a system, as prohibited by § 234.209, is subject to testing.

ii. Train crewmember who was, or who should have been, flagging

highway traffic to stop due to an activation failure of a grade crossing system, as provided § 234.105 (c)(3), is subject to testing.

iii. Regulated employee who was performing, or should have been

performing, the duties of an appropriately equipped flagger (as defined in § 234.5), but who failed to do so, due to an activation failure, partial activation, or false activation of the grade crossing signal system, as provided by § 234.105 (c)(1) and (2), 234.106, or 234.107 (c)(1)(i), is subject to testing.

iv. If there is a fatality of any regulated service employee regardless of

fault (fatally injured regulated employee must be tested).

v. If regulated employee violates an FRA regulation or railroad operating rules and whose actions may have played a role in the cause or severity of the accident/incident, is subject to testing.

Testing Decision: For an accident that meets the criteria for a Major Train Accident, all assigned crew members of all involved trains and on-track equipment must be tested. Test any other regulated service employees that had a possible role in the cause or severity of the accident. For an Impact Accident, Fatal Train Incident, Passenger Train Accident or Human-Factor Highway-Rail Grade Crossing Accident/Incident, test any other regulated service employees that had a possible role in the cause or severity of the accident. The company must exclude other regulated service employee if the responding railroad representative can immediately determine, on the basis of specific information, that the employee had no role in the cause(s) or severity of the accident/incident (considering any such information immediately available at the time).


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For a fatal train incident, the fatally injured employee cannot be excluded from being tested. If there is a fatality of any regulated service employee as result of a Highway-Rail Grade Crossing Accident/Incident, the fatally injured regulated employee must be tested regardless of fault. Exceptions from Testing: No test may be required in the case of a collision between railroad rolling stock (including any on-track equipment) and a motor vehicle or other highway conveyance at a rail/highway grade crossing, unless it meets the criteria set forth above in Item 5 (i-v). No test may be required in the case of an accident/incident the cause and severity of which are wholly attributable to a natural cause (e.g., flood, tornado, or other natural disaster) or to vandalism or trespasser(s), as determined on the basis of objective and documented facts by the railroad representative responding to the scene. The railroad supervisor(s) on the scene will make timely determinations as to the event being a qualifying event and which regulated service employees (if any) are required to be tested according to the rule. This railroad will identify the appropriate personnel who must be tested and then ensure that specimens are collected and shipped. A. Random Drug and Alcohol Testing – (49 CFR 219.601)

The railroad is responsible for ensuring that the random program meets regulatory requirements and is accepted by FRA (see Appendix A). The principles which are required in the FRA regulation for the plan to be in compliance are attached (see Appendix B). The selection process will ensure that each regulated service person has an equal chance of being selected at every random selection. The random plan shall ensure that testing is accomplished at the beginning and at the end of the duty period for alcohol. The minimum annual random percentage of alcohol testing at either end of the duty period is 10 percent over the course of the year. Regulated Service (Covered Service) Current employers must test at a minimum of 25 percent annual rate for drugs and 10 percent annual rate for alcohol for employees who perform regulated duties subject to the Federal Hours of Service Laws “Covered Service.” A company is permitted to test at a higher rate than the minimum. A company is permitted to test at a higher rate than the minimum. You must identify if you are testing at a higher rate and if so, the rate(s):


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______________________________________________________________ Regulated Service (Roadway Worker) Beginning June 12, 2017, Current employers must test at a minimum 50 percent annual rate for drugs and 25 percent annual rate for alcohol for employees who perform regulated duties defined as “Roadway Worker” in 49CFR § 214.7. A company is permitted to test at a higher rate than the minimum. You must identify if you are testing at a higher rate and if so, the rate(s): ______________________________________________________________ Random Testing Pools: a) Identify and maintain an up-to-date database or list of all personnel working in

regulated service (at least once per quarter) and ensure they are all in the random pool(s). Identify how many random testing pools you have. For example, most contractors will have only one random pool, but larger contractors may have multiple pools (FRA recommends Roadway Workers be placed in separate and stand-alone random pools. Railroads not normally required to submit MIS reports as required by 49 CFR Part 219.800 should contact Sam Noe at [email protected] to discuss the combining of random pools): We will manage one testing pool made up of approximately 50 craft employees who do not work on any railway projects (Non-DOT) and approximately 3 roadway workers (DOT) from our rail division.

b) Identify what regulated service employee crafts/functions are in each of the

company’s random testing pool(s). For example, engineers, conductors, brakemen, switchmen, utility employees, hostlers, mechanical employees performing hostling duties, train dispatchers, signal maintainers, roadway workers, etc. Rail Division - 3 Roadway workers Construction Division (Heavy Civil - No rail work) - 50 Craft Workers

Random Selection and Testing Procedures:

1. There are only two acceptable methods of selection: computer program or

random number table. The lottery style, e.g., drawing names out of a hat, is no longer an acceptable method of selection. Identify your company’s method of selection: Computer Program

mailto:[email protected]


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2. Identify whether your company is making selections by name, ID number, train number, job number, etc. Name

3. Random Pools are in a consortium: Yes No 4. If using TPA Consortium pools, please provide name of Consortium pool:

Alere eScreen FRA Consortium

5. If your company is using a consortium/third party administrator (C/TPA) to assist in random testing, identify the following information for the C/TPA: Name of C/TPA: Alere eScreen Address: 8140 Ward Parkway, Suite 300 – Kansas City, MO 64114 Contact Person: Deborah Brandt Phone: (800)-881-0722 Please mark the following services the C/TPA are performing for your company: ___None

X Random Pool Maintenance X Random Pool Selections X Collection Services Drug X Collection Services Alcohol X HHS Laboratory X Medical Review Officer ___Substance Abuse Professional (SAP) ___Employee Assistance Professional (EAP) ___Drug and Alcohol Counselor (DAC)

___Other: _________________________________________________

6. Identify how often your company is making selections, e.g., monthly or quarterly: Quarterly Note: If selecting quarterly in order to maintain the deterrent effect of random testing for very small railroads and contractors, FRA is requiring each individual random testing pool established under subpart G to select and randomly test at least one entry per quarter, even if fewer tests are needed to meet FRA’s minimum random testing rates. Objective Procedure, if making quarterly selections: Quarterly. At least one worker will be randomly tested per quarter, even if fewer tests are needed to meet FRA’s minimum random testing rates.

7. Identify how you determine whether a selection is to be tested for drugs, for alcohol, or both: We identify and make selections to meet the number of drug tests based on frequency requirements. As workers become identified for

X


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random drug testing, some are also randomly identified for alcohol based on frequency requirements.

8. Identify your testing “window,” e.g., 30 days. Every quarter or 90 days but not past the end of the quarter. Note that if you’re making monthly selections, the testing windows may not exceed 30 days and not past the end of the month. If you’re making quarterly selections, the testing window is 90 days but not past the end of the quarter.

9. Provide additional descriptions of your random testing selection procedure, as applicable: No additional descriptions to provide.

10. McMillen Jacobs Associates will safeguard these selection records to ensure that information concerning collection dates and selections are not disclosed until necessary to arrange for collection or provide notifications.

11. These random testing records are required to be maintained for 2 years. This includes an electronic or hard copy “snapshot” of the random testing pool each time selections are made, a copy of the list of selected employees, a copy of the drug chain of custody form and/or alcohol testing form, and the reason for not testing any of the selected employees.

12. In the event that all or a clearly defined portion of the railroad is subject to an emergency such as a flood or severe ice storm, the ranking operations officer on duty is authorized to declare an emergency by completing a memorandum setting forth the facts necessitating this action. If such an emergency determination is made, the date/time of the emergency and random drug/alcohol tests that were suspended must be entered into the DER’s files. Random selections not administered because of the emergency are deemed void, and the selection numbers will be adjusted later to make the required percentage.

13. Only a substantiated medical emergency involving the selected person or an emergency involving an immediate family member (e.g., birth, death, or a medical emergency) provides the basis for excusing a regulated employee/person from being tested once notified. A medical emergency is defined as an acute medical condition requiring immediate emergency care. A person excluded under these criteria must provide substantiation from a credible outside professional (e.g., doctor, hospital, law enforcement officer, school authority, court official) which can be furnished prior to this release or within a reasonable period of time after the emergency has been resolved. Such excluded (excused) persons will not be tested based on this selection.

14. Once the regulated service person selection is made, the DER will arrange notification. No prior notification will be given. A selected person will only be tested during his/her tour of duty, extended only long enough to complete testing but not to exceed Federal hours of service law requirements. The person, once notified, must proceed to the selected testing facility IMMEDIATELY. Identify how your company will notify selected employees: eScreen (TPA) will notify the HR Department of a Random Section. The HR Department will contact the selected worker’s supervisor to explain that the


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employee must leave work immediately to take a random drug and/or alcohol test at a predetermined clinic. That supervisor will then relay the information to his or her employee including the clinic contact information. The employee will be given a 2-hour window of time to take the random test. The collection date and time during the selection period (testing window) will be varied by the DER to ensure that it cannot be anticipated. It is not necessary for the company to randomly select the “testing date.”

V. Drug Testing Procedures

The designated collection agents will be qualified and follow the proper collection procedures as described in 49 CFR Part 40.

a. The Medical Review Officer (MRO) will review drug test results as required in 49 CFR Part 40. All test results will be reported exclusively through the MRO.

b. A laboratory certified by the Department of Health and Human Services/

Substance Abuse and Mental Health Service Administration (DHHS/ SAMHSA), under the Mandatory Guidelines for Federal Workplace Drug Testing Programs, will perform all drug testing.

c. Test results will be reported from the laboratory only to the MRO for review

and action consistent with 49 CFR Part 40.

d. The name of the individual providing the specimen will remain confidential and will not be provided to the laboratory performing the test. The testing laboratory is only able to identify the specimen by the specimen ID number printed on the chain-of-custody form. The laboratory will only use a urine custody and control form consistent with the requirements of 49 CFR Part 40.

e. The designated laboratory will only test for the drugs listed in 49 CFR 40.85.

f. The MRO will verify the results and report (using procedures in 49 CFR Part

40) to the DER whether the test was positive or negative and the drugs for which there was a positive result.

g. External blind performance testing of specimens is now only required for

those employers or C/TPAs with an aggregate of 2,000 or more DOT-regulated employees per 49 CFR 40.103.


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VI. Alcohol Testing Procedures

Breath alcohol testing will be performed by fully trained and certified Breath Alcohol Technicians (BAT) using the National Highway Traffic Safety Administration (NHTSA) approved testing devices. The results will be documented on an approved Federal Breath Alcohol Testing Form and will be signed by the employee and the BAT. At the time of the alcohol test, the employee will receive a copy of the test result, with an identical copy being sent to the company’s DER.

a. Negative results. The DER will be mailed a copy of the negative test results.

b. Positive results. The BAT will immediately and directly notify the company’s DER if the test results are positive (0.02 percent or higher) who will take appropriate action to remove or restrict the employee from regulated service as required by Part 219.

VII. Drug Test Results

For any FRA testing, the company should as a “best practice” notify the employee in writing of test results. Positive or Otherwise Non-Negative Results. If the laboratory reports the drug test result as POSITIVE or otherwise non-negative, the following procedures will be followed:

a. The MRO will immediately inform the regulated service person of the result and offer the person the opportunity for an interview to discuss the test result. If the MRO has difficulty reaching the employee, the procedures set forth in 49 CFR 40.131 will be followed.

b. The MRO will complete and document the review as required by 49 CFR Part 40 Subpart G, determining if the external chain of custody was intact, if the person has a legitimate medical explanation for the presence of any controlled substance, and whether there is any basis to question the scientific sufficiency of the test results. In the case of an opiate positive, the MRO will also make the special determinations required by the regulation.

c. If the MRO verifies the test result as positive, the MRO will report the result to the company’s DER. If the MRO determines that the result is non-negative and the non-negative result cannot be explained, the appropriate regulatory action will be pursued. The chart at Appendix D delineates the appropriate action. The MRO will report the verified test result in accordance with 49 CFR § 40.163. The MRO will not provide the DER with the quantitative test results unless the employee, as stipulated in the regulation, disputes the test.


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Negative results. If the MRO has determined that the drug test is NEGATIVE, the MRO will accomplish the required administrative review and report the negative results to the company’s DER in accordance with 49 CFR § 40.163. Negative-dilute results. Unless the MRO directs a company to conduct a recollection under direct observation (for a result with creatinine from 2 to 5 mg/dL), per 40.197, a negative-dilute is considered a negative test, although a company may, but is not required to direct the employee to immediately take another test. Such recollections must not be collected under direct observation unless there is another basis to do so. A company must treat all regulated employees the same. For example, it must not retest some employees and not others. A company may establish different policies for different types of tests (e.g., conduct retests in pre-employment situations, but not in random test situations). McMillen Jacobs Associates’ policy for negative-dilutes is as follows: If an employee receives a negative-dilute test result, the employee will be asked to return to the clinic to take an additional test. If the second test shows a negative dilute test result, then this test will be accepted by the employer as an approved test result.

VIII. Confidentiality

a. Medical information a regulated person provides to the MRO during the

verification process is treated as confidential by the MRO and is not communicated to the company except as provided in Part 40.

b. Confidentiality of Federal drug or alcohol testing results will be maintained as required by the regulations. For example:

1. The laboratory observes confidentiality requirements as provided in the regulations. McMillen Jacobs Associates does not advise the laboratory of the identity of persons submitting specimens. The laboratory performing the testing must keep all records pertaining to the drug test for a period of two years.

2. All test results will remain exclusively in the secure files of the MRO. The MRO will observe strict confidentiality in accordance with the regulations and professional standards. The MRO will retain the reports of individual test results as required in Part 219 Subpart J.

3. The DER will maintain all test results reported by the MRO, both positive and negative, in secure storage. The results will be retained as required in Part 219 Subpart J. Other personnel will be informed of individual test results only in the case of positive tests and authorized only on a need-to-know basis.

IX. Regulated Service Personnel Training Program (49 CFR 219.11)

Each regulated service person will receive a copy of this policy and the other information requirements in 49 CFR Part 219.23 (e) which clearly states the


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prohibitions required by the regulation. In addition, each regulated person will be given information concerning the problems caused by alcohol or controlled substances and available methods of intervening when an alcohol or controlled substance problem is suspected, including confrontation, referral to an employee assistance program and/or referral to management.

X. Prescription Drugs (40 CFR 219.103) The use of controlled substances (on Schedules II through V of the controlled substance list) is not prohibited as long as they are prescribed or authorized by a medical practitioner and used at the dosage prescribed or authorized. Either one treating medical professional or a company-designated physician should determine that use of the prescription(s) at the prescribed or authorized dosage is consistent with the safe performance of the employee’s duties. Regulated service employees should also seek the advice of a medical professional whenever they are taking any over-the-counter drug that may adversely affect the safe performance of duties. XI. Compliance with Testing Procedures

a. All regulated service personnel/applicants requested to undergo a Federal drug and/or alcohol test are required to promptly comply with this request. McMillen Jacobs Associates expects all prospective and current regulated service personnel to exercise good faith and cooperation in complying with any procedures required under this policy. Refusal to submit to a Federal drug or alcohol test required under FRA rules, engaging in any conduct which jeopardizes the integrity of the specimen or the reliability of the test result, or any other violations of the prohibited conduct in 49 CFR 219.101 or 219.102 could subject the person to disciplinary action (up to and including termination), independent and regardless of any test result. This includes failure to show up on time for a drug/alcohol test, failing to remain at the testing site until the testing process is complete, etc. (see 40.191).

b. All DOT Federal return-to-duty and follow-up urine specimens must be collected under direct observation (using the direct observation procedures in 40.67 (i)). Note that a SAP may also require return-to-duty and follow-up “drug” tests in addition to alcohol tests following an alcohol positive of 0.04 percent or greater.

c. Direct Observation Urine Collection Procedures: The collector (or observer) must be the same gender as the employee. If the collector is not the observer, the collector must instruct the observer about the procedures for checking the employee for prosthetic or other devices designed to carry “clean” urine and urine substitutes AND for watching the employee urinate into the collection container. The observer will request the employee to raise his or her shirt, blouse or dress/skirt, as appropriate, above the waist, just above the navel; and lower clothing and underpants to mid-thigh and show the observer, by turning around, that the employee does not have such a device.


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1) If the employee has a device, the observer immediately notifies the collector; the collector stops the collection; and the collector thoroughly documents the circumstances surrounding the event in the remarks section of the testing form. The collector notifies the DER. This is a refusal to test. 2) If the employee does not have a device, the employee is permitted to return his/her clothing to its proper position for the observed collection. The observer must watch the urine go from the employee’s body into the collection container. The observer must watch as the employee takes the specimen to the collector. The collector then completes the collection process. 3) Failure of the employee to permit any part of the direct observation procedure is a refusal to test.

d. As a minimum, a regulated service person will be removed from FRA regulated service for a minimum of nine months if there is a finding of “refusal to test.”

XII. Positive Test Results

a. Alcohol positive of 0.02 to 0.039: Regulated service personnel should receive

written notification of test results which are other than negative. A Federal positive drug test or a Federal alcohol test result of 0.02 percent or greater or a refusal to test will result in immediate removal from regulated service under FRA regulations. A positive alcohol test of at least 0.02 percent but less than 0.04 percent will result in the removal of the person from regulated service for at least eight hours. The company is not prohibited from taking further action under its own company policy.

b. Federal violation: A regulated service person with an MRO verified positive drug test or a breath alcohol test result of 0.04 percent or greater (or a refusal) has violated Federal regulations and must be immediately removed from regulated service. Prior to or upon withdrawing the employee from regulated service, the company must provide notice to the employee of the reason for this action. If the employee denies that the test result is valid evidence of alcohol or drug use prohibited by 219.101 or 219.102, the employee may demand and must be provided an opportunity for a prompt post-suspension hearing. See 219.104 (c) for the hearing provisions.

Even if the company does not wish to keep the employee in its employment, it must provide the above hearing (if requested) and at a minimum provide the employee with a list of qualified Substance Abuse Professionals. Prior to returning to regulated service the employee will be required to undergo an evaluation by a qualified Substance Abuse Professional (SAP) that is company approved, to determine the need for treatment and/or education. The employee


18

will be required to participate and comply with the SAP-recommended treatment and any after-care or follow-up treatment that may be recommended or required.

After successful treatment, for a Federal positive drug test (or alcohol test result of 0.04 percent or greater), per the SAP’s requirements, the person must provide a Federal return-to-duty urine specimen and/or breath specimen for testing (which is negative) prior to being allowed to return to regulates service. In addition, the person will be subject to additional unannounced Federal follow-up testing, as determined by the SAP, for a maximum period of 60 months, with a minimum of six tests being performed in the first twelve months (engineers and conductors – SAP with require a minimum of 6 drug tests and 6 alcohol tests in the first 12 months). Failure to comply with these provisions and remain alcohol and/or drug-free will result in subsequent removal from regulated service and could result in disciplinary action, up to and including termination. Note: Federal regulation does not guarantee the employee will maintain an employment relationship. This is determined via employer and employee negotiation. These Federal return-to-duty and follow-up drug tests must be collected under direct observation.

c. Identify other employer sanctions (if applicable) for a Federal alcohol test result of at least 0.02 percent but less than 0.04 percent: The employee will be placed on a 24-hour suspension. Before returning to work the following day, that employee will have to take an additional test confirming a negative result. Identify other employer sanctions (if applicable) for a Federal alcohol test result of 0.04 percent or greater: Any employee who tests positive will be considered in violation of the company policy and may face discipline up to and including immediate termination. Identify other employer sanctions (if applicable) for a Federal positive drug test: Non-applicable

XIII. Self-referral, Co-worker referral, and Non-peer referral (optional) Policies

McMillen Jacobs Associates’ policy to comply with 49 CFR Part 219.1001 and 49 CFR Part 219.1003 is as follows: Employment Relationship. As per 219.1003(b), a regulated employee who enters and follows the tenets of this program as discussed below, will maintain his or her position upon successful completion of an education, counseling, and treatment program as specified by a DAC. Before the employee is charged with conduct sufficient to warrant dismissal, the employee must seek assistance through the company for his or her alcohol or drug use problem or be referred for such assistance


19

by another employee or by a representative of the employee’s collective bargaining unit. Imminent Detection. An employee may not use the referral program for the purpose of avoiding the imminent and probable detection of a rule violation by a supervising employee. No employee may take advantage of self-referral after being notified of a testing event or while in imminent risk of being detected for possession of alcohol or controlled substances. Reasonable Suspicion. In the case of a Co-worker referral or a Non-peer referral (optional), if the employee accepts the referral and has agreed to a Rule G waiver, there is no need for the company to perform a Federal reasonable suspicion test. If the Federal reasonable suspicion test occurs, the referral takes precedence and a written request shall be submitted to the FRA Drug and Alcohol Program Manager for permission for reclassification to non-DOT status. This will allow the employer to vacate the return-to-duty and follow-up (RTD/FU) requirements of the reasonable suspicion test violation. Thus, the co-worker referral will take precedence and all subsequent RTD/FU testing will be appropriately conducted under non-DOT/company authority as per Part 219 Subpart K. In this scenario, the reasonable suspicion positive test result(s) are not subject to 49 CFR Part 40.25 requests from any subsequent DOT-regulated employers. In the case of a Co-worker referral or a Non-peer referral (optional), when the employee does not accept the referral and does not agree to a Rule G waiver, the company must properly observe the employee for signs and symptoms of alcohol and/or drug use/misuse. If signs and symptoms are observed, the company must perform a Federal reasonable suspicion testing. In this scenario, the reasonable suspicion positive test result(s) are subject to DOT-regulated RTD/FU testing and 49 CFR Part 40.25 requests from any subsequent DOT-regulated employers. Referral Sources. The company must specify whether, and under what circumstances, its policy provides for the acceptance of referrals from other sources, including (at the option of the company) supervisory employees. Identify acceptable referral sources besides the affected regulated service employee:

McMillen Jacobs Associates accepts referrals from non-peer sources? Yes No

X


20

Examples of non-peer sources include friends and family, etc. that contact the company. A company representative will meet with the employee in person regarding the information and determine whether to the employee is unsafe to work with or in violation of 49 CFR Part 219. If the company representative determines that employee is unsafe, the employee may either accept or reject the referral. If rejected, a company representative trained in signs and symptoms would perform a Rule G observation on the employee in question. If signs and symptoms are present, then the railroad representative would order reasonable suspicion testing of the on-duty employee. General Conditions. If the employee accepts the referral they must contact the DAC within 3 days. The employee must cooperate with the DAC in the recommended course of counseling or treatment. Locomotive engineers and conductors that do not cooperate with the DAC will be considered to have active substance abuse disorders as per 49 CFR Part 240.119 and 49 CFR Part 242.115 and would have their confidentiality waived. Once an employee has contacted the DAC, the DAC’s evaluation shall be completed within 10 working days. If more than one evaluation is required, the evaluations must be completed within 20 working days. No follow-up treatment, care, or testing shall exceed 24 months unless it involved a Part 219 violation. Confidentiality. The company treats the referral and subsequent handling, including counseling and treatment, as confidential. With respect to a certified locomotive engineer, conductor or a candidate for certification, the policy of confidentiality is waived (to the extent that the company shall receive from the Employee Assistance Professional (EAP) or DAC, official notice of the substance abuse disorder and shall suspend or revoke the certification, as appropriate) if the person at any time refuses to cooperate in a recommended course of counseling or treatment. Any drug and/or alcohol testing conducted pursuant to McMillen Jacobs Associates’ referral policy is non-Federal testing because a violation of Federal regulations has not occurred. Leave of Absence. The company will grant a minimum leave of absence that the DAC recommends to complete a primary education, counseling, or treatment program


21

and to establish control over the employee’s drug or alcohol abuse problem. An employee with an active substance abuse disorder may not perform regulated service until the DAC reports that safety is no longer affected. Return to Service. The employee will be returned to service on the recommendation of the DAC. The employee must be returned to service within five working days of the DAC’s notification to the company that the employee is fit to return to regulated service and the receipt of a follow-up testing plan as per Part 219.1003(h)(2). The company may condition the employee’s return on a return-to-duty medical evaluation.

McMillen Jacobs Associates requires a return-to-duty medical evaluation? Yes No Compensation. 49 CFR Part 219.1001(d)(1) does not require the company to compensate the employee for any period that the regulated employee is restricted from performing regulated service under the referral program. However, compensation at a nominal rate has been seen to markedly increase participation in the referral program to enhance safety at the company. McMillen Jacobs Associates compensates employees while engaged in a referral program of education, counseling, and treatment? Yes No Compensation is at 0% of regular pay while participating in a referral program. Self-referral: Regulated employees may contact the DAC at the following telephone and/or email address and contact hours:

X

X

Drug and Alcohol Counselor (DAC): Contact person: Guardian Integrated Behavioral Health: WorkLife

Matters Address: 3070 Bristol Street Ste 350 Costa Mesa, CA 92626 Phone: ((800)386.7055


22

Optional Provisions. 1. The policy may provide that it does not apply to an employee who has

previously been assisted by the company under a policy or program substantially consistent with 49 CFR Part 219.1005(c) or who has previously elected to waive investigation under 49 CFR Part 219.1005 (co-worker report policy). Adopts this option: Yes No If you checked the above option “No”, please identify how many times and/or at what intervals an employee may use the referral programs: _____________________________________________________________________________________________________________________________________________________________________________________________

2. A referral policy may provide that the rule of confidentiality is waived if the employee at any time refuses to cooperate in a DAC’s recommended course of counseling or treatment; and/or the employee is later determined, after investigation, to have been involved in an alcohol or drug related disciplinary offense growing out of subsequent conduct. Identify whether you adopt the first, second, or both options: Adopts Both Options: Yes No Adopts 1st Option only: Yes No Adopts 2nd Option only: Yes No

3. The policy may provide that, in order to invoke its benefits, the employee must report to the contact designated by the company either during non-duty hours (i.e., at a time when the employee is off duty); or while unimpaired and otherwise in compliance with the company’s alcohol and drug rules consistent with 219.1005(d). Identify whether you adopt this optional provision: Adopts this option: Yes No

4. The policy may require successful completion of a return-to-service medical examination as a further condition on reinstatement in regulated service. Identify whether you adopt this optional provision: Adopts this option: Yes No

5. Other Optional Provisions: ________________________________________ ______________________________________________________________

X

X

X

X


23

Co-worker referral General Conditions and Procedures. 1. The alleged violation must come to the attention of the company as a result of

a report by a co-worker that the employee was apparently unsafe to work with or was, or appeared to be, in violation of Part 219 or the company’s alcohol and drug rules.

2. If the company representative determines that the employee is in violation, the

company will immediately remove the employee from service in accordance with its existing policies and procedures. The company must allow the employee the opportunity to accept the co-worker referral. If rejected, the company may proceed to reasonable suspicion testing based on signs and symptoms of prohibited alcohol or drug use as determined by a trained supervisor.

Alternate Programs.

The company may request FRA to consider the following alternate program to fulfill the requirements under 49 CFR Part 219.1001 with more favorable conditions to regulated employees troubled by drug or alcohol abuse problems. The alternate program must have the concurrence of the recognized representatives of the company employees as per 49 CFR Part 219.1007(b):

McMillen Jacobs Associates requests FRA to consider an alternate program for consideration? Yes No Submit to the FRA Drug and Alcohol Program Manager at:

U.S. Department of Transportation Federal Railroad Administration, Office of Railroad Safety - RRS-19 1200 New Jersey Avenue SE Washington DC 20590

If applicable enter alternate program in this box.

X


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APPENDIX A Once the FRA has accepted a railroad contractors Random drug and alcohol testing plan, the company will receive an acceptance letter, which includes these conditions.

STANDARD APPROVAL CONDITIONS FOR RANDOM TESTING PROGRAMS

1. This acceptance is effective upon receipt with respect to all matters within its

scope. FRA reserves administration jurisdiction over all approvals and may reopen review based upon experience gained during implementation (audits).

2. Acceptance of the subject random testing program does not constitute or imply the granting of a waiver or exemption from any provision of Federal law or regulation. Compliance with all applicable provisions of 49 CFR Parts 219 and 40 is required. All random program plans must be applied in accordance with the criteria listed in this Appendix A and Appendix B.

3. Acceptance is contingent upon the company making appropriate amendments to the program to conform to any pertinent regulatory amendments that may be issued hereafter. Any such program amendments that may be required shall be submitted to the Associate Administrator for Safety at FRA by the effective date of the subject regulatory amendments, or by the expiration of 30 days from publication of the regulatory amendments in the Federal Register, whichever is later.

4. Amendments to the program shall be submitted as required by 49 CFR 219.605 and 49 CFR 219.607 and 219.609 and shall not be implemented prior to acceptance. The following guidance is provided with respect to when a program is deemed to have been amended. A. Any change in the selection methodology, the criteria for scheduling

collections, non-availability criteria, or other structural element is a program amendment. Any change in the organizational level at which a function is carried out is a program amendment.

B. Substitution of incumbents performing the same function at the same organizational level (persons or contractors/volunteers) is not deemed to amend the program. Notification of these changes would be appreciated to assist FRA in maintaining liaison, but is not required.

C. Any change in a program that is occasioned by an amendment of an applicable DOT/FRA regulation and that involves the exercise of discretion to choose between or among one or more courses of action is a program amendment required to be filed under item 3 above. Any non-discretionary change in a program that is required by amendment of an applicable DOT/FRA regulation is not considered a program amendment requiring approval; however, the Office of Safety, FRA, would appreciate receipt of an informational copy of the revised program document showing current compliance.


25

D. Any case not addressed above may be resolved by contacting the Office of Safety, Administrator for Safety or that individual’s delegate.


26

APPENDIX B

CRITERIA FOR ASSESSING DEPARTMENT OF TRANSPORTATION (DOT) RANDOM DRUG AND ALCOHOL TESTING PROGRAMS

Section I. Random Testing Pools

A. Random pool(s) must accurately and completely include all regulated service personnel. Whoever is performing the safety-sensitive “regulated service”, regardless of job title or status, is subject to 49 CFR Part 219 requirements (supervisors, volunteers, contractors, etc.). Pool lists must be retained for a minimum of two years.

B. An employer may not mix regulated service and non- regulated service personnel in the same pool.

C. Multiple pools for an employer are acceptable. D. Employees do not need to be placed in separate pools for drug and alcohol

testing selection. E. Employees from different DOT operating administrations can be included in

the same pool. It is strongly recommended, however, that employers not mix groups of personnel subject to different drug or different alcohol testing rates (i.e., having some employees subject to a 50% rate for drugs and other employees subject to a 25% rate in the same pool). If they do, they must test the entire pool at the highest selection rate for any of the groups with personnel in the pool.

F. Pools may not be diluted with regulated service personnel who rarely perform regulated service duties (i.e., less than once per quarter).

G. Pools must be routinely updated (i.e., at least monthly for employers with either a changing workforce or seasonal employees; and quarterly for employers with a generally stable workforce).

H. Besides individual employees, specific jobs (i.e., third shift main dispatcher at XYZ location) or operational units (i.e., trains) may also be pool entries. However, there may not be a significant difference in the size of the entries in the pool.

I. Pool entries may not be constructed in a way which could result in a manager/supervisor having discretion as to who would actually provide a sample (e.g., a specific job cannot be selected with multiple people working in it at the same time, but with only one to be tested).

Section II. Random Selections

A. Everyone in a pool must have an equal chance of selection in each selection period. 1. No individual, job, or operational unit may be removed from the pool if it

is still actively performing regulated service. However, employees doing


27

de minimus regulated service may be eliminated from the pool (see Section I.-F).

2. There may be no selections without replacement (i.e., an individual cannot be removed from the pool because he or she was previously tested).

3. No selection weightings are allowed which would increase or decrease the chance of any individual being selected.

B. The following selection options are acceptable. Note that manual selection using names or social security numbers drawn out of a hat (or equivalent) is no longer an acceptable practice:

1. Computer programs which randomly select entries from an employee list without apparent bias. The specific selection criteria used by the computer must be extensively detailed in writing, and each computer draw must be retained as a record for a minimum of two years; or

2. Manual selection from a list of employees using a random-number table. The specific criteria used to select from the table must be documented in writing, including detail on how the initial starting point in the table was determined. Each draw, as well as a copy of the table portion used, must be retained as a record for a minimum of two years. See Appendix C for Model Procedures to Conduct a FRA-Acceptable Random Testing Program Using a Random Number Table for Selections.

C. If the employee testing pool is so small that it does not allow testing each selection period, then the employer must have in place a mechanism to randomly determine which selection periods will have selections and which will not. The specific criteria used to make this determination must be detailed in writing and the determination itself must be retained as a record for a minimum of two years.

D. If required drug and alcohol testing rates are different (i.e., 25% for drugs and 10% for alcohol) and a single pool is being used, it is permissible to select one list of employees and designate a proportion for both drug and alcohol testing and a proportion for drug testing only. The specific criteria used to make this determination must be detailed in writing, and the master selection list with both sub-groups clearly identified must be retained as a record for a minimum of two years.

E. Employers should carefully monitor significant changes in its workforce in order to ensure that an appropriate number of tests will be conducted each year. Unless otherwise directed by the DOT Operating Administration, changes in the employee base of greater than 10% in a quarter should result in a recalculation of total tests required.

Section III. Implementation of Random Collections

A. Collections must be distributed unpredictably throughout the designated testing period, covering all operating days (including holidays) and shifts (24-


28

hour clock). There is no expectation that day/night or shift collection distributions be equal but there has to be sufficient testing to establish deterrence by generally mirroring employer operations.

B. Collections must be unpredictable within a work shift (some collections must be conducted at the beginning, middle, and end). There is no expectation that “within-shift” collection distributions be equal. Sufficient testing must be conducted at the start, middle and end of shifts to provide deterrence. Both beginning of and ending of shift collections are particularly important. For alcohol testing, at least 10% of successful collections must fall within each period of the shift.

C. No discretion is allowed with collection dates or collection times which would result in a subjective choice by a field manager/supervisor as to who was actually collected. That is, if a test time frame is permitted in the employer’s program, a manager/supervisor with knowledge of specific personnel assignments may not have discretion in the selection of who will be tested.

D. Specific reasons for “no-tests” must be documented in writing by the employer, with records maintained for two years. Acceptable reasons for no-tests should relate to critical safety concerns, unforeseen or unpredictable significant adverse impact to operations, or employee illness or vacation.

Section IV. Records All records which support the random testing program, including notes, memoranda, pool makeups, number tables, etc., must be retained for a minimum of two years.



Attachment B Verification – Roadway Worker Protection / On-Track Railroad Safety Plan


Verification – Roadway Worker Protection / On-Track Railroad Safety


To: _________________________, Environmental Health and Safety Director

cc: Human Resources

RE: Underground Division Safety: Roadway Worker Protection / On-Track Railroad Safety

I have read the Underground Division Roadway Worker Protection / On-Track Railroad Safety Plan and understand my responsibilities as outlined in the plan.

Print Name: ___________________________________

Signature: ___________________________________

Date: ___________________________________

Underground Division Supervisor: _____________________________________

Underground Division Office: _____________________________________



Appendix J Forms These forms are examples and may be modified for site-specific plans:

Accident Investigation Aid Accident Investigation Report Construction Site Safety Review Form Field Risk Assessment Briefing Checklist Office Safety Review Form Surface Site Safety Review Form Underground Site Safety Review Form*


Accident Investigation Aid


SECTION 1. PREANALYSIS PREPARATION Information and Evidence Here’s a partial list to consider: Site visit Evidence Photographs Diagram of the location showing the places of involved

people, vehicles, equipment Environmental conditions The equipment and tools involved, including equipment tag,

equipment specs, read out of instruments, condition of equipment, etc.

The work procedures used, tailboard topic, etc. Responder’s notes, reports (e.g., police, CHP, emergency

responders) The relevant previous hazard identification reports (e.g., Job

Safety Analysis for the task, design review for the equipment, inspection for the vehicle)

Drug and alcohol test results

Interview Questions You may want to interview employee(s), third parties, contractors, witnesses, responders (sheriff, police, fire, emergency medical, etc.), technical specialists, and/or others who do similar tasks. Determine (if applicable): What was the site condition before the incident? Why was the person doing this task/activity? What initiated (started) the incident (event)? What happened (if safe to do so, see if person could “act out” the

situation)? What is the typical way to do this task or activity? Was this something new? If so, what was new? Is there a written procedure for this task? What is the procedure? If

not, how did the person know how to do the task? How has a tailgate, meeting, or public information venue covered this

topic? How were people trained on this? When? Refresher? Certifications? What were people wearing (shoes, safety glasses, long sleeve shirt,

PPE, etc.)? Any ideas for prevention or correction?

SECTION 2. ROOT CAUSE ANALYSIS AID: CONTRIBUTING FACTORS Physical Factors

Working conditions: Housekeeping Lighting Visibility Noise Temperature (hot/cold) Room to maneuver Wet or slippery surfaces Working at heights Working below grade Working in or near traffic Confined space Seismic activity Criminal behavior Weather conditions

Facilities or Equipment: Equipment failure Difficult to operate or maintain Visual displays Warning signs Maintenance or calibration

Environmental: Lightning Storm conditions Water / flood Excess heat Animals, insects, poisonous plants

Human Factors

Worker(s) Actions/ Reasoning: Experience Rule or procedure not followed Training/instructions/procedure Understanding procedures /instructions Attention distracted Hasty Fooling around/horseplay Shortcut (note if done regularly and by

others) Wrong type of equipment or tool used

Personal Factors Fatigued or sick Emotional stress Impairment from medication or other

substances Personal or other Protective Equipment: Did not consider PPE PPE encumbered or stressed the worker PPE not worn Inappropriate clothing or footwear

Management Systems

Personnel Supervision: Work assignment or capabilities/skills

match Task briefing or tailboard meeting Monitoring or evaluation of worker Procedure/Instructions enforcement Communication by supervisors Did not know PPE required for task

Work Scheduling or Planning: Change of personnel or shift turnover Inadequate tools or materials Improper tools or materials Insufficient time or manpower Coordination between work groups

Work Rules or Procedures: No rule or procedure exists Rule or procedure inaccurate or unclear Rule or procedure out-of-date

PPE Unavailable?

Wrong Type of Equipment or Tool Installed or Available?


Accident Investigation Report


SECTION 1. INVESTIGATION INFORMATION

☐ Injury ☐ Illness ☐ Injury Near Miss ☐ Non-Injury Accident

Report Prepared By:

Phone:

Injured Employees’ Supervisor:

Date of Incident Notification:

Date of Incident:

Time of Incident:

Line of Business:

Name of Injured Individual:

Region/ Department/:

Choose one: ☐ Regular ☐ Subcontractor

Choose one: ☐ Full Time ☐ Part Time

Work Schedule on day of incident: ☐ Regular ☐ Overtime

Address of Headquarters: Street: City:

State: Zip:

Job Classification:

Time in Classification:

Employment Date:

IF INCIDENT INVOLVED USE OF MOBILE EMERGENCY SERVICES (ambulance, fire dept., police) OR IN-PATIENT HOSPITALIZATION, CALL THE ENVIRONMENTAL HEALTH AND SAFETY DIRECTOR IMMEDIATELY. Date Called: Choose all that apply: ☐ Not Injured ☐ First Aid ☐ OSHA Recordable ☐ Restricted Duty (cannot do normal job) ☐ Lost Work Day

(Refer to the attached Investigation Aid for guidance on information gathering and interview questions.)

Identify and describe the exact location where the incident occurred:

Describe the incident, including the exact task the person was doing and equipment involved. Give as much detail as possible. Use additional sheets if necessary:

Identify witnesses to the incident (if appropriate, document any witness statements and attach):

Affected individual’s comments (if appropriate, document statement and attach):

Evidence collected and location stored (if appropriate):

Underground Division Safety Policy Manual Accident Investigation Report


INJURY INFORMATION

Specific body part(s) involved (optional for near misses):

Check all that apply for the type of injury: BURNS ENVIRONMENTALLY

RELATED MUSCLE/ BONE/ TISSUE

SURFACE ILLNESS OR DISEASE TEST OR SYMPTOMS

☐ Chemical ☐ Heatstroke/ Heat injury

☐ Dislocation ☐ Animal/ Insect Bite

☐ Infectious ☐ Eyestrain

☐ Electrical ☐ Hypothermia/ Cold Injury

☐ Sprain/ Strain

☐ Cut/Scratch ☐ Skin ☐ Nausea

☐ Heat/Scalds ☐ Drowning ☐ Other Trauma

☐ Puncture ☐ Musculoskeletal ☐ Headache

☐ Cold ☐ Electrocution ☐ Amputation ☐ Blister ☐ Hernia/Digestive ☐ Fatigue ☐ Radiation ☐ Chemical

Effect ☐ Crushing ☐ Bruise ☐ Psyche ☐ Abnormal Blood

Test ☐ Concussion ☐ Foreign

Body Respiratory Abnormal X-Ray

☐ Fracture ☐ ☐ Hearing

If other, please describe:

SECTION 2. IDENTIFICATION AND EVALUATION OF CAUSAL FACTORS Identify the causes and the contributing factors in the boxes below and estimate the frequency for each cause. The four factors are: (a) physical; (b) human; (c) environmental; (d) management systems. Refer to the attached Analysis Aid on page 4 for examples of root causes, and contributing causes.

CAUSES FACTOR

Direct (immediate) Cause (s):

Contributing Cause(s):

Root Cause(s):



SEVERITY: This type of incident will typically result in the following: ☐ First Aid ☐ OSHA-Recordable ☐ Restricted Duty or Lost Time ☐ Fatality FREQUENCY: How often will this type of incident occur: ☐ Monthly ☐ Yearly ☐ 2–10 years ☐ 10+ years

SECTION 3. CORRECTIVE ACTION PLAN Identify the corrective action for each of the causes listed in Section 2 above. Specify who will initiate the corrective action, type of control used, how long it will take to implement, and follow-up date to ensure correction.

Direct Cause Corrective Action:

Responsible Person or Org.: Type of Control: ☐ Engineering ☐ Administrative ☐ PPE Time to Implement: Follow-up Date:

Contributing Cause(s) Corrective Action:

Responsible Person or Org.: Type of Control: ☐ Engineering ☐ Administrative ☐ PPE

Time to Implement: Follow-up Date:

Root Cause Corrective Action: Responsible Person or Org.: Type of Control: ☐ Engineering ☐ Administrative ☐ PPE Time to Implement: Follow-up Date:

SECTION 4. INCIDENT COMMUNICATION What are the “lesson(s) learned”?

Distribute this Report to:

Tailgate Topic to:

E-mail to Other

Supervisors ☐ ☐ ☐

Local Office Employees ☐ ☐ ☐

Regional Office Employees ☐ ☐ ☐

All Employees ☐ ☐ ☐

Contractor/Agency Employees ☐ ☐ ☐

Safety Department ☐ ☐ ☐

Other Organizations ☐ ☐ ☐

Others: ☐ ☐ ☐



SECTION 5. MANAGEMENT REVIEW OF REPORT

Name: Title: Co. Telephone: Date:

Comments:

SECTION 6. ACTION PLAN FOLLOW-UP (for steps in Section 3) For each corrective action identified in Section 3, follow up to ensure it was implemented. Evaluate that the hazard was controlled and no new hazards were created.

Direct Cause Corrective Action: Actual Completion Date: Was the hazard controlled? ☐ Yes ☐ No If no, action taken:

Did this create additional hazards? ☐ Yes ☐ No If yes, action taken:

Contributing Cause(s) Corrective Action: Actual Completion Date: Was the hazard controlled? ☐ Yes ☐ No If no, action taken:


Root Cause Corrective Action: Actual Completion Date:

Was the hazard controlled? ☐ Yes ☐ No If no, action taken:


SECTION 7. MANAGEMENT REVIEW OF FOLLOW-UP

Name/Comments:

Distribution: ☐ If medical services were obtained for Underground Division employee, send original to the Site Safety Health

Officer, with additional copies to McMillen Jacobs Associates Environmental Health and Safety Director and the Underground Division’s Human Resources Department.

☐ Principal-in-Charge. ☐ Other:


Construction Site Safety Review Form


Job Location:

Foreperson: Date of Review:

DESCRIPTION OF JOB: (Describe work taking place at time of Safety Review) ______________________________________________________________ ______________________________________________________________ Below is a checklist of possible conditions you may have seen, please indicate if a condition was: A = Adequate C = Corrected Immediately N = Not Adequate N/A = Not Applicable

Possible Conditions Circle Applicable Codes

Remarks

1. PROGRAM ADMINISTRATION a. Posting OSHA and other Project Site warning posters. A C N N/A b. Do you have safety meetings? A C N N/A

c. Are there medical service and first-aid equipment, stretchers and emergency vehicles available?

A C N N/A

d. Are Project Site injury records being kept? A C N N/A e. Are emergency telephone numbers, such as police

department, fire department, doctor, hospital, ambulance, posted?

A C N N/A

f. Are there site specific rules or regulations that need to be observed (e.g., California Tunnel Orders – Safety Reps and Gas Testers)

A C N N/A

2. HOUSEKEEPING AND SANITATION a. General neatness of working areas. A C N N/A b. Regular disposal of waste and trash. A C N N/A c. Passageways and walkways clear. A C N N/A d. Adequate lighting. A C N N/A e. Projecting nails removed. A C N N/A f. Oil and grease removed. A C N N/A g. Waste containers provided and used. A C N N/A h. Sanitary facilities adequate and clean. A C N N/A i. Drinking water tested and approved. A C N N/A j. Adequate supply of water. A C N N/A k. Disposable drinking cups. A C N N/A

3. FIRE PREVENTIONS a. Fire instructions to personnel. A C N N/A b. Fire extinguishers identified, checked, w/ signs. A C N N/A

Underground Division Safety Policy Manual Construction Site Safety Review Form



Remarks

c. Phone number of fire department posted. A C N N/A d. Hydrants clear, access to public thoroughfare open. A C N N/A e. Good housekeeping. A C N N/A f. No Smoking” posted and enforced where needed. A C N N/A g. Fire brigades. A C N N/A

4. ELECTRICAL INSTALLATIONS a. Adequate wiring and well insulated. A C N N/A b. Fuses provided. A C N N/A c. Fire hazards checked. A C N N/A d. Electrical dangers posted. A C N N/A e. Proper fire extinguishers provided. A C N N/A f. Are terminal boxes equipped with required covers? Are

covers used? A C N N/A

5. HAND TOOLS a. Proper tool being used for each job. A C N N/A b. Neat storage, safe carrying. A C N N/A c. Inspection and maintenance. A C N N/A d. Damaged tools repaired or replaced promptly. Are

employee’s tools inspected and repaired? A C N N/A

6. POWER TOOLS a. Good housekeeping where tools are used. A C N N/A b. Tools and cords in good condition. A C N N/A c. Proper grounding. A C N N/A d. All mechanical safeguards in use. A C N N/A e. Tools neatly stored when not in use. A C N N/A f. Right tool being used for the job at hand. A C N N/A g. Wiring properly installed. A C N N/A

7. POWDER-ACTUATED TOOLS a. Local laws and ordinances complied with. A C N N/A b. All operators qualified / trained? A C N N/A c. Tools and charges protected from unauthorized use. A C N N/A d. Competent instruction and supervision. A C N N/A e. Tools checked and in good working order each day. A C N N/A f. Tools not used on any but recommended materials. A C N N/A g. Safety goggles or face shields in use. A C N N/A h. Flying hazard checked by backing up, removal of

personnel, or use of captive stud tool. A C N N/A

8. LADDERS a. Ladders inspected and in good condition? A C N N/A b. Properly secured to prevent slipping, sliding, or falling? A C N N/A c. Do side rails extend 36 inches above top of landing? A C N N/A d. Rungs or cleats not over 12 inches on center. A C N N/A e. Stepladders fully open when in use. A C N N/A




Remarks

f. Metal ladders not used around electrical hazards. A C N N/A g. Proper maintenance and storage. A C N N/A h. Are ladders painted? A C N N/A i. Are safety shoes in use? A C N N/A

9. SCAFFOLDING a. Is erection properly supervised? A C N N/A b. Will all structural members meet the safety factor? A C N N/A c. Are all connections secure? A C N N/A d. Is scaffold tied into structure? A C N N/A e. Are working areas free of debris, snow, ice, grease? A C N N/A f. Are foot sills and mud sills provided? A C N N/A g. Are workers protected from falling objects? A C N N/A h. Is the scaffold plumb and square with cross-bracing? A C N N/A i. Are guardrails, intermediate rails, & toe boards in place? A C N N/A j. Is scaffold equipment in good working order? A C N N/A k. Are ropes and cables in good condition? A C N N/A

10. HOISTS, CRANES, AND DERRICKS a. Inspect cables and sheaves. A C N N/A b. Check slings and chains, hooks and eyes. A C N N/A c. Equipment fully supported. A C N N/A d Outriggers used if needed. A C N N/A e. Power lines inactivated, removed or at safe distance. A C N N/A f. Proper loading for capacity at lifting radius. A C N N/A g. All equipment properly lubricated and maintained. A C N N/A h. Signal person where needed. A C N N/A i. Signals understood and observed. A C N N/A j. Are inspection and maintenance logs maintained? A C N N/A

11. HEAVY EQUIPMENT a. Regular inspection and maintenance. A C N N/A b. Lubrication and repair of moving parts. A C N N/A c. Lights, brakes, warning signals operative. A C N N/A d. Wheels chocked when necessary. A C N N/A e. Haul roads well maintained and laid out properly. A C N N/A f. Protection when equipment is not in use. A C N N/A g. Are shut-off devices on hose lines in case of hose

failure? A C N N/A

h. Are noise arresters in use? A C N N/A

12. MOTOR VEHICLES a. Regular inspection and maintenance. A C N N/A b. Qualified operators. A C N N/A c. Local and state vehicles laws and regulations observed. A C N N/A d Brakes, lights, warning devices operative. A C N N/A




Remarks

e. Weight limits and load sizes controlled. A C N N/A f. Personnel carried in a safe manner - seated. A C N N/A g. Is all glass in good condition? A C N N/A h. Are back-up signals provided? A C N N/A i. Are fire extinguishers installed where required? A C N N/A

13. GARAGES AND REPAIR SHOPS a. Fire hazards. A C N N/A b. Dispensing of fuels and lubricants. A C N N/A c. Good housekeeping. A C N N/A d Lighting. A C N N/A e. Carbon monoxide dangers. A C N N/A f. Are all fuels and lubricants in proper containers? A C N N/A g. Proper ventilation. A C N N/A h. Proper grounding and bonding. A C N N/A

14. BARRICADES a. Flood openings planked over or barricaded. A C N N/A b. Roadways and sidewalks effectively protected. A C N N/A c. Adequate lighting provided. A C N N/A d. Traffic controlled. A C N N/A

15. HANDLING AND STORAGE OF MATERIALS a. Are materials properly stored or stacked? A C N N/A b. Are passageways clear? A C N N/A c. Stacks on firm footings, not too high. A C N N/A d. Proper number of personnel for each operation. A C N N/A e. Are personnel lifting loads correctly? A C N N/A f. Are materials protected from weather conditions? A C N N/A g. Protection against falling into hoppers and bins. A C N N/A h. Is dust protection observed? A C N N/A i. Extinguishers and other fire protection. A C N N/A j. Is traffic controlled in the storage area? A C N N/A

16. EXCAVATION AND SHORING a. Are adjacent structures properly shored? A C N N/A b. Is shoring and sheathing used for soil and depth? A C N N/A c. Are roads and sidewalks supported and protected? A C N N/A d. Is material stored too close to excavations? A C N N/A e. Is excavation barricaded and lighting provided? A C N N/A f. Is equipment a safe distance from edge of excavation? A C N N/A g. Are ladders provided where needed? A C N N/A h. Are equipment ramps adequate? A C N N/A i. Is job supervision adequate? A C N N/A

17. DEMOLITION a. Are operations planned ahead? A C N N/A




Remarks

b. Is there shoring of adjacent structures? A C N N/A c. Are material chutes used? A C N N/A d. Is there sidewalk and other public protection? A C N N/A e. Clear operating space for trucks and other vehicles. A C N N/A f. Adequate access ladders or stairs. A C N N/A

18. PILE DRIVING a. Are there proper storage procedures? A C N N/A b. Is unloading only by properly instructed personnel? A C N N/A c. Are steam lines, slings, etc., in operating condition? A C N N/A d. Are pile driving rigs properly supported? A C N N/A e. Are ladders on frames? A C N N/A f. Are cofferdams maintained and inspected? A C N N/A g. Is adequate pumping available? A C N N/A h. Is personnel protection adequate? A C N N/A

19. EXPLOSIVES AND BLASTING a. Qualified operators and supervision. A C N N/A b. Proper transport vehicles. A C N N/A c. Local laws and regulations observed. A C N N/A d Storage magazines constructed per regulations or as

recommended. A C N N/A

e. Cases opened properly. A C N N/A f. “No Smoking” signs posted and observed where

appropriate. A C N N/A

g. Detonators tested before each shot. A C N N/A h. All personnel familiar with signals, and signals properly

used at all times. A C N N/A

i. Inspection after each shot. A C N N/A j. Proper protection and accounting for all explosives at all

times. A C N N/A

k. Proper disposition of wrappings, waste and scrap. A C N N/A l. Advise nearby residents of blasting, and inspect potential

damage areas. A C N N/A

m. Check radio frequency hazards. A C N N/A

20. FLAMMABLE GASES AND LIQUIDS a. All containers clearly identified. A C N N/A b. Proper storage practices observed. A C N N/A c. Fire hazards checked. A C N N/A d. Proper storage temperatures and protection. A C N N/A e. Proper types and number of extinguishers nearby. A C N N/A f. Carts for moving cylinders. A C N N/A

21. MASONRY a. Proper scaffolding. A C N N/A




Remarks

b. Masonry saws properly equipped, dust protection provided.

A C N N/A

c. Safe hoisting equipment. A C N N/A

22. CONSTRUCTION IN or NEAR ROADS a. Laws and ordinances observed. A C N N/A b. Competent flaggers properly dressed, instructed and

posted. A C N N/A

c. Adequate warning signs and markers. A C N N/A d. Equipment not blocking right-of-way. A C N N/A e. Traffic control through construction site. A C N N/A f. Adequate marking and maintenance of detours. A C N N/A g. Dust control. A C N N/A h. Adequate lighting. A C N N/A

23. PERSONAL PROTECTIVE EQUIPMENT a. Hardhats -head protection. A C N N/A b. Eye protection. A C N N/A c. Face shields. A C N N/A d. Helmets and hoods. A C N N/A e. Respirators and masks. A C N N/A f. Gloves, aprons, and sleeves: rubber or plastic, designed

to afford protection from alkalis and acids; electrician’s rubber gloves with protectors.

A C N N/A

g. Respirators for harmful dust, asbestos, sand blasting, welding (lead paint and galvanized zinc or cadmium).

When there is a question about injurious exposure, notify superior immediately, who in turn shall arrange for atmospheric samples to be taken.

A C N N/A

h. Adequate ventilation when painting or applying epoxy resins. All safe practices in spraying asbestos materials using vacuum to clean up.

A C N N/A

24. UNSAFE ACTS AND/OR PRACTICES OBSERVED (list) 25. OTHER Underground Division Representative’s Signature:

DATE:


Field Risk Assessment Briefing Checklist


Project Name & Site Location

Job No.

Description of the Site (list all applicable)

First or Return Visit?

Project Manager Date Person(s) Visiting Site File Ref.

Activities to be Carried Out Special Considerations Injury or Illness Reporting Requirements

Details of Visit and Contact Arrangements Working Alone Limitations Equipment Required for Visit (Check to

confirm or enter N/A)

Place Site

Surface work may be performed alone when permitted by the RE.

Underground work may NOT be performed alone at any time.

Hard hat

High visibility jacket (orange/yellow)

Contact Details

Client / Contractor Contact Name

Can any temporary access equipment be operated by one person?

Y/N Protective footwear

Can all equipment be handled and operated by one person?

Y/N Goggles / safety / glasses

(Have they been notified of the visit?) Y/N Is there a risk from violence? Y/N Gloves

Tel No.

Will adequate means of communication be available?

Y/N Respiratory protection

Authorized to work alone? Y/N Life jacket

Mobile Lone working authorized by:

Survey ladder

Mobile phone or radio

Manhole lifting irons

Estimated Start Time

Travel documents (insurance?)

Completion Time

Training Inoculations

Office notification

To whom?

Has a general site safety awareness briefing been provided?

Y/N Other (please specify

below):

Date of Next Meeting

When?

Are high risk activities involved that require the provision of specific training: e.g., for entry into confined spaces, work on or near railways?

Y/N

• Existing training up to date? Y/N

[Project Name] Field Risk Assessment Briefing Checklist


Briefed by Date Acknowledged by Date Review Date – Where appropriate

Additional Notes

Job Safety Analysis

Complete All Sections. If section is not applicable, then note “Not Applicable.”

Hazards and Exposures Mitigation Measures Initial & Date Completed

Notes: Residual Risk and References

SECTION 1: IS ANY PORTION OF THIS WORK PERFORMED ON OR NEAR ACTIVE CONSTRUCTION SITE?

If yes and your tasks will be performed only in the field office, then Risk Assessment is Low and follow all applicable mitigation measures.

Low Risk Exposure Arrive on-site and park your vehicle in

designated parking areas only.

Sign in at the Resident Engineer’s or Construction Superintendent’s trailer upon arrival.

Be familiar with the contractor’s site-specific safety plan and complete all applicable site safety training PRIOR to beginning your field work.

Follow all field office safety procedures. Notify the field office receptionist when you are

going onto the construction site or into the tunnel.

If yes and your tasks will be performed on the construction site, then Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: high-speed vehicles; uneven walking or work surfaces; fall potential; falling objects; haulage malfunctions & impingements.

Moderate Risk Exposure. In addition to the Low Risk Mitigations: Utilize the following Personal Protective

Equipment (PPE) at ALL times outside of the field office: hard hat; eye protection with side shields; long sleeve shirt; Class II reflective safety vest; long pants; work boots with ankle support and steel toe protection.

Carry, and use as applicable, the following PPE: gloves and ear plugs.

Walk in designated areas only. When walking near high-speed traffic, a Class III reflective vest is required unless you are walking behind a K-rail or other structural barrier.

When heavy equipment is approaching you, move away from the traffic-way and stop until the operator designates that it is safe for you to continue walking or until the equipment has passed you.

Never walk or stand under a suspended crane load or walk under the crane boom unless the crane operator designates that it is safe for you to continue walking.

Any location where a fall potential exceeding 4 feet exists requires a barrier or fall protection.

Consult site Tunnel Safety Representative if you have any questions or concerns.



Job Safety Analysis Complete All Sections. If section is not applicable, then note “Not Applicable.”



If yes and your tasks will be performed in the tunnel, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; flooding; loss of ground control; fire & explosion; haulage malfunctions & impingements; airborne dust, toxic fumes, and vapors; and burns.

High Risk Exposure. In addition to the Moderate Risk Mitigations: In addition to the PPE requirements above,

utilize the following additional PPE at ALL times underground: MSHA-rated flashlight; gloves; ear plugs; waterproof (knee) boots with steel toe protection.

Smoking or using smokeless tobaccos is not permitted underground.

If the work area is dusty, refer to specific respiratory protection requirements below.

If the work area is on live rail track, refer to specific rail safety requirements.

If the work area includes pits, vaults, or shafts, refer to specific confined space safety requirements below.

Consult site Tunnel Safety Representative if you have any questions or concerns.

SECTION 2: IS THERE A RISK OF EXPOSURE TO DUST AND AIRBORNE CONTAMINANTS LIKE ASBESTOS, CEMENT, FLY ASH, OR SILICA DUST? If yes and if engineering and

administrative controls HAVE eliminated the exposure, then Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; respiratory illness; and airborne dust, toxic fumes, and vapors.

Moderate Risk Exposure Monitor atmospheric conditions for any

changes.

Carry a dust mask and use as desired. Do not disturb or touch any settled dusts or

animal dung.

Notify supervisor immediately regarding respiratory protection if working conditions change.

If yes and if engineering and administrative controls HAVE NOT eliminated the exposure, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; respiratory illness; and airborne dust, toxic fumes, and vapors.

High Risk Exposure Avoid the dusty work environment.

Notify supervisor immediately regarding respiratory protection.

Complete appropriate respiratory protection training including baseline physical examination.

As approved, wear appropriate respiratory protective device(s) and maintain personal hygiene consistent with health requirements.

Maintain protective devices as trained and in accordance with manufacturer’s recommendations.

Seek specialist advice if appropriate. Consult site Tunnel Safety Representative if

you have any questions or concerns.

If yes, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety

High Risk Exposure In addition to the PPE requirements above,

utilize the following additional PPE at ALL times underground: two MSHA rated






Analysis; loss of accountability; hypothermia; hazardous atmospheres; flooding; loss of ground control; fire & explosion; and airborne dust, toxic fumes, and vapors.

flashlights; gloves; ear plugs; waterproof (knee) boots with steel toe protection.

Comply with the Permit-Required Confined Space Safety Plan (Appendix C of the Underground Division Safety Policy Manual).

At least two entrants must be currently certified in first aid and CPR.

Smoking or using smokeless tobaccos is not permitted underground.


Seek specialist advice if appropriate. Consult site safety manager (SSM) if you have

any questions or concerns.

If yes and your tasks will be performed along the line or in the tunnel, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: rail traffic; hazardous atmospheres; flooding; loss of ground control; fire & explosion; haulage malfunctions & impingements; airborne dust, toxic fumes, and vapors; and burns.

High Risk Exposure In addition to the PPE requirements above,

utilize the following additional PPE at ALL times underground: MSHA rated flashlight; gloves; ear plugs; waterproof (knee) boots with steel toe protection.

Comply with the Roadway Worker Protection / On-Track Railroad Safety Plan (Appendix I of the Underground Division Safety Policy Manual).

Complete all appropriate rail safety training. Smoking or using smokeless tobaccos is not

permitted underground.


If the work area includes pits, vaults, or shafts, refer to specific confined space safety requirements below.

Seek specialist advice if appropriate. Consult site Tunnel Safety Representative if

you have any questions or concerns.

SECTION 3: IS THERE A RISK OF EXPOSURE TO OTHER HAZARDOUS SUBSTANCES OR CHEMICALS? If yes and engineering controls are

sufficient to reduce or eliminate a potential exposure, then Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; fire & explosion; airborne toxic fumes and vapors; and burns.

Moderate Risk Exposure Notify your supervisor that you will be working

near hazardous substances or chemicals and describe the engineering controls necessary to reduce or eliminate the potential exposure.

Monitor work conditions and avoid the work area if engineering controls are disabled.

If yes and your tasks will be performed in the vicinity of the substances, then Risk Assessment is High and follow all applicable

High Risk Exposure Notify your supervisor that you will be working

near or handling hazardous substances or chemicals.






mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; fire & explosion; airborne toxic fumes and vapors; and burns.

Complete all appropriate safety training for working near or handling the hazardous substances or chemicals.

Wear appropriate protective clothing and PPE for the task.

Perform the work responsibly. Clean up and dispose of contaminated

clothing, PPE, & equipment as necessary.

Notify your supervisor that the work is completed.

SECTION 4: IS THE WORK TO BE CARRIED OUT OVER, ALONGSIDE, OR IN WATER? If yes and the water is not flowing

“rapidly” but deeper than 3.3 feet (1 m), then the Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: water hazards; drowning; hypothermia.

Moderate Risk Exposure Notify your supervisor that you will be working

near water.

Wear appropriate knee boots, hip boots, or waders to limit exposure to water. Use a walking stick, as appropriate, to maintain balance.

Consider wearing a personal flotation device. Monitor work conditions and avoid the work

area if engineering controls are disabled.

If yes and the water is flowing “rapidly” deeper than 3.3 feet (1 m), and includes a fall potential, then the Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: water hazards; drowning; hypothermia.


near water.

Wear appropriate knee boots, hip boots, or waders to limit exposure to water. Use a walking stick, as appropriate, to maintain balance.

Wear an appropriate fall protection device (including harness) to prevent entering the water.

Wear a personal flotation device. All over-the-water activities will be monitored

by an attendant.


SECTION 5: IS THE WORK TO BE PERFORMED IN A PRESSURIZED WORK ENVIRONMENT? If yes, then the Risk Assessment is

High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: pressurized work environment hazards; confined space hazards; water hazards; drowning; hypothermia; and atmospheric hazards.


in a pressurized work environment.

Obtain medical clearance from a licensed physician specialized in hyperbaric work environments and provide a copy to HR & the Environmental Health and Safety Director.

Complete compressed air worker training specific to the work site.

Document the maximum working pressure and “bottom time” limits for each entry,

Identify the specific hazards within the pressurized work environment area with the job supervisor including: hot work, high or low air temperature, poor air quality, poor mixed-gas






quality, loss of ground support, loss of water control, slips & falls.

Review the contingency plans with the job supervisor in the event that engineering controls malfunction or fail.

Wear appropriate PPE and apparel. Wear an appropriate fall protection device

(including harness), as applicable.


SECTION 6: OTHER SITE CHARACTERISTICS Does the work require the use of specialist access equipment? Ladders, scaffold towers, mobile plant etc.?

Use appropriate access method. Use harness. Use contractor’s personnel cages & hoists

properly.

Does the site lack control by the owner/contractor?

Adopt remote supervision from office. Adopt a cautious approach on site; assess

before proceeding.

Other …………………………. Does the work involve access to a highway / road?

Remove hazard, close road. Only use access road when specifically

required. If weather conditions limit your visibility or motorist’s visibility, consider rescheduling the work.

Use a lookout. Wear Class III (highway) or Class II (road) high

visibility clothing.

Could parking be a problem? (Struck by other road users, creating a hazard to other users.)

Park in a designated car park. Park clear of the traffic corridors or lanes. Park off site and walk. Carpool to reduce the number of vehicles on-

site.

Are personal welfare facilities readily available?

Toilets. Washing facilities. Food (hot drinks). Other:

Are appropriate first aid responders and equipment readily available on site?

Does site have ready access to first aid facilities?

Does first aid kit or person qualified in first aid need to be supplied?

Additional Comments


Office Safety Review Form


Office:

Reviewer:

Date of Review:

Items Comments A N C N/A Steps/stairwells are unobstructed and in compliance with OSHA

General housekeeping is acceptable

Aisles/walkways/stairs are clean and unobstructed

First aid kit is available & well stocked

Blood-borne pathogen kit is available & well stocked

Exits are properly marked

Fire extinguishers are available

Fully charged

Inspected annually

Unobstructed

Lighting is appropriate

Items stored higher than 5 feet are secured

Security system is in place and functional

Employees are comfortable in their workstations

OSHA Bulletin Board Postings include:

Job Safety and Health Protection workplace poster (OSHA 3165 or state equivalent)

Summaries of all petitions for variances from standards or recordkeeping procedures.

Copies of all OSHA citations for violations of standards.

Log and Summary of Occupational Injuries and Illnesses (OSHA 200/300 Log)

Emergency Communication Plan

Extension cords

Faulty outlets

Handrails/stairs

Underground Division Safety Policy Manual Office Safety Review Form


Items Comments A N C N/A Slip and fall concerns (e.g., ice, oil)

Clear pathways/stairs

Exterior Lighting

OTHER:

Surface Site Safety Review Form


Job Location:

Foreperson:

Date of Review

DESCRIPTION OF JOB: (Describe work taking place at time of Safety Review) ______________________________________________________________________________ ______________________________________________________________________________ Below is a checklist of possible conditions you may have seen, please indicate if a condition was: A = Adequate C = Corrected Immediately N = Not Adequate N/A = Not Applicable

Possible Conditions Circle Applicable Code PERSONAL PROTECTIVE EQUIPMENT First aid kits/emergency response equipment A C N N/A Eye protection / welding/grinding shields A C N N/A Welding jackets/ knee pads A C N N/A Hand protection / rubber goods A C N N/A Hard hats A C N N/A Hearing protection A C N N/A Respirators & cartridges A C N N/A Tools: General inspection / safety guides A C N N/A Safety belts, harnesses, lanyards, ropes A C N N/A

SAFETY ENGINEERING Fire: Tools – extinguishers – inspected/current, permits A C N N/A Flares: Triangular, reflectors, flashlights A C N N/A Radios/communication operational A C N N/A Access trails, walkways, handrails A C N N/A Man lifts/boom trucks/cranes/rigging A C N N/A Public safety (warning signs, etc.) wheel chocks A C N N/A Electrical grounds installed A C N N/A Hazard barriers/high voltage signs up A C N N/A Clearances taken, man-on-line tags, electric hazards identified A C N N/A “Qualified Observer” on site A C N N/A Scaffold & work platforms, ladders A C N N/A Pre–Job Safety Plan completed A C N N/A Local or regional requirements (e.g., California Tunnel Orders) A C N N/A

Underground Division Safety Policy Manual Surface Site Safety Review Form


Possible Conditions Circle Applicable Code HOUSEKEEPING Are trash and debris contained? A C N N/A Are hallways clear of obstructions? A C N N/A Are all Accident Report Forms in vehicles & first aid kits? Yes No N/A Are commercial vehicles inspected daily & every 90 days? Yes No N/A Did you have a tailgate and did everyone attend? Yes No N/A

HAZARD IDENTIFICATION & CORRECTION (Describe the safety hazards that exist on the job and/or accident prevention measures taken):

HAZARDOUS MATERIALS / WASTE Are hazardous materials and wastes properly stored/used? Yes No N/A Is there a Hazardous Materials Inventory (updated monthly)? Yes No N/A Are the SDSs readily available? Yes No N/A Is there any indication of hazardous material spills? Yes No N/A Is the Emergency Response Plan up to date and on site? Yes No N/A

Observations:

Resident Engineer’s Signature: DATE:

Underground Site Safety Review Form


Job Location:

Foreperson:

Date of Review DESCRIPTION OF JOB: (Describe work taking place at time of Safety Review) ______________________________________________________________ ______________________________________________________________ Below is a checklist of possible conditions you may have seen, please indicate if a condition was: A = Adequate C = Corrected Immediately N = Not Adequate N/A = Not Applicable


MEETINGS, JHAs, CORRECTIVE ACTION Is there a “competent person” on site to take corrective action? A C N N/A Has a Job Hazard Assessment (JHA) been performed for all of the day’s activities?

A C N N/A

Has JHA been reviewed for thoroughness; is it complete? A C N N/A Did everyone sign in at the Toolbox (tailgate) Meeting at the start of the shift? A C N N/A Is there a weekly or monthly safety meeting; is attendance documented? A C N N/A Are there site specific rules or regulations that need to be observed (e.g., California Tunnel Orders – Safety Reps and Gas Testers)?

A C N N/A

NOTIFICATION, COMMUNICATION, SECURITY REQUIREMENTS Are check-in/check-out procedures (Brass Board) in place and used? A C N N/A Is the public protected (signage, fences, caution tape, etc.)? A C N N/A Communication (mine phone, radio, etc.). A C N N/A Visitors to site (orientation, tracking, site-specific safety). A C N N/A Is the site secure? (signage, fences, secured, guarded, etc.). A C N N/A

PERSONAL PROTECTIVE EQUIPMENT First aid kits/emergency response equipment (stokes basket, etc.). A C N N/A Are the crews using eye protection / welding / grinding shields? A C N N/A Are the crews using welding jackets / knee pads? A C N N/A Are welding screens being used in the shop to protect workers passing by? A C N N/A Are workers wearing the proper hand protection, rubber gear? A C N N/A Is everyone wearing their hard hat? A C N N/A Are workers wearing hearing protection when noise levels are elevated? A C N N/A Have fit test and physicals been done before respirators are worn? A C N N/A Tools: General Inspection / proper cords / safety guards in place? A C N N/A Fall protection in place and functional? Safety Belts, Harnesses, Lanyards, Ropes.

A C N N/A

Underground Division Safety Policy Manual Underground Site Safety Review Form



FIRE PREVENTION / CONTROL Fire suppression / extinguishers – Are they current? Are permits in place? A C N N/A Are oil soaked rags properly disposed of? A C N N/A No flammable material should be stored within 100 feet of shaft. A C N N/A

GROUND SUPPORT Is portal area adequately supported? A C N N/A Is shaft support installed as planned / required? A C N N/A Is subsidence being monitored and is it <= to expected? A C N N/A Is ground support of underground areas being installed as designed / required? A C N N/A Is rock scaling being performed regularly and as needed? A C N N/A Is there periodic inspection of haulage ways, etc. (monthly track inspection)? A C N N/A

VENTILATION REQUIREMENTS: First consideration is Air Quality Are scrubbers / converters/ or clean burning engines in use? A C N N/A Is air volume (200 cfm/man, 100 cfm/hp) adequate? (Only Feds Allow)? A C N N/A Is air speed at least 30 feet per minute? (Only Feds Allow) A C N N/A Is smoke time being observed (when blasting or other fumes/dust present)? A C N N/A Is ventilation reversible from the surface? A C N N/A Is a competent person checking daily; is flow and quality documented? A C N N/A Is oxygen between 19.5 and 22%? A C N N/A Methane and other flammable gases: 5% of LEL (increase ventilation), 10% of LEL (suspend welding, cutting, or other hot work), 20% of LEL (stop equipment except pumps and ventilation, evacuate unnecessary workers; only workers improving ventilation may be working).

A C N N/A

Hydrogen sulfide levels 5 PPM (Alarm), 10 PPM (10 Minute Exposure), 20 PPM (Stop Work).

A C N N/A

Nitrogen dioxide 5 PPM PEL. A C N N/A Carbon monoxide 50 PPM PEL. A C N N/A Respirators signed area, physicals, decontamination. A C N N/A Gassy or potentially gassy operations. A C N N/A Signs before entering area. A C N N/A Welding/fire watch/hot work permit. A C N N/A Electrical requirements Class 1 Div. 1. A C N N/A Diesel (30 CFR 36). A C N N/A Competent person testing for flammable gases minimum twice per day. A C N N/A Is an entry permit required (confined space). A C N N/A

ILLUMINATION REQUIREMENTS 5 foot candles in general, 10 at work site (drilling, mucking, scaling). A C N N/A Must have a flashlight, caplamp, or emergency lighting. A C N N/A




SPECIAL CONDITIONS FOR DRILLING AND BLASTING UNDERGROUND Safety around a drill jumbo. A C N N/A Powder storage transportation. A C N N/A

SPECIAL REQUIREMENTS FOR USING CRANES / HOISTS Test equipment and man-cage before use. A C N N/A An open cage must be secured by fall protection harness. A C N N/A Communications. A C N N/A Top lander and bottom lander and with rigging training. A C N N/A Max pick load plans. A C N N/A

EMERGENCY PROCEDURES Top landers/bottom landers. A C N N/A Self-rescuers with workers or cached near workers. A C N N/A Is there readily available backup hoisting capacity? A C N N/A

GENERAL ITEMS

Housekeeping Are trash and debris contained? A C N N/A Are passageways clear of obstructions? A C N N/A All company vehicles – do they have Accident Report Forms and first aid kits? Yes No N/A Are commercial vehicles inspected daily & every 90 days? Yes No N/A Electrical assured grounding or GFCI properly used? A C N N/A Is a permit process used for confined space entry? A C N N/A Man-lift/forklift daily inspection. A C N N/A Compressed air: Are whip checks used? A C N N/A Vehicles maintained and inspected? A C N N/A Rail haulage (top of rail out of water, fish plate bolts tight, equipment maintained in good condition, brakes work, etc.).

A C N N/A

Rubber tired haulage. A C N N/A Conveyor belts (guards in place, e-stops, etc.). A C N N/A First aid supplies. A C N N/A Fire extinguishers (head and tail pulleys, welding, etc.). A C N N/A Are only OSHA approved fuel cans used on the project? A C N N/A Is oxygen/acetylene stored/transported correctly? A C N N/A Are flashback arrestors used on acetylene and oxygen regulators? A C N N/A Are all containers labeled? A C N N/A Are walkways clear of debris, and have handrails if necessary? A C N N/A Are ladders correct for the application, and secured? A C N N/A Scaffold/stair towers. A C N N/A Openings/holes covered and secured fenced off. A C N N/A Formwork nails, ties, rebar caps, etc. A C N N/A



Possible Conditions Circle Applicable Codes Spill protection. A C N N/A Emergency phone numbers. A C N N/A Utility companies / emergency shutoff locations. A C N N/A

TRAFFIC/TRUCKING Are traffic plans / detours MUTCD compliant and installed per approved plan? A C N N/A Do vehicles have current DOT inspections? A C N N/A Are loads secured, dump trucks tarped, loose rocks cleaned off of tailgate, etc.?

A C N N/A

HAZARDOUS MATERIALS / WASTE Are hazardous materials and wastes properly stored/used? Yes No N/A Is there a Hazardous Materials Inventory (updated monthly)? Yes No N/A Are the SDSs readily available? Yes No N/A Is there any indication of Hazardous Materials Spills? Yes No N/A Is the Emergency Response Plan up to date and on site? Yes No N/A

Observations:

Underground Division Representative’s Signature:

DATE:



Appendix K Examples These forms are examples and may be modified for site-specific plans:

Assumption of Risk, Release of Liability for Personal Injury Emergency Communication Plan Field Risk Assessment Briefing Checklist Visitor Acknowledgment of Project Site Rules


Assumption of Risk, Release of Liability for Personal Injury

(EXAMPLE)

McMillen Jacobs Associates Underground Division January 2020

I, _______________________________, do hereby release [Construction Company], [Construction Management Company], [Owner], [Others involved], and their joint ventures, owners, officers, insurers, operators, employees, agents, and servants from any and all liability in any way related to my participation in any activities or access I have been granted to the [XXXXXXXX Tunnel Project], located in [XXXX Counties] (the “Project”). I do hereby agree to release and hold harmless any said claims, demands, costs, expenses and compensation arising out of or in the course of or in any way related to any personal injury to me while at the Project.

By signing the release, I acknowledge my understanding and acceptance of the following:

1. Construction activities are inherently dangerous.

2. The Project is not complete and, as such, there are construction debris and open tunnels and holes located at the Project site. Failure on my part to take proper precautions or use a standard level of care to avoid said construction debris and open tunnels and/or holes may result in severe, permanent personal injuries, including, but not limited to, bruised, strained, sprained or torn muscles, tendons and ligaments, broken bones, derangements or dislocations of joints, concussion, brain damage, nerve and spinal cord injury, paralysis and death.

3. The Project is not complete and there is construction equipment on site. Failure on my part to take proper care and precautions to avoid equipment while in use may result in severe, permanent personal injuries, including, but not limited to, bruised, strained, sprained or torn muscles, tendons and ligaments, broken bones, derangements or dislocations of joints, concussion, brain damage, nerve and spinal cord injury, paralysis, and death.

4. The use of proper safety gear is required for the entry into certain aspects of the Project.

I hereby agree to assume the risk of any personal injuries, including death, that may occur as a result of my participation in the photographing, taping, or other activities at the Project site, including, but not limited to, entering into open tunnels, holes, or shafts.

I have read the Assumption of Risk, Release of Liability for Personal Injury and hereby agree to be bound by its terms.

Printed Name: ______________________________________

Signature: _________________________________________

Date: _____________________________________________


Emergency Communication Plan (EXAMPLE)


If you are first on the scene, complete Steps 1 and 2. If not, go to Step 3.

1. CALL 911

2. GIVE EMERGENCY DISPATCHER THIS INFORMATION EXAMPLE only. Put project office address and information below.

Project/Office Name: McMillen Jacobs Associates St. Louis

Street Address: 3636 South Geyer St., St Louis, MO 63127.

Cross streets / Intersection: SE corner of South Geyer and Watson Rd.

Call-back Phone Number: 314.585.5000

3. GO TO THE EMERGENCY ASSEMBLY LOCATION (Note that the assembly location may vary depending on the emergency. Therefore, you may not want to exit a strong building in the event of a tornado.)

Example only. Put assembly location address and information below

Location Name: Airplane at Sculpture Park, basement in the event of a tornado

Address / Intersection: South Geyer and Rott Road

Landmarks: Airplane Sculpture

4. SUPERVISORS, ACCOUNT FOR ALL PERSONNEL

5. SUPERVISORS, NOTIFY THE FOLLOWING PEOPLE Example only. Put current addresses and information below

Office Manager: Wayne Lindsay, 314.858.5001

Regional Principal: Ted DePooter, Office [Get Current Number]

Safety Director: Bill Mitchell [Get Current Cell Phone Number]

Human Resources: Greta Miller [Get Current Number]

President: Dan Adams 206.588.8130

Building Management: Margret Heath, 314.556.8248

Building Management: After Hours 866.878.5102

Hospital: St. Anthony's Medical Center, 314.525.1000

10010 Kennerly Road, St Louis, MO 63128

Hospital: Des Peres Hospital, 314.966.9100

2345 Dougherty Ferry Rd. St Louis, MO 63122

[Project / Office Name] Emergency Communication Plan (EXAMPLE)


6. SUPERVISORS, COMPLETE AN ACCIDENT REPORT WITHIN 24 HOURS EXAMPLE: Assembly location



EXAMPLE: Map to St. Anthony’s Hospital

Normally, you would print the turn-by-turn directions as well.



EXAMPLE: Map to Des Peres Hospital

Normally, you would print the turn-by-turn directions as well.

Caldecott Tunnel – 4th Bore Construction Field Risk Assessment & Briefing Checklist (EXAMPLE) Page 1 of 8

Project name and site location

Caldecott Tunnel – 4th Bore Tunnel Construction Job number JA J3892.3

Description of the site (circle all applicable)

Highway tunnel construction adjacent to in-service traffic lanes of Highway 24. The primary construction site & offices will be located near the Oakland Portal and a secondary site will be located near the Orinda Portal.

First or return visit?

First & Return

Project Manager Date 4 January 2010

Person(s) visiting site

Bhaskar Thapa, Mike McRae, John Stolz, Jan Van Greunen File ref

Activities to be carried out

Provide engineering support during construction including field office engineering and construction observations.

Special considerations

All visitors MUST be preapproved by the Resident Engineer (RE). Persons unfamiliar with underground construction safety must be escorted by a person designated by the RE. The escort must be familiar with the

specific hazards present at the site and the safety precautions necessary to protect all personnel. For visits undertaken by young persons (under 18) or otherwise vulnerable people (e.g., expectant mothers), a more detailed assessment is needed. When work conditions change, this risk assessment must be updated.

Injury or Illness Reporting Requirements

Notify the RE or Superintendent of any injuries or illnesses you incur or witness. If you are injured, DO NOT transport yourself to a clinic or hospital. Ask for assistance. Transportation will be provided for you. Notify your supervisor of any injury or illness.

Details of visit and contact arrangements Working Alone Limitations Equipment Required for Visit (Check to confirm or enter N/A)

Place Site Surface work may be performed alone when permitted

by the RE. Underground work may NOT be performed alone at any

time.

Hard hat

High visibility jacket (orange/yellow)

Contact details

Client / contractor contact name: Can any temporary access equipment be operated by one person?

Y/N Protective footwear State of California, Department of Transportation

Can all equipment be handled and operated by one person?

Y/N Goggles / safety / glasses (Have they been notified of the visit?) Y/N Is there a risk from violence? Y/N Gloves Have available

Tel no. Will adequate means of communication be

available? Y/N Respiratory protection

Not required at this time

Authorized to work alone? Y/N Life jacket Not required at

this time


Mobile

Lone working authorized by: Survey ladder Not required at

this time

Project Director Mobile phone or radio Not required at

this time

Manhole lifting irons Not required at

this time

Estimated start time

8 January 2010, no limitations Travel documents (insurance?) Not required at

this time

Completion time TBD Training Inoculations Not required at

this time

Office notification

To whom? • Has a general site safety awareness briefing

been provided? Y Other (please specify below):

Date of next meeting

When? • Are high risk activities involved which require

the provision of specific training e.g. for entry into confined spaces, work on or near railways etc.?

N

• Existing training up to date? Y/N

Briefed by Date Acknowledged by Date Review Date – Where appropriate

Additional Notes


Hazards and Exposures Mitigation Measures Initial and Date

Completed Notes: Residual Risk and References


Hazards and Exposures Mitigation Measures Initial and

date complete


Section 1: Is any portion of this work performed on or near an active construction site? If yes and your tasks will be performed only in the field

office, then Risk Assessment is Low and follow all applicable mitigation measures.

Low Risk Exposure: • Arrive on-site and park your vehicle in designated parking areas

only.

• Sign-in at the Resident Engineer’s or Construction Superintendent’s trailer upon arrival.

• Be familiar with the contractor’s site-specific safety plan and complete all applicable site safety training PRIOR to beginning your field work.

• Follow all field office safety procedures. • Notify the field office receptionist when you are going onto the

construction site or into the tunnel.

If yes and your tasks will be performed on the construction site, then Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: high-speed vehicles; uneven walking or work surfaces; fall potential; falling objects; haulage malfunctions & impingements.

Moderate Risk Exposure. In addition to the Low Risk Mitigations: • Utilize the following Personal Protective Equipment (PPE) at ALL

times outside of the field office: hard hat; eye protection with side shields; long sleeve shirt; Class II reflective safety vest; long pants; work boots with ankle support; and steel toe protection.

• Carry, and use as applicable, the following PPE: gloves and ear plugs.

• Walk in designated areas only. When walking near high-speed traffic, a Class III reflective vest is required unless you are walking behind a K-rail or other structural barrier.

• When heavy equipment is approaching you, move away from the traffic-way and stop until the operator designates that it is safe for you to continue walking or until the equipment has passed you.

• Never walk or stand under a suspended crane load or walk under the crane boom unless the crane operator designates that is safe for you to continue walking.

• Any location where a fall potentially exceeding 4 feet exists requires a barrier or fall protection.

• Consult site Tunnel Safety Representative if you have any questions or concerns.

High Risk Exposure. In addition to the Moderate Risk Mitigations:




If yes and your tasks will be performed in the tunnel, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; flooding; loss of ground control; fire & explosion; haulage malfunctions & impingements; airborne dust, toxic fumes, and vapors; and burns.

• In addition to the PPE requirements above, utilize the following additional PPE at ALL times underground: MSHA rated flashlight; gloves; ear plugs; waterproof (knee) boots with steel toe protection.

• Smoking or using smokeless tobaccos is not permitted underground.

• If the work area is dusty, refer to specific respiratory protection requirements below.

• If the work area is on live rail track, refer to specific rail safety

requirements. • If the work area includes pits, vaults, or shafts, refer to specific

confined space safety requirements below. • Consult site Tunnel Safety Representative if you have any

questions or concerns.

Section 2: Is there a risk of exposure to dust and airborne contaminants like asbestos, cement, fly ash, or silica dust? If yes and if engineering and administrative controls HAVE

eliminated the exposure, then Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; respiratory illness; airborne dust, toxic fumes, and vapors.

Moderate Risk Exposure • Monitor atmospheric conditions for any changes.

• Carry a dust mask and use as desired. • Do not disturb or touch any settled dusts or animal dung.

• Notify supervisor immediately regarding respiratory protection if working conditions change.

If yes and if engineering and administrative controls HAVE

NOT eliminated the exposure, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; respiratory illness; airborne dust, toxic fumes, and vapors.

High Risk Exposure • Avoid the dusty work environment.

• Notify supervisor immediately regarding respiratory protection. • Complete appropriate respiratory protection training including

baseline physical examination.

• As approved, wear appropriate respiratory protective device(s) and maintain personal hygiene consistent with health requirements.

• Maintain protective devices as trained and in accordance with manufacturer’s recommendations.

• Seek specialist advice if appropriate. • Consult site Tunnel Safety Representative if you have any





Section 3: Is any portion of this work performed in an in-service water/stormwater/sewer tunnel, pipeline, vault, pit, shaft, or head-head access tunnel? If yes, then Risk Assessment is High and follow all

applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: loss of accountability; hypothermia; hazardous atmospheres; flooding; loss of ground control; fire & explosion; airborne dust, toxic fumes, and vapors.

High Risk Exposure • In addition to the PPE requirements above, utilize the following

additional PPE at ALL times underground: two MSHA rated flashlights; gloves; ear plugs; waterproof (knee) boots with steel toe protection.

• Comply with the Tunnel & Confined Space Safety portion of the JA Safety & Health Plan.

• At least two entrants must be currently certified in first aid and CPR.

• Smoking or using smokeless tobaccos is not permitted

underground. • If the work area is dusty, refer to specific respiratory protection

requirements below.

• Seek specialist advice if appropriate. • Consult site Safety Manager if you have any questions or

concerns.

Section 4: Is any portion of this work performed on or near active railroad lines? If yes and your tasks will be performed along the line or in

the tunnel, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: rail traffic; hazardous atmospheres; flooding; loss of ground control; fire & explosion; haulage malfunctions & impingements; airborne dust, toxic fumes, and vapors; and burns.

High Risk Exposure • In addition to the PPE requirements above, utilize the following

additional PPE at ALL times underground: MSHA rated flashlight; gloves; ear plugs; waterproof (knee) boots with steel toe protection.

• Comply with the Railroad Safety portion of the JA Safety & Health Plan.

• Complete all appropriate rail safety training. • Smoking or using smokeless tobaccos is not permitted

underground.

• If the work area is dusty, refer to specific respiratory protection requirements below.

• If the work area includes pits, vaults, or shafts, refer to specific confined space safety requirements below.

• Seek specialist advice if appropriate. • Consult site Tunnel Safety Representative if you have any





Section 5: Is there a risk of exposure to other hazardous substances or chemicals? If yes and engineering controls are sufficient to reduce or

eliminate a potential exposure, then Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; fire & explosion; airborne toxic fumes and vapors; and burns.

Moderate Risk Exposure • Notify your supervisor that you will be working near hazardous

substances or chemicals and describe the engineering controls necessary to reduce or eliminate the potential exposure.

Consider previous site uses

Personal hygiene practices

• Monitor work conditions and avoid the work area if engineering controls are disabled.

If yes and your tasks will be performed in the vicinity of the substances, then Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: hazardous atmospheres; fire & explosion; airborne toxic fumes and vapors; and burns.

High Risk Exposure • Notify your supervisor that you will be working near or handling

hazardous substances or chemicals.

• Complete all appropriate safety training for working near or handling the hazardous substances or chemicals.

• Wear appropriate protective clothing and PPE for the task. • Perform the work responsibly. • Clean up and dispose of contaminated clothing, PPE, &

equipment as necessary. • Notify your supervisor that the work is completed.

Section 6: Is the work to be carried out over, alongside, or in water? If yes and the water is not flowing “rapidly” but deeper than

1 meter, then the Risk Assessment is Moderate and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: water hazards; drowning; hypothermia.

Moderate Risk Exposure • Notify your supervisor that you will be working near water. • Wear appropriate knee boots, hip-boots, or waders to limit

exposure to water. Use a walking stick, as appropriate, to maintain balance.

• Consider wearing a personal flotation device. • Monitor work conditions and avoid the work area if engineering

controls are disabled. If yes and the water is flowing “rapidly” and deeper than 1

meter, and includes a fall potential, then the Risk Assessment is High and follow all applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: water hazards; drowning; hypothermia.

High Risk Exposure • Notify your supervisor that you will be working near water. • Wear appropriate knee boots, hip-boots, or waders to limit

exposure to water. Use a walking stick, as appropriate, to maintain balance.

• Wear an appropriate fall protection device (including harness) to prevent entering the water.

• Wear a personal flotation device. • All over-the-water activities will be monitored by an attendant. • Monitor work conditions and avoid the work area if engineering

controls are disabled.




Section 7: Is the work to be performed in a pressurized work environment? If yes, then the Risk Assessment is High and follow all

applicable mitigation measures. The following hazards were considered in this Job Safety Analysis: pressurized work environment hazards; confined space hazards; water hazards; drowning; hypothermia; atmospheric hazards.

High Risk Exposure • Notify your supervisor that you will be working in a pressurized

work environment.

• Obtain medical clearance from a licensed physician specialized in hyperbaric work environments and provide a copy to HR & Safety.

• Complete compressed air worker training specific to the work site. • Document the maximum working pressure and “bottom time”

limits for each entry. • Identify the specific hazards within the pressurized work

environment area with the job supervisor, including: hot work, high or low air temperature, poor air quality, poor mixed-gas quality, loss of ground support, loss of water control, slips & falls.

• Review the contingency plans with the job supervisor in the event that engineering controls malfunction or fail.

• Wear appropriate PPE and apparel. • Wear an appropriate fall protection device (including harness), as

applicable. • Monitor work conditions and avoid the work area if engineering

controls are disabled.

Section 8: Other site characteristics-- Does the work require the use of specialist access equipment? Ladders, scaffold towers, mobile plant, etc.?

• Use appropriate access method. • Use harness. • Use contractor’s personnel cages & hoists properly. Does the site lack control by the owner/contractor? • Adopt remote supervision from office. • Adopt a cautious approach on site, assess before proceeding. • Other …………………………. Does the work involve access to a highway / road? • Remove hazard, close road. • Only access road when specifically required. If weather conditions

limit your or motorist’s visibility, consider rescheduling the work. • Use a lookout. • Wear Class III (highway) or Class II (road) high visibility clothing. Could parking be a problem? (Struck by other road users, creating a hazard to other users.)

• Park in a designated car park.




• Park clear of the traffic corridors or lanes. • Park off-site and walk. • Carpool to reduce the number of vehicles on-site. Are personal welfare facilities readily available? • Toilets. • Washing facilities. • Food (hot drinks). • Other …………………………. Are appropriate first aid responders and equipment readily available on-site?

• Does site have ready access to first aid facilities? • Does qualified first aider or kit need to be supplied?

Additional Comments


Visitor Acknowledgment of

Project Site Rules (EXAMPLE)


By signing this Visitor’s Log, I acknowledge that I understand and agree to abide by the project rules outlined below.

In consideration of my receipt of a visitor’s pass as issued by the Construction Manager directly or indirectly for the Owner, I waive on behalf of myself, my heirs, employer, legal representatives, and assigns and hereby release and discharge the Owner, Construction Manager, Engineer, Designer, and their subcontractors and consultants and each of their directors, officers, employees, representatives, and agents from any and all claims, actions, causes of action, or any charge of any kind whatsoever that may arise or could arise in the future as a result of my being present at the facility including injury, death, or property damage whether or not caused by the fault or negligence of any of the parties released hereunder.

I further acknowledge that I have been trained on specific hazards, hazardous substances that are on site, and the site emergency action procedure.

Prohibited Activities Unauthorized removal or theft of OWNER’s property

Violation of safety or security rules or procedures

Possession of firearms or lethal weapons on jobsite

Acts of sabotage

Destruction or defacing OWNER’s property

Failure to use sanitary facilities

Failure to report accidents or job-related injuries

Being under the apparent influence of drugs, alcohol, or other intoxicants or in possession of drugs, alcohol, or other intoxicants on the property

Wearing shorts or tennis shoes on the project site

Failure to wear a hard hat/safety glasses

Gambling at any time on the project site

Fighting, threatening behavior, or engaging in horseplay on the project site

Smoking in unauthorized areas on the project site

Open fire cooking or making unauthorized fires on project property

Selling items or raffles without authorization

Use of unauthorized cameras on the project site

Use of radio or television in the construction area

Failure to park personal vehicle in authorized parking area

Failure to wear designated identification [Site Specific]

[Project Name] Visitor Acknowledgment of Project Site Rules (EXAMPLE)


Failure to use designated gates

I have read, understand, and agree to abide by the PROJECT SITE RULES. Furthermore, I understand failure to abide by these rules is grounds for being denied access to the project site. I have received a personal copy for my use and reference.

Visitor’s Log By the signing of this log I acknowledge that I have read, understand, and agree to abide by the project rules outlined above. This is not a vehicle access permit.

Visitor’s Name (Print) Signature Company Visited Date Time In Time Out

underground division safety policy manual

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