1.0 SCOPE
This Health and Safety Plan (HASP) describes the safety and health guidelines developed to protect on-site personnel, visitors, and the public from physical harm and exposure to hazards during the project activities at the Boeing Michigan Aeronautical Research Center (BOMARC) Missile Site Plutonium Remediation in Plumsted Township, New Jersey. This HASP is prepared in accordance with the standards established by the U.S. Occupational Safety and Health Administration (OSHA) for regulated sites.
Specifically, this HASP complies with the appropriate standards contained in Title 29 Code of Federal Regulations (CFR) 1910.120 and 29 CFR 1926.65 Hazardous Waste Operations and Emergency Response and 10 CFR 20 Standards for Protection Against Radiation. The remediation effort will be conducted in such a manner to provide a level of protection to the public and remediation workers consistent with applicable radiation exposure guidelines and with the objective of achieving ALARA exposure levels.
1.1 Objective
The health and safety measures presented are in effect for the duration of the project. This document is intended for field use by project personnel, subcontractors, and visitors. All personnel are required to abide by these measures. Where not specifically mentioned, all personnel are required to comply with the applicable regulations contained in 29 CFR 1910, 29 CFR 1926, and 10 CFR 20, while conducting this work. The procedures and guidelines contained herein are based upon the best available information at the time of the plan's preparation. Specific requirements may be revised if new information is received or site conditions change. This HASP is used in conjunction with the Activity Hazard Analyses (AHA) described in Section 4.1 and will address the project's:
· Accident Prevention Plan.
· Emergency Response Plan.
· Emergency Action Plan.
· Contingency Plan.
· Fire Prevention Plan.
· Radiation Control Overview
1.2 Staff Organization and Responsibilities
The necessary personnel will be Home Office team members, on-site project personnel, AF and IOC oversight, and subcontractors. All project personnel will share the responsibility for safely completing project activities. The site organization is included as Figure 1-1 of the Site Operations Work Plan.
All on-site personnel are responsible for continuous adherence to health and safety procedures during the performance of assigned work. In no case may work be performed in a manner that conflicts with the inherent safety and environmental precautions outlined in this plan. After due warning, personnel violating safety procedures will be dismissed from the project and possibly terminated from further work.
Any person who observes unsafe acts or conditions or other safety problems should immediately stop work activity and report to supervisory personnel. If there is any dispute with regard to safety and health, on-site staff will attempt to resolve the issue and if the issue cannot be resolved, they will consult off-site technical staff and supervisors for assistance. The specific task or operation in question shall be discontinued until the issue is resolved.
1.2.1 Project Manager
The Project Manger (PM) is responsible for the overall safety, coordination and direction of the remediation effort. He will serve as the principle point of contact with the IOC project organization. The PM is responsible for the overall health, safety, regulatory compliance, and quality programs of the project.
1.2.2 Construction Manager (CM)
The Construction Manager will act on behalf of the PM in the PM's absence from the site. The Construction Manager is responsible for the field implementation and enforcement of this HASP. The CM will ensure , but not limited to the following; Personnel having access to the site are properly trained, activity hazards have been identified and mitigated:
· Medical monitoring of personnel is current
· Periodic site safety walk-downs are conducted
· Emergency communication systems are operational
· Unsafe conditions are addressed as resolved immediately
· Ensure new employees are briefed on site safety
· Sanitary conditions on-site are maintained at an acceptable condition
· Spills (oil, hydraulic fluids, buel, etc.) are remediated in a timely manner
1.2.3 Site Certified Health Physicist (CHP)
The Site Certified Health Physicist (CHP) is responsible for ensuring that all applicable radiation safety requirements are adhered to during the conduct of this project, for including these requirements within the HASP, and for overseeing health physics activities. In conjunction with his radiological control responsibilities, the CHP will function as the project's safety representative. The CHP reports administratively to the Project Manager on-site and functionally to the Vice President of Regulatory Affairs in the Home Office.
1.2.4 Site Quality Assurance Officer
The Site Quality Assurance Officer (QA) is responsible for day-to-day monitoring, surveillance and inspection to verify compliance with written procedures, technical guidance and client requirements. For health and safety functions, the QA functions to ensure all aspects of the HASP and RPP are followed during site operations and that support documentation exists and is maintained
1.2.5 Health Physics Technician
Health Physics Technician(s) (HPT) are assigned to provide support to each major field activity. An HPT is responsible for implementing the elements of the HASP regarding radiation control under the direction of the CHP. An HPT will perform air monitoring/sampling, perform radiation surveys, evaluate the adequacy of radiation protection methods being implemented in work areas, and perform site inspections to identify unsafe conditions with respect to radiation hazards and employee exposures. An HPT has the authority to stop work, when necessary, to maintain a safe radiological work area. HPTs report to the CHP.
1.2.6 Home Office Support
Supporting the commitment to safety are health and safety professionals providing compliance assistance, audits, technical guidance and support functions. Typically, these personnel visit the site on an as-needed basis. Personnel supporting from off-site include:
· Industrial Hygienists
· Safety Professionals
· Health Physicists
· Waste Management Experts
1.2.7 Subcontractors
Subcontractors are responsible for the safety and health of their employees and for complying with the standards established in this HASP and all other project requirements. The following are some of the requirements that apply to subcontractors:
All subcontractors will report to the CM.
An assigned safety representative for each subcontractor must be present on any day that work is being performed. The name of the assigned safety representative must be conveyed to the CM and CHP.
Subcontractors will submit all training and medical surveillance documents prior to mobilization. Subcontractors shall be pre-qualified.
Planned operations for the day must be verbally conveyed to the CM at the beginning of each day. Any changes in scope of work or specified quantities must also be conveyed to the CM on a regular basis.
The Site Entry Log must be signed at the beginning and end of each workday by all subcontractor employees working on-site.
All subcontractor personnel must attend a project safety orientation prior to beginning work on-site.
All subcontractor personnel must attend the morning tailgate safety meeting. If scheduling precludes attendance, then subcontractors must hold and document their own safety meeting. Safety meeting documentation is to be submitted to the QA Officer.
All accidents, fires, injuries, illnesses, and spills must be immediately reported to the CHP.
Heavy equipment is to be inspected daily by the equipment operator. Inspection documentation is to be submitted to the QA Officer.
Vehicles, such as trucks, vans, and automobiles are to be inspected once per week by the individual driving. Inspection documentation is to be turned into the QA Officer.
Subcontractors are required to frequently inspect work sites for safety deficiencies and correct all deficiencies. Documentation of these inspections, as well as the corrective actions implemented for the preceding week shall be retained by the subcontractors and subject to review/audit.
The necessary forms to document these requirements are available in the Project Office trailer.
The following subcontracts are expected to be required for onsite project activities:
· Radiological support services
· Onsite laboratory
· Onsite Health Physics Technicians
· Offsite radiological laboratory
· Offsite environmental laboratory
· Site preparation subcontractor
· Electrical/Utility Hook-up
· Transportation and disposal subcontractor
· Material hauling
· Equipment vendor
· Fuel supplier.
1.2.8 Air Force, IOC and Visitors
Air Force (AF) and IOC personnel who visit and/or work at the site on a regular basis will comply with all health and safety, training and notification requirements established for the site. Incidental visitors to the site shall sign in at the main entrance and notify the CM or CHP. They will attend an orientation briefing on the site hazards and safety requirements. While on the site, the visitors shall be continuously escorted unless waived by the CM with concurrence of the CHP.
2.0 REFERENCES
2.1 American Conference of Governmental Industrial Hygienists (ACGIH), 1999, Threshold Limit Values and Biological Exposure Indices,
2.2 Frazier LM, Hage ML, Eds., 1998, Reproductive Hazards of the Workplace, NY, Van Nostrand Reinhold,
2.3 Headquarters, Department of the Army, 1994, Unexploded Ordnance Procedures, FM 21-16,
2.4 Material Safety Data Sheet Collection, Genium Publishing Corp., Schenectady, NY, March 1992,
2.5 National Institute for Occupational Safety and Health, Occupational Safety and Health Administration, U.S. Coast Guard, and U.S. Environmental Protection Agency (USACE et al.), 1985 Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, NIOSH Publication No. 85-115, October 1985,
2.6 National Safety Council, 1996, Fundamentals of Industrial Hygiene, Second Edition,
2.7 The Effects of Workplace Hazards on Male Reproductive Health, DHHS (NIOSH) Publication No. 96-132,
2.8 Title 10 Code of Federal Regulation (CFR) Part 20, Standards for Protection Against Radiation,
2.9 Title 29 Code of Federal Regulations (CFR) Part 1910, Safety and Health Regulations for General Industry,
2.10 Title 29 Code of Federal Regulations (CFR) Part 1926, Safety and Health Regulations for Construction,
2.11 U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and prevention, National Institute for Occupational Safety and Health (NIOSH et al.), 1997, NIOSH Pocket Guide to Chemical Hazards, NIOSH Publication No. 97-140, June 1997,
2.12 U.S. Environmental Protection Agency (EPA), 1988, Standard Operating Safety Guidelines, July 1988 and
2.13 USACE, 1996, SAFETY AND HEALTH REQUIREMENTS MANUAL, EM 385-1-1. Prepared by U. S. Army Corps of Engineers (USACE), Washington, D.C. 3 Sep 1996.
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