Construction Projects Combined Environmental and Safety

Transcription

Transportation Research Board ADC 60
Committee on Waste Management and Resource Efficiency in Transportation
Fort Worth Renaissance Worthingtown Hotel July 9-10,2007
Construction Projects
Combined Environmental and Safety Management
Systems
Susan Bayat, P.E.
EnTech Engineering, P.C.
July 2007
1
Combined Environmental and Safety Management Systems
A New Era in Construction Industry…
A New Age in ES Consulting…
and …
A New Perceptions for:
Safe Workplace,
Protection of Environment, and
Health of Work Force and Communities.
July 2007
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Since 1970, more than 30,000 pages of ES regulations were
developed and approved by legislative bodies to become
Federal Laws of the United States.
Why?
Many workers did not go home at the end of the workdays due to
workplace accidents. Many communities were impacted due
to environmental hazards associated with industrial activities.
Some at a disaster scale, e.g. Love Canal, Exxon Valdez,
Hudson River PCBs, etc.
July 2007
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July 2007
Construction Workers Lunching on a Crossbeam
EnTech Engineering,
Rockefeller
Center,1932.P.C.
4
July 2007
Window Washers
EnTech Engineering,
P.C.
Rockefeller
Center,1933
5
July 2007
Lunch Hour With Harmonicas
22 Floors Up,1925
EnTech Engineering,
P.C.
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July 2007
Painters on Brooklyn Bridge,1926
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Painting Cables of Brooklyn Bridge,1926
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July 2007
RockefellerEnTech
Center Engineering,
Under Construction,1938
P.C.
9
July 2007
Workmen
Atop Chrysler Building-1940’s
10
July 2007
Triborough Bridge,1935
11
July 2007
Painting the Flagpole in Times Square,1925
12
July 2007
Man Waving
from Empire
StateP.C.
Building ,1930
EnTech
Engineering,
13
Break Time Rockefeller Center,1932
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Lunch Break
Rockefeller Center, 1932
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Codes of Federal Regulations (CFR) were developed to address
the ES requirements, including:

29 CFR Labor (AKA Workplace Safety)
33 CFR Navigable Waters
40 CFR Protection of Environment
49 CFR Transportation
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Objectives of ES Regulations:
The intention of ES regulations is to address potential and/or
actual safety and environmental hazards associated with
construction, industrial, and commercial activities.
Objective of My Presentation:
Combined management of Environmental and Safety issues in
large and multi-disciplinary construction projects increases
the efficiency significantly.
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Environmental and Safety regulations can be grouped
in the following categories based on the concerns
they would address.
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Industry Related Regulations:
Address issues related to specific type of industry. Examples of
these regulations are:

29 CFR 1926 Construction Industry
29 CFR 1910.269 Electric Power Generation, Transmission,
and Distribution
40 CFR 60.50 Standard Performance for Incinerators
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Hazardous Materials Related Regulations:

Asbestos
Lead
PCB (TSCA)
RCRA
CERCLA Comprehensive Environmental Response
Compensation and Liability Act
Oil Pollution Prevention (PPO)
Workers Right-To-Know (Hazard Communication)
Community Right-To-Know (EPCRA)
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Emission/Discharge/Waste Regulations:
Air Emission
Hazardous Waste
Stormwater Discharge
Wastewater Discharge
Construction and Demolition Waste
Contaminated Site Remediation
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Process and Operation Related Regulations:
These regulations are for specific process and or operation:

Welding and Cutting
Commercial Diving
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Equipment Related Regulations:

Heavy Construction Equipment
Electrical Equipment
Crane and Forklift
Storage Tanks
Transformers
Ladders
Personal Protective Equipment (PPE)
Lock out/Tag out for Equipment with Hazardous Energy
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ES Regulations concerned about “Location”:

Wetlands
Navigable Waters
Confined Spaces
Contaminated Sites
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Exposure Regulations:

Exposure to Chemicals
Exposure to Noise/Vibration
Exposure to Radiation
Exposure to Heat/Cold and Extreme Weather Conditions
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Emergency Situation Regulations:

Fire Prevention
Hazardous Material Spill/Leak
Medical Emergencies
Incident/Accident Reporting
Toxic Air Release
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The extent and complexity of ES regulations and their constant
evolution, as well as advancement of the associated
technologies makes the current approach (one person in
charge of all in each site) obsolete.
Implementation of a management system for combined
environmental and safety will ensure ES compliance.
Type Writer VS Word Processing
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The Combined ES – MS covers:
29 CFR 1926, construction industry specific regulations…..
AND OTHER APPLICABLE REGULATIONS Due to:
• Chemicals/materials used at the site
Emissions/discharges/wastes
Specific process and/or operation
Equipment being used
Location of the project or activities
Exposure for crew and public
Emergency scenarios
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Problems with current approach to ES :
•
•
•
•
ES is a non- core, yet very important part of construction.
Contractor’s core business is construction!
Contractor is the responsible party for ES
Contractor may not have the resources for ES.
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Reality Check:
•
•
•
•
Removal of a transformer from the site -TSCA documents
Identifying hi-noise areas and activities - Hearing Protection
RTK Training and MSDS
Hazardous waste generation and classification - RCRA
(Note: the generator of hazardous waste is the ultimate responsible party for proper management of the material according to RCRA)
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Basic problem with current approach to ES :
Like every other scientific field in recent years, the ES covers a
wide range of technical issues and requires experts in
different areas, including industrial hygienist, safety
professionals, environmental engineers, natural resources
specialists, etc.
To ensure ES compliance these professionals should be
involved through a combined Environmental and Safety
Management System
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Example of Combined ES Management System:
New York City Transit
Environmental Management System Incorporates Health and
Safety Issues
Asbestos Removal
Lead Paint Disturbance
PCB Transformer Removal
Contaminated Soil
Other Hazardous Waste Management
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Current Approach:

Contractor develops a large boiler-plate document: “Health and
Safety Plan (HASP)”.
The project crew may have no access and/or understanding of
the HASP.
Contractor may not have the expertise nor motivation to
implement HASP requirements.
Sometimes it would be to his financial benefit if they don’t.
The cost and schedule are main excuses for ES noncompliance.
July 2007
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Problems with current approach to ES:

Too many regulations.
Prepared by attorneys, hard to understand.
Little input from professionals.
Not compatible with dynamic nature of construction.
Little flexibility, not helpful to meet the scope, schedule,
and budget requirements.
It’s almost impossible to stay in compliance.
Most of construction sites have numbers of noncompliance.
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When ES non-compliance becomes kind of daily routine, then
where is the red line? How much non-compliance is safe and
acceptable?
This should be a Judgement by a Professional
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While non-compliance with ES regulations may not have discernible
immediate effects on project crew, project community, and project
environment, the cumulative effects are recognized mainly when it’s
hard and/or impossible to retrofit them.
There is also consideration about the legal liabilities associated with noncompliance in construction projects. Sooner or later it may cost more
to deal with consequences of non-compliance than implementing a
combined management system to ensure ES compliance.
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Benefits of Combined ES- MS:

A Team of professionals is responsible for ES compliance.
Develops site-specific/project-specific ES - MS.
Develops ES compliance check list.
Assigns responsibilities to project crew.
Oversees site activities to ensure: “Safety First”, and
“Environmental Protection”.
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Documentation of ES compliance activities.
Provide “Certification of ES Compliance”
The Certification is proof of client’s fulfilment of its obligations.
The Certification and the ES team can help in legal cases
against client.
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Improved institutional knowledge.
Improved efficiency.
Cost control and reduction – economy of scale
No legal and long-term liability for client.
Clients pays for what they need and only when its needed.
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The flexibility of a combined ES - MS makes it enable to take on
any requirements.

Ergonomics Requirements
New Products
New Equipment
New Concepts
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Long-Term Goals of Combined ES - MS

Improvement to ES Regulations.
Make them industry-friendly.
More involvement of technical/professional.
Make them more flexible and compatible with dynamic realty of
the construction industry and activities.
More issues should be left to “professional judgment” at the
site.
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Long-Term Goals of Combined ES - MS

If the goal of OSHA is to provide a “Safe Work Place”, it should
use a language that can be understood by “Workers”

The legal language and format are an obstacle for those who
want to understand the requirements and want to comply with
them.
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Overall benefits:

Cost Control
Efficiency
Flexibility
Compatible with evolving industrial and technological trends
Site and project specific solutions
And more important:
Open to future evolution of construction industry.
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Thank you
Transportation Research Board ADC 60
Committee on Waste Management and Resource
Efficiency in Transportation
Questions!!
July 2007
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July 2007
Man Waving
from Empire
StateP.C.
Building ,1930
EnTech
Engineering,
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