Overview
NAVFAC is focused on ensuring a culture of safety in all efforts. Established requirements and procedures are in place to ensure consistent safety oversight for Environmental Restoration Program (ERP) projects.
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Process
All activities at an ERP site must comply with applicable Department of the Navy (DON) health and safety requirements and procedures, which are compliant with federal regulations and other Department of Defense (DoD) guidance. These requirements are summarized in the DON Occupational Safety and Health Program Manual (OPNAVINST 5100.23G). The DON also relies on the current edition of the U.S. Army Corps of Engineers (USACE) Engineering Manual (EM) 385-1-1 Safety and Health Requirements. Cleanup activities must comply with the Occupational Safety and Health Administration’s (OSHA’s) Hazardous Waste Operations and Emergency Response (HAZWOPER) standards (29 CFR Part 1910.120 and 29 CFR Part 1926.65). In addition, projects under the Munitions Response Program (MRP) have specialized health and safety requirements as overseen by the Naval Ordnance Safety and Security Activity (NOSSA) and Marine Corps Systems Command (MARCORSYSCOM).
Roles and Responsibilities
Although NAVFAC is responsible for the overall health and safety program, safety oversight for ERP projects is generally administered through the Field Engineering Commands (FECs). The DON Remedial Project Manager (RPM) coordinates health and safety matters with the designated FEC Safety Manager and the Facility Engineering and Acquisition Division (FEAD). The RPM and the FEC Safety Manager are responsible for reviewing site-specific health and safety documentation to ensure that proposed operating procedures and monitoring are adequate to protect worker health and safety. The FEAD Construction Manager or ROICC is responsible for reviewing the Accident Prevention Plan (APP) and the Activity Hazard Analysis (AHA) portion of the HASP. To assist with this review, the RPM can refer to the APP Review Checklist and SSHP Review Checklist as developed by Navy and Marine Corps Public Health Center (NMCPHC) based on the applicable requirements described above. The RPM may also request NMCPHC to review the project APP/SSHP and associated AHA. The NMCPHC is a support center to provide health and safety support to the ERP. The contractor is responsible for complying with all federal, state, and local health and safety requirements, as well as meeting the DON ERP health and safety requirements as outlined in their contract.
For more information, Chapter 17 of the DON Environmental Restoration Program Manual details health and safety considerations.
Accident Prevention Plan (APP) and Site Safety and Health Plan (SSHP)
DON ERP projects that involve field work require contractors to develop project-specific APPs and SSHPs in accordance with the current edition of USACE EM 385-1-1. The APP defines the contractor’s health and safety policies and how they will safely manage the site activities during the contract. An abbreviated APP may be appropriate for some limited scope projects including routine site surveying, grounds maintenance, and routine periodic site monitoring (see Appendix A of EM 385-1-1). If HAZWOPER is applicable, a site-specific SSHP must be included as an appendix to the APP based on the OSHA requirements and Section 33 of USACE EM 385-1-1.
Activity Hazard Analysis (AHA)
A critical and required component of the APP/SSHP is the AHA. The AHA is part of the overall project health and safety risk assessment and management process and is considered a field health and safety risk management tool. An AHA is developed for each project task or definable feature of work (DFOW). For each task/DFOW, the AHA identifies and assesses the potential hazards, the control measures to be implemented, and the site conditions and other project parameters that impact the safety and health of personnel performing the task. USACE EM 385-1-1 provides templates and instructions for AHA development.
Review and Approval
The RPM coordinates the review and acceptance of the APP/SSHP with the FEC Safety Manager and the FEAD Construction Manager/ROICC to ensure that the plan protects the health and safety of the workers and the environment. To assist with this review, the RPM can refer to the APP Review Checklist and SSHP Review Checklist as developed by Navy and Marine Corps Public Health Center (NMCPHC) based on the applicable requirements described above. The RPM may also request NMCPHC to review the project APP/SSHP and associated AHA. The NMCPHC is a support center to provide health and safety support to the ERP.
For more information, Chapter 17 of the DON Environmental Restoration Program Manual details health and safety considerations.