Session No.

771

Protecting Employees Who Work on Homeland Security and Critical Infrastructure Projects
Amit Reizes, P.E., CSP, CISSP Johnson Controls, Inc., Gaithersburg, MD.

Overview

Since September 11, 2001, Homeland Security and Critical Infrastructure Projects have increased in magnitude and scope while their schedules have been compressed. This discussion will address the complex occupational safety and health issues that have been thrust upon the workforce, and describe a multi-step approach that has been taken to promote the safety and health of employees, while increasing productivity and reducing workplace incidents.
Introduction

The increased focus on security in the post-September 11 period has forced numerous agencies and organizations to assess their security and make plans to protect their human and physical assets. This challenge has typically included resource and budget limitations. What has resulted is an increase in Homeland Security and Critical Infrastructure projects that require a quick response to existing conditions and accelerated schedules for the implementation of integrated security systems that include Access Control, Intrusion Detection, CCTV, Command and Control Centers, Barriers, Blast Protections and other means of protection. Accordingly, employees have been presented with work conditions that contain numerous hazards and risks and must be provided with the appropriate protection mechanisms. A sound, systematic multi-step approach that includes risk assessment, employee empowerment, audits and above all open communications, has been shown to work. There are a variety of safety and health hazards that exist in Homeland Security and Critical Infrastructure projects. Many of these tasks are short duration and typically involve unique hazards. Project work includes rooftop installation and repair,, confined spaces (usually PRCS), use of aerial lifts, trenching work, fencing jobs, work in switch yards, and work in areas that contain bio-hazards. Work in classified locations is usually limited to identified and qualified project staff. Work on such project requires quick response and turnaround time. Therefore, welltrained, properly equipped workers who make use of the following Ten Commandments of Worker Protection for Security and Infrastructure Projects will yield benefits to themselves and their organization. These analytical tools, techniques and methodologies, and proven project approaches will result in increased worker safety and health.

Every project should develop and use an activity-based, hazard/risk matrix to quantify the potential hazards facing your employees. The matrix identifies major employee risk and compliance issues. Each major issue has follow-on questions that further quantify the risks and indicate the subsequent required protective measures. An example of this technique is illustrated below.

Commandment No. 1: Utilize an Activity-based Hazard/Risk Matrix

TYPE OF WORK RISK ASSESSMENT

HAZARD COMMUNICATION: Will employee be exposed to or use hazardous chemicals?

Provide: Hazard communication training on these chemicals MSDS and updated Chemical Inventory Yes Yes No No

Yes

No

ASBESTOS EXPOSURE: Will employee work in areas of known asbestos?

Provide: Initial and annual asbestos awareness training Information to employee on locations/types of known asbestos OBTAIN ANY AVAILABLE SITE DATA (Asbestos Mgmt Plan, surveys that have been conducted, etc.) Yes Yes No No

Yes

No

LEAD EXPOSURE: Will employee be exposed to lead hazards at or above OSHA exposure limits?
Provide: Initial and annual lead awareness training Safe Work Practices to minimize exposure risk Required medical monitoring including blood lead level testing OBTAIN ANY AVAILABLE SITE DATA (Lead exposure control Plan, surveys that have been conducted, etc.) Yes Yes Yes No No No

Yes

No

FIRST AID/CPR: Will employee be required to perform first aid and/or CPR or to be qualified to do so? Exception: 5 minutes from Medical Facility or Physician
Provide: Initial first aid/CPR training Retraining to maintain currency (check expiration date on cards) Comply with Bloodborne Pathogen Requirements (below) DOT compliant drug screening Yes Yes Yes Yes No No No No

Yes

No

BLOODBORNE PATHOGENS: Will employee be occupationally exposed to bloodborne pathogens?

Provide: Initial bloodborne pathogen training Hepatitis B vaccinations Yes Yes No No

Yes

No

The matrix has additional major components including: Personal Protective Equipment, Electrical Work Hazards, Emergency Evacuations, Noise Exposure, Stored Hazardous Energy, Respiratory Protection, Confined Spaces, Welding (Hot work) activities, Fall Hazards, Scaffolds, Trenching/Excavations, Demolitions, Personnel Aerial Lifts, Cranes, Hazardous Waste, Special Hazardous Facilities, and Hazards associated with High-Risk Natural Disasters. The use of the Hazard/Risk Matrix and the involvement of managers and employees in the initial assessments results in upfront hazard recognition and issue response provides a path forward for increased worker safety and health.

Commandment No. 2: Apply Protective Measures that provide employees with safe work conditions.
Employees and subcontractors assigned to Homeland Security and Critical Infrastructure Projects typically install electronic security, access control and warning systems. Installation activities include installing closed circuit television (CCTV) system components, lighting components, vehicle barriers, and warning signs, signals and lights. Depending on location, work may require entry through manholes, crawlspaces, or other permit-required confined spaces. Depending on the job site, employees may be exposed to chemicals, biohazards and other hazardous materials. Therefore, a hazard assessment is performed in accordance with 29 CFR 1910.132, in each workplace to determine if hazards are present or likely to be present and that necessitate the use of Personal Protective Equipment (PPE.) The results of that assessment are categorized as follows: 1. 2. 3. 4. 5. 6. 7. 8. Eye and Face Protection (29 CFR 1910.133) Respiratory Protection (29 CFR 1910.134): Head Protection (29 CFR 1910.135) Foot Protection (29 CFR 1910.136) Hearing Protection (29 CFR 1910.95) Full-Body Protection Fall Protection Devices Hand Protection (29 CFR 1910.138)

Employees who work within the flash protection boundary (per NFPA 70E) are required to wear protective clothing and other personal protective equipment. The boundary is defined by the table below:

Arc Location Relative to Equipment Arc in air Arc in enclosure Arc in enclosure

System Voltage Between 200-1,000 Volts Between 200-1,000 Volts 1,000 Volts and above

Flash Protection Boundary (Feet) 4 10 20

In addition, whenever possible, apply protective measures that minimize risks to employees. This may include the use of aerial lifts and scaffolds in place of ladders, design and engineer swing out

arms for CCTV cameras to minimize fall hazards during camera maintenance, and applied safe work practices in hazardous locations.

Commandment No. 3: Use Documented Key Job Step Matrix

A documented Key Job (Task) Step Matrix includes tools, identified hazards, and safe practices/protective means as identified in Commandment No. 2 above, as well as mandatory inspection/certification and mandatory training. A well-documented tool that has proven effective on many Critical Infrastructure jobs is the U.S. Army Corps of Engineers developed Activity Hazard Analysis (AHA) of the work performed. Throughout the life of the project, supervisors and employees are responsible for assessing new hazards and risks as they arise. They must review and modify the AHA as necessary to address changing site conditions, operations, or change of competent/qualified personnel.

Job: Employee(s): KEY JOB STEPS Install conduit TOOL USED Threading machine Power tools Pipe bender Ladder POTENTIAL HEALTH AND INJURY HAZARD Eye injury from flying particles Hand injury from sharp objects or tools Back injury from improper lifting/bending Fall injury from ladder Slips/trips/falls

Date: Dept/Area: Office: Auditor: SAFE PRACTICES, APPAREL & EQUIPMENT Use the required PPE in accordance with the assessments in Appendix C including UV safety glasses, electrical rated gloves, safetytoed shoes or boots, and hard hats. Use care when drilling the holes to mount the conduit. Ream conduit ends after cutting. Keep all loose clothing and hair away from moving parts of power tools. Ensure that all power tools are GFCI protected. De-energize all equipment when possible. Do not use electrical cords that are damaged or frayed. Keep work area free of all scrap materials and debris. Follow proper lifting/bending techniques. Apply ladder safety work practices.

INSPECTION REQUIREMENTS Hand/power tools and other equipment shall be inspected prior to each use to ensure that they are in safe operating condition. See the manufacturers instructions and for additional inspection requirements for hand tools, power tools, equipment, and cords. Ladders must be inspected daily for visible defects. PPE must be inspected prior to each use. The PM or Site Safety Health Officer will designate a qualified person (TBD) to conduct the periodic inspections.

TRAINING REQUIREMENTS All personnel responsible for the conduit installations must be qualified and properly trained to perform the required tasks prior to engaging in the activities. They shall be trained on the proper usage of the required tools, equipment, and PPE.

Key employees must be documented with regard to Safety and Health competency including Competent Person definition per the hazards identified in Commandment No. 1 above. Homeland Security and Critical Infrastructure projects are likely to involve unique hazards and therefore, empowering efficient project teams of employees to assess work conditions that may be subject to dynamic change is essential to successful completion with zero accidents. These projects require safety to be everyone's responsibility at all levels of the organization including subcontractors and vendors. Every on-site worker must be empowered to stop work, or not start work, if they believe a violation of a health or safety standard exists that poses an imminent danger to the worker, others, or equipment. In addition, Key personnel must be identified including the Corporate Safety Director who provides high-level direction and guidance, the Project Manager, who has the overall authority to implement and ensure safety measures and controls, and the Competent Person, onsite, who is empowered to halt project work if safety standards are not met. In addition, highhazard work requires employees to be certified and approved. For example, if work is required on electrical systems that are 50V or greater, the licenses (Masters or Journeymen) of the electrician authorized to work on those systems shall be verified prior to the commencement of any electrical work. A good practice example for the documentation of mandatory training and certification requirements follows:
Name Employee 1 Employee 2 Employee 3 Employee 4 Employee 5 Employee 6 Employee 7 Employee 8 X OSHA 10-hr Training X X CPR / 1st Aid Training X X X X X X X X Medically Cleared for Respirator Wear X X X X X X X X 8/2/2004 7/21/2004 7/21/2004 7/22/2004 8/2/2004 8/2/2004 10/4/2004 9/22/2004 9/22/2004 9/23/2004 10/4/2004 10/4/2004 Project Specific Protocol A Project Specific Protocol B

Commandment No. 4: Document Key employees including Competent Person

Commandment No. 5: Assess Your Employees to Make Sure That They Can Do the Job Safely
Employees who work on Homeland Security and Critical Infrastructure Projects must be physically, medically, and emotionally qualified for performing the duties to which they are assigned. Some factors to be considered when making work assignments are strength, endurance, agility, coordination, and visual and hearing acuity.

Assessment Worksheet: Physical Demands Job Analysis

Name: Job Title: Brief Description of Job Requirements: A. 4. 9. 10. 11. 12. 13. 14. 15. 16. 23. 24. 25. 26. 27. 28. 29. 30. 31. PHYSICAL DEMANDS N/A Lifting: Heavy Max 50# Pushing Est. Wt. ____________ Pulling Est. Wt. _____________ Pulling hand over hand Climbing Stairs Climbing: Use of legs/arms Balance Stooping Kneeling Both legs required Ability for rapid mental/muscular coordination simultaneously Oral communication. Speak Clearly Hearing Conservation Specific visual requirements Near ____ Depth Perception Yes ____ Color vision: Distinguish basic Yes shades ____ Color vision: Distinguish basic Yes colors ____ Operation of crane, truck, motor vet. Yes ____ Other _________________________ B. O F C 4. 9. 10. 11. 12. 13. 14. 15. 16. 23. 24. 25. 26. 27. Heat over 100 degrees F Confined Spaces Heights Constant noise above 85 dB Intermittent noise above 85 dB Vibration Fumes Irritant Toxic (circle one) Dust (More than nuisance) Gases Type ________________ Working with ladders/scaffolding Working below ground-steam pits Working with hands in water Working alone. Hours worked weekly more than 40 Other _________________________ Working Conditions N/A O F C

Far ____ No ____ No ____ No ____ No ____

C. 1. 2. 3. 4. 5. 6. 7.

PROTECTIVE EQUIPMENT REQUIRED Respirator Type ________________ Eye Protection Type ____________ Hearing Protection Type _________ Hard Hat Gloves Type __________________ Boots Type ___________________ Body Protection Type ___________ Other _________________________

O = Occasionally: Up to 25% time on job F = Frequently: 25-75% time on job C = Constantly: More than 75% time on job N/A = Not applicable

Date:

Authorized Signature:

Commandment No. 6: Implement a Lessons Learned program that applies to actual project conditions
On-site projects typically involve construction activities, that require site safety supervisors to conduct and document weekly safety meetings with salient topics, specific accident review, employee concerns, and documented participation by specific attendee. Such meetings are proven to be more effective than the typical Toolbox Talks and are used to review past incidents at the site, prepare for new or changed processes, review applicable aspects of appropriate key tasks (Commandment No. 3), establish safe working measures for expected hazards, and provide relevant safety and health training and motivation. Weekly meetings incorporate Lessons Learned to facilitate continuous and systematic information sharing and learning across the various projects. Every attendee will discover better ways of working safely and avoiding accidents. Through the Lessons Learned activity, each project site has established a safety and occupational health deficiency tracking system that chronologically lists and monitors the status of safety and health deficiencies. The list is updated daily and posted on the projects safety bulletin board. The list is maintained in the following format:
Date Deficiency is Identified 1. 2. 3. Description of Deficiency Name of Person Responsible for Correcting Deficiency Projected Resolution Date Actual Resolution Date

Commandment No. 7: Provide a set of business processes (BP) that apply workplace Safety rules and provides work instructions (WI) to the tasks at hand An effective Safety & Health Management System (SMS) will support site-specific activities as well as corporate programs. The foundation and infrastructure for creating a systematic approach that binds corporate business processes with safety and weaves them into the organizations structure includes a top to bottom approach that mandates commitment to safety at all levels of the organization. Safety becomes a core competency of employees job functions and performance and is measured at all levels. SMS includes the use of structured Business Processes (BPs), Work Instructions (WIs) and measurement tools to conduct activities, track and audit progress,, manage employee training records, and document incidents as well as improvements to ongoing activities. A customized set of BPs and WIs applied effectively to the dynamically changing world of Critical Infrastructure Protection and Homeland Security Projects will lead a project team to achieve identified objectives and targets, maintain control of significant task activities, manage hazards and risks, and to ensure regulatory and contract compliance. As a minimum the effort will establish and maintain processes that address:

Situations where their absence could lead to deviations of the safety policy and objectives Operational criteria and identified risks Design of workplace, process, installations, machinery, operating procedures and work organization, including their adaptation to human capabilities to eliminate/reduce safety risks

DOCUMENT NUMBER
12-01.01 12-01.02 12.01.03 12.01.05 12-04.0 301-01 301-02 301-03 301-04

TYPE DOCUMENT
Business Process Business Process Business Process Business Process Business Process Work Instruction Work Instruction Work Instruction Work Instruction

TITLE
Safety Program Administration Injury Reporting and Investigation Program Workers' Compensation Case Management Program Electrical Safe Work Practices ESH Management System Physician Selection Notification and Submittal of Forms Case Management Transitional Work Program

Commandment No. 8: Provide Workers with an Emergency Response Plan

Always provide workers with an emergency response plan for each project. Critical Infrastructure and Security projects are dynamic in nature and require employees to be knowledgeable and responsive to emergencies that may develop. Emergency operations and recovery assistance activities may be required on Homeland Security Project and therefore, safety and health requirements must be implemented. Workers may be tasked to perform unusual, difficult, hazardous tasks while in a challenging environment, and these conditions will increase the risk of accident. The Emergency Response Plan is designed to assist the site in a variety of emergency categories including: Medical Emergency, Fire/Explosion, and Severe Weather. Typically, the plan consists of five primary sections to be implemented by the Project: Responsibilities, Post Incident, Accident Investigation, Written Reports, and Corporate Communication Policy. In addition, the plan includes basic procedures to follow in emergencies.

I. Fire/Explosion A. Fire/Explosion Response 1. Stay calm and evaluate the situation. 2. If possible, put the fire out using a fire extinguisher. Only approach a fire that you feel can be handled by a fire extinguisher. 3. When calling for fire personnel have the following information ready: a. Job site address b. Severity of fire/explosion c. Number of injured workers and the nature/severity of their injuries d. Any hazardous materials/chemical involved in the fire B. Post Fire Response 1. Secure the area off using red DO NOT ENTER warning tape. 2. All heavy equipment (cranes, lifts, etc.) involved in a fire must be removed from site.

Commandment No. 9: Provide an Audit and Inspection mechanism to ensure workers are implementing the protective measures.
Long-term projects must ensure that systemic, periodic, fully documented safety audits are performed. This activity includes an auditing matrix. In addition, previous audit results should be on file and corrective actions documented for deficiencies noted. Listed below are sample audit questions.

# 8.1

Question Title Confined Space Identification

Question Is there a process to visibly identify confined spaces (i.e. an inventory list and posted signs) accordance with local health and safety standards? Is there a process to prevent unauthorized access to confined spaces? Is there a permit process specific to confined spaces that controls access to and work inside these spaces? Is training documentation available for employees who work in or around confined spaces in accordance with local health and safety regulations? Are confined space permits issued in accordance with regional health and safety standards? Is there a confined space emergency rescue plan?

Response Yes-No-NA

Default Recommendation There should be a process to visibly identify confined spaces (i.e. an inventory list and posted signs) in the operations in accordance with local health and safety standards. There should be a process to prevent unauthorized access to confined spaces. There should be a work permit process specific to confined spaces that controls access to and work inside these spaces. Training documentation should be available for employees who work in or around confined spaces in accordance with local health and safety regulations. Confined space permits should be issued in accordance with regional health and safety standards. There should be a confined space emergency rescue plan, based on applicable risk assessments, in accordance with regional health and safety standards.

8.2

Unauthorized Access to Confines Spaces Permit Process

Yes-No-NA

8.3

Yes-No-NA

8.4

Confined Space Training Documentation

Yes-No-NA

8.5

Issuing Confined Space Permits

Yes-No-NA

8.6

Emergency Rescue Operations

Yes-No-NA

Commandment No. 10: Stress and assure that an open communications dialog with workers is fully operating on the project.

Keep an open communications dialog with workers. This ensures accurate interchange and feedback that will enable and empower employees to conduct work in full safety and health compliance and ensure that the tools and equipment that they need to perform their jobs safely are provided. An effective mechanism for continuous improvement of safety when other mechanisms are already in place is the use of Behavior-Based Safety. This mechanism utilizes the progressive iteration of Observation, Feedback and Reinforcement. Employees who work in fast-paced,

Homeland Security and Critical Infrastructure projects need this type of mechanism to re-enforce safe behavior and minimize the likelihood of accidental mishaps.
Conclusion

We have looked at specific methods and mechanisms for increasing the safety and health of employees who work on Homeland Security and Critical Infrastructure Projects. Well-trained, properly equipped workers who make use of the Ten Commandments will perform their assignments with increased worker safety and health. This has become more important because after September 11, 2001, Homeland Security and Critical Infrastructure Projects have increased in magnitude and scope while their time to completion has been compressed. A proven approach to assure worker health and safety, appropriate tools, mechanisms and approaches to plan deploy and document a proven program will yield substantial benefits to the employee and the individual.