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Construction Safety for Those on the Sidelines

Throughout the construction process, both new construction and renovation, the focus is on the end product. Is the design what we need? Will it work for us? Is the quality of construction meeting our expe tations? Will it be on time and within budget? These are all, without a doubt, critical considerations in any construction project. There is one aspect of the design and execution of a project that we as “safety guys” find often stirs up more business for us than one might expect; the protection of building occupants and the people in public areas adjacent to the projects who must put up with it and carry on their normal activities. Before proceeding, one point of clarification, we’ll refer to the “public”: by this we mean anyone, whether a worker in your area or the general public on your site, not directly associated with the construction process. Construction can be a very disruptive process if not well managed. Problems might include: falling or windborne debris, dusts/fumes/odors, blocked exits, fires caused by welding, soldering or roofing, tripping hazards or uneven surfaces, changes to paths of travel within a facility, noise, vibration, lighting (or lack of it), UV radiation (e.g. welding), construction equipment and vehicles, utility interruptions, building access issues (both pedestrian, ADA access, vehicle and loading dock), and security. Many of these also may impact the ability to provide care for the animals housed in the facility.

Although there are a number of standards for protection of the public to specific hazards, most notable, asbestos and lead, traditionally there were no real comprehensive safety standards or guidelines to hang your hat on that applied to overall protection of the general public. That changed with the approval of the American National Standards Institute (ANSI) A10.34-2001 standard entitled “Protection of the Public on or Adjacent to Construction Sites – American National Standard for Construction and Demolition Operation.” This is not a law or regulation as are the asbestos and lead standards, but it is a recognized consensus document that can be included in the contract specifications and therefore be enforced by the project manager.

To be approved by ANSI, the requirements of due process, consensus, and other criteria for approval had to be met. Consensus is established when in the judgment of ANSI, substantial agreement by those groups directly and materially affected has been reached. In this case, it was a collaborative effort between construction companies, government, trade unions, design professionals, the insurance industry, and others.

Let’s walk through the standard and cover some of the fundamental points. The standard first provides basic definitions. Hazard is a condition that can cause illness, injury or damage to property. This is somewhat unique as most safety standards only address personnel protection. In our case a hazard would also be a condition that could negatively impact the animals within a facility. The Project Constructor is the person or entity named in the project documents responsible for oversight and controlling the work on the project. This is the “go-to” person/group if there are problems and a relationship should be established before shovel meets dirt. The Enforcing Authority is the one with authority to enforce safety on the site. This may be the Project Constructor, the owner’s project manager, the controlling contractor, or government entity. The most important part of the process after obtaining commitment from the entities above is the development of the Public Hazard Control Plan.

The Public Hazard Control Plan is the meat of the standard. The purpose is to evaluate and reduce to a minimum the hazards to the public identified through analysis of the project prior to the commencement of work and then throughout the process. This is where effective and open communication and discussion must occur before the work starts. This is particularly important since most contractors will be unfamiliar with the requirements for working in facilities housing animals especially if the animals will be onsite during the project. A phased approach to safety program elements will often need to be implemented. Start with groundbreaking and move through all the phases of the project when identifying hazards and consider solutions. It is critical for the facility management to participate in this process as some of the proposed solutions by the contractor may be incompatiblewith the ability to properly care for the animals.

Hazards to consider include:

• Noise – Noise may impair the ability to conduct normal operations and discussion. It may cause stress in housed animals. Impact noise may startle and cause secondary hazards. Noise, if loud enough, may interfere with the ability to hear audible warnings such as fire alarms.
• Dusts, Fumes, Mists, Smoke, and Vapors – Though these seldom reach hazardous levels for building occupants they often result in a rash of complaints, lost work time from headaches/general malaise, and occasionally cause building evacuations from activation of smoke detectors. Ventilation throughout the life of the project is an important consideration.
• Pedestrian Hazards – Safe walking surfaces and routes must be provided. This includes maintenance of required emergency egress and evacuation routes for all. ADA issues must also be addressed. Where sidewalk closures occur, safe alternate paths must be provided. Where carts must be rolled the surface must be adequately maintained,
• Utilities – Where utility interruptions are required (electricity, steam, chilled water, etc.) the outage must be planned in advance to identify what accommodations are required for the animals or the services they require (e.g. cage wash, autoclave, etc.).
• Other areas discussed include: lighting, radiation, machinery and vehicles, falling objects, security, pollution control, hazardous materials, vibrations and subsidence, actions for injuries and damage, and an emergency action plan. The ANSI standard has a non-mandatory appendix that essentially serves as a hazard protection plan template to help meet the requirements of the standard.

One area of note not covered in the standard is “hot work” (e.g. welding, soldering, grinding metals) while in occupied buildings. We strongly recommend adoption of a “hot work” permit process. This should be included in any Public Hazard Control Plan as contractor initiated fire is a very real possibility.

The Hazard Control Plan, to be effective, must be communicated to all the contractors and subcontractors working on the site. This again is the responsibility of the Project Constructor.

On a side note, safety runs both ways. There may be hidden hazards for the contractor that must be revealed prior to bid or preferably abated before the contractor commences operations. These hazards might include contamination issues, for instance, if radioactive materials were used, potentially contaminated surfaces must be confirmed “clean” and documented. Infectious disease or isolation areas will need decontamination. HEPA filters may need to be removed from exhaust systems and biosafety cabinets will need to be decontaminated prior to contractor work. We strongly recommend a formal clearance process where every non-routine hazard (from the contractor perspective) is addressed and abated before turning the space over to a general construction contractor.

This ANSI standard provides a good foundation for analysis of construction projects from a safety perspective. Although it is focused on the protection of people, it does provide a logical path for the protection of animals as well. It relies on the identification of hazards and development of strategies and assignment of responsibility to address those hazards. Development of a plan and detailed open discussion can make life easier and less stressful for all involved.

The Safety Guys welcome your comments and questions. You can email them at thesafetyguys@alnmag.com.

Vince McLeod is a Certified Industrial Hygienist by the American Board of Industrial Hygiene and the senior IH with the University of Florida’s Environmental Health and Safety Division. He has 15 years of experience in all facets of occupational health and safety and specializes in hazard evaluation and exposure assessments.

Glenn Ketcham is a Certified Industrial Hygienist with 20 years experience in the health and safety field. He is currently the Risk Manager for the University of Florida. He has worked as a USDOL/OSHA compliance, laboratory and chemical safety, workplace ergonomics, disaster preparedness, and classical industrial hygiene with 10 years direct experience in animal care areas.