**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 1**

**Indianapolis, Indiana**

**SUBJECT:** Occupational Safety and Health Program

**1. PURPOSE:** The purpose of this program is to provide guidance,
establish policies, follow procedures and methods by which an
Occupational Safety and Health (OSH) Program will be implemented at all
Memorial Service Network IV (MSN IV) Cemeteries to provide a safe
working environment for all employees and volunteers.

**2. POLICY:** As a basic policy, every level of management in MSN IV is
responsible for the prevention of accidents and injuries, including
occupational disease to persons under its control, and for the
protection of National Cemetery Administration (NCA) records and
property against lose by fire or other accidental damage. T**he success
of the program is dependent upon the active involvement of every NCA
employee.**

**3. RESPONSIBILITY:** This responsibility applies to all persons on NCA
premises, in NCA vehicles, whether employees or not, and all property by
or under the jurisdiction of the Department of Veterans Affairs (VA)
whether or not government owned. Moreover, the Department of Veterans
Affairs may be held pecuniary liable for damage to and loss of private
property and for personal injury or death due to negligence of a NCA
employee.

A.  The **MSN IV Director** is responsible for the overall safety of all
    visitors, volunteers, employees and for the protection of property
    at all MSN IV Cemeteries.

B.  The **MSN IV Safety Officer** is responsible to management for the
    direction of the OSH Program. The MSN IV Safety Officer will render
    technical advice and assistance, which may be required in connection
    with OSH and Fire Protection Programs.

C.  **Cemetery Directors** are responsible for the establishment and
    execution of the OSH Program. The Cemetery Director should perform
    an OSH inspection annually. The Cemetery Director will take
    immediate action to correct safety hazards or situations of imminent
    danger whenever such situations come to their attention either by
    observation, inspections or through reports of hazards (such as:
    Safety Meeting Minutes).

D.  **Cemetery Safety Officers (CSO)** will support the OSH Program
    through monthly safety meetings. Also the CSO will conduct routine
    inspection of areas under their control and initiate action to abate
    any hazardous conditions discovered; monitor accident incidents at
    the cemetery level through review of VA Form 2162 (Report of
    Accident); and enforce all applicable OSH and Fire
    Protection/Prevention rules and regulations, and promote favorable
    attitudes toward safety, occupational health and fire prevention by
    supervisors and employees.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 2**

**Indianapolis, Indiana**

E.  **Supervisors and/or Wage Grade Leaders** will support the OSH
    Program by application of approved standards, regulations, and
    practices and work methods. It is there responsibility to train
    subordinates in safe working practices, correcting or reporting for
    correction any condition or practices that appears to be a potential
    hazard. They will also inspect their work areas to detect fire and
    accident hazards and initiate preventive or corrective action.

F.  **Individual Employees** will apply all established safe practices
    and report unsafe conditions or practices to their supervisors.

**4. GENERAL:**

> **A. Cemetery Occupational Safety and Health (COSH) Program:**
> Cemetery Directors will establish written policies and procedures to
> develop their COSH Program in accordance with Public Law 91-596,
> Executive order 12196, EPA, OSHA, VA Manuals MP-1 (Part III), MP-3
> (Part III), Safety Requirements for VA National Cemeteries Handbook
> (7710), guidelines from VACO Office of Occupational Safety and Health
> (00S1), Safety & Health Office at the servicing VA Medical Center,
> Fire Protection Engineer, Safety & Health Officer and Industrial
> Hygienist -- VA Regional Office (VISN), MSN IV, Federal, State and
> Local Regulatory Agencies codes, regulations, standards, policies,
> procedures, manuals & etc. The COSH Program must include the following
> programs/policies as a minimum:
>
> Emergency Preparedness Hazard Communication Hearing Conservation
>
> Pesticide & Herbicide Respiratory Protection Medical Surveillance
>
> Personal Protective Equipment Accident Prevention Accident Reporting
>
> Fire Plan Fire Protection/Prevention Confined Space Entry Education &
> Training Workplace Violence Biological & Chemical Weapons & Mail Bombs
> Equipment Operators Training Program
>
> **B. Promotional Projects and Materials.** The CSO and the Cemetery
> Director will obtain, on a recurring basis, both educational and
> promotional material to maintain interest and consciousness of their
> COSH Program. They will assist supervisors to obtain safety and fire
> protection training material, which is available and suitable for use
> in integrating safety and fire protection into employee training
> courses. Such training and material can, in most instances, be
> obtained at or through the Safety & Health Office at the servicing VA
> Medical Center, Fire Protection Engineer, Safety & Health Officer and
> Industrial Hygienist -- VA Regional Office (VISN), Federal, State and
> Local Regulatory Agencies or MSN IV Safety Officer.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 3**

**Indianapolis, Indiana**

> **C. Job Safety Training.** All employees will receive training in
> Safety, Emergency Preparedness and Fire Prevention/Protection
> annually.
>
> **(1) Supervisors and/or Wage Grade Leaders** will be required to
> attend Fire Prevention/Protection and OSH courses that are structured
> to fulfill the requirement for training supervisors, as stated in
> MP-3, Part III, at their servicing VA Medical Center. Each year
> thereafter a one-hour refresher training course will be offered to
> advise supervisors of changes, revisions and interpretations that have
> occurred in the previous year. Routine discharge of supervisory
> responsibilities includes instructing and training subordinates in
> safe working methods.
>
> **(2) New Employees** will be given a worksite orientation before they
> begin work. They will also be assigned to attend Fire
> Prevention/Protection and OSH classes as soon as possible. Worksite
> orientation will cover location of the Emergency Preparedness Plan,
> Material Data Safety Sheets (Binders), Fire Alarms, Fire
> Extinguishers, hoses and exits, how to use them, and what to do in
> case of fire or disaster. The safety and fire protection portion of
> the new employee orientation will cover Emergency Preparedness Plan,
> electrical, chemical and physical hazards what to do in case of
> occupational injury or illness and other special regulations
> applicable to Cemetery employment.
>
> **(3) On-the-Job Instructions** will be given to all new and all
> reassigned employees regarding the potential hazards of the job and
> safety practices to be followed.
>
> **(4) Refresher Instructions** will be given to all employees in
> safety and fire prevention/protection at lease once each calendar year
> with emphasis on safe work practices and changes in regulations.
>
> **(5) Responsibilities:** All Cemetery Directors will maintain a
> training log or file indicating the following as a minimum:

(a) Names of all full and part-time employees assigned to the Cemetery
    and the names of all, which have completed the refresher training.

(b) Names of all personnel who entered the Cemetery as new employees or
    were reassigned during the past year and the names of all who have
    received the full orientation, special on-the-job instruction and
    station-wide fire prevention/protection and safety training course.

(c) Names of supervisory personnel, including the Cemetery Director,
    assigned to the Cemetery and names of all who has attended the OSH
    and Fire Prevention/Protection Course for Supervisor, and the
    Refresher Supervisory Training Course.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 4**

**Indianapolis, Indiana**

(d) All Certifications such as pesticide, herbicide and driver
    operator's licenses.

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D.  **Safety Meetings** will be held at least once a month. One or more
    representatives from each supervisory unit and bargaining unit, if
    applicable, will participate in the Cemetery\'s safety meeting.
    **Minutes will be recorded of all, safety meetings and a copy will
    be sent to the Cemetery Director.** These minutes will be reviewed
    to evaluate the progress of each Cemetery\'s program and to identify
    specific problems and innovations, which are appropriate for
    communication to other Cemeteries.

E.  **Safe Job Assignments and Suitable Equipment**

**1. Physical Fitness:** Employees will be assigned only jobs they are
qualified, and physically able, to perform safely.

**2. Suitable Equipment:** Employees will be provided with equipment,
tools, and supplies suitable for safe performance of their work.

**5. ACCIDENT REPORTING**

> **A. Accident Reporting:** Notify local police authority immediately.
> The local police authority will conduct an accident investigation.
> Employee will immediately make an oral report to their direct
> supervisor. The direct supervisor will conduct an accident
> investigation. Do not move damaged property/vehicles until an
> inspection has been completed by a Cemetery supervisor & completion of
> the local police authority's accident investigation. The Cemetery
> Director will notify MSN IV Safety Officer and the Safety & Health
> Office at the servicing VA Medical Center within 24 hours of
> occurrence, of any accident resulting in:

\(1\) A Cemetery employee losing one or more workdays.

(2) Any injury to a cemetery visitor.

(3) Private property damage attributable to a cemetery employee,
    regardless of the dollar value.

(4) Cemetery property, or vehicle damage assessed to be \$100 or more.

> **B.** **The Cemetery Director** will ensure that the proper VA Forms
> are filled out and submitted such as: VA Form 2162, CA-1, CA-2, CA-6,
> SF-91 & VA Form 90-1217 whichever is required in accordance with
> NCA/VA Handbook 7710 & 7125. The Cemetery Director will also notify
> the VA Regional Counsel of any accident occurring on Cemetery
> property, which could possibly result in a tort claim against the
> government.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 5**

**Indianapolis, Indiana**

C.  **Accident Reports (Employees, Volunteers & Visitors):** A copy of
    SF 91, Operator\'s Report of Motor-Vehicle Accident Form, will be
    kept in the glove compartment of each motor vehicle for use in the
    event of an accident. Any Cemetery Employee involved in an accident
    while operating a Cemetery vehicle will complete the SF 91 while at
    the scene of the accident. This form will be prepared in triplicate
    and mailed to the offices indicated in paragraph E below. The
    employee involved in the accident will stop and render such
    assistance as may be needed, within employee\'s qualifications, in
    case of visible or alleged injuries to individuals or damages to
    private property. The employee will furnish proper identification to
    persons directly involved in the accident. No statements, oral or
    written, will be made to claimants or their agents regarding
    liability or claim approval. Insurance company accident report forms
    will not be completed except in cases where the cemetery employee is
    self‑insured.

D.  Accident reports required by state or local regulations will be
    forwarded to MSN IV for review prior to submission.

E.  An investigation of the accident and corrective action of the
    problem will be conducted by the direct supervisor within four
    working days from the date of the incident. VA Form 2162 must be
    submitted in cases where occupational injury/illness or property
    damage occurs involving employees, volunteers, students, or
    visitors. The investigation and corrective action report shall be
    submitted within six (6) working days from the date of the incident.
    The original shall be retained in the Cemetery accident files. Mail
    a copy, along with any CA-1, CA-2 or CA-6 forms, to the MSN IV
    Safety Officer and Safety & Health Office of the servicing VA
    Medical Center. Mail a copy to the VACO Office of Occupational
    Safety & Health (00S1).

F.  VA Form 2162 may be supplemented and/or corrected as many times as
    necessary in order to obtain an accurate report of the incident. Do
    not delay turning in a report due to lack of accuracy or
    information.

G.  A log of occupational illnesses/injuries shall be maintained
    up-to-date. A synopsis of the log shall be posted within 45 days
    after the close of the fiscal year for no less than 30 consecutive
    days in a conspicuous place or places.

H.  The Cemetery Director will **immediately notify MSN IV Director, MSN
    IV Safety Officer, Safety & Health Office at the servicing VA
    Medical Center, VA Regional Counsel, VACO Office of Occupational
    Safety & Health (00S1) and NCACO Office of Field Operations if there
    is a fatality** as a result of an accident.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 6**

**Indianapolis, Indiana**

I.  **Reporting A Death (natural causes only) of Visitors/Volunteers on
    Cemetery Property:** The Cemetery Director will **immediately notify
    MSN IV Director, MSN IV Safety Officer, Safety & Health Office at
    the servicing VA Medical Center, VA Regional Counsel, VACO Office of
    Occupational Safety & Health (00S1) and NCACO Office of Field
    Operations.** The Cemetery Director will prepare & submit a copy of
    VA Form 119 to the MSN IV Safety Officer and the Safety & Health
    Office at the servicing VA Medical Center.

**6. OTHER SAFETY AND HEALTH PROGRAMS**

> **A. Hot Weather**
>
> **(1) Purpose:** This program communicates the manner in which
> employees should conduct their activities during the periods of
> extreme heat and humidity.
>
> **(2) Policy:** Cemetery employees will refer to the following
> recommended procedures when working on days when the temperature is
> expected to reach 90 F and above.

**(3) Procedures:**

> **(a)** The more strenuous tasks should be completed in the coolest
> part of the day, if possible.

1.  This does not include burial related activities, which will be
    scheduled and conducted during the morning and afternoon hours.

2.  Other more physically demanding jobs such as string trimming and
    back filling sunken graves should be limited to the morning hours,
    if possible.

> **(b)** Employees should be encouraged to drink plenty of liquids
> throughout the day and take an adequate supply of water with them into
> the field.
>
> **(c)** Additional, but shorter breaks may be necessary when working
> under the hot afternoon sun. Additional, but shorter breaks may be
> necessary when working under the hot afternoon sun.
>
> **(d)** The Cemetery Director will provide the employees with the
> following supplies during the summer months.

1.) Sunscreen will be made available to employees who request it.

2.) Uniform type cotton shirts will be provided to the employees.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 7**

**Indianapolis, Indiana**

> **(e)** The program will be discussed with the employees on an annual
> basis before onset of hot weather.
>
> **B. Cold Weather**
>
> **(1) Purpose:** This program communicates the manner in which
> employees should conduct their activities during the periods of
> extreme cold.
>
> **(2) Policy:** Cemetery employees will refer to the following
> recommended procedures when working on days when the temperature is
> expected to reach 35 F and below.

**(3) Procedures:**

> **(a)** The more strenuous tasks should be completed in the warmest
> part of the day, if possible.
>
> 1.) Burial related activities, which will be scheduled and conducted
> during the afternoon hours.
>
> **(b)** Employees should be encouraged to drink plenty of hot liquids
> throughout the day.
>
> **(c)** Multi-layers of clothing are encouraged and should be worn
> properly.
>
> **(d)** The Cemetery Director will provide cold weather gear to the
> employees to protect their face, hands and feet during the winter
> months.
>
> **(e)** The program will be discussed with the employees on an annual
> basis before onset of cold weather.
>
> **C. Excavation of Graves**

**Requirements**

> **(1)** Each employee who enters a grave excavation shall be protected
> from cave-in by an adequate protective system designed in accordance
> with OSHA Standard 1926, except when:

**(a)** Excavations are made entirely in stable rock.

**Department of Veterans Affairs MSN IV Circular 774-03-01**

**National Cemetery Administration July 10, 2003**

**Memorial Service Network IV Page 8**

**Indianapolis, Indiana**

> **(b)** Excavations are less than 5 feet in depth and examination of
> the ground by a competent person provides no indication of a potential
> cave-in.
>
> 1\) Competent person means one who is capable of identifying existing
> and predictable hazards in the surroundings, or working conditions
> which are unsanitary, hazardous, or dangerous to employees, and who
> has authorization to take prompt corrective measures to eliminate
> them.

**6. REFERENCES:**

> Public Law 91-596, Executive order 12196, EPA, OSHA Standard 1910;
> OSHA Standard 1926; OSHA 3123; VA Manuals MP-1 (Part III), MP-3 (Part
> III); Safety Requirements for VA National Cemeteries Handbook (7710);
> guidelines from the Office of Occupational Safety and Health (00S1);
> Safety & Health Office at the servicing VA Medical Center, Fire
> Protection Engineer, Industrial Hygienist - VA Regional Office (VISN);
> and MSN IV, Federal, State and Local Regulatory Agencies.

**7. EFFECTIVE AND RESCISSION DATE:** This circular is effective upon
receipt and

remains in effect until further notice.

George M. Webb

MSN IV Director

Distribution:

Cemetery Directors

Safety Officers

Supervisors/Foremen/Work Leaders