# Presentation: 432598

## NASA Safety & Health Programs Guidelines for Responding to Safety Requirements in Construction Requests for Proposal (RFP)

**NASA Johnson Space Center**
**David T. Loyd**
**Safety and Test Operations Division**
**May 23, 2006**

## Agenda

**Overview of the NASA Safety Program**
**What will be expected of you at JSC**
**Specifically Applicable Requirements**
**A Successful Safety Program Model**
**The Safety & Health Plan**
**Examples of How to Gain Un-wanted Attention**
**Helpful Resources**
**Recommendations **
**References **

## Overview of the NASA Safety Program

**NASA safety objective is to avoid loss of life, personal injury and illness, property loss or damage, or environmental harm resulting from any of its activities and to ensure safety and healthful conditions for persons working at or visiting NASA facilities**
**NASA shall comply with all applicable regulations**
**NASA safety and health requirements**
**Requirements of those federal agencies with regulatory authority over NASA such as OSHA, EPA, and DoT**
**NASA requires every employee to report workplace hazards**
**NASA ensures that there is no reprisal to personnel for reporting unsafe or unhealthy conditions**

## Overview of the NASA Safety Program

**The NASA Safety Policy stresses the individual responsibility of each employee for their own safety and that of their co-worker.  Risk within the work environment must be managed to control hazards and continuously improve workplace conditions  **
**The Occupational Safety and Health Administration (OSHA) has recognized JSC as a leader in health and safety by awarding the “Star” designation level of achievement in the Voluntary Protection Program (VPP) **
**As a VPP Star, JSC has a comprehensive and successful safety and health program, is below the national average for the industry in injury/illness rates, has demonstrated good faith in dealing with OSHA, and serves as a safety & health mentor to regional industry**

## Specifically Applicable Requirements

**29 CFR Part 1926 OSHA Standards for the Construction Industry (applies at construction sites and work areas)**
**29 CFR Part 1910 OSHA Standards for General Industry (applies across JSC workplaces)**
**JPR 1700.1 JSC Safety and Health Handbook (Latest Revision)**
**General Requirement - Contractor Safety and Health Program (Specification Section 01410)**
**Specification Section 01410 Sec. 1.8, addressing Asbestos, Required Safety Training, Lockout/Tagout, Fall Protections, etc.**
**The contractor’s approved site specific Safety and Health Plan will be fully incorporated into the contract and followed during the period of performance.**

**Notes:**
Spec 1410 addresses:
GENERAL JSC SAFETY INFORMATION
SUMMARY
REFERENCES
SUBMITTALS
SAFETY AND HEALTH PROGRAM GENERAL PROVISIONS
1.5.1 Meetings
1.5.2 Inspections
1.5.3 Safety and Health Activity Reports
1.5.4 Inspection and Hazard Tracking Records
1.5.5 Mishap Investigation and Reporting
1.5.6 Near Miss Investigation
1.5.7 Form JF288 "Statistical Information"
1.5.8 Clearance of Roadways
1.5.9 Protection From Injurious Dirt and Dust
1.5.10 Hydrostatic or Other Special Testing
1.6 SAFETY AND HEALTH PLAN REQUIREMENTS
1.6.1 Contractor's General Safety and Health Plan
1.6.2 Contract Specific Safety and Health Plan
1.6.3 Subcontractor Safety and Health Plans
1.6.4 Changes to Safety and Health Plans
1.7 SAFETY AND HEALTH SYSTEM ORGANIZATION REQUIREMENTS

## What would be expected of you at JSC

**All contractors performing work at JSC shall comply with all applicable safety and health regulations**
**JSC does not assume the responsibility of the “employer” for contractor employees**
**Every major onsite contractor shall have a designated safety official and shall conform to a written safety and health plan**
**Failure to comply with safety and health requirements may result in contract termination and exclusion from future contract awards**

**Notes:**
1410 Requires:
Contractor's General Safety and Health Plan
The Contractor shall submit a current, comprehensive, written General
Safety and Health Plan describing the Contractor’s overall Safety and
Health Program. The General Safety and Health Plan shall be submitted and
approved prior to work activities being started.

Contract Specific Safety and Health Plan
The Contractor shall submit a comprehensive, written Contract Specific
Safety and Health Plan describing how the Contractor’s General Safety and
Health Program will be tailored to the activities on this contract at
Johnson Space Center. The Contract Specific Safety and Health Plan shall
be submitted and approved prior to work activities being started.

Subcontractor Safety and Health Plans
The Contractor shall submit detailed, written Subcontractor Safety and
Health Plans as described below. Each subcontractor’s plan shall be
specific to the activities at Johnson Space Center. The Subcontractor
Safety and Health Plans shall be submitted and approved by the Contracting
Officer prior to subcontractor work activities being started.
NOTE:  The subcontractor may elect to participate in the prime contract S&H Plan, but there are specific data requirements and specific written program requirements that may still apply to the sub-contractor.

## A Successful Safety Program Model

**Based on 4 Basic VPP elements defined by OSHA**

- Worksite Analysis

**Notes:**
Whether or not you participate in the OSHA VPP program, you are expected to cultivate a strong relationship between management and employees.  
This has been proven most effective at identifying common hazards and encouraging employees to work with management to prevent injuries.
Workplace Analysis systematically identifies hazards
Hazard Prevention and Control manages hazards once they are identified.
Training programs establish and maintain your culture and educates employees how to protect themselves and their co-workers.

## The Safety & Health Plan

**	****Safety & Health Plan provisions you may be expected to address on a typical JSC service or construction contract**
_***Management Leadership and Employee Involvement***_
**Management Commitment – demonstrable leadership via goals and objectives, policy**
**Planning – safety is planned, it doesn’t just happen**
**Written Safety and Health Program – documented program (corporate manual or handbook)**
**Top Management Leadership – starts at the top**
**Authority and Resources – roles and responsibilities, funds, manpower (designated safety and health official, safety representative, medical contact, building fire wardens)**

**Notes:**
1410 General Plan

Safety and Health Policy of the corporation/company signed by the firm’s CEO, President, Owner, or other senior executive
Purpose and Scope of the Safety and Health Program
Management Leadership Commitment and Employee Involvement in the Safety and Health Program
Responsibilities of participants in the Safety and Health Program
Managers
Supervisors
Employees
Safety and Health Manager
Training Coordinator

## The Safety & Health Plan

**	****Safety & Health Plan provisions you may be expected to address on a typical JSC service or construction contract**
_***Management Leadership and Employee Involvement***_*** (cont.)***
**Line Accountability – safety is not a service but a fundamental part of each manager’s job**
**Contract Workers – how subcontractors are included seamlessly into the prime’s safety program**
**Employee Involvement – participative involvement in safety program to all levels of the organization**
**Safety & Health Program Evaluation – how is the program doing and any issues with the NASA safety program**

**Notes:**
How will you hold your leaders accountable for safe performance on the job?
Prevention activities a part of job performance evaluation
Taking effective corrective actions following an injury
Pay incentives for good performance
Discipline approaches for poor safety leadership
Make your subcontractors responsible for PREVENTING their employee’s injuries.  Ensure they observe your safety practices.  Hold them accountable for safety by withholding payment or stopping their work if they aren’t complying with safety requirements.
Subcontract S&H Plans are required by Spec. 1410
Give employees a role in the safety program, like:
Conducting safety meetings or committee involvement
Inspection activities
Suggestion programs
Close Call or Near Miss programs and investigation involvement
Buddy systems and cross-checks
Providing training and updating training
Evaluate how your safety practices, policies, and programs are doing by looking at elements of the program against you S&H Plan requirements, OSHA requirements, industry best practices.  This can be done with employees, management, and/or consultants.  This evaluation must be written and recommendations should be included with estimate of completion. 
Specific written reports are required in Spec. 1410
Prep, Initial, Follow-up, and Weekly Inspection 
S&H Activity Reports

## The Safety & Health Plan

**	****Safety & Health Plan provisions cont’d**
_***Worksite Analysis***_
**Management Understanding – of hazards (recognition and response)**
**Industrial Hygiene – a specialized area of a safety program requiring technical support**
**Pre-use Analysis – before u use a new or modified piece of equipment or process, what has changed with respect to the hazards involved?**
**Hazard Analysis – of jobs, tasks, equipment, systems, processes**

**Notes:**
Identify the hazards that are typically present in your type of business.  How will you regularly educate your employees on these hazards?  What action will you typically take to control these hazards?
Special S&H Program Requirements (Spec 1410):
Processes for hazard identification, prevention, and control as
applicable:
Inspections and Surveys
Exposure monitoring (chemical, noise, radiation)
Asbestos Program
Lead and Heavy Metal Exposures
Confined Space Entry Program
Hearing Conservation Program
Written Hazard Communication Program
Written Respiratory Protection Program
Personal Protective Equipment
Energy Control and Lockout/Tagout
Welding and Cutting Program
Fall Protection Program
Crane Operations and Heavy Lifting
Material Handling Program
Scaffolding and Ladder Safety
Excavations and Trenches
Concrete and Masonry Program
Motor Vehicle and Heavy Equipment Operation
Demolition
Other construction activities applicable to the firm

## The Safety & Health Plan

**	****Safety & Health Plan provisions cont’d**
_***Worksite Analysis***_*** (cont.)***
**Routine Inspections – to catch hazardous conditions before some one is hurt**
**Employee Hazard Reporting System – for employees to report hazards and close calls proactively and in near real time so they can be addressed before someone gets hurt**
**Accident/Incident Investigations – provides information on how to keep them from happening again**
**Trend Analysis – degrading, stable, improving **

**Notes:**
Discuss your methods of performing inspections – who does it, how often, what will you do with the results
What processes will you have for employees to report safety problems?
How will you conduct investigations?  What will you investigate? – You must investigate injuries, but other types of investigations could give you a more competitive advantage on your S&H Plan and will bolster your injury prevention efforts.
You can do this over a long period of time with injuries and you can gain advantage by trending your hazard reduction efforts – what are you seeing, how are you doing correcting hazards, etc.

Spec 1410 – 
Inspection requirements – daily, weekly
Hazard tracking system
Hazard abatement plans
Report mishaps to Contracting Officer (or COTR) within 24 hrs
Investigate mishaps and close calls

## The Safety & Health Plan

**Safety & Health Plan provisions cont’d**
_***Hazard Prevention and Control***_
**Certified Professional Resources – safety professionals, industrial hygienists, trainers, system safety practitioners, trainers**
**Hazard Elimination or Control**
**Engineering Controls**
**Administrative Controls**
**Safety and Health Rules**
**Personal Protection Equipment (PPE) – selection, care, and training**
**Hazard Control Programs – such as lockout/tagout, confined space entry**

**Notes:**
Do you have access to safety professionals, like CSP’s and Industrial Hygienists?  Where do they come from?  How and when will you call for help?

1410 requires specific contract representatives based on the size of the job:
Safety & Health System Specialist/Professional – degreed with 5yrs experience, or a CSP
Safety & Health System Staff – craft specialists reporting to the SHSS.
Competent Person – OSHA designation  
Discuss what your process is for selecting controls for hazards?  Will you always look to eliminate them, or will you rely more on training, procedures, equipment....
What PPE will you need?  Will you provide it to employees or will you insist they get their own
Eye goggles – impact, chipping, hammering, etc.
Protective footwear for heavy machinery operations
Gloves for chemical handling, sharp tool handling, hazardous materials handling, etc.
What OSHA special programs do you think will apply to your work?

1410 program requirements:
Confined Space Entry Program
Hearing Conservation Program
Written Respiratory Protection Program
Energy Control and Lockout/Tagout
Welding and Cutting Program
Fall Protection Program
Crane Operations and Heavy Lifting

## The Safety & Health Plan

**Safety & Health Plan provisions cont’d**
_***Hazard Prevention and Control***_*** (cont.)***
**Occupational Healthcare Program – treating injuries and illnesses, case management**
**Prevention Maintenance – of equipment and systems to ensure workers are not exposed to damaged or failing hardware**
**Hazard Correction Tracking – one a hazard is found, how tracked to completion of corrective actions**
**Disciplinary System – self explanatory**
**Emergency Procedures**** – ****how to respond to an emergency**

**Notes:**
What medical care will be necessary for your employees – first aid training, medical facility availability, etc.
How will you maintain your equipment in safe working order?  Schedules, agreements with manufacturers, etc.
How will you manage hazards identification? An organized notebook is sufficient for simple service contracts, binder for employee reports, spreadsheet, etc.
Prioritization of corrective actions
Funding availability
Interim controls
Status reporting
Discipline should be consistently defined and communicated to the workforce.  The most effective discipline is administered before someone gets hurt.
What emergencies could occur in your type of work?  How would you respond to the emergency?  What role do your employees play in an emergency?  How would you communicate the expectations?

## The Safety & Health Plan

**Safety & Health Plan provisions cont’d**
_***Safety and Health Training***_
**Program Description – training program description**
**Supervisors – specialized training for supervisors**
**Employees  - specialized training for employees according to their jobs (crafts, office workers, etc.) especially in hazard recognition**
**Emergencies – fire drills, evacuation drills, site emergency**
**Personal Protective Equipment – training in use and care of PPE**
**Managers**** – ****specialized training for managers**

**Notes:**
What kinds of training will you provide yourself?  What training is best provided by outside resources?
Based on the plan already described, what do you think a supervisor training program should consist of – KEEP YOUR S&H PLAN CONSISTENT WITHIN ITSELF.
Basic employee safety must instruct the employee how to perform their job safely.
Manager training could be the same as supervisor training.

Spec 1410 Training Requirements:
JSC employee orientation
JSC Construction Industry Safety Training
Confined Space Entry
LO/TO
Asbestos awareness
APPROVED TRAINING RESOURCE – HOUSTON AREA SAFETY COUNCIL
Contractor employees must maintain evidence of completed training.  Acceptable evidence includes HASC badge, JSC-issued cards, OSHA card, attendance records.

## The Safety & Health Plan

**Safety/Health and Environmental Goals – should be measurable**
**Environmental Requirements (included due to serendipity with Safety and Health) – covers areas such as toxic materials, environmental releases and spills**
**Miscellaneous reports contained in body of Data Requirement – statistics; mishap reports; close call reports; hazard reports; inspection reports; building fire wardens; hazardous materials inventory; roster of terminated employees; material safety data sheets; OSHA logs; program self evaluation; participation in performance evaluation profile surveys**

**Notes:**
Goals should be measurable and attainable –
Reduce injuries
Ensure all personnel are trained

Address environmental requirements associated with your service:
Hazardous materials handling and disposal (gasoline, oil, pesticides, fertilizers)
Water and energy conservation
Waste disposal

Follow the rules on reporting – if you wont be occupying a JSC building you may not need a fire warden.

1410 Required Reports:
Plan/Permit status
MSDS submitted
Inspections performed
Hazard investigations

##         Examples of How to Gain Unwanted    Attention from JSC Safety

**Willful and deliberate disregard of hazardous area access controls**
**Lockout/Tagout or Confined Space violations**
**Inadequate fall protection**
**Defective, defeated, or removed machine guarding**
**Failure to use personal protective equipment**
**Unauthorized confined space entry**
**Horseplay and other unsafe behaviors**
**Possession of drugs, alcohol, or firearms while on duty**
**Failure to submit reports on schedule**

## Helpful Resources

**	****There are a number of helpful publications available from OSHA which offer guidance on safety and health regulations**
**	****www.osha.gov/Publications**
**OSHA 2202, Construction Industry Digest**
**OSHA 2209, Small Business Handbook**
**OSHA 2254, Training Requirements in OSHA Standards**
**OSHA 3071, Job Hazard Analysis**
**OSHA 3146, Fall Protection in Construction**
**OSHA 3151, Personal Protective Equipment**
**OSHA 3252, Construction Pocket Guide**
**OSHA 3289, Construction PPE Quick Card**

## Recommendations

**For the good of your employees and your business, take safety seriously and proactively plan to PREVENT injuries**
**Contact the procurement point of contact on the solicitation if you have questions**
**Understand the data requirements**
**Your own format for a plan is acceptable, but to expedite government review, please provide a traceability map if your format will not follow Data Requirement format**
**Tailor your plan to what you will do on the contract**
**Any RFP requirement you feel is inappropriate for the plan, tell us why**

## References

**NASA Federal Acquisition Regulation Supplements (NFS)**
_**[http://nais.nasa.gov/FAR/](http://nais.nasa.gov/FAR/)**_
**	**** ****NFS 1852.223-70  -  Safety and Health **
**	**** ****NFS1852.223-73  -  Safety and Health Plan **
**	**** ****NFS 1852.223-75  -  Major Breach of Safety or Security **
**General NASA information**
_**[http://](http://www.nasa.gov/)**__**[www.nasa.gov](http://www.nasa.gov/)**__**[/](http://www.nasa.gov/)**_
**Occupational Safety & Health Administration**
_**[http://www.osha.gov/](http://www.osha.gov/)**_
**JSC Safety and Health handbook (JPR 1700.1)**
_**[http://](http://jschandbook.jsc.nasa.gov/)**__**[jschandbook.jsc.nasa.gov](http://jschandbook.jsc.nasa.gov/)**__**[/](http://jschandbook.jsc.nasa.gov/)**_