Front Load Dumpster
Scrap Metal Buyer
GA Cites Served
Safety Rules for Job Site Construction Clean Up
- Asbestos Containing Material (ACM)
- Competent Person
- Confined Space
- Department of Environmental Safety
- Imminent Danger
- Lead-Based Paint
- Material Safety Data Sheets (MSDS)
- Project Manager
- Project Monitor
- Site Inspector
- DUTIES AND
- University Project Mangers
- DES Employees
- DES Director or Designee
- Site Inspectors
- Contractors and Subcontractors
- GENERAL UM
ENVIRONMENTAL HEALTH AND SAFETY REQUIREMENTS
- Work Issues
- Protection of Property
- Demolition: Preparatory Operations
- Asbestos and Lead-Based Paint
- Portable Ladders and Scaffolds
- Site Access and Use
- Fall Protection
- Contractor Tools and Equipment (including Man lifts)
- Transfer of Flammable Liquids to Containers, Equipment, and Vehicles
- Lockout/Tag out
- Confined Space Entry
- Excavation Safety
- HAZCOM Standard
- Personal Protective Equipment (PPE) and Hazard Signage
- Hazardous Materials
- Hazardous and Regulated Waste
- Spills and Releases
- Natural Resources Permitting and Compliance Issues
- Fire Protection/Life Safety
- Small Projects
REQUIREMENTS AND INFORMATION
- REGULATORY AGENCY
APPENDIX A - DES SUBJECT
APPENDIX B - ASBESTOS
APPENDIX C - DES
ENVIRONMENTAL HEALTH AND SAFETY FACT SHEETS CONSTRUCTION TOPICS
APPENDIX D - FEDERAL OSHA
APPENDIX E - MARYLAND OSHA
Environmental Health and Safety Guidelines For Construction,
Renovation and Demolition
This guidance document has been prepared by the University of Maryland
College Park (UM) Departments of Environmental Safety (DES) and Facilities
Management (FM) to define the environmental, health, and safety (EHS)
responsibilities of FM personnel managing Contractors who conduct work on
campus property. These guidelines apply to Contractor activities that may
impact the safety and health of UM employees and contractual personnel; pose
an environmental hazard; or are contrary to Federal/State regulations and
contract requirements. The information provided in this document should be
used to assist Project Managers and Site Inspectors in the identification of
construction hazards and facilitate inter-departmental communications.
Furthermore, it should be used by Contractors as a reference source for basic
health, safety, and environmental information while working on the UM campus
and affiliated locations. This document does not address all EHS issues that
may arise during a construction, renovation or demolition project. It is
designed to address those EHS issues that are typically encountered during the
course of UM projects. If conditions are encountered during a project that are
not addressed in this document or clarification is required relative to site
specific conditions, the Project Manager should consult with DES.
This guidance document applies to all FM units that hire outside
Contractors to perform work on campus and affiliated off-campus locations.
Oversight of contractual services is the general responsibility of the
contracting FM department. The individual responsible for coordinating and
accepting the work is referred to in this document as the "Project Manager".
The individual who inspects the progress of work at the project site is
referred to as the "Site Inspector".
Many contracted services have the potential for direct impact to UM
students, faculty, staff, employees and visitors. Failure to comply with
construction specifications or accepted EHS practices and regulations may pose
a risk to the campus community, UM assets, and the environment.
In all circumstances, outside Contractors are directly and legally
responsible for the health and safety of their employees, and for compliance
with environmental, health and safety regulations. They must also correct EHS
deficiencies that are brought to their attention. An identified imminent
danger must be corrected immediately. Failure to adequately address
deficiencies is cause for progressive actions up to and including discharge
For these reasons, this guidance document is written to explain the roles
and responsibilities for conducting and managing work performed by
Contractors. This document is not intended to replace a Contractor's safety
program nor summarize all the EHS regulations governing the Contractor's
Should situations arise which are not covered in these guidelines, or if
you have a question about a guideline, contact the UM Project Manager or DES
- Asbestos Containing Material (ACM) - A material that contains
detectable asbestos according to the Maryland Asbestos Oversight Committee (AOC).
- Competent Person - A person who is trained and capable of
recognizing existing and predictable hazards in the workplace and has the
authority to take corrective action and/or stop work. In terms of fall
protection, this individual can also identify dangerous conditions in the
personal fall arrest system or any component as well as their application
and use with related equipment. For trenching and shoring, this person is
trained in the relevant OSHA requirements, soil types and conditions,
acceptable benching and sloping methods and excavation support techniques
- Confined Space - A Permit-Required Confined Space is a space
- Is large enough and so configured that an individual can enter and
performed assigned work; AND
- Has limited or restricted means for entry or exit; AND
- Is not designed for continuous occupancy; AND
- Has ONE OR MORE of the following characteristics:
- Contains or has the potential to contain a hazardous atmosphere; OR
- Contains a material that has the potential for entrapping, engulfing
or suffocating an individual; OR
- Has an internal configuration such that an individual could be
trapped or asphyxiated by inwardly converging walls or by a floor which
slopes downward and tapers to a smaller cross-section; OR
- Contains any other recognized serious safety or health hazard.
- Department of Environmental Safety (DES) - The Department of
Environmental Safety is a unit within the Division of Administrative Affairs
and has the primary responsibility for facilitating UM compliance with all
applicable safety and environmental laws, regulations and permit conditions.
DES serves as the lead department in coordinating UM activities with safety
and environmental regulatory agencies including Maryland Occupational Safety
and Health, Maryland Department of the Environment, Maryland Department of
Natural Resources, U.S. Environmental Protection Agency, U.S. Occupational
Safety and Health Administration, Nuclear Regulatory Commission and several
quasi regulatory institutions. DES is organized into several units
including: the Occupational Safety and Health unit (OSHA); Environmental
Affairs (EA); Code Services; Radiation Safety; Biosafety; Fire Marshal; and
Risk Management and Communications.
DES units have the following general responsibilities:
|EA is responsible for overseeing all environmental compliance
activities including hazardous, radioactive and biohazardous waste
management; environmental permitting, environmental sampling, spill
response and environmental cleanup activities. |
|OSHA is responsible for facilitating compliance with applicable safety
and health regulations including: hazard communication; fall protection;
confined space entry; lockout/tag out; asbestos and lead management;
accident/incident investigation and mitigation; and indoor air quality
|Code Services reviews project designs managed by FM for fire, health
and safety issues; code compliance, and coordinates health and safety
issues associated with construction, renovation and demolition projects
including asbestos and lead management. Code Services includes an
Assistant State Fire Marshal who must approve all project design
documents, test and accept fire suppression systems and issue final
occupancy approvals. |
|The Fire Marshal Unit includes additional Assistant State Fire
Marshals who have jurisdiction over ongoing campus activities including
activities that pose a risk to building occupants, existing fire
suppression systems, management of the hot works permits program and
public assemblies. |
|Risk Management and Communication is responsible for the campus
Worker's Compensation Program and management of UM's insurance claim
|Biosafety is responsible for the approving and overseeing the safe use
of biological agents and response to biological incidents. |
|Radiation Safety has overall authority over licensing, purchase and
use of radioactive sources. |
|The Manager of Natural Resource Permitting is responsible for
advising, facilitating, reviewing, and tracking, all natural resource
permits associated with construction. These include wetland, floodplain,
sediment and erosion control, storm water and forestation permits. |
All DES departments may be reached by calling (301) 405-3960. The DES web
page, located at http://www.des.umd.edu,
includes subject specific contacts within the Department (See Appendix A);
Fact Sheets summarizing key EHS issues; training opportunities including
online training; all DES procedures and policies; DES forms, permit
applications and databases related to confined spaces and ACM inventories;
online permits; and links to Material Safety Data Sheet databases and
regulatory agency web sites.
Imminent Danger - An imminent danger is defined as a condition or
practice that (1) could reasonably be expected to cause death or serious
physical harm to UM faculty, staff or students, and/or Contractor personnel,
or (2) has or may cause an uncontrolled release of hazardous or otherwise
regulated material to the air, water or soil.
Lead-Based Paint (LBP) - A paint containing at least 0.7 milligrams
of lead per square centimeter (0.7 mg-Pb/cm2) of surface area or 0.5% lead
Material Safety Data Sheet (MSDS) - A document supplied by a
manufacturer that describes the ingredients, health hazards and means of
protection related to a hazardous material. MSDS's are required by and must
meet the informational requirements specified by OSHA.
Project Manager - The individual responsible for coordinating and
accepting the Contractor's work. The Project Manager may officially carry
that job title (e.g., Project Manager for construction of a new building),
or may have that contingent duty assigned by FM. The Project Manager is the
primary conduit of information between the contractor and the University,
and employees responsible for this work should have an awareness of EHS
regulations, permits, plans and UM policies. Projects that are designed by
Facilities Management (FM) are assigned a FM Project Manager.
Project Monitor - The Project Monitor is an approved industrial
hygienist that is professionally insured, licensed in Maryland and qualified
to provide asbestos and lead-based paint abatement project oversight.
Site Inspector - The individual responsible for routine
monitoring of Contractor activities on the site is the Site Inspector. For
projects managed by FM, a Site Inspector is assigned to the Project. This
individual routinely visits the site; monitors progress, identifies
situations that do not comply with terms of the Contract; and works in
tandem with the Project Manager and the Contractor to resolve those
UM Project Managers and Site Inspectors should obtain training about EHS
topics relevant to the types of projects they are involved in managing.
Training is available through DES and external sources including OSHA and MOSH.
Training may include one or more of the following: a review of regulations
that apply to the project; DES "Fact Sheets"; online DES courses including
ACM/LBP awareness, hazardous waste management, radioactive materials
management, etc.; routinely scheduled face-to-face DES training including
Natural Resource Permitting, Environmental Hazard and Safety Awareness related
to Construction; blood-borne pathogen training; Hazard Communication training;
and Spill Prevention Control and Countermeasure (oil spill response) training.
DES course schedules are available at. In addition to these sources, individuals may
review DES published guidance manuals, procedures and plans available through
the DES web site or request a training session from DES about one or more
topics. OSHA and MOSH provide extensive information through their web sites
and provide courses and workshops related to EHS and construction activities.
Duties and Responsibilities
General UM Environmental, Health, and Safety Requirements
- University Project Managers shall:
- Be knowledgeable concerning EHS items that occur on projects that the
PM is responsible for and receive training that provides an awareness of
EHS issues as appropriate.
- Ensure that all planned projects involving new construction; changes
in existing space use and occupancy; changes in floor plans; and
installation or modification of building systems are reviewed and approved
by DES at each design phase of the project to ensure compliance with
applicable codes and permits. In addition, ensure that all projects
involving the disturbance of land is evaluated by the Manager of Natural
Resource Permitting to determine the need for environmental (natural
resource) permits. For those projects described above, ensure final use
and occupancy inspection is completed by DES before occupancy is
permitted. It should be noted that some small projects may not require DES
review and approval (i.e. painting, casement replacement, etc.). Project
Managers should contact DES to determine the need for code review.
- Ensure that pre-existing hazards at a UM work site (i.e. presence of
asbestos, lead, contaminated soil, etc.) are communicated to the affected
Contractor prior to the start of work.
- Respond to EHS deficiencies identified by DES and other UM employees
and work with the Contractor to eliminate the deficiencies.
- Communicate observed or suspect EHS concerns to DES.
- Immediately notify the DES Director if the Contractor fails to correct
an identified imminent danger.
- Note deficiencies and corrections in the project log and report
instances of continued non-compliance to DES. Keep DES informed of the
status and resolution of identified deficiencies.
- Ensure that Contractors are following the EHS requirements specified
in the contract.
- Require that Contractors provide copies of EHS regulatory agency
inspection and violation reports they may receive relative to the
contracted work and the campus site they are working on.
- Follow up on corrective actions for reported deficiencies from
- In the event of an incident, ensure that Material Safety Data Sheets (MSDS's)
are immediately available for all hazardous materials that will be used by
Contractors on campus.
- Ensure that all hazardous, biological or radioactive waste resulting
from a project is processed through DES. These include wastes resulting
from the demolition, renovation or removal of building and building
components. Waste generated by the Contractor such as those from cleaning
and degreasing, unused hazardous material products supplied by the
Contractor, etc. are the sole responsibility of the Contractor.
- Notify the Contractor of any observed or reported EHS concern, but do
not prescribe corrective action at a Contractor-controlled site without
specific authorization from the DES Director.
- Ensure that UM specific information concerning topics such as
lock-out/tag-out procedures and confined spaces are communicated to the
Contractors as appropriate and as required by OSHA regulations.
- As applicable, ensure Contractor submits completed Asbestos Abatement
permit located on the DES web site: (http://www.des.umd.edu/os/asbestos/form/asbabate.pdf)
See Appendix B. At the conclusion of the work, notify the UM Project
Manager and DES of actual ACM removed and remaining in the affected work
- Coordinate the movement of any equipment/processes that must be
relocated as a consequence of the work.
- DES Employees shall:
- Provide EHS training for individuals assuming Project Manager and Site
- Respond to complaints regarding Contractor activities that may impact
the safety of UM employees and visitors, the campus environment, or that
are deemed imminent dangers.
- DES employees who observe an imminent danger shall inform Contractual
personnel that the activity must be immediately stopped until appropriate
corrective actions are implemented. The DES employee will immediately
contact the UM Project Manager (or their supervisor, if the Project
Manager is unavailable or unknown) to explain the circumstances of the
work stoppage, and shall notify the DES Director in writing by the end of
that business day. Notify the DES Director if the Contractor fails to
correct an imminent danger.
- When approved by the DES Director, contact the appropriate regulatory
agency (e.g., MDE, MOSH) to report Contractor non-compliance, and provide
support services to regulatory agency representatives as necessary.
- Notify the Project Manager of any observed or reported EHS concern.
- Not prescribe corrective action at a Contractor-controlled site
without specific authorization from the DES Director.
- DES Director or Designee shall:
- In the event an imminent danger exists at a construction site,
determine the need to contact UM FM management, the Legal Office, and/or
the appropriate regulatory agencies when Contractors fail to make
sufficient efforts to correct imminent dangers. In the case of
public/private partnerships, or other projects not directly managed by
Facilities Management, written notice will be provided to the appropriate
responsible parties, the UM Legal Office and the Associate Vice President
of Administrative Affairs.
Provide recommendations, as determined necessary, to the appropriate
Project Manager and Procurement for discharge of Contractor from the
- Site Inspectors shall:
- Obtain necessary EHS awareness training to be aware of common
environmental permit requirements and safety and environmental hazards
associated with construction and renovation projects.
- Inspect and monitor Contractor and subcontractor project activities to
ensure contract compliance with EHS requirements.
- Notify the Project Manager and the Contractor of any observed or
reported EHS concern, but do not prescribe corrective action at a
Contractor-controlled site without specific authorization from the DES
- Report uncorrected imminent dangers to the UM Project Manager and DES.
- Contractors and Subcontractors:
- Comply with all EHS contract requirements as well as applicable
federal, state, and local regulations.
- Provide all safety and personal protective equipment (PPE) required to
complete the contracted scope of work. PPE equipment must meet or exceed
the requirements of the appropriate governmental regulatory agency.
- In the event of an incident, ensure that copies of Material Safety
Data Sheets are immediately available for all hazardous chemicals and
products that will be brought onto campus.
- Process all hazardous waste described under Section IV.B.16 through
DES by calling (301) 405-3163/2. All hazardous waste containers must be
closed, labeled to identify the container contents and in good condition.
State and federal regulations require the use of the federal Hazardous
- Ensure the supervisor on-site is well trained on EHS activities and
regulations in the performance of the work.
- Be familiar with the contents of this guidance document as it applies
to the contracted scope of work.
- Provide a copy of the firm's safety and health program as an
attachment to the bid proposal and/or acceptance of contract.
- Notify DES when hot work is to be performed (welding, cutting, etc.)
Appropriate permits should be obtained and filed with DES). This can be
done through the DES web site (http://www.des.umd.edu).
- Review UM's lockout - tagout procedures when working on UM controlled
equipment and sites.
- Provide all specified submittals for review as deliverable documents
where required for asbestos and lead removal work (i.e. NESHAP
notifications with Maryland, DES asbestos abatement permit, etc.).
- If work is to be done in a confined space, check the UM inventory for
special hazards via the DES web site described above. Contractor's should
follow their Confined Space Entry program requirements. Notify Work
Control (301-405-2222) when an entry is to be made. Forward a copy of
completed permits to DES at 3115 Chesapeake Building, College Park, MD.
20742, or via fax (301-314-9294).
The following information is provided to assist FM employees in recognizing
hazards that may occur in conjunction with contractor projects; facilitate
communications between FM and DES regarding construction EHS issues; and to
minimize risks that construction activities may impose on UM employees,
visitors and the campus environment. Project Managers, Site Inspectors and DES
staff should identify EHS concerns to the Contractor, but not prescribe
corrective actions. Contractors may be directed to government web sites or
other generally recognized information services.
- Emergency Procedures
- Reporting Emergencies:
If a Contractor notices signs that may indicate a fire, gas/vapor
release, downed electrical wires, releases to the environment, etc., the
contractor shall call 911 or call the campus Police using one of the
available campus emergency "Blue" phones. Provide the 911 operator with as
much detail as possible, caller's name and the employer's name. Remain on
the phone until the operator has verified the information. At this point,
unless otherwise told, the Contractor should leave the area per their
Emergency Response Guidelines and notify the Project Manager, Site
Inspector, or DES immediately.
- Contractor Responses:
Upon hearing any alarms, the contractor should stop all work and
evacuate as necessary. This includes ceasing all welding and burning
activities, shutting off all equipment (electrical, motorized, and
pneumatic), and extinguishing all sources of ignition.
The Contractor supervisor or crew leader should take a head count to
ensure that all contract personnel are accounted for. The Contractor
personnel should remain within at a safe distance of the area they
evacuated until the "ALL CLEAR" is announced and a UM employee has
instructed them that they may return to work.
- Obtaining Assistance for a Medical Emergency:
If the contractor requires assistance for a Medical Emergency, it can
be obtained by calling 911. When the person answers, the caller shall
identify the area where assistance is needed, type of injury or accident,
his/her name, and the company name. The caller should not hang up until
all the information has been verified.
- Accident/Incident Reporting:
If a person is seriously injured or the Contractor becomes aware of a
fire, explosion, fatality, or other serious incident, the Contractor
should immediately notify Campus Police. The UM Project Manager and DES
should then be immediately informed of the incident. Contractors are
responsible for notifying MOSH in the event of a fatality or multiple
injuries involving their employees. News releases should be coordinated
with the UM Communications office on campus.
- Work Issues
- Protection of Property:
In accordance with the project contract, the Contractor will be held
liable for all damage to personal and real property as a result of the
contractor's negligence to provide appropriate protective measures.
The Contractor shall keep the work area, specifically walking and
working surfaces, clean and free from debris and trash which could cause
slipping and tripping hazards. Tools, materials, dirt, lumber, concrete,
metal, insulation, paper, etc. should be promptly cleared and disposed of
by the Contractor. All debris should be disposed of each day off the
campus or in a Contractor supplied dumpster.
- Demolition: Preparatory Operations
- Coordinate utility and mechanical service modifications with FM Work
Control in advance of work.
- Provide public pedestrian protections such as barrier fences and
sidewalk sheds in accordance with local building code; and coordinate
vehicle traffic control with campus police, subject to MUTCD (2000).
- Identify potential hazardous material conditions at the site. When
potential hazardous conditions are apparent or suspected, testing shall
be performed and the hazard eliminated before demolition starts. Common
hazardous material site conditions include (but are not necessarily
limited to); asbestos-containing building materials (ACBMs), lead-based
paint (LBP), polychlorinated biphenyls (PCBs) in lamp ballasts, mercury
in fluorescent lamps and thermostats, microbial amplification reservoirs
(molds, fungi, animal droppings), recoverable refrigerants, caustics,
corrosives, metals, and petroleum products.
- Asbestos and Lead-Based Paint
- Asbestos-containing building materials and lead-based paint coated
substrates are located throughout UM buildings and present special
management requirements. These materials are regulated by MOSH, OSHA,
MDE and USEPA. An asbestos inventory is located on the DES web site and
can be referenced to assist with asbestos identification.
- An inspection of building materials for the presence of asbestos and
lead hazards must be conducted prior to initiating renovation and
demolition projects. Facilities Management-Operations & Maintenance
(FM-O&M) manages On-Call contracts with several firms that can perform
asbestos and lead-based paint surveys and abatement. DES recommends that
Project Managers contact FM-O&M prior to renovation to arrange for
survey and abatement work through these on-call firms. These firms have
met specific qualifications of insurance, work and training through a
competitive bid process and are familiar with UM procedures in this
- Federal and state regulations require the identification and
management of asbestos and lead-based paint prior to renovation or
demolition. On larger projects, management by FM-O&M on-call abatement
and Project Monitoring firms should be coordinated to precede the
General Contractor's work.
- All asbestos abatement projects must be overseen by a Project
Monitor unless specifically directed otherwise by the Project Manager
and approved by DES. The Project Monitor is an approved industrial
hygiene firm that is professionally insured and qualified to provide
abatement oversight. The Project Monitor must provide a scope of work
that includes sampling protocols and the submission of a Project
Monitoring Report for DES review. The report must include an executive
summary of all project activities and verification that all required
abatement submittals meet technical specifications.
- Asbestos and lead-paint abatement contractor's final progress
payment should be withheld by UM's Project Manager until DES completes
review of the Project Monitoring Report. For large projects, it is
recommended that FM's Project Manager withhold at least 20% of payments
until DES completes review of the Project Monitoring Report.
DES is available for consultation with Project Managers and Site
Inspectors on all aspects of asbestos and lead-based paint related work.
- Portable Ladders and Scaffolds:
All walking/working surfaces including ladders and scaffolds that may
be utilized by UM employees are subject to inspection by DES for
compliance with OSHA regulations.
- Site Access and Use:
All sites must have controlled access to limit unauthorized individuals
from entering the construction or renovation area. Large projects within a
defined boundary, such as a new building site, must be fenced. Smaller
sites within or in the vicinity of buildings must have temporary fencing,
barricades, etc. subject to building code requirements. Building doors and
roadways may not be blocked without the approval of the Project Manager or
Site Inspector. The use of parking lot space must be pre-approved by
- Fall Protection:
OSHA standards on fall protection must be followed. Major issues
|Providing engineering controls as a primary protective mechanism.
|Providing a Competent Person at the job site where fall hazards
|Providing personal protective equipment and training to protect
employees from fall hazards where engineering controls are not feasible.|
Contractor Tools and Equipment (including Manlifts) :
All equipment brought to a project site by Contractors must be in safe
operating condition. All guards must be in place, and meet or exceed all
applicable governmental regulations (OSHA, EPA, DOT, etc).
Transfer of Flammable Liquids to Containers, Equipment, and Vehicles:
All small quantities (5 gallons or less) of flammable liquids must be
stored in an approved UL listed safety can in approved storage areas at
the project site. Equipment refueling must be accomplished by using
vehicles and hoses that are maintained, inspected and in good condition.
All vehicle engines must be turned off during refueling activities. Using
UM fuel pumps for refueling contractor equipment is prohibited. ABC rated
fire extinguishers (10-lb. minimum) must be provided in the immediate area
of the refueling and chemical storage areas. It is recommended that the
transfer of flammable liquids from drums to small containers incorporate
the use of grounding and bonding.
Work on UM electrical systems is prohibited unless employees or groups
have been given authorization by the Associate Vice President , Facilities
Management to work on these systems. These systems include premise wiring,
wiring for connection to supply, installations of other outside conductors
on the premises, installations of optical fiber cable where such
installations are made along with electrical conductors and work around
exposed energized parts.
Groups currently holding authorization to work on UM electrical systems
include; Facilities Maintenance, Residential Facilities, Dining Services
and Contractors under their control. Additional authorizations will be
reviewed and granted as appropriate.
All work on electrical systems must be performed in a "De-Energized"
state as required by OSHA unless employees have been authorized to work on
systems live. Exceptions to the De-Energized rule may be made for work
where it can be demonstrated that de-energizing introduces additional or
increased hazards or when troubleshooting or maintenance can only be
performed on a live system.
Only authorized/qualified persons may work on electric circuit parts or
equipment that have not been de-energized. Such persons shall be capable
of working safely on energized circuits and shall be familiar with the
proper use of special precautionary techniques, personal protective
equipment, insulating and shielding materials and insulated tools. UM
employees who are authorized to work on UM systems are the authorized
University maintenance staff as and licensed electrical contractors and
sub-contractors, working from designs that have been reviewed and approved
by Facilities Management.
For systems that are de-energized and subsequently locked and tagged
out, UM personnel and UM contractors must inform each other of their
respective lock-out tag-out procedures and shall understand and comply
with the applicable restrictions and prohibitions. UM employees are
required to perform lockout - tagout in accordance with the UM policy and
program VI-14.00(A) UM Policy on Control of Hazardous Energy During
Maintenance of Equipment.
Confined Space Entry:
If a contractor is performing work that requires a confined space
entry, the contractor must provide employees who are trained and qualified
as required by 29 CFR 1910.146 (i.e. Authorized Entrants, Attendants,
Entry Supervisor/Competent Person, Rescue and Emergency Services, etc.).
DES has identified permit required and non-permit required confined spaces
and associated hazards on its web site (http://www.des.umd.edu).
The UM Project Manager must inform the Contractor of identified confined
spaces they may encounter as part of the project. Unless the project site
is fenced and controlled by the contractor or subject to a public/private
agreement, contractors must contact Work Control (301-405-2222), provide
notification of a planned confined space entry and forward a copy of the
contractor's Confined Space Entry Permit to the DES. If a confined space
is to be added, demolished or altered, complete the confined space survey
form and forward it to DES.
All excavations on UM property must be performed in accordance with
applicable OSHA regulations (shored, sloped, shielded, barricaded,
acceptable egress. etc.). The contractor is responsible for providing a
"Competent Person" at every excavation site. This individual must be
capable of identifying existing and predictable hazards in the
surroundings or working conditions which are unsanitary, hazardous, or
dangerous to employees, and who has the authorization to take prompt
corrective measures to eliminate them. Also he/she must be able, through
experience or training, to determine the suitability of equipment or
materials used for support systems, shield systems, and other protective
systems. Prior to starting the actual excavation, the contractor must
ensure that all underground utility installations in the area (such as
electrical, phone, gas, sewage, water, irrigation and fuel lines) have
been identified. On the College Park campus, contact Work Control
(301-405-2222) to request a utility marking.
DES has an established hot work policy. No hot work is allowed without
a permit. A copy of the policy may be obtained from the UM Project Manager
or DES. A hot works permit can be completed online at the Department of
Environmental Safety Homepage (http://www.des.umd.edu).
Hazard Communication (HAZCOM) Standard:
OSHA requires that contractors train their employees in basic chemical
safety precautions and in precautions required for chemicals they work
with, so as not to cause a hazard for themselves and others in the
vicinity. UM expects that all contractors will comply with OSHA's HAZCOM
Standard requirements. PM's must also ensure that contractors make MSDSs
available for chemicals used in areas where UM faculty, students and staff
may be exposed.
Personal Protective Equipment (PPE) and Hazard Signage:
- Contractors must not create hazards for UM employees, students and
visitors. Hazardous areas should be properly secured and signage should
be posted to identify PPE required at the project site and hazards posed
by site activities.
- If non-contractor persons need to enter or pass directly through the
work area, the contractor may be expected to provide appropriate
Personal Protective Equipment (PPE) for such visitors at anytime. The
PPE to be made available is dependent on the hazards posed by
construction activities. Typically, hard hats and safety glasses are
Safety equipment supplied and used by contractors is expected to
comply with OSHA requirements.
There are many hazardous materials at UM. These materials are typically
found in laboratories in the form of chemicals, biological agents, and
radioisotopes. Contractors must avoid creating an unsafe work environment
or cause disruption of any lab activity when working in these areas.
The following precautions should be followed by the Contractor before
working in a laboratory or hazardous material storage area. In addition,
these guidelines apply to hazardous materials the Contractor brings and
stores on a project site.
Hazardous and Regulated Waste:
- Advise the laboratory supervisor or primary researcher what work
will be completed so appropriate precautions can be taken.
- Avoid contact with any lab equipment left in the work area.
- Material Safety Data Sheets for all chemical compounds used at the
job site should be immediately available on-site or off-site.
Contractors must be capable of providing a MSDS within 1 hour of an
incident. Contractor employees should carefully read container caution
labels and be able to provide information concerning the hazardous
materials they are using or storing.
- When using chemical compounds, especially odorous products,
appropriate precautions should be followed as stated on container
labels. As necessary, proper ventilation should be established prior to
their use. The UM Project Manager may require modification of existing
ventilation systems or restrict work to specific days/times to minimize
occupant chemical exposure.
- Containers of chemicals and hazardous materials brought on site by a
Contractor must be stored indoors; labeled with the manufacturer's
original label and remain closed, except when removing material from the
container. The indoor area used for storage must be secure and not be
located where a release could enter the environment, a sewer system or
cause a hazard to other building activities.
- Compressed gas cylinders should be clearly labeled to identify their
contents and chained or otherwise secured to a fixed object, such as a
wall, to prevent them from falling and releasing their contents.
- The disposal of chemicals or hazardous materials via sinks, drains,
ground disposal or by evaporation is prohibited. Nothing should be
poured down building floor drains or storm drains including, but not
limited to, chemicals, chlorinated water, detergents, glycols, and
- Portable fuel tanks at construction sites must be staged away from
storm drains and any body of water. The tanks should be properly labeled
and have secondary containment to contain any spills or leaks.
UM requires that materials or substances classified as hazardous or
regulated waste be handled carefully and receive proper disposal. Examples
include, but are not limited to: paints, thinners, glues, solvents, gas
cylinders, cathode ray and television tubes, fluorescent or H.I.D. (high
intensity discharge) lamps, lamp ballasts, batteries, ACM, LBP debris,
oils/fuels, freon, glycols, corrosives, and CFCs. Shipments of hazardous
and regulated waste must be processed through DES. Disposal costs for
these materials will be charged back to the project. The University is
only responsible for University generated waste. Hazardous waste generated
by the contractor will be the contractor's responsibility and will not be
processed by the University. Hazardous waste generated by contractors may
not be stored on-site during construction and renovation projects, except
ACM and LBP abatement projects. Storage related to these projects must be
in a secured indoor area in containers or outdoors in a covered roll-off
that are marked with the words Hazardous Waste and a description of the
waste, and the date waste was first placed in the container. All
containers must be in good condition and closed when waste is not being
added to the container.
Spills and Releases:
- Fluorescent lamps and H.I.D. lamps are to be removed from fixtures
with care and placed in special cartons provided by DES. Since these
lamps contain mercury it is important that they are not broken,
releasing toxic mercury dust and vapor into the environment. Coordinate
the removal and disposal of these materials with DES.
- Fluorescent lamp ballasts containing PCBs (polychlorinated
biphenyls) must be removed from fixtures and placed in pails or drums
for disposal by DES.
- Batteries containing heavy metals must not be placed in University
trash containers. DES collects these batteries for proper disposal or
recycling. Batteries used by contractors are the contractor's
responsibility and are to be removed from University premises when
- Asbestos removal from University buildings is considered regulated
waste and is the responsibility of the asbestos abatement contractor to
properly remove and dispose as required by their contract and applicable
regulations. FM and DES coordinate the assessment and removal of
asbestos in existing structures.
- Lead-based paint removed from structures or their components is
considered hazardous waste and must be properly disposed. Coordinate the
disposal process, including manifesting and scheduling of any containers
or roll-off dumpsters with DES (UM's controlled waste vendor requires at
least 3 days advance notice to deliver a roll-off container). DES may
assist in determining if paint or painted material contains lead and if
it requires special handling or disposal as a hazardous waste.
- Tritium gas-containing exit signs, when removed under renovation
work, must be collected and disposed of properly. Contact DES to
evaluate and assist with this process.
Regulatory agencies require containment and remediation of all spills
or releases of hazardous materials, including fuels, oils and anti freeze.
Contractors who spill, or detect a release, of a hazardous material on UM
property must report it immediately to DES or the Campus Police. Clean-up
costs resulting from a spill or release caused by a contractor are the
contractor's responsibility. Depending on the substance and quantity, DES
may notify regulatory agencies. Cleanup and restoration of the
contaminated area must be performed to regulatory and UM acceptable
levels. DES will coordinate analytical testing to determine the extent of
the contamination and the acceptable cleanup level. DES, at its
discretion, may elect to conduct the cleanup and charge associated costs
to the project or allow the contractor to conduct the cleanup based on the
material released and site conditions. If the contractor conducts the
cleanup, proper documentation, including manifests, for the disposal of
the hazardous material, contaminated soil, and any other materials
contaminated during the spill or release must be provided to DES.
Natural Resources Permitting and Compliance Issues:
Natural resources or environmental permits such as those for Sediment
and Erosion Control, Storm Water Management, Forestation, or for work in
Non-tidal Wetlands or within 100-year Floodplains should be obtained prior
to start of construction and should be reflected in the contract documents
of the project. Natural resource permitting may take as long as one year
and must be obtained prior to construction. It remains the responsibility
of UM as the owner to insure that these regulations are complied with. If
a Project Manager or any responsible person connected with the project
observes work that violates environmental regulations, or fails to follow
the contract or applicable permit requirements, this should be brought to
the attention of the Contractor to correct. The deficiency should be noted
in the project's log. If the Contractor fails to comply in a timely
fashion, the incident should be brought to the attention of the Director
of DES for further action.
Fire Protection/Life Safety:
The following fire protection and life safety requirements apply to all
Small Projects - FM routinely conducts "small projects" with the
use of internal and Contractor resources. Small projects involve minor
activities such as the replacement or installation of carpeting, ceiling
tiles, walls, dividers, cubicles, small equipment, etc. FM will assign a
Project Manager who may also be the Site Inspector. For such projects,
Project Managers must:
- Applicable Codes: All work must be performed in accordance with NFPA
1 (National Fire Prevention Code), NFPA 101 Life Safety Code and NFPA
241 (Standard for Construction, Demolition and Alterations).
- Working Plans and Shop Drawings: A set of design drawings approved
by DES must be on site at all times. For small projects, the Project
Manager should contact DES Code Services (301-405-3970) to determine the
need for drawings, plans, approvals and inspections. DES Code Services
will generally provide expedited assistance and have limited
requirements for such projects.
- Fire Alarm Systems: Existing fire alarm systems must remain in
service whenever a building is occupied. Outages in existing fire alarm
systems should be kept to a minimum. All fire alarm system outages shall
be scheduled through UM Operations and Maintenance Life Safety Systems
at 301-405-2222. Once all fire alarm system work is completed, an
acceptance test must be scheduled through Code Services at 301-405-3970.
- Automatic Sprinkler Systems: Existing sprinkler systems must remain
in service whenever the building is occupied. A sprinkler contractor
licensed in the State of Maryland shall perform all modifications and
additions to an existing sprinkler system. All sprinkler system outages
shall be scheduled through UM Operations and Maintenance Life Safety
Systems at 301-405-2222. Once all sprinkler system work is completed, a
hydrostatic test must be scheduled through DES at 301-405-3970. DES
approved shop drawings must be on site at all times for any sprinkler
work performed by a Contractor.
- Corridors/Exits: Corridors, stair enclosures and exits must remain
clear at all times in occupied buildings. Storage is not permitted in
corridors, stair enclosures and exits.
- Gas Cylinders: All compressed gas cylinders must be transported,
used and stored properly. All cylinders (full or empty) must be secured
in place at all times.
- Flammable and Combustible Liquids: Storage of flammable and
combustible liquids must be in accordance with NFPA 30 (Flammable and
Combustible Liquids Code).
- Fire Extinguishers: At least one fire extinguisher must be provided
in plain sight on each floor for each construction area.
- Smoking: Smoking is not permitted in the buildings at any time.
- Final Occupancy: Occupancy is not permitted until a final occupancy
inspection is completed by DES.
Regulatory Requirements and Information
- Obtain the necessary EHS awareness training to be familiar with the
environmental and safety issues involved with the specific project they
intend to manage.
- Contact Code Services (301) 405-3970 to determine the need for
drawings, plans, approvals and inspections; as well as a pre-demolition
hazardous material abatement survey.
- Contact Facilities Management if the project impacts existing building
- If a Contractor will perform all or a portion of the work, ensure the
project contract requires the Contractor to comply with all applicable
federal, State and local environmental and safety regulations and
- Adhere to all fire and life safety guidelines in this document.
- Adhere to all other applicable guidelines in this document based on
the nature and scope of the project.
The EHS regulations that apply to construction and renovation activities on
campus are numerous and constantly undergo modifications and additions by the
regulatory agencies. For projects managed by FM, DES reviews and comments on
draft specifications and design drawings to identify applicable EHS regulatory
requirements and environmental permitting issues. Environmental permitting may
take as long as one year and must be obtained prior to construction. It is
advised that the Natural Resource Permitting Manager and the Environmental
Affairs unit be consulted during the project planning stage to determine
applicable environmental permitting requirements, schedules and fees.
Several sources of regulatory information are available to Project Managers
and Site Inspectors. These include:
Public/Private Partnership Projects
- Several topic specific Fact Sheets prepared by DES that identify
applicable regulatory citations and summarize key requirements. The Fact
Sheets are typically 2 to 3 pages in length and are available at: http://www.des.umd.edu/compliance/factsheet/index.html.
Appendix C is a printout of the web page as of August 2002 and lists the
available Fact Sheets. The Fact Sheets are updated annually.
- Federal OSHA's web site (http://osha.gov/)
also has summaries of individual EHS topics related to construction as well
as online training. Appendix D is a printout of the above-described web page
as of August 2002.
- Maryland OSH also provides regulatory information and provides a listing
of available seminars on its web page, which may be found at:
http://www.dllr.state.md.us/labor/mosh.html. Appendix E is a printout of
the web page as of August 2002.
The University is increasingly developing projects through public/private
Memoranda of Understanding (MOU). The MOU establishes the contractual terms
and conditions for the project and will place responsibility for EHS
compliance on the private developer. Ultimately, the private developer's
contractors and subcontractors will be responsible for the safety of their
employees and compliance with OSHA requirements. DES will support the project
by providing Fire Marshal services. Therefore, they must approve project
design drawings, conduct inspections and perform testing. The Fire
Protection/Life Safety requirements previously described will apply to
public/private partnerships. The developer and its contractors must also
obtain required environmental permits and comply with applicable environmental
regulations and permit requirements. In the event a UM employee observes an
imminent danger as defined in Section II of this document, they should notify
the DES Director and the UM Legal office.
Regulatory Agency Inspections
Contractor sites are subject to inspection by safety and environmental
regulatory agencies for compliance with applicable regulations and permit
conditions. In all cases, the contractor should immediately inform the Project
Manager if a regulatory agency conducts a site visit; provide the results of
the inspection and the schedule of corrective actions the contractor will take
to remedy deficiencies, as applicable. In the event of an environmental
regulatory inspection, the Project Manager should notify the Manager of
Natural Resource Permitting (301-405-3462) regarding the conduct of natural
resource inspections (i.e. sediment/erosion control, wetlands, forestation,
floodplains); the DES Environmental Compliance Manager (301-405-3163)
regarding the conduct of other environmental inspections (i.e. stormwater
discharges, regulated and hazardous waste, air quality, spill/releases); and
the Assistant Director of Occupational Safety and Health (301-405-3965) for
safety related inspections (MOSH/OSHA).
Construction sites are also subject to fire protection and life safety
inspections by the DES Fire Marshals. The Fire Marshal should notify the UM
Project Manager of any significant deficiencies observed during inspections
Public/private developments are subject to the terms of the MOU. The Fire
Marshal will directly notify the developer and contractor of any deficiencies
identified during inspection and testing activities. The contractor should
immediately notify the DES Environmental Compliance Manager (301-405-3163) of
any identified environmental deficiency that may impact the campus environment
including air, water or soil; or the off campus environment through air
dispersion, surface or subsurface migration or campus utilities.
DES SUBJECT SPECIFIC CONTACTS
DES ENVIRONMENTAL HEALTH AND SAFETY FACT SHEETS
FEDERAL OSHA WEB PAGE
MARYLAND OSHA WEBPAGE