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SECTION 1: Introduction
| Notice: Training materials found on these pages
are provided for the use of Princeton University faculty, staff
and students to meet training needs specific to Princeton University. |
Introduction (top)
The purpose of this guide is to provide Project Managers with an
overview of environmental, health and safety issues as they relate
to the organization and management of construction and renovation
projects performed by outside contractors and university personnel.
Project Managers are not expected to be health and safety experts,
nor are they expected to conduct thorough worksite safety inspections.
However, a basic appreciation of the safety and regulatory issues
most frequently encountered in construction and renovation projects
will help to ensure a safe work environment for University employees
and contractors and minimize
potential liability exposures.
Responsibility for Safety (top)
Department chairs, heads of offices, directors of programs, laboratory
directors, principal investigators, managers, supervisors, foremen,
etc. all share responsibility for the health and safety of individuals
engaged in
activities under their direction or supervision. They must ensure that the
activities of these individuals comply with all relevant regulations and
accepted standards and that work activities are performed in a safe and
considerate manner.
Each employee is responsible for complying with the applicable
provisions of environmental, health, and safety standards and regulations.
They also must adhere to all University and departmental
or office safety policies and procedures and comply with safety directives
issued by their individual supervisors.
Resources (top)
There are several resources available to provide information, consultation
and other services, as needed. The following departments or individuals
have particular expertise in health and safety-related issues:
Environmental Health and Safety
The Office of Environmental Health and Safety (EHS) serves the University
community by providing technical support, information and training,
consultation, and periodic audits of health and safety practices and
regulatory compliance. The EHS staff comprises University employees,
working in a coordinated effort to address environmental, health, and
safety issues in four broad areas: workplace safety, industrial hygiene,
radiation safety, and biosafety and sanitation. A great deal of information
is available on the EHS web site.
Risk Management
The Risk Management Office works with University counsel and the
Facilities business office on matters of insurance coverage and contracts
for outside services.
Manager of Environmental Compliance
The Manager of Environmental Compliance is located in the Facilities-Engineering
Department. For the purposes of this handbook, he is concerned
with large-scale renovations involving disturbance of asbestos
containing materials, underground storage tanks, spills or releases
of hazardous
materials into soil or groundwater, and any environmental engineering concerns,
including installation of backflow preventers on water supply connections.
Manager of Special Facilities
The Manager of Special Facilities is part of Grounds and Buildings
Maintenance. He is responsible for oversight of Special Facilities
maintenance personnel in the science and engineering departments.
Manager of Alarms/Mechanical Trades
The Manager of Alarms/Mechanical Trades is part of
Grounds and Buildings Maintenance. He coordinates asbestos abatement
activities as they relate to maintenance projects.
University Fire Marshal
The University Fire Marshal is part of the Department of Public Safety.
He is concerned with issues related to fire and life safety, and acts
as liaison with local fire officials. He has also established procedures
for maintaining fire safety during projects that require silencing of
fire alarms or detection.
Departmental Safety Managers
Many University departments have appointed a Departmental Safety
Manager to act as a liaison between the department and EHS. In most
academic departments, the Department Manager has taken on this role.
Individuals may contact the Department Manager or their supervisor
to determine who acts in this role in their department.
The Departmental Safety Manager has responsibility for oversight
of health and safety within the department and is a principal contact
for faculty, staff and students to address health and safety issues
or concerns. The Departmental Safety Manager works with faculty,
management and supervisory personnel in the department to identify
potential hazards associated with their operations and activities.
The main objective is to . clearly identify and understand safety responsibilities,
while providing the means and authority necessary to carry out
those responsibilities.
Introduction to OSHA (top)
Construction and renovation activities at the University can be
performed by either outside contractors or University workers. The
work may be done exclusively by one group or the other,
or a project may be a collaborative effort. Because of these differing arrangements,
it often is unclear who has the responsibility and authority to ensure
that safety and health regulations are followed. The Occupational
Safety and Health Administration (OSHA) has addressed this issue by developing
rules for multi-employer worksites and defining the responsibility
of each employer.
Most of OSHA's regulations for construction work can be found in
Title 29 of the Code of Federal Regulation (CFR), Part 1926, entitled "Safety
and Health Regulations for Construction." However,
there are several instances where a particular job or activity may not be
addressed by these regulations. In those cases, the regulations for
General Industry, found in Part 1910, may apply. If there are no
regulations in either Part for a given activity, then OSHA's "General
Duty Clause", which states
that an employer must provide a workplace free of recognized hazards, would
still be applicable.
Multi-Employer Worksites
OSHA has determined that employers at a multi-employer worksite
fall into four basic categories--controlling, creating, correcting,
or exposing. The controlling employer is the employer
who, by contract or actual practice, has the responsibility and authority
for ensuring that hazardous work conditions are corrected. This employer
is usually the General Contractor, or GC. When the University acts
as the General Contractor for a construction project, it would be considered
the controlling employer and would be responsible for the safety
and health of all workers at the site.
The creating employer is the employer whose activities actually
create a hazardous condition, while the correcting employer is the
employer that has the responsibility for correcting
the hazardous condition. An exposing employer is any employer whose workers
are exposed to the hazardous condition. Depending upon the situation,
any employer at a construction site could fall into one or more of
these classifications and could be issued a citation by OSHA.
Departments should consider the multi-employer worksite rule whenever
their workers are working at a University construction site, or whenever
they are acting as the project manager for such an activity. In those
situations where the University acts as the General Contractor, the
burden for
providing a safe worksite rests with the project manager and every
University supervisor involved with the project. However, even on
those projects where an outside contractor is acting as the General
Contractor, Departments are still responsible for their own workers'
safety. Any hazardous condition should be brought to the attention
of the General Contractor immediately, through the project manager,
along with a request for its correction. If the condition is so
hazardous as to be imminently dangerous, Departments should remove
their workers
from the worksite and contact Environmental Health and Safety (EHS)
immediately.
If a Compliance Officer Shows Up at Your Doorstep
If a Compliance Officer from any regulatory agency (e.g., OSHA,
EPA, DEP)
contacts anyone via phone, mail, or in person, contact EHS at 258-5294.
EHS will assist the department in determining what steps, if any, need
to be
taken.
While the following example focuses on procedures to follow if
an OSHA Compliance Officer arrives at your department to conduct
an inspection, most
of these steps
could be used for other compliance visits as well.
 1. Ask the Compliance Officer for credentials – a
badge or identification card specifying that the person is an
agent of OSHA.
2. Ask whether the Compliance Officer has a warrant for the inspection.
Do not demand a warrant; simply inquire whether or not one exists.
3. Before an inspection, the Compliance Officer will conduct an
opening conference, during which the Compliance Officer explains
why he or she is there and what he or she wishes
to do. Ask the Compliance Officer to wait while you assemble the appropriate
people for the opening conference.
4. Contact EHS to inform them about the arrival of the Compliance
Officer. Do not begin the opening conference without a representative
from EHS present.
5. After the opening conference, the Compliance
Officer will conduct a walk-around inspection. EHS and department
representatives
must accompany the Compliance Officer during the inspection. If
affected employees in the department are represented by a union,
ask employees to designate
a union
representative to be present during the inspection.
6. After the inspection, department representatives and EHS will
meet to discuss the outcome and plan for
action, as needed.
7. If a notice of violation is received, copies must be provided
to EHS and the Office of General Counsel.
The violation must also be posted in the area of the offense for at least
three days.
8. Any fines issued by OSHA are the responsibility of the department.
Consult with EHS and the Office of
General Counsel before paying fines.
In order to have the most “effective” inspection, the
following suggestions should be considered:
1. Answer any questions truthfully, without directly admitting
guilt. Never knowingly give false statements or
intentionally mislead a Compliance Officer. If you do not know the answer
to a question, explain that you
are not certain and that you will look into the matter further, as necessary.
2. Do not offer information unless asked for it. Do not talk about
accidents or incidents that have occurred in
the past unless specifically asked to do so.
3. Be courteous. Do not be rude to the Compliance Officer or argue
with him or her.
4. Do not discuss political views regarding OSHA or the federal government.
For more information about OSHA,
see Section F1 of the Princeton
University Health and Safety
Guide.
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