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Project Manager Safety Guide


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.

inspector1. 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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