Nevin E. Thomas, CIH, CSP
Bechtel National, Inc.

The Formerly Utilized Sites Remedial Action Program (FUSRAP) has successfully implemented an Environmental, Safety, and Health program in compliance with 29 CFR 1926, "Occupational Safety and Health Administration Safety and Health Regulations for Construction," and other applicable federal regulations and the Bechtel Corporation "Zero Accident Performance" program. The FUSRAP Environmental, Safety, and Health program maintains protection of the safety and health of workers, the public, and the environment; provides a balance between costs and benefits; is reasonably tailored to the work to be performed; and is feasible and defensible.

FUSRAP safety success is directly attributable to employee involvement in the safety process from work planning through demobilization. As a result, the program has worked more than 2 years-more than 1 million jobhours-without a lost-time injury. The tools used to maintain this safety record include use of a task hazard analysis to ensure that the specific hazards of all work activities are evaluated and that training and safety measures are implemented before the work begins. This paper also discusses scope of work, preplanning safety controls, input from workers, and briefings conducted before work begins.

The Formerly Utilized Sites Remedial Action Program (FUSRAP) was previously administered by the U.S. Department of Energy but was recently transferred to the U.S. Army Corps of Engineers (USACE). Remediation work at FUSRAP sites is conducted by the project management contractor, Bechtel National, Inc. (BNI). FUSRAP has been highly successful in conducting hazardous waste work safely: the program has worked more than 2 years without a lost-time injury. This record is the result of a combination of efforts, including the Bechtel "Zero Tolerance for Accidents Program," which has successfully reduced accidents during the last 5 years. The initiatives of this program include incorporating safety into the work planning process, conducting a hazard analysis before work begins, and encouraging worker involvement in the work planning process. In addition, hazard recognition training is provided to help in identifying and eliminating hazards.

Safe operations are the primary element of the zero accident process and require regular safety performance reports to senior managers, including the company president (Attachment A). If incidents occur, reports of the incidents begin at the site, go to the Program Manager, and are directed to the senior managers. This visibility and reporting requirement develop ownership and accountability for the Environment, Safety, and Health Program. In fact, the BNI president begins staff meetings with a briefing on the safety performance of the various operating groups. If an operating group's safety performance does not meet the BNI safety performance standards, high-level safety audits and surveillances are required that include corrective actions by the operating group. Safety performance is an important factor in the determination of individual annual performance awards. Failure to implement the BNI basic safety program on a project is not tolerated.

The first step in achieving any goal, whether it is a safety performance standard or a business objective, is developing a plan to reach that goal. Then we need to continually review the plan in relation to the goal. The review should tell us whether the goal is realistic or requires modifications. The Bechtel policy states that "Bechtel is dedicated to the concept that all accidents are preventable," and the objective of the safety program is to promote safety as the first priority in designing, planning, training, and executing work. The scope for each task is evaluated before work begins so that potential hazards can be identified and safety measures can be planned and implemented. For example, fall protection needs to be an integral part of the design of a system with elevations. Each hazard identified in the design and planning stage must be addressed to achieve zero accidents, and ownership of the safety program needs to be spread throughout the organization for implementation to be successful.

Hazard recognition by work crews is an important method of spreading ownership of safety and health programs. FUSRAP supervisors are encouraged to draw upon the knowledge and experience of employees. Workers generally have good knowledge of what the hazards are as well as ways to reduce and eliminate the hazards. They also can provide ideas for improving the work process. Bechtel workers are encouraged to question work processes and seek better and safer ways of working.

It is a FUSRAP requirement that employees must be provided safety and health indoctrination and continuing safety and health training to enable them to perform their work safely. Additional training requirements are specified in the hazardous waste operations and emergency response (HAZWOPER) regulations, which apply to all FUSRAP work. To meet these requirements and promote safe work practices, all site workers are required to receive 40-hour HAZWOPER training away from the work site before they are assigned to work. Two other regulatory training requirements that reinforce safety awareness are site-specific briefings and annual 8-hour refreshers. The site-specific briefings also provide an excellent forum for drawing on workers' knowledge by soliciting their input into the hazard recognition process. It is well understood that training is more effective when there is two-way communication. Encouraging worker input to hazard evaluation and control provides this opportunity and leads to a clearer understanding of each requirement. When workers are involved in the process of hazard identification and control, there is more opportunity for worker buy-in to the process and the regulatory requirements to complete the assigned work in a safe manner.

As reported in the November issue of Occupational Health and Safety, increasing workforce diversity requires extra confirmation that workers understand work processes and procedures and safety requirements. Because of cultural and other differences, a simple "yes" or "no" response from a worker may not indicate sufficient understanding of safety guidelines. For example, during hazardous waste work, an employee's "yes" response to directions for using a protective method or equipment may indicate only hearing and not understanding; in this case, occupational injury or illness is likely to result.

Although considerable FUSRAP cleanup work is conducted by subcontractors, the prime contractor is evaluated by clients and senior management for the total safety performance. Additionally, the Occupational Safety and Health Administration (OSHA) holds the prime contractor responsible for safety compliance on its projects. This is also consistent with the USACE safety and health manual requirements in Section 28.B.01(d): "the prime contractor shall integrate all subcontractor work activities into the site specific safety and health plans." Therefore, to ensure that subcontractors meet regulatory requirements and Bechtel safety standards, each subcontract incorporates the zero tolerance philosophy for accidents program guidance. Each subcontract clause is evaluated to make sure that the safety expectations are enumerated explicitly before the bidding process begins. These requirements and expectations are reemphasized at prebid meetings.

Before work begins, the selected subcontractor is required to provide the contractually specified documentation to meet regulatory requirements. A check-off matrix is used to show that the contract requirements are covered, and the matrix is evaluated in relation to both the USACE manual and the OSHA regulations. The prime contractor maintains a file of this activity to ensure compliance. To verify continuing compliance, regular field safety and health audits and surveillances of subcontractors are conducted. The standards for these surveillances are the contract requirements, and the surveillances are carried out as regulatory compliance audits. To assist in audits and to document compliance, subcontractors maintain hard copies of all employees' medical and training records.

While work is progressing, it is important to evaluate and report the safety performance of the project. In addition to being a requirement of the prime contract, safety reporting is an element of the zero accidents program and must include the subcontractor's safety performance. This information is evaluated by BNI senior project management to determine whether accident trends are developing. For example, the number and types of first aid cases recorded in the first aid log can provide an early indication of trends that need to be addressed and can also help in evaluating the use of personal protective equipmentCe.g., minor finger cuts and scrapes may indicate that effective hand protection is not being used.

If incidents occur, a mechanism must be in place for recording them immediately and communicating the information to management. One viable means is a field injury report that is faxed to BNI senior management (Attachment B). Final reports of the incident should follow within 24 hours and should include plans for corrective action to prevent future occurrences and a schedule for implementing the corrective action. The report should be signed by the manager in charge of the operations where the incident occurred to ensure that the corrective action will be completed. Information on the incident should also be captured for training sessions and used as a lesson learned.

If an incident results in worker injury that requires medical attention, treatment of the worker has the highest priority. An injured worker should be accompanied to the physician's office. Physicians who treat injured workers should be informed of job descriptions and physical demands of the job, and they should be given an opportunity to visit the workplace. This information will help the physicians to return workers to full work duty.

Bureau of Labor Statistics Recordkeeping Guidelines for Occupational Injury and Illness (1986) must be followed to determine whether an incident is recordable. Even if an injury is covered by workers' compensation, it is not necessarily OSHA recordable. For example, workers injured in the workplace parking lot before or after work are usually eligible for workers' compensation, but such incidents are usually not OSHA recordable (though some of them may be). Also, many injuries treated by doctors are first aid cases and need not be recorded in the OSHA log. For example, application of antiseptics during a first visit, application of bandages during any visit, and removal of foreign bodies that are not imbedded in an eye or part of a wound complication are considered first aid procedures and are not recordable.

The attainment of zero accidents in the workplace requires a commitment by both management and workers and empowerment of workers to achieve that goal. The work scope of every task must be thoroughly reviewed to identify potential hazards and plan safety measures into work processes. A hazard analysis must be conducted and must incorporate input from workers, and a briefing must be conducted before work begins to ensure that workers are aware of potential hazards and understand the necessary safety precautions.

Another critical component of the zero accidents program is the regular reporting of safety successes and the analysis and correction of any safety failures. Annual performance reviews of responsible managers include a review of safety records and offer rewards for zero accident achievement. Also, subcontractors who are awarded contracts must be committed to a policy of zero tolerance for accidents, and regular audits and surveillances of subcontractor operations are conducted to ensure that contract requirements are met and safety standards are upheld.

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