Date Established: 7/1/2009
Date Last Updated: 4/6/2015
Category: Environmental, Health and Safety
Environment, Health and Safety
Associate Vice President for Facilities
The University at Buffalo (UB, university) recognizes that many hazards are inherent in construction and other contract work. Compliance with safety regulations can prevent virtually all serious injuries. This guide serves as notification of campus safety requirements to contractors, including subcontractors, who perform work at UB and any other facilitiesoperated by the university. Contractors should not assume that this guide covers all applicable safety and health laws, as it does not. Instead, it provides contractors with sitespecific health, safety, and environmental rules and policies that the university expects will be followed on all university property. The rules, regulations and guidance contained herein represent program areas that have been problematic in the past or require special care and consideration due to the nature of the working environment at the university.
Additionally, contractors are required to follow applicable federal, state, and local safety and health regulations.
This policy shall apply to all contract and contractor personnel performing work on University at Buffalo property regardless of the manner in which the contracts were let. Typically, contracts are let by the SUCF, DASNY, and University at Buffalo Facilities for work on the North, South, Downtown campuses along with other non-traditional off campus properties such as RIA at 1021 Main St and the Anderson Gallery.
Person assigned by FP&D or DASNY to manage activities relating to a project.
Contractors should obtain the latest revision of this document with their bid submission and ensure that their field supervisors have a copy available at their worksite or job trailer. EH&S intends to update or amend this guide annually.
The contractor is responsible and accountable for the safety of their employees. However, the University reserves the right to order the contractor to stop work any time the following conditions exist.
Contractors must abide by all alarms and evacuation procedures as established by UB. This information must be included in the contractor’s emergency plan and training. The contractor shall have pre-planned emergency evacuation areas for all worksites and all personnel shall be directed to check into this area in the event of an emergency. Personnel accountability is critical to emergency responders. Contractor personnel shall call UB Police to report any of the following:
Contractor personnel should program the University Police number into their cell phones to ensure prompt reporting of emergencies.
Lost time injuries sustained by employees of a general contractor or its sub-contractors shall be reported to UB Environment, Health and Safety as soon as possible. Additionally, within 72 hours of an incident, the contractor shall furnish EH&S with a copy of any accident/incident reports. Such reports must include a medical description of the injury (if applicable) and action taken to prevent recurrence. Personal information covered by HIPA should be redacted.
The contractor shall ensure that their employees and sub-contractor employees conduct themselves in a proper manner while on the university campus. Gestures, remarks, cat calls, whistling, or anything of a derogatory nature will not be tolerated. The University makes every effort to remove personnel engaging in these activities.
Safety Data Sheets (formerly material safety data sheets or MSDS) for all material used on the project must be submitted to EH&S for review prior to the start of the project. Products containing carcinogens, asbestos and lead are not allowed onsite without prior approval from EH&S.
The contractor shall maintain copies of all material safety data sheets on site for review by their employees, the University, regulators, and emergency services personnel.
The contractor shall endeavor to keep the work area as quiet as possible when the work is in proximity to buildings with classrooms. If heavy machinery, powder activated tools, screw guns, or other such devices must be used to accomplish the work, the contractor shall notify the UB project manager (UB PM) and advise him/her of the type of equipment to be used and the duration of the work. At times it will become necessary for the contractor to stop work immediately when advised by the UB PM or EH&S that the work is adversely affecting classrooms activities.
Contractors shall plan work in conjunction with their UB PM to minimize the effects of fugitive emissions, dust, welding fumes, VOC vapors, and other emissions which can adversely affect the University community. In particular, the following methods are considered good practice:
Visible dust clouds from masonry cutting operations are strictly prohibited. All cutting shall be performed in a manner that minimized silica and dust exposure to contractor employees and the campus community. Water suppression and vacuums with HEPA filters shall be used for all operations. Extra care is needed when working near building air intakes to ensure that dust does not contaminate the building HVAC system.
UB expects contractors to be in full compliance with OSHA’s Silica rule by June 23, 2017.
Operation of fossil-fueled combustion equipment within or adjacent to openings and intakes at University buildings is strictly prohibited without necessary controls and approvals. Equipment that requires special work planning includes, but is not limited to, Bobcat-type loaders, Target and K12 saws, powered augers, portable and trailer mounted generators and compressors.
The following rules apply:
When setting up this type of equipment outdoors, consideration must be given for wind direction and infiltration into potentially occupied spaces.
All required personal protective equipment (PPE) shall be provided by the contractor. Its use is mandatory and enforcement is the responsibility of the contractor. The contractor’s supervisor shall ensure that their employees wear appropriate clothing that would provide adequate protection from normal hazards associated with the job. Examples of PPE are head, eye, hearing, hand, respiratory and fall protection equipment. All PPE used must meet appropriate ANSI standards.
Electricians are expected to be in compliance with NFPA 70E-2015. Proper use of Arc-rated clothing that meets Arc Flash PPE category will be strictly enforced.
The specific standards for working in underground or enclosed spaces are specified in OSHA 1926.268-Telecommunications and 1926.269-Electric power generation, transmission and distribution.
UB has these spaces on all of its campuses. Many spaces have combined communications and power that may require workers to be trained to handle the greater hazard. In all cases, the following requirements shall be followed in addition to those specified in 1926.26x.
UB follows the OSHA 1926.500 standard for fall protection with some exceptions where local standards are more stringent than Federal Law.
Whenever work surfaces are 6’ or greater above a lower surface, some means of fall protection is mandatory. Fall protection may take the form of guardrails, railings, scaffolds, safety nets or safety lines. In most cases, engineering controls are preferred to active fall restraint.
Contractors are tasked with the proper handling and disposal of universal waste and hazardous materials used on their projects. In all cases, materials transported for disposal shall have manifests signed by DOT trained EH&S personnel.
There are three general classes of these materials and each has a different disposal path.
Asbestos-containing materials (ACM) are present on both the North and South campuses of UB. The UB PM is responsible for notifying the contractor of the presence of known ACM. All handling of ACM must be by NYS licensed asbestos handle rs under the direct and continuous site supervision of a NYS licensed Asbestos Supervisor.
If job conditions change such that presumed asbestos containing materials (PACM) are discovered on the job site, the area in question shall be secured, the job stopped, and the UB PM notified along with EH&S Asbestos Program Coordinator.
Working around friable ACM may cause problems due to vibration from tools, and air movement from air-cooled tools or ventilation. Job site supervisors should work with their University PM to conduct a 360° inspection of each such site to ensure minimal impact outside of the immediate work area. Spaces above and below the work area may be as problematic as those on the same floor. Discovering potential areas of asbestos disturbance prior to a job may save many days or weeks of downtime due to accidental and unintended releases of asbestos fibers.
Prior to the start of work, the University attempts to discover the locations and concentrations of lead in order provide contractors with the best information possible to protect their employees. Despite this, lead is routinely discovered during construction activities.
Lead is much less regulated but still potentially hazardous. If quantities of lead are discovered, please notify the UB PM for safe handling, removal, or disposal instructions. The primary expected locations of lead are for X-Ray room shielding, surface coatings on steel, high voltage electrical cable sheathing, and lead anchors. Lead must not be thrown in the regular trash.
All work zones in roadways and rights-of-way must be properly laid out in accordance with the UB Work Zone Policy, SA-026-A. This is available on the web at ehs.buffalo.edu or by calling EH&S. The policy is based on the Cornell Local Roads Program.
All personnel working on roadways, adjacent to roadways, in a right-of-way, in a parking lot, or a temporary access way for vehicular traffic shall wear high visibility clothing that meets the current MUTCD requirements.
The most common problems encountered with roadway work zone safety are:
Additionally, some work on campus may actually be on a State road in the right-of-way. Millersport Highway on the North Campus along with its cross streets and access roads fall into this category. Work on these portions of roadway/rights-of-way requires a highway work permit from State DOT. UB does not issue these permits.
Where powder actuated tools such as Hitli™ guns, or tools that can cause flying debris are used (jackhammers or cutoff saws) in public access areas such as roadways, hallways, or sidewalks, temporary barricades shall be erected to protect the University community and the public. When welding and cutting is performed in areas that present a danger to the general public, welding curtains will be deployed.
Maintaining site safety during off times is very important. Locks, fencing, barricades, and other means shall be deployed to ensure that campus community is not at risk from contractor work areas. One frequent concern is fencing construction as we find many fences that do no survive normal winds on campus.
Contractor activities that reduce campus walkway lighting levels will result in a less secure environment for the campus community. The contractor must work with the UB PM toensure that alternate lighting is provided.
Contractors shall notify EH&S any time radioactive materials are brought onto campus. These materials are typically used in instruments that gauge thickness, test for lead, and X-ray welds. The contractor’s Radiation Safety Officer (RSO) should contact Jeffery Slawson, CHP, the UB RSO with the proposed dates and times of material usage along with the areas or buildings in which the device(s) will be used.
Subcontractors are frequently the entities that use radioactive materials in a testing capacity. It will be the GC’s responsibility to ensure that UB is properly notified by the RSO in charge of the material.
Section 12 of the SUCF document “Management of Construction Projects” mandates a pre-construction orientation meeting. This meeting will contain safety orientation for each contractor who works at the University. Specific safety information contained herein will be presented and discussed.
|Revision||Section(s) Changed ||Change(s) Made ||Date|
|00||All||Original document created||7/1/09|
|01||Dig Safely New York, Excavation and Trenching, Lead ||Minor procedural modifications||6/18/12 |
|02||Emergencies, Alarms and Police Notifications, Document Revision History ||Changed EH&S phone number||6/5/13|
|03||Air Quality — Masonry Operations ||Masonry dust||4/6/15|
|03||Air Quality — Carbon Monoxide (CO) ||CO||4/6/15|
|03||Personal Protective Equipment (PPE)||PPE for electrical work||4/6/15|
|03||Electrical Safety/Lockout-Tagout (LOTO) — All portable power tools ||GFCI requipred for all portable tools||4/6/15|
|04||All||Reformatted for web||1/2018|
|Dig Safely New York ||811|
|Environment, Health and Safety||716-829-3301|
|Planning, Designing and Construction ||716-645-2612|
|Facilities Customer Service||716-645-2025|