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5. Health and safety contamination procedures
5.1 Overview
This CDWP provides procedures for site personnel working in and around contaminated and/or potentially contaminated soil and water during the excavation works. The following is designed to dovetail with the Construction Health and Safety Management Plan.
The procedures have been developed to provide a framework for managing contamination related effects at the site. However, these procedures are not intended to relieve the owner or controller of the place of work of either their responsibility for the health and safety of their workers, contractors and the public, or their responsibility for the protection of the environment.
All parties working on the Karangahape Station main works shall comply with:
Applicable parts of the Link Alliance Health and Safety Policy; Construction Health and Safety Management Plan; Any requirements of WorkSafe New Zealand; The Health and Safety at Work Act 2016 and Regulations; and Any other applicable legislation, regulations, codes and guidelines.
Sub-contractors engaged on the Karangahape Station main works area are required to provide their own Health and Safety Plan for their equipment and workers.
Daily toolbox meetings are to be undertaken and documented.
5.2 General safety requirements and training
All relevant personnel shall be required to participate in a site induction that includes a review of procedures with respect to contamination. The induction shall be provided such that all relevant personnel understand, prior to commencing work, what procedures are to be implemented and why. The purpose of the induction is to educate the workers with respect to the hazards associated with contaminated soil and water, safe working procedures, safety equipment and requirements, and the response plan in the event of an emergency.
An appropriately qualified Health and Safety Officer (HSO), or similar, shall be appointed for the duration of the works so that where contamination is being managed, there is a designated person responsible for the implementation of and adherence to contamination related health and safety procedures, in addition to the other site specific health and safety requirements.
The HSO shall ensure that all relevant personnel are familiar with the application and use of required PPE and procedures specified in this CDWP and other site specific documentation prior to the commencement of work.
The following general safety procedures shall be followed by all personnel entering and/or working in the construction zone:
Hazards encountered and not identified during the site induction/toolbox shall be reported to the designated HSO; Any incidents shall be reported to the HSO;
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Site personnel shall avoid unnecessary contact with documented and potentially contaminated soil and groundwater; and Site personnel who may come into contact with contaminated soil shall be provided with the minimum level of PPE as defined in Section 5.7 of this CDWP.
5.3 Control measures
When considering hazard and risk controls, the hierarchy listed below will be followed, in preference from one to five. Example questions are provided to illustrate each step.
1. 2. 3. 4.
5. ELIMINATION –does the task that creates the hazard need to be performed? SUBSTITUTION –can a different tool be used? ENGINEERING –can the hazard be guarded to protect people? ADMINISTRATION –are there warning signs and a procedure to address the hazard? Administrative controls include procedures to reduce the risks associated with identified hazards. These controls include: a. Job Safety Analysis (JSA) or Task Analysis. b. Work plans. c. Training. d. Warning signs. e. Communication with the Site Manager/HSO. PERSONAL PROTECTIVE EQUIPMENT –is the appropriate PPE being used? The following is noted. a. PPE is considered the lowest level of protection against a hazard. b. No single combination of protective equipment and clothing can provide protection against all hazards; PPE should be used in conjunction with other protective methods. c. The types of PPE will depend on the specific task undertaken. However, certain PPE is required in all work areas.
5.4 Identification of hazards
This CDWP identifies potential hazards associated with the presence of soil and groundwater contamination and recommends procedures to mitigate these risks. Contamination investigations indicate low level contamination within fill material and groundwater (refer Section 3). The fill material contamination includes metals/metalloids and hydrocarbons, and groundwater was found to exceed consented discharge criteria for some metals/metalloids.
Potential exposure routes for contaminants include:
Inhalation of dust (potentially contaminated and uncontaminated); Ingestion of potentially contaminated soil, dust or groundwater; Dermal absorption of potentially contaminated soil or dust; and Skin and eye contact with potentially contaminated soil or dust.
Recommended procedures to mitigate the risk associated with these hazards are provided in Section 5.6.
5.5 Identification of new hazards
There is the potential for additional hazards to be identified and encountered during the Karangahape Station main works. The HSO is responsible for reviewing any new work element and assessing whether there are any new associated hazards and associated elimination, isolation and
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minimisation measures. The HSO shall seek review by the CLS if necessary. The HSO shall then instruct all personnel on the health and safety procedures associated with the new hazard.
5.6 Hazard mitigation procedures
5.6.1. Dust inhalation
Inhalation of dust (whether it is contaminated or not) can pose a health risk and therefore the dust control measures shall be implemented for the duration of the earthworks as outlined in Section 4.7 of this CDWP. The following additional measures shall be considered to minimise inhalation of dust:
Monitor wind speed and direction, and where practicable, stand up wind of excavations and vehicle loading areas; Water spray via localised points; and Boot wash available for personnel leaving excavation areas to prevent the tracking of soil around and off-site.
Additional controls may be required if asbestos in soils is detected as part of any additional testing or if unexpected contamination is encountered. The controls to be implemented are outlined in Section 6.1.1 and may include the use of a polymer spray in addition to water to manage dust and additional PPE (i.e. disposable coveralls, and respiratory protective equipment).
5.6.2. Vapour and gas inhalation
The investigations to date indicate there is a low potential for the presence of volatile contaminants or gases that are likely to represent a human health risk with respect to the inhalation exposure route. However, mitigation of vapour or risk can be achieved as follows:
If there are olfactory indications for vapours, or vapours are suspected, the volatile organic compound (VOC) content of the area shall be checked with a calibrated photo-ionisation detector (PID) with a 10.6 electron volt (eV) lamp. If readings are above 50 ppm, work shall stop, the area vacated and the CLS and/or HSO shall be informed. A respirator shall be worn when re-entering the area to re-test the atmosphere;
At the same time, and if an area or excavation is to be accessed with limited air flow (i.e.
excavations below existing floor slabs) air quality shall be monitored prior to entry using a calibrated gas meter(s) able to measure lower explosive limit (LEL), oxygen (O 2 ), methane (CH 4 ), carbon monoxide (CO) and hydrogen sulphide (H 2 S); and Work shall not resume unless approved by the HSO in consultation with the CLS.
5.6.3. Dermal contact and ingestion
The following precautionary measures shall be implemented to ensure skin contact with, and ingestion of, contaminants is minimised:
Disposable gloves shall be worn by personnel who need to have contact with contaminated soil during the excavation works. Consideration shall be given to the requirement for tear resistant gloves; Overalls shall be worn if there is the potential for contaminated soil to contact other parts of the body (legs, arms etc.); Boot covers shall be worn by personnel who need to traverse contaminated soils during excavation works or washable boots worn with a boot wash in place and utilised; and
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There shall be no eating, drinking or smoking in the works area to prevent contaminated soil contacting food or being ingested directly via soiled hands.
A key factor in controlling dermal contact and ingestion of contaminated soil is through maintaining good personal hygiene. The following shall be observed for works involving contaminated soils:
Hand to mouth and hand to face contact shall be avoided during work; Hands shall be washed before eating, drinking and smoking; Eating, drinking and smoking shall only be permitted in designated areas; Overalls worn within the works area shall be removed before leaving the works area; and Disposable coveralls may be worn and disposed of at the end of each working day.
5.7 Personal protective equipment
All workers handling or coming into contact with contaminated or potentially contaminated soil shall wear the following PPE to protect against the above risks:
Overalls or disposable coveralls; and Impermeable gloves (tear resistant if appropriate).
Additional PPE (refer PPE and minimum respiratory protective equipment in Section 6.1.1) may be required if asbestos in soil is detected as part of any additional testing or if unexpected contamination is encountered. Such controls include the use of disposable coveralls (rated type 5, category 3), disposable overshoes (or similar) and specific respiratory protective equipment depending on the type and concentration of asbestos present (as a minimum disposable P2 dust mask shall be available on site). Changes to site specific PPE requirements shall be reflected in all health and safety documentation and all parties notified. The PPE specified above is in addition to that required for non-contamination related health and safety.
5.8 Communication plan
Details of communication and consultation procedures are set out within Sections 6.5 and 7 of the Karangahape Main Works Communication and Consultation Plan (CCP). The CCP outlines the way in which the general public are to be communicated with on CRL project matters, including the management of the adverse effects relating to the contamination and the process for public and affected parties to register a complaint.
5.9 Incident reporting
Procedures relating to environmental emergencies and incidents are detailed within the CEMP. The CEMP should be referenced for further information on environmental incidents including spill response, incident recording and reporting.
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