HomeMy WebLinkAboutADMINISTRATION ACTION SUMMARY 05-13-14i s gill
SPECIAL OF
CENTRAL CONTRA
SANITARY DISTRICT
02AR 1 1,
ACTION SUMMARY
Chair McGill
Member Williams
Tuesday, May 13, 2014
8:00 a.m.
Executive Conference Room
5019 Imhoff Place
Martinez, California
BOARD OF DIRECTORS:
DAVID R. WILLIAMS
President
MICHAEL R. MCGILL
President Pro Tem
PAUL H CAUSEY
JAMES A. NEJEDLY
TAD J PILF,CKI
PHONE: (925) 228 -9500
FAX- (925) 372 -0192
www.centralsan.org
PRESENT: Chair Mike McGill, Member David Williams, General Manager Roger
Bailey, Director of Administration David Heath, Secretary of the District Elaine Boehme
(left after Item 3.), Communication Services Manager Michael Scahill, Human
Resources Manager Teji O'Malley (absent during Item 8.), Human Resources Analyst
Twila Mullenix (absent during Item 8.), Assistant to the Secretary of the District
Donna Anderson, Senior Principal of Consultants to Management, Inc. Larry Bienati,
Ph.D. (for Item 8.)
1. Call Meeting to Order
Chair McGill called the meeting to order at 8:12 a.m.
2. Public Comments
None.
3. Consider proposed changes to California Association of Sanitation Agencies
(CASA) Bylaws
Member Williams discussed the proposed changes to the bylaws, which are
necessary because of significant changes at CASA over the past year Most of
the changes remove inconsistencies, but one major change would set new three -
year term limits for the 12 elected Board members. This would mean that
Administration Committee Action Summary
May 13, 2014
Page 2
roughly one -third of the Board will be replaced each year, which should
encourage participation and allow for continual "refreshing" of the organization.
Member Williams noted that, according to Article ll, Section 2. Members, of the
proposed Bylaws, each voting member of CASA must "designate in writing the
individual who shall exercise the voting rights ... and two alternates to that
individual as well. "
COMMITTEE ACTION: Recommended the Board: (1) Approve the proposed
amendments to the CASA Bylaws; and (2) designate the District's voting
delegates as follows:
Voting Delegate: Member Williams
First Alternate: Member McGill
Second Alternate: General Manager Roger Bailey; and
In the event all of the designated representatives are unavailable to
exercise the District's voting rights, the Board President may appoint
another delegate to serve in that capacity.
4. Receive profile summary information about Industrial Employers Distributors
Association (IEDA), potential labor relations consultant to represent the District's
interests in the 2017 labor negotiations
Human Resources Manager Teji O'Malley stated that she obtained information
on IEDA at the request of the Board after interest was expressed at the October
2013 Board Workshop to engage the services of a labor relations expert well
before the current Memoranda of Understanding (MOU) expire in December
2017. She said IEDA, a nonprofit agency with clients all over California, uses a
monthly fee structure based on the number of employees and bargaining units.
Ms. O'Malley said IEDA has offered to reduce its monthly premium to the District
by 50 percent for the strategic planning phase of negotiations because the
District's Human Resources staff typically handles human resource and day -to-
day labor relations issues. She said it may also be helpful to consider IEDA for
providing training sessions to first -line supervisors.
It was clarified that if the District were to engage IEDA effective July 1, 2014 at
the discounted monthly rate of approximately $1,700 for 36 months and at the full
monthly rate of approximately $3,400 for the six months immediately preceding
MOU contract expiration, the total cost would be roughly $81,600.
Administration Committee Action Summary
May 13, 2014
Page 3
The Committee expressed interest in meeting with a representative of IEDA at a
future Committee meeting and, for due diligence purposes, asked Ms. O'Malley
to provide information on at least two other potential labor relations experts.
Chair McGill stated that the District is in the midst of a cost -of- service study, and
acknowledged that consultant Larry Bienati is currently assisting staff with
developing a leadership training academy. Given these activities, and the fact
there may be other ongoing studies or activities which could overlap in one way
or another with services that IEDA could provide, he suggested that staff take an
overarching look at how all these studies and other activities fit together.
COMMITTEE ACTION: Received the information. Directed staff to
(1) arrange for an IEDA representative to attend a subsequent
Administration Committee meeting, (2) provide information on at least two
other potential labor relations experts, and (3) present a report on how the
work of various District consultants and ongoing studies fit together with
the plan to retain a labor relations expert.
*5. Review the draft Position Paper adding and authorizing the filling of an
Operations Safety Specialist (S -71, $7,305 - $8,837) position
Ms. O'Malley stated that this item resulted from the 2012 study of the District's
Safety Program conducted by Environmental and Occupational Risk
Management (EORM). She distributed copies of the consultant's final report
(copy attached). Creating another Operations Safety Specialist position should
remedy many of these concerns because under the new structure, the Safety
Officer position, which will report directly to the Director of Operations, will
oversee two specialists, one assigned to the Plant Operations Division and the
other assigned to the Collection Systems Operation Division. Responsibility for
safety issues involving Administration and other District staff will also be covered
by these positions. Ms. O'Malley said funding for the new position has been
included in the draft Fiscal Year 2014 -15 Operations and Maintenance Budget.
Member Williams commented that it would be helpful if staff made a Board
presentation on the findings of the study and then another presentation after the
implementation of the permanent organizational structure and recommendations
made in the study. Member Williams stated that he would like to receive a high -
level, annual loss and injury report that would include comparisons with other
agencies in the industry to aid in assessing the effectiveness of the District's new
Safety Program..
COMMITTEE ACTION: Reviewed and recommended Board approval of the
new Operations Safety Specialist position, and requested that a loss and
Administration Committee Action Summary
May 13, 2014
Page 4
injury report, including comparisons with other agencies in the industry, be
presented to the Board on an annual recurring basis.
6. Update on Employee Benefits for Plan Year 2014 -15
Ms. O'Malley briefly stated that staff has completed all negotiations with benefits
carriers for the coming fiscal year. Looking only at rates for health care, she said
she plans to hire a consultant to evaluate whether Ca1PERS may be a viable
option for the District.
COMMITTEE ACTION: Received the update.
7. Discuss revised draft of customer service survey questions from consultant
Sherri Petro of VPI Strategies
This matter was taken out of order, immediately following Item 8.
In the interest of time, this matter was discussed very briefly. General Manager
Roger Bailey said that completion of the survey hinges on whether the questions
would solicit information other than what is already known. It is possible that
responses to questions on recycled water could yield useful information.
Communication Services Manager Michael Scahill said he discussed with
consultant Sherri Petro the benefits of conducting focus groups in lieu of a
survey, which would reduce costs by half.
COMMITTEE ACTION: This item was continued to a future meeting.
8. Final review of draft 2014 Strategic Plan with consultant Larry Bienati, Ph.D.
This matter was taken out of order, immediately following Item 4.
Mr. Scahill said the second draft of the 2014 Strategic Plan incorporated the
comments made at the last Committee meeting. A sixth goal was added
regarding infrastructure, and some items were shifted around. At this point, he
said he was looking for feedback from the Committee, primarily with regard to the
way the goals were listed. The Committee Members agreed all the goals were of
equal importance; however, Consultant Larry Bienati said enumerating them
could give the appearance that they are ranked in order of priority. It was
suggested that the goals appear on a wheel with six spokes, each one
representing a goal, the hub of which might be the mission and /or values
statements.
Administration Committee Action Summary
May 13, 2014
Page 5
The Committee also discussed the merits of seeking Board approval of the goals,
strategies, mission, and values statements before delving deeper into the key
performance indicators, etc. Member Williams said the key performance
indicators are critical in providing feedback the Board needs to assess whether
targets are being met. Mr. Scahill noted that the final key indicators will also
become the basis for the District's business plan.
Member Williams said it would be helpful to see a two -year timeline overlaid on
the budget planning process to see how the strategic planning sequence works
with the budget cycle. For example, staff would review the strategic plan from
which it would develop an annual business plan. Staff would then decide what
resources would be needed to carry out the business plan and would include
those resources in the budget planning process. The timeline would cycle every
two years. Mr. Bailey said staff could prepare such a timeline.
COMMITTEE ACTION: Discussed and recommended the Board approve
the goals, strategies, and mission and values statements in the draft 2014
Strategic Plan before proceeding further with the key performance
indicators, initiatives, etc.
9. Announcements
a. Next meeting scheduled for Wednesday, May 28, 2014 at 8:00 a.m.
COMMITTEE ACTION: Received the announcements.
10. Suggestions for future agenda items
None.
11. Adjournment — at 10:05 a.m.
* Attachment
5.
Central Contra Costa Sanitary District
July 25, 2013
TO: CURTIS W. SWANSON, PROVISIONAL GENERAL MANAGER
FROM: JOHN ORTEGA, DISTRICT SAFETY COMMITTEE CHAIRPERSON
SUBJECT: CCCSD SAFETY PROGRAM ASSESSMENT FINAL REPORT
On behalf of the District Safety Committee (DSC), I am pleased to present the final
report of the Environmental and Occupational Risk Management's (EORM) Safety
Program Assessment. We hope that the information collected from this assessment will
be utilized to enhance our Safety Program and continued growth to strengthen our
safety culture throughout the District.
The DSC looks forward to supporting the implementation of EORM's findings or
recommendations. If you have any questions regarding the assessment, please feel
free to contact me.
JO /mvp
Attachments
cc: Dave Robbins, Provisional Plant Maintenance Division Manager
Paul Seitz, Collection System Operations Division Manager
Alan Weer, Plant Operations Division Manager
Safety Program
Assessment
Prepared for:
Central Contra Costa Sanitary District
5019 Imoff PlaceSanitary
Martinez, CA
June 25, 2013
Prepared by:
Christy Wolter
Principal Consultant
Reviewed by:
Danielle Reilly
Managing Principal
IR., FORM'
Environmental, Health, Safety
and Sustainability Consulting
Table of Contents
Executive Summary 1
Introduction 2
Scope of Work 2
Assessment Methodology 3
Site Description and Organization Profile 4
Safety Program Goals and Culture 6
Management Interview 6
Safety Representative Interviews 7
Staff Interviews 8
Safety Culture Summary 10
Safety Support Size and Reporting Structure Recommendations 11
Regulatory /Compliance Review 15
Site Walks 15
Field Operations 15
Documentation Review 16
Attachments
Attachment 1: Prioritization of Issues
Attachment 2: Photos
Attachment 3: Benchmarking Data
T FORM" 12.1007 CCCSD Safety Program Assessment Final 071813: Table of Contents i
Central Contra Costa Sanitary District - Safety Program Assessment
Executive Summary
Environmental and Occupational Risk Management, Inc. (EORM®) was selected to perform a safety
program assessment including current regulatory compliance and organizational safety culture.
Based on the assessment, Central Contra Costa Sanitary District (CCCSD) has a solid written safety
program with the majority of compliance elements in place, and employees are engaged and
genuinely dedicated to a safe workplace. It is evident that management supports safety, and that
there is a desire for continuous improvement. CCCSD can improve their safety program by
restructuring the Safety Department to reduce confusion, ensure adequate technical support, and
increase accountability for safety throughout the organization. The retirement of the current Safety
Officer offers a prime opportunity to re -look at the structure of the Safety Department and the
required qualifications for a Safety Officer position. Although employees have safety as a focus in
their day -to -day operations, site operational priorities at times result in employee shortcuts with
associated safety risks. In many cases the execution of the safety programs did not match what was
directed within the written programs. With additional qualified resources, increased accountability,
and administrative support, the Safety Department at CCCSD has the potential to be "best in class"
for the industry.
cf, FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Executive Summary 1
Central Contra Costa Sanitary District - Safety Program Assessment
Introduction
EORM was selected to conduct a safety program assessment for CCCSD operations. The purpose of
the safety program assessment was to provide recommendations to enhance the organizational
structure of the existing CCCSD safety program. A second objective of the project was to provide the
CCCSD with a summary of health and safety issues that may exist and provide recommendations to
reduce the potential for injury and illness prioritized by risk. Our assessment included reviewing
both successful components of the safety program and areas for improvement, including the size
and reporting structure of staff, communications, training, and compliance.
Scope of Work
The scope of the assessment was to:
* Analyze existing safety program structure with regard to training, documentation
management, communication and oversight.
* Determine number of staff required to adequately support all aspects of the safety program.
* Suggest reporting structure of safety staff.
* Determine if the existing safety program is meeting regulatory compliance.
ffal FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Introduction 2
Central Contra Costa Sanitary District - Safety Program Assessment
Assessment Methodology
The safety program assessment included a site walkthrough of all major operations facilities to
assess compliance with California safety regulations including:
• the treatment plant,
• laboratory,
• household hazardous waste facility,
• engineering,
• collections systems facility (including the vehicle shop),
• two major pump stations, and
® field operations for the collections systems group.
During the site visit, members of the CCCSD Safety Committee, management, and employees
throughout the organization were interviewed to determine the extent of program implementation,
employee engagement, and overall safety culture of the organization. In addition, a documentation
review was conducted to verify recordkeeping and program implementation including safety
committee minutes, training records, job hazard analysis, Material Safety Data Sheet (MSDS)
management, accident /incident investigation, and injury /illness trends.
T FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Assessment Methodology 3
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Site Description and Organization
Profile
CCCSD is a special district that collects and treats an average of 45 million gallons of wastewater per
day for 10 cities within Contra Costa County. The treatment facility is located in Martinez and has
the capacity to treat 54 million gallons of water per day. In addition to the treatment plant, the
Martinez facility includes a household hazardous waste collection facility and buildings for
administration, engineering, pollution prevention and education programs, and inspection.
Collection System Operations (CSO) Division is located in Walnut Creek, and the system includes
1500 miles of underground pipe and 18 pump stations. CCCSD employs approximately 250 people.
The structure of the Safety Department has changed over the last year, and has been in flux over the
last five years. Currently, there are two dedicated safety positions, a Safety Officer and a Safety
Specialist. The Safety Officer reports to the Division Manager for Plant Operations (POD), and the
Safety Specialist reports to the Division Manager in CSO. There is also an intern that assists part-
time, mainly for POD.
The Safety Officer oversees and conducts training, respiratory protection fit testing, recordkeeping,
safety directives, contractor safety orientation and pre -job walks, MSDS management for POD, and
participates on the POD and district wide safety committees.
The Safety Specialist conducts and oversees training for CSO, maintains training and inspection
records for CSO, conducts field safety inspections, and maintains calibration and inspection for air
monitoring equipment and personal protective equipment.
In addition, there is a Safety and Risk Management Administrator that reports in to the Director of
Administration. This individual oversees a safety and risk management technician who assists with
workers compensation, medical surveillance, ergonomics, and security for the facility. Today, the
safety and risk management department is focused on workers compensation administration,
litigation management, medical surveillance programs (except respiratory protection) and disaster
preparedness activities. There is currently no centralized reporting structure for all safety
responsibilities, and implementation of safety programs across the organization is inconsistent.
Note: Previously, the Safety Officer reported to the Safety and Risk Management Administrator.
cP FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Site Description and Organization Profile 4
Central Contra Costa Sanitary District - Safety Program Assessment
Current Reporting Structure for Safety:
CCCSD has two safety committee structures, one for district wide operations and a second for
department level activities. CCCSD safety committee consists of 15 to 20 representatives including
chairs of the three department safety teams (POD; CSO; Administration /Engineering). The
committee has representatives from management, Safety, and the two unions (four MSCG
members, four Local One members).
'P FORM® 12.1007 CCCSD Safety Program Assessment Final 071813: Site Description and Organization Profile 5
Central Contra Costa Sanitary District - Safety Program Assessment
Safety Program Goals and Culture
Management Interview
EORM met with CCCSD management personnel to learn about management's goals for the safety
program, and assess the actual safety culture. Areas that were discussed during the interview
included:
• goals and vision for the assessment and for the safety program moving forward,
• roles and responsibilities of management,
• communication,
• management of change,
• hazard identification and mitigation,
• corrective and preventative action, and
• the role of the Safety Department within CCCSD operations.
Management present in that interview included Paul Seitz, Dave Robbins, Curt Swanson, and
Alan Weer.
All members of the management team felt that there was a strong basis of a safety culture at the
facility, with everyone focused on maintaining a safe working environment for all. The management
team clearly understands the complexity of the safety hazards within the operations, and the need
for a robust safety program. It was noted that over the past five years there has been a shift in the
involvement of the Safety Officer in day -to -day activities, with far less involvement recently than
there had been in the past. The IIPP was recently re- written to shift a great deal of day -to -day safety
responsibility to department Supervisors, without training or resources provided to assist them in
implementing their new responsibilities. This has created a great deal of anxiety for the supervisors
and managers, and the execution of these new responsibilities has been inconsistent across the
organization. The management team expressed a desire to know more about how their facility
compares to others in terms of injury rates, staffing, and training or certification of safety
professionals. The management team was also interested in better insight on how the contractor
safety program is working, and how it compares to other facilities.
Goals and vision for the safety program included more physical presence and involvement from
Safety, more assistance and better tools for implementing the safety program at the department
level, and more site specific training. Management understands their role within the safety program,
but is frustrated by the shift of responsibility without the training, time, tools, and assistance to help
them implement these new responsibilities. The management group was interested in receiving
more hands -on technical support from the safety representatives. It was clear that implementation
of safety programs at Plant Operations was handled very differently than in Collections Systems, and
that Admin and Engineering has little to no dedicated support from Safety.
MI FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Program Goals and Culture 6
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Safety Representative Interviews
EORM interviewed the current Safety Officer, Diane Hinson, the Operations Safety Specialist, Dwight
Williams, the Safety and Risk Management Administrator, Shari Deutch, and the Safety and Risk
Management Technician, Ruth Bennett. Each interview was conducted separately. The focus of
these interviews was to determine the extent of support provided by the Safety representatives,
opportunities and challenges encountered in implementing the safety program, and an overview of
training and recordkeeping for the program.
According to Diane, the demands of updating the safety directives and administering the training
programs consume a majority of her time on a day -to -day basis. She does participate in the group
and district -wide Safety Committee meetings, and conducts contractor safety orientation prior to
major projects at the plant. The part -time safety intern assists with administrative duties such as
record keeping, MSDS management, and the newly developed training database. Diane is also
involved in selecting personal protective equipment (PPE) for employees and job tasks; although no
formal documentation of PPE evaluations is taking place. There is no formal process in place for
safety review of new substances or processes at the facility. The Safety Officer expressed frustration
with both this lack of pro- active review and the perception that the current reporting structure for
safety dilutes the impact that she can have on decision making within the organization.
Dwight has been with CCCSD since 1999, and has observed many changes in safety over the years.
He commented that the safety function was most effective when it reported higher in the
organization, and he specifically liked when safety reported straight to the Director of Operations.
Dwight expressed some concerns about two safety individuals working in two separate
organizations, and not necessarily sharing common methods for hazard assessment, training, and
recordkeeping. Dwight felt that there is a great deal of attention to safety within the organization,
but that commitment and follow through were not as strong as he would like. The lack of a
dedicated resource for Admin and Engineering was also brought up as a concern.
Shari currently oversees workers compensation insurance administration, other insurance and
claims, incident investigation, medical surveillance (except respiratory protection), litigation
management, security, and community disaster preparedness (Emergency Operations Center
preparation and administration). The movement of the Safety Officer from her group over to
Operations about one year ago has caused confusion in expectations and responsibilities for safety.
Shari would like to see safety representatives that are respected customer service partners, with
technical expertise, and an ability to work well with all groups. Shari also mentioned that she would
like to see more consistency in the follow through on safety violations across the organization.
Ruth has been working in safety at CCCSD since 1993. Ruth's responsibilities have included the
administration of the OSHA 300 log, workers compensation recordkeeping, return to work
programs, medical surveillance management, hearing conversation program, ergonomics, and
security. Many of these responsibilities have been transitioned to the Safety Officer over the past
year as part of the movement of that position to Plant Operations. Ruth expressed some confusion
about her current duties as a result of that split. Ruth also mentioned that the ergonomics program
often did not have the support it needed due to resource limitations. Ruth sees inconsistency in the
safety training program across the organization, and mentioned that many supervisors she speaks to
T, FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Program Goals and Culture 7
Central Contra Costa Sanitary District - Safety Program Assessment
do not know who needs training and why, despite the development of the training matrix. Ruth also
felt strongly that all safety representatives should report in to one individual responsible for safety
District wide.
All safety individuals expressed some difficulty in implementing safety programs, due to time and
resources limitations, confusion over responsibilities, and a perception that production or
operations takes precedence over safety on many occasions.
Staff Interviews
EORM interviewed a total of 53 employees throughout the organizations in various positions (> 20%
of the total employee population). The focus of these interviews was to gauge employee perception
of safety within the organization, and identify opportunities for improvement from the employee's
perspective. The following is a list of representative questions that were used in the employee
interviews:
• How do you communicate a safety concern?
• Are safety concerns addressed and corrected in a reasonable amount of time?
• Are you notified when your safety concern has been reviewed and /or resolved? How are
you notified?
• Tell us what you think about the effectiveness of safety training.
• Do you feel that CCCSD gives you the proper training, tools, protective equipment, and
environment to do your job safely?
• Tell us about your involvement in the safety process?
• Do you feel that your co- workers look out for your safety?
• If you could make one improvement in the current safety program what would it be?
• Compared to five years ago, where do you see today's safety program?
• Do you think contractors are held to the same standards as employees for safety?
There were many common themes heard throughout the interview process. These observations are
summarized in the following paragraphs.
CCCSD has a solid process for the communication of safety hazards, and has developed an
exemplary program for recognizing and rewarding employees for safety suggestions. The employees
interviewed were all able to articulate exactly how they would report a safety concern, and where
those concerns would be reviewed. The opportunities identified for improvement in this process
were the speed of resolution for safety concerns that involved purchases of equipment or capital
improvements, communication of status back to the initial reporting party, and sharing of lessons
learned /best practices from safety suggestions across the organization. Employees stated that "red
tape" within the purchasing process often slowed down resolution of safety issues. They also
commented that they did not always know the status of their suggestions. Some employees
communicated a lack of desire to contribute new ideas based on frustrations in resolution of past
suggestions.
FR FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Program Goals and Culture 8
Central Contra Costa Sanitary District - Safety Program Assessment
Employees across the organization commented about the volume of safety training, and could
articulate a variety of classes that they were offered. Employees and Supervisors felt that the
amount and types of training that they were offered was generally satisfactory and in some cases
employees were very pleased with the variety and frequency of training that they were able to
participate in. The use of safety tailgate meetings was common throughout the organization, and
demonstrates a strong commitment to safety across CCCSD. Employees, and particularly
supervisors, expressed significant frustration with the tracking, management, and administration of
training from the safety department. The training matrix developed to assist supervisors in
determining which training classes their employees need to attend is complicated, cumbersome,
and difficult to use. Supervisors felt that they did not have the time to check in regularly on status of
training for their employees, and often felt unclear about which classes were required for certain
employees. There were also several comments made about the lack of a robust training calendar,
classes being held without enough spaces or sessions, and difficulty in actually registering for classes
provided by the Safety Department. In both the management interview and in staff interviews, the
use of outside consultants to provide training was brought up as a concern, as there was a feeling
that these classes were often generic in nature and did not always apply to the operations at the
facility. Web -based training is used regularly as a replacement for in person training when
employees are unable to attend the session(s) provided. This results in some people having a
completely different level of training than their co- workers. Across the organization, employee
would like to see a better organized more site specific, and more convenient safety training
program.
For the Plant Operations Division, HHW, and within Admin and Engineering, there is a strong desire
for more involvement and physical presence of the Safety Officer and /or Safety Specialist. Both of
these groups reported that they rarely saw the safety person, and that on several occasions when
support was urgently needed, the safety professionals were unavailable, unreachable, and /or
unresponsive. Both groups would like technical assistance for safety issues in their areas, and have
essentially given up hope of getting this support from the internal resources. In some cases
erroneous information provided by the Safety Officer has resulted in a lack of trust and desire to use
this resource for ongoing safety support. Each of these groups manages on their own, but expressed
a strong desire to get additional help. The CSO group reported general satisfaction with the level of
support they receive from the Safety Department. They are happy with the assistance that safety
provides for detection equipment calibration, training, and field support. There is a sense from this
group that they would not like any additional involvement from safety within their day -to -day
operations.
Contractor safety was discussed with each of the employee groups, to better understand the
implementation of the program within CCCSD operations. Several employees and supervisors felt
that the program was heading in the right direction with the implementation of a contractor safety
orientation, but that contractors were not held accountable for following safety procedures, and
that staff often ignored and disregarded violations in safety protocols by contractors. When asked
why this may be occurring, there was a feeling that most employees did not want to impeded
project process or "rock the boat." There were several stories and pictures shared with the EORM
staff that illustrated egregious safety violations by contractors. The overall assessment was that
ultimately contractors were not held to the same safety standards as employees.
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Safety Culture Summary
This section summarizes EORM's observation of the CCCSD safety culture based on employee and
management interviews, and what was observed during the site walkthroughs. Employees overall
are very committed to working safely, and take safety very seriously. They generally view safety as
an important part of the business, equal to quality, production, etc. They felt that their safety
concerns were addressed. Employees are looking for additional organizational structure and
leadership /vision from top management, including the Safety Department.
Employee participation in the safety program is good. Each department has periodic safety tailgate
meetings several times a month. Accident investigations and corrective actions are posted and
reviewed with the crews after being discussed at CCCSD Safety Committee. This employee
engagement creates a solid foundation for a successful safety program.
Opportunities for improvement in strengthening safety culture include more visibility and support
from the management team, more accountability for safety performance from each employee and
supervisor, and stronger policies on repercussions of not adhering to safety policies, both for
employees and contractors. Centralization of the safety function can also help to ensure that safety
policies are applied consistently across the organization. Employees need to feel empowered and
comfortable to stop unsafe actions, and supervisors need to consistently follow through to address
safety violations. This support throughout the organization will help solidify the safety culture that is
present today.
M FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Program Goals and Culture 10
Central Contra Costa Sanitary District - Safety Program Assessment
Safety Support Size and Reporting
Structure Recommendations
The current Safety support structure is split between three different areas of the organization, and
would benefit from consolidation under one individual, reporting to the highest level in the
organization possible. EORM recommends that the safety function report directly to the General
Manager. This ensures visibility and management support for the Safety Department at a level that
oversees each of the major functions within the organization. Alternatively, the Safety Officer could
report in to the Director of Operations. If the Safety Officer reports directly to the General Manager
or Director of Operations, the Safety and Risk Management Function should be separated, so that
there is a clear line of responsibility for safety functions. Risk Management should retain
responsibility for Security, Legal Affairs, and Community Disaster Preparedness.
Given the size, complexity, and geographic location of the operations, EORM recommends a Safety
Officer position, as well as a dedicated safety professional for either each of the main divisions, POD,
CSO, and Engineering /Administration, or one for each main location (Martinez and Walnut Creek). In
addition, an administration function should be added to assist with documentation and training
management throughout the organization to allow the safety professionals to spend more time in
the field assisting with safety assessments, inspections, and training. EORM also recommends that
the title of Safety Officer be changed to Safety Administrator, Safety Specialist, or Safety Consultant.
The term "Officer" implies a policing function, and safety should be considered more of a technical
resource and partner within the organization.
EORM has provided three options for structure of the safety organization, depending upon available
resources.
Option 1: Safety Officer, reporting in to General Manager, with four direct reports. The Safety
Officer would have three Safety Specialists (one for each POD, one for CSO, and one for Admin,
Engineering, and HHW), and one administrative professional to assist with all program
documentation and training management. In this arrangement, the Safety Officer would provide
general safety program oversight, assist with each of the three areas as needed, and provide
feedback and guidance for the program overall. This individual could direct and assist with site
inspections, and support training efforts throughout the District.
T EORM* 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Support Size and Reporting Structure Recommendations 11
Central Contra Costa Sanitary District - Safety Program Assessment
Option 2: Safety Officer, reporting in to General Manager, with three direct reports, one safety
specialist for each main site location, and one administrative professional. The Safety Officer
would have general program oversight, but also assist in day -to -day safety operations at the
Martinez site.
T E O R M m 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Support Size and Reporting Structure Recommendations 12
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Option 3: Safety Officer reporting in to the General Manager, with one direct report for
administrative assistance. In addition, there would be dedicated safety coordinators in each
individual department with specific responsibilities for site inspections, equipment maintenance,
and some department training. These individuals would need to have a percentage (15 -25 %) of their
time completely dedicated to safety responsibility for their departments, and would need to have
some dotted -line accountability to the Safety Officer. This is the least ideal option given that day -to-
day operations responsibilities may be in direct conflict with safety management responsibilities.
The Safety Officer selected to oversee the program for district -wide operations should have a
minimum of five years of industrial and /or field safety experience. Ideally, this person would either
have a Certified Safety Professional (CSP) or Certified Industrial Hygienist (CIH) designation. This
individual should also possess strong communication, writing, and organizational skills. Previous
experience working in wastewater or sewer collections operations would be beneficial.
Another key component of a successful safety program is management accountability and
engagement. The responsibility for maintaining a safe, healthful, and compliant workplace rests with
CCCSD management and should be distributed among supervisors and managers of each
department under the guidance of CCCSD safety officer /group. Supervisors should be trained on
their responsibilities under the program. In addition, supervisors should be held accountable for
safety performance in each of their groups, including adherence to site policies, training, and results
of site inspections. Department safety inspections should ideally be conducted at least twice per
year by a safety professional, with the participation of the department supervisor and /or manager.
Supervisors should be held responsible for successful completion of any corrective actions identified
in the course of site inspections or incident investigations. The safety department should be a
resource that is engaged in identifying operational and regulatory safety issues, and suggestion
resolutions for these issues, but the ultimate responsibility for resolution should lie with the
department management.
T, E O R M * 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Support Size and Reporting Structure Recommendations 13
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As part of the recommendation for Safety organization structure, EORM conducted informal
benchmarking with 11 other water supply and wastewater treatment /Sanitary districts within the
State of California, to assess industry trends for Safety Department staffing. The results of this
benchmarking indicated that safety staffing varies greatly from one organization to the next, and is
not consistent based on the size of the operations or number of staff. Staffing ranged from six full
time safety professionals (Orange County Sanitation) to no full -time staff with safety being handled
as part of maintenance superintendent duties (Ironhorse Sanitation). Safety reports in to a variety of
departments including operations, administration, finance, and HR. For organizations that had a
safety professional, safety responsibilities were centralized. All of the organizations supplemented
safety program support with outside consultants. Detailed benchmarking information is provided in
Attachment 3.
M E O R M * 12.1007 CCCSD Safety Program Assessment Final 071813: Safety Support Size and Reporting Structure Reoommendations 14
Central Contra Costa Sanitary District - Safety Program Assessment
Regulatory /Compliance Review
In addition to the safety culture and safety reporting structure assessment, EORM conducted a
regulatory /compliance review of CCCSD operations. This was not intended to be an exhaustive
compliance audit. During inspection and interviews, EORM noted items that did not comply with
current occupational health and safety standards and has listed these areas for improvement. EORM
did not investigate the accuracy or thoroughness of representations made by CCCSD personnel
during the assessment. Furthermore, observations noted in this report were based only on
interviews with personnel and physical observations of conditions at the facilities on the day(s) of
the assessments.
This report is primarily an exceptions report, identifying areas that require compliance, or benefit
from best practice, or management systems improvements. Programs that exceed governmental
and internal standards and guidelines may not be highlighted. This type of report is designed to
enable management to focus on weaknesses and improve programs through appropriate corrective
actions.
Site Walks
EORM conducted a site walkthrough in the water treatment plant buildings, the laboratory,
household hazardous waste operations, collection systems operations (including vehicle shop), and
two pump stations. The focus of the site walks was to identify regulatory or industry best practice
safety program gaps. Finding from the site walk are included in the Prioritization of Issue table
below.
Housekeeping throughout all the facilities was exemplary. The use of personal protective equipment
was consistent in all locations, and the equipment appeared to be well maintained and easily
available. Machine guarding was exceptional, particularly in the plant operations areas.
Areas for improvement include labeling of secondary chemical containers, guardrails for elevated
locations, and ventilation assessments for local exhaust ventilation equipment. Detailed information
regarding these areas for improvement is contained within the Prioritization of Issues table.
Field Operations
EORM conducted field observations for CSO in two separate locations. Employees were observed to
be using the correct detection equipment prior to beginning work in any sewer lines, and were
wearing appropriate personal protective equipment. Cones were used at each of the sites to help
with traffic control, and in some cases signs and spotters were used for additional traffic safety. The
implementation of traffic safety procedures was inconsistent, and appeared to be subject to the
judgment of the person conducting the work. The employees and their supervisors indicated that
CalTrans traffic control procedures were supposed to be followed, however this is not what was
observed during the field visits.
F FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Regulatory/Compliance Review 15
Central Contra Costa Sanitary District - Safety Program Assessment
Documentation Review
EORM reviewed each of the Safety Directives for overall content and high level regulatory
compliance. The implementation of these programs was verified in the field during the site walks
and employee interviews. In addition, EORM conducted a selected spot check of program
documentation including training records, inspection records, safety committee minutes, job hazard
analysis, and corrective action plans. Written programs were in place or in development for each of
the CalOSHA requirements that applied to operations.
The general observation for recordkeeping was that documents were difficult to locate, lacked
organization, and were inconsistent. Recordkeeping in POD was completely differently than in CSO.
Training records for employees in POD took some time to locate, and did not include any reference
to the contents of the class. For CSO, records were kept on the computer of the Operations Safety
Specialist, but they also took time to locate, and hard copy records with training materials were not
available. The Safety function was in the process of switching to a training database to help manage
these records, and this may have impacted the ability to locate records for specific employees
and /or classes. Safety inspection documentation was sporadic in all areas, with several departments
having no documented inspections within the last three years. Inspection forms included comments
on safety issues, but no documented corrective action. Job Hazard Analysis /Job Safety Analysis
documentation was inconsistent and at times incomplete.
Regulatory findings have been organized into a Prioritization of Issues (POI) table presented in
Attachment 1. The table lists compliance issues that require attention from CCCSD and their
associated priority ranking. Issues include deficiencies and potential non - compliance items identified
by EORM in critical Health and Safety program areas. EORM assigns priority based on the finding's
potential or actual risk to employees and /or the environment, the level of compliance observed, and
the current enforcement policies of regulatory agencies as perceived by EORM. Current Best
Management Practices (BMP) and Safety management systems were also considered when
identifying areas for improvement. The priorities are assigned as follows.
High Priority (HIGH)
High priority findings could result in substantial risk to the environment, the public, employees,
stockholders (if applicable), customers, the client, or criminal or civil liability for knowing
violations. Findings classified as High Priority can be considered a serious violation by a
regulatory agency. Administrative issues can be categorized as High Priority (e.g., failure to
report an OSHA recordable injury when required).
Medium Priority (MED)
Medium priority findings do not meet the criteria for High Priority, but are more than an
isolated or occasional situation. These findings should not continue beyond the short term.
Findings in this category can result in a notice of violation from a regulatory agency or could be a
void in a management system.
FR FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Regulatory /Compliance Review 16
Central Contra Costa Sanitary District - Safety Program Assessment
Low Priority (LOW)
Low priority findings may be administrative or involve an isolated or rare situation. These
findings may involve temporary or occasional instances of non - compliance or opportunities for
system improvement.
Best Management Practices (BMP)
A practice not required by a regulation, order, or rule that has been defined by industry as
better than the standard EHS operational management. BMPs, if not adopted, can lead to
regulatory findings (e.g., failure to train employees annually on hazard communication issues
can lead to poor employee knowledge of chemical safety information).
T' FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Regulatory /Compliance Review 17
Central Contra Costa Sanitary District - Safety Program Assessment
Attachment 1: Prioritization of Issues
MI E R 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues.
Central Contra Costa Sanitary District - Safety Program Assessment
Health and Safety Prioritization of Issues Table
He
Prc
Cor
alth &Safety
►gram / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
ifined Space
8CCR §5157
Requirements
HIGH
• Confined space means a space that:
• (2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos,
storage bins, hoppers, vaults, and pits are spaces that may have limited means of
entry).
• Permit - required confined space (permit space) means a confined space that has one
or more of the following characteristics:
• (4) Contains any other recognized serious safety or health hazard.
Findings
• The 21 double -door entry points used to access the 21 large individual racks of UV
lights near UV Building #10 are currently not classified, labeled, or treated as confined
spaces. These 21 spaces are lined up in three rows of seven each. The six Building and
Grounds employees periodically enter these underground spaces to unplug and attach
each rack of UV lights to an overhead crane in order to transport the rack to a
phosphoric acid tank and a water rinse tank for cleaning. After the rack is cleaned, the
reverse steps are followed to place the rack back into its position.
• These four foot deep spaces clearly meet the criteria for classification as a confined
space, since the four foot access ladder meets the definition of a space that has
"limited or restricted means for entry or exit." The portable stainless steel ladder is
currently not used by employees since it is too heavy to move around easily. As a
result, the current practice is to jump or lower oneself about four feet down onto the
top of the UV light rack.
• Once the employee is standing in this position, he unplugs the multiple light
connectors (after the potential electrical hazard has been controlled by
lockout /tagout), and then connects the overhead crane sling to the four corner
connection points of the UV light rack. While either accessing or working in the space,
the employee is exposed to other safety hazards, with the most significant being a
slip, trip and fall hazard either onto the UV light rack or into the water space below.
• Based upon this fall hazard, which is a "recognized serious safety or health hazard ",
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Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
these 21 spaces are clearly "permit- required confined spaces (PRCSs)," and should be
classified as PRCSs. However, a lengthy discussion about changing how this job is done
revealed that, with several modifications, the employee may never have to enter the
space, thus eliminating the requirements of working in a PRCS.
Recommendations
• With several modifications, the employee may never have to enter the space, thus
eliminating the requirements of working in a PRCS. The two major proposed changes
are:
• Have the employee unplug and plug back in the multiple light connectors while
kneeling at ground level, prior to opening up the double doors.
• Extend or raise the height of the four corner connection points on the UV light rack so
that the employee can connect the overhead crane sling while kneeling at ground
level without ever having to enter the space.
Electrical Safety
8CCR §3556
Requirements
HIGH
State regulation requires damaged or defective power equipment to be removed from service
until repairs are made and tests show the equipment is safe.
Findings
The yellow portable DeWalt disc grinder (Serial #822581) on the welding table in the
Mechanical Shop has an electrical cord with damaged insulation and exposed wiring.
Recommendations
This grinder should be tagged out -of- service until the electrical cord is repaired.
T FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
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Health & Safe
Program / Iss
Emergency Act
(EAP) — Writtei
T FORM'
ty
ue
Regulatory
Citation
Requirement/Findings/Recommendations
Priority
:ion Plan
8CCR §3220(a -d)
Requirements
HIGH
i Plan
The Emergency Action Plan (EAP) shall be in writing and shall cover those designated actions
employers and employees must take to ensure employee safety from fire and other
emergencies. The EAP should include the following elements:
(1) Emergency escape procedures and emergency escape route assignments;
(2) Procedures to be followed by employees who remain to operate critical plant operations
before they evacuate;
(3) Procedures to account for all employees after emergency evacuation has been completed;
(4) Rescue and medical duties for those employees who are to perform them;
(5) The preferred means of reporting fires and other emergencies; and
(6) Names or regular job titles of persons or departments who can be contacted for further
information or explanation of duties under the plan.
Findings
• The written emergency action plan does not contain procedures for responding to
specific emergencies such as fire, chemical spill, power failure, earthquake, etc.
• According to employees interviewed throughout the organization, a formal
evacuation drill has not been conducted in several years. Several staff expressed a
similar concern for Shelter In Place drills.
• When employees were asked about procedures to follow during an emergency,
evacuation, they were unable to articulate their specific responsibilities or procedures
to follow.
Recommendations
• Update the written EAP to include specific procedures for the highest risk
emergencies such as fire, injury, chemical spill, shelter in place, and earthquake.
• Conduct and document a minimum of one evacuation drill per calendar year.
12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
Central Contra Costa Sanitary District - Safety Program Assessment
Health & Safety Regulatory
Program / Issue Citation
Hazardous Energy Control 8CCR3314(e)
(Lockout/ Tag out)
Program
Requirement /Findings /Recommendations
Requirements
Hazardous Energy Control Procedures. A hazardous energy control procedure shall be
developed and utilized by the employer when employees are engaged in the cleaning,
repairing, servicing, setting -up or adjusting of prime movers, machinery and equipment.
(1) The procedure shall clearly and specifically outline the scope, purpose, authorization, rules,
and techniques to be utilized for the control of hazardous energy, and the means to enforce
compliance, including but not limited to, the following:
(A) A statement of the intended use of the procedure;
(B) The procedural steps for shutting down, isolating, blocking and securing machines or
equipment to control hazardous energy;
(C) The procedural steps for the placement, removal and transfer of lockout devices and
tagout devices and responsibilities; and,
(D) The requirements for testing a machine or equipment, to determine and verify the
effectiveness of lockout devices, tagout devices and other hazardous energy control
devices.
(2) The employer's hazardous energy control procedures shall be documented in writing.
(A) The employer's hazardous energy control procedure shall include separate procedural
steps for the safe lockout /tagout of each machine or piece of equipment affected by the
hazardous energy control procedure.
Exception to subsection (g)(2)(A): The procedural steps for the safe lockout /tagout of
prime movers, machinery or equipment may be used for a group or type of machinery or
equipment, when either of the following two conditions exist:
(1) Condition 1:
(A) The operational controls named in the procedural steps are configured in a similar
manner, and
(B) The locations of disconnect points (energy isolating devices) are identified, and
(C) The sequence of steps to safely lockout or tagout the machinery or equipment is
similar.
(2) Condition 2: The machinery or equipment has a single energy supply that is readily
Priority
HIGH
0
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Health &Safety Regulatory
Pro ram Issue I-Citation Requirement /Findings /Recommendations
gram
icienuned and isolated and has no stored or residual hazardous energy.
Findings
A Hazardous Energy Control program is in place, and equipment specific procedures have been
developed. These procedures are associated with a work order and are printed for the
employee before maintenance or repair is performed.
Employees indicated during the interview process that LOTO procedures are often not
followed completely in practice. The most frequent comment made by employees was that
locks are often placed on the start /stop /power buttons, and not at the energy isolation point.
There were no records of annual LOTO procedure audits, and employees stated that audits
have not been completed in several years.
Recommendations
CCCSD should begin conducting and documenting annual inspections of the LOTO procedure.
These audits should be conducted by someone familiar with the equipment and the procedure
to be used.
Industrial Hygiene 8 CCR §5141 Requirements
• The ventilation rate of every mechanical ventilation system used to prevent harmful
exposure shall be tested after initial installation, alterations, or maintenance, and at
least annually, by means of a pitot traverse of the exhaust duct or equivalent
measurements.
• Records of these tests shall be retained for at least five years.
Findings
• Three flexible exhaust duct hoods (two for absorbent dust, and one for solvent
vapors) in the HHWCF Building #1 had no annual ventilation airflow check.
• All of the other ventilation hoods (with the exception of the lab fume hoods) observed
in other departments and areas were not checked annually. These included several
flexible exhaust ducts (elephant trunks) used in the main weld shop and in the
mechanical shop weld area, and a parts washer in the machine shop.
Recommendations
Have all ventilation hoods checked annua
and retain the records at a minimum of five years.
Priority
High
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Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
-Program-/
Injury and Illness
8CCR §3203
Requirements
HIGH
Prevention Program (IIPP)
Every employer in California must establish, implement and maintain an effective Injury and
Illness Prevention Program (IIPP). The IIPP must be in writing and include the following, at a
minimum:
• Identify the person or persons with responsibility for implementing the IIPP.
• Include a system for ensuring employees comply with safe and healthy work practices
including recognition of employees who follow safe and healthy work practices,
training and retraining programs, disciplinary actions, or any other similar means.
• Include a system for communicating with employees in a form readily understandable
by affected employees on matters relating to occupational safety and health,
including provisions designed to encourage employees to inform the employer of
hazards without fear of reprisal. Substantial compliance includes meetings, training
programs, posting, written communications, a system of anonymous notification by
employees about hazards, labor /management safety and health committees, or any
other similar means.
• Include procedures for identifying and evaluating workplace hazards including
scheduled periodic inspections to identify unsafe conditions and work practices and
hazards.
• Include a procedure to investigate occupational injury or illness.
• Include methods for correcting unsafe or unhealthy conditions and work practices.
• Include site inspections.
Findings
• Site inspection for several departments had not been documented in the last two
years.
• Documentation of investigation and corrective action for injuries and illness was
inconsistent and at times incomplete.
Recommendations
Move the responsibility for conducting site inspections back to the Safety Officer, with
participation and follow up from the department supervisors.
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Program / Issue
Regulatory
Citation
Requirement/Findings/Recommendations
Priority
Industrial Hygiene
8 CCR §5154.1
Requirements
Medium
Fume hoods shall be equipped with a quantitative airflow monitor that continuously indicates
whether air is flowing into the exhaust system during operation.
Findings
One lab fume hood in the HHWCF Building #1 had an annual ventilation airflow check, but did
not have a continuous reading airflow monitoring device like the ones in all of the other lab
fume hoods, such as in the main laboratory building #8.
Recommendations
Install a continuous monitoring airflow device on non - compliant fume hoods.
Fall Protection
8 CCR §3212(a)(1)
Requirements
MEDIUM
Every floor and roof opening shall be guarded by a cover, a guardrail, or equivalent on all open
sides. While the cover is not in place, the openings shall be constantly attended by someone or
shall be protected by guardrails.
Findings
When each of the 21 double -door entry points used to access the 21 large individual racks of
UV lights near UV Building #10 is opened and the large UV light rack is removed by the
overhead crane, the large double metal cover doors to the space are left in the open position
for one to two hours while the light rack is being dipped into the nearby phosphoric acid and
water rinse tanks. During this one to two -hour period, the large opening presents a 10 -ft. fall
hazard. No barrier is used to prevent persons from falling into this opening.
Recommendations
Two methods of mitigation are available:
• Close the two metal covers immediately after pulling the UV light rack out of the hole,
and make this a required part of the standard operating procedure.
• Use temporary guardrails on the two open sides.
FORM* 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
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Health & Safety
Program / Issue
Industrial Hygiene
yg
Regulatory
Citation
Requirement /Findings /Recommendations
Requirements
Priority
MEDIUM
8 CCR §5155
Whenever it is reasonable to suspect that employees may be exposed to concentrations of
airborne contaminants in excess of levels permitted in Section 5155(c), the employer shall
monitor the work environment so that exposures to employees can be measured or calculated.
Findings
• The second floor of the SCB Building #23 has four fixed Hydrogen Sulfide (1-12S) sensors
that read out at one panel where the background noise level is high. The ambient
noise would likely make it difficult to hear a high H2S level alarm warning sound in
areas other than those in close proximity to the alarm panel.
• The third floor of the SCB Building #23 has some fixed Carbon Monoxide (CO) sensors
near the boilers that have an alarm panel with a small warning light. It is doubtful that
anyone would see this high CO level warning light in areas other than those in close
proximity to the alarm panel.
• The biggest disadvantage of fixed monitors is that they only measure one point in
space. As a result, they may not be an accurate measurement of worker exposures
since the employees move around a lot, and they are sometimes much closer to the
point of contaminant (1-12S, CO) generation. In this case, the high background noise
levels are a second disadvantage of fixed monitors.
Recommendations
During this assessment, no information was provided regarding the history of H2S and CO
levels in this building, or the rationale for installing these fixed monitors. Formal industrial
hygiene surveys for H2S and CO should be conducted and the results documented and
evaluated to determine if there are risks that need to be mitigated. If excessive levels are
found, affected employees should wear personal H2S and /or CO monitors in place of the fixed
monitors.
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Health &Safety
Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
Industrial Hygiene
8 CCR §5155
Requirements
MEDIUM
Whenever it is reasonable to suspect that employees may be exposed to concentrations of
airborne contaminants in excess of levels permitted in Section 5155(c), the employer shall
monitor the work environment so that exposures to employees can be measured or calculated.
Findings
The air intake opening to the general ventilation system for the SCB Building #23 is located
about 30 feet away from the outside ground level lime storage tank. When the tanker truck
delivers lime three times per week, the driver leaves a gas fuel - powered pump running for
about an hour. If the wind conditions blow the pump exhaust towards the air intake, then
Carbon Monoxide (CO) could be pulled into the building.
Recommendations
Potential exposure to CO should be tested with a portable CO detector at least three times and
the results should be documented and evaluated to determine if there is a risk that needs to
be mitigated.
Guardrails at Elevated
8 CCR §3209
Requirements
MEDIUM
Locations
8 CCR §3210
Elevated work latforms shall have one or more mid -rails in addition to the top p guardrail for
fall protection. A plant -wide survey should be done to identify those elevated work platforms
that do not meet this requirement.
Findings
The "Centrate" Tank on the second Floor of the SCB Building #23 had a 10 -ft. high yellow
painted fixed metal ladder going up to a yellow painted elevated work platform that accessed
the top of the tank. The platform had a top guardrail but no mid -rail. A person could fall
through the open mid -rail section. Elevated work platforms are required to have at least one
mid -rail in addition to the top guardrail for fall protection. This same situation existed in other
areas, such as the 6' -7' high elevated work platforms on two of the three red final effluent
pumps in PBB Building #6 that did not have a mid -rail.
Recommendations
Install mid -rails in non - compliant locations.
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Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Requirements
Priority
MEDIUM
Elevated Work Platforms
8 CCR §3212
Fixed ladder access points to elevated work platforms shall have a swing gate or equivalent
protection that prevents a person from falling through the ladder opening, especially in those
situations where the elevated working space is limited.
• A plant -wide survey should be done to identify those fixed ladder access points to
elevated work platforms that do not meet the following requirements.
• (a)(2)(A) Every ladder way floor opening or platform with access provided by a ladder
way shall be protected by guardrails with toe boards meeting the requirements of
General Industry Safety Orders, Section 3209 (i.e., top guardrail and mid - rail), on all
exposed sides except at the entrance to the opening. The opening through the railing
shall have either a swinging gate or equivalent protection, or the passageway to the
opening shall be so offset that a person cannot walk directly into the opening.
• (13)(1) The uppermost surface or railing member of the swinging gate or other
equivalent protection required by subsection (a)(2)(A) shall have a vertical height from
the platform or floor level between 42 to 45 inches plus or minus one inch;
• (13)(2) The swinging gate or other equivalent protection shall be capable of
withstanding a force of at least 200 pounds applied vertically downward to the
uppermost surface or railing member, and horizontally outward at any point on the
exit side of the ladder opening.
Findings
The fixed ladder access points to elevated work platforms at multiple locations and in various
buildings throughout the plant were non - compliant and had either no chain, a chain, or a single
metal bar going across the top to prevent a person from falling through the ladder opening.
These specific locations that failed to comply with current requirements specified in Section
3212 were:
• The 6' -7' high elevated work platforms on two of the three red final effluent pumps in
PBB Building #6
• The Four 6' high elevated work platforms at the two steam turbines on the first floor
of the PBB Building #6
• In the FPOB Building #26
OP
R M* 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
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Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Recommendations
Priority
Retrofit these work platforms to ensure compliance with the regulations by installing swing
gates on all of the elevated work platform fixed ladder openings. The swing gates shall be
equipped with both a top guardrail and a mid -rail.
Hazard Communication
8 CCR §5194
Requirements
MEDIUM
Labeling
All hazardous material secondary containers shall have labels that include both the identity
(name) of the hazardous material and appropriate hazard warnings. Incorporating the new
hazard communication labeling requirements of the Global Harmonization Standard (GHS)
should be seriously considered, due to its upcoming implementation date.
Findings
Almost all of the secondary chemical containers (i.e., water testing kit chemicals such as
phenylarsine oxide, vacuum pump oil, etc.) observed throughout the plant and in the main
laboratory building #8 had non - compliant hazard communication labeling. Many secondary
container bottles had the identity (name) of the hazardous material, but no hazard warnings.
Several chemical containers had no identification or hazard communication label at all. "Fill-in -
the- blanks" blue, red, and yellow hazard communication labels are available from the
warehouse and are supposed to be filled out by the employees, but they are not being used.
This appears to be a system -wide problem.
Recommendations
• Ensure that all hazardous materials labels are compliant with both the identity and
hazard warnings for the product.
• Evaluate updating all hazardous material labeling to comply with GHS requirements to
meet future deadlines.
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Health & Safety
Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
Respiratory Protection
8 CCR §5144
Requirements
MEDIUM
8 CCR §5144(d)
If the employer determines that any voluntary respirator use is permissible, the employer shall
provide the respirator users with the information contained in Appendix D to this section
( "Information for Employees Using Respirators When Not Required Under the Standard. ")
Findings
• Nuisance -type disposable dust masks are available for employee use in some areas
(i.e., lab). It was unclear whether or not employees were provided with a copy of
Cal /OSHA Appendix D on Voluntary Use of Disposable Dust Masks.
Recommendations
Provide employees with Appendix D and document the distribution.
Contractor Safety
8 CCR 336.10 and
Requirement
MEDIUM
336.11
As a best management practice to minimize risk as a multi - employer worksite, develop and
BMP
implement a formal contractor safety policy including requirements for training, MSDSs for
chemicals being brought on the property, prior safety record, and emergency preparedness.
Findings
A written Multi- Employer Worksite Safety Directive is currently in development, but was not
available for review.
Recommendations
• Complete development of written program and provide training to all staff that hire
or interact with contractors.
• Establish some basic criteria to ensure contractors brought onsite have a strong safety
record. This can be done through the use of a MOD rate or their OSHA 300 log.
• Ensure that Facilities and the EHS Department are working closely regarding who is
coming onsite and what chemicals they may be bringing with them.
M] FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
Central Contra Costa Sanitary District - Safety Program Assessment
Health &Safety
Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
First Aid Supplies
8 CCR §3400
Requirements
LOW
A frequent inspection shall be made of all first -aid materials, which shall be replenished as
necessary.
Findings
A few supply items in several first aid cabinets were observed to be past their expiration date.
Recommendations
• Remove expired materials
• Create and implement process for regular inspection of cabinets that includes
replacing used or expired materials
FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
Central Contra Costa Sanitary District - Safety Program Assessment
Health & Safety
/Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
_Program _ _
Personal Protective
8CCR §3380
Requirements
LOW
Equipment
Hazard assessment and equipment selection.
(1) The employer shall assess the workplace to determine if hazards are present, or are likely to
be present, which necessitate the use of personal protective equipment (PPE). If such hazards
are present, or likely to be present, the employer shall:
(A) Select, and have each affected employee use, the types of PPE that will protect the
affected employee from the hazards identified in the hazard assessment;
(B) Communicate selection decisions to each affected employee; and,
(C) Select PPE that properly fits each affected employee.
Note: Non - mandatory Appendix A contains an example of procedures that would comply with
the requirement for a hazard assessment.
(2) The employer shall verify that the required workplace hazard assessment has been
performed through a written certification that identifies the workplace evaluated; the person
certifying that the evaluation has been performed; the date(s) of the hazard assessment; and,
which identifies the document as a certification of hazard assessment.
Findings
There has been no formal documentation of PPE hazard assessments. Some personal
protective equipment notations have been made where a job hazard analysis was conducted,
but this process has not been implemented consistently across the organization, and PPE
documentation is not always included in these assessments.
Recommendations
• Conduct and document formal PPE hazard assessments for all facility operations.
• Ensure that the PPE requirements are included in SOPS and employee training.
FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
Central Contra Costa Sanitary District - Safety Program Assessment
Health &Safety
Program / Issue
Regulatory
Citation
Requirement /Findings /Recommendations
Priority
Confined Space
None
BMP
Requirements
None
Findings
Although confined spaces are posted with Danger signs, the signs do not have confined space
numbers.
Recommendations
A Best Management Practice (BMP) should be implemented to number each confined space.
This number should be included on both the Danger sign and the entry permit. Numbering
helps with identification and allows better tracking on a confined space inventory.
None
Requirements
BMP
Employee Safety
None
Findings
The basement tunnel area of the PBB Building #6 had a significant steam leak in which steam
was being released into a fairly large area.
Recommendations
Although a person could see the white steam cloud, this area should be isolated by placement
of yellow and black Caution tape around the hazard zone as a temporary control measure,
_
followed by repair and stop-page of the steam Leak as a permanent control measure.
Traffic Control Safety
None
Requirements
BMP
Traffic control measures used at each filed site were inconsistent and did not follow the
internal standard that has been established (use of CalTrans traffic control procedures).
Recommendations
• Continue field audits and ensure the results of those audits are communicated to
management
• Establish accountability for following these procedures. Include this in daily
coaching, performance reviews, and as needed disciplinary processes.
T FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
Central Contra Costa Sanitary District - Safety Program Assessment
Health & Safety
Program / Issue
Employee Safety
Regulatory
Citation Requirement /Findings /Recommendations
None Requirements
None
Findings
Several chairs in a few different buildings (i.e., control room in SCB Building #23, FPOB Building
#26) were observed with some damage (i.e., missing wheels). These present an opportunity for
a serious accident and injury to occur.
Recommendations
A system -wide review of chairs should be conducted, and any damaged or defective chairs
should be disposed of and replaced if necessary.
Priority
BMP
T FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 1: Prioritization of Issues
Central Contra Costa Sanitary District - Safety Program Assessment
Attachment 2: Photos
T FORM' 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 2: Photos
Central Contra Costa Sanitary District - Safety Program Assessment
UV Building — LOTO Prior To Cleaning UV Lights
UV Light Cleaning Process — Confined Space (21 like this; not currently treated as confined
spaces)
cf'. FOR Mw 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 2: Photos
Central Contra Costa Sanitary District - Safety Program Assessment
UV Light Cleaning Process — Confined Space (21 like this; not currently treated as confined
spaces)
Ergonomics Improvement at Pumping Station
cP E O R M® 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 2: Photos
Central Contra Costa Sanitary District - Safety Program Assessment
Ergonomics Improvement at Pumping Station
F' EO R Mw 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 2: Photos
Central Contra Costa Sanitary District - Safety Program Assessment
Attachment 3: Benchmarking Data
ffl FORM® 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 3: Benchmarking Data
Central Contra Costa Sanitary District - Safety Program Assessment
Benchmarking Data
Organization
Number of Safety Professionals
Safety Structure Notes
Delta Diablo Sanitation
1 full -time safety professional
Centralized safety responsibility,
also use consultants to supplement
Union Sanitary
1 full -time safety officer
Centralized safety
City of San Leandro
1 Plant Operator handles safety part
Some safety responsibility is shared
time
across the organization
Dublin San Ramon
1 part -time safety specialist
Centralized safety. Safety reports to
HR, use consultants through the
pooling authority to write programs
and provide training
Ironhorse Sanitary
No dedicated safety position
Safety is handled by the
Maintenance Superintendent
Ora Loma Sanitary
1 full -time safety and special
Centralized safety
programs administrator
Orange County Sanitation
6 full time safety representatives
Centralized safety, reports in
through Administration
Irving Ranch Water District
1 full -time safety professional.
Centralized safety, use consultants
to assist
Mesa Water
1 full -time safety professional
Centralized safety, reports to Risk
Management in Finance
Long Beach Water
3 full time safety professionals
Centralized safety
Orange County Water District
1 full -time safety professional plus
Centralized safety
1 intern
T FORM® 12.1007 CCCSD Safety Program Assessment Final 071813: Attachment 3: Benchmarking Data