Barry Holliday Dredging Contractors of America Dredging 2012 Conference October 22-25, 2012 S an Diego, CA
� Mission & Goals � Membership � Partnering � Work Products � Rulemakings � Issues � US ACE EM 385-1-1 S afety Manual Rewrite
Our Mission To improve safety standards and best practices for the dredging and marine construction industry. Our Goals • Promote a culture of safety at all levels • Resolve safety issues • Apply lessons learned • Enhance marine safety training • Foster the development of safety management systems
Membership Open to all Industry contractors, labor unions, Federal agencies, safety professionals and trade associations. Current Members
CDMCS Members Partner on Safety • Discussing Accident/ Inj ury Trends and Positive Developments • S haring Best Practices • Coordinating Revisions to the Corps S afety Manual • Monitoring Regulatory Rulemakings and Coordinating Individual/ Group Public Comments • Developing S afety Bitts and Toolbox Topics • Tackling Tough Issues
Monitoring Safety Rulemakings • Automatic Identification Systems & Notice of Arrival/Departure o Final Rule – Fall 2012 ~ US CG o Purpose = to identify and track vessels in the interest of national security, improve safety on the water, and heighten maritime domain awareness o Expands AIS applicability beyond VTS areas to all U.S . navigable waters o Expands AIS applicability to additional commercial vessels, incl. dredges and floating platforms o Expands NOAD applicability to all commercial vessels under 300 GT , all foreign commercial vessels, and all U.S . commercial vessels coming from a foreign port
Monitoring Safety Rulemakings • Confined Spaces in Construction (OSHA) Final Rule – Fall 2012 o Purpose = to protect construction workers operating in confined spaces o Extends to the construction industry regulations that currently cover the general industry o • Tracking Workplace Injuries and Illnesses (OSHA) Proposed Rule – Fall 2012 – OMB review extended o Purpose = to improve recordkeeping and prevent inj uries/ illnesses through continuous real- o time (rather than once/ yr.) collection of inj ury/ illness data in a modern, electronic format • Injury & Illness Recording & Reporting Requirements (OSHA) Public Comment Analysis S tage o Purpose = to facilitate timely investigation of incidents & quick mitigation of hazards o Current reporting rule – 8 hrs. - fatalities, 8 hrs. - in-patient hospitalizations of 3 or more o employees Proposed reporting rule – 8 hrs. - fatalities, 8 hrs. - all in-patient hospitalizations , 24 hrs. – all o amputations
Monitoring Safety Rulemakings • Towing Vessel Inspections (USCG) o Final Rule – Later this year, exact date TBD (directed by CG Transportation Acts of 2004 and 2010) o Purpose = to promote safer work practices and reduce casualties on towing vessels by setting a variety of operational and machinery-related standards o S afety compliance can be achieved by either adopting an audited safety mgmt system or undergoing annual CG inspections o Dredging industry supports the 2 options for compliance – greater flexibility o Proposed Rule retains exemptions for 1. towboats < 26ft. and 2. workboats intermittently moving equipment exclusively within a dredging or construction worksite – however, this may go away in future as CG staggers implementation
Cranes and Derricks in Construction Final Rule (OSHA) • Effective November 9, 2010 • Significant New Requirements • Pre-erection inspection of crane parts • Working safely near power lines • Crane operators must be qualified and/ or certified • Crane Operator Certification/Qualification Issue • OS HA granted 4 year phase-in for crane operator certification; US ACE did not • Existing accredited certification companies are geared toward land-based crane operators, not marine; their timed exams are inappropriate for operators of floating cranes • 2 Options for Industry to Certify/Qualify Crane Operators : 1) Use an accredited crane testing organization (NCCCO,NCCER, CIC, etc.) or 2) Use a 3 rd party or in-house Qualified Person (until Nov 14, 2014, at which time a cert ified auditor that is not an employee of the company must be used), as long as the employer training program is audited. Not e : if a lack of certified auditors persists past Nov 14, contractors will be allowed to continue using in-house Qualified Persons.
Site Safety & Health Officer Requirements on USACE Jobsites • Variable interpretations and enforcement of language in 2008 EM385-1-1 by USACE Districts created confusion regarding duties, experience, training, etc. • USACE and Industry revised contract language for dredging jobs • Effective in UFGS, Guidance sent to the Districts • What are the new requirements? • S S HO for one shift, Alternate S S HO with collateral duties covers other shifts • S S HO can be a collateral duty aboard hopper dredges and on dredges with a workforce crew less than 8/ shift • 1 S S HO per proj ect site, unless specified differently in advance by District • Experience requirement lowered from 5 to 3 yrs., its definition expanded • Designated Rep. required at all remote work locations > 45 min. from S S HO location • US ACE to include this new spec language in the EM385 S afety Manual
Swimming to Perform Coastal Surveys • Prohibited on all USACE project sites per EM385-1-1 • Yet, swimming had become a practice by both industry and the Corps • Was a method for extending the topographic survey without jeopardizing crews aboard survey boats • USACE granted waivers to industry, when following interim swimming guidance • After review and industry feedback, USACE decided to continue prohibiting swimming in the interest of safety; industry should pursue technological solutions and/or coordinate other options with the Division Chiefs • New Draft Language in Corps Safety Manual reads as follows: “Swimming and/or diving shall be prohibited for all personnel, except certified divers in the performance of their duties, unless necessary to prevent injury or loss of life.”
Underwater Utilities in the Dredging Footprint • Pipeline/ cable crossings & ownership data in contracts and permits are often inaccurate � creating hazards for crews, vessels, environment, local communities; increasing proj ect costs • Utility company cooperation on safety is inconsistent and unreliable. • Contractor cannot hold utility company responsible for economic damages (proj ect delay and labor/ material downtime) resulting from faulty markings or a lack thereof ( Excavat ion Tech. v. Columbia Gas of P A, 2009) • US ACE issued Utility Line Guidance to the Field on May 31 • Calls for greater coordination & info sharing between Regulatory and Navigation in the Districts • Instructs Regulatory to provide copies of all permits to National Ocean S ervice • Requires depth and toe data for future permits • Emphasizes US ACE’s power to make utility owner remove/ relocate line if safety hazard • US ACE and Industry working to include language in EM385-1-1 rewrite, seeking Guidance Letter from HQ, & considering improved contract spec language
Poorly Marked/Unmarked Underwater Utilities are a Serious Threat to Human Life and the Environment
USACE EM 385-1-1 (2008) Rewrite • A comprehensive rewrite with a high degree of industry participation • US ACE, DCA, AGC and CDMCS all working together • Rewrite schedule includes 3 rounds of drafts • Currently awaiting release of Draft #2 on Nov. 5, comments due by end-Jan. • Expect a summer publication • Key areas under review: S ection 1 - Program Mgmt., S ection 16 Cranes & Hoisting Equip., and S ection 19 – Floating Plant
How Can I Get Involved? • S end request through CDMCS ’ Contact Us page at www.cdmcs.org. • Attend a quarterly meeting as a guest. • $500 for first year, $250/ yr. thereafter – grants full access to member products • Come attend our quarterly meetings.
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