Contractor Safety

Accidental spills and releases

In the event of an accidental release or spill of chemicals, or other hazardous materials by the contractor, the contractor shall:

• Immediately take action as appropriate to contain the spill (if this action can be taken without jeopardizing the health or safety of employees;
• Notify the rescue squad, fire department, or other entities as needed or requested by calling 911;
• Contact Environmental Health & Safety at 540-231-3600 (or via calling 911 after hours); and
• Contact the university project manager.

All university costs associated with responding to, or remediating of, a chemical or hazardous material spill or release may be assessed to the contractor.

Emergency Notification System

VT Alerts if Virginia Tech’s emergency notification system. In the event of a campus emergency, Virginia Tech will use several information delivery methods to reach personnel. To sign up for VT Alerts, refer to Virginia Tech Emergency Management’s website at emergency.vt.edu.

First aid services

The Virginia Tech Rescue Squad will provide an emergency medical response to construction projects; however, the Rescue Squad cannot guarantee a minimum response time as required by OSHA, and may not be named in lieu of the contractor providing adequately trained personnel on-site.

Means of egress

The contractor shall not conduct work or operations that obstruct exits or the means of egress from an occupied building without the prior approval of Environmental Health & Safety and the university project manager. Equipment and materials are not to be stored in exits or exit stairwells at any time, and may not be stored in the means of egress without prior approval. Fire-rated doors shall not be chocked or blocked open, except temporarily and while constantly supervised; such chocks/blocks must be immediately removed in the event of a building fire alarm or similar emergency. Contact Environmental Health & Safety at 540-231-4207 for more information.

Fire protection and suppression systems

The contractor shall not conduct any work that disables or alters the functionality or technical specifications of fire protection and suppression systems without prior approval of the university project manager. Environmental Health & Safety must be notified and will secure any external approvals, as required. These systems include but are not limited to, fire-rated assemblies and enclosures, smoke barriers and partitions, fire alarm panels, exit signs and emergency lighting, sprinkler, and other suppression systems, heat and smoke detection, fire hydrants, fire department access, and fire pumps. Contact Environmental Health & Safety at 540-231-4207 for more information.

Building alarms

In the event of a fire, sound the alarm and/or notify other building occupants immediately. Call 911 and report as much information as possible to the dispatcher. Contractor personnel shall respond appropriately to all alarms by exiting the building immediately and remaining at least 50 feet from the building to allow for emergency response access.

Compressed gases

Compressed gases shall be stored, used, and transported in accordance with the requirements of the Virginia Statewide Fire Prevention Code (VSFPC). New compressed gas installations shall comply with the VSFPC.

Temporary structures

All tents, stages, and temporary structures shall comply with the requirements of university Policy 5406. 

Temporary traffic control

Work that falls under the Virginia Work Area Protection Manual (VWAPM), such as road/lane/sidewalk closures, minor road encroachments, or bicycle paths, must implement temporary traffic control measures in accordance with the VWAPM to properly regulate, warn, and guide vehicular, non-motorized, and pedestrian traffic on campus. Flagging operations must comply with VWAPM.

University equipment

University equipment (ex. forklifts, aerial lifts, ladders, etc.) should not be loaned to contractors for liability and/or specialized training purposes. Contractors should provide the necessary equipment to perform the job.

All agencies/firms conducting work on Virginia Tech property shall comply with the requirements of VDLI, OSHA and this program, even where no formal contractual relationship exists between Virginia Tech and the agency/firm. The agency/firm shall maintain appropriate insurance, including general liability, auto liability, and workers compensation insurance. Verification of insurance shall be coordinated with Virginia Tech's director of risk management, who may be reached at 540-231-7439, prior to the start of work. Such agencies/firms shall not, without prior written approval of Environmental Health & Safety:

• Use a product(s) or material(s) that has a permissible exposure limit (PEL) established by OSHA or VDLI;
• Damage or disturb any known or suspect asbestos materials or suspect lead-containing materials;
• Enter into a confined space;
• Work on any electrical system or utility;
• Perform excavation or trenching activities;
• Perform hot work operations; and/or
• Access roofs of buildings.

If a hazardous condition is identified by Environmenteal Health & Safety during such work, it shall be immediately corrected.  If it cannot be immediately corrected, the agency/firm shall stop work and shall take effective steps to isolate the hazardous condition from personnel and the public. Repeat safety violations of a similar nature or willful disregard for VDLI/OSHA requirements, or the requirements outlined in this program will result in immediate removal from Virginia Tech property.

Worksite inspections may be conducted by Environmental Health & Safety or other designated university personnel. These inspections are conducted solely for the benefit of the university, and shall not relieve the contractor of responsibility for enforcement of, and compliance with, VDLI and the OSHA regulations. 

In worksite conditions exist that potentially impact the safety of university employees, students, or the public, the university inspector shall issue a verbal or written warning to the  contractor and shall notify the university project manager. If the unsafe conditions cannot be immediately corrected and represent a danger or have the potential to harm university employees, students, or the public, then the university inspector will:

• Assure that other university personnel, students, or the public present onsite are warned to avoid the area of the hazardous condition;
• Detail the VDLI and/or OSHA violations that were noted, and explain the potential impact upon university employees, students or the public; and
• Require that the university project manager have the contractor either stop work or implement measures to isolate the hazardous condition until the unsafe condition can be mitigated.

A formal written report of the violation(s) may be issued to the contractor. This report shall be copied to the university project manager.

Contractor Safety Program Definitions

• Contractors are responsible for providing awareness level training for their employees.  Training shall include but is not limited to, the information contained in this section and that specified by OSHA in 29 CFR 1926.1101. Training records must be available upon request to the university. 
• Contractors employed by the university to perform building or facilities-related maintenance, repair, or renovation shall be informed by the university project manager of the location of known or suspect asbestos-containing materials (ACM) in the work area(s) to which they are assigned. Designated departmental safety coordinators shall supply this information to the project manager by means of: 
  • A copy of a completed Asbestos and Lead Survey Report specific to the scope of work and materials that are to be disturbed, or 
  • Construction documents that clearly detail ACM locations within the work area.
• Contractors shall under no circumstances damage or disturb suspect or known friable ACM unless they are a licensed Virginia asbestos abatement contractor and have been specifically employed to perform asbestos repair or removal for the university. 
• If suspect ACM is discovered during the course of the work, the contractor shall stop work immediately and notify the university project manager (or as indicated in contract documents). 
• The contractor shall not proceed with any change in work, which requires a material to be disturbed, that the Asbestos and Lead Survey Report, or construction documents, that have not previously been tested or disclosed.  If a change in the scope of work becomes necessary, the revised scope of work shall be reviewed, and the Asbestos and Lead Survey Report or construction documents revised to reflect any changes. 
• Asbestos materials shall not be used or installed in university facilities.

• The university project manager shall coordinate with the departmental principal investigator and lab manager to ensure that no active manipulation of biohazardous materials will occur during the course of contractor access.
• If work will be conducted on the roof systems of a building where biological research occurs, the university project manager shall coordinate access with the Division of Campus Planning, Infrastructure, and Facilities, the departments, and/or facility managers within the building, and Environmental Health & Safety as necessary to ensure that:
  • No experiments are in progress that would generate toxic or infectious airborne contaminants and that all biohazardous materials are contained while the contractor will be performing work on these systems; 
  • Contractor is informed of any special precautions that must be taken to prevent employee exposure to biohazards; 
  • Contractor is informed of emergency procedures that the contractor is to follow in the event of accidental exposures during the course of the work; and 
  • Contractor is provided a copy of Virginia Tech’s roof access procedure upon request, which outlines the precautions that should be taken to protect its employees while conducting such work. This information may be obtained by contacting Environmental Health & Safety at 540-231-3427.

• The contractor shall maintain Safety Data Sheets (SDS) on-site for all chemicals used or stored at the job site as required by VDLI/OSHA regulations and the contract documents. Copies of SDS shall be provided to the university project manager and EHS upon request.
• When work will be performed in areas with chemical hazards, such as chemical laboratories, chemical stock rooms, chemical waste accumulation areas, custodial closets, etc., the university project manager shall inform the contractor of the following:
  • Known hazards and any required safety procedures that must be followed in the work area; 
  • Methods for obtaining access to SDSs for hazardous chemicals present in the work area; 
  • Information regarding any labeling system used in the work area; 
  • Emergency procedures that the contractor is to follow in the event of accidental exposures or releases of hazardous chemicals.
• Where the contractor has taken air samples documenting employee exposure to airborne chemical or particulate hazards during the course of work, a copy of results must be provided to Environmental Health & Safety within 24 hours of receipt.
• Access to building roofs with fume hood exhausts must be in accordance with Environmental Health & Safety's roof access procedure. This information is available at 540-231-3427.

• Where confined spaces must be entered prior to having a formal agreement with the university, a Visitor Confirmation of Confined Space Program Compliance form must be completed by the entrant and submitted to the Project Manger prior to entering. 
• Contractors shall be informed by the Project Manager that work will occur in a confined space, and that entry is allowed only through compliance with a Confined Space Program meeting the requirements in 29 CFR 1926 Subpart AA or 29 CFR 1910.146, as applicable for the scope of work.
  • A copy of the Contractor’s Confined Space Program must be provided to the university project manager and Environmental Health & Safety upon request. 
  • Copies of canceled entry permits shall be provided to the university project manager and Environmental Health & Safety upon request. 
  • Where rescue services are required, the contractor shall inform the university project manager in writing whom they will be used during entry.
• Contractors shall be informed of the elements involved with the confined space, any hazards identified by the department, and the university’s experience with space prior to entry. Any precautions or procedures that the university has implemented for the protection of its personnel shall also be conveyed to the contractor.
• Contractors shall provide at least 24-hour advance notice to the university project manager when contractor personnel will be working in a confined space on campus.
• Where contractor and university personnel will be working in or near the same confined space, Environmental Health & Safety must be notified at 540-231-2341, and entry precautions and procedures shall be coordinated.
  • Each group shall independently assess, test, and issue permits for entry. Neither entity shall rely upon the other to perform the required assessment or testing.
• Any hazards confronted or created in the confined space during entry shall be communicated to Environmental Health & Safety the department, and the university project manager.
• Virginia Tech’s Confined Space Entry Program is available online.

• The contractor shall take all reasonable precautions necessary to control fugitive emissions from the job site. Fugitive emissions include, but are not limited to, nuisance dust, chemical odors/vapors/gases, hazardous materials (such as asbestos fibers or lead dust), and excessive noise.
• Where the product(s) or material(s) to be used by the contractor has a Permissible Exposure Limit (PEL) established by OSHA or VDLI, and where university employees or the public may be exposed to the product/material, the contractor shall take all reasonable steps to maintain exposures below the PEL where an exposure condition during use exceeding the PEL could reasonably be anticipated.  
• Where it is anticipated that the PEL could be exceeded, or when building occupants report objectionable concentrations of an air contaminant or possible health effects from said exposure, the contractor shall monitor, or shall contract to have monitored, these work areas and/or building exposure conditions.
  • Monitoring shall occur, at a minimum, during the start of work and whenever there is a change in procedure, process, or chemical/material used, and in response to the building occupant concerns where applicable.
  • If feasible control measures are not practical to maintain exposures below the PEL, the contractor shall restrict access to all areas where exposures exceed the PEL to authorized personnel only.
  • Copies of this air monitoring data shall be provided to the university project manager or their designated representative upon request.

• Project managers shall coordinate access to electrical systems, work scheduling, pre-planning for power outages in a building, and coordination of safety requirements between contractors/subcontractors and university personnel, where appropriate.
• Contractors shall coordinate requests for shutdowns and/or power outages with the university project manager, the department affected, and the Division of Campus Planning, Infrastructure, and Facilities, as appropriate.
  • At least a two-week notice shall be provided for shutdowns/outages affecting a building or department so that temporary power, work schedules, or other necessary arrangements can be made to minimize the interruption of departmental activities and ensure the safety of personnel performing the electrical work.
• Contractors shall establish a Limited Approach Boundary to protect unqualified or unauthorized personnel when energized electrical equipment or components greater than 50 volts will be exposed in occupied buildings.

The storage and use of explosives, blasting agents, and pyrotechnic devices are strictly regulated and shall comply with all state and federal laws. A fee, blasters certification, and background check may be required to obtain a permit. Contact the Virginia State Fire Marshal’s Office at 276-646-0266 for more information.

• The university project manager shall inform the contractor of any fall protection system(s) installed in the work area, or of the absence of such systems, so that temporary controls may be considered by the contractor.  
• Anchor points installed on university properties may only be used for the purpose and manner for which they were designed (i.e. personal fall arrest or restraint).  
• Where contractors will be using available mobile anchor points on Virginia Tech building roofs, the university will provide manufacturer-specific information to the contractor prior to use. 
• The contractor is responsible for providing employee protection in accordance with 29 CFR 1926.502 on unguarded roofs, open-sided floors, loading areas, etc.

• Contractors shall assure that all hazardous chemicals or materials are handled and disposed of in accordance with federal and state regulations. For assistance, contact Environmental Health & Safety at 540-231-2982, 540-231-2510, 540-231-6321, or 540-231-3220.
  • The contractor shall not ship any “hazardous” or “universal” wastes without Environmental Health & Safety notification and approval. Proper paperwork with correct EPA identification numbers, addresses, and emergency contact information must be submitted. 
  • Where a hazardous waste disposal manifest is required by regulation, the contractor shall contact the  hazardous material program manager at 540-231-2982 to assure that manifesting, storage, and the proposed disposal method and site meet university requirements. 
  • Bills of Lading manifests, and LDRs must be signed by the hazardous material program manager, or designated representative, for all shipments of “hazardous” or “universal” waste, excluding asbestos. Refer to construction specifications for asbestos abatement for relative information.
• Hazardous waste includes such items as:
  • Bulbs: The following procedure is to be used for 4- and 8-foot fluorescent bulbs, High-Density Discharge Bulbs (mercury bulbs), and U-tubes:
    • Bulbs should be placed in manufactured boxes.
    • When the first bulb is put in the box, a Universal Waste Label shall be placed on the outside of the box. Fill in contents and date.
    • When not actively putting bulbs in the box, the lid shall be closed and sealed.
    • Keep boxes inside, in a dry location, away from water.
    • Environmental Health & Safety will not approve the use of a fluorescent bulb crusher. 
  • Mercury-contaminated materials: All mercury-contaminated materials must be treated as “hazardous” waste and disposed of according to state and federal regulations. All sink traps located within research buildings are suspected to potentially be contaminated with some mercury. Anyone working on sink traps/drains on campus should wear appropriate personal protective equipment, such as eye protection, face shield for splash protection, gloves, and disposable coveralls, as applicable. Contact Environmental Health & Safety if these items are discovered. 
  • Ballasts: PCB and non-PCB ballasts shall be placed into UN-approved 55-gallon drums for disposal and shipped on a hazardous waste manifest. The lid on the drum shall be secured unless actively adding to the drum. There is a one-year time limit to dispose of the drum, beginning when the first ballast went into it.  
    • Ballasts are considered to be PCB ballasts if the label says it is, or the label does not say “No PCBs.”
    • Non-PCB ballasts will have “no PCBs” written on the ballast. These should be placed in a separate drum (UN-approved) for recycling. 
  • Broken Fluorescent/HIDs/U-Tubes that are unintentionally broken shall be placed into an UN-approved poly drum. These may be considered “hazardous” waste and should be treated as such due to the possible release of mercury vapors.
    • When not actively adding to the drum, the lid shall be on and secure.
    • The drum must be labeled “Broken Fluorescent Bulbs” and indicate the date the first bulb was placed in the drum.
    • There is a one-year time limit to dispose of the drum, beginning when the first ballast went into it.  
  • Lead Paint: Waste from scraping, grinding, or peeling is considered “hazardous” waste and shall be stored in an UN-approved drum with the lid securely fastened. This drum must be labeled as “Lead Paint Chips,” and locked in an area away from public access.
    • Core samples from suspected lead-based paint containing materials, such as walls, doors, and door casings, shall be taken prior to demolitions and sent for TCLP analysis. An Environmental Health & Safety representative shall be present for any sampling activities.
    • All sampling results shall be copied to Environmental Health & Safety for proper waste disposal determination. 
  • Miscellaneous chemicals: Any chemical found during demolition shall be handled as “hazardous” waste.  Examples include cylinders, bottles, cans with liquid, spill cleanup, etc.

Contractors performing hot work (i.e. use of open flames, welding, cutting, brazing, soldering, grinding, compressed gases, supplied fuel burning, thawing pipe, or torch-applied roofing) shall maintain a Hot Work Permit program that meets 29 CFR 1926.352, ANSI Z49.1-88, and NFPA 51B.

• A copy of the canceled permit(s) shall be provided to the university project manager and Environmental Health & Safety, upon request.

• Contractors employed by the university to perform building or facilities-related maintenance, repair, or renovation shall be informed by the university project manager of the location of lead-containing building materials in the work area(s) to which they are assigned. Designated departmental safety coordinators shall supply this information to the project manager by means of: 
  • A copy of a completed Asbestos and Lead Survey Report specific to the scope of work and materials that are to be disturbed, or
  • Construction documents that clearly detail the location of lead-containing building materials within the work area.
• Contractors who will disturb lead-containing building materials during the course of work shall take all necessary precautions to protect university employees and the public from exposure to lead dust or contamination. These measures shall conform, at a minimum, to OSHA requirements detailed in 29 CFR 1926.62 and applicable local, state, and federal regulations related to health, safety, transportation, and disposal of such materials. 
• Contractors shall submit a copy of their lead compliance program for review and approval by either the departmental safety representatives or Environmental Health & Safety upon request. This submittal shall be made sufficiently in advance of construction to avoid delay of the project. 
• Where work will occur in child-occupied facilities (as defined by 40 CFR Part 745), such work shall be performed in accordance with 40 CFR Part 745, and clearance testing shall be performed by the departmental safety representative, Environmental Health & Safety, or a licensed consultant at the conclusion of the project. 
• A copy of the analytical report(s) for any personal air sampling taken during the course of the work must be provided to Environmental Health & Safety. 
• The contractor shall not proceed with any change in work, which requires a material to be disturbed, that the Asbestos and Lead Survey Report, or construction documents, that have not previously been tested or disclosed. If a change in the scope of work becomes necessary, the revised scope of work shall be reviewed and the Asbestos and Lead Survey Report or construction documents revised to reflect any changes. 
• On projects where lead-containing materials will be disturbed or removed, the waste stream shall be TCLP-tested, and the university project manager shall contact the hazardous waste coordinator at 540-231-2982 to determine disposal requirements during the design phase of the project with Environmental Health & Safety.

• Contractors shall comply with 29 CFR 1910.147 when de-energizing hazardous energy sources on campus, such as electrical, mechanical, hydraulic, pneumatic, chemical, steam, gravity, etc.
  • A copy of their Lockout/Tagout Program shall be provided to the project manager and/or Environmental Health & Safety upon request. 
  • Locks and tags must be used when de-energizing hazardous energy sources on campus.
  • Virginia Tech's Lockout/Tagout Program is available online.
• The project manager, in cooperation with the responsible department, shall inform the contractor of available Energy Control Procedures that must be followed for campus equipment. Any questions or concerns regarding the procedure should be communicated to the project manager and Environmental Health & Safety for resolution.

• The Virginia Tech/Montgomery Executive Airport shall be notified as soon as possible when work activities will involve the use of a mobile crane on campus. A "Notice of Proposed Construction or Alteration" may be required to be submitted to the Federal Aviation Administration (FAA), which can take up to 45 days for approval. Forms are available at faa.gov.
• Contractors shall provide copies of their annual and monthly crane inspections to Environmental Health & Safety upon request.
• Contractors shall ensure that the crane, swing radius, and load path is properly barricaded to prevent personnel from being struck or crushed by the crane or the load.
• Where loads will be raised over occupied buildings and the weight of the load could pierce the building envelope if it were dropped, the project manager shall coordinate temporary removal of personnel directly beneath the load during lifting operations.

• If work will be conducted on the roof of a building, the university project manager shall coordinate access with Facilities, the departments of the building (when appropriate), and Environmental Health & Safety as necessary.  
• Roof access shall be in accordance with Roof Access Procedure(s) regarding potential exposure to chemical fume hood systems and exhausts, biological fume hood exhausts, severe noise hazards, radiofrequency towers, and fall hazards may be present.  
  • Refer to building-specific information.
• Fume hoods within, or adjacent to, the work area may be shut down, if necessary.  

• Scaffolding shall comply with 29 CFR 1926.Subpart L and manufacturer’s instructions.
• University personnel who must access contractor scaffolding for purposes of inspection or related work activities shall complete Environmental Health & Safety Scaffold Awareness level training prior to access. 
• Contractors shall make routine and periodic inspection data available to university personnel upon request.

• Contractors shall take all necessary steps to comply with the exposure limits for silica established in 29 CFR 1926.1153. Your written Exposure Control Plan must detail how potential exposure to Virginia Tech personnel and the general public in adjacent areas will be kept below allowable limits. A copy of this plan shall be provided to Environmental Health & Safety and/or the university project manager upon request.
• Where tasks are performed indoors or in an enclosed area, exhaust shall be provided as needed to minimize the accumulation of visible airborne dust.  If the exhaust is vented where building occupants or the general public may be exposed, the system must incorporate HEPA filtration.
• If the building ventilation system provides air to an area where “restricted work” is being performed, the air returns shall be blanked or closed while such work is in progress.
• A “temporary restricted area” must be established where tasks performed in accordance with Table 1 of 29 CFR 1926.1153 require that respiratory protection be used, or where tasks are performed that are not listed in Table 1, and where no historic or objective data exists to prove exposures will be below the action level.
  • Temporary Restricted Areas must be designated with signs, barriers, or other effective means that will assure unauthorized persons do not enter.
  • If such work is performed in occupied buildings, dust barriers shall be installed as necessary to isolate the restricted area.

• Contractors shall follow 29 CFR 1926.650 for trenching and excavation work conducted on campus.  
  • The contractor shall ensure that a “competent person” will be onsite to oversee such activities.
  • Inspections shall be conducted by the “competent person” and made available upon request to university personnel who may need to enter to perform inspections or other activities.
    • University personnel who must enter excavations/trenches should coordinate a pre-inspection by a university “competent person” prior to entry.
    • Contractors shall be notified prior to university personnel entering excavations/trenches on projects. 
  • Where the design of protective systems requires review and approval by a registered professional engineer, the contractor shall provide a copy of the documentation to the project manager and/or Environmental Health & Safety upon request.
• Contractors are responsible for contacting Miss Utility prior to digging/excavating.
• Where heavy equipment will be in the vicinity of overhead power lines, the project manager shall notify the Virginia Tech Electric Service and coordinate any special precautions that must be implemented.

Frequently Asked Questions

Airport Notification of Crane Activities

Appendix A

Confined Space Program Compliance Form

Contractor Safety Guide

Equipment Decontamination Form

Lab Access Form