Environmental and Occupational Safety and Health (EOSH

Distribution: A-FAF-0 (STD)

Initiated By: AJW-23

1. The Federal Aviation Administration (FAA) is subject to numerous federal, state, and local

requirements in the areas of environmental protection and employee safety. Consistent with the

FAA’s mission to be the national and international leader in aviation, while fostering a safe, secure,

and efficient aviation system, is the need for an effective process to incorporate environmental and

occupational safety and health requirements in the planning, design, construction, maintenance and

decommissioning activities at NAS facilities.

2. This order prescribes policy, delegates authority, and assigns responsibility for ensuring agency

compliance with environmental and occupational safety and health requirements. This order is in

concert with the following:

a. FAA Order 1050.10C, Prevention, Control and Abatement of Environmental Pollution at

FAA Facilities, establishes agency wide policy, roles, and responsibilities pertaining to the prevention,

control, and abatement of environmental pollution at, or from, FAA-owned, -leased, -licensed, or

-operated facilities.

b. FAA Order 1050.17, Airway Facilities Environmental and Safety Compliance Program,

prescribes procedures and assigns responsibilities within the Air Traffic Organization (ATO) for the

implementation of FAA Order 1050.10C.

Teri L. Bristol

Chief Operating Officer

Air Traffic Organization

SUBJ:

Environmental and Occupational Safety and Health (EOSH) Requirements in the Planning

and Execution of Construction and Maintenance Activities at National Airspace System

(NAS) Facilities

Air Traffic Organization Policy

ORDER

JO 3900.57A

CHG 1

Effective Date:

02/2

5/2015

02/25/2015 JO 3900.57A CHG 1

Table of Contents

Paragraph Page

Chapter 1. General Requirements

1-1. Purpose of This Order ................................................................................................... 1-1

1-2. Audience ....................................................................................................................... 1-1

1-3. Where Can I Find This Order ....................................................................................... 1-1

1-4. Cancellation .................................................................................................................. 1-1

1-5. Explanation of Policy Changes ..................................................................................... 1-1

1-6. Effective Date ............................................................................................................... 1-1

1-7. Roles and Responsibilities ............................................................................................ 1-1

1-8. Safety Risk Management .............................................................................................. 1-3

1-9. Requirements/Summary of Policy ................................................................................ 1-3

Chapter 2. Planning

2-1. General .......................................................................................................................... 2-1

2-2. Responsibility ............................................................................................................... 2-1

2-3. Project Planning ............................................................................................................ 2-1

2-4. Environmental Processes .............................................................................................. 2-2

Chapter 3. Design and Acquisition

3-1. General .......................................................................................................................... 3-1

3-2. Responsibility ............................................................................................................... 3-1

3-3. Design Phase ................................................................................................................. 3-1

3-4. Acquisition Phase.......................................................................................................... 3-1

Chapter 4. Construction

4-1. General .......................................................................................................................... 4-1

4-2. Responsibility ............................................................................................................... 4-1

4-3. Pre-Construction EOSH Checklist ................................................................................ 4-1

4-4. Permits .......................................................................................................................... 4-2

4-5. Resident Engineer Construction Safety Checklist ........................................................ 4-3

4-6. Deliverables .................................................................................................................. 4-3

Chapter 5. Maintenance

5-1. General .......................................................................................................................... 5-1

5-2. Responsibility ............................................................................................................... 5-1

5-3. Facility Risk Prioritization ............................................................................................ 5-1

5-4. Activity Risk Prioritization ........................................................................................... 5-1

5-5. Pre-Maintenance Checklist ........................................................................................... 5-2

Chapter 6. Decommissioning and Disposition

6-1. General .......................................................................................................................... 6-1

6-2. Responsibility ............................................................................................................... 6-1

6-3. Real Property ................................................................................................................ 6-1

6-4. Reutilization and Disposition of Personal Property ...................................................... 6-2

02/25/2015 JO 3900.57A CHG 1

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Chapter 7. Administrative Information

7-1. Distribution ................................................................................................................... 7-1

7-2. Background ................................................................................................................... 7-1

7-3. Authority to Change This Order ................................................................................... 7-1

7-4. Definitions and Acronyms ............................................................................................ 7-1

7-5. Related Publications...................................................................................................... 7-1

7-6. Forms and Checklists .................................................................................................... 7-3

Appendix A. Acronym List

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Chapter 1. General Requirements

1-1. Purpose of This Order. The purpose of this FAA order is to prescribe FAA’s environmental

and occupational safety and health (EOSH) policy, delegation of authority, and assignment of

responsibility to ensure agency compliance, and establishing effective processes that incorporate

EOSH requirements in planning, design, construction, maintenance and decommissioning of National

Airspace System (NAS) systems and facilities that will foster a safe, secure and efficient NAS.

1-2. Audience. Air Traffic Organization (ATO) headquarters and field organizations that are

involved with the operation and support of NAS facilities. At the headquarters level, these

organizations include System Operations Services (AJR), Safety and Technical Training (AJI), Air

Traffic Services (AJT), Mission Support Services (AJV), and Technical Operations Services (AJW).

At the field level, this includes the Service Center, Service Areas, and all of the organizations

subordinate to the Service Areas involved with the operation and/or support of NAS facilities.

1-3. Where Can I Find This Order. You can find an electronic copy of this order on the Directives

Management System (DMS) website: https://employees.faa.gov/tools_resources/orders_notices/, or

go to the MyFAA Employee website, select ‘Tools and Resources’, then select ‘Orders and Notices’.

1-4. Cancellation. FAA Order 3900.57, FAA Pre-Construction and Maintenance Project Safety and

Health Checklist, dated January 11, 1999, is canceled.

1-5. Explanation of Policy Changes. The order has been revised to include:

a. Roles and Responsibilities. Provides updated roles and responsibilities reflecting current

FAA organizational structure and assignment of program responsibilities.

b. Project Management. Requires the review of EOSH requirements prior to budget planning

and the completion of checklists for design, construction, and maintenance activities that have the

potential to generate EOSH impacts to FAA employees and NAS operations. The order addresses

project management aspects of EOSH planning and requirements throughout the facility lifecycle.

c. EOSH Requirements. Establishes a process that will minimize and/or eliminate EOSH

impacts from design, construction, and maintenance projects at NAS facilities. The order addresses

EOSH requirements in order to minimize NAS outages, environmental impacts, and employee safety

risks.

1-6. Effective Date. The requirements of this directive are to become effective six months after

publication.

1-7. Roles and Responsibilities.

a. Chief Operating Officer, AJO-0, ensures that ATO organizations implement the

requirements of this order into the planning and execution of their programs and activities.

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b. Vice President, Office of Safety and Technical Training, AJI-0, implements the

requirements of this order into training programs and other activities managed by his or her

organization, including any interaction of this order with the Safety Management System (SMS).

c. Vice President, System Operations, AJR-0, implements the requirements of this order into

programs and activities managed by their organization.

d. Vice President, Air Traffic Services, AJT-0, implements the requirements of this order into

the planning, design, and deployment of new systems as well as the modernization and/or

refurbishment of existing NAS facilities; and implements the requirements of this order into planning

for lifecycle requirements.

e. Vice President, Mission Support Services, AJV-0, implements the requirements of this

order into programs and activities managed by their organization.

f. Vice President, Program Management Organization, AJM-0, implements the

requirements of this order into programs and activities managed by their organization.

g. Vice President, Technical Operations Services, AJW-0, implements the requirements of

this order into the design and deployment of new systems as well as the modernization and/or

refurbishment of existing NAS facilities; implements the requirements of this order into planning for

lifecycle requirements; and ensures compliance with the requirements of this order by field

organizations in AJW.

h. Service Area Directors for AJT and AJW. The ATO Service Area Directors, or designees,

implement the requirements of this order by field organizations.

i. Service Center Directors. The ATO Service Center Directors, or designees, assist the ATO

Service Area Directors for AJT and AJW in implementing the requirements of this order; and

implement the requirements of this order into the processes for the planning of projects.

Implementation support may include the formulation and review of budgets and requirements, and

technical support on EOSH topics.

j. ATO Technical Operations Services, Air Traffic Control (ATC) Facilities, EOSH

Services Group ensures EOSH requirements are incorporated into all new NAS systems in order

to maximize employee safety, minimize negative impacts to the environment, and comply with

federal regulations. EOSH Services ensures compliance with the requirements of this order for

applicable activities.

k. Engineering Services Managers, AJW, implement the requirements of this order into the

design and deployment of new systems as well as the modernization and/or refurbishment of existing

NAS facilities and implement the requirements of this order into planning for lifecycle requirements.

l. District Office Managers, AJW, ensure compliance with the requirements of this order for

applicable activities.

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m. Technical Support Center Managers, AJW, ensure compliance with the requirements of

this order for applicable activities.

1-8. Safety Risk Management. The FAA SMS requires that safety assessments be performed on

changes to the NAS that have significant safety impact on aviation safety. The SMS does not address

occupational safety (e.g., Occupational Safety and Health Administration (OSHA)). Instead, the SMS

focuses on the broader topic of aviation safety and safe provision for air traffic control and navigation

services. This order is subordinate to the SMS.

1-9. Requirements/Summary of Policy. This order is organized by life-cycle of the facility

(design, establish, improve, maintain, decommission). The purpose of the order is to ensure that

EOSH requirements are incorporated into both project planning and execution throughout the facility

lifecycle.

a. Planning. Chapter 2 contains the requirements for the planning phase. Appropriate project

planning for EOSH issues and requirements will reduce risks to FAA employee safety, and impacts

on the environment. The requirements of this chapter will be carried out by the organization

implementing the project (e.g., Engineering Services Managers for Engineering Services projects,

national Program Offices for turnkey projects managed by Headquarters, and the appropriate front line

manager for local projects).

b. Design and Acquisition. Chapter 3 contains the requirements for the design and acquisition

phases. The chapter introduces aspects of sustainable design and affirmative procurement

requirements for projects and programs. The requirements of this chapter will be carried out by the

organization implementing the project (e.g., Engineering Services Managers for Engineering Services

projects, national Program Offices for turnkey projects managed by Headquarters, and the appropriate

front line manager for local projects).

c. Construction. Chapter 4 contains the requirements for the construction phase. The chapter

outlines requirements for pre-construction coordination of EOSH issues, as well as EOSH

considerations during construction. The requirements for construction safety and environmental

issues during construction are the responsibility of the organization directly managing the project, with

the assistance and coordination of EOSH professionals in their organization. The organization

managing the project should coordinate with EOSH professionals in the Service Center, District

Office, and/or the Safety and Environmental Compliance Manager (SECM) at the Technical Support

Center.

d. Maintenance (In-Service Management). Chapter 5 contains the requirements for the

maintenance phase. The requirements of this chapter will be carried out by the organization

implementing maintenance.

e. Disposition. Chapter 6 contains the requirements for the disposition phase, which includes

decommissioning and demolition. The requirements for safety and environmental issues during

demolition or decommission are the responsibility of the organization directly managing the project,

with the assistance and coordination of EOSH professionals in Engineering Services, the Service

Center, District Office and/or the SECM at the Technical Support Center.

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Chapter 2. Planning

2-1. Overview. The planning phase of a construction project must consider EOSH requirements

relative to the risks to NAS operations. Early EOSH planning helps to manage possible issues over

the lifecycle of the facility. Lifecycle engineering is part of project planning, and every project from

conception through completion must include multidisciplinary EOSH expertise. Proper planning can

reduce hazardous wastes and liability concerns, improve public and stakeholder perception, improve

employee and contractor safety, and lessen overall costs to the FAA.

2-2. Responsibility. Engineering Services Managers ensure the requirements of this chapter are

incorporated into all applicable projects managed by Engineering Services. For turnkey projects

managed by Headquarters organizations, the national Program Office ensures that the requirements of

this chapter are incorporated into their projects and ensures that sufficient resources are provided in

terms of EOSH technical support. For non-Engineering Services projects managed exclusively by

local facilities and/or field organizations, the appropriate manager (e.g., District Office Manager or

System Support Center [SSC] Manager) ensures that the requirements of this chapter are incorporated

into applicable projects (e.g., fence construction, painting, remodeling).

2-3. Project Planning.

a. EOSH Planning Requirements. The organization responsible for planning any construction,

maintenance, or renovation project (e.g., national program office, District Office management) is

required to consider potential EOSH issues. To that end, organizations planning projects may use the

Project Planning EOSH Checklist, FAA Form 3900-16. The purpose of the checklist is to identify

EOSH issues in the project that may impact the design, budget, and schedule. This form identifies

program areas that may be subject to compliance obligations, as well as potential opportunities to

minimize health and safety risk, and environmental impacts, such as waste generation, ecological

degradation, energy consumption, and raw material consumption over the entire life of the project.

The consequences of improper planning for EOSH requirements can be severe, including disruption

of NAS operations, project delays, cost increases, and non-compliance with safety and environmental

requirements. Non-compliance with EOSH requirements puts FAA employees and contractors at risk

and exposes the agency to environmental risks and liability under OSHA regulations (29 CFR) and

U.S. Environmental Protection Agency (EPA) regulations (40 CFR).

b. Elements of the Project Planning EOSH Checklist. During the planning stages of an

engineering, construction, or maintenance project, the organization implementing the project must

consider the potential EOSH hazards and risks in the various program areas listed below and

discussed in FAA Form 3900-16, Project Planning EOSH Checklist. Organizations implementing

projects must consider sensitive NAS operations and all facility occupants impacted by this project, as

well as known or potential EOSH hazards. Any hazards identified in the Project Planning EOSH

Checklist must be addressed through changes in the budget, schedule, or design of the project.

Mitigation may include, but is not limited to, selection of alternative designs and/or sites, and

budgeting for expected costs of hazardous material removal, environmental permitting, or other

EOSH concerns.

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Occupational Safety and Health Areas

Construction Safety

Hazard Communication

Confined Space Entry

Equipment and Tool Safety

Working Conditions

Radiation

Hazardous Energy

Lead

Asbestos

Indoor Air Quality

Climbing, Walking, Working Surfaces

Employee Health Exposure

Vehicle Safety

Respiratory Protection

Personal Protective Equipment

Hearing Conservation

Fire Protection

Environmental Areas

Air Pollution

Water Pollution

Drinking Water

Hazardous Materials

Hazardous Waste

Nonhazardous Solid Waste

Fuel Storage Tank

Polychlorinated Biphenyl (PCB)

Pesticides

Asbestos

Lead

Radon

Natural Resources

Cultural Resources

Environmental Due Diligence Audits

National Environmental Policy Act (NEPA)

Environmental Cleanup/CERCLA

c. EOSH Areas of Concern for Planning Review. The key EOSH requirements for planning,

implementation, and oversight of projects at ATO facilities include the following:

Figure 2-1. EOSH Areas of Concern for Planning Review

2-4. Special Environmental Compliance Topics. The organization responsible for the siting and

planning phase implements the following environmental processes as required by law, regulations,

and FAA orders. The organization implementing the project must initiate the request for the

following environmental processes with the appropriate EOSH professionals (i.e., Engineering

Services EOSH Coordinator, SECM, or Program Office) as early as possible, and no later than at

receipt of the project authorization. Compliance with the National Environmental Policy Act (NEPA)

and environmental due diligence audit (EDDA) requirements may pose significant impacts on project

design, budget, and schedule.

a. NEPA. NEPA requires federal agencies to systematically identify and evaluate potential

environmental impacts associated with implementing major federal actions. The organization

implementing the project must comply with NEPA and commence NEPA analysis and associated

documentation in accordance with FAA Order 1050.1E, Environmental Impacts: Policies and

Procedures. See FAA Order 1050.1E Paragraph 310, Categorical Exclusions for Facility Siting,

Construction and Maintenance, for the list of categorical exclusions for FAA actions involving

acquisition, repair, replacement, maintenance, or upgrading of grounds, infrastructure, buildings,

structures, or facilities that generally are minor in nature. An action on the categorically excluded list

is not automatically exempted from environmental review under NEPA. The responsible FAA

official must also review FAA Order 1050.1E Paragraph 304, Extraordinary Circumstances, before

finalizing a decision to categorically exclude a proposed action, or to proceed with an environmental

assessment or an environmental impact statement.

b. Environmental Due Diligence Audit (EDDA). To minimize the FAA’s liability during real

property transfers (e.g., acquisitions, disposals, lease actions) and to comply with the requirements of

the Community Environmental Response Facilitation Act (CERFA) and General Service

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Administration (GSA) real property transfer requirements, ATO must determine the applicability of

an EDDA when real property transfer is involved in project implementation. The organization

implementing the project must determine need for an EDDA and commence EDDA documentation in

accordance with FAA Order 1050.19B, Environmental Due Diligence Audits in the Conduct of FAA

Real Property Transactions. See FAA Order 1050.19B Paragraph 1-9, Determining the Need for an

EDDA, for more information on EDDA applicability.

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Chapter 3. Design and Acquisition

3-1. Overview. EOSH requirements must be incorporated into the design and acquisition of new

facilities and renovation of existing facilities. Identifying applicable EOSH requirements and possible

areas for improvement provides opportunities to improve design and to be proactive in promoting

sustainable design and buildings. Incorporating EOSH concerns into the design and acquisition

processes allows more thorough application of requirements and provides more oversight of EOSH

issues throughout the program lifecycle.

3-2. Responsibility. The organization implementing the project must incorporate the requirements

of this chapter into applicable engineering, construction, or renovation projects. Engineering Services

Managers ensure the requirements of this chapter are incorporated into all applicable projects

managed by Engineering Services. For turnkey projects managed by Headquarters organizations, the

national Program Office ensures that sufficient EOSH technical support resources are provided. For

non-Engineering Services projects managed exclusively by local facilities and/or field organizations,

the appropriate manager (e.g., District Office Manager or SSC Manager) ensures that the requirements

of this chapter are incorporated into applicable projects (e.g., fence construction, painting,

remodeling).

3-3. Design Phase. The organization implementing the project must review the following processes

and incorporate them in order to improve project design:

a. FAA Form 3900-17, Design Risk Analysis EOSH Checklist. The design phase of a

construction project must identify applicable EOSH considerations included in FAA Form 3900-17,

the Design Risk Analysis EOSH Checklist.

b. Sustainability. It is required that projects incorporate the applicable requirements for

sustainable design during the design stage of the project per Executive Orders 13423 and 13514.

These orders set forth requirements for sustainability, including energy management, water

conservation, sustainable design, and diversion of construction waste. Resources include the Whole

Building Design Guide and the Guiding Principles for Federal Leadership in High Performance and

Sustainable Buildings (see Paragraph 7-5).

c. Safe Distance. Ensure that the proposed project complies with FAA Order 6050.32B,

Chapter 16, in terms of the project’s location and the safe distance to adjacent transmitting facilities.

3-4. Acquisition Phase. In the acquisition phase the following processes must be reviewed and

applied as required:

a. Incorporate the results of the Design Risk Analysis EOSH Checklist into acquisition

documents such as the market survey and screening information request (SIR). There are three

categories of SIRs: qualification information, screening information, and request for offers. Each

category of SIR is discussed in FAA Acquisition System Toolset (FAST) Acquisition Management

Policy Section 3.2.2.3.1.2.1 (http://fast.faa.gov/).

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b. Review project design submittals and/or other acquisition documents based on criteria

established in Form 3900-17, Design Risk Analysis EOSH Checklist.

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Chapter 4. Construction

4-1. Overview. The requirements in this chapter apply to all NAS construction activities with

potential EOSH impacts to FAA employees/contractors and NAS operations. The purposes of these

requirements are as follows: (1) safeguarding NAS operations from outages, (2) ensuring construction

safety is enforced at work sites, (3) ensuring employees/contractors at FAA facilities are not exposed

to hazards during construction, and (4) complying with environmental and safety and health

regulations.

a. The construction phase of a project must address the EOSH considerations as identified in

Form 3900-17, Design Risk Analysis EOSH Checklist, completed during the design phase.

b. The organization that directly manages the construction project is responsible for evaluating

the potential EOSH impact to NAS operations, reviewing site-specific procedures and project

management plans, identifying potential hazards, ensuring measures and controls address applicable

hazards, conducting site inspections, and ensuring the application, submittal, and compliance with all

permits.

4-2. Responsibility. Engineering Services Managers must ensure requirements in this chapter are

incorporated into all applicable projects. Turnkey projects managed by national Program Offices at

Headquarters organizations must ensure requirements in this chapter are incorporated and that

sufficient EOSH technical support resources are provided. For projects managed directly by the

District Office and field organizations other than Engineering Services (or projects not managed by

Engineering Services and not turnkey projects), it is the responsibility of front line manager or

supervisor (e.g., District Office Manager) to ensure the requirements of this chapter are applied to

those projects.

4-3. Pre-Construction EOSH Checklist.

a. The organization that directly manages the construction project is responsible for completing

the FAA Form 3900-18, Pre-Construction EOSH Checklist, and coordinating with the appropriate

District Office prior to commencement of the project. Actual work on the project (i.e., construction)

may not be initiated prior to completion and review of FAA Form 3900-18. In most cases, the

organization directly managing the day-to-day activities in a construction project will be outside FAA

Headquarters (e.g., Service Area Engineering Services, District Office, or Field Maintenance

Program). If an FAA Headquarters office directly manages a construction project, it will need to

coordinate the completion of the checklist with the District Office.

b. FAA Form 3900-18 is a tool used by each Resident Engineer (RE), Contracting Officer’s

Representative (COR), designated facility point of contact, or District Office Manager who oversees

construction and maintenance activities that potentially have EOSH impacts on NAS operations. This

checklist should be used, as appropriate, during critical phases of construction and maintenance

activities (e.g., the pre-construction meeting, 30-60 days prior to commencement of work,

daily/weekly construction meetings). Emphasis should be placed on using the checklist as a tool to

assess, as well as reassess, hazards as the project progresses. The checklist contains detailed

instructions regarding its use. Prior to starting a construction project, the organization directly

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managing the day-to-day activities of the project will complete FAA Form 3900-18 Section B, Work

Summary Information. The intent of Section B is to provide a description of the construction project

and identify key personnel responsible for project completion. After completing Section B, the

organization directly managing the day-to-day activities in the construction project and/or

maintenance tasks will fax/mail/e-mail/deliver the checklist to the District Office Manager or

designee. The designee may be the Contracting Officer’s Representative, SSC Manager or other

party.

c. The District Office Manager or designee will complete Section C of the checklist, Evaluation.

The intent of Section C is to allow the District Office Manager to determine whether the remainder of

the checklist needs to be completed by the organization directly managing the day-to-day activities in

the construction project. If necessary, the District Office Manager or designee shall be provided any

additional information regarding the project that will facilitate their determination on whether the

remainder of the checklist should be completed.

d. The remainder of the checklist shall be completed by the organization directing the

construction project. Completion of the checklist will require further coordination between the

District Office and the organization directly managing the day-to-day activities in the construction

project. The checklist shall not be considered complete until the District Office Manager or designee

signs in Section H of the checklist. Therefore it is the responsibility of the organization managing the

day-to-day activities of the construction project to ensure that the checklist is complete with the

District Office approval. The organization directing the project will also ensure that the District Office

is provided a copy of the completed checklist.

e. A copy of the completed checklist shall be kept on file electronically or in hard copy at the

District Office in which the work was accomplished for a minimum of two years after the construction

is completed. A copy of the completed checklist shall be forwarded in accordance with the

distribution list on the checklist. As appropriate, each RE, COR, District Office Manager, or

designated facility point-of-contact is responsible for distribution of the checklist.

4-4. Permits. Develop and submit the following permits, if applicable:

a. Asbestos Work Permit. FAA Order 1050.20A, Airway Facilities Asbestos Control Program,

requires a work permit for construction activities impacting asbestos containing material. The

checklist contained in this order does not replace the permit requirement in Order 1050.20A.

b. Confined Space Permit. See FAA Order 3900.19B, Chapter 11, Confined Space Entry

Program.

c. Energized Electrical Work Permit. See FAA Order 3900.19B, Chapter 34, Electrical

Safety. An Energized Electrical Work Permit is a requirement as per National Fire Protection

Association (NFPA) 70E, Article 110.8(B)(2), and Article 130.1(B).

d. Hot Work Permit. A permit may be necessary in order to comply with the requirements for

hot work in 29 CFR §1910.252 and/or NFPA 51B.

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e. Environmental Permits. FAA Order 1050.10C requires that all FAA facilities be designed,

constructed, managed, operated, maintained and decommissioned to conform to applicable pollution

control statutes (e.g., Clean Air Act, Clean Water Act). Some of the pollution control statutes require

permits, such as the following:

(1) Air pollution control;

(2) Fuel storage tank notification and state permits;

(3) Local fire marshal notification for bulk flammable/combustible/reactive liquids;

(4) PCB management;

(5) Nuclear Regulatory Commission license for radioactive materials;

(6) Permits for connections to municipal drinking water lines, sewer connections;

(7) Sediment control and storm water management; and

(8) Wastewater pretreatment.

4-5. Resident Engineer EOSH Checklist. The purpose of the Resident Engineer EOSH Checklist

is to ensure adherence to construction safety requirements at the construction site. It must be noted

that contractors are responsible for ensuring the safety of their employees. The checklist does not

release the contractors of this responsibility. The checklist may be used by the RE as a tool to support

their oversight role. The checklist may be completed at the time of the pre-construction conference

and reviewed and updated as the project proceeds. EOSH risks associated with each construction

project vary considerably. Some projects are small in scope and present relatively few EOSH risks,

while others are more complex and offer a variety of EOSH risks. The RE will assess the risks

associated with construction projects at NAS facilities and based on their risk assessment, determine

the need to apply the Resident Engineer Construction Safety Checklist. The Checklist may also be

used by others in the construction process, including the project engineer or representatives from

parties involved in construction.

4-6. Deliverables. As part of project management, ensure that the following deliverables, if

applicable, are provided to the District Office in addition to documents required for the Joint

Acceptance Inspection (JAI). Development of deliverables is the responsibility of the organization

directly managing the project. It is anticipated that the completion of the deliverables may be done

through a collaboration between several groups, including contractors, facility personnel, EOSH

personnel, and Engineering Services staff.

a. Written lockout/tagout (LOTO) procedures.

b. Fall protection procedures and equipment.

c. Occupant Emergency Plans.

d. Material Safety Data Sheets (MSDS) for hazardous materials.

e. Hazardous material storage lockers (e.g., flammables cabinets).

f. Hazardous material spill kits.

g. Air pollution permits.

h. Fuel storage tank (FST) permits.

i. National Pollutant Discharge Elimination System (NPDES) permits.

j. Spill Prevention, Control, and Countermeasure (SPCC) Plan.

k. Other permits as necessary (e.g., hot work permit, asbestos permit).

l. Test certifications and documents (e.g., fire life safety system).

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m. Training and information on systems as necessary (e.g., fire life safety system).

n. Documentation of asbestos-free construction as per FAA Order 1050.20A.

o. Arc Flash Hazard Analysis in accordance with FAA Order 3900.19B, Chapter 34,

Electrical Safety.

p. Job Hazard Analysis (JHA) for the system, facility, and/or equipment being deployed as per

29 CFR §1910.132(d) and FAA Order 3900.19B, Chapter 23, Job Hazard Analysis. The JHA will

analyze the employee safety hazards associated with the system, facility, and/or equipment and

associated maintenance tasks.

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Chapter 5. Maintenance

5-1. Overview. Numerous maintenance activities are performed at NAS facilities every day. These

activities include preventive maintenance, corrective maintenance, facility modifications, and

equipment modifications. Each of these maintenance activities may pose EOSH risks.

a. The purpose of this chapter is to provide guidance to prioritize the indoor air quality risks

associated with those maintenance activities and provide guidance to manage the highest priority

risks.

b. Chapter 4 addresses construction projects. Large-scale maintenance projects are essentially

construction projects. The requirements of Chapter 4 may be applicable to the following large-scale

maintenance tasks:

(1) Tasks that involve construction activities such as, but not limited to road grading, tree

removal, pesticide application, equipment installation, and facility infrastructure modifications (e.g.,

roofing repairs).

(2) Activities in an air traffic control area that require the use of hazardous material (e.g.,

paint, solvent) or activities that may impact a hazardous material such as asbestos.

c. This chapter addresses indoor air quality risks specifically. The Resident Engineer EOSH

Checklist (FAA Form 3900-19) may be used to account for and manage other EOSH risks related to

maintenance projects.

5-2. Responsibility. District Office Managers ensure the requirements of this chapter are

incorporated into all applicable projects.

5-3. Facility Risk Prioritization. Based on the volume and complexity of air traffic control

operations, the following prioritization will be used for NAS facilities in terms of managing indoor air

quality risks during facility maintenance:

a. Air Route Traffic Control Center (ARTCC).

b. Terminal Radar Approach Control (TRACON).

c. Airport Traffic Control Tower (ATCT).

d. Other staffed NAS facilities.

e. Unstaffed NAS facilities.

5-4. Activity Risk Prioritization. In terms of maintenance activities, the following scheme will be

used for prioritization:

a. Maintenance activities involving the facility’s heating, ventilation, and air conditioning

(HVAC) system.

b. Maintenance activities involving the use of volatile materials (such as paints and solvents).

c. Maintenance activities involving welding or brazing inside NAS facilities.

d. Maintenance activities involving cutting, grinding, and demolition inside NAS facilities.

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Table 5.1. Prioritization of Indoor Air Quality Risks for Maintenance Projects at NAS Facilities

Maintenance

project involving:

ARTCC

TRACON

ATCT

Staffed NAS

Facility

Unstaffed

NAS Facility

Facility’s HVAC

system

High

Moderate

Low

Volatile materials

(paints, solvents,

roofing sealants,

herbicides)

High

Moderate

Low

Welding or brazing

High

Moderate

Low

Cutting, grinding, or

demolition

High

Moderate

Low

5-5. Pre-Maintenance EOSH Checklist. Table 5.1 presents a basic prioritization for indoor air

quality risks associated with maintenance projects at NAS facilities. The risks associated with each

maintenance task are unique, and should be addressed accordingly. FAA Form 3900-20 is the

Pre-Maintenance EOSH Checklist. The District Office Manager and/or their designee should rely on

technical guidance provided by the SECM at the Technical Support Center to assess the risks

associated with maintenance projects in their NAS facilities, and based on their risk assessment,

determine the need to apply the Pre-Maintenance EOSH Checklist. The Pre-Maintenance EOSH

Checklist may not necessarily apply to all maintenance activities, but should be used to manage

activities with the highest risk.

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Chapter 6. Decommissioning and Disposition

6-1. Overview. The decommissioning phase of a NAS facility must include applicable EOSH

considerations identified in the Project Planning EOSH Checklist (refer to FAA Form 3900-16). This

checklist identifies compliance obligations and project planning issues to minimize waste generation, health

and safety impacts, ecological degradation, and raw material consumption over the entire lifecycle of the

project. In addition, this checklist is designed to correctly identify and highlight EOSH cost considerations

and impacts to the project. Proper planning will result in a reduction of hazardous wastes, reduced liability

concerns, improved public and stakeholder perception, improved employee and contractor safety and less cost

to the FAA.

6-2. Responsibility.

a. National Program Offices, as part of pre-deployment planning provisions in the AMS, are required

to complete an In Service Review (ISR) checklist. The ISR checklist and FAA Order 4600.27A, Personal

Property Management, requires that a disposition plan be developed for personal property that will be

disposed as a result of new NAS system installation.

b. Manager, Engineering Services, ensures the requirements of this chapter are incorporated into all

applicable projects managed by Engineering Services. For turnkey projects managed by Headquarters

organizations, the national Program Office ensures that the requirements of this chapter are incorporated into

their projects and ensures that sufficient EOSH technical support resources are provided.

c. District Office Managers ensure the requirements of this chapter are incorporated into all applicable

projects (i.e., projects planned and executed at the local level).

6-3. Real Property. For decommissioning projects involving real property, the following processes must be

reviewed for applicability and, if applicable, completed:

a. NEPA. Comply with NEPA and complete appropriate NEPA requirements prior to commencing

actions, in accordance with FAA Order 1050.1E, Environmental Impacts: Policies and Procedures. See

Paragraph 310, Categorical Exclusions for Facility Siting, Construction and Maintenance.

b. EDDA. Determine need for an EDDA and commence EDDA documentation in accordance with

FAA Order 1050.19B, Environmental Due Diligence Audits in the Conduct of FAA Real Property

Transactions. The order also briefly describes compliance with disclosure and reporting requirements of 40

CFR Part 373 and the Federal Management Regulation (FMR) applicable to the selling, transferring, or

disposal of federal real property. The disclosure and reporting requirements may be included as part of the

EDDA documentation.

c. Asbestos. Comply with FAA Order 1050.20A, Airway Facilities Asbestos Control, and review

demolition projects regarding impact to asbestos-containing material.

d. Other environmental considerations. Comply with FAA Orders regarding environmental and

hazardous materials considerations in facility decommissioning and disposition, including Order 1050.12,

Order 1050.16, 1050.17, Order 1050.19B, and Order 1050.20.

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6-4. Reutilization and Disposition of Personal Property. Unrequired or excess FAA personal property

will be utilized or disposed in compliance with FAA Order 4600.27A, Personal Property Management.

a. Many FAA systems and equipment are unique and serve no practical purpose to other entities, and

may endanger NAS integrity if used outside the NAS. Under the provisions of Title 49, United States Code,

Section 4011(c)(2)(F), the FAA is exempted from the provisions of the FMR regarding the disposition of

FAA airport, airway systems, or technical equipment with the capacity to transmit across NAS-controlled

airway frequencies. Implementation of this authority is delegated to AJW. All NAS systems require a

reutilization and disposition plan.

b. Specific guidance resources regarding personal property are listed below.

(1) FAA Order 4600.27A, Personal Property Management.

(2) FAA Order 1050.20A, Airway Facilities Asbestos Control Program, requires pre-construction

asbestos surveys (including demolition and renovation).

(3) For NAS systems, the approved reutilization and disposition plan.

(4) FMR, 41 CFR Part 102, Subpart B. Specific additional requirements regarding certification

apply to materials that meet the definition of “hazardous personal property” (see 41 CFR §102-36.40).

Specifically, 41 CFR §102-36.425 requires that executive agencies dispose of excess hazardous property in

accordance with 41 CFR Part 101-42.

(5) ATO Logistics Personal Property Management Bulletin PPB 11-01, of December 2010,

Compliant Disposal of Electronic Equipment.

(6) AMS Policy

(7) Exhibit 300 Program Baseline (OMB Circular A-11).

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Chapter 7. Administrative Information

7-1. Distribution. This order is distributed to all Technical Operations field offices with a standard

distribution.

7-2. Background.

a. The FAA ATO is responsible for managing myriad aspects of NAS operations, from

constructing new facilities to controlling air traffic to maintaining the NAS infrastructure. The

employees of the ATO are service providers—the 38,000 controllers, technicians, engineers, and

support personnel whose daily efforts keep air traffic moving. ATO’s mission is to safeguard NAS

operations, while ensuring the safety of its employees and minimizing its impact on the environment.

b. This order revises and updates a previous order, 3900.57, which laid out a checklist for pre-

construction coordination of EOSH issues. This order designates responsibilities and opportunities for

organizations involved in the lifecycle of ATO facilities to address EOSH issues.

c. Numerous organizations in the FAA fund, plan, design, and manage activities throughout the

NAS facility life cycle. These organizations are responsible for properly planning and coordinating

construction activities to minimize EOSH risks to FAA employees and NAS operations.

7-3. Authority to Change This Order.

a. ATO. The ATO has the authority to add new chapters, or change existing chapters that

are proposed by organizational elements of FAA after appropriate coordination with internal

stakeholder organizations. The COO has the right to further delegate this authority.

b. FAA Organizational Elements. Changes proposed by an organizational element within the

FAA must be submitted to the ATO, EOSH Services, AJW-23, who will evaluate, or assign a

designee to evaluate, the changes for incorporation. When using this order, all organizations are

encouraged to assess its effectiveness and usefulness. Organizations should provide feedback

regarding the effectiveness and usefulness of the order to EOSH Services, AJW-23, through

memorandum or electronic mail. FAA Form 1320-19, Directive Feedback Information, may also be

used.

7-4. Acronyms and Definitions. A list of acronyms is provided in Appendix A.

7-5. Related Publications.

a. Guiding Principles. The Memorandum of Understanding entitled Federal Leadership in

High Performance and Sustainable Buildings (January 2006),

http://www.wbdg.org/sustainableEO/mou.php, defines guiding principles for agency policy The

guiding principles are as follows:

(1) Employ Integrated Design Principles;

(2) Optimize Energy Performance;

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7-2

(3) Protect and Conserve Water;

(4) Enhance Indoor Environmental Quality;

(5) Reduce Environmental Impact of Materials.

b. Whole Building Design Guide is a web-based portal, http://www.wbdg.org/, providing

government and industry practitioners with one-stop access to up-to-date information on a wide range

of building-related guidance, criteria and technology from a ‘whole buildings’ perspective. The portal

is organized into the following major categories:

(1) Design guidance;

(2) Project planning, management, and delivery;

(3) Facilities operations and maintenance;

(4) Documents and references;

(5) Tools;

(6) Continuing education;

(7) Building Information Modeling; and

(8) Applied research.

c. Executive Orders 13423 and 13514 establish requirements for sustainability and affirmative

purchasing for Federal agencies. The requirements in these Executive Orders establish targets for

environmentally preferable purchasing, recycling, and other environmental requirements.

d. Energy Policy Act of 2005 (EPAct 2005) establishes requirements for energy management

and affirmative procurement for federal agencies.

e. Energy Independence and Security Act of 2007 (EISA 2007) lays out further reduction

goals for energy use at federal buildings and specifies standards for high-performance buildings,

procurement of energy efficient products, and reporting on energy costs, energy efficiency, and

greenhouse gas emissions.

f. FAA Orders. You can find an electronic copy of FAA Orders on the DMS website:

https://employees.faa.gov/tools_resources/orders_notices/. The FAA Orders referenced in this order

are listed below.

(1) FAA Order 1050.1E, Policies and Procedures for Considering Environmental Impacts.

(2) FAA Order 1050.10C, Prevention, Control and Abatement of Environmental Pollution

at FAA Facilities.

(3) FAA Order 1050.12, Application of Nonrestricted and Restricted Use Pesticides

(4) FAA Order 1050.15A, Fuel Storage Tanks at FAA Facilities.

(5) FAA Order 1050.16, Implementation Guidelines for Compliance with Underground

Storage Tanks

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7-3

(6) FAA Order 1050.17, Airway Facilities Environmental and Safety Compliance Program.

(7) FAA Order 1050.19B, Environmental Due Diligence Audits in the Conduct of FAA

Real Property Transactions.

(8) FAA Order 1050.20A, Airway Facilities Asbestos Control Program.

(9) FAA Order 3900.19B, FAA Occupational Safety and Health Program.

(10) FAA Order JO 3900.63, ATO Fall Protection Program.

(11) FAA Order 4600.27A, Personal Property Management.

(12) FAA Order 6000.54, Airway Facilities Hazard Communication Program.

g. Federal Regulations. The Code of Federal Regulations (CFR) specifies applicable standards

and requirements for federal agencies. Applicable sections include, but are not limited to: 29 CFR

Parts 1910 and 1926, 40 CFR Parts 1 - 1299, and 49 CFR Parts 171 - 180, and other applicable

regulations mentioned in this and other orders.

7-6. Forms and Checklists. The following forms are provided to supplement this directive.

Document retention is described below. The forms are available on the FAA Forms website at

www.faa.gov/forms.

a. Project Planning EOSH Checklist (FAA Form 3900-16). The Project Planning EOSH

Checklist is for use when reviewing plans/projects during the initial conceptual stage of planning for a

project. It is intended to identify environmental and safety issues in the project that may impact the

design, budget, and schedule. Retain as desired, checklist is not mandatory.

b. Design Risk Analysis EOSH Checklist (FAA Form 3900-17). This checklist is intended to

be used as a tool by the Project Engineer and/or Program Manager to identify and fully characterize

areas that may potentially have EOSH related impacts to FAA projects. Retain a copy with project

engineering documents, as necessary, through the duration of the project, in electronic or hard copy.

c. Pre-Construction EOSH Checklist (FAA Form 3900-18). This checklist is intended to

review construction, installation and non-routine maintenance activities, prior to commencement, that

potentially have occupational safety and health related impacts on NAS operations and employees.

Retain a copy with project engineering documents, as necessary, through the duration of the project, in

electronic or hard copy.

d. Resident Engineer EOSH Checklist (FAA Form 3900-19). This checklist is intended to be

used as a tool by the RE to ensure adherence to construction safety requirements at the FAA

contractor site. It must be noted that contractors are responsible for ensuring the safety of their

employees. The checklist may be used by the RE as a tool to support their oversight role at the

construction site. This is a voluntary checklist. If used during a project, retain a copy with project

engineering documents.

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7-4

e. Pre-Maintenance EOSH Checklist (FAA Form 3900-20). This checklist is intended to be

used as a tool by those who design, review and/or oversee maintenance activities that have potential

airborne contaminant impacts on NAS operations. This tool should be used, as appropriate, during

design and review phases of construction and maintenance activities. Maintain a copy in the Facility

Data File, as appropriate.

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Appendix A

A-1

Appendix A. Acronym List

ABU Office of Budget

ACM Asbestos-Containing Material

AGC Office of the Chief Counsel

AMS Acquisition Management System

APP Office of Airport Planning and Programming

ARTCC Air Route Traffic Control Center

AST Aboveground Storage Tank

ATCT Airport Traffic Control Tower

ATO Air Traffic Organization

BACT Best Available Control Technology

CAA Clean Air Act

CERFA Community Environmental Response Facilitation Act

CFC Chlorofluorocarbon

CFR Code of Federal Regulations

COR Contracting Officer’s Representative

DMS Directives Management System

EDDA Environmental Due Diligence Audit

EOSH Environmental and Occupational Safety and Health

EPA U.S. Environmental Protection Agency

FAST FAA Acquisition System Toolset

FMR Federal Management Regulation

FST Fuel Storage Tank

GSA General Service Administration

HVAC Heating, Ventilation, and Air Conditioning

IIPP Injury and Illness Prevention Program

ISR In Service Review

JAI Joint Acceptance Inspection

JHA Job Hazard Analysis

LOTO Lockout/Tagout

MSDS Material Safety Data Sheet

NAS National Airspace System

NEPA National Environmental Policy Act

NFPA National Fire Protection Association

NPDES National Pollutant Discharge Elimination System

OSHA Occupational Safety and Health Administration

O&M Operations and Maintenance

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Appendix A

A-2

PACM Presumed Asbestos-Containing Material

PCB Polychlorinated Biphenyl

PPB Personal Property Bulletin

PPE Personal Protective Equipment

RE Resident Engineer

SECM Safety and Environmental Compliance Manager

SIR Screening Information Request

SMS Safety Management System

SPCC Spill Prevention, Control, and Countermeasure

TRACON Terminal Radar Approach Control

TWA Time Weighted Average

UBC Universal Building Code

UFC Universal Fire Code

UST Underground Storage Tank