The general responsibilities of employers for worker occupational health and safety are specified in Title 8, Industrial Relations, of the California Code of Regulations. Section 1509 of Title 8, Injury and Illness Prevention Program, requires that every employer shall take the following actions concerning health and safety:

The specific requirements of the Injury and Illness Prevention Program, which constitutes the core of health and safety programs, are enumerated in Section 3203 of Title 8, Injury and Illness Prevention Program, and include the following:

The Department of Public Works' Administration of the Health and Safety Program

Workplace health and safety is a basic management responsibility, and for the Department of Public Works, a significant responsibility. The work performed by the Bureaus of the Department's Operations Division - Building Repair, Street and Sewer Repair, Urban Forestry, and Street Environmental Services - often involves significant hazards to health and safety. Managing the work environment so as to minimize injuries and illnesses should be a key result area for the Department's management.

The Department's six staffperson Environmental Health and Safety Office is responsible for providing Department-wide guidance and technical assistance to the Director of Public Works, the Deputy Directors, and to the Bureau Chiefs to assist in implementing a comprehensive health and safety program. The responsibilities of the Environmental Health and Safety Office, as stated the Department's Safety Policy Manual, are to

The Department of Public Works' Environmental Health and Safety Office has implemented an effective system of controls for administering the Department's Health and Safety Program. The Environmental Health and Safety Office's mission statement, performance measures, and objectives reflect the Office's functions and responsibilities and serve to focus effort and measure achievement. The Office's administrative publications, including the Safety Policy Manual, the Code of Safe Practices (Department-wide version), the Employee Health and Safety Handbook, the Supervisor Safety Handbook, and the quarterly Wellness & Safety Newsletter up-to-date and of professional quality.

The Department of Public Works has not issued a Public Works Safety Policy Statement since the 1980s. The Director of Public Works should issue an updated Safety Policy Statement, indicating his dedication to the Health and Safety Program. This action, if followed by initiatives supporting the Program, should aid the work of the Environmental Health and Safety Office and the managers who have been implementing improved practices during the course of this audit.

Health and Safety Program Outcomes

In order to evaluate the effectiveness of major segments the Department of Public Works' Health and Safety Program, the Budget Analyst (1) oversaw an evaluation of the health, safety, and environmental status of the Department's Maintenance Yard and Asphalt Plant, and (2) conducted a comparative analysis of the Department's injury and illness incidence rates.

Health, Safety, and Environmental Inspections

At the request of the Budget Analyst, staff of the Safety and Health Department of the San Francisco International Airport and the Public Utilities Commission's Health and Safety and Environmental Regulation Office conducted a health, safety, and environmental inspection of the Department of Public Works' Maintenance Yard, located at 2323 Cesar Chavez Street, and the Asphalt Plant located at 1801 Quint Street, on April 4, 2006. The inspection included a walk-through of the trade shops, the fueling station, street sweeping operations, vehicle and equipment storage areas, the Bureau of Urban Forestry areas, and the hazardous materials storage area.

We have provided summaries of the inspection, below. We have also provided complete inspection reports with photographs, including detailed "Observations" and "Required Actions," to the Department of Public Works.

Health and Safety Issues

The inspectors made the following observations concerning common safety issues:

In addition to the items noted in the detailed inspection report, there were other capital improvement, building, and facility safety hazards noted by the inspection team, as follows:

The inspectors also noted the following deficiencies in the Hazardous Materials Storage Area, Carport 4 of the Maintenance Yard, which is maintained by the Department of Public Health:

The inspectors noted exposed thermal system insulation on pipe at the Asphalt Plant. The pipe wrapping should be repaired.

The Health and Safety inspection revealed that although housekeeping was very good in many of the trade shops, housekeeping and material storage was poor in the Sheet Metal Annex, the Glass Shop, and the Homeless Belongings area in the Lower Yard. Also, the inspection noted several instances of improper storage of flammable chemicals, unlabeled chemical containers, incompatible chemicals stored together, lack of signage, and hazardous wastes stored on wooden pallets instead of spill pallets. Further, shelving in the shop areas and annex locations is inadequate and some shops have wooden ladders that do not have any safety feet.

Environmental Inspection Results

The sections that follow pertain to areas that exhibit the highest potential sources of storm water pollution: The areas inspected are required to comply with the Sewer Use Ordinance (San Francisco Municipal Code [Public Works Code] Part II, Chapter 10, Article 4.1), which regulates runoff to the sewer system.

Street Sweeper Unloading/Washing Pads

The Street Sweeper Unloading/Washing Pad operation constitutes the most serious concern for the safety of the sewer conveyance system. Currently, the street sweepers are unloaded on one of two asphalt pads that are each graded toward a central drain, and surrounded by an asphalt berm on three sides (See Exhibit 1, below). The sweepers back up over the pad and tilt the collection bins to dump collected materials. While the sweeper's bins are in the dump position, access panels on the sides and front are opened and the operators hose out the inside of the collection bin. The liquid component, potentially high in pollutants, flows directly to the drains in the center of the pad (See Exhibit 2, below). Larger debris such as trash, gravel, and a large portion of the sediments are routinely removed by front-end loaders and hand shovels after the sweepers pull out of the pads or at the end of a shift. The drains that service these areas are standard catch basins and offer minimum pretreatment of the liquid waste stream, except for larger sediment particles and trash removal. The effluent from this washing process is eventually treated at the treatment plant; however, there are no measures in place to prevent an acute discharge of a collected hazardous material, or to reduce the chronic influx of pollutants generated from this activity. The Public Utilities Commission's Wastewater Enterprise staff, who are responsible for the City's wastewater collection system, currently clean the trapped coarse sediments and other debris from the catch basins on a weekly basis. At the time of the inspection, the basins were filled up to the drain pipe with sediment, not allowing for any further material capture. Studies conducted by the Alameda County Urban Runoff Clean Water Program showed that once the sump of a catch basin exceeds one-third the height from the bottom to the water line, the basin loses its treatment capacity. The inspector recommended the following actions to correct the problem:

Exhibit 15.1
Street Sweeper Unloading /
Debris Dumping Area

Exhibit 1: Sweeper Wash Pad Debris is dumped onto this pad, sweeper holding chambers are sprayed out, and trash and large sediment particles are scooped and placed in debris box. Liquid pollutants and suspended solids flow to the drain. Photo taken from adjacent pad.

Exhibit 15.2
Street Sweeper Unloading /
Washing Pad Debris Pile

Exhibit. 2 Sweeper Wash Pad. Debris pile covering drain after street sweeper has been emptied.

Housekeeping and Material Storage

Housekeeping was generally good throughout the yard with negligible accumulation of haphazard storage of parts, equipment, supplies, and other materials, or accumulation of items with little or no remaining utility. Most shops had uncovered garbage containers with trash in them. During rain, as observed on the inspection day, the garbage cans partially fill with water, and the water will end up on the ground either through holes in the cans, or from spills while emptying the cans. The water from the garbage cans will contain trace amounts of any pollutants inside the cans. To correct this problem, the Director of Operations should ensure that all garbage containers have a lid in place or are stored under a roof or indoors.

The materials storage area located outside of carport 2 in the Northeast corner of the yard had many containers of soaps and cleaners whose containers had weathered to the point of questionable integrity. This inspector was able to simply break off pieces of the lids by hand due to their brittleness. The Director of Operations should ensure inventory management that employs a "first in-first out procedure for materials.

Hazardous Material Storage

The Operations Division staff store hazardous materials, located in the Northwest corner of the facility, in a proper manner. The inspectors noted only one deficiency: the placement of the spill protection berm along the front of the storage area was outside the drip line of the roof, allowing rainwater to collect inside the bermed area. The collected rainwater allows for the mobilization of chemicals and/or dry-sweep materials that have accumulated on the ground. The Director of Operations should instruct the appropriate staff to relocate the berm inside the drip line.

Vehicle Fueling and Service

The gasoline and diesel fueling area complied with most storm water Best Management Practices. The inspectors noted one deficiency: the lack of a complete spill kit. Containers of absorbent "kitty litter" were present, but no brooms or dustpans to complete the spill cleanup procedure were present. As a result, an accumulation of spent absorbent was present on the fueling pad, which will eventually get tracked to the surrounding area (Fig. 7). Upon a return visit, the proper tools were placed in the spill kit, but accumulated absorbent was still present on the fueling pad. The Director of Operations should post signage to remind personnel of proper cleanup procedures, and ensure annual tailgate training for city employees who operate vehicles.

The vehicle service area located adjacent to the fueling area exhibited nearly complete use of Best Management Practices at the time of the inspection. Waste oil is handled in a closed loop system that requires no manual fluid transfer except from the vehicle oil pan to the collection pan in the mechanic's pit. Spill kits were present and well marked, and spill prevention devices were properly employed. The only deficiency noted was the procedure for disposing of spent mop water from clean up of the shop. Currently water gets disposed in a nearby storm drain outside the shop. There is an oil/water separator drain located inside the shop that needs to be used for all mop water containing traces of oil. The Director of Operations should ensure that the oil/water separator is used only for dumping oily mop water. Additionally, a mop needs to be designated for cleaning up oil spills and residues and rinsed in a bucket only containing water. A second mop designated for finishing with a soap solution is needed designated as well.

Cement Shop

One wastewater collection system issue was cited in the cement shop. An indoor floor drain located approximately one yard from the hazardous material storage closet inside the shop where chemicals including corrosives are stored is not used on a regular basis for any purpose. The Cement Shop Superintendent should ensure that the drain is plugged with a removable stopper to prevent any accidental spills from entering the sewer system. The stopper should remain in place except at the rare times when drainage for that area may be needed (e.g. washing the floor).

Graffiti Paint Sinks

The graffiti crew washes paint equipment in sinks located along an east-facing wall between the upper and lower yards. The sinks drain through two particle traps designed to separate paint particles from the wastewater generated during cleaning. The traps had not been serviced as evidenced by rust and accumulated paint over maintenance points on the traps and confirmed through interviews with the graffiti crew supervisors. These traps require regular servicing to properly function and removed material should be disposed of as hazardous waste if the content of the material is not completely known.

Bureau of Urban Forestry Area

The Bureau of Urban Forestry stores plant material, soils, and equipment in the southwestern corner of the lower yard. At the time of the inspection, sediment-laden runoff was entering a storm drain that services the area. The sediment was generated from uncovered piles of soil in storage bins. These piles need to be covered during the rainy season. In addition to preventing the mobilization of soil particles by keeping the piles covered, an additional level of drain protection should be implemented at the drains themselves by placing gravel bags around the drains. In addition to the storm drain, vegetation was growing inside the separator chamber of the grated trench that flows to an oil/grit separator on an equipment washing pad, indicating lack of servicing for an extended period. The Bureau of Urban Forestry manager needs to ensure that staff cover the stores of plant material, soils, and equipment during the rainy season and service the separator chamber routinely. Further, all vehicle washing (except street cleaners as described in an earlier section) should be performed on this pad. The oil/grit separator will need regular servicing above the level to which it is currently receiving.

Asphalt Plant

The Department of Public Works asphalt plant located on Jerrold and Quint streets employed good implementation of Best Management Practices overall. Improved preventative maintenance of the drainage system and improved spill protection are the only recommendations. For the drainage system, there are seven storm drains that serve the facility. These should be inspected on a weekly basis throughout the rainy season, and cleaned if necessary. A thorough inspection and cleaning should be scheduled starting in September to prepare for the rainy season. Also, spill kits in hazardous material storage areas need to be clearly marked. There is significant diesel storage and usage at the facility; therefore, temporary drain blockers should be located and marked adjacent to each storm drain. An example of a portable and rapidly deployable drain protection unit is included in attachment B.

The Department of Public Works' Incidence of Workplace Injury and Illness

The recordable incidence rate and the recordable severity rate are measures of injury experience calculated such that interested parties can make meaningful trend analyses or cross-comparisons of injury experience within a given industry, trade, or project type. A recordable injury is an injury that requires other than first aid. The formula for calculating the recordable incidence rate yields the number of recordable incidents per 100 employees working 40 hours per week for 50 weeks per year. The formula for calculating the recordable severity rate yields the number of lost workdays per 100 employees working 40 hours per week for 50 weeks per year.

Table 15.1 below displays the recordable incidence rate and recordable severity rate for the Department of Public Works and other City agencies for the periods indicated. Table 15.1 shows that there were 18.0 recordable incidents per 100 employees in calendar year (CY) 2005, which is slightly below the five-year mean of 18.1 recordable incidents per 100 employees. Another way of viewing the statistic is that approximately 18 percent of the Department of Public Works' employees had a recordable injury in calendar year 2005.

Table 15.1 also shows that the Department of Public Works experienced 594.7 lost workdays per 100 employees in calendar year 2005, the highest recordable severity rate within the last five years of a statistic that has increased in each of those years.

Table 15.1

Department of Public Works' Recordable Incidence and Severity Rates Compared to Other City Departments

Source: Published Department of Public Works and Public Utilities Commission Health and Safety statistics.

The California Occupational Safety and Health Administration (Cal-OSHA) web site includes tables showing recordable incidence rates for 2004, the most recent year that data has been published, for both governmental and private organizations of all types. The recordable incidence rate for all industries including State and local government is 8.9, and the recordable incidence rate for private industry is 4.9. For repair and maintenance organizations, the recordable incidence rate is 4.1, which is approximately 77.2 percent less than the Department of Public Works' recordable incidence rate of 18.0. Further, the statistics shown for the Department of Public Works as a whole include the rates for Engineering and Finance and Administration, organizations with relatively low recordable rates.

The data in Table 15.1 shows that the Hetch Hetchy Enterprise of the Public Utilities Commission has by far the best health and safety record of the organizations shown. The Department of Public Works and the Water Pollution Control Division of the Public Utilities Commission have comparable health and safety records: the Department of Public Works has a higher rate of recordable incidents, but they are moderately less severe over the five-year period shown. The Recreation and Park Department, for the period shown, has by far the highest incidence of recordable injuries and the second highest severity rates.

According to health and safety specialists, the significant variables determining health and safety rate experiences include the following: (1) management commitment, (2) safety planning for work, (3) employee fitness, and (4) and type of work performed. The significant variables are not completely independent: management commitment can certainly affect safety planning for work and employee fitness, as well as other health and safety factors.

Tables 15.2 and 15.3 show the recordable incidence rates and the recordable severity rates, respectively, for the Bureaus of the Operations Division and for the Operations Division as an entity for the calendar years shown.

Table 15.2

Operations Division Recordable Incidence Rates

Source: Published Department of Public Works Health and Safety Statistics

Table 15.3

Operations Division Recordable Severity Rates

Source: Published Department of Public Works Health and Safety Statistics

The recordable incidence rate of the Operations Division as an entity has been fairly stable for the past five years, ranging from 26.9 to 30.5. However, the recordable severity rate has been increasing significantly over that time period – from 593.0 to calendar year 2001 to 994.5 in calendar year 2005.

As an indication of the significance of health and safety rates on productivity, had the Operations Division experienced the Hetch Hetchy recordable severity rate of 233.2 in calendar year 2005 instead of its reported recordable severity rate of 994.5, the prevention of lost work due to injuries would be approximately 23.4 full time equivalent positions, based on an assigned Operations Division strength of approximately 800 employees. The cost of 23.4 full time equivalent positions, based on the average salary and mandatory fringe benefits costs for an Operations Division employee, is $2,062,559. Additional savings in medical and related costs could also be realized.

The Operations Division rates are only an indicator of the health and safety experience of the organization over a given time period. The Department of Public Works needs to analyze the rates of workplace injury or illness within each of the Bureaus and the activities contributing the most to the high incidence Bureaus in order to implement effective interventions. Based on the information shown in Table 15.2 and Table 15.3, the Department of Public Works should investigate the causes of the apparent high injury and severity rates among members of the Operations Division, with particular emphasis on the Bureau of Urban Forestry, and develop action plans to significantly reduce the incidence and severity of injury in the Division.

Conclusion

The Department of Public Works needs to implement specific environmental improvements in the 2323 Cesar Chavez Street maintenance yard. Inspections of the yard showed that, while the yard was generally clean and free of significant hazards, numerous incidents of poor maintenance, servicing, or management contribute to safety problems. The Director of Operations needs to ensure that the maintenance yard is well maintained and free of hazards and implement specific corrections identified by Public Utilities Commission and Airport health and safety staff.

The Department of Public Works' lost work days due to work place injury or illness over the past several years has increased significantly. From calendar year 2001 through calendar year 2005, the number of the Department's Operation Division's workplace injuries per 100 employees, requiring more than first aid treatment, was largely unchanged. However, the severity of the Operation Division's workplace injuries and illnesses, measured by the number of lost work days per 100 employees, increased significantly, especially in the Bureaus of Building Repair, Urban Forestry, and Street Environmental Services.

Recommendations

Costs and Benefits

With the exception of implementing an environmentally-acceptable method of disposing of effluent on the street sweeper unloading/washing pad, which according to the Department of Public Works will cost approximately $15,000 to $20,000, the Budget Analyst's recommendations can be accomplished with existing staff, in-house. The benefits of the recommendations would include a healthier, safer, and environmentally compliant workplace, and the potential prevention of lost work due to injuries of approximately 23.4 full time equivalent positions. The cost of 23.4 full time equivalent positions, based on the average salary and mandatory fringe benefits costs for an Operations Division employee, is $2,062,559. Additional savings in medical and related costs could also be realized.