Contractors working on Airport Authority properties are expected to incorporate best practices to reduce BRHM-related risks to health and safety to as low as reasonably achievable (ALARA).
BRHEMP Request for Information
A BRHEMP Request for Information (RFI) is a form that stakeholders submit to obtain historical information about BRHMs that may be within their workplace and that could result in a hazardous exposure if disturbed.
In this section, “stakeholders” include Airport Authority contract owners, tenants, Airport Authority Maintenance personnel, and designated service providers. Only these individuals may submit BRHEMP RFIs.
It is critical to submit the BRHEMP RFI as early in the project/work planning process as possible, as additional sampling or abatement may be required before starting work.
The BRHEMP administrator aims to issue a Conditional Report in response to the RFI within 10 business days. However, response time will depend on the complexity and volume of submitted RFIs.
There are two steps to the BRHEMP RFI process.
Step 1: Determine if a BRHEMP RFI must be submitted
For any proposed work, stakeholders ask the following questions to determine if a BRHEMP RFI is required:
- Is a Facility Alteration Permit (FAP) required for the work?
- Is work being done in B Pier?
- Does the scope include work on mechanical systems?
- Will building materials (including pavement and roofing materials) be disturbed by the work? This refers to work that disturbs a surface, such as scraping, sanding, cutting, grinding, welding, sand blasting, demolition, and floor removal. The disturbance could create airborne particulate and lead to a hazardous exposure.
If the conditions listed above do not apply to the work but stakeholders have concerns about exposure, they should submit a BRHEMP RFI.
Step 2: Submit the BRHEMP RFI
If stakeholders have determined that a BRHEMP RFI is required, they complete the form and submit it to the BRHEMP administrator.
For unplanned events and emergency work, see:
- Airport Authority Maintenance Work
- Airport Authority Emergency Event
BRHEMP Conditional Report
In response to the BRHEMP RFI submission, the Airport Authority produces a BRHEMP Conditional Report to communicate all known information on BRHMs within the project location. The report lists all known BRHMs and specifies general requirements that must be met.
Work WILL NOT START until the stakeholder has received the BRHEMP Conditional Report and met the requirements outlined in the report. This includes completion of any subsequent Hazardous Materials Assessments.
The information in a BRHEMP Conditional Report and any subsequent Hazardous Materials Assessments must be incorporated into the Contractor Safe Work Plan. The individual(s) overseeing the work are expected to review these reports with all site personnel and incorporate the hazards into a written Site-Specific Orientation. All site personnel are to sign the signature page in the BRHEMP Conditional Report.
All BRHEMP-related reports must be posted on the project information board. If there is no project information board, a copy of all BRHEMP-related reports must be on site and available to all personnel.
During the course of the work, contractors or workers may encounter other environmental hazards within the project location. If they encounter a suspect material that is not listed in the BRHEMP Conditional Report or subsequent Hazardous Materials Assessments, they are to contact the BRHEMP administrator and consider the material hazardous until confirmed otherwise.
Tenant BRHMs Inventory Report
The Airport Authority produces BRHMs Inventory Reports to communicate all known information on BRHMs within the base building of tenants’ leased space. These reports are issued when tenants take possession of a space or request the information.
BRHEMP Inventory Reports may not provide comprehensive lists of all base building hazardous materials within the space. They may only list known materials when the tenant takes possession. Tenants who would like to complete upgrades or renovations to the space must submit a BRHEMP RFI, and additional sampling for hazardous materials may be required.
Airport Authority Maintenance Work
Airport Authority Maintenance personnel should ask the questions above to determine if an RFI is required. If the answer to any of the questions is YES, they must contact the BRHEMP administrator for further guidance.
Airport Authority Emergency Event
In the context of the BRHEMP, an “emergency event” is an event that cannot wait to be addressed until the next business day. Airport Authority emergency procedures should be followed and the scene secured immediately.
If immediate access is required and there is no known or accessible information on BRHMs, workers must assume that hazardous materials are present and protect themselves accordingly using the hierarchy of controls. If they do not feel that they have adequate training, equipment, or safe work procedures to deal with the situation, they must contact a contractor who does.
Prime contractors are responsible for all emergency procedures in their workspaces. They should have a detailed emergency response plan for accidental release events, and for emergencies not directly related to hazardous materials that would require entering a ‘dirty’ space undergoing abatement (such as a water pipe bursting).