03/05/2013 JO 3900.57A
2-1
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.