When you’re bidding on a San Diego public works construction project, you might encounter a requirement to develop and implement a Community Health and Safety Plan (CHSP). This guide explains what a CHSP is, when you need one, what it requires, and how to move forward, based on the City of San Diego’s 2024 Whitebook (effective April 1, 2026).
Not sure whether your project needs a CHSP, or already have one that needs a qualified review before you submit it? Our Certified Industrial Hygienists can review your project specs and tell you exactly where you stand, usually within 24 hours. More on how we help below.
What Is a CHSP and When Do You Need One?
A Community Health and Safety Plan is a document required by the City of San Diego for construction projects that may encounter hazardous substances such as lead, solvents, petroleum products, or other contaminants in soil or groundwater. The plan outlines how you’ll protect both workers and the surrounding community from exposure during construction.
You’ll need a CHSP if:
- Your project’s Special Provisions or site assessment data identify contaminated soil or groundwater
- Environmental reports reference lead, petroleum, solvents, or other hazardous substances
- You’ll be dewatering in an area with known or potential petroleum product contamination
- The site appears in California’s Geotracker database as a contaminated site
- You’ll be excavating in areas with historical industrial use
The 2024 Whitebook covers CHSP requirements under Section 5-15.3. Once required, the plan must be submitted through the project’s formal submittal process, and contaminated soil work cannot begin until the City approves it.
Note on asbestos: Asbestos-containing materials are handled under a separate section of the Whitebook (Section 306-3.3.5) and are not addressed by the CHSP. If your project involves asbestos, talk with your CIH about the requirements that apply.
Don’t have contamination at your site? If environmental reports, Special Provisions, and Geotracker all show no contamination, you likely don’t need a CHSP. Check with the City engineer if you’re unsure.
HAZWOPER: A Separate but Related Requirement
If your construction activities encounter flammable liquids or other Hazardous Substances, the Whitebook requires HAZWOPER (Hazardous Waste Operations and Emergency Response) certification for construction staff who may be exposed, including City engineers and inspectors performing onsite inspections. Your CIH determines who that includes based on the actual work and exposure potential, since not every worker on a site necessarily falls within the requirement. Where it applies, you are responsible for:
- Scheduling HAZWOPER training for all required construction staff
- Submitting verification of current certifications to the City engineer before continuing work in affected areas
- Maintaining those certifications annually until the triggering construction activities are complete
This is separate from the CHSP itself but is often triggered by the same site conditions, so plan for both.
What Does a CHSP Need to Include?
A complete CHSP under Section 5-15.3 addresses the following core elements:
1. Site Assessment and Hazard Identification
The plan begins with a detailed plot plan identifying all on-site and surrounding structures, topography, prevailing wind directions, surrounding land uses, nearby populations, and known sensitive receptors. It must also describe the potential public health hazards and exposure pathways (vapors, dust, fires, explosions, and physical hazards), considering both immediate and long-term risks.
2. Monitoring Equipment and Action Levels
You must specify the monitoring equipment your CIH or trained staff will use, the action levels for each contaminant, and the protocol to protect the public. The Whitebook specifically calls for these instruments:
- Photo Ionization Detector (PID), for vapors
- Combustible Gas Indicator (CGI)
- Benzene Monitor, required when gasoline or other petroleum fuels may be encountered
- X-Ray Fluorescence (XRF) Analyzer, required when lead-bearing contaminated soil may be encountered
All equipment must be calibrated before use, and the CHSP specifies which instruments apply based on the contaminants present at your site.
3. Dust and Vapor Control Measures
The plan must describe the administrative and engineering controls used to prevent or minimize public exposure. Acceptable vapor and odor controls include pumping out non-aqueous phase liquids (NAPL), covering off-gassing excavations or stockpiles, misting with water, applying vapor-suppressant foam, and locating stockpiles downwind of public receptors. For dust, acceptable controls include covering sources, misting with water, slowing the pace of site activities, and stopping work when conditions require it.
The Whitebook also requires the CIH to train all of your staff on the CHSP requirements as part of these administrative controls. This is a mandate, not just a best practice.
4. Soil Management and Stockpiling
- How soil will be segregated (clean vs. contaminated)
- Stockpile containment, including berming and covering to prevent runoff, vapor, and dust
- Storage in a secured area to prevent public access
- Proposed disposition and the time frame for removal
- A Hazardous Waste Determination within 10 working days of generating potentially hazardous waste, with results submitted to the City for approval before disposal
Note: Storage time limits for hazardous waste are governed by California hazardous waste regulations (22 CCR Division 4.5), not the Whitebook. Your CIH or environmental consultant can advise on the limits that apply to your site.
5. Community Notification
You must outline how you’ll keep neighbors informed. At a minimum, notices must be distributed to residences and businesses adjacent to or in the vicinity of potential project impacts, and posted around the site perimeter. Each notice must include:
- The name and 24-hour telephone number of the Site safety manager and anyone else who may be contacted with public inquiries
- A brief description of the proposed activities
- The dates and times work will be conducted and when it will be completed
- Any required Proposition 65 warnings (California Health and Safety Code Section 25249.6) if cancer-causing chemicals such as lead or petroleum are present
6. Emergency Response and Site Security
The plan must address site security to keep the public away from open excavations, and include emergency response procedures for community emergency situations such as natural gas leaks, water main ruptures, ignition of flammable substances, and large chemical releases. It must identify the roles of the Site safety manager, CIH, and workers in the event of a sudden hazardous substance release, including how a release is assessed for regulatory reporting and who is responsible for notifications.
If you encounter or cause a release of hazardous substances or petroleum products, construction in that area must stop immediately. Notify the City engineer and the County Department of Environmental Health and Quality (DEHQ), Hazardous Materials Division, at (858) 505-6880. If there is an immediate fire, explosion, or health threat, call 911.
7. Contact Information
The CHSP must provide the name and 24-hour phone number of the Site safety manager, the name and qualifications of the CIH, and the names, roles, experience, and training documentation for any workers assigned to help implement the plan, particularly those operating monitoring equipment.
The Critical Role of a Certified Industrial Hygienist (CIH)
This is non-negotiable. The Whitebook requires a Certified Industrial Hygienist to oversee the CHSP and monitor site activities to confirm that no health and safety violations exist during the work. The CIH must spell out in the plan the specific actions to take when health and safety concerns or elevated contaminant readings come up.
Your CIH will:
- Develop the site-specific CHSP based on environmental reports and site conditions
- Attend the pre-construction meeting with the City
- Train your crew on the CHSP requirements
- Be available during contaminated soil work for site monitoring and oversight
- Respond to air monitoring results and determine whether additional controls are needed
- Document compliance and provide the required reporting to the City
Verify credentials: Ask your CIH to show current certification from the Board for Global EHS Credentialing (BGC); you can verify CIH status at https://gobgc.org/verify/. Ask about their experience with similar San Diego public works projects. You can also see the range of industrial hygiene services our CIHs provide.
Vendor Regulatory Standing Requirements
The Whitebook also requires that the businesses you use for hazardous substance management be in good regulatory standing, with no regulatory fines totaling more than $25,000 in the past three years. This applies to licensed hazardous waste transporters, petroleum contaminated soil disposal and recycling facilities, treatment/storage/disposal facilities (TSDFs), and handling facilities. Verify vendor standing before you engage disposal subcontractors, since a disqualified vendor can halt your project.
The CHSP Development and Approval Process
Timeline: Plan for 3-4 weeks from start to work authorization.
Week 1: CHSP Development
- Your CIH reviews environmental reports and planned work methods
- CIH visits the site and prepares the site-specific CHSP
- The document addresses all elements listed above
- Typical length: 20-30 pages with site plans and figures
Weeks 2-3: City Review
- Submit the CHSP to the City engineer through the project submittal process
- The City reviews for completeness and compliance (typically 5-7 working days)
- The City may request clarifications or additional detail
- You respond with revisions (usually 2-3 working days)
Weeks 3-4: Pre-Construction Meeting
- Scheduled after the City approves the CHSP
- Your Site Superintendent and Site Safety Manager attend, along with your CIH when the project warrants
- The City project engineer and QCP Administrator also attend
- The team reviews the CHSP, community notification procedures, monitoring protocols, and emergency procedures
- Your crew receives authorization to begin contaminated soil work
Key point: You cannot begin contaminated soil work until the City approves your CHSP. Starting early results in work stoppage and potential back-charges, so treat CHSP approval as an item on your critical path.
Costs and Budget Planning
CHSP development is a fixed fee scoped to your site’s complexity, the contaminants involved, and the number of work phases. Because those factors vary so much from project to project, we quote it after a quick look at your specs rather than off a rate sheet. Contact us and we’ll turn around a fee and timeline within 24 hours.
The construction-phase items below are the ongoing costs to build into your bid:
- CIH site visits (daily to weekly, depending on contamination): $1,500-$3,000 per visit
- Monitoring equipment rental: $500-$2,000/month
- Soil characterization sampling: $200-$500 per sample
Budget Tips:
- Include CHSP costs in your bid
- Coordinate with your environmental consultant on sampling to avoid duplicate testing
- Line up disposal facilities before excavation starts
- Budget for contingencies, since unexpected contamination can add 2-4 weeks and significant cost
- Confirm vendor regulatory standing before engaging disposal contractors
What Contractors Should Do Now
If your project requires a CHSP, a few steps will keep you on schedule:
- Get a CIH review early. If someone else prepared your CHSP, have a qualified CIH review it before you submit, since rejection and revision delays are costly.
- Identify your CIH. Whether you’re developing from scratch or reviewing an existing plan, you need a qualified CIH with San Diego public works experience.
- Review the environmental reports so you understand what contamination exists and where.
- Request a pre-bid meeting with the City engineer if you’re unsure about requirements or scope.
- Budget appropriately and include CHSP review or development costs in your bid.
- Plan your timeline. If you’re building the plan from scratch, start 3-4 weeks before you need City approval.
A little planning up front here saves weeks of back-and-forth later, and a qualified CIH review before submittal is the single best way to avoid a rejection.
Frequently Asked Questions
What if we discover contamination not mentioned in the environmental report?
Stop work in that area immediately and notify both the City engineer and DEHQ at (858) 505-6880. Construction activities in the affected area must cease except in an emergency, and you shouldn’t resume until the area is determined safe or the City specifies conditions for safe resumption. Your CIH will assess the situation, prepare an addendum to your CHSP, and get City approval before you continue. This typically takes 5-10 working days and may qualify for schedule extensions and cost adjustments.
Can we start work while waiting for CHSP approval?
Limited work only. You can mobilize, install fencing, set up facilities, and work in verified clean areas. You cannot excavate, dewater, or handle contaminated soil until the CHSP is approved.
What happens if we don’t follow the CHSP?
The City inspector can issue a stop-work order. You’d then need to implement corrective actions, demonstrate compliance, and get City re-authorization before resuming, which creates delays and can trigger back-charges.
Do we need separate CHSPs for different phases of a multi-year project?
Usually not. One comprehensive CHSP can cover multiple phases as long as it addresses all anticipated contaminated work. You’ll refresh community notifications before each phase and re-verify equipment calibrations. If contaminant types differ significantly between phases, an addendum may be needed.
Which monitoring instruments does the Whitebook require?
A PID and CGI on all sites, a Benzene Monitor when gasoline or petroleum fuels may be encountered, and an XRF Analyzer when lead-bearing contaminated soil may be encountered. Your CIH determines which instruments apply and sets the action levels for each.
How often do we need to monitor air quality?
It depends on contamination type and activity. Typically that means continuous monitoring during active excavation where readings approach or exceed action levels, hourly during routine excavation, and daily during other phases. Your CHSP sets the schedule.
Can we stockpile contaminated soil on site?
Yes, with specific requirements. Soil must be contained within berms and covered to prevent runoff, vapor, and dust, and stored in a secured area to prevent public access. A Hazardous Waste Determination must be completed within 10 working days of generation, with results submitted to the City for approval before disposal. Storage time limits are governed by California hazardous waste regulations (22 CCR Division 4.5); your CIH can advise on what applies.
What’s a Proposition 65 warning, and do we need one?
California Health and Safety Code Section 25249.6 requires a warning when people may be exposed to chemicals known to cause cancer or birth defects. If your site has lead, petroleum, or other Prop 65 chemicals, your posted notices must include the warning, and your CIH will specify the exact language.
What if the community complains about dust or odors?
Document the complaint, investigate right away, enhance controls if needed, and respond to the complainant within 24 hours. The City expects a 24-hour contact number posted at the site and distributed to neighbors. Most complaints are manageable with improved dust control or adjusted work timing.
How much training does our crew need?
The CIH must train all of your staff on the CHSP requirements, and equipment operators and supervisors need additional training on monitoring procedures and action-level responses. Document all of it. If your project encounters Hazardous Substances, HAZWOPER certification may also be required for staff who could be exposed; your CIH will determine who that includes.
How EHS Analytical Solutions Can Help
Some contractors already have a draft CHSP in hand and need a qualified CIH to review it before submitting to the City. Others need the plan built from scratch. We do both.
CHSP Review Services (most common)
You already have a draft CHSP and want a CIH to review it for completeness and City compliance before submittal. We check for:
- Proper site characterization and hazard identification
- Appropriate monitoring equipment and action levels
- Adequate dust and vapor control measures
- Community notification compliance
- Realistic emergency procedures
- Overall compliance with the 2024 Whitebook
Standard review runs 5-7 working days; expedited review is available in 24-48 hours when you’re up against a deadline. You get a marked-up draft with comments and recommendations.
CHSP Development Services
If you need the plan built from scratch, our CIHs review your environmental reports and site conditions, develop site-specific monitoring and control plans, prepare a complete CHSP ready for City submission, and attend the pre-construction meeting with the City engineer. Development typically takes under a week from the time we have your reports and schedule.
CHSP work draws on the same expertise behind our full range of industrial hygiene services, from exposure monitoring to compliance planning.
Our qualifications:
- Certified Industrial Hygienists (CIH) with 20+ years of San Diego project experience
- Successful CHSP approvals on City of San Diego projects
- Experience with lead, petroleum, solvent, and heavy-metal contamination
- Deep familiarity with City engineer expectations and 2024 Whitebook requirements
- Available for site monitoring and oversight during construction (a separate service)
EHS Analytical Solutions, Inc. provides CIH-prepared and CIH-reviewed Community Health and Safety Plans for City of San Diego public works projects. As a Disabled Veteran Business Enterprise (DVBE) with Certified Industrial Hygienists on staff, we can review your specs and return a fee and timeline within 24 hours.
Contact us today to discuss your project. Call 619-288-3094 or email [email protected]
We look forward to supporting you!!!
To learn more about the City of San Diego Whitebook, visit the City of San Diego official website.
