HSE Department Plan · APB South

WHY THIS DEPARTMENT EXISTSThe stakes, named

A boatyard in the Lower Keys answers to more agencies, in a more sensitive place, than almost any yard in America. HSE here is not a binder on a shelf — it is the license to operate, the shield in a lawsuit, the pass mark in every vendor and government audit, and a paying department in its own right.

Who is watching	What they watch
NOAA — Florida Keys National Marine Sanctuary	The water itself. Discharge prohibitions across the sanctuary; anything leaving this property into the water is a federal matter.
EPA / FDEP — stormwater & waste	Industrial stormwater permitting for boatyards (the multi-sector general permit and its Florida equivalent), used-oil and hazardous-waste handling, petroleum storage.
OSHA — 29 CFR 1915 & 1910	Shipyard employment standards: hot work, confined spaces (tanks and bilges), fall protection, cranes and rigging, respiratory protection for paint and blast.
US Coast Guard	Spill notification (the National Response Center) and anything that makes a sheen on the water.
Monroe County / City of Key West	Land use, derelict vessel process, fire marshal, noise and nuisance.

Verification note. The regulatory names above are the correct families; the exact permits this property needs (stormwater NOI, petroleum storage registration, SPCC applicability by tank volume) must be confirmed by the environmental consultant during the site survey — thresholds turn on facts like aggregate oil storage that are unverified until the survey.

The flag to fly: Florida Clean Boatyard designation. The state's voluntary designation is the visible proof that the yard runs clean — it belongs on the website, the gate sign, and every investor and government submission. The whole plan below doubles as the application checklist.

DOCTRINEThree rules the whole yard runs on

1 · Nothing reaches the water. No wash water, no paint dust, no fuel, no trash. Every operation that could touch the water has a containment answer before it starts.
2 · Everything is documented. Every waste pickup has a manifest, every incident has a report, every inspection has a record. If it isn't written down, it didn't happen — and in an audit, that cuts both ways.
3 · The polluter pays. Every waste stream is billed to the vessel or contractor that generated it, on the invoice, as its own line. The HSE desk is a revenue department — the menu is on the rate card and every item has a folio line type in Marina Manager.

ORGANIZATIONWho owns it

Seat	Responsibility
HSE Manager Yard Manager, dual-hat at opening	Owns this plan. Runs inspections, incident response, training records, waste-vendor contracts, and the permit calendar. The opening roster already assigns the yard manager the HSE hat — a dedicated HSE hire is a growth-trigger decision, not a day-one cost.
Corporate Safety Coordinator APB North — Jerry Clark	The company's existing written programs, training matrix and OSHA logs live at APB North. This plan adapts that library to the yard — it does not rewrite it. Corporate audits the yard quarterly.
Every supervisor	Owns the safety of their crew and their patch of ground. Signs the hot-work permits, runs the toolbox talks, stops any job that isn't safe to continue.
Every hand	Stop-work authority, no exceptions. Anyone can halt any job over safety or an imminent discharge — and the halt is thanked, not punished.
Contractor compliance desk	Already built: the contractor portal's green/yellow/red risk tiers, carrier-issued certificates, and the authorization agreement. HSE sets the tier definitions; the portal enforces them.

THE WASTE STREAMSEvery stream, handled and billed

This is the heart of the department: each stream has a container, a home, a disposal path, and a price. The price column is live — these are real line types on the Marina Manager folio, priced off the rate card's Environmental & HSE section.

Stream	Handling on the yard	Leaves the yard via	Billed as
Used oil	Sealed transfer to the used-oil tank at the waste depot; no open pans left out	Licensed used-oil transporter, manifested	HSE · Used oil disposal ($/gal)
Oily bilge water	Pumped, never dumped; oil-water separation before disposal	Licensed transporter	HSE · Oily water pump-out ($/gal)
Antifreeze / coolant	Dedicated drum, never the storm drain	Recycler	HSE · Antifreeze disposal ($/gal)
Solvents & paint waste	Flammables locker; hazardous-waste drum, dated when the first drop goes in	Hazardous-waste hauler, manifested	HSE · Solvent & paint waste ($/gal)
Filters, rags, absorbents	Contaminated-solids drum at the depot	Hazardous or special waste per content	HSE · Filters & absorbents ($ each)
Batteries	Palletized, terminals protected, under cover	Battery recycler	HSE · Battery disposal ($ each)
Spent zincs & anodes	Scrap bin	Metal recycler	HSE · Spent anodes ($ each)
Sewage / holding tanks	Pump-out at the dock or on the hard — the agreement already requires an empty tank before the slings	Sanitary system via pump-out service	HSE · Holding-tank pump-out ($ flat)
Bottom-wash water	Wash pad with capture — interim berms and vacuum recovery on day one, closed-loop recycling pad as the capital build	Filtered solids to special waste	inside the pressure-wash rate
Paint dust & blast media	Full containment: tenting, tarps, vacuum sanders — APB-only bottom work makes this enforceable	Contaminated solids stream	inside the paint job
Every hazardous pickup	Carries its paperwork — the manifest is what proves where the waste went, and it is retained for the record		HSE · Waste manifest ($ each)

Plus the blanket: environmental recovery on every line. The card already carries the comparison yard's own billing shape — a percentage on every line item, printed as its own column. The stream charges above are on top: the recovery fee pays for the yard's standing compliance; the stream charges pay for the vessel's own waste.

SPILLSThree tiers, one phone number

Tier	What it looks like	Response
Tier 1 On the ground	Small spill on pavement or ground, contained on property	Nearest spill kit — pads, absorbent, drum the waste. Logged same day; billed to the vessel or contractor that caused it.
Tier 2 Sheen on the water	Any petroleum reaching the water, any size	Boom it immediately, then the legal duty: National Response Center 1-800-424-8802 — a sheen on sanctuary water is reportable, and failing to call is the bigger offense. FDEP watch office follows.
Tier 3 Beyond the yard	More than the kits and crew can hold	Contracted spill-response company (OSRO) on retainer — the contract is a Phase-2 deliverable. Yard crew holds the perimeter until they arrive.

Billing: a spill caused by a vessel or its contractor bills the callout (HSE · Spill response), cleanup labor by the hour (HSE · Environmental cleanup), and disposal of everything recovered — the polluter pays, on the yard's paper, documented photo-first like everything else.

THE PROGRAM LIBRARYThe written programs, phased honestly

APB already holds written HSE programs, a training matrix and OSHA logs at the corporate library — the work here is adaptation to a yard, not authorship from zero.

Program	Why the yard needs it	Phase
Hot work permit system	Welding and cutting near fuel, foam and paint — permit per job, fire watch, signed by the supervisor	Day one
Hazard communication + SDS library	Every chemical on the yard, findable in one place	Day one
PPE assessment	By task: eyes, hearing, respiratory, feet, high-vis on the lift apron	Day one
Spill response plan (this page, operationalized)	Kits staged, tiers drilled, the NRC number posted at the fuel point and the office	Day one
Crane & rigging / lift plans	The 85-ton lift is the yard's beating heart — daily inspection, annual certification, written lift plan for anything unusual	Day one
Stormwater plan (SWPPP + permit NOI)	The industrial stormwater permit for boatyards — drains mapped and marked, benchmarks monitored	30–90
SPCC plan	Required when aggregate oil storage crosses the federal threshold — evaluate against actual tankage at survey, then write it	30–90
Confined space program	Tanks, bilges, chain lockers — shipyard confined-space rules, permits and attendants	30–90
LOTO · fall protection · respiratory protection	Adapted from the corporate programs to yard equipment and paint work	30–90
Hurricane & severe weather plan	June–November reality: haul-out surge protocol, tie-down standards, crew stand-down, restart inspection	Before Sep
Derelict & legal-hold vessel protocol	The property inherits non-payers and derelicts — a written chain (notice, lien, county derelict process) keeps the cleanup lawful	30–90
Clean Boatyard designation package	The application that proves all of the above to the state	Season

TRAININGWho learns what, and when

Course	Who	Cadence
Yard orientation — the three rules, spill kits, stop-work, gate & lift apron discipline	Every hand, every contractor, before first day of work	Once + annual refresh
Toolbox talks	Every crew	Weekly, 10 minutes, logged
Spill response drill	All yard staff	Quarterly; one wet drill before storm season
Hot work / fire watch	Welders, fitters, their watches	Annual
Lift & machine operation	Named operators only	Certification + annual review
Forklift	Named operators	3-year cert cycle
First aid / CPR	At least one per shift on the ground	2-year cycle
OSHA 10 (shipyard) — hands · OSHA 30 — supervisors	Per role	Once, tracked
HAZWOPER awareness	The spill-response core team	Initial + annual refresher

The corporate training/cert matrix already tracks this format at APB North — the yard inherits the system, adds the yard-specific rows, and the Cert Hub pattern from the PM Console is the tracking tool.

RECORDS & METRICSWhat gets written down, and what it proves

OSHA 300 / 300A — the injury log, posted each February–April. Kept clean and current from day one, because…
TRIR and EMR — every prime contractor and government customer asks for these numbers. The vendor-packet work has already shown where the gaps are; the yard's own records close them going forward. A safety record is a sales asset in the government lane.
Inspections — daily walk (folded into the existing Power Walk route — cords, cooling, and containment), weekly supervisor yard inspection, monthly full-checklist inspection by the HSE manager. All logged.
Incidents — same-day report, photographed, investigated within 48 hours, corrective action tracked to closure in the audit trail.
Manifests & waste records — every pickup filed; the manifest number ties to the customer invoice line, so the compliance record and the revenue record are the same record.
Permit calendar — every permit, registration and designation with its renewal date, owned by the HSE manager, reviewed monthly.

THE CLOCKPhased like everything else — operating first, audit-ready by season

Phase 1 · Days 1–30

Safe to operate, clean from the first haul

Spill kits staged at the lift, the fuel point, and the waste depot. Drums and containers on the ground before the first job. Hot-work permits, orientation, PPE, and the lift inspection regime live. The HSE billing menu is on the rate card — every stream chargeable from the first customer. NRC number posted.

Phase 2 · Days 30–90

The paper catches up to the practice

Stormwater NOI filed and drains marked; SPCC evaluated against surveyed tankage and written if triggered; confined space, LOTO, fall protection and respiratory programs adapted from the corporate library; the spill-response contractor retained; the derelict-vessel protocol drafted with counsel — it is also the legal backbone of the property cleanup.

Phase 3 · September–October

Storm-ready, then season-ready

Hurricane plan drilled in the quiet months; the wet spill drill run; training matrix current; OSHA log clean. Clean Boatyard application submitted so the designation can fly when the fleet arrives.

Season

Audit-ready as a way of life

Any surveyor, insurer, prime contractor or agency can walk in unannounced and find the records current — because the records are the operating system, not a scramble before the visit.

APB South · HSE Department Plan · August 2026 — working draft.
Prepared for internal planning. Regulatory references are summaries of publicly known program families and must be confirmed with qualified counsel and a licensed environmental consultant against the surveyed facts of the property (tank volumes, drainage, permits of record) before being relied upon. The corporate written programs, training matrix and OSHA logs referenced are APB's existing library at Fort Lauderdale; this plan adapts them to the yard.

The yard that operates inside a sanctuary.