TITLE:

ES&H Manual

 

DOCUMENT ID:

3420 ES&H Aspects of Procured Services and Construction

 

 

Introduction

 

Jefferson Lab, in its role as a federal contractor, subcontracts for many tasks on site. These include construction, repair, service, and preventive maintenance activities. We also occasionally use subcontract labor on specific projects. It is essential that our subcontractors perform to our high expectations for health, safety, and environmental stewardship. In general, subcontractor employees are required to observe the same ESH&Q precautions as Jefferson Lab employees. Additional specific procedures or requirements may apply to particular subcontracts—this includes the use of environmentally friendly products and practices required in the performance of their tasks. This chapter describes how these expectations are integrated into the procurement and management of subcontractor activities.

 

It is equally important that we evaluate prospective subcontracted projects for ESH&Q implications. This should be done in the earliest phases of planning and design to avoid personnel and environmental hazards during the project. We also need to examine proposed activities for long-term liabilities. This chapter describes the ESH&Q review process for procured services and construction. A similar process for the procurement of materials is provided in ES&H Manual Chapter 3410 ESH&Q Aspects of Material Acquisitions.

 

In addition to other requirements for subcontractors to perform work on the Jefferson Lab site safely, the following requirements shall apply. The subcontractor shall furnish to Jefferson Lab, for approval, an Integrated Safety Management Plan under any of the following situations:

 

·       subcontracts for $20M or more for work to be performed on site

·       renewable subcontracts for $5M or more per year for work to be performed on site

·       contracts which have a scope of work on site not fully covered by Jefferson Lab’s Final Safety Assessment Document

 

The required elements of the plan shall be the same as those required of the laboratory. Schedules and guidance for providing the plan shall be provided to potential subcontractors at the time bids or proposals are solicited. The Subcontracting Officer’s Technical Representative for the contract shall be responsible for approving the plan.

 

Key Terms

 

affirmative procurement The acquisition of products determined to be environmentally friendly. This includes products that have recycled content or are bio-based products.

bio-based product A commercial or industrial product (other than food or feed) that utilizes biological products or renewable domestic agricultural (plant, animal, or marine) or forestry materials.

customer (For the purposes of this chapter.) The Jefferson Lab manager who has signed or approved a requisition for a procured service.

integrated safety management (ISM) An approach where safety accountability and performance are woven into all aspects of work planning, design, and conduct.

life-safety Features of building construction and operations which ensure safe egress and which minimize the risk to occupants from fire and explosion. National consensus codes define life-safety provisions and practices.

lower-tier subcontractors All additional subcontractors performing work on site for and under the direction of a business that is under contract with Jefferson Lab.

managing division The Jefferson Lab division which has daily operational control over the subcontractor’s operations. This includes control over quality, performance, adherence to technical and ESH&Q specifications, and authorization for payment.

safety plan An official, binding document prepared by a subcontractor, bearing the signature of a responsible manager of the subcontracting company, that defines the ESH&Q practices and responsibilities necessary to conduct operations on Jefferson Lab property in a safe and environmentally sound manner. Safety plans must be augmented by specific activity hazard analyses where required.

subcontractor A business entity under contract with Jefferson Lab to perform specified operations or services.

subcontracting officer’s technical representative (SOTR) A knowledgeable Jefferson Lab employee assigned to the subcontract. The SOTR ensures subcontractor conformance with technical specifications, ESH&Q requirements, and serves as the primary liaison between the subcontractor and Jefferson Lab.

 

Hazard Avoidance

 

Hazards to Subcontractor Employees

Subcontracted work activities can entail all of the potential hazards that confront Jefferson Lab employees and other site visitors. The main distinction (and area of greatest concern) is that subcontractor employees may not have adequate requisite recognition skills for hazards found at Jefferson Lab which are unusual elsewhere. For this reason, Jefferson Lab-conducted awareness training is mandatory for all subcontractor workers who may be exposed to hazards found here.

 

Operational Hazards to Jefferson Lab Employees

It is possible for a customer to identify an operational need, envision a solution, initiate the procurement process, and take delivery of a finished product with serious, unforeseen ESH&Q implications. Jefferson Lab has experienced situations where the subcontractor activity itself posed problems. There have also been situations where long-term ESH&Q liabilities were created by a project. These include inappropriate use of a space with respect to fire codes, insufficient electrical services for the intended operation, and inadequate exhaust ventilation. To prevent these kinds of problems, it is important for informed ESH&Q staff to participate in planning of all projects and operations which are to be subcontracted.

 

If you witness a subcontractor creating an imminent danger, issue a stop-work order on the spot, as prescribed by ES&H Manual Chapter 3330 Stop-Work Orders.

 

If you witness a subcontractor performing work in an unsafe manner, attempt to notify the SOTR immediately (call Facilities Management at ext. 7400). If you cannot locate the SOTR or ESH&Q staff who can resolve the problem, use the ESH&Q concern resolution process provided in ES&H Manual Chapter 2310 ES&H Concern Resolution.

 

Environmental Hazards & Liabilities

It is important that subcontractors know of our expectations for sound environmental work practices. Issues such as chemical emissions, waste disposal, spill prevention, and erosion control must be addressed in specifications and written scope of work. These should be emphasized in pre-bid and pre-work meetings, and they must be monitored as part of regular subcontract performance oversight.

 

Typical Potential Hazards:

Introduction of new hazardous materials onto Jefferson Lab properties:

·       The contractor must have a copy of the MSDS for each material and provide a copy to the SOTR.

·       Erosion control measures should be implemented for projects involving excavation.

·       Waste materials must be disposed of appropriately in either the trash or by recycling:

o   Contractors should be encouraged to recycle whenever possible. 

o   Contractors should be encouraged to purchase goods made from recycled materials whenever feasible. 

·       Potential for groundwater contamination.

·       Use of any Ozone Depleting Substances (ODSs) during construction (contact ESH&Q if ODSs are being used). 

·       Conservation of water and energy resources should be implemented whenever possible.

 

Prior to large scale construction projects, a NEPA review will be performed to identify all potential Environmental Impacts the project may impose. The review will also address acceptable control methods to be used to mitigate impact. It is important that all of these controls are addressed in specifications and scope of work.

 

Responsibilities

 

Customer

 

Customer’s Division ESH&Q Staff

 

Managing Division/SOTR

 

Business Services Director

 

Subcontracting Officer

 

Initial Subcontract Review Procedures

 

Customer (the Requisitioning Jefferson Lab Manager)

Services procured from subcontractors include repair, labor, new equipment installation, environmental monitoring, fabrication projects, renovation of existing space, new construction and so on. The process is essentially the same in all cases. Before you, as customer, submit a requisition, follow this procedure:

 

1.     Use the one-page evaluation list—ES&H Manual 3420 Appendix T1 ESH&Q Evaluation of Proposed Subcontracted Activities. Will the proposed activity have any of these aspects? If there are life-safety issues involved, contact Facilities Management.

2.     Use the risk/hazard evaluation techniques prescribed in ES&H Manual Chapter 3210 Hazard Identification and Characterization. Note the resulting risk code prominently on the requisition.

3.     Consult your division ESH&Q staff for recommendations about specifications, the scope-of-work description, and other preliminary project documentation.

4.     If you will not be the project manager, consult with the appropriate person in the managing division to ensure the ESH&Q expectations are well stated and enforceable.

 

When you approve the requisition, this attests to your good-faith efforts in evaluating the activity for ESH&Q implications.

 

ESH&Q Staff (Customer Division)

Back up the customer’s review of proposed subcontracted activities. Consider both immediate and long-term ESH&Q implications. If a project has aspects unfamiliar to you, consult with other laboratory resources to get an accurate understanding of potential problems.

Inform the customer of the risks you believe need mitigation. Recommend mitigation strategies as appropriate.

 

Make recommendations to the customer in a useful format. This may include marked-up drawings and specifications, new draft specifications, detailed sequence of work, references to Jefferson Lab ESH&Q Manual, codes or standards, required permits, etc. Give recommendations on requirements for the subcontractor's safety plan, including any specific hazardous activity analysis and control strategies. In cooperation with the SOTR and the Business Services Department, determine if the project warrants some form of subcontractor pre-qualification, credentials, or demonstrated competency.

 

Managing Division/SOTR

To the greatest extent practicable, use normal design review and approval processes to address ESH&Q aspects. Invoke the appropriate ESH&Q clauses into the project specifications. Ensure that expectations for ESH&Q performance are integrated into the project in an effective and enforceable way. Include special project management tools into the specifications whenever needed.

 

Specifications beyond the standard requirements should be tailored to the job. Examples include:

 

·       Protective measures for people or equipment in the vicinity

·       Advance work-start notice

·       Pre-approval by Jefferson Lab of chemicals or apparatus

·       Training, qualification required beyond ESH&Q orientation and GERT

·       Requirements for permits, certifications, or proof of special credentials

·       Special work hours

·       Incentives and penalties

 

Procurement Department

Incorporate standard Jefferson Lab ESH&Q specifications into the bid package as prepared by the SOTR. Include activity-specific requirements as provided by the customer and/or managing division. Schedule and conduct pre-bid and pre-work meetings with the subcontractor, customer, SOTR, Procurement Department representative, and ESH&Q staff from the customer's division.

 

Inform the SOTR of the option to include incentives and penalties for ESH&Q performance and ensure a decision is made on the appropriateness of this strategy for the work being subcontracted.

 

Subcontract Management Procedures

 

Managing division/SOTR

Use pre-bid and pre-work meetings with subcontractors to state Jefferson Lab ESH&Q expectations clearly. Inform subcontractors of our training requirements, job-specific submittals, stop-work procedures, and any other project management tools in effect for the activity.

 

Provide sufficient direct oversight of subcontractors to ensure compliance with ESH&Q requirements. Be especially attentive in the early phases of an activity. Ensure subcontractor personnel receive required Jefferson Lab training before starting work. If advance notice of work-start was required, insist on its observance. Inform ESH&Q staff and Area Safety Wardens who need to know about start-up of potentially hazardous work.

 

Consult with customer’s division ESH&Q staff whenever you have concerns about safe practices. Intervene quickly if you believe there is a problem. Document all observations of ESH&Q deficiencies (and also noteworthy proficiencies). Confer with Jefferson Lab procurement staff if you have questions or concerns about subcontractor performance.

 

Ensure that the subcontractor and subcontractor employees are aware of safety concern hotlines and reporting mechanisms.

 

Advance notice of work-start

Some activities pose a higher-than-normal degree of hazard potential. It is important that key Jefferson Lab personnel—SOTR and selected ESH&Q staff—get sufficient prior notice of these jobs to schedule observation of the work. These activities include, but are not limited to:

·       •Work aloft

·       •Excavation

·       •Confined-space entry

·       •Fire hazard work

·       •Work on energized electrical equipment

·       •Use of motorized cranes

·       Use of flammable or toxic materials inside buildings

 

Specifications for subcontracted activities shall include requirements for the subcontractor to provide not less than 24 hours advance notice of these operations. This notification must be given directly to the SOTR, who must give consent to the operation.

 

The SOTR shall promptly inform the appropriate individuals who need to be aware of the activity or who may need to inspect the work site.

 

This is normally a one-time notification unless the SOTR specifically directs the subcontractor to provide subsequent advance notice of potentially hazardous phases of work.

 

Subcontractor Safety Plans

Safety plans are required for all service subcontractors working on site. They are also required for all construction and on-site fabrication activities with an estimated cost of $100,000 and above. Regardless of dollar value, a safety plan is required for any activity that has an anticipated Risk Code of 2 or greater (see ES&H Manual Chapter 3210 Hazard Identification and Characterization), or that has a need for special worker protection measures.

 

Basic required safety plan elements are listed in Jefferson Lab’s standard service and construction specifications. Any hazardous element of a project mu