3410 Subcontractor Construction Safety
The purpose of this chapter is to ensure that construction activities meet the Jefferson Lab environmental, safety, health and quality (ESH&Q) requirements and expectations in order to fulfill the ESH&Q Policy. Information provided in this chapter is for use by Jefferson Lab personnel to establish minimum requirements for the safety and health protection of subcontractor personnel, lab staff, and visitors involved in construction activities.
This chapter applies lab-wide to all construction activities. “Construction means combination of erection, installation, assembly, demolition, or fabrication activities involved to create a new facility or to alter, add to, rehabilitate, dismantle, or remove an existing facility. It also includes alteration and repair (including dredging, excavating, and painting) of buildings, structures, or other real property, as well as any construction, demolition, and excavation activities conducted as part of environmental restoration and remediation efforts.” as defined by DOE’s Worker Safety and Health Program 10CFR Part 851. This chapter also applies to subcontracted service activities.
3.0 Roles and Responsibilities
3.1 Planning Phase
3.1.1 Requisitioner/Subcontracting Officer’s Technical Representative (SOTR)
· Develop the Statement of Work (SOW). SOW should be written with clear and concise objectives and expectations.
· Determine and specify safety documentation to be submitted.
· Explicitly identify safety and health requirements in ES&H Manual Chapter 3410 Appendix T1 Division 1 Specification Section 013529 Safety and Health Requirements.
· Utilize JLab Subject Matter Experts (SME) for guidance. [see ES&H Manual Chapter 2410 Appendix T1 for a listing of hazard issue SMEs]
· Determine and specify the level of training and qualifications needed for the Site Safety and Health Representative (SSHR).
· Identify any Jefferson Lab specific hazards as they apply to the scope of work or work area (e.g. ODH, radiation area, etc.). Refer to ES&H Manual Chapter 2410 Appendix T1.
· Specify inspection hold points as required. [defined as a mandatory verification point beyond which a work cannot proceed without approval by the Engineer or Consultant or Municipality Inspector]
· Route the specifications and drawings through Jefferson Lab ESH&Q Division for review before releasing for bid, allowing 10 business days for the review.
3.1.2 ESH&Q Division
· Review PRs that identify the use of on-site labor. Inform Procurement and Requisitioner whether SOW is construction as defined in this chapter.
· Assign ESH&Q Representative to support SOTR during pre-bid and post-award activities.
· Review and provide comments to the specification and associated documentation.
· Work with the Requisitioner/SOTR in determining the qualification level required for SSHR. SSHR qualifications are to be based on the complexity of the scope of work and the skill set needed to provide proper oversight of the project.
· Work with the Requisitioner/SOTR in determining the safety documentation required based on the complexity of the scope of work and the skill set needed to provide proper oversight of the project. Refer to ES&H Manual Chapter 3410 Appendix T2 Matrix for Determining SSP, Safety Rep, AHA.
3.1.3 Facility Management & Logistics
· Maintain Master Division Specification for procured services and construction activities.
· Provide guidance to the Requisitioner in the development of the SOW.
3.1.4 Associate Directors/Division Managers
· Assign qualified SOTR for construction activities, if not being managed through FM&L. [SOTRs shall have minimum Jefferson Lab SOTR training and shall have either 30hr OSHA training or shall obtain the direct support of equally qualified staff.]
3.1.5 Procurement Services
· Assign Subcontracting Officer (SO).
· Assure the ES&H requirements are included with the contract specifications.
· Maintain list of qualified SOTRs.
3.2 Pre-Bid/Pre-Award Meeting
3.2.1 Subcontracting Officer
· Organize site visit.
· Conduct Pre-bid meeting to include SOTR, ESH&Q Representative, and other support staff as required based on the scope of the work.
· Document meeting minutes.
· Communicate questions received during the site visit using a contract amendment.
· Collect required documentations for evaluation of bids received.
· Follow the Procurement Operation Manual (POM) for awarding contract.
· Provide an overview of the SOW.
· Specify hold points in the project. [can refer to a safety issue such as verifying the suitabilitiy of a tie-off point or a hold on construction activities until an inspection is passed; particularly important when work cannot be inspected later because a problem could be covered up (i.e., a hold point before a concrete pour permits verification of steel reinforcing before it is covered with concrete).]
· Identify required training.
3.2.3 ESH&Q Representative
· Communicate mitigation requirements to subcontractor provided in ES&H Manual Chapter 3410 Appendix T5 Mitigation Requirements for Subcontracted Work Worksheet prior to bid.
· Provide safety brief prior to visitors before embarking on site visit.
· Provide clarification of ES&H questions via the SOTR to Procurement.
· Evaluate/accept ES&H Subcontractor Evaluation submittal as part of the initial proposal [see ES&H Manual Chapter 3410 Appendix T3 Subcontractor ES&H Evaluation].
3.3 Post Award
3.3.1 Procurement Services
· Conduct a Pre-Construction Meeting.
· Maintain contract documentation.
· Provide copies of Written SSP and initial Activity Hazard Analysis (AHA) to SOTR for approval.
· Submit Written SSPs to the SOTR review.
· Notify subcontractor of issues and concern.
· Maintain records of subcontractor performance related to ES&H requirements
· For contracts >$150K, evaluate subcontractor’s eligibility for future subcontracts based upon ES&H performance.
· Manage the contracted work in accordance with the contract specification.
· Serve as first line of contact with subcontractor in the field.
· Submit Written SSP to ESH&Q for review.
· Approve Written SSP and Activity Hazard Analysis (AHA).
· Obtain the required JLab work permits.
· Assure no work is performed until written SSP and/or AHA are approved.
· Conduct walk-throughs of work site.
· Notify Procurement if formal Stop Work is required.
· Enforce the ES&H requirements of the contract. Ensure subcontractor:
o Complies with the requirements of the contract.
o Attends SAF100C-P.
o Flows down ES&H expectations to all lower tier subcontractors.
o Maintains SSP current throughout the life of the project.
o Suspends work when conditions or work processes are inconsistent with approved SSP or AHA.
o Ensures and verifies that all personnel performing work are properly trained.
o Ensures that workers are aware of the hazards related to their work and others that may be present at the work site.
o Verifies that workers have acknowledged in writing that they have reviewed the AHA.
o Reinforces the expectation that when conditions change as a result of a change to the process, scope creep, tooling, or other factors or if workers are unsure about the task to be performed that work will be stopped and reassessed before proceeding. Initiate revision to AHA or SSP when necessary.
o Reports all events and submits incident reports. Reports injuries to Occupational Medicine (Occ. Med).
· Communicate subcontractor’s ES&H deficiencies to Procurement.
· Share lessons learned applicable to the task with subcontractor. When there has been a change in project staffing either from Jefferson Lab or the subcontractor, SOTR shall communicate any project specific lessons learned to the new team members.
3.3.3 ESH&Q Division
· At the Post Award meeting, reinforce the mitigation requirements to subcontractor provided in the ES&H Manual 3410 Appendix T5 Mitgation Requirements for Subcontracted Work Worksheet .
· Provide SME support to review written SSP, activity hazard analysis, and mitigation plans prior to SOTR’s approval.
· Assist SOTRs with safety oversight during the construction activity.
· Evaluate subcontractor’s safety submittals (e.g. fall protection plan, exposure assessment, IH monitoring plan, etc.) provide feedback to SOTRs.
· Share lessons learned with SOTRs.
4.1 Pre-Bid Meeting
The SO schedules the meeting. The ESH&Q Liaison attends to review ES&H requirements at Jefferson Lab. ESH&Q staff will utilize the ES&H Manual 3410 Appendix T5 Mitigation Requirements for Subcontracted Work Worksheet.
4.2 Evaluation of Subcontractor
The Subcontractor shall have past safety performance evaluated and accepted before any subcontract can be awarded. ESH&Q will evaluate that performance against the criteria in ES&H Manual Chapter 3410 Appendix T3 Subcontractor ES&H Evaluation. Recommendations on acceptability of the subcontractor will be made to the SOTR.
4.4 Subcontractor Site Safety Plan Review
· Where required by contract, the subcontractor shall submit a copy of the company’s SSP for review and acceptance. ES&H Manual Chapter 3410 Appendix T1 Division 1 Specification Section 013529 Safety and Health Requirements outlines the expectations for the SSP.
· For small, non-complex construction activities, an AHA may be all that is required to meet these requirements [see ES&H Manual Chapter 3410 Appendix T2 Form Matrix for Determining SSP, Safety Rep, AHA]. If no subcontractor SSP is required, the subcontractor shall submit a document that includes:
o The name and qualifications of the SSHR for the project, as well as any hazard specific competent persons required by the OSHA standard (excavation, or scaffolding for example).
o A list of the project activities for which hazard analyses will be written and submitted.
· ESH&Q and the SOTR jointly review the SSP Review Checklist. ESH&Q provides comments and recommendations back to the SOTR within 15 working days. This is performed through the ESH&Q Design Review database.
· Once the SOTR has approved the SSP, it is valid for a three-year period; however the SSP will be reviewed for completeness with each new project.
· Work cannot commence until SSP and AHA have been approved by SOTR.
· There may be conditions under which a modification to the SSP may be required:
o Change in work scope not previously addressed in the accepted plan;
o Incorporation of Lesson Learned which required programmatic change; or
o New standards have become effective.
· In these cases the subcontractor must submit in writing the section of the plan revised, justification for the changes, and any supporting documentation necessary. ESH&Q will review this change and provide recommendations for approval to the SOTR.
4.5 Emergent Work
Occasionally it may be necessary for subcontractors to perform emergent work but timing does not allow for submittal of a SSP. In these cases, an AHA is required and must be approved by the SOTR. It must be reviewed by ESH&Q in accordance with 4.4 above. Under no circumstances shall an emergency serve as an exemption from complying with ES&H requirements
· A written AHA is required of all construction work, regardless of cost and who performs the work. The AHA shall identify all hazards associated with each phase of work, and the mitigations to be employed to eliminate or reduce those hazards. Each identifiable feature within a project requires a written hazard analysis. Work will not begin until the SOTR has reviewed and approved the AHA and any associated work control documents.
· In some instances, ESH&Q is required to review the AHA prior to the SOTR approval. These AHAs must be submitted to the ESH&Q Division Liaison for review. Those instances include:
o Work with silica or silica containing products. Activities include, but are not limited to:
o Cutting of masonry products.
o Installing, cutting, or removing concrete.
o Installing or removing sheet rock compound.
o Required use of special ventilation and/or respiratory protection.
o Use of toxic or flammable materials in occupied spaces.
o Active fall protection in use.
· Subcontractor employees must review the AHA and sign the document, signaling their acknowledgement of the information, and agreeing to comply. If new hazards are identified, the AHA must be revised and resubmitted for approval.
· If there are two or more subcontractors working in the same area under different AHAs, the SOTR(s) must coordinate activities and resolve any conflicts. All working groups must review and sign each other’s AHA.
· The completed, signed AHA must be available at the jobsite.
4.7 Preconstruction Meeting
All work requires a preconstruction meeting. The purpose of the meeting is to review the work scope, and assure all submittals have been accepted and work is ready to begin. The following shall be invited: SOTR, ESH&Q Liaison, Occupational Medicine, and any support staff required. The Preconstruction meeting will cover the period of performance, SOW, ESH&Q requirements, training and security requirements. The ESH&Q Division Liaison or the DSO will attend to ensure that ES&H expectations are conveyed to the subcontractor via the ES&H Manual Chapter 3410 Appendix T5 Mitigation Requirements for Subcontracted Work Worksheet.
4.8 SOTR Training
Any SOTR who is assigned to oversee construction work as defined by 10 CFR 851 (see section 2.0 above), is required to take the following:
· Procurement SOTR Training
· OSHA Construction 30 hour
· Activity Hazard Analysis (GEN133)
· SOTR ES&H
· Training required by the area where the work will be performed
4.9 Subcontractor Training
· All subcontractors who will not be continuously escorted by a trained Jefferson Lab employee are required to take SAF100C-P before start of work. The training expires three years from the date of attendance. Training can be arranged through FM&L.
· Subcontractor employees are expected to have the training, medical surveillance (as defined by OSHA), and PPE that will allow them to work safely at Jefferson Lab. SOTRs are expected to confirm that subcontractor training is complete. Jefferson Lab will provide training, medical surveillance (as defined by Occ. Med), and equipment for those hazards that are unique to Jefferson Lab, and may not be routinely encountered elsewhere. These hazards include:
o Oxygen Deficiency
4.9.1 Delivery Personnel
Delivery personnel are not required to take SAF100C-P if a trained subcontractor or Jefferson lab employee escorts them. They are required to wear PPE applicable to their own activities. When outside their vehicle, they must wear PPE as specified in the AHA within the construction delivery area.
4.10 Visits to Construction Sites
Anyone entering a construction site must notify the SOTR. The SOTR will provide a briefing or provide a copy of the AHA for them to read and sign. PPE as defined in the AHA or by the subcontractors SSP is required at all times.
4.11 Oversight of ES&H Performance
· The SOTR is responsible for monitoring the subcontractor’s performance to verify conformance with the SSP and AHAs.
· ESH&Q will perform oversight inspections of construction sites as well. The frequency is based upon the complexity of the project and specific activities, hazard level, and subcontract’s demonstrated level of compliance. Any findings will be brought to the attention of the SOTR. These inspections are to be documented in the Safety Observation database.
· Consistent with JLab ES&H Manual, JSA employees, users, and subcontractors have the responsibility and expectation to stop work that endangers people, environment, or property. This extends to construction activities by subcontractors. For construction activities by subcontractors, a stop work order is a contractual matter implemented by the SO.
· If the SO or SOTR is not available at the time a Jefferson Lab employee, user, or subcontractor observes an imminent danger condition, that employee, user, or subcontractor shall interface with the individual conducting the activity and ask for the SSHR or Superintendent to join them for the discussion. If the observed issue is not resolved, a work suspension should be issued and the SOTR notified. Subcontractors are instructed to immediately notify the SOTR or if unavailable, contact 269-7400 any time work is stopped under the above described conditions.
· The SOTR will consult with the subcontractor SSHR or work superintendent to determine if the hazardous condition represents a deficiency with the subcontractor safety program or its implementation, or represents an issue that can be quickly abated.
· If the issue is abated by the subcontractor, the work may be restarted if the conditions identified in the AHA or SSHP, as applicable, are met. If the hazard cannot be abated quickly, or if consensus cannot be reached as to the corrective action, or if the issue represents a deficiency with the subcontractor safety program, the SOTR will consult with the SO to determine if a contractual stop work order is necessary. The SO, SOTR, and EH&S will work with the subcontractor to restart work.
· An activity that has been stopped by a contractual stop work will require SO approval after any established restart conditions have been completed.
4.13 Work Clothing/PPE on a Construction Site
Anyone entering a construction area must wear safety shoes or boots that cover the ankle. Long pants and shirts with sleeves must be worn as well. In addition, any specific clothing or PPE requirements established in the AHA must be worn as well.
4.14 Heavy Equipment Inspections
The Material Handling Manager (MHM) must inspect heavy equipment and rolling stock, such as mobile cranes, aerial lifts, and fork trucks, prior to use. The SOTR must coordinate this inspection.
4.15 Incident Investigations
The SOTR shall report all incidents and near-misses to the ESH&Q Reporting Officer. If a Notable Event is declared, the SOTR will coordinate the initial fact finding meeting with the subcontractor, and implement the requirement of ES&H Manual Chapter 5200 Event Investigation and Causal Analysis Process.
5.0 Technical Appendices
· ESH Manual Chapter 3110 Facility Design and Modification Review applies during the design process.
7.0 Revision Summary
Revision 3.0 – 03/23/16 – Formerly titled ‘ES&H Aspects of Procurements’; revised to clarify responsibilities and align with 10CFR851
Revision 2.3 – 09/17/12 – Update to reflect changes to Appendix T2
Revision 2.2 – 03/27/12 – Update to Web Chapter Format.
Revision 2.1 – 07/18/11 – Technical Point-of-Contact re-assigned from John Kelly to Bob May, per Mary Logue.
Revision 2.0 – 01/28/10 – Edited to address responsibility of requisitioners and SOTRs to review ES&H Manual Chapter 2410 Appendix T1 Hazard Issues List and associated documents to ensure Jefferson Lab safety requirements are addressed for material and subcontractor procurements.
Revision 1.0 – 03/10/09 – Rewrite of document to reflect current laboratory operations.