ES&H Manual



3410 Appendix T2

Mitigation Requirements for  Hazard Issues involving Service and Construction Procurements



1.0          Purpose


Jefferson Lab’s Subcontracting Officer’s Technical Representatives (SOTR) use this procedure to:


·       Appropriately plan procurement documents to accurately identify hazard issues and required mitigation;

·       Adequately communicate mitigation requirements to subcontractor prior to bid;

·       Reiterate mitigation requirements to subcontractor during a post contract award and pre-work meeting; 

·       Document Feedback and Lessons Learned.


2.0          Scope


The requirements of this appendix apply to all subcontracted services including construction in accordance with ES&H Manual Chapter 3410 ES&H Aspects of Procurements.


3.0          Responsibilities

NOTE:           Management authority may be delegated at the discretion of the responsible manager.


3.1            Requisitioner/Subcontracting Officer’s Technical Representative (SOTR)

·       Complete and maintain GEN 133 Activity Hazard Analysis.

·       Identify hazard issues.  (See ES&H Manual 2410 Appendix T1 Hazard Issues List.)

·       Establish safety and health mitigation requirements - Confer with ES&H Subject Matter Experts (SMEs).

·       Explicitly identify safety and health requirements within the contract documents.

·       Document feedback and lessons learned in accordance with ES&H Manual Chapter 3410 Appendix T1 Mitigation Requirements for Hazard Issues relating to Equipment and Material Procurements.


3.1.1       SOTR also:

·       Determine the need of a Subcontractor Safety Plan and/or Hazard Analysis.

·       Communicate Jefferson Lab’s hazard mitigation requirements to subcontractors as detailed within relevant ES&H Manual Chapters.

·       Communicate subcontractor ES&H deficiencies to Procurement.


3.2            Procurement Services

·       Assure the identified ES&H requirements are included within the contract.

·       Maintain records of supplier/subcontractor performance related to ES&H requirements.

·       Evaluate subcontractor’s eligibility for future subcontracts by reviewing feedback documentation.


3.3            ESH&Q Division

·       Provide guidance to requisitioners, SOTRs, and Procurement Services, in the development of ES&H mitigation requirements.


3.4            Facilities Management &Logistics Manager

·       Maintains ES&H specifications for procured services and construction.


4.0          Process Steps


4.1            Planning

The SOTR completes the following process steps and uses the information to develop procurement documents that contain mitigation required by Jefferson Lab for recognized hazard issues.


Step 1:          Identify Hazard Issues


·       Review ES&H Manual Chapter 2410 Appendix T1 Hazard Issues List.

·       Determine relevant hazard issues.  


Step 2:          Establish Safety and Health Mitigation Requirements

For all hazard issues recognized to be relevant:


·       Review the associated ES&H Manual Chapters and Appendices listed to determine the established hazard mitigation requirements.

·       Consult with the Subject Matter Experts to identify specific ES&H requirements.


NOTE:  The Material Identification and Traceability, Supplier Evaluation, and Pressure System Quality Procedures may apply to some acquisitions (e.g., materials for use in pressure vessel systems).  These documents are available in the QA Program Description.


Step 3:          Explicitly Identify Mitigation Requirements within the Contract Documents:


·       Include FM&L’s Division 1 Master Specifications in all procurements of construction services


·       Subcontractor Safety Plan (SSP)

The need for a subcontractor to provide a SSP is related to the scope, complexity, and duration of the work.  The determination is made by the SOTR after consultation with Procurement, the Division Safety Officer, and the ESH&Q professional(s).  Jefferson Lab reserves the right to request a SSP for any work performed by an outside vendor.  One is required if:


o   The value of the subcontract exceeds $20 million,

o   The subcontract will occur over multiple years with the value of services in any year exceeding $5 million




·       Task Hazard Analysis (THA, AHA or equivalent):


o   All construction activities, regardless of cost  

o   On-site fabrication activities with an estimated cost of $100,000 and above,

o   Any activity that has an anticipated Risk Code of >3 (see ES&H Manual Chapter 3210 Appendix T3 Risk Code Assignment), or

o   As required for specialized work*. 


*Specialized work includes:

  • 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


  • Required use of special ventilation and/or respiratory protection.  Examples include:

o   Use of chemicals in a quantity or manner recommended by the MSDS.

o   As recommended by manufacturer information.


  • Use of toxic materials inside a building.


Submit any mitigation requirement documents, or equivalent, to ES&H Division Liaison for review prior to approval.


4.2            Communicate Mitigation Requirements to Subcontractor

The SOTR completes the following process steps.


Step 1:          Schedule Pre-Work (e.g.: Pre-Bid, Pre-Award) Meeting


·       Invite relevant ESH&Q SMEs to the meeting.

·       Allow ESH&Q SMEs adequate time to fully explain mitigation required by Jefferson Lab


ESH&Q staff will utilize the following worksheet:


4.3            Post Contract Award and Pre-Work Meeting

The SOTR completes the following process steps.


Step 1:          Review and Approve Subcontractor Documentation


·       Conduct a pre-work meeting with subcontractors to communicate Jefferson Lab’s expectations regarding ES&H work practices. 

·       Invite relevant ESH&Q SMEs to the meeting.

·       Allow ESH&Q SMEs adequate time to fully explain mitigation required by Jefferson Lab.


ESH&Q staff will utilize the following worksheet:

·       Submit any required safety plans, licenses, permits, training to appropriate SME for review prior to commencement of work. 


4.4            Document Feedback and Lessons Learned

The SOTR performs the following as required.


·       Monitor the subcontractor’s performance to ensure requirements are maintained and the safety and health of Jefferson Lab personnel, subcontractor employees, and the public are considered.

·       Stop work and notify ESH&Q professional if work results in any unmitigated hazard issues.

·       If there is a change in Project Leadership or ES&H Staff, assure that subcontractor shares key lessons learned (perhaps a discussion on previous events).  This is especially important on a multi-year, multi-phase project where lessons learned early on in the project need to be communicated to new subcontractor staff.

·       Provide comments to Procurement Services regarding subcontractor performance.

·       Document lessons learned utilizing Jefferson Lab Operating Experience Database.


5.0          Revision Summary


Revision 2.3  11/12/13  Added bullet #3 in section 4.4 to assure lessons learned are communicated when project leadership or ES&H staff change per MLogue.

Revision 2.2  09/17/12  Clarification made to Process Steps.

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  Re-write of document to reflect current laboratory operations.









ESH&Q Division

Bob May





This document is controlled as an on line file.  It may be printed but the print copy is not a controlled document.  It is the user’s responsibility to ensure that the document is the same revision as the current on line file.  This copy was printed on 11/12/2013.