3410 Appendix T5

Mitigation Requirements for Subcontracted Work Worksheet





DOE-JSA–Prime–Sub Relationship



We operate the site for DOE and they expect safety excellence from us, we expect it from you, you must expect it from all subs you hire.


SOTR is primarily responsible for confirming safe practices, JSA ES&H staff provide additional oversight and support, and DOE hold us all accountable


All employee, user, subcontractor personnel are expected to call attention to unsafe work practices – this can range from a simple question (easy to resolve issue) to rare stop work.


Questions can usually be resolved by SOTR in the field, ES&H staff can also support


All of this applies to environmental compliance; all state and federal laws apply

JSA Requirements vs.




We have specific requirements for things OSHA does not address such as cryogenics, lasers, radiation protection, etc.


Discuss specific differences based on SOW

SDS Requirements



SDS must be kept on site where workers can have access


Contractor must submit all SDS to JSA for product review and approval

Site Specific

Safety Plan (SSSP)



No work will occur until SSSP is approved


SSSP outlines general safety program; AHAs are more detailed

Activity Hazard Analysis (AHA)



This is your agreement with us regarding how you will do work, which tools and equipment will be employed


AHA required for  “each separately definable activity”;


AHAs are likely to be reviewed during safety inspections


Need to be re-evaluated if work changes; Changes can be approved in the field by the SOTR


Must be on-site with worker signatures indicating they have been briefed


Signed copies must be posted such that they are accessible to anyone


AHAs for certain “Special Hazards” must be approved by JSA including:

  • Work with silica or silica containing materials
  • Work requiring special ventilation or respiratory protection
  • Work involving use of toxic materials within a building

This additional review must be taken into account when scheduling activities


JSA may require contractor to provide a basis to support hazard mitigation measures

Site Safety & Health Representative Qualifications, Roles and Responsibilities



Certain size and or type of jobs require this full time position.  This is an important position, person will be challenged and should be prepared


SS&HR will be contractor point of contact for safety inspections


Must be located on-site and that the identified staff will have no non-safety job responsibilities

Respiratory Protection



If any AHA indicates the need for respiratory protection, JSA will review the contractors program and require evidence of medical monitoring and training appropriate to their work


JSA will provide training related to the unique hazards at Jefferson Lab including radiation and oxygen deficiency hazards.

Special Requirements for Fall Protection and Excavation



Fall protection plan must be submitted and approved prior to applicable work


Fall protection plan must address each phase of work; requirements for steel  erectors; leading-edge work; roofing; etc.

Medical Support



Subcontractor is responsible for providing its workers with occupational medicine support as needed (respirator qualification)


First aid will be provided by JSA during normal business hours – provide directions to Occupational Medicine


Serious injuries may require notification via 911, call Guard Shack at 269-5822 immediately afterwards


Report all occupational injuries or illness to JSA whether minor (first-aid) or requiring immediate medical attention. Explain reporting process. Give examples of what constitutes occupational injury or illness for the hazards identified in the AHA.

Work Permits



All permits obtained through SOTR:

  • Dig/Blind Penetration
  • Confined Space Entry
  • Hot Work
  • Lift Plans


Work may require erosion and sediment control plan


JSA staff must also inspect all construction equipment for environmental and safety issues; no leaking equipment on-site


Release of waste water to surface or sewer will need to be pre-approved by JSA

Worker Training



Detail training requirements


Basic requirements are SAF100C


Work inside the accelerator includes radiation training; type is dictated by areas to be entered; ODH training for work in tunnel, other locations


Discuss other required training based on scope of work

Tools & Equipment 



Contractor must provide JSA with proof that their employees are trained in the use of powder actuated equipment and powered industrial equipment. 


Proof of this training must be provided before related activities.


Form Revision Summary


Revision 0.1 – 03/23/19 – Periodic Review; updated TPOC from B.May to B.Rainey

Revision 0.0 – 03/23/16 – New Content











ES&H Division

Bill Rainey





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 3/21/2019.