3410 Appendix T5

Mitigation Requirements for Subcontracted Work Worksheet

 

 

SUBJECT

DETAILS

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.

OSHA

 

 

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

 

 

ISSUING AUTHORITY

FORM TECHNICAL

POINT-OF-CONTACT

APPROVAL DATE

REVIEW DATE

REV.

 

 

ES&H Division

Bill Rainey

03/23/19

03/23/22

0.1

 

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.