|Chapter 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.
T1 Division 1 Specification Section 013529 Safety and Health Requirements
T5 Mitigation Requirements for Subcontracted Work Worksheet
| Responsibilities - Planning Phase:
Requisitioner/Subcontracting Officer's Technical Representative (SOTR)
- 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.
Facility Management & Logistics
- Maintain Master Division Specification for procured services and construction activities.
- Provide guidance to the Requisitioner in the development of the SOW.
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.]
- Assign Subcontracting Officer (SO).
- Assure the ES&H requirements are included with the contract specifications.
- Maintain list of qualified SOTRs.
Responsibilities - Pre-Bid/Pre-Award Meeting:
- 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.
Responsibilities - Post Award:
- 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:
- Complies with the requirements of the contract.
- Attends SAF100C-P.
- Flows down ES&H expectations to all lower tier subcontractors.
- Maintains SSP current throughout the life of the project.
- Suspends work when conditions or work processes are inconsistent with approved SSP or AHA.
- Ensures and verifies that all personnel performing work are properly trained.
- Ensures that workers are aware of the hazards related to their work and others that may be present at the work site.
- Verifies that workers have acknowledged in writing that they have reviewed the AHA.
- 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.
- 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.
- 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.
ISSUING AUTHORITY: ESH&Q Division
TECHNICAL POINT-OF-CONTACT: Bob May
APPROVAL DATE: 03/23/16
REVIEW DATE: 03/23/19
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 - Re-write of document to reflect current laboratory operations.
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