Contractor reviews issues

Seee.g.,SmithKline v. Stoats, 668F.2d201 (3rd Cir. 1981), cert, denied, Bowsher v. SmithKline Corp., 461 I S. 913, 103 S. Ct. 1891 (1983). For a more complete discussion of this issue, see Case Comments, The Comptroller General s Authority To Examine the Private Business Records of Government Contractors Eli Lilly Co. v. Stoats, Harvard Law Review 92 1148-1159 (1979). 

Important issues related to improper waste handling, treatment, and disposal. Reviews essentials of compliance central administration, waste reduction, safety labeling standards, recordkeeping, monitoring waste contractors, transportation safety, and employee emergency training. 

This analysis effort has focused on two areas 1) model enhancement and validation with data collected from DOE contractors and 2) application of the model to understand some of the design tradeoffs associated with fuel cell vehicles. The approach has been to work closely with industry partners to ensure that the models are accurate, to focus on appropriate systems issues, and to disseminate the study results in peer reviewed forums when possible. 

For this report the committee did not evaluate the two ACWA program sites at Pueblo Chemical Depot (Colorado) and Blue Grass Army Depot (Kentucky). However, the committee suggests that ACWA government and contractor management personnel review this report in detail for information, issues, and recommendations that have potential applicability to the ACWA program procedures and processes. This is particularly important since the ACWA sites... 

Contractors should conduct periodic safety meetings for their employees and subcontractors. These meetings generally review health and safety issues but environmental issues such as waste management or spill prevention can also be addressed. Informal tailgate meetings can be held daily, and... 

Training can also be a problem area. Most companies only provide basic hazard communication (HAZCOM) training to contractor employees and then rely on the contract company to provide any job-specific training to their own employees. In many instances this leaves the contract employees with gaps in their training, especially when it comes to unique issues and concerns related to the process or chemicals handled at the facility. When outsourcing functions which impact process safety, the details of the training provided to the contract employees should be carefully reviewed and customized or enhanced as needed. 

The Occupational Safety and Health Review Commission (OSHRC) initially addressed the employer-employee relationship shortly after the OSH Act was enacted in the case titled Gilles v. Cotting, Inc. In this case, two employees of the primary contractor were killed in an accident created by and resulting from the actions of a subcontractor. OSHA issued one citation to the primary contractor and one citation to the subcontractor. OSHA subsequently vacated the citation to the primary contractor, finding the citation was improper and would impose liability outside the employment relationship. Over the years, the OSHRC, as well as the various federal Circuit Courts of Appeal, has addressed this issue primarily in the construction area, with focus on creation of the hazard and control of the hazard. In recent decisions and with the inception of the multiemployer woiksite rule, the scope of the duty to safeguard employees at the worksite has been substantially expanded."... 

There were no credible indications of the temperature of the coke inside the vessel. The only temperature sensors were on the outside of the dmm. Although the operators believed that steam had passed into the drum, no steam had actually been admitted to the drum. Furthermore, no attempt had been made to put water into the drum. Nevertheless, on the morning of November 25, the foreman and operators reviewed the drnm temperature sensors and concluded that the drum contents had cooled sufficiently. It appears that Equilon plant management were also involved in the decision to go ahead, and a Permit to Work was issued for a specialist contractor, Western Plant Services, to open up the drum. Wearing oxygen masks, workers removed the top lid from the drum safely. 

For some contracts of a specialized nature, the scope of work of the construction contractor may include a design element giving rise to specifications and drawings. This could be the case for a cooling tower or a water treatment plant for example. These will go through a review and approval sequence with the EPCM contractor. They will be issued to site at approved for construction status. When a construction contractor s document supersedes an initial EPCM contractor document, the change needs to be formalized. 

For the principal contractor and contractors the identified risks that need to be considered are similar to those reviewed in the previous section. The main issue to be considered is the separation of employer operations from construction operations in terms of time, space and conditions , as summarised below ... 

This extensive report became a standard document by which the AEC staff and the Safeguard Committee judged the hazards of a reactor. The staff first reviewed it, then sent the report to the committee. It considered the report in two ways. If there were no new or unusual problems either in the report or in the staff comments on it, the committee passed judgment without a formal meeting. If major issues or new types of reactors were involved, the staff and representatives of the contractor were called before the committee to provide additional information."... 

Before the permit is issued, all hazards associated with the work should have been identified, and controls put in place. The person who issues the permit is different from the permit holder. A person cannot issue a permit for themselves because one of the objectives of the system is to make sure that a second, qualified person critically reviews the hazards and the proposed controls. If a contractor is the permit holder, then the permit should be issued by a qualified person from the host company. 

The vendors are responsible for the Risk assessments of machinery. The reports from these assessments are part of the required documentation to issue a declaration of conformity with the machinery regulations. The contractor defines the documentation on risk assessments to be delivered by the vendors for review and verification. This includes the risk assessments for machinery and assemblies of machinery that are critical from a safety point of view (cf. NORSOK S-005 in Norsk Standard, 1999). 

An evaluation form can facilitate consistent review practices and documentation. If the organization decides to perform active, frequent auditing of safety performance during the project, a detailed checklist of common construction safety requirements/issues is helpful. This checklist is usually different from an overall safety performance evaluation, which is used to support future contractor selection decisions. Detailed auditing may identify hazard and noncompliance issues, and documentation should include corrective actions taken by the contractor. 

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