Rules for contractors

Subcontractors are responsible for the health and safety of their employees and for complying with the requirements established in the HASP and the guidelines established in Safety Rules for Contractors. Subcontractors will report to the SM. 

As you can see, OSHA sets forth plenty of rules for contractors to follow. In addition to OSHA, you have to work within the framework of EPA regulations and any state and local requirements. Large companies can afford safety officers to adhere to the rules. Most contractors do not have this luxury. Therefore, the burden may fall on your shoulders. If it does, take it seriously. 

Promulgation of the PSM Rule has heightened the awareness of chemical safety management issues whithin the DOE. This handbook is intended for use by DOE facilities and processes covered by the PSM rule to facilitate contractor implementation of the PrHA element of the PSM Rule. However, contractors whose facilities and processes not covered by the PSM Rule may also use this handbook as a basis for conducting process hazards analyses as part of their good management practices. 

With miles of tarred roads around the smelter shared by metal transport vehicles, contractors vehicles, and bicycles, a major road safety campaign was implemented. Two security personnel were selected and sent to the local municipality for training and were appointed as traffic controllers. They patrolled the roads and issued friendly warnings to traffic rule offenders. The objective was to educate rather than punish, but there was a three strikes and you re out policy, especially for contractors. A mobile, solar-powered radar road speed indicator was placed at different positions within the plant to remind drivers of the speed limit. A strict vehicle seat belt policy was introduced, and no one was allowed onto the premises unless all vehicle occupants were buckled up. 

Many departments and agencies not listed above have safety programs for their own employees or contractors. For example, the U.S. Army Corps of Engineers has detailed safety rules for Corps construction that contractors must foUow. 

If a company or organization hires a contractor to do work, it is critical to identify protections for contractor employees. A contract should state which safety and health laws, regulafions, standards, rules, and procedures apply to the contractor and the work provided. 

The TSR rule requires contractors to prepare and submit TSRs for DOE approval. This guide provides guidance in identifying imporfanf safefy paramefers and developing fhe content for the TSRs that are required by 10 CFR 830.205. 

DOE issued 10 CFR 820 Procedural Rules for DOE Nuclear Activities (23) effective September 16, 1993. These procedural rules are used in applying its substantive regulations and orders relating to nuclear safety. These procedural rules are intended to be an essential part of the framework through which DOE deals with its contractors, subcontractors, and suppliers to ensure that its nuclear facilities are operated in a manner that protects public and worker safety and the environment. In particular, this part sets forth the procedures to implement the provisions of the PAAA of 1988 which subjects DOE contractors to potential civil and criminal penalties for violations of DOE rules, regulations, and orders relating to nuclear safety (DOE Nuclear Safety Requirements). 

Before the Deepwater Horizon accident, the embodiment of a disastrous oil spill was the 1989 grounding of the Exxon Valdez in Prince William Sound off the coast of Alaska. That accident, for which Exxon was found responsible, led to a profound rethinking of safety management at the company. Exxon developed a rigid system of rules for all its operations, from gas stations to offshore platforms, and it empowered everyone, even contractors, to speak up about safety problems. 

Human factors should be considered in the development of safe work practices. These safe work practices will normally apply to multiple locations and will normally be in written form (safety manual, safety standards, work rules, etc.). For some locations, site-specific work practices may be appropriate. The program should provide guidelines for selection and performance evaluation of contractors. API RP 76, Improving Owner and Contractor Safety Performance, may be helpful in developing guidelines for contractor selection. 

Any experienced contractor is aware of the purpose of the Occupational Safety and Health Administration (OSHA). Part of the U.S. Department of Labor, it is the goverimient agency that makes rules regarding safety in the workplace and levies stiff fines for those who abuse those rules. No contractor wants to be on the wrong side of OSHA. Failing a code enforcement inspection is bad. Failing an OSHA inspection is worse, and more expensive. 

Soon after the commencement of site work, a Safety Department was established by the Main Contractor, headed by an experienced Safety Officer with a clerical assistant, a trainee assistant, two carpenters and a signwriter, the craftsmen being employed to construct and erect fences, warning signs and so on. Sets of safety rules for various sections such as truck drivers, crane drivers and electricians were prepared and distributed to the men. 

No matter if subcontractors are working for a general or main contractor or working directly for the client, when two or more prime contractors conduct activities at the same worksite, it is prudent that a common basis for health and safety rules and controls be established. Wlien one contractor performs an intrusive activity that increases the hazard level for all workers at a worksite, that information should be communicated to other contractors to permit them to plan and control their activities accordingly. 

A copy of the general safety rules accompanied by a receipt form shall be included with the prequalification letter to a prospective contrac-tor/subcontractor. This document sets forth in broad terms the safety requirements with which a contractor/subcontractor is expected to conform while working under contract for the host organization. 

Wlien a contractor/subcontractor is hired to perform work in a potentially hazardous area on one of your facilities or that of a client, the project manager shall provide the contractor/subcontractor a copy of the contractor site safety rules checklist for completion. The form and any other rules specific to that site must be signed, dated, and returned prior to any work being performed at a particular site. An executed copy will be made a part of the project file. 

All lower tier subcontractors engaged by a contractor/subcontractor providing services to the host organization will be qualified in accordance with this procedure, the same as the contractor/subcontractor, with particular emphasis on the prequalification form, insurance requirements, and safety rules. A qualified contractor/subcontractor file shall be maintained by purchasing for each lower tier subcontractor employed by a contractor/subcontractor. 

The receipt for company general safety rules signed by the contractor/subcontractor and any lower tier subcontractors... 

An obvious solution would be to undervalue the work done, in order to avoid a claim from the client. The case of Lubenham Fidelities and Investment Co v. South Pembrokeshire District Council (1986) took care of any tendency to undervalue. In that case, the Court of Appeal ruled that the contractor might sue the architect in tort for any damages suffered by him because of the negligent valuation. 

DOE contractors must retain PrHAs and updates for each process covered by the PSM Rule, along with documented resolutions of recommendations, for the life of the process. 

A computer system is composed of software and hardware, equipment, a processor, and a user, and it is used to execute a specific procedure. Regardless of whether the computer system is developed in-house or by a contractor or purchased off the shelf, establishing documented end-user requirements is extremely important for computer systems validation. Without first establishing end-user needs and intended use, it is virtually impossible to confirm that the system can consistently meet them. Once established, it should obtain evidence that the computer system implements those needs correctly and that they are traceable to system design requirements and specifications. It is important that the end-user requirements specifications take into account predicate rules [12]. 

Business Associate Contract. When a covered entity uses a contractor or other non workforce member to perform business associate services or activities, the Rule requires that the covered entity include certain protections for the information in a business associate agreement (in certain circumstances governmental entities may use alternative means to achieve the same protections). In the business associate contract, a covered entity must impose specified written safeguards on the individually identifiable health information used or disclosed by its business associates. Moreover, a covered entity may not contractually authorize its business associate to make any use or disclosure of protected health information that would violate the Rule [DHHS, 2003b],... 

Four appendixes are included. Appendix A contains standard materials selection used by many refiners and contractors in petroleum processing equipment. Appendix B contains a rules of thumb overview of refinery materials of construction. Appendix C contains background information on hydrogen diffusion through vessel walls, and Appendix D contains a standard specification for steel line pipe. 

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