Subcontractors safety

Periodically evaluating subcontractor safety performance and compliance with the PSM requirements. 

Contractor and Subcontractor Safety Programs Review and Evaluation... 

Requirements generally flow down to subcontractors for such things as insurance and compliance, but practices vary regarding flow down of safety performance selection criteria. An organization may decide to flowdown all requirements to all subcontractors, apply them only to major subcontractors over a designated dollar threshold, identify a limited set of subcontractor criteria to all subcontractors (e.g., EMR), or apply none at all. Regardless, contractor and subcontractor safety requirements, along with any applicable flow-down clauses, should be exphdtly written into the contract documents. 

Subcontractor selection and management it has to consider subcontractors safety and health performance during the selection process and management. 

A toller may need to use resources outside their company to measure physical properties, conduct safety or other testing, engineer changes to piping or other facilities and equipment. This need frequently occurs for products in the initial development or commercialization stage. The toller should maintain confidentiality agreements with their suppliers and subcontractors commensurate with the proprietary nature of their client companies processes. Provision to allow disclosure of information to third parties should be addressed in the contract between the toller and the client. It may be structured so that the client must approve the toller s release of information to third parties. 

The assessor should look for objective evidence that subcontractors are made aware of and comply with the tollers safety standards and procedures. 

Contractors and subcontractors are typically required by contract to be responsible for their own workers and should provide a level of oversight to meet all specifications. The primary contractor who is responsible for the worksite typically establishes the minimum requirements, controls access to the worksite, and verifies that subcontractors fulfill their health and safety duties and responsibilities. Wlien these specifications are defined, all contractors and subcontractors should meet or exceed these requirements, as appropriate. This could be based on the nature of the assigned tasks and associated hazards [2]. 

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. 

To make sure that all contractors and subcontractors maintain a minimum level of safety performance, the client, or general or main contractor, should establish standards for compliance. During the project planning stage, affected prime contractors should have an opportunity to provide input and resolve differences. Cross-cut committees are encouraged to allow prime contractors to standardize or normalize such essential elements as procedures, permit systems, and training. 

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. 

The next step is to talk to individual task managers or others who can expect to perform the work. This may include subcontractors or other personnel who will perform work on the site. If contractors are involved, a decision should be made as to the relationship and responsibility for overall safety responsibility. If the HASP is likely to be adopted by others, this should be kept in mind during development. 

JHAs of individual work operations or tasks and their associated hazards should be included in the plan to help develop effective controls. Many times subcontractor activities are added to the safety plan after its original publication. Typically, subcontractor activity is specialized and short lived. It would be advantageous to have all JHAs completed and included as part of the work before the work begins. 

The bench where decontamination took place was only a few feet from the thermal unit and was not isolated from exclusion zone activities employees moved freely between their work stations in the exclusion zone and the decontamination bench. In addition, the subcontractor did not conduct monitoring activities to support work zone designations. Neither Site K contractor used warning signs to delineate exclusion zones, as required by their respective health and safety plans. 

The contractors SSAHPs at Sites I and K required that safety and health program inspections be conducted however, these requirements were not effectively implemented at either of these sites. Both Site K contractors required the HSO to conduct daily inspections, and both stated in their written plans that hazards would be immediately corrected. Neither contractor, however, had established hazard abatement procedures to ensure the prompt correction of hazards, and site records for both contractors indicated that hazard abatement activities were either not documented or not completed. For example, the subcontractor s daily safety log contained several notations of safety hazards, including an unstable concrete well and storage of diesel cans near the propane tank however, later log entries and site records did not track the abatement of these hazards. 

At Site I, the prime contractor s SSAHP required daily site inspections, the documentation of safety and health deficiencies, and the abatement of deficiencies. Records of site deficiencies, however, were kept intermittently, and hazard abatement was not documented. The subcontractor s SSAHP did not address site inspections and hazard abatement, but its TSCA permit application included requirements for site inspections. Inspection documentation, however, was not available on site, and the site manager was unaware of these written requirements. The site manager did, however, indicate that he conducted site inspections using a mental checklist and that he conducted inspections of remediation equipment before each use. 

Send completed contractor/subcontractor prequalification forms for approval to designated location health and safety professional and QA/QC officers... 

Establish the criteria for training the contractor/subcontractor. Review the completed contractor/subcontractor prequalification forms and provide an evaluation of the contractor/subcontractor s ability to meet the host organization s health and safety policies and procedures. Contractors/subcontractors must demonstrate their ability to meet established criteria, to the satisfaction of the health and safety professional, in order to be considered for prequalification. 

Ensure that the contractor/subcontractor can implement a comprehensive health and safety program in compliance with applicable regulations, including accident prevention programs, medical surveillance, training, work practice controls, use of personal protective equipment, and so on. 

Project managers or health and safety staff are responsible for obtaining and verifying training and medical certifications for individual subcontractors employees assigned to a project. 

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... 

Subcontractor may be used in support zone or nonhazardous site activities. Eor limited activities at a hazardous waste site, the scope of work must be reviewed with the health and safety professional before work is started (examples landscape service, electricians, software development, training, etc.). The subcontractor must meet the following minimum requirements ... 

Design analysis procedures (reliability, safety, maintainability, etc.) Supplier/subcontractor performance review procedure Management review procedure Continuous improvement procedure... 

This accident has also been discussed in terms of a comparison between developed countries and developing ones. The developing countries are considered likely to fall prey to major accidents because of technological imbalances within them and because of less interest in safety. There is some truth in these statements.Even in Japan, many accidents have involved subcontractors. Hazardous goods need to be handled only in places where their dangerous properties are well understood and appropriate safety measures can be taken. 

Process Safety Incident Severity Rate (Total severity score for all PS incidents x 200,000/total employee, contractor subcontractor work hours) X ... 

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