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42: Subcontractor Construction Safety
Overview Requirements Standards Definitions    


Chapter 42 Table of Contents. View the entire chapter in a PDF format. Please use the pdf for printing.

Requirements:
General (5.1)

Managing (5.1.1)

The management of subcontracted construction work is a specialized discipline. Detailed guidance for managing this work can be found in the SLAC University Technical Representative Requirements and Procedures for Construction [pdf]. All contracted construction work performed at SLAC will be managed following this document.

SLAC Support Organizations (5.1.1.1)

There are four SLAC organizations responsible for managing construction subcontractors. These four organizations are

  1. Facilities Department
  2. Experimental Systems and Research Department (ESRD)
  3. Linac Coherent Light Source (LCLS) Construction Directorate
  4. Environment, Safety, and Health (ES&H) Division

These four organizations assign project managers to the various construction projects sponsored by their respective organizations. In turn, the project managers draw on the UTR pools from within their own organizations and also have the ability to use UTRs from other organizations, as the specific technical nature of the work and resource availability dictate. The Facilities Department and the ES&H Division, in particular the Chemical and General Safety (CGS) Department, have additional responsibilities related to construction subcontracts, as noted in Section 5.1.9, “Roles and Responsibilities”.

Planning (5.1.2)

Safety requirements are part of the project planning process almost from inception. How the subcontractor is to meet these requirements is documented through a hierarchy of plans required by SLAC, described below (listed from general to specific).

If it does not have reviewed copies on file in SLAC Purchasing not more than 12 months old, the subcontractor is required to submit its company illness and injury prevention plan, company code of safe work practices, and employee training documentation, directly related to the scope of work to be performed at SLAC, at least 10 days before mobilization on SLAC property, along with the project-specific site-specific safety plan.

Injury and Illness Prevention Plan (5.1.2.1)

The subcontractor illness and injury prevention plan (IIPP) is a general safety document, required by Cal/OSHA, governing the subcontractor's approach to safety and work practices for the trades the subcontractor employees will be using. Subcontractors are required to submit a current IIPP.

Note: A model IIPP is available on the Cal/OSHA web site. The long list of training and inspection topics at the end need not be included in your IIPP, only the items that pertain to your company scope of work.

Review and Approval

IIPPs must be reviewed and approved by the construction safety program manager.

Code(s) of Safe Work Practices (5.1.2.2)

Subcontractors are required to submit a code of safe work practice for each type of work they do. The code must be specifically applicable to the type of work the subcontractor will be performing at SLAC.

Review and Approval

Code(s) of safe work practice must be reviewed and approved by the construction safety program manager.

Safety Qualification Criteria Form  (5.1.2.3)

Subcontractors are required to submit a completed safety qualification criteria form.

Review and Approval

Subcontractor safety qualifications are reviewed by Purchasing, the PM, and the construction safety program manager as part of pre-bid evaluations.

Site-specific Safety Plan (5.1.2.4)

Subcontractors are required to submit a site-specific safety plan (SSSP). The SSSP is intended to provide specific information on the hazards, contact people, and emergency response for a particular project.

The SSSP must

  • Identify persons with authority and responsibility for implementing the safety program and appropriate subcontractor contacts (superintendent, PM, safety officer, and competent persons)
  • Include an acknowledgment of the requirements of 10 CFR 851
  • Describe the work to be performed, outline the hazards anticipated to be encountered with each task, and the specific mitigation
  • Describe the system used to ensure personnel will comply with safe and healthy work practices, including
    • Safety indoctrination and safety meetings
    • Worker training in hazard recognition
    • Disciplinary policy
    • Means of communicating with personnel, including notification of hazards

Additional specific requirements must be included for projects that include SLAC-required permits, such as excavations. Subcontractor employees must be trained in the contents of the SSSP and the training documented.

Review and Approval

SSSPs are approved jointly by the PM, UTR, and the line management safety coordinator, departmental safety coordinator, or a CGS staff member.

Any changes to the SSSP must be approved by the subcontractor competent person and SLAC as above and all employees must be trained on those changes.

Job Safety Analysis (5.1.2.5)

Job safety analysis (JSA) is critical at the start and throughout a project. The process takes hazards identified already for a given project in the statement of work, contractor site visit, SSSP, and related documents and provides details of how to control them for specific tasks. The analysis and results are discussed with workers before beginning the task and documented using JSA forms.

Review and Acknowledgment

JSAs must be prepared by the subcontractor prior to the start of any on-site work, before initiating any new phase or task, and before modifying an existing phase or task resulting in a change in hazards.

The JSA must be reviewed, acknowledged, and signed by the UTR. If the hazard involved with the work is beyond the knowledge of the UTR, the UTR must consult with a subject matter expert before signing. If the subject matter expert believes the JSA is insufficient or incomplete, he or she must inform the UTR and the subcontractor so the necessary improvements can be made.

JSAs must be reviewed and discussed by subcontractor employees as part of daily briefings. Employees must sign the form, acknowledging they understand the contents.

JSAs are to be made available for reviewed to SLAC or DOE personnel whenever conducting job-site walkthroughs of work areas. The completed forms become training tools and documentation of completed hazard analyses and employee training, to be checked as part of daily inspections. The necessary ES&H permits are posted with the JSA. A copy of the approved drawings and specifications are also key documents to be kept on the job site.

Permits (5.1.2.6)

In addition to controls documented in the above plans, permits are required for activities typically recognized to have significant safety and/or environmental consequences if not executed properly. Examples of such permits include excavation permits, (SLAC and Cal/OSHA issued) confined space entry permits, hot work (welding/cutting) permits, and the notice of intent (NOI) permit required by the regional water quality control board whenever a construction site will disturb an area greater than one acre in size. Such permits will be completed and approved by the appropriate program managers, or their delegates, before start of work and will be attached to the JSA and posted conspicuously at the work site. See Chapter 2, "Work Authorization", and the respective hazard chapters of this manual.

Demolition (5.1.2.7)

Prior to permitting employees to start demolition operations, a qualified person will make a survey of the structure to determine the condition of the framing, floors, and walls, and the possibility of an unplanned collapse of any portion of the structure. Any adjacent structure where employees may be exposed will also be similarly checked. The survey will be in written form, kept on the job site, and made available to the ES&H Construction Safety or Building Inspection offices upon request. The written survey will be maintained for the duration of the demolition project.

The SSSP must ensure that demolition work plans are reviewed by the ES&H Construction Safety or Building Inspection offices or their designees prior to commencement of work.

Demolition work will at all times be under the immediate supervision of a qualified person with the authority to secure maximum safety for employees engaged in demolition work.

All demolition will comply with Cal/OSHA (8 CCR 1733-1737).

Asbestos

A demolition notice to air quality authorities is required for all demolitions, whether or not asbestos is involved. (See Air Quality: Construction Project Air Permit Requirements [pdf] and Air Quality: Asbestos Notification Procedure [pdf] for details.)

Performing (5.1.3)

Work must be performed according to

  1. Submitted and approved plans and permit conditions
  2. The requirements of this chapter and related chapters

These conditions will be implemented through the preparation of job safety analyses and daily briefings, and verified by inspections

Job Safety Analysis and Task-specific Orientation (5.1.3.1)

The job safety analyses that subcontractors are required to develop provide the basis for the UTR and subcontractor's job foremen to brief their employees daily on the work to be performed, the hazards specific to the task they are being assigned to perform, and the specific work assignments.

On completion of the daily task-specific briefing every employee engaged in the task must sign the JSA acknowledging that they understood the briefing and their assignments.

Site Access (5.1.3.2)

Access to SLAC

Subcontractor access to SLAC will follow the requirements in Section Error! Reference source not found., "Error! Reference source not found.".

Note: The Field Operations group leader of the Radiation Protection Department must be notified before subcontracted construction work begins in areas where workers may be exposed to ionizing radiation. The UTR will make this determination during the pre-bid site walkthrough. Additional access restrictions, including training and the wearing of personal dosimeters, will apply. (See ES&H Manual, Chapter 9, "Radiological Safety".)

Access to Construction Sites

Only authorized and qualified personnel are allowed in construction sites. Subcontractors are required to maintain daily lists of all personnel on site, including sub-tier personnel.

Other personnel desiring access to a construction area must do the following:

  • Except for emergencies, in the case of subcontractors' work sites, obtain approval to enter the construction premises from the subcontractor's superintendent or UTR. Visitors must be escorted by the UTR or the subcontractor's superintendent while on the job site.
  • Obey all safety regulations, wear appropriate protective equipment, and follow special instructions given by the escort
  • Not discuss contractual or technical matters with subcontractor representatives unless authorized by the UTR or project manager
  • Notify the UTR when the visit is completed

Inspections (5.1.3.3)

Throughout all phases of construction, PMs, UTRs, ES&H program managers, and/or other SLAC personnel overseeing the work being performed by construction subcontractors will monitor field activities on a regular basis to ensure that work is being conducted in a safe manner. They will assess the effectiveness of the safety measures being implemented by their subcontractors to minimize the possibility of injury to personnel, damage to property, adverse effects to the environment, and program disruptions or delays resulting from accidents, fires, or hazardous material incidents.

The frequency of work site inspections will depend on

  • The number and type of hazards involved (for example, trenching and excavating, work at elevations, confined spaces)
  • The level of risk to the workforce, property, and the environment
  • The presence of qualified safety and health personnel assigned to the work crew
  • Previous experience with the work crew (subcontractor)

Safety Oversight by the ES&H Division

Inspections by the ES&H program managers may take place at any time to ensure compliance with applicable codes, standards, and regulations. Inspection of subcontractor's construction sites must be coordinated through the PM or UTR. All inspections will be discussed with the PM/UTR promptly and results documented so that any identified hazards can be addressed.

The SLAC PM and/or UTR will formally notify the subcontractor of any deficiencies and verify that appropriate corrections are made.

Safety Oversight by the Department of Energy

The Stanford Site Office (SSO) of the United States Department of Energy (DOE) employs several ES&H professionals. Any of these individuals have both the authority and the responsibility to conduct operational awareness walkthroughs of construction projects taking place at the SLAC facility, in a manner similar to that used for issues identified during inspections performed by SLAC employees.

Safety Inspections

SLAC PMs and/or UTRs, the construction safety program manager, and subcontractors must perform daily inspections of activities and work sites relevant to the work being performed that day to ensure that the subcontractor is working within identified controls and has effectively controlled identified hazards and that subcontractor employees are wearing appropriate PPE. If immediate corrective action is not possible where uncontrolled hazards are identified, the affected workers must be notified, warning signs posted, and interim control measures established to guard against the hazards. All inspections, findings, and corrective measures must be documented and be available for review by the BIO and contract administrator. The daily inspection records must be kept at the job site along with any corrective actions taken in a binder accessible to SLAC PM/UTR.

The subcontractor's competent person will conduct regular inspections of the work place and maintain a log certifying compliance with accepted safe work conditions. For example, the "Scaffolding Entries" section on subcontractor-supplied scaffold tags should include evidence of daily inspections and/or configuration change approvals.

Stop Activity/Work (5.1.3.4)

Hazards must be abated as soon as possible after they have been identified. Imminent-hazard activities must be stopped and corrected immediately. Work posing imminent hazards must be stopped and corrected prior to resumption of the associated activity.

SLAC has granted authority to UTRs, PMs, and ES&H representatives to stop any person at a job site (whether SLAC employee, subcontractor, or other form of non-employee) from continuing an activity. This authority is an essential tool that will be used when safety, environmental, and code requirements are not being followed. UTRs, PMs, and ES&H representatives will utilize a stop activity order to accomplish this. Furthermore, if warranted by the severity or frequency of the violations, the contract administrator has the authority to shut down an entire project by issuing a stop work order.

For details on stop activity/stop work for subcontractors, see Work Authorization: Subcontractor Stop Activity/Work Requirements [pdf].

Incident Reporting (5.1.3.5)

Subcontractor construction personnel must report immediately all incidents that occur at SLAC in the course of their work to their foreman/superintendent, who will report to the PM or UTR (see Incident Investigation: Subcontractor Incident Reporting Procedure [pdf]).

Emergency Work (5.1.4)

[ to be determined ]

Recordkeeping (5.1.5)

According to Title 48, Code of Federal Regulations, "Federal Acquisition Regulations System", parts 900 through 999, safety-related documentation for construction work must be retained for a period of six years except as otherwise specified below. These documents are

  • Subcontractor site-specific safety plan and IIPP
  • Job safety analysis (JSA)
  • Accident investigations
  • Written authorization to use tools or equipment owned by the laboratory, not otherwise specified in the subcontract documents
  • SLAC-specific training
  • Subcontractor evaluation (contract administrator)
  • Safety violation notices (contract administrator)

At the completion of each subcontract these documents will be compiled and provided to the contract administrator to be archived with the contract documents. The project manager is responsible for providing this information to the contract administrator.

Equipment (5.1.6)

Subcontractors will

  • Provide the suitable equipment required for the project
  • Ensure the safety of their and their sub-tier subcontractors' equipment

Personnel (5.1.7)

Qualifications (5.1.7.1)

University Technical Representative

A UTR must be qualified. Baseline qualifications for SLAC construction UTRs include

  • Commitment to safe construction activities at SLAC
  • Successful completion of required training courses (see Section 5.3, “Training”)
  • General knowledge of commercial building, grounds, and utilities construction
  • Ability to communicate effectively with construction workers, supervisors, project managers, internal customers (for example, researchers, department heads, contract administrators), and ES&H personnel

The ideal candidate would also have at least three years of hands-on construction or construction management experience.

The lead UTR is chosen by the PM at the beginning of a project for his/her expertise in the technical, safety, and environmental aspects of the particular project. Multiple UTRs may be required for a given project with a lead UTR selected to coordinate the efforts of the others. When the UTR's experience is insufficient he/she must bring in appropriate experienced assistance such as a UTR with specialized training/experience or a subject matter expert (SME). On less complex projects, the PM can also serve as UTR.

Project Manager

Project managers (PMs) are chosen by supervisors for their project management expertise and experience for a particular project. Project managers determine and approve the technical, safety, and environmental compliance guidance required to achieve successful completion of the project.

Subcontractor

Subcontractors are responsible for ensuring that their workers are trained and qualified according to federal, state, and SLAC requirements. (See sections 5.1.3.2, “Site Access”, and 5.3, “Training”.) When contracted personnel arrive at SLAC they must

  • Be skilled in their specific trade
  • Be knowledgeable of the applicable safety requirements for that trade
  • Be equipped with the proper PPE and tools to safely perform their work
  • Be physically ready to work
  • Have completed all administrative requirements such as medical exams

For subcontracted work where Cal/OSHA requires a competent person, the subcontractor will designate such an individual in writing and be prepared to demonstrate to the SLAC PM and the ES&H construction safety program manager the basis for the individual's competency.

The following are activities that typically require a competent person:

  • Excavation
  • Scaffold erection (This must have a qualified scaffold erector to assemble, disassemble or modify any scaffolding)
  • Fall protection
  • Confined space entry
  • Respiratory protection
  • Hoisting and rigging

Badging (5.1.7.2)

UTRs will ensure that service subcontracting company employees are badged in accordance with the Site Access and Identification Badges Policy and Procedures. [pdf]

Only subcontractors with employees who have met the training requirements in Section 5.3, “Training”, are allowed to perform work on SLAC property. They will carry a current SLAC-issued badge or be escorted by an authorized SLAC-trained escort.

The subcontractor will maintain a list of badge holders. A copy of the list will be submitted to the contract administrator whenever a change is made. The subcontractor is responsible for the return of each badge/dosimeter to the guard at the Sector 30 Gate when each individual completes his or her activity under the subcontract. All badges must be returned or otherwise accounted for in writing prior to final payment.

Disciplinary Program (5.1.7.3)

The subcontractor is required to implement a disciplinary program to control poor performance, misconduct, negligence and safety violations by both its own employees and by any of its respective subcontractors. If it is determined that the subcontractor has not implemented such a program, the laboratory will enforce its own disciplinary program, found in the construction contract supplemental conditions.

Personal Protective Equipment (5.1.8)

Individuals working in areas designated as construction sites must wear personal protective equipment (PPE) appropriate for their work and job location. PPE requirements will be determined by the subcontractor, in compliance with SLAC requirements as described in hazard-specific chapters of this manual, and documented in the task-specific JSAs.

Individuals visiting construction work sites, including SLAC and/or DOE employees, must wear PPE that meet the requirements specified by the subcontractor, appropriate to the hazards likely to be encountered on the job site. The subcontractor must post these requirements.

 

 

continue to Requirements, Roles & Responsibilities (5.1.9)


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