Page 2 of 29
HSE Requirements for US Subcontractors Rev. 10, 17Mar2014
Attachment A
Health, Safety, and Environment Requirements
For US Subcontractors
Revision 10
March 2014
Health, Safety, and Environment Requirements
For US Subcontractors
Table of Contents
1.0 Subcontractor Health, Safety and Environment Requirements 3
2.0 Definitions 3
3.0 Written HSE Program 3
4.0 Critical Risk Management (HSEP 11.11) 5
5.0 Basic HSE requirements 11
6.0 Pre-task Planning and Observation Procedures 14
7.0 HSE Training/Communication Requirements 15
8.0 Certification, Inspections, and Regulatory Agency Permits 15
9.0 HSE Surveys 15
10.0 Accident/Incident Investigation 15
11.0 Drugs, Alcohol, and Contraband 16
12.0 Personal Conduct 17
13.0 Medical And Exposure Monitoring 17
14.0 Imminent Danger Situations 17
15.0 HSE Adherence Policy 17
16.0 Exhibits 18
Exhibit 1 — Subcontractor HSE Data Form 19
Exhibit 2— Weekly Subcontractor HSE Statistics Report 23
Exhibit 3 — Notice of HSE Non-Compliance 24
Exhibit 4 — Warning Letter for HSE Non-Compliance 25
Exhibit 5 — Written Notice of Temporary Job Suspension 26
Exhibit 6 — Safe Plan of Action 27
Exhibit 7 — Safety Observation Report 27
Exhibit 8 — Injured Employee’s Statement 27
Exhibit 9 -- Witness Statement ………………………………………………………………………………...27
Exhibit 10 — First Aid Register 27
Exhibit 11 — Hazard Assessment Safety Action Plan (HASAP) 27
Exhibit 12 – Critical Risk Awareness Tools 27
Exhibit 13 -- Life Saving Rules
1.0 Subcontractor Health, Safety and Environment Requirements
It is the policy of Jacobs, hereafter referred to as “Contractor”, to select, contract with, and oversee Subcontractors with the same priority and emphasis on Health, Safety and Environment (HSE) protection as we practice for our own employees. It is a contractual requirement that Subcontractors comply with all applicable contractor, client, State, and Federal health, safety, and environmental regulations. The subcontractor is responsible for reviewing the Contractor safety program to gap differences, develop a mitigation plan and raise potential issues with implementation prior to starting work.
This Attachment specifies Contractor’s HSE requirements that may exceed OSHA standards or the Subcontractors’ normal HSE procedures. Subcontractors are responsible for reviewing and implementing the HSE requirements set forth in this Attachment, the Project Hazard Assessment and Safety Action Plan (HASAP) also known as the Project Safety Execution Plan (SEP), Jacobs Field Safety Handbook, and Jacobs Health Safety and Environmental Procedures (HSEPs). Subcontractors are also responsible for ensuring that their lower tier subcontractors review and implement these HSE requirements.
Each Subcontractor shall appoint an on-site HSE representative, who will attend regular Contractor HSE meetings and will support implementation of the rules listed below, as well as other HSE rules determined, by the Contractor, to be necessary for the safe execution of the project. Subcontractors employing 35 or more workers, including their lower tier subcontract employees, must provide a full-time site HSE professional. Additional site HSE personnel are required for each additional 50 workers thereafter, including their lower tier subcontract employees. Subcontractor shall also provide HSE Administrative support personnel as necessary to implement their HSE program. Contractor shall determine appropriate qualifications for Subcontractor HSE personnel, based on project demands and reserve the right to interview candidates.
Subcontractors unable to meet the minimum safety requirements may submit a written safety enhancement program designed to improve Health and Safety performance. If approved by Contractor, the safety enhancement plan will become part of the Contractor’s job specific HSE plan.
2.0 Definitions
Accident/Incident / An unplanned, undesirable event that disrupts work activity.Contractor / Jacobs or the Jacobs operating group or subsidiary company named in this contract in which these Subcontractor HSE requirements are incorporated.
HSE Professional / This is a generic term that may be used to include a worker with a minimum of 3-5 years’ experience whose full-time job is the execution of HSE related tasks, e.g., Manager of HSE, HSE Supervisor, Safety Supervisor, etc.
Safe Plan of Action (SPA) / Pre Task Risk Assessment / A task-specific planning document used to identify steps to execute the task, the hazards associated with each step and the mitigation measures to eliminate or minimize the hazard. Also referred to as a Job Safety Analysis (JSA) in some locations.
Subcontractor / The party, including “subconsultants”, defined in the subcontract with Contractor for which these subcontractor Health, Safety, and Environmental Requirements are incorporated. Subcontractor Health, Safety, and Environmental Requirements shall extend to and govern Subcontractor’s subcontractors, vendors, employees, and others under its direction or control.
Site/Project Management / The highest-ranking Contractor representative whose regular work location/office is at the project site.
Safety Observation Report (SOR) / The SOR is a proactive process designed to identify and document HSE-related acts and conditions in the work environment.
Task Safety Awareness (TSA) / A review of the SPA among the crew and supervisor to discuss and resolve any HSE issues before work is continued, when there has been a break in the work schedule, change in work conditions, change in crew, etc.
Work / The total of the Subcontractor’s responsibilities as set forth in the Subcontract Documents.
3.0 written HSE program
A minimum of 10 days before mobilizing to the project, the Subcontractor and its lower-tier subcontractors shall forward to the Contractor Site/Project Management a copy of their company’s HSE Program.
· Elements should include but not limited to:
o Safety procedures
o Personnel training certificates/records
o Construction permits
o Crane certifications and operator qualification
o Case management
o Emergency preparedness, planning and response plan
o Risk and Control measures
· Subcontractor shall furnish to the Contactor the names and qualifications of the Competent Persons and Qualified Persons, who may be required for their scope of work by the contractor’s safety procedures and by Federal, State, or local regulations. Examples include Competent Persons and/or Qualified Persons for steel erection, excavation, scaffold erection, confined space entry, crane and rigging operations, annual crane inspections, fall protection, including horizontal lifeline systems, etc.
· Subcontractors must submit the information required by Exhibit 1, Subcontractor HSE Data Form, before award of subcontract, unless specifically exempted from this provision by the Contractor.
· Subcontractors will conduct weekly HSE meetings, and signed copies of the meeting attendance and content reports shall be made available to the Contractor upon request.
3.1. Hazardous Waste Operations
· A project-specific HSE Plan or, in the case of hazardous waste operations, a Health and Safety Plan (HSP), must be generated by each Subcontractor mobilizing on the project. This plan must include a project-specific Emergency Response Action Plan in accordance with Contractor, Client, State, and Federal requirements.
· If the project is regulated as a hazardous waste or emergency response operation, as defined in 29CFR 1926.65 or 29CFR 1910.120, then the Subcontractor has the choice of adopting the site Health and Safety Plan (HSP) or developing a similar plan that is, at a minimum, equally protective and compliant. Subcontractor site personnel shall read and acknowledge by signature that they will comply with the applicable HSP.
4.0 Critical Risk Management (HSEP 11.11)
Ensure minimum requirements for planning, implementing, monitoring and assessing Critical Risk Activities are followed and integrated into work execution and support existing contractor, client, state, and Federal regulatory requirements. Critical Risk Activities are identified below, with support information found in the Critical Risk Awareness Tools Exhibit 12 and Life Saving Rules poster found in Exhibit 13. The Critical Risk Awareness tools focus attention on those risks that have potential to result in serious injury or death.
The following Universal Requirements must always be considered:
· Work must not be conducted without a pre-job risk assessment and safety discussion, appropriate to the level of risk.
· All personnel must be trained and competent for the work that they are assigned.
· Personal Protective Equipment (PPE) must be worn in accordance with the requirements identified by the risk assessment and work procedures.
· Suitable emergency response plans must be in place before work commences.
· If anyone has any questions or concerns about performing the work in a safe manner they should stop work and raise those concerns immediately.
4.1. Work at Elevation (HSEP 13.8)
Work at elevation 6 feet or higher above the ground or working surface must not proceed unless properly managed so as to eliminate or mitigate the risk of falling, or dropped objects. In addition, floor and roof openings must be properly managed to eliminate the risk of people falling through them.
· Subcontractor shall comply with the Contractor’s 100% Fall Protection Policy. This policy states “anytime employees are exposed to an unprotected elevation of six feet or more, fall arrest or restraint shall be used.” Working as stated above means while traveling, stationary, or at any time exposed to a fall from a surface not protected by approved handrails, guardrails or some other approved fall elimination device. This distance is measured from the walking working surface supporting the employee to the next lower surface onto which the employee may fall.
In general industry settings, such as in completed buildings and in operating facilities, work near unprotected floors, platforms or leading edges four feet or more above the adjacent floor or ground requires fall arrest or restraint.
· All work that requires personnel to work in a fall arrest situation requires a risk assessment which shall include a rescue plan.
· The Subcontractor shall ensure that when providing personal fall arrest equipment that it has sufficient inertia reels, inertia blocks, shock absorbers and adjustable lanyards. Six foot fixed lanyards should be the last option when providing lanyards.
· All horizontal life lines shall be inspected by designated competent person prior to use.
· Jacobs prohibits the use of positioning devices as the sole means of fall protection when working above six feet. Positioning device means a body belt or body harness system rigged to allow a worker to be supported on an elevated vertical surface, such as a wall, and work with both hands free.
· The use of “passive” systems, such as safety nets, monitoring systems, or controlled access zones, as the sole means of fall protection when working above six feet, is prohibited. Jacobs prohibits the use of safety nets as an independent means of fall protection.
· Whenever tools are used at elevation and there is a potential hazard of falling objects, the tool shall be tethered to prevent the fall.
· Workers in mechanical lifts, including scissor lifts, boom trucks, suspended or supported personnel baskets, articulating lifts, and other similar devices must use fall arrest/restraint equipment at all times with lanyards/attachment devices as short as possible to minimize the hazard of being thrown out of the basket. Personal fall arrest systems, when stopping a fall, shall be rigged such that an employee can neither free fall more than 6 feet nor contact any lower level/equipment/material. Exiting and accessing an elevated platform is permissible only when it is determined to be the safest means of access to an elevated work area. This determination must be documented and have prior approval by the Site Manager or the Site HSE Manager. Handrails on lifts may only be used for fall arrest anchor points if approved by a Qualified Person and manufacturer. Such devices shall not be used as elevators to transport workers to different work locations.
· All portable ladders must be clearly marked with the ladder owner’s name and inspected by a competent person at least quarterly. Ladders will be held at the base until secured at the top.
· The safest means of worker access for overhead work (e.g., rolling scaffolds, mechanical lifts, platform ladders, etc.) shall be considered as primary alternatives to the use of portable ladders. If ladders are used, then the top of all straight and extension ladders shall be tied to a substantial anchor point before use; a second worker must hold the ladder until the tie-off is secure. And, if a worker’s feet are on or above the fifth rung of a stepladder, the top of the ladder must be tied to a substantial anchor or a second worker must hold the ladder throughout the task.
· When ascending or descending a portable ladder, three-point contact is considered acceptable fall protection for fall exposures of less than 20 feet. When potential fall exposure exceeds 20 feet, personnel on ladders must be protected with a personal fall arrest system.
· All scaffolding must be inspected and tagged by a Competent Person prior to initial use, before each work shift, and after any event that could affect its structural integrity. Suspended scaffolds must receive documented daily pre-use inspections. Untagged scaffolds must not be used.
· All scaffold platforms shall have self-closing swing gates for access unless it is not feasible. Contractor approval required and mitigation plan in place.
· Scaffolds and floor openings: Fall protection shall be installed as soon as the opening is created. Where a scaffold platform or floor is incomplete leaving a floor opening, there shall be a cover secured over the hole capable of supporting twice the weight of employees and clearly marked with “hole” or “cover”. During activities when the hole must be uncovered a guardrail must be installed around the hole or utilize personal fall arrest equipment must be used at all times by all workers on the platform. If the fall hazard inside the guardrail is within six feet of the scaffold access point, personnel shall be protected while transitioning from the scaffold ladder to an approved anchorage point at the platform level.
· Whenever the scaffold is used as an anchorage point for fall arrest, the scaffold manufacturer’s tie-off procedures for erection, dismantling, and use shall be followed.
· Decking sections used for pour-in-place concrete floor construction shall be laid tightly and immediately secured upon placement to prevent accidental movement. During initial placement, decking sections shall be placed in such a manner to ensure full support by structural members and each piece shall be individually secured. Pre-installation or shake-out of multiple sections of decking using temporary methods of attachment, such as tack welding, is not allowed. The use of controlled decking zones is not allowed.