02_GS_1000_02
USGC Gulfstream Program October 2013
The Dow Chemical Company Page 1 of 24
Gulfstream Construction Safety Management Instructions to EPC / Contractor Companies
These Gulfstream Safety Management Instructions to EPC / Contractor Companies is specially developed and will be implemented for the use on the Gulfstream Projects. Corresponding sections in the Construction, Constructability and Security Management Plans should refer to this document to eliminate unnecessary duplication. This document incorporates input from the Dow Chemical Company, Standard GPM documents and standard contract bid documents. At all times, US labor law must be followed.
It will:
ü Define roles, responsibilities and minimum EH&S requirements for the Gulfstream Project teams, the Project Safety organization and most specifically the contractors and subcontractors who will be working on this project.
ü Establish clear expectations for safety performance with all who will work in the field on this Gulfstream Project.
ü Define the requirements for contractor safety including safety training, requirements for use of safety equipment, and the maintenance of records and submission of reports.
The follow sections make up this document:
General 5
Project Safety Vision 5
Owners & EPC / Contractor Company Responsibilities 6
Construction Contractor Site Conditions and Requirements 6
Qualified and At-Risk Labor Contractor Personnel 11
Minimum Safety Equipment Required 12
Personal Protective Equipment 12
Minimum Initial Safety Training Requirements 14
Emergency Response Procedure 18
Job Execution Plan (JEP) 18
Pre-Task Analysis (PTA) 18
Heat & Health Stress 18
Project Site Safety Leadership Team (SSLT) and Construction Leadership Team (CLT) 19
SSLT Members: Normal Duties/Responsibilities 19
CLT Members: Normal Duties/Responsibilities 19
CSLT Members: Normal Duties/Responsibilities 19
Project Safety Contacts Team 20
Meeting Structure 20
EPC / Contractor Company Kick-Off Meeting/ Pre Job Safety Meeting 20
Weekly Site Safety Meetings and Audits 20
Visibility 22
Special Considerations 22
Housekeeping 22
Daily Site Safety Observations 23
Barricades 23
Life Critical Standards (LCS) 23
Safe Working Conditions 24
Crane Work 25
Return to Operations (RTO) 25
Substance abuse policy 25
Zero Tolerance Policy 26
Balance of Consequences (BOC) 26
Tobacco Products Policy 27
Record Keeping and Safety Objectives 27
Safe Working Conditions 28
Additional Information & EPC / Contractor Company Submissions with Bid Proposal 28
Supporting Documents:
· Gulfstream Safety Administration Manual
· Gulfstream Safety and Health Handbook
· Dow Life Critical Standards
· Site Specific Safety Standards and Rules
CHANGE LOG
Date / Revision / DescriptionFebruary 2013 / 1 / Updated format
May 2013 / 2 / Revised to address Plaquemine projects
October 2013 / 3 / Formatting updated. Content did not change
General
This document is designed to define the minimum requirements for all of the construction activities for the Gulfstream Project teams, the Project Safety Organization and most specifically the EPC / Contractor Company and their Subcontractors who will be executing the work on the Gulfstream project.
The Program Construction Manager together with the Program EH&S Manager will establish three (3) Safety Management Teams that will establish and agree on this frame work to support and set safety guidelines for the Gulfstream project.
Gulfstream Project teams
· Project’s Safety Leadership Team (PSLT)
· Construction Leadership Team (CLT)
· Contractor Safety Leader’s Team (CSLT)
The EPC / Contractor Company shall submit their Safety plans with their bids.
Three months before mobilizing to site the EPC / Contractor Company shall have an approved Construction Site Safety Manual (CSSM) specific to their works. The CSSM shall as a minimum capture Owners Safety Standards and Requirements specified in this Section and shall meet the local governmental requirements.
All EPC / Contractor Company’s Sub Contractors shall follow all agreed to plans between Owner and the EPC / Contractor Company.
Each Sub contract or contractor that falls under the EPC / Contractor Company responsibility shall follow the agreed to plans between the Owner and the EPC / Contractor Company.
Construction area:
These plans will all be ruling for a defined construction area i.e. fenced off with a physical fence or on a drawing agreed with the Owner. Safe work permits can be signed off by the agreed person in the project. These permit plans are part of the EPC / Contractor Company safety manual.
In plant or OSBL works:
All works that fall in areas where existing production plants are operating, the Owner requires all works and workers to follow the Site or Plant safety requirements. Any deviation must be agreed between the Owner EH&S leader from the Project and the Plant Owners.
Project Safety Vision
The Gulfstream Project is obligated to provide all Owner, Contractor or Sub contractor employees workplaces which are in compliance with EH&S procedures and standards and applicable government regulations
The objective of the application of our DRIVE TO ZERO program is to prevent incidents and accidents by minimizing any potential dangerous situations.
The identification and investigation of unsafe actions and conditions are critical to avoid the next incident. Each incident or accident as well as near miss shall therefore be investigated, and the outcome shall be shared across the Gulfstream program via the project teams.
DRIVE to ZERO objectives:
· Zero (0) Injuries to all who work on this Project
· Zero (0) environmental injuries or Loss of Primary Containment (LOPC)
· Zero (0) Motor Vehicle Accident (M.V.A)
Owners & EPC / Contractor Company Responsibilities
The Gulfstream Project has established clear expectations for who will work in the field on this Project. Before a labor contractor starts any work, the EPC / Contractor Company shall hold a Kick off Meeting i.e. Pre-job Safety Meetings for “all” labor contractor leaders and their respective Subcontractor leadership. This meeting is designed to provide the clearest possible understanding of Owner’s expectations as defined in the Zero Incident Principles.
The Gulfstream Administration Manual details all the requirements for contractors.
Weekly Safety & Coordination meeting:
Each Project shall have a weekly integrated Owner / EPC / Contractor Company Construction Management team safety and coordination meeting where the teams make time for about one hour to look at the previous weekly activities, as well a look ahead for the coming week activities and possible coordination/safety implications. This meeting shall start with a safety moment of an educational/cultural level or a happening that happened that week rotating per week over the contractors.
It’s mandatory for this weekly safety/coordination meeting that all Contractors and Subcontractor Construction Leaders/Safety Leaders participate.
Construction Contractor Site Conditions and Requirements
Construction Sub-Contractor Qualifications:
For Gulfstream, no Construction Labor Contractor including Construction Labor Sub-Contractors will be engaged on the Site unless their safety performance history for the last three (3) years meets or exceeds performance expectations. Requirements can be found in the Gulfstream Admin Manual.
A thorough procedure and selection process shall be applied for all contractors to work on our sites.
Life threatening situations
In the event of life threatening situations, everyone has the right to stop the work, inform the responsible Construction Manager, stay with the event, involve the people in that event and discuss the situation with the Owner / EPC / Contractor Company responsible people and find a solution for a safer work execution. In all other events that might be unsafe in people’s observations, work shall not be stopped but same procedure shall be followed to make sure the works will be executed safely.
Construction Site Safety Plan
The Construction Site Safety Plan shall be supportive of the Owner’s safety requirements as defined in the Gulfstream Administration Manual. The Gulfstream Administration Manual will be updated as new and improved safety measures are developed and will be an evergreen document.
It will be the contractor’s responsibility to stay current with the latest revisions and to inform their workforce of any changes to the Gulfstream Administration Manual.
The Owner Safety Management teams shall have the right without effect on the contract prices of the project schedule to prohibit the commencement of the work or to stop any part of the work in progress, when the construction equipment, personnel or work conditions are considered at the Owner’s discretion to be life threatening unsafe or not in compliance with applicable laws, rules, or Owner defined requirements.
Integrated team’s safety approach:
The Owners Construction Safety Leader and Contractor EH&S leader/safety teams shall work as an integrated team and work closely with the Superintendent/Supervisors to make them aware when construction equipment, personnel or work conditions are considered unsafe or not in compliance with the CSSM (Construction Site Safety Manual) and / or the site specific safety requirements.
Tool and Equipment inspections:
Part of the EPC / Contractor Company’s Construction Site Safety Manual shall have a defined process for the inspection and acceptance of all tools and equipment used on the project. Should defective tools and equipment be found, they shall be removed and replaced prior to further use by the workers. The goal of the tool & equipment inspections plans shall be to have proper tools and equipment on the jobsite at all times.
ES&S:
All Contractor and Subcontractor personnel shall comply with the Owner’s access requirements for this Project. A separate site access plan will be provided to the contractors before working on the Gulfstream project.
First Aid and Medical services:
The EPC / Contractor Company is allowed to provide first aid services to the workers that fall under their responsibilities. Weekly reports of medical treatment will be shared with the Gulfstream EH&S Leader. Medical services external to the construction site for providing medical treatment, drug testing, etc. shall be provided by EPC / Contractor Company. The EPC / Contractor Company will identify an independent Medical Review Officer to review the results of drug tests.
Case Management procedure:
The EPC / Contractor Company is responsible to implement case management in order to provide assistance to employees in returning to work and reduce the severity of injuries.
EPC / Contractor Company EH&S Manager:
The EPC / Contractor Company shall have a Qualified EH&S (Environmental, Health and Safety) Manager. The EPC / Contractor Company EH&S Manager shall lead the overall compliance with the agreed to Project’s Construction Safety Manual in the field.
The EPC / Contractor Company shall provide an EH&S organization that will ensure all agreed Owner and EPC / Contractor Company EH&S requirements are being met or exceeded.
Safety Staffing:
Each EPC / Contractor Company and Sub contractor shall provide a minimum number of Safety Persons per workers for the project.
The following formula will be utilized on the Gulfstream Project as a minimum.
The Owner / EPC / Contractor Company has the right to add more safety persons if the EH&S performance is below set requirements without extra costs.
1 (Part-Time) / 1 – 24
1 (Full Time) / 25 – 50
2 (Full Time) / 51 – 75
3 (Full Time) / 76 – 150 (May be a HSE Professional)
One (1) additional for every 50 people above 150
Restrooms and Lunch facilities:
The EPC / Contractor Company shall have a program in place which covers restroom and lunch facilities and is responsible to keep them clean and maintained.
The EPC / Contractor Company shall have a procedure to address minimum requirements for welfare facilities for the field workers including climate controlled lunch facility, restroom and places for the workers to wash before eating, etc.
PPE provision:
The EPC / Contractor Company shall provide minimum PPE for all their Supervision, craft people, and EPC / Contractor Company visitors to the construction site. The Sub contractors shall provide minimum PPE to their people working on this site as well as sub contractor visitors.
Site Material Management plan:
“Just in time” delivery shall be part of the Material Management Plan. No more materials than for two (2) working days of materials may be located in the direct construction areas at any time. This to avoid congestion and the chance for tripping hazards/coordination issues with other parties on the jobsite.
Waste Management:
The EPC / Contractor Company shall follow the waste management procedures specific for each job site.
The EPC / Contractor Company shall have a housekeeping program in place, which shall specify who will be responsible for the daily housekeeping, sweep team compilation, trash pickup program, etc.
Vendor /Supplier Rep’s:
Vendors or Supplier manufacturer representatives ordered by EPC / Contractor Company’s to work on site shall follow the agreed Owner / EPC / Contractor Company EH&S manual and fall under the EPC / Contractor Company care custody.
Owner vendor/supplier reps:
The vendor supplier or manufacturer representatives ordered by Owner Team or Owner Commissioning and Start-Up Team will be under their care custody.
High risks jobs:
The EPC / Contractor Company shall develop and maintain a list of high risk jobs which will be agreed with the Owner’s Construction Manager where as a minimum additional risk mitigation reviews need to be done prior to execution of the work i.e. but not limited to piling works, civil works, steel erection works, equipment works, piping erection works, scaffolding works, E/I works, insulation works, refractory works, tower internal works, heavy lifts, pre dress works etc.
Qualified and At-Risk Labor Contractor Personnel
It’s the responsibility of the EPC / Contractor Company to demonstrate that sub contractors are adequately qualified to perform the work.
At Risk Personnel
At-Risk Personnel is defined as:
1. “At risk, language”: People who do not speak the agreed project language which is English or Spanish.
2. ”At risk, work experience”. People without recent experience on a Dow site.
3. “At risk people” are to be recognized through indication on their hardhat which they receive during the introduction training. The “at risk” program must be a minimum of 60 days duration, after which the indicator must be removed from the hard hat.
Language At-Risk Personnel
§ Must follow the Gulfstream English Comprehension Policy.
§ Two members of each work group / unit must be fluent in the local language.
§ These people will receive indoctrination training in the English language.