Chapter 31
NON-CONSTRUCTION SAFETY ASSURANCE FOR SUBCONTRACTORS, VENDORS, AND GUESTS
Chapter 31
Approved by Michael Ruggieri
Revised 10/10
31.1 Policy
31.2 Scope
31.3 Applicability
31.4 Roles and Responsibilities
31.5 Definitions
31.6 Required Work Processes
Work Process A. Non-Construction Safety Assurance Process
Work Process B. Records Management
Work Process C. Flowchart for the Non-Construction Safety Assurance Process
Work Process D. Guidance for Performing Non-Construction Safety Assurance Process
Work Process E. Subcontractor Job Hazards Analysis and Work Authorization Form and Database
Work Process F. EH&S Orientation for Non-Construction Subcontractors, Vendors, and Guests
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Lawrence Berkeley National Laboratory (LBNL) is required to ensure that all subcontractors, vendors, and guests who perform work at LBNL facilities do so in a safe manner in compliance with applicable regulations. General requirements are documented in LBNL/PUB-3140, Integrated Environment, Health, and Safety Management Plan: Integrated Safety Management (ISM) System, and LBNL/PUB-3851, Worker Safety and Health Program. Each division is responsible for ensuring that its subcontractors, vendors, and guests perform work on site in compliance with LBNL Environment, Health, and Safety (EH&S) requirements. The EH&S Division helps LBNL divisions carry out their responsibilities through the Non-Construction Safety Assurance Program, whose policies, processes, and responsibilities are described in this chapter. Construction safety assurance is discussed separately in PUB-3000, Chapter 10 (Construction Safety Manual Administrative Policies), and the institutional requirement for job hazards analysis is discussed in Chapter 32 (Job Hazards Analysis).
Before hands-on work (see Definitions, Section 31.5.3) can be performed by subcontractors, vendors, or guests at LBNL facilities, the following activities must be completed:
During the conduct of the hands-on work performed by the subcontractor, vendor, or guest,
When a deviation to this policy is required, advance approval must be obtained from the Subcontractor Safety Assurance Program Manager in the EH&S Division. The process for these requirements is described in Work Process A (Non-Construction Safety Assurance Process).
This policy applies to all LBNL divisions and all hands-on work performed at LBNL facilities by non-construction subcontractors, vendors, and guests who are not under direct supervisory control of Laboratory personnel. This policy does not apply to most consultants, personal services agreements, contract labor, intrauniversity transactions, ALS users, and other university agreements. In addition, this policy does not apply to subcontractors, vendors, or guests who have completed an LBNL Job Hazards Analysis and Work Authorization per PUB-3000, Chapter 32.
This program applies to subcontractors, vendors, and guests who perform non-construction, hands-on work at facilities that are owned or leased by LBNL.
31.4 Roles and Responsibilities
31.4.2 Division Safety Coordinator
31.4.3 Subcontractor, Vendor, and Guest
31.4.4 EH&S Division Non-Construction Safety Assurance Program Manager
The following are definitions for key terms used in this chapter.
31.5.1 EH&S Orientation for Non-Construction Subcontractors, Vendors, and Guests
An LBNL-produced pamphlet (or training program) that includes important information regarding responsibilities, EH&S policies, security, parking, prohibited articles, etc.
An individual who is invited to come to an LBNL facility and does not work under a subcontract with LBNL or an LBNL subcontractor.
Includes all activities except administrative office work and other similar activities.
The following activities are examples of hands-on work:
The following activities are not defined as hands-on work, unless they also include an activity associated with hands-on work (see above):
Any activity that requires a safe work authorization (e.g., laser activity hazard document, radiological work authorization) as described in PUB-3000, Chapter 6 (Safe Work Authorizations) and 18 (LockoutTagout and Verification).
An activity that does not require a safe work authorization.
Activities that do not include any combination of engineering, procurement, erection, installation, assembly, demolition, or fabrication used to create a new facility, or to alter, add to, rehabilitate, dismantle, or remove an existing facility. Non-construction work also excludes the alteration and repair (including dredging, excavating, and painting) of buildings, structures, or other real property, as well as any construction and excavation activities conducted as part of environmental remediation efforts (see PUB-3000, Chapter 10 (Construction Safety Manual Administrative Policies).
31.5.7 Non-Construction Safety Assurance Program
An EH&S Division program that provides guidance, leadership, and direct consultative services to divisions for the implementation of the policy and requirements in this chapter.
An individual in an LBNL division who requests and oversees the conduct of subcontractor, vendor, or guest services.
An LBNL worker who is trained and authorized to use procurement software programs for initiating requisitions and purchase orders.
31.5.10 Risk-Based Graded Approach
A process to ensure that work activities are efficiently managed through systems that are adequate to and commensurate with the risk involved in the activity. Risks include potential impact to worker or public health and safety, threats to the environment, consequences of noncompliance, and cost impacts. The risk-based approach considers whether work is hands-on or not hands-on, and includes low or high hazards in order to determine if a written authorization (beyond the SJHAWA) is required and what level of oversight is necessary.
31.5.11 Subcontractor
A firm that has sole contractual responsibility for execution of defined work related to a project, and for compliance with all safety, health, and environmental codes, standards, and regulations.
31.5.12 Subcontractor Job Hazards Analysis and Work Authorization (SJHAWA)
An SJHAWA describes the work to be performed and identifies work hazards and controls and is the work authorization document for subcontractors, vendors, and guests. When required, safe work or electrical work authorizations are obtained and appended to the SJHAWA. Maximum duration of an SJHAWA is one year. Authorizations and restrictions stipulated by any required safe work or electrical work authorizations supersede those in the SJHAWA.
An entity that sells a product for which installation or warranty service may be provided.
Work Process A. Non-Construction Safety Assurance Process
Before hands-on work (see Definitions, Section 31.5.3) can be performed by subcontractors, vendors, or guests at LBNL facilities, the following activities must be completed,
During the conduct of the hands-on work performed by the subcontractor, vendor, or guest,
The following paragraphs 1 through 3 define the minimum requirements for authorizing a subcontractor, vendor, or guest to perform non-construction work at LBNL facilities. Recognizing that operational differences exist among divisions, divisions may develop methods to fulfill requirements that suit their organizations and work environments, and include these requirements in their division’s ISMS implementation plans. Guidance for performing the three required activities is provided in the attached appendices.
1. Subcontractor Job Hazards Analysis Work Authorization
To develop the SJHAWA and prepare for the pre-job meeting, the following activities must be completed:
2. Pre-Job Meeting between Requester and Subcontractor, Vendor, and Guest
To facilitate effective communication between the requester and the subcontractor, vendor, and guest, a pre-job meeting is required. At the pre-job meeting, the following activities are to be completed:
The signed documents must be scanned and uploaded to the SJHAWA database in a timely manner.
3. To confirm and document that the subcontractor, vendor, or guest is performing the work as authorized, the requester shall provide and record oversight using the online SJHAWA form and a risk-based graded approach as described below:
Work that is not performed in conformance with the SJHAWA is corrected on the spot. Significant or multiple nonconformances are entered into the LBNL Corrective Action Tracking System (CATS) or another appropriate system. In addition to the requester’s/division’s oversight, the Non-Construction Safety Assurance Program Manager will perform independent checks that will be documented and used to assess program effectiveness.
Work Process B. Records Management
Completed Subcontractor Job Hazards Analysis and Work Authorizations and related documents (i.e., safe work authorizations, evidence of training) shall be maintained in the SJHAWA database by the requester in accordance with the PUB-201, Regulations and Procedures Manual (RPM).
Work Process C. Flowchart for the Non-Construction Safety Assurance Process
Work Process D. Guidance for Performing the Non-Construction Safety Assurance Process
Work Process E. Subcontractor Job Hazards Analysis and Work Authorization Form for Non-Construction Activities Performed at LBNL Facilities
Work Process F. EH&S Orientation for Non-Construction Subcontractors, Vendors, and Guests
Related PUB-3000 Chapters
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Chapter 30 || Table of Contents || Chapter 32
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