flagflag Chapter 31
sJHA PROCESS – SUBCONTRACTOR JOB HAZARDS ANALYSIS

Contents

Approved by Bill Wells
Revised 07/12


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31.1 Policy

The Subcontractor Job Hazards Analysis Program at Berkeley Lab ensures that all nonconstruction subcontractor work is performed safely and in accordance to regulations by:

31.2 Scope

The Subcontractor Job Hazards Analysis (sJHA) program covers environmental, health and safety reviews for all nonconstruction projects at LBNL.

Each division must ensure that its subcontractors, vendors, and affiliates perform on-site work in compliance with Berkeley Lab Environment, Safety & Health (ES&H) requirements.   The SJHA process includes:

A pre-job meeting must occur between the requester and the subcontractor, vendor, or affiliate at which:

31.3 Applicability

This policy applies to:

31.4 Exceptions

This policy does not apply to:

31.5 Roles and Responsibilities

Role

Responsibility

Division Safety Coordinator

  • Provides Environment, Safety & Health (ES&H) support to his or her division as needed for implementing the safety-assurance process defined in this chapter
  • Requests support from the EHS Division Nonconstruction Safety Assurance Program Manager and EHS subject matter experts, when necessary

EHS Division Nonconstruction Safety Assurance Program Manager

  • Provides guidance, leadership, and direct consultative services to the requesting division to guide implementation of the policy and requirements
  • Monitors the Laboratory's performance of this program's policy and requirements, and enters that information into a database
  • Maintains the program

Procurement Department

  • Communicates this program's policy and requirements to subcontract bidders and awardees
  • Requests that each subcontractor and vendor who will perform hands-on work at a Berkeley Lab facility complete an sJHA and review the Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet before starting work
  • Monitors subcontractor and vendor performance, including ES&H compliance

Requestor

  • Ensures that an sJHA is prepared for the subcontractor, vendor, or affiliate who will perform hands-on work at a Berkeley Lab facility, and that a pre-job meeting is held between the requestor and the subcontractor, vendor, or affiliate before work is performed
  • Signs the sJHA and thereby authorizes the work to be performed
  • When required, obtains safe work authorizations for the scope of the work to be performed by the subcontractor, vendor, or affiliate
  • Using the risk-based graded approach described in this chapter, provides and records oversight of the subcontractors
  • Maintains completed Subcontractor Job Hazards Analysis and related documents (i.e., safe work authorizations, evidence of training) in the sJHA database in accordance with the Berkeley Lab Requirements and Policies Manual (RPM)

Subcontractor, Vendor, and Affiliate

  • Provide input on the sJHA and submit it to the requestor
  • Review the Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet
  • Attend the pre-job meeting and discuss the steps of the work scope and the associated hazards and controls
  • Sign the sJHA and any required safe work authorizations
  • Agree to work in conformance with the authorized conditions
  • Perform the scope of work as authorized

31.6 Definitions

The following are definitions for key terms used in this chapter.

Affiliates

Non-Laboratory employees engaged in on-site Laboratory activities. Affiliates are subject to training in safety and other subjects. They are also issued a Berkeley Lab identification badge. Affiliates may receive system accounts, research access to facilities, and a per diem allowance for housing and living expenses. Examples: facility users, scientific collaborators, students.

Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates

A Berkeley Lab-produced pamphlet (or training program) that includes important information regarding responsibilities, ES&H policies, security, parking, prohibited articles, etc.

Hands-on work

Includes all activities except administrative office work and other similar activities.

The following activities are examples of hands-on work:

  • Use of hand or power tools
  • Repair or service of a device, apparatus, machine, or mechanism
  • Material handling
  • Handling or disposing of a chemical; a compressed gas; or a hazardous, radioactive, or biohazardous material

The following activities are not defined as hands-on work, unless they also include an activity associated with hands-on work (see above):

  • Office and administrative duties
  • Computer programming
  • Attending or making a presentation
  • Supervision of a worker(s) who is not performing hands-on work
  • Document archiving
  • Financial auditing
  • Photography
  • Language translation

High-Level Hazard Work

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 Chapter 21 (Radiation Safety)

Low-Level Hazard Work

An activity that does not require a safe work authorization

Nonconstruction Work

Activities that do not create a new facility or alter, add to, rehabilitate, dismantle, or remove an existing facility, including any combination of engineering, procurement, erection, installation, assembly, demolition, or fabrication

Nonconstruction 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, Construction Safety Manual Administrative Policies).

Non-Construction Safety Assurance Program

An EHS Division program that provides guidance, leadership, and direct consultative services to divisions for the implementation of the policy and requirements in this chapter

Requestor/Division

An individual in a Berkeley Lab division who requests and oversees the conduct of subcontractor, vendor, or affiliate services

Requisition Preparer

A Berkeley Lab worker who is trained and authorized to use procurement software programs for initiating requisitions and purchase orders

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, and includes low or high hazards in order to determine if a written authorization (beyond the sJHA) is required and what level of oversight is necessary.

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

Subcontractor Job Hazards Analysis

  • An sJHA:
    • Describes the scope of work to be performed
    • Identifies work hazards and controls
    • Is the work authorization document for subcontractors, vendors, and affiliates
  • When required, other safe work or electrical work authorizations are obtained and appended to the sJHA. Maximum duration of an sJHA is one year.
  • Authorizations and restrictions stipulated by any required safe work or electrical work authorizations supersede those in the sJHA.

Vendor

An entity that sells a product for which installation or warranty service may be provided

31.7 Required Work Processes

Work Process A.  sJHA Process Overview

Work Process A.  sJHA Process Overview

  1. Lawrence Berkeley National Laboratory (Berkeley Lab or LBNL) must ensure that all subcontractors, vendors, and affiliates who perform work at its facilities do so safely and in compliance with applicable regulations. The Non-Construction Safety Assurance Program is designed to meet this requirement. General requirements are documented in PUB-3140 (Integrated Environment, Safety & Health Management Plan: Integrated Safety Management (ISM) System), and PUB-3851 (Worker Safety and Health Program). Each division must ensure that its subcontractors, vendors, and affiliates perform on-site work in compliance with Berkeley Lab Environment, Safety & Health (ES&H) requirements. The Environment, Health & Safety (EH&S) Division helps Berkeley Lab divisions carry out their responsibilities through the Non-Construction Safety Assurance Program and the online Subcontractor Job Hazards Analysis (sJHA), whose policies, processes, and responsibilities are described in this document. Detailed information on the use of the password-protected online sJHA Form and Database is provided in the online help associated with the database.
  2. The sJHA process is linked to the Berkeley Lab Procurement process so a decision is made as to whether on-site hands-on work will be performed by the subcontractor, vendor, or affiliate. If the decision is yes, the sJHA process is initiated. A flowchart for the Non-Construction Subcontractor Safety Process is found here.
  3. The full suite of Safe Work Authorizations also includes:
    1. Berkeley Lab worker's Job Hazards Analysis (JHA), discussed in Chapter 32 (Job Hazards Analysis)
    2. Formal Authorizations for Increased Hazards discussed in Chapter 6 (Safe Work Authorizations).

    NOTE: Construction safety assurance is discussed in Chapter 10 Construction Safety Manual Administrative Policies.

Work Process B.  Creating an sJHA

  1. Before hands-on work (see Definitions, Section 31.6) can be performed by subcontractors, vendors, or affiliates at Berkeley Lab facilities, the following activities must be completed:
    1. A Subcontractor Job Hazards Analysis (sJHA) form must be created, and the subcontractor, vendor, or affiliate must review the ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet, or equivalent (See Work Process C).
    2. A pre-job meeting must take place between the requestor and the subcontractor, vendor, or affiliate at which:
      1. The sJHA and any other required work authorizations are reviewed and signed.
      2. The ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates safety pamphlet is discussed.
  2. During the hands-on work performed by the subcontractor, vendor, or affiliate, the requestor provides oversight of the subcontractors using a risk-based graded approach.
  3. After the hands-on work is completed, the signed sJHA and any associated documents and observations are scanned and uploaded into the online sJHA database.
  4. The following paragraphs define the minimum requirements for authorizing a subcontractor, vendor, or affiliate to perform nonconstruction work at Berkeley Lab facilities. Operational differences exist among divisions, and divisions may develop methods to fulfill requirements that suit their organization and work environments, and include these requirements in their division's ISMS implementation plans.
    1. Pre-Job Planning — Creating the sJHA and Subcontractor Orientation. To develop the sJHA and prepare for the pre-job meeting, the following activities must be completed:
      1. An sJHA must be created by using the online sJHA form and database, if one does not already exist. Site-wide sJHAs have been developed for many subcontractors that frequently work at the Laboratory.
      2. The Web link for the online SJHA form must be sent to Procurement as part of the requisition process and, if appropriate, sent directly to the subcontractor, vendor, or affiliate  (e.g., for warranty work not obtained through the Procurement process).
      3. Prior to the pre-job meeting, the subcontractor, vendor, or affiliate must:
        1. Review the draft online sJHA form, enter his or her input into the draft online sJHA form
        2. Review the ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates.
    2. Pre-Job Meeting — To facilitate effective communication between the requestor and the subcontractor, vendor, and affiliate, a pre-job meeting is required. At the pre-job meeting, the following activities are to be completed:
      1. Review, discuss, and modify, as necessary, the sJHA and any required safe work authorizations.
      2. Confirm the work hazard level.
      3. Identify any additional required hazard controls.
      4. Both parties sign the sJHA and any required safe work authorizations.
      5. The completed and signed copy of the sJHA and required safe work authorizations are provided to the subcontractor, vendor, or affiliate, and are available at the work location during the period of performance of the work.
      6. The signed documents must be scanned and uploaded to the sJHA database in a timely manner (e.g., preferably by the end of the next business day).
    3. Subcontractor Oversight — To confirm and document that the subcontractor, vendor, or affiliate is performing the work as authorized, the requestor must provide oversight and record observations by using the risk-based, graded approach described below and completing the online sJHA form.

      Work that is not performed in conformance with the sJHA must be corrected on the spot. Significant or multiple nonconformances are entered into the Laboratory's Corrective Action Tracking System (CATS) or another appropriate system. In addition to the requestor's/division's oversight, the Non-Construction Safety Assurance Program Manager will perform independent spot-checks that will be documented and used to assess program effectiveness.

Hazard Level

Frequency

Low-Level Hazard Work

Oversight of low-level hazard work (see Definitions, Section 31.6) is performed at a frequency that is discretionary and comparable to the oversight of similar activities performed by Berkeley Lab employees.

High-Level Hazard Work

High-level hazard work (see Definitions, Section 31.6) must be observed and documented at a minimum frequency of once per workday, or more frequently if required by work authorizations.



Work Process C.  Training and Orientation

Nonconstruction subcontractors must review the ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet:

31.8 Source Requirements

31.9 Reference Documents

Document number

Title

Type

07.02.003.000

Chapter 6 (Safe Work Authorizations)

Program

07.07.011.000

Chapter 8, (Electrical Safety)

Program

07.07.007.000

Chapter 10 (Construction Safety Manual Administrative Policies)

Program

07.02.001.000

Chapter 32 (Job Hazards Analysis)

Program

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Chapter 30 || Table of Contents || Chapter 32