Chapter 31
sJHA PROCESS – SUBCONTRACTOR JOB HAZARDS ANALYSIS

Contents

Approved by Bill Wells
Revised 07/12

• 31.1 Policy
• 31.2 Scope
• 31.3 Applicability
• 31.4 Exceptions
• 31.5 Roles and Responsibilities
• 31.6 Definitions
• 31.7 Required Work Processes
  • Work Process A. sJHA Process Overview
  • Work Process B. Creating an sJHA
  • Work Process C. Training and Orientation
• 31.8 Source Requirements
• 31.9 Reference Documents

NOTE:
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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:

• Completing the Subcontractor Job Hazards Analysis (sJHA)
• Reviewing the sJHA and validating findings with the subcontractor
• Providing work oversight to ensure the subcontractor is performing the work as authorized

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:

• The sJHA and any other required work authorizations are reviewed and signed.
• The ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates is discussed.

31.3 Applicability

This policy applies to:

• All Berkeley Lab divisions
• All hands-on work performed at Berkeley Lab facilities by nonconstruction subcontractors, vendors, and affiliates who are not under direct supervisory control of Laboratory personnel
• Subcontractors, vendors, and affiliates who perform nonconstruction, hands-on work at facilities owned or leased by Berkeley Lab

31.4 Exceptions

This policy does not apply to:

• Most consultants
• Personal services agreements
• Contract labor
• Intra-university transactions
• Advanced Light Source (ALS) and other user-facility affiliates addressed by another work authorization mechanism
• Other university agreements
• Subcontractors, vendors, or affiliates who have completed a Berkeley Lab Job Hazards Analysis and Work Authorization per the Environment, Health & Safety (EHS) Health & Safety Manual, Chapter 32 (Job Hazards Analysis)

31.5 Roles and Responsibilities

31.6 Definitions

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

31.7 Required Work Processes

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.

Work Process C.  Training and Orientation

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

• Prior to working on site, and
• To verify understanding at the pre-job meeting.

31.8 Source Requirements

• PUB-3140, Integrated Environment, Safety & Health Management Plan: Integrated Safety Management (ISM) System
• PUB-3851, Worker Safety and Health Program
• 10 CFR 851, Worker Safety and Health Program

31.9 Reference Documents

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Chapter 30 || Table of Contents || Chapter 32