Contractor Safety Program

Developed By: Brian Anderson

Last Reviewed: 04/27/2023

Audience: Confidential, For SBM Use Only

This is the Contractor Safety Program for SBM Management Services, LP. It applies to all our work operations. SBM Management Services, LP will be responsible for overall direction of the Contractor Safety Program.

Introduction

All firms contracted by our company, because they are employers, are required by the Occupational Safety and Health (OSH) Act of 1970 to provide safe and healthy employment to their employees.

It is also our policy as an employer to be responsible for providing a safe and healthful work environment for employees. Contract work, especially in occupied buildings, may present situations or conditions that may adversely impact the safety and health of employees.

Responsibilities

All personnel responsible for managing contracts will ensure that:

1. Each contractor is provided with warnings of hazards and information about our programs for abating these hazards.
2. Each contractor is informed of our safety, health, and environmental requirements.
3. The work is conducted in a safe and responsible manner in compliance with applicable regulations.

Contracting Officer

The Contracting Officer will require the contractor to:

1. Meet all applicable federal, state, and local environmental, health, and safety regulations.
2. Provide its employees with the necessary training, medical exams, and safety equipment.
3. Submit written comprehensive safety and health plan for the specific contract undertaken.
4. Comply with all applicable federal, state, and local regulations and if found in violation of these being grounds for default of the contract.

The Project’s Contracting Officer will:

1. Communicate the contractual, statutory, and other environmental, health and safety requirements to the contractor prior to the start of the contract.
2. Ensure that the safety and health plan is submitted with the bid package.
3. Ensure that such requirements are addressed in the Request for Solicitation and/or contract paperwork.
4. Ensure that such requirements are observed.
5. Upon receipt of a report of a noncompliance or any condition, which poses a serious or imminent danger to health or safety, issue a request for immediate corrective action from the contractor.

Project Officer

The Project Officer will, prior to the start of the contract, inform the contractor of the requirement to observe all environmental, health, and safety provisions specified in the contract, provided by statutes/regulations or otherwise required.

The Project Officer will:

1. Ensure that the Safety Manager is provided with a copy of the contractor’s written health and safety plan for review prior to the first meeting with the contractor.
2. Ensure the Safety Manager is represented at all meetings held with contractors.
3. Provide the Safety Manager with a tentative schedule for contractors on-site and immediate written notification of changes.
4. Notify C/I/O’s of contractor work schedule, location, and special precautions or concerns prior to the start of the project.
5. Monitor the contractor’s work performance and determine if contractor is complying with the contract health and safety plan and pertinent environmental, health, and safety regulations. Any questions regarding compliance with specific regulations should be referred to the Safety Manager.
6. Ensure that the contractor completes all required permits and provides a signature of an authorized person and/or appropriate personnel.
7. Notify the Safety Manager immediately of accidents or injuries and provide him with a copy of the contractor’s accident reports.
8. Notify the Safety Manager immediately of an OSHA complaint and/or inspection of contractor’s jobsite.

Contractor

A firm or individual contracted by our company is responsible for meeting all contractual agreements and for providing a safe and healthy workplace for its employees.

The contractor will observe the following:

1. Provide for frequent and regular safety inspections of the worksites, materials, and equipment by competent employees.
2. Notify the Project Officer of construction accidents in a timely manner.
3. Notify the Project Officer of non-formal OSHA complaint notifications and/or OSHA inspection of the jobsite.

Safety and Health Plan

When required by the contract, the contractor must develop and implement a comprehensive health and safety plan for his or her employees, which covers all aspects of onsite operations and activities associated with the contract. This plan must comply with all applicable health and safety regulations and any project-specific requirements that our company has specified. The contractor must provide the Contracting Officer with a copy of this plan with its bid package.

Acceptance of the contractor’s health and safety plan only signifies that the plan generally conforms to the requirements of the contract. It does not relieve the contractor of the responsibility for providing employees with a safe and healthful work environment. This concept must be communicated to the contractor by the Contracting Officer and also incorporated into the contract document.

Pre-Project Meeting

Representatives of the contractor shall meet with the Contracting Officer, Project Officer, and representatives prior to the start of the project for the purpose of reviewing safety requirements and discussing implementation of all health and safety provisions pertinent to the work under contract.

The representative will review the contractor’s site-specific safety and health plan with the contractor as well as review all required safety data sheets (SDS) submitted for proposed products to be used by the contractor.

SBM Management is required by OSHA standards, most notably 29 CFR 1910.1200, Hazard Communication Standard, to provide information to contractors on the hazards present at the work site. This information will be made available to the contractor in the project specifications (pre-bid) as well as at the pre-project meeting.

Fire Prevention and Protection

The contractor shall prepare and carry out an effective fire protection and prevention plan, including provisions for the fire protection and suppression equipment set forth in this section. This plan shall be made part of the comprehensive safety and health plan submitted by the contractor with its bid package and cover the following:

Housekeeping - Good housekeeping, with provision for prompt removal and disposal of accumulations of combustible scrap and debris, shall be maintained in all areas of the jobsite. Self-closing metal containers shall be used for disposal of waste saturated with flammable liquids.

Codes and regulations - The contractor shall comply with the requirements published in the current revisions of the National Electrical Code, National Electrical Safety Code, and the National Fire Protection Association standards.

Smoking - Smoking or other sources of ignition shall not be permitted in areas where flammable or explosive materials are stored or are present. There is a no smoking policy in effect within all our facilities. All such areas shall be conspicuously posted: NO SMOKING OR OPEN FLAMES.

Fires - Fires and open flame devices shall not be left unattended unless protected with automatic temperature control and cutoff devices.

Cleaning and degreasing - Gasoline and liquids with a flash point below 100 degrees Fahrenheit shall not be used for cleaning and degreasing.

Building exits - All buildings, shops, and plant facilities in which employees are required to work shall have at least two well-marked and lighted exits. The two exits shall be arranged to minimize the possibility of both exits being rendered inaccessible by one fire or emergency condition.

Fire extinguishers - Distinctly marked fire extinguishers rated 2A40B:C or greater shall be suitably placed as follows:

1. One for each 3,000 square feet of building area or major fraction thereof. Travel distance from any point of protected area to nearest extinguisher shall not exceed 100 feet.
2. One or more on each floor of buildings with at least one located adjacent to each stairway.
3. At least one located outside but not more than 10 feet from the door opening into any room used for storage of more than 60 gallons of flammable or combustible liquids.
4. At least one located not less than 25 feet, or more than 75 feet from any outside flammable or combustible liquid storage area.
5. At least one within 50 feet of wherever more than 5 gallons of flammable or combustible liquids or 5 pounds of flammable gas is being used.

Noncompliance with Safety and Health Requirements

During the course of the contract situations of non-compliance with the contractor’s safety and health plan or our company’s safety and health requirements, will be brought to the attention of the Project Officer and the Contracting Officer verbally and will immediately be followed-up in writing. Failure to correct the violation or continued violations shall be grounds for termination of the contract.

If after notifying the Project Officer and Contracting Officer in writing of deficiencies of any health and safety violations which could pose an imminent danger, an immediate order to stop work will be issued. Should this occur, the Safety Manager would bring the matter to the immediate attention of the Project Officer, Contracting Officer, and the Director. Such violations may result in the default of the contract.

Safety Training

The contractor must ensure that its employees have completed appropriate health and safety training when required by statute/regulation and provide documentation of such training when required by the contract. All training must be documented and made available upon request.

Medical Clearance

The contractor must ensure that its employees have appropriate medical clearance when required either by governmental regulations or by our company’s requirements. Copies of medical clearance for contractor personnel are required to be presented as specified by the contract.

The Project Officer and the Safety Manager shall determine if additional medical requirements (i.e., Blood serum samples, immunizations) are required for contractor personnel prior to the start of work.

Incident Reporting

An SBM EHS Manager will participate with contractors in the investigations of incidents resulting in injury/illness and/or damage or loss of property and also near misses.

Safety and Personal Protective Equipment

Unless otherwise specified, the contractor is responsible for providing all necessary safety and personal protective equipment (PPE) needed by its employees. This equipment must meet appropriate OSHA requirements and be in good working order.

The contractor shall ensure that its employees have received appropriate training on the use and maintenance of safety and PPE prior to its use. Failure to correctly use appropriate safety equipment is a violation of the contract and may result in default of the contract.

Documentation

The contractor must provide our company with documentation of all required training, medical exams, permits, safety data sheets (SDS), etc., for his or her employees or operations at the pre-project meeting.