Non-Construction Safety Assurance for Subcontractors, Vendors and Guests Working at LBNL Facilities (PUB-3000 Chapter 31) Mike Ruggieri Safety Program Manager EH&S Division Earth Sciences Division Meeting October 28, 2008
JHAs and Work Authorizations Are Required at LBNL Every Worker must be either directly supervised or have a current Work Authorization resulting from a job hazards analysis process. [PUB-3000 Chapter 32 Section 32.3 Policy]
What is the Scope of PUB-3000 Chapter 31 Policy? The 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: Consultants, personal services agreements, contract labor, Intra University Transactions, ALS Users and other university agreements Subcontractors, vendors or guests who have completed a LBNL Job Hazards Analysis.
What is Considered Hands-On Work? Hands-on work includes: • Use of hand or power tools • Repair or service of a device, apparatus, machine or mechanism • Material handling • Handling or disposing of a chemical, compressed gas, or hazardous, radioactive or bio-hazardous material Hands-on work does not include: • Office and administrative duties • Computer programming • Attending or making a presentation • Supervision of a worker who is not performing hands-on work • Photography • Chauffer or taxi services
What is the “Old” Non-Construction Safety Assurance Process? A Requisition Preparer uses the E-Procurement system to submit a contract requisition and designates if onsite services are required. Procurement Buyer checks if scope of work is on the Designated Commercial Services list, if it is not, the Buyer asks the subcontractor to complete a safety checklist and return it to the Buyer. Buyer sends the completed checklist to the EH&S Program Manager for Non-Construction Safety Assurance for approval. EH&S Program Manager approves checklist and notifies the Buyer or requests more information. When checklist is approved, Buyer can give the start work notification.
There are Three Requirements for the “New” Non-Construction Safety Program Subcontractor Job Hazard Analysis and Work Authorization (SJHAWA) Must be completed for hands-on work performed at LBNL facilities by non-construction subcontractors, vendors and guests (SVG) who are not captured by the LBNL JHA system. Pre-Job meeting must occur between the Requester and SVG To review SJHAWA and EH&S Orientation Determine work hazard level Sign SJHAWA which is the written work authorization Graded oversight of SVG’s work Requester provides graded oversight of the work based on the work hazard level.
What is the “New” Non-Construction Safety Assurance Process? Requester submits a contract requisition form (or equivalent) for on-site hands-on services and a SJHAWA form to a Requisition Preparer. Requisition Preparer uses E-Procurement software to submit the contract requisition and attaches the SJHAWA form. Upon award of the contract, the Procurement Buyer sends the SJHAWA and other safety expectations to the Subcontractor. The Subcontractor completes the SJHAWA and sends it to the Requester and reviews EH&S Orientation.
What is the “New” Non-Construction Safety Assurance Process? (continued) The Requester determines the hazard level for the work scope and obtains any other necessary work authorizations. A Pre-Job Meeting is held with the Requester and Subcontractor and the SJHAWA is signed. The scope of work is performed by the Subcontractor with graded oversight by the Requester. Safety performance data is collected by the Program Manager for Non-construction Safety Assurance and the data is reported to the Procurement Department.
Who Are the Main Participants and What Are their Responsibilities?
Implementation of Chapter 31 Includes Three Types of Work Activities Subcontractor work to be performed on new or revised service contracts including onsite installation or warranty service related to equipment purchases. 2. Subcontractor work being performed on existing service contracts that pre-date PUB-3000 Chapter 31. 3. Work to be performed onsite by Guests without a contract.
Step 1: Contract Requisition Process is Initiated The Requester defines scope of work, completes contract requisition form and determines if hands-on services will be required at an LBNL facility. If hands-on services will be required at an LBNL facility, the Requester: Obtains a blank SJHAWA form from the NSAP Program’s web page Completes the section allocated to the Requester Submits the contract requisition form and the SJHAWA to the Requisition Preparer.
Step 2: Requisition Submitted to the Procurement Department The Requisition Preparer uses the E-Procurement software to initiate, modify or renew a contract. Refers to the documents submitted by the Requester to answersquestions on the E-Pro form that ask if hands-on services will be required at an LBNL facility. If the answer is yes, the Requisition Preparer submits a contract requisition and the SJHAWA to the Procurement Department. The Requester and Division Safety Coordinator receive an e-mail message providing instructions on the safety assurance process from the NSAP Program Manager.
Step 3: Safety Expectations are Communicated to the Subcontractor Procurement Buyer prepares the contract documents and sends them to the Subcontractor Documents include contract language regarding EH&S requirements, instructions on the SJHAWA and EH&S Orientation, and use of the web page for the Program Attaches SJHAWA (partially completed by Requisition Preparer) that includes instructions to complete the SJHAWA and send it to the Requester.
Step 4: Subcontractor Completes SJHAWAand Other EH&S Requirements The Subcontractor Completes the SJHAWA form Reviews the EH&S Orientation Completes GERT if not already completed Returns the SJHAWA Form to the Requester/Division Contacts the Requester regarding a pre-job meeting
Step 5: The Work Hazard Level is Determined* The Requester reviews the completed SJHAWA and determines if additional work authorizations are required. If additional authorizations are required, the Requester obtains those before the pre-job meeting. * Support may be necessary from Division Safety Coordinator or EH&S Subject Matter Expert.
Step 5a: How is the Work Hazard Level Determined? The hazard level in the scope of work is determined using the following definitions from PUB-3000 Chapter 31. High Level Hazard Work: An activity that requires a safe work authorization (e.g. laser activity hazard document, radiological work authorization) or electrical work authorization, as described in PUB-3000 Chapter 6 and Chapter 8, respectively. Low Level Hazard Work: An activity that does not require a safe work authorization or electrical work authorization.
Step 6: The Pre-Job Meeting* The Requester and the Subcontractor meet in person to discuss: The scope of work, hazards and controls Verification of GERT completion The EH&S Orientation Any other required work authorizations The SJHAWA and any other written work authorizations are signed by the Requester and the Subcontractor. A copy of the SJHAWA package is given to the Subcontractor and a copy is stored close to the work area. The Requester is required to retain a copy of the SJHAWA package and provide it to the EH&S Division upon request. * Support may be necessary from Division Safety Coordinator or EH&S Subject Matter Expert.
Step 7: Work is Performed With Oversight from Requester The Requester provides oversight of the work performed by the Subcontractor. Low hazard work is overseen at the same level as if an employee was performing the work High hazard work is overseen at least daily and more frequently if other safe work or electrical authorizations require it. Oversight notes are recorded and filed with the SJHAWA. Work that is not performed in conformance with the SJHAWA is corrected on the spot. Significant or multiple non-conformances are entered into the LBNL Corrective Action Tracking System or other appropriate system.
The Non-Construction Safety Program collects performance data using DBO2 database. • Field observations on pre-job meetings and work performance • Review of SJHAWA documents • Safety violations and incidents • Quarterly data reports are provided to the Procurement Department. Step 8: Safety Performance Data is Reported to Procurement Department.
There are Four Process Steps for Work On Pre-Existing Contracts The Requester with input from the Subcontractorcompletes an SJHAWA for the ongoing scope of work* The hazard level for the work scope is determined by the Requester and any required written work authorizations are obtained.* The SJHAWA is signed by the Requester and the Subcontractor. The work continues to be performed by the Subcontractor and the Requester provides the level of oversight required. *Support may be necessary from Division Safety Coordinator or EH&S Subject Matter Expert.
There Are Five Process Steps for Guests Performing Work Without a Contract The Requester prepares a SJHAWA and sends it to the Guest* The SJHAWA is completed by the Guest and returned to the Requester The hazard level for the work is determined by the Requester and necessary work authorizations are obtained* A Pre-Job Meeting is held with the Requester and Guest and the SJHAWA is signed * The work is performed by the Guest with graded oversight by the Requester * Support may be necessary from Division Safety Coordinator or EH&S Subject Matter Expert.
Some Additional Information SJHAWAs are valid for up to one year for the identified scope of work, work locations, and personnel. Work authorizations based on the “Old” Non-Construction Safety Work Checklist are valid for up to one year after the Division implements Chapter 31 or the period of performance for the contract, whichever is shortest. PUB-3000 Chapter 31 is being implemented at the Division Level and will become Laboratory Policy on January 1, 2009. The Program Manager for Non-construction Safety Assurance notifies the Procurement Department as Divisions begin implementing Chapter 31.
Where Do You Find Information and Guidance on the Program? PUB-3000 Chapter 31 Non-Construction Safety Assurance for Subcontractors, Vendors and Guests at LBNL Facilities Policy, scope, definitions, process descriptions, flow charts, guidance, and related documents EH&S Division web page for the Program SJHAWA form, EH&S Orientation, guidance, and resources Program Manager Your Division Safety Coordinator and EH&S Division Liaison EH&S Subject Matter Experts
Documents for the Pilot Program Currently on the Web http://www.lbl.gov/ehs/ssa/nssa/ SJHAWA form EH&S Orientation Booklet for Non-Construction Subcontractor, Vendors and Guests PUB-3000 Chapter 31 Link to LBNL GERT web page Links to PUB-3000, Chapter 6 Safe Work Authorizations, Appendix B Formal Authorizations Chapter 8 Electrical Safety List of Subject Matter Experts
Next Steps October 31 (Friday) ESD begins performing the SJHAWA process for new and revised subcontracts for SVGs. November 1st week ESD prepares to implement Chapter 31 process for pre-existing subcontracts. -- Submit list of existing SVGs to Maryann and Vivi so that they can check the SVG list against existing dataset. -- Maryann and Vivi finalize the ESD implementation process for existing SVGs. -- The ESD Chapter 31 process is sent to Requestors. November 2nd week Requestors implement the Chapter 31 process for pre-existing SVGs.