Chapter 31
NON-CONSTRUCTION SAFETY ASSURANCE FOR SUBCONTRACTORS, VENDORS, AND GUESTS AT LBNL FACILITIES

Note: The requirements described in Chapter 31, "Non-Construction Safety Assurance for Subcontractors, Vendors, and Guests at LBNL Facilities," of PUB-3000 are being implemented at the division level during the remainder of CY 2008. Accordingly, Chapter 31 will not be Laboratory-wide policy until the beginning of CY 2009. Contact your Division Safety Coordinator to find out when your division is implementing Chapter 31 and how it will affect your daily work activities.

Approved by Michael Ruggieri
Rev. 09/08

31.1   Background
31.2   Policy
31.3   Scope
31.4   Definitions
31.5   Responsibilities
31.6   Non-Construction Safety Assurance Process
31.7   Records Management
31.8   Standards
31.9   Related PUB-3000 Chapters
31.10 References
31.11 Appendices

Appendix A. Flowcharts for the Non-Construction Safety Assurance Process
Appendix B. Guidance for Performing Non-Construction Safety Assurance Process
Appendix C. Job Hazards Analysis and Work Authorization Form for Non-Construction Activities Performed by Subcontractors, Vendors, and Guests
Appendix D. List of Examples of Hands-On Work Activities
Appendix E. EH&S Orientation for Non-Construction Subcontractors, Vendors, and Guests

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31.1 Background

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 their Subcontractors, Vendors, and Guests perform work on-site in compliance with LBNL 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, and the institutional requirement for job hazards analysis is discussed in Chapter 32.

31.2 Policy

Before Hands-On Work (see “Definitions,” Section 31.4.3) can be performed by Subcontractors, Vendors, or Guests at LBNL facilities, the following activities must be completed,

A Subcontractor Job Hazards Analysis and Work Authorization (SJHAWA) form must be completed, and the subcontractor, vendor, or guest must review the LBNL EH&S Non-Construction Safety Orientation.
A pre-job meeting between the Requester/Division and the subcontractor, vendor, or guest must occur at which:

The SJHAWA and the EH&S Non-Construction Safety Orientation is discussed and the hazard level for the work is determined.
A work authorization is prepared and signed by the Requester/Division and the subcontractor, vendor, or guest, which summarizes the scope of the work, hazards, hazard controls, and any related conditions or constraints for the work.

During the conduct of the hands-on work performed by the subcontractor, vendor, or guest,

The Requester/Division provides oversight of the subcontractors using a risk-based graded approach (see Section 31.6.3).

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 Section 31.6.

31.3 Scope

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 consultants, personal services agreements, contract labor, Intra-University 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.

31.4 Definitions

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

31.4.1 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.

31.4.2 Guest

An individual who is invited to come to an LBNL facility and does not work under a subcontract with LBNL or an LBNL subcontractor.

31.4.3 Hands-on Work

Includes all activities except administrative office work and other similar activities. For more guidance on what is defined as hands-on work, see Appendix D, “List of Examples of Hands-On Work Activities.”

31.4.4 High-Level Hazard Work

Any 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.

31.4.5 Low-Level Hazard Work

An activity that does not require a safe work authorization or electrical work authorization.

31.4.6 Non-Construction Work

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).

31.4.7 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.

31.4.8 Requester/Division

An individual in an LBNL division who requests and oversees the conduct of Subcontractor, Vendor, or Guest services.

31.4.9 Requisition Preparer

An LBNL worker who is trained and authorized to use procurement software programs for initiating requisitions and purchase orders.

31.4.10 Risk-Based Graded Approach

A process to ensure that work activities are efficiently managed through systems that are adequate 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.

31.4.11 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.

31.4.12 Subcontractor Job Hazards Analysis and Work Authorization (SJHAWA)

An SJHAWA 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 supercede those in the SJHAWA.

31.4.13 Vendor

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

31.5 Responsibilities

31.5.1 Requester/Division

Ensures that an SJHAWA is prepared for the Subcontractor, Vendor, or Guest who will perform hands-on work at an LBNL facility, and that a pre-job meeting is held between the Requester/Division and the Subcontractor, Vendor, or Guest before work is performed.
When required, obtains safe work or electrical work authorizations for the scope of the work to be performed by the Subcontractor, Vendor, or Guest.
Using the risk-based graded approach described in this chapter, provides oversight of the Subcontractors.

31.5.2 Division Safety Coordinators

Provide EH&S support to their Division as necessary for implementing the Subcontractor, Vendor, and Guest safety assurance process defined in this Chapter.
Request support from the EH&S Division Non-Construction Safety Assurance Program Manager when necessary.

31.5.3 Subcontractor, Vendor, and Guest

Provides input on SJHAWA, and submits it to the Requester/Division.
Reviews the LBNL EH&S Non-Construction Subcontractor, Vendor, and Guest Orientation.
Attends the pre-job meeting, and discusses the steps of the work and the associated hazards and controls.
Agrees to work in conformance with the authorized conditions.
Performs the scope of work as authorized.

31.5.4 EH&S Division Non-Construction Safety Assurance Program Manager

Provides guidance, leadership, and direct consultative services to the requesting division to guide its 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 (e.g., SafetyNet).
Maintains the program.

31.5.5 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 an LBNL facility complete an SJHAWA and review the LBNL EH&S Non-Construction Safety Orientation before starting work.
Using the SafetyNet database or another system, monitors Subcontractor and Vendor performance including EH&S compliance.

31.6 Non-Construction Safety Assurance Process

The following three activities must be performed before hands-on work is performed on-site by a subcontractor, vendor, or guest.

An SJHAWA form must be completed, and the Subcontractor, Vendor, or Guest must review the LBNL EH&S Non-Construction Safety Orientation.
A pre-job meeting between the Requester/Division and Subcontractor, Vendor, or Guest must occur at which

The SJHAWA and EH&S Orientation is discussed, and the hazard level for the work is determined.
The SJHAWA and any other required work authorization is signed by the Requester/Division and the Subcontractor, Vendor, or Guest.

Using a risk-based graded approach, the Requester/Division must provide oversight of the Subcontractor, Vendor, or Guest.

The following sections (31.6.1 through 31.6.3) define the minimum requirements for authorizing a Subcontractor, Vendor, or Guest to perform non-construction work at LBNL facilities. Recognizing that operational differences exist between divisions, divisions may develop methods to fulfill requirements that suit their organizations and work environments, and include them in their division’s ISMS implementation plans. Guidance for performing the three required activities is provided in the attached appendices.

31.6.1 Subcontractor Job Hazards Analysis Work Authorization

An SJHAWA must be prepared for all hands-on work that will be performed on-site by the Subcontractor, Vendor, or Guest for the scope of work over a period of performance. To assist the Subcontractor, Vendor, or Guest in developing an effective SJHAWA, the requesting division will provide the following items:

A written scope of work that defines the tasks to be performed and includes sufficient information about local conditions and hazards.
The standardized LBNL SJHAWA form that is available on the LBNL EH&S Web page.
The LBNL EH&S Non-Construction Safety Orientation that is also available on the LBNL EH&S Web page.

31.6.2 Pre-Job Meeting between Requester/Division and Subcontractor, Vendor, and Guest

To facilitate effective communication between the Requester/Division and Subcontractor, Vendor, and Guest, a pre-job meeting is required. Prior to the pre-job meeting, the Subcontractor, Vendor, or Guest will review the LBNL EH&S Non-Construction Safety Orientation, which is available on the LBNL EH&S Web page, and discuss any topics of concern at the meeting. At the pre-job meeting, the following activities are to be completed:

Review, discuss, and modify as necessary the SJHAWA.
Determine if the work hazard level is low or high.
Identify any required hazard controls.
Obtain any other necessary written work authorizations (safe work or electrical work authorizations) and identify the period of performance for the SJHAWA.
Both parties sign the SJHAWA; for work hazard levels that are determined to be high, the required safe work or electrical work authorizations are also signed.
The completed and signed copy of the SJHAWA is provided to the Subcontractor, Vendor, or Guest, and is available at the work location during the period of performance of the work.

31.6.3 Oversight of the Subcontractor’s Work

To confirm and document that the Subcontractor, Vendor, or Guest is performing the work as authorized, the Requester/Division shall provide and record oversight using a risk-based graded approach as described below:

Oversight of low-level hazard work (see “Definitions,” Section 31.4.5) is comparable to the oversight of similar activities performed by LBNL employees.
High-level hazard work (see “Definitions,” Section 31.4.4) must be checked at a minimum frequency of once per workday, or more frequently if required by work authorizations.

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 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.

31.7 Records Management

Completed Subcontractor Job Hazards Analysis and Work Authorization forms and related documents (i.e., safe work and or electrical authorizations, evidence of training) shall be maintained (as printed or electronic documents) by the Requester/Division in accordance with the LBNL/PUB-201, Regulations and Procedures Manual (RPM).

Completed Subcontractor Job Hazards Analysis forms and related materials (i.e., safe work or electrical authorizations, evidence of training) shall be made available to EH&S Division personnel.

31.8 Standards

10 CFR 851, Worker Safety and Health Program

31.9 Related PUB-3000 Chapters

31.10 References

31.11 Appendices

Appendix A Flowcharts for the Non-Construction Safety Assurance Process
Appendix B Guidance for Performing the Non-Construction Safety Assurance Process
Appendix C Subcontractor, Vendor, and Guest Job Hazards Analysis and Work Authorization Form
Appendix D List of Examples of Hands-On Work Activities
Appendix E EH&S Orientation for Non-Construction Subcontractors, Vendors, and Guests