The objective of the subcontractor safety element is to ensure that levels of safety are not
compromised by subcontractor operations and that subcontractor employees are an integral part
of the PSM program. (A sample subcontractor safety program is provided at the end of this
section.) Prior to hiring such subcontractors, DOE contractors must screen their safety programs
and performance to ensure that they have the knowledge, skills, and certifications to safely
complete the work [Q69]. The subcontractor safety element includes requirements for both DOE
contractors and their subcontractors, as described below.
Corresponding DOE Programs and Requirements
Most DOE contractors are required to describe applicable workplace hazards and to monitor the
safety of subcontractor operations as part of traditional safety programs. These programs are
reexamined periodically to ensure continued control under conduct of operations and
maintenance management requirements. Similarly, such programs must be examined for
consistency with the requirements of the PSM subcontractor safety element.
DOE has program oversight responsibility for DOE contractors. However, the principle focus of
this PSM element is on DOE contractors who have operational control of covered processes and
their subcontractors whose work might affect these process units.
DOE contractors may use a variety of methods to ensure that subcontractors comply with
obligations under the PSM Rule, including pre-contract evaluation of safety programs, periodic
inspections of a work site, reviews of subcontractor training programs and records, and
inspection of subcontractor incident reports. These methods can be used to obtain a sampling of
contractor activity. The results of physical and record-keeping audits can be summarized and
retained in a subcontractor performance file [Q70].
DOE contractors are required to maintain a log of subcontractor injuries and illnesses (OSHA
200 Form) for operations in the vicinity of processes covered by the PSM Rule. Subcontractors
are required to document worker training.
Minimum Implementation Criteria
DOE contractors must:
obtain and evaluate information about subcontractors safety and performance including
safety manuals, current injury and illness incidence rates, and the past years OSHA 200
before work begins, inform subcontractors of the potential fire, explosion, and toxic
release hazards related to the subcontractors work and describe the process;
provide for subcontractor employee access to PrHAs and PSI for the processes where
they are working [Q71];
explain the applicable provisions of the emergency action plan to subcontractors;