Who is responsible for training subcontractor employees to do their job safely?
Who is responsible for providing site-specific safety orientation?
Subcontractors are responsible for training their own employees. DOE contractors are
responsible for providing their subcontractors with sufficient hazard and process
information to enable them to conduct appropriate training. DOE contractors are also
responsible for ensuring that this training has been performed. Further, DOE contractors
are responsible for providing sufficient emergency action plan information to
subcontractors so that their employees know what to do in an emergency. In some cases,
it may be more efficient for DOE contractors to perform safety orientations and to
familiarize subcontractor employees with emergency action plans. In these cases, the
training responsibilities of the two parties should be clearly defined and understood.
When a subcontractor is hired to perform a job for which a DOE contractor has no
expertise, how can the DOE contractor be expected to ensure that the subcontract
employees are trained to do their job safely?
A DOE contractor must establish safe work practices for the facility and is expected to
require subcontractors to follow these practices. Although a DOE contractor is not
expected to know all requirements for a specific work practice associated with a special
skill or craft for which the subcontractor was hired (e.g., proper handling of hazardous
waste generated as a result of a unique maintenance activity), the DOE contractor is
required to evaluate and audit the subcontractor's own safety programs and practices.
Is a subcontractor injury/illness log required during the construction of a covered
If a new process is being built in an area totally removed from any other covered process,
and if no HHC has been introduced, the subcontractor injury/illness log provision does
not apply. However, if an existing process has been made chemical-free for construction
purposes, the subcontractor element of the PSM Rule still applies, due to the potential
presence of residual chemicals.