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DOE-HDBK-1101-96
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 perfor-
mance 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
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 CSOs have program oversight responsibility for DOE contractors under their control.
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.
Documentation Requirements
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 perfor-
mance 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 year's OSHA 200 Log;
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;
develop and implement safe work practices to control the entrance, presence, and exit of
subcontractors;
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