Intent - doe-hdbk-1101-20040061

DOE-HDBK-1101-2004

Intent

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.

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 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

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;