Questions - doe-hdbk-1101-20040062

DOE-HDBK-1101-2004

develop and implement safe work practices to control the entrance, presence, and exit of

subcontractors;

conduct periodic evaluations of subcontractor worker performance and training and

ensure compliance with applicable PSM and other safety requirements;

verify that each subcontractor worker is trained in the work necessary to perform the job

safely [72];

maintain an employee injury and illness log related to the subcontractors work in process

areas covered by the PSM Rule [Q73];

establish a work authorization or permit system to control access to process areas and

ensure that workers are aware of subcontractor operations that may have an impact on

covered processes;

provide relevant information from the process and site emergency action plans to

subcontractors so that their employees know what to do in an emergency [Q71].

Subcontractors must:

train each worker in the potential fire, explosion, or toxic release hazards related to the

job and the process, and the applicable provisions of the emergency action plan [Q71];

document worker training required by the PSM Rule with records that identify the

employee and date of training, and include a means to verify successful completion

ensure that each of its workers follows the safety rules of the facility, including the safe

work practices;

advise DOE contractors of any unique hazards presented by their work, or of any hazards

found in the course of their work.

Questions

69.

Must contractors apply all of the PSM Rule contractor requirements to a

subcontractor already working on or near a covered process?

Yes. DOE contractors should consider evaluating their programs and performance as a

way of ensuring that the subcontractor is able to comply with the facility's safe work

practices. However, the PSM Rule does not require that DOE contractors subject existing

subcontractors to the pre-contract screening designed for selection of new subcontractors.

70.

What is acceptable documentation for ensuring that a subcontractor complies with

its obligations under the PSM Rule?

DOE contractors may use a variety of methods to ensure that subcontractors comply with

obligations under the PSM Rule, including periodic inspections of a work sites, reviews

of subcontractor training programs and records, and inspection of subcontractor incident

reports. Each method can be used to obtain a sampling of subcontractor activity. The

results of these physical or record-keeping audits can be summarized and retained in a

subcontractor performance file.