Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

71.

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 respon-

sible 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.

72.

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 em-

ployees 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 requirments 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.

73.

Is a subcontractor injury/illness log required during the construction of a covered

process?

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.