Staging Solutions has established procedures to review and require that subcontractor safety programs, training, procedures and initiatives coordinate with the Company’s own standards of safety.
The process is intended to help ensure that, in the event subcontractors are utilized by the Company as part of a work project, each subcontractor’s safety programs, OSHA compliance, training, confirmations, documentations and statistical results of previous safety performance are in accordance with requirements of both the Company and general contractor.
Under this program and its associated processes, any subcontractor will be reviewed and qualified by the Company prior to performing work for a general contractor as part of a Company project.
Subcontractor safety and health requirements:
- Pre-qualification by the Company will include review of the subcontractor’s:
- Review of the subcontractor’s OSHA 300 log for the last five years, or from the date the subcontractor began doing business if this time is less than five years;
- OSHA experience regarding any previous inspections or citations;
- Written safety and health programs as required by the Company and/or the respective host employer or general contractor;
- Written subcontractor procedures for at-work incident, injury, illness and emergency response, reporting and investigation requirements;
- Workers’ compensation insurance EMR (Experience Modification Rating) information;
- Proof of insurance documented by a current certificate of insurance from the subcontractor’s insurance agent(s);
- Documentation of required safety training of subcontractor employees that will be assigned to the respective project, including supervisor, competent person training and site safety representative training;
- Documentation of required Operator Qualification (OQ) and other individual qualifications or certifications as may be required by the project; and
- Documentation as may be available to explain the subcontractor’s previous safety performance using a statistical method.
- Review and evaluation will be performed by the Company Safety Manager, or a qualified third party as designated by the Safety Coordinator.
- Written materials, submissions, results and documentations of subcontractor pre- qualification reviews will be maintained by the Safety Coordinator in a file for a period to be determined in coordination with the Company’s designated legal counsel.
Measurements of workplace safety and health results
- To manage a process or system, you must be able to measure it. This is why the Company measures safety performance and results as a tool toward identifying and eliminating hazards, mitigating risks and protecting employees and other individuals from workplace injuries and illnesses.
- For purposes of this program, a safety metric will be considered as any such measurement of safety performance and injury/illness/incident prevention results.
- Specific safety metrics to be considered during subcontractor pre-qualification will include, but are not limited to, items 2.1.1 through 2.1.9 above.
- Safety metrics will be utilized to help evaluate when, where and how safety programs and initiatives have been successful, and also to identify areas that require additional attention.
- Subcontractor safety performance will be reviewed and evaluated in part through comparisons of the subcontractor’s safety metrics with levels of accomplishment as identified by the Company.
- Subcontractors that evidence safety metrics that are not in accordance with project requirements will not be utilized for that specific project; or they will be utilized in roles and assignments that have lower levels of risk and are acceptable to the Company and host employer or general contractor.
- All determinations of acceptability of a subcontractor’s safety metrics, as requested and reviewed in accordance with this program, will be made by the Company and/or the host employer or general contractor for the respective project.
Inclusion and participation of subcontractors in project safety initiatives
- Subcontractors assigned by the Company to a project will attend initial safety and planning meetings; project safety orientations; incident, injury and illness response planning and coordination meetings.
- Subcontractor personnel will participate in these and other such activities as required in preparation for working safely at the project location.
- Subcontractor personnel will utilize, cooperate with, attend and support all pertinent components of safety programs and procedures; safety orientation, training, tailgate and daily meetings; qualification and/or certification requirements; periodic safety meetings and awareness activities; safety inspections; incident reporting and investigation procedures; and other such safety, health and incident prevention initiatives as may be established for all workers at a project location.
- Subcontractor personnel will participate in and cooperate with Job Hazard Analysis (JHA), Job Safety Analysis (JSA) and Job Safety Observations (JSO) as established for the project workplace.
Requirements for reporting hazards, incidents, injuries and illnesses
- Subcontractor employees are responsible for reporting any observed near-miss, hazard or unsafe behavior of another person when there is a potential for causing an incident, chemical release, injury or illness in the project workplace. First report will be made to the subcontractor’s on-site supervisor or to the Company contact person if the supervisor is not readily available. Reporting should be made without delay to help facilitate intervention and preventive measures.
- Subcontractor supervisors and/or management will forward any such report to their Company contact person so that additional communication can be made and/or actions taken if the Company deems this necessary.
- Any on-the-job injury or illness that requires medical attention by a physician or professional medical provider will be reported immediately to the Company contact person after the individual(s) requiring treatment are in route to medical care.
- Subcontractors will investigate near-misses, first aid injuries, and incidents, injuries or illnesses in the project workplace in accordance with requirements established for the project.
- Post-project review of subcontractor safety performance and results
- On conclusion of a project, the Company will make a timely review of each subcontractor’s safety performance, incident and injury experience, and other factors that will be helpful in evaluating the subcontractor’s suitability for future projects.
- In the event that a subcontractor exits or is terminated from a project that remains in progress, a similar timely review will be performed.
- Post-project evaluations will be performed by the Company Safety Manager in coordination with Company managers and supervisors who worked with the subcontractor during the specific project under review.