Chapter 8: Contractor Safety Policy

Good communication is a necessary element of maintaining safety at construction sites. Communication with subcontractor groups must identify safety hazards and prevention practices that each bring to the worksite. Therefore, UMW has implemented the following contractor safety program for our worksites so that on the job injuries are minimized and work practices may be standardized.

Purpose

A written contractor safety policy establishes guidelines to be followed for contractors working at the University.

The rules established:

Provide a safe working environment.
Govern facility relationships with outside contractors.
Ensure that contractor employees and our employees are trained to protect themselves from all potential and existing hazards.

The effectiveness of the contractor safety program depends upon the active support and involvement of all employees. This plan is intended to implement a program to ensure that all contractor work practices are carried out safely to minimize the possibility of injury or harm to the contractors’ employees or employees of UMW. It is intended to serve as an additional tool in safeguarding the health and safety of employees.

The contractor safety policy establishes uniform requirements designed to ensure that contractor safety orientation, coordination, and safety administration practices are communicated to and understood by employees.

The University is a higher education facility requiring special scheduling of work to be performed in relationship to student needs and requirements. Work must be performed with the least amount of disruption to the system during the school calendar.

This document is provided to ensure all corporate safety plans, policies and procedures are communicated to all participating contractors. It also provides an avenue for contractors to communicate their safety plans, policies and procedures to the University. This program aims to prevent personal injuries and illnesses for ALL employees

Administrative Duties

The Director of OEMS is responsible for developing and maintaining the program. A copy of the plan may be reviewed by employees. It is located in the OEMS Offices at Hamlet House. In addition, the Director of Maintenance, Director of Capital Outlay, and the Director of Contract Services are responsible for maintaining any records related to the contractor safety program.

If after reading this program, you find that improvements can be made, please contact OEMS. We encourage all suggestions because UMW is committed to the success of our safety program. We strive for clear understanding, safe behavior, and involvement.

Explanation of Responsibilities

UMW Responsibilities

UMW has specific safety responsibilities when hiring contractors to come onto the campus to perform work. Responsibilities when hiring contractors include the following:

Take steps to protect contract workers who perform work on or near a potentially hazardous process.
Obtain and evaluate information regarding the contract employer’s safety performance and programs.
Inform the contractor of known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process.
Explain the applicable provisions of the emergency action plan to the contractor and require that the contractor relay that information to all workers who will work at this site.
Develop and implement safe work practice procedures to control contract employee entry into hazardous work areas.
Periodically evaluate the contract employer’s fulfillment of his or her responsibilities under this policy.
Hire and use only contractors who meet Contractor Selection Criteria as listed in the next section of this policy.
Ensure a contractor safety plan is submitted for work that is being performed as well as any necessary licenses or standards.

Contractor Responsibilities

Contract employees must perform their work safely. Considering that contractors often perform very specialized and potentially hazardous tasks, such as confined space entry activities and non-routine repair activities, their work must be controlled. Contractor responsibilities when accepting contracts with the University will include the following listed steps. The contract employer will:

Assure that the contract employees are trained in the work practices necessary to safely perform his or her job.
Instruct the contract employee in the potential fire, explosion, or toxic release related to his or her job and the process.
Assure that the contract employee knows the applicable provisions of the emergency action plan.
Document contract employee training.
Inform contract employees of and then enforce safety rules of the facility, particularly those implemented to control the hazards of the contracted process during operations.
Require that all subcontractors abide by the same rules to which the contractor is bound.
Abide by UMW Policies, where applicable, including Smoking Policy.
Secure badging and key authorizations according to the University Badge and Key Policy.

Before contract work begins, the University will:

Designate a representative to coordinate and communicate all health and safety issues with the contractor. The designated representative will have a copy of the work document, be thoroughly familiar with its contents, and be familiar with the health and safety aspects of the work and know “who” to call to obtain this information. The designated representative is responsible for ensuring that all company responsibilities listed below are carried out.
Provide information about the facilities’ written safety policies and procedures to the contractor.
Inform the contractor of any emergency signals and procedures that may occur in areas where the contractor’s employees are working. The contractor should be given emergency response numbers.
Conduct an inspection of the proposed worksite area before the pre-construction meeting so any known information about on-site hazards (particularly non-obvious hazards) are documented and thoroughly communicated to the contractor.
Work directly with the contractor’s designated representative.
Conduct a pre-construction meeting (walkthrough) with the contractor’s designated representative and a supervisor from each of the areas of the facility involved in the contractor’s work. The meeting should include a representative from Public Safety to address parking and badging as well as the Institution Fire Safety Officer.
Review all contract requirements related to health and safety with the contractor’s designated representative, including but not limited to, rules and procedures, Personal Protective Equipment (PPE), and special work permits or specialized work procedures. Advise the contractor that the facility health and safety policies must be followed at all times.
Inform contractor’s designated representative of the required response to employee alarms and furnish the contractor with a demonstration or explanation of the alarms.
Communicate thoroughly with the contractor’s designated representative any health and safety hazards (particularly non-obvious hazards and hazard communication issues) known to be associated with the work, including those in areas adjacent to the worksite. Tell them it is the contractor’s responsibility to convey this information to its employees.
Review preparation of worksite before contractor begins initial work.
Identify connection points for all services, such as steam, gas, water, electricity, etc. Define any limitations of use of such services. This includes securing permits for confined space entry, hot work and any work that may affect any and all systems related to Life Safety at the University.
Ensure that all affected employees at the University receive training on all hazards to which they will encounter during the contract work.

The UMW Representative will:

Limit, as necessary, the entry of employees and students into contractor work areas.
Monitor the contractor’s compliance with the contract throughout the duration of the work. When checking contractor work during the project, note any negligent or unlawful act or condition in violation of safety standards or requirements. Any items noted should be brought immediately to the attention of the contractor’s designated representative in writing. However, if an unsafe act or a condition is noted that creates an imminent danger of serious injury, immediate steps should be taken with the contractor’s designated representative, or in his or her absence, the contractor’s employees to stop the unsafe act or condition. Do not allow work that is in violation of a regulation to continue.
Document all discussions, including place, time, and names of contractor employees in attendance.
Approve the contractor beginning work each day unless it is routine service or maintenance work or periodic outdoor service or maintenance work.
For work for which this company has developed specific and generally applicable procedures, make sure contractors and their subcontractors follow the same procedures.
Do not allow loaning of tools and equipment to outside contractors and their subcontractors. The contractor is required to provide the necessary tools and equipment.
Contact the nearest medical facilities, when available, in emergency situations where severity of the injury dictates immediate attention.
Investigate and report any property losses.

Contractor Guidelines for Information Exchange

Before the contract work begins, the contractor must:

Designate a representative to coordinate all health and safety issues and communicate with the University’s designated representative.
Provide documentation of any necessary safety training as described in the Training Requirements section of this policy.
Provide information to the designated representative on the safety and health hazards that may arise during the course of the contractor’s work at the University, and the means necessary to avoid danger from those hazards, including Hazard Communication and all other potential hazards.
Obtain from the University any safety rules and regulations in effect at the site or potential hazards present that may affect the contractor’s work.
Be certain to be informed of any emergency signals and procedures that may be put into operation in areas where the contractor’s employees are working. The contractor should be certain to have the telephone numbers of the nearest hospital, ambulance service, fire department and campus police.
Advise and train its employees on hazards associated with the work to be performed, including any Hazard Communication or other hazard information.
Keep the designated representative for the University fully informed of any work which may affect the safety of UMW’s employees, students, or property. This includes complying with the state and federal Right-To-Know legislation and providing the designated representative appropriate safety data sheets (SDS) or other required information about chemicals the contractor will bring onto the site.
Know who to call and what to do in emergencies, including where first aid and medical services are located.

During the contract work, the contractor will:

Have a designated site safety coordinator present and attentive to the work being carried out at all times that the contractors and/or subcontractors are working at the facility site.
Ensure that all subcontractors are abiding by the terms of this plan.
At Times, perform its work while the University is operating, if necessary, and establish necessary safe practices to permit work under operating conditions without endangering UMW’s employees, students, or property. This includes, but is not limited to:
1. Barricading
2. Sign Posting
3. Flagging
4. Fire Watches
Make sure that any equipment, chemicals, or procedures used by the contractor meet all OSHA requirements.
Be held responsible and accountable for any losses or damages suffered by the University and/or its employees or students as a result of contractor negligence.
Provide its employees with medical care and first-aid treatment.
Use only the building entrance designated, if applicable, and follow the facility access control practice. The contractor also will ensure that each contractor employee is issued and wears UMW issued badges which are to be obtained daily from the Public Safety Emergency Communications Office located in Brent Hall.
Provide supervisors and employees who are competent and adequately trained, including training in all health and safety aspects of the work involved in the contract.
Provide all tools and equipment for the work, including Personal Protective Equipment (PPE), and ensure the equipment is in proper working order and employees are instructed in its proper use.
Maintain good housekeeping in the workplace.
Follow specific instructions supplied by the University should emergency alarms be activated.
Notify the designated representative immediately of any OSHA recordable injury or illness to contractor employees or subcontractor employees occurring while on the site of any UMW property. Provide a copy of each accident report to the designated representative.

After conclusion of the contract work, the contractor is responsible for cleaning all work areas and disposing of any discarded materials in a proper and legal manner.

Training Requirements

UMW Requirements

UMW makes sure that affected employees and/or students receive training on all hazards to which they will be introduced by a contractor. In addition, we emphasize to the contractor that it is the contractor’s responsibility to convey to its employees any safety information provided by the company to the contractor.

Contractor Requirements

The contractor must:

Train all workers on all health and safety hazards and provisions applicable to the type of work being done and provide documentation of such training to the University’s designated representative.
Train employees on where to obtain first aid and medical services.

Recordkeeping Requirements

UMW Requirements

The designated representative will:

Have a copy of the contract on file and be thoroughly familiar with its contents and with the health and safety aspects of the work.
Keep copies on file of all forms or statements related to the contract that are required by the company to be filled out before or during contract work.
Keep a daily log regarding prework inspection findings.
Keep records of all documentation of any sort given to you by the contractor, including records of training, SDS, accident reports, etc.
Document all discussions, letters, memos, or other communications made to the contractor regarding safety issues, including place, time, names of people involved.

Contractor Requirements

The contractor will:

Keep records of all training done with contract workers and all documentation provided to the contracting company regarding such training.
Keep copies on file of all forms or statements related to the contract that are required by the company to be filled out before or during contract work.
Have on file the telephone numbers of the nearest hospital, ambulance service, and fire department.
Have copies on-site of all Safety Data Sheets (SDS) or other required information about chemicals relevant to the work on-site.
Keep an OSHA recordable injury and illness log for the project, as well as copies of accident reports on all accidents that occur in the course of the project.