Purpose The purpose of this safety program is to aid business owners with their Federal OSHA compliance efforts. Each business is unique and each program will require customization. As the program is customized, remember to only include words, sections, concepts, procedures, etc. that are relevant to the operations. The purpose of any written safety program is to provide a clear and consistent plan for addressing safety in a particular area of focus. Use Use this wizard to customize your program. Instructions To develop your customized plan, follow steps 1 through 3 in order, by clicking the buttons and following the instructions prompted by the program. Customize Review and Format Approve & Save

<CompanyName>

Subcontractor Safety Program

Version <Version>

Updated: <Date>

Contents

1.	Program Purpose	3

2.	Responsibilities	3

3.	Contractor Forms	3

4.	Establishing Safety Requirements	4

5.	Training & Communication	4

6.	General Safety Requirements	5

Appendix I: Contractor Qualification Form	9

Employee Acknowledgement	15

Program Purpose

To provide guidelines for the review and approval of contractors and subcontractors by determining whether potential contractors (including suppliers and vendors) meet their risk management, insurance, and general liability obligations prior to formalizing a contract.

To establish the safety measures that are necessary for contractors to follow onsite, which includes the risk management and incident prevention efforts of <CompanyName> in addition to the contractor’s own safety program.

This program affects those in the hiring process, contractors, subcontractors, and creators of the safety and health program. It must be used in conjunction with several other programs:

Comprehensive Safety and Health Program: This includes ongoing hazard analyses and hazard controls to protect contractors when they are on site. Also, contractors must be trained in safety policies and procedures.

Hazard Communication Plan: Contractors must be aware of the chemical hazards in their work areas.

Incident Response Plan: Contractors must be trained on how to respond to emergencies and all incidents.

Responsibilities

The overall implementation of this program is the responsibility of <JobPosition1>.

<JobPosition2> will establish the organization’s minimum insurance requirements.

<JobPosition3> will check the COIs (certificates of insurance) against the minimum requirements.

If COIs meet the minimums and the Contractor Qualification Form is approved, <JobPosition4> can finalize the contract for that contractor.

<JobPosition5> will review the submitted Contractor Qualification Forms.

<JobPosition6> will conduct training to all qualified contractors and their personnel on Hazard Communication, Process Safety Management, and Emergency Procedures. Other topics may be included as stipulated in the pre-work conference.

Contractor Forms

Forms that the contractors must submit:

The Contractor Qualification Form: This form outlines the contractors’ experience in the areas of risk management, insurance coverages, and general liability and also provides information on their insurance policies. Prospective contractors must complete this form prior to participating in the bid process. (See Appendix I.)

Certificates of insurance (COIs): Contractors must also provide copies of COIs for all applicable insurance coverages (i.e. Automotive, General Liability, Workers’ Compensation, etc.), prior to contract acceptance.

Establishing Safety Requirements

The pre-work conference:

Prior to work beginning at the job site, the contractor’s management representative and the Project Manager must attend a pre-work conference to review both the contractor’s safety and health programs and the programs of <CompanyName>.

Regulations that must be followed:

When the requirements and best practices differ between the contractor and <CompanyName>, the most stringent requirements and best practices must be followed.

All contractor and subcontractor employees must follow all requirements established by <CompanyName>, host employers, or customers, such as personal protective equipment (PPE), training, or facility-specific requirements posted throughout the jobsite.

In addition, all contractor and subcontractor employees must follow all Federal and State, Occupational Safety and Health Administration (OSHA), and environmental regulations.

Training & Communication

Documentation of all training is to be keep on file by <JobPosition7>.

Training topics:

Prior to working on the job site, all contractor representatives and employees must attend safety and health training on:

Hazard communication

Process safety management

Emergency procedures

Other topics stipulated in the pre-work conference

Walkthrough training:

<JobPosition8> must walk the contractor representatives and their employees throughout the job site to:

Explain the alarm system and evacuation plan

Review any safety or health hazards and protective measures associated with specific work areas

Weekly safety meetings:

At a minimum, weekly safety meetings must be held onsite with the goals of establishing open communication about safety and continuously improving the program.

Company and contractor safety representatives must perform daily jobsite walkthroughs with the purpose of immediately addressing safety issues and to note issues for discussion at the weekly safety meetings.

The meeting must include:

Safety representatives from every contractor

A safety representative from the facility

All contractors

General Safety Requirements

Contractor management responsibilities:

Every day prior to the arrival of workers for each shift, the contractor representative must meet with <JobPosition9> to review daily work activities and safety concerns.

Contractors must provide their employees with all the PPE and safety equipment needed to perform their jobs safely.

Daily “toolbox safety meetings” must be held by all contractors/subcontractors and attended by all employees. Records from all daily and weekly safety meetings and walkthroughs must be forwarded to <JobPosition10> for permanent retention.

Contractor employee responsibilities:

Every day prior to starting work, check in with your lead contractor representative.

No one under the influence of drugs or alcohol is permitted on the jobsite. Do not bring drugs and/or alcoholic beverages on the jobsite.

Do not engage in horseplay or recklessness, which can endanger employees and property.

Do not bring firearms or other weapons on the jobsite.

Hot work permits:

Hot work includes welding, burning, grinding, and open flame or torch cutting operations.

Prior to the performance of any hot work, a hot work permit must be obtained from <JobPosition11>.

A fire watchman with a proper fire extinguisher must be placed at hot work sites and remain there for at least 60 minutes after the work is finished per the hot work permit.

Chemical handling:

Before they are brought onsite, <JobPosition12> must review chemicals and their SDS’s for their hazard potential and disposal requirements. Do not bring chemicals onsite without this review.

Assure that chemicals are contained in DOT-specified containers with proper GHS-compliant labels.

Follow grounding and bonding procedures for all flammable/combustible materials.

Do not transport chemicals through any portion of the facility without prior consent.

Power and Hand Tool Use:

All applicable guards will remain on and operational. All damaged tools will be removed from service. All equipment should have clear identification on it and be locked in gang boxes or trailers at the end of shift. Subcontractors are responsible for maintaining a hand & power tool inspection program.

Powder Actuated Tools:

Only qualified and properly trained operators should use powder-actuated tools. Users should possess Qualified Operator Cards issued by a manufacturers authorized dealer or other competent source.

Ladders:

Ladders present one of the major hazards in construction work. All ladders (stock) should meet ANSI standards and be equipped with safety shoes. Ladders should be on a regular inspection program. All defective ladders should be repaired or destroyed. Ladders should be placed approximately 1/4 of its supported length away from the vertical plane of its top surface. Both top and bottom of ladders should be secured. Metal ladders should not be used around electrical equipment. Permanent stairways should be installed as soon as possible to minimize the need for job built ladders.

Scaffolding:

Scaffolds should be designed, built and inspected by competent persons. Firm footings for each upright should be provided. Footings should be secured against moving by recessing, staking or other means. Platforms should be constructed of 2 x 10 wood plants. A minimum of 6 inch laps on each side of ledger member. Guard rails and toe boards should be installed. Rolling scaffolds should not be moved with workers riding them. Brakes should be applied when scaffolds are not being moved. All scaffolds should be constructed and designed for a safety factor of at least 4 feet. Scaffolds should be inspected daily prior to use.

Mobile Cranes, Derricks, and Tower Cranes:

Only able-bodied, trained, and qualified personnel should be permitted to operate this type of equipment. Maintenance is the responsibility of the subcontractor. All equipment used for hoisting should be inspected daily. A qualified person should make inspections of cables, sheaves, and pulleys, booms & boom stops on a regular basis. Workers should not be permitted to adjust, lubricate, or repair any mechanism with moving parts until stopped and de-energized. All appropriate safety devices should be in place. No crane should be operated in excess of the rated capacity. Two crane lifts should have radio communication between crane operators. Cranes should not be operated near excavations or power lines.

Material Hoists:

Material hoists should not be used for transportation of workmen and no personnel should be allowed to ride in material hoist cages. Hoistways and towers should be built with foundation foots with a safety factor of at least 5 feet to sustain maximum possible loading. The bottom panel should be screened in on as many sides as possible. Outdoor hoist ways should be enclosed the entire height, except for loading and unloading platforms. All personnel hoists should be in compliance with ANSI A10.4 SAFETY REQUIREMENTS FOR PERSONNEL HOISTS.

Heavy Earthmoving & Handling Equipment:

Only able-bodied, trained, and qualified operators should be permitted to operate this type of equipment. Training should include a thorough review of hazards, safe and unsafe procedures, and good working knowledge of the machine itself. Maintenance programs should be thorough, workable, and consistent with the manufacturer’s specifications. A systematic preventative maintenance program should be established and records kept. Regular inspection procedures should be followed. Hardhats should be worn by operators at all times. Unauthorized riding on equipment should be prohibited.

Conveyors & Cableways:

All gears, shafts, pulleys and nip points should be guarded. Emergency stop devices should be installed at intervals. No riding of conveyors. Cross overs or unders shall be provided periodically along the line to provide safe passage. When conveyors pass overhead they must be guarded substantially to prevent objects from falling onto workers below.

Materials Handling & Storage:

Materials should be segregated as to kind, size, and length, and placed in neat, orderly, stable piles. If the piles are high, they should be stepped back as the height increases, and be secured by cross piling or cross tying. Piles of materials should be arranged so as to allow for passage ways. Materials placed in or near public streets should be well guarded, have suitable warning signs in daytime and have red lights on or around them at night.

Petroleum Products:

Drums and tanks should be labeled and have “NO SMOKING" signs posted. Transfer points should have bonding and grounding lines. Spill containment should be utilized if possible. Earthen dikes should be built to divert spills away from structures.

Excavation & Shoring:

Prior to excavation, a preliminary survey should be completed with evaluation of damage potentials to utilities, adjoining properties, etc. Any existing damage should be identified and documented. Open cuts and adjacent thoroughfares should be adequately barricaded and posted. Lighting should be provided during hours of darkness. Pedestrian traffic should be controlled by guardrails or fences. Trenches and excavations should be filled or covered and signed at the end of the workday.

A competent person should be held responsible for frequent inspection of shoring and each workman should be instructed to report any signs of weakness. Trench shields and shoring should be used in all trenches workers must enter that are deeper than 5 feet.

Demolition:

Only licensed, experienced demolition subcontractors shall be used. A demolition plan will be discussed with the Project Superintendent prior to commencing the demolition. Asbestos and lead exposures will be evaluated by the demolition subcontractors. Public protection is a priority as is protection of other workers. Material chutes must be enclosed and must not extend over two levels in a straight line. If dust is an issue, watering down will be required.

Pile Driving:

Workers not engaged in pile driving will be kept a distance equal to twice the pile length. Boilers must be inspected and approved. Pile driving equipment shall be inspected frequently.

Explosives:

Explosives should be delivered to the jobsite in daily use quantity if at all possible. Explosive storage areas will be stored a distance noted in the American Table of Distances in a magazine meeting all fire and protection requirements. ONLY AUTHORIZED PERSONNEL WILL HAVE KEYS TO THE MAGAZINES. Appropriate caution and warning signs shall be used. All blasting, public protection, traffic control, radio frequency control, and other safety issues will be coordinated with the Project Superintendent.

Welding and Cutting:

A suitable fire extinguisher should be ready for use in any area where welding and torch cutting is being completed. All cylinders will be chained upright when not in use. Oxygen and acetylene shall be stored a minimum of 20 feet apart. Welding screen should be used when possible.

Steel Erection:

Hardhats are required and material is not to be hoisted to a structure until ready to be put into position. Cranes and other equipment should be kept a minimum of 10 feet from all power lines. Provisions should be made to protect other personnel when throwing rivets. Fire protection should be provided at all rivet heaters. Floors should be installed as much as possible.

Concrete Construction:

Form lumber and supports should be selected after careful consideration of the loading factors. If there is a falling hazard when setting forms, safety belts or other means of fall protection will be required. Adequate setting time should be used prior to removing forms. Temporary bracing on tilt up walls and masonry walls during construction will be required.

Floor & Wall Opening:

Any and all floor openings larger than 12 inches shall be planked over or barricaded. Guard rails and toe boards shall be used where necessary.

Hazard Communication:

All subcontractors will provide a list of chemicals they will be using on site along with related Safety Data Sheets.

Appendix I: Contractor Qualification Form

Contractor Name:	Date:
QUESTIONS	Yes	No
Has your organization’s interstate Experience Modification Factor over the last three years stayed below 1.0?	☐Y	☐N
Has your organization's interstate Experience Modification Factor over the last three years trended downward?	☐Y	☐N
Has your organization’s OSHA Recordable Rates been below your industry’s average, nationally and on the state level, for the last three years?	☐Y	☐N
Has your organization’s OSHA Recordable Rate over the last three years trended downward?	☐Y	☐N
Have more than 25% of your organization’s employee-hours been spent in your industry-type?	☐Y	☐N
Do you provide new-hire orientation and daily, weekly, or monthly safety training for employees?	☐Y	☐N
Do you provide new-hire orientation and daily, weekly, or monthly safety training for foremen/supervisors?	☐Y	☐N
Do you provide new-hire orientation and daily, weekly, or monthly safety training for management?	☐Y	☐N
Do you conduct daily, weekly, or monthly safety inspections?	☐Y	☐N
Do you keep incident records and do your employees and management know how well the organization is doing?	☐Y	☐N
Do you have a written safety program and does it address general liability and automobile issues in addition to employee safety and health?	☐Y	☐N
List your Experience Modification Factor for the last 3 years:
List the OSHA Recordable Rates for the last 3 years:
List the percentage of employee-hours worked last year in your industry-type:
What are the major loss sources for your organization and what controls have you implemented to address them? List workers’ compensation, auto, and general liability claims against your organization and the controls for each using the outline below.
Loss Sources	Controls
Does your Safety Program include written procedures and employee training on the following? Note to Project Manager: Assess whether N/A responses are appropriate based on the type of activity the contractor is to perform.
Category	There is a written procedure	There is training	N/A
Personal protective equipment (PPE)	☐ Written	☐ Training	☐ N/A
Hazard assessment process	☐ Written	☐ Training	☐ N/A
Pre-hire background checks	☐ Written	☐ Training	☐ N/A
Subcontractor audits and a shared space safety plan	☐ Written	☐ Training	☐ N/A
Certificate of insurance (COI) tracking	☐ Written	☐ Training	☐ N/A
Respiratory protection	☐ Written	☐ Training	☐ N/A
Fall protection, including perimeter and openings guarding and a competent person onsite	☐ Written	☐ Training	☐ N/A
Ladder safety	☐ Written	☐ Training	☐ N/A
Scaffolding and person-lift safety, including having a competent person onsite	☐ Written	☐ Training	☐ N/A
A clear statement that the goal of the safety program is prevention and not just compliance	☐ Written	☐ Training	☐ N/A
Housekeeping for work areas, walkways, and stairs	☐ Written	☐ Training	☐ N/A
Fire protection	☐ Written	☐ Training	☐ N/A
First aid facilities and first aid staff onsite	☐ Written	☐ Training	☐ N/A
Emergency preparedness (e.g., for weather or chemical spills)	☐ Written	☐ Training	☐ N/A
Hazard communication program, including training and labeling	☐ Written	☐ Training	☐ N/A
Trenching, shoring, and excavation safety, including having a competent person onsite	☐ Written	☐ Training	☐ N/A
Public protection, controlled access, traffic flow, barricades and flagging, and attractive nuisance control	☐ Written	☐ Training	☐ N/A
Electrical safety and ground assurance	☐ Written	☐ Training	☐ N/A
Rigging and crane certification	☐ Written	☐ Training	☐ N/A
Confined space entry	☐ Written	☐ Training	☐ N/A
Process safety	☐ Written	☐ Training	☐ N/A
Spill prevention, containment, drainage control, and physical protection of tanks and containers	☐ Written	☐ Training	☐ N/A
Hot work permits	☐ Written	☐ Training	☐ N/A
Pre-hire (and random) drug and alcohol screens	☐ Written	☐ Training	☐ N/A
Utility location procedures	☐ Written	☐ Training	☐ N/A
Machinery training	☐ Written	☐ Training	☐ N/A
Authorization for machinery use program	☐ Written	☐ Training	☐ N/A
Machinery preventive maintenance	☐ Written	☐ Training	☐ N/A
Flammable and combustible material storage and handling	☐ Written	☐ Training	☐ N/A
Pre-demolition hazard assessment (testing for asbestos, lead, cadmium, etc.)	☐ Written	☐ Training	☐ N/A
Safety and health plan based on pre-demolition hazard assessment	☐ Written	☐ Training	☐ N/A
Blasting controls	☐ Written	☐ Training	☐ N/A
An operation start-up safety audit	☐ Written	☐ Training	☐ N/A
ISO compliance, including a quality plan to assure that supplied materials are of known and consistent composition	☐ Written	☐ Training	☐ N/A
A hold harmless agreement to transfer risk to the contractor	☐ Written	☐ Training	☐ N/A
Secured site access and security in place	☐ Written	☐ Training	☐ N/A
Controlled construction debris	☐ Written	☐ Training	☐ N/A
Sufficient lighting	☐ Written	☐ Training	☐ N/A
Communication and coordination with local neighbors, police, and fire departments	☐ Written	☐ Training	☐ N/A
Safety committee program	☐ Written	☐ Training	☐ N/A
Ergonomics and body mechanics training and daily required stretching program	☐ Written	☐ Training	☒ N/A
Job safety analyses and safety observations completed for all positions and tasks	☐ Written	☐ Training	☐ N/A
Lock-out program	☐ Written	☐ Training	☐ N/A
QUESTIONS	Yes	No
Does your organization use job hazard analyses (JHAs) to communicate hazards and protective measures and to hold people accountable?	☐Y	☐N
Are investigations done for all incidents and near misses and not just for incidents?	☐Y	☐N
Are completed Incident Reports sent to:
President/Owner	☐Y	☐N
Vice President/Operations Management	☐Y	☐N
Foreman/Superintendent	☐Y	☐N
Do the Incident Reports describe and report results by respective line and department management?	☐Y	☐N
Is there a Behavioral based safety observation program, or at least on site supervisory observations, in place which include safety coaching?	☐Y	☐N
How are these safety observations documented?
Are the respective line and department management held accountable with the following methods?
Monthly safety performance evaluations in writing	☐Y	☐N
Written disciplinary procedure that references safety performance	☐Y	☐N
All levels of employees including upper management are included in the disciplinary process	☐Y	☐N
A Safety Incentive Program that includes safety behavior for employees and management	☐Y	☐N
Has anyone ever been held accountable for unsafe behavior using the following methods?
Employee written notice	☐Y	☐N
Management written notice	☐Y	☐N
Employee termination	☐Y	☐N
Management termination	☐Y	☐N

Employee Acknowledgement

I have received information on <CompanyName>’s Subcontractor Safety Program. By signing below, I agree to abide by the procedures in this document and bring to the attention of my supervisor any questions or concerns had.

Employee Name:
Employee Signature:
Date:

icwgroup.com ICW Group is the marketing name for ICW Group Holdings, Inc. For a list of all ICW Group Holdings, Inc. subsidiaries, please visit our website www.icwgroup.com.
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