Contractor Safety Management Program

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CONTRACTOR SAFETY MANAGEMENTPROGRAMSection:Occupational Health and Safety Management SystemPart: orDocument:Contractor SafetyPages:14 10 AppendicesIssued By:Issued Date:Revised Date:Reviewed Date:Revision #:By:Environmental Health and Safety2018.01.092020.12.022020.12.025Richard EnnsCONTENTSPURPOSE AND SCOPE2DEFINITIONS2ROLES AND RESPONSIBILITIES2CONTRACTOR SAFETY MANAGEMENT PROCESS5CONTRACTOR PREQUALIFICATION6CONTRACTOR SELECTION7IDENTIFICATION OF PROJECT/SITE H&S REQUIREMENTS9PRIME CONTRACTOR HANDOVER11CONTRACTOR PERFORMANCE MONITORING12POST JOB ACTIVITIES13REFERENCES14The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 1 of 30

PURPOSE AND SCOPEThe University of Calgary (University) is committed to providing a safe and healthy environment for itsemployees, students, visitors and contractors in accordance with the University’s Occupational Healthand Safety (OHS) Policy and applicable legislation.The University meets or exceeds the legislated requirements provided under the Alberta OccupationalHealth and Safety Act, Regulation and Code.All contractors conducting work for or on behalf of the University are required to meet or exceed allapplicable legislation including the Alberta Occupational Health and Safety Act, Regulation and Code.Contractors must also meet or exceed requirements set out in applicable University safety programs.This Contractor Safety Management Program applies to all contractors, including prime contractors,conducting physical work at the University such as construction and maintenance activities. It does notapply to consultants or contract employees such as contract instructors.Contractor occupational health and safety performance is a factor in the awarding and renewal ofUniversity contracts.This program applies to all faculties and units at University of Calgary who hire contractors.DEFINITIONSContractor – a person or company employed by the University that is directly involved in the executionof work under a contract with the University.Contractor Representative – a representative of the University who is accountable for managing theContractor.Prime Contractor – contractor responsible for coordinating health and safety management systems ofmultiple employers and to do what is reasonably practicable to ensure that OH&S legislation is compliedwith on the worksite. The duties of a prime contractor are set out in the Alberta Occupational Healthand Safety Act.ROLES AND RESPONSIBILITIESContractor RepresentativeContractor Representatives are representatives of the University. The Contractor Representative mayhold one of the following roles: Program ManagerProject Manager or CoordinatorFacilities or Zone ManagerMaintenance SupervisorDepartmental or Faculty hiring managerThe electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 2 of 30

A Contractor Representative MUST be designated for all contractors working at the University. A keyrole of the Contractor Representative is to ensure that this contractor safety management program isfollowed.When the contractor is a prime contractor, the specific responsibilities of the Contractor Representativeincludes ensuring: A construction kick-off meeting is held.The contractor is aware of their safety management responsibilities for their subcontractors.The contractor is aware of the requirement for workers to take the University safety orientation.The contractor is aware of University safety programs and their obligation to meet or exceed therequirements of applicable programs.The contractor’s safety management system is being executed as documented with a focus onhazard assessments, inspections, safety meetings, orientations, and incident management.Monthly reporting to the university includes the required safety information and there isappropriate follow up based on the monthly reporting.A project posting form is posted at each entrance to the worksite.Safety issues arising from the work of the contractor are resolved.A post-job contractor evaluation is conducted as required by this program.When University is the prime contractor or there is no prime contractor, the specific responsibilities ofthe Contractor Representative includes ensuring: Contractor workers take the University’s safety orientation.The contractor is informed of their health and safety responsibilities and performanceaccountability.The contractor is aware of University safety programs and their obligation to meet or exceed therequirements of applicable programs.Project kick-off meetings are conducted and recorded.Safety Issues arising from the work of the contractor are resolved.A project posting form is posted at each entrance to the worksite.All incidents and injuries are reporting in OARS and investigated.Environment Health and Safety Department Establish content and delivery process for the University contractor safety orientation. Advise and assist Contractor Representatives as necessary to resolve health and safety issues. Immediately communicate all health and safety concerns to the appropriate UniversityRepresentative, site supervisor and/or Contractor Representative. Support the pre-qualification of contractors. Process ISN exception and variance requests.Supply Chain Management Manage ISNetworld process. Develop contracting strategy regarding prime contractor with project proponent. Ensure the tender documents contain prime contractor designation for the work. Ensure contract holds contractor accountable to meet University safety requirements and thecontractors documented safety management system.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 3 of 30

ContractorGeneral Role Establish safety accountability of its employees and subcontractors and demonstrate visiblesafety leadership. Be familiar with University Safety Programs and meet or exceed the requirements of applicableprograms. Maintain ISNetworld account to University standard.Role when contractor is designated as the prime contractor for the project: Ensures that a project specific safety orientation is conducted prior to work commencing withcontractor and sub-contractor workers.Ensures workers have received University contractor safety orientation training.Communicates to contractor and sub-contractor workers their health and safety responsibilitiesand performance accountability.Ensures Field Level Hazard Assessments are completed.Provides the necessary level of supervision during execution of work.Immediately notifies the university whenever an EHS incident occurs that must be reported toan external regulatory agency.Ensures Joint Worksite Health and Safety Committees are established when required.Executes their safety management system as documented.Performs periodic documented worksite safety inspections.Collaborates with workers to resolve safety issues reported or otherwise identified.Takes the appropriate steps when a violation of health and safety requirements is identified.Completes a Project Posting Form and posts it at each entrance to the worksite.Investigates all incidents / injuries that occur at the worksite.Submits a summary report of leading and lagging indicators to the University ContractorRepresentative on a monthly basis.Role when university is designated as the prime contractor or there is no prime contractor for thework/project: Ensures their workers have received University contractor safety orientation training.Communicates to their contractor employees their health and safety responsibilities andperformance accountability.Ensures Field Level Hazard Assessments are completed.Provides the necessary level of supervision during execution of work.Notifies the University (Contractor Representative) whenever a safety incident occurs, includingfirst aid, medical aid and lost time incidents.Executes their safety management system as documented in ISN or otherwise submitted to theuniversity.Collaborates with workers to resolve safety issues.Takes the appropriate steps when a violation of health and safety requirements is identified.Completes a Project Posting Form and posts it at each entrance to the worksite.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 4 of 30

CONTRACTOR SAFETY MANAGEMENT PROCESSThere are six stages to the University’s Contractor Safety Management Process:The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 5 of 30

CONTRACTOR PREQUALIFICATIONPrequalification is the process of assessing a contractor’s EHS related information to determine the stateof their management system as well as their performance. The University uses the ISNetworld processto prequalify contractors from an EHS standpoint. The EHS Department is responsible to establish thecriteria against which contractors are assessed. The SCM department manages the ISNetworld process.The University does not prequalify contractors that are subcontractors to direct contractors of theUniversity and therefore these subcontractors are not required to subscribe to ISNetworld.ISN Subscription RequirementsEach contractor subscribed to ISNetworld is given an overall grade (A, B, C, D, or F) based on theirperformance history, specific safety programs, Workers Compensation Rate, Certificate of Recognition(COR) status, and insurance.If a Contractor is not subscribed to ISNetworld (or subscribed but not connected to the University), thenSCM may connect the vendor to the University in ISNetworld. It usually takes 1-2 business day(s) toconnect a contractor in ISNetworld. The contractor will then provide the required information and beassessed against the University’s ISNetworld evaluation criteria. For efficiency, there is a strongpreference that all contractors require a subscription to ISNetworld prior to bidding for work at theUniversity of Calgary.ISNetworld Contractor Exception ProcessIf the project proponent wishes to use a contractor that is not in the ISNetworld system and will notsubscribe to the ISNetworld system then a Contractor Exception Form (Appendix A) is completed by theproject proponent or EHS representative. To grant an exception, the Exception Process will call forsafety prequalification information to be collected from the contractor (Insurance, WCB rate, COR,safety performance, safety management system, etc). The contractor will be required to complete theContractor Prequalification Form (Appendix B) to enable the University to collect this information. Theinformation contained in the Contractor Prequalification form will be used to determine whether togrant an exception. When a contractor is required to address an emergency situation there may not betime for the contractor to complete the Contractor Prequalification Form and this would be taken intoaccount by the approvers of the Contractor Exception.The Contractor Exception Form may call for a higher level of University oversight of the contractor thannormal. The Contractor Exception form must be approved by an EHS Department Manager/Director anda Director level representative in the Business Unit/Faculty that would be managing the contractor.These approvals may be indicated by email or by signing the Contractor Exception Form. Contractorexceptions are not permitted for prime contractors. All prime contractors must subscribe to ISNetworld.ISNetworld Contractor Variance ProcessIf the project proponent wishes to use a contractor that is in the ISNetworld system but does not havethe required standing in ISNetworld, then an ISNetworld Variance Request Form (Appendix C) iscompleted by the project proponent or EHS representative. The Variance Request Form will identifymitigating factors in the contractor’s ISNetworld rating (e.g. high injury frequency rate but smallcompany so based on few exposure hours) and any improvement measures the company must take tobe employed by the University. The Variance Process may call for a higher level of University oversightThe electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 6 of 30

of the contractor than normal. The ISNetworld Variance Request must be approved by an EHSDepartment Manager/Director and a Director level representative in the Business Unit/Faculty thatwould be managing the contractor. These approvals may be indicated by email or by signing theContractor Variance Form. If the Variance Request calls for the contractor to take measures to improvetheir safety management processes then there must agreement from the contractor in writing.Contractor Prequalification Stage SummaryCONTRACTOR SELECTIONTender documents are to be prepared informing bidders of: Whether contractor will be prime contractor. University safety requirements. Hazards associated with the University site and infrastructure.Determination of Prime ContractorWhere a prime contractor is required, the University may designate prime contractor status andassociated responsibilities to a contractor by written agreement. The University will determine if aprime contractor is required and if so whether the contractor will be prime before the tenderdocuments are prepared. Whether or not the contractor will be prime is included in the tenderdocuments because it may affect the bid of the contractor.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 7 of 30

Reference the decision tree below to determine designation of Prime Contractor.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 8 of 30

Safety Requirements Conveyed in Contract/POThe following items must be conveyed to the contractor in writing as part of the Contractor or PurchaseOrder. Contractor must meet all applicable Occupational Health and Safety regulatory requirements. Contractor companies will be held accountable to execute their management system aspresented in their ISNetworld materials and any other submissions made to the University. The contractor must immediately report to the Contractor Representative all incidents that arerequired to be reported to external agencies. The University has the right to conduct investigations into contractor safety or environmentalincidents. If contractor is required to submit a document to Alberta OHS the University has right to reviewit in advance. The contractor must report immediately any on-site visit by an OHS Officer. The University has right to conduct inspections and audits of a contractor’s worksite. If a contractor worker appears not to be fit for work, the University has the right to request thecontractor to investigate and report on the outcome of the investigation to the University. Contractors must meet or exceed program requirements from the list of University programs setout in the ISNetworld system. Contractors must not use the University’s tools and equipment unless written authorization isobtained from the University.Contractor Selection Stage SummaryIDENTIFICATION OF PROJECT/SITE H&S REQUIREMENTSUniversity Safety OrientationAll contractor workers including subcontractor workers are required to complete the University’s on-linesafety orientation. A classroom session is also available for contractor workers unable to take the online orientation. This orientation informs contractor workers of University policies, procedures, andpotential hazards. Orientation records from the on-line orientation must be maintained by thecontractor company and made available to the university upon request for verification purposes.When laboratories are part of the worksite, a laboratory tour shall be conducted by or arranged by thecontractor representative as part of the construction/field work kick-off to ensure that the contractorsThe electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 9 of 30

are informed of hazards at the work site.Contractor Prime—Hazards Associated with University Infrastructure/SettingWhen the Contractor is prime, the University will communicate to the contractor the site hazards thatthe University is aware of associated with University infrastructure. These hazards will becommunicated to the contractor using the form contained in Appendix H—Worksite Hazards Associatedwith University Infrastructure/Setting. The contractor is expected to establish controls related to theidentified hazards.Contractor Prime—Contractor Emergency Response PlanWhen the contractor is prime, the contractor shall provide the University with a site-specific emergencyresponse plan that meets the standards outlined in the National Fire Code – Alberta Edition.Contractor Prime—Construction Kick-off MeetingA construction kick-off meeting will be held with the contractor to: Review contractor responsibilities. Outline reporting requirements from the contractor. Identify University safety programs and permit requirements that apply to the work.Appendix E is the kick-off meeting agenda form that is to be completed and signed by both theUniversity Representative and a representative of the Contractor at the time of the meeting.Contractor is Not Prime—Field Work Kick-off MeetingFor all contractors that are new to the University a field work kick-off meeting will be held with thecontractor. The Kick-Off Meeting Agenda form (Appendix E) will be used to guide the agenda for themeeting and serve a record that the meeting was held. If a contractor is on-site continuously orregularly to conduct the same type of work, instead of kick-off meetings there shall be safety reviewmeetings held at least annually. The items covered at these meetings shall include: Review of any safety incidents and follow up. Review of conformance to University safety programs that apply to the work. Review of any safety inspection results. Any safety improvement opportunities identified by either the contractor or the University.Contractor is not Prime—Hazards Associated with University Infrastructure/SettingWhen the Contractor is not prime, the University Representative will communicate to the contractor thesite hazards that the University is aware of associated with University infrastructure. These hazards willbe communicated to the contractor using the form contained in Appendix H—Worksite HazardsAssociated with University Infrastructure/Setting. The contractor is expected follow all universityprograms establishing controls related to the identified hazards.Contractor is not Prime—Contractor Emergency Response PlanWhere the contractor is not prime, the University Representative must supply a copy of the EmergencyResponse plan for the area work is to be conducted.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 10 of 30

Identification of Project/Site H&S Requirements Stage SummaryPRIME CONTRACTOR HANDOVERThe following requirements apply to Contractor’s that have been assigned the role of Prime Contractor.Project SignageA Project Posting Form must be completed and posted at the worksite. The Form is included asAppendix D and contains information on the time period over which the work is to be conducted, theUniversity contacts for the project and the contractor contacts for the project. The Contractor must alsopost signage at the worksite indicating that the Contractor is prime.Prime Contractor Handover DocumentA Prime Contractor Handover Document form is included as Appendix F. The document specifies thegeographic area of the worksite which is subject to the handover to the Prime Contractor. The PrimeContractor Worksite shall ideally be indicated by a continuous visible boundary such as fencing. When acontinuous visible boundary is not possible, structures or other physical markings may be used. Thedescription of the boundaries of the worksite to be handed over to the Prime Contractor must be agreedto in writing by the University and the Prime Contractor in the handover document.Worksite Safety OrientationsIn addition to the University of Calgary on-line safety orientation that all contractor workers must take,the Contractor is required to conduct orientations for all workers conducting work on a worksite forwhich the Contractor is prime. This orientation will inform workers of the specific hazards of theworksite and the measures to control those hazards, emergency response plans, and key elements ofthe Contractor’s safety management system. Records must be retained to demonstrate that all workerson the Contractor’s worksite have successfully taken the Contractor’s worksite safety orientation.Worksite AccessThe Contractor must establish and maintain Check-In areas to the Contractor’s worksite withappropriate signage. The Contactor must require all persons entering the worksite to register at acheck-in area. At the time of check-in, the Contractor shall communicate to them: Its role as Prime Contractor for the worksite.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 11 of 30

Existing and potential hazards at the worksite and the means by which those hazards shall beeliminated or controlled.The Contractor’s health and safety requirements for the worksite.Prime Contractor Handover SummaryCONTRACTOR PERFORMANCE MONITORINGWhen Contractor is PrimeInspections by Prime ContractorsAll prime contractors are required to perform regular worksite safety inspections. The writteninspection must document any necessary actions to be taken, who is responsible for completion ofthose actions, and anticipated timelines to correct any identified unsafe conditions and/or workpractices. The inspection process must include a follow-up process to ensure previously identifiedunsafe conditions and/or work practices are corrected. The contractor may be required to demonstratedue diligence by confirming that corrective actions were completed in a timely manner. These reportsmust be available for review upon request by the University.The University, upon request, may attend periodic inspections performed by prime contractors for thepurposes of fulfilling owner safety responsibilities and to ensure the protection of University publicspaces, its workers and students, and the public at large.Incident Reporting and InvestigationAll incidents resulting in an injury or environmental release must be investigated by the prime contractor.The prime contractor must immediately report to the Contractor Representative all incidents that arerequired to be reported to external agencies and provide copies of the associated incident investigationreports. The University has the right to conduct investigations into contractor safety and environmentalincidents. If the prime contractor is required to submit an incident investigation report to Alberta OHS,the University has the right to review the report before submission. The prime contractor must alsoreport immediately any on-site visit by an OHS Officer.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 12 of 30

Safety ReportingPrime contractors must complete a leading and lagging indicator report on a monthly basis whenever thecontractor is working continuously for a period in excess of one month. The specific information to beprovided in the monthly report will be communicated to the Contractor through the ISNetworld systemand the reporting shall be done through the ISNetworld system. The contractor representative shall useinformation from the prime contractor’s safety reporting, other information gathered from attendingproject meetings, observations from site tours, and whatever other information gathering process maybe necessary to assess whether the prime contractor is executing their EHS management system asdocumented.Document RetentionAll documents pertaining to project safety shall be retained for no less than 3 years after projectcompletion and shall be reviewable upon request by the University.When the Contractor is Not PrimeInspectionsSpot inspections are required to be conducted by the Contractor Representative in collaboration withthe contractor and with support from the EHS Department as needed.Within Facilities Management, one out of every 20 Work Requests involving contractors will undergo aspot safety inspection. Factors such as the hazards associated with the work and the contractor’sISNetworld standing will be included in the selection of the contractor being inspected. The ContractorSafety Inspection Checklist (Appendix G) shall be used when conducting these inspections and shallprovide a record that the inspection occurred. Completed checklists shall be retained for a three yearperiod.When a recommendation is made to correct an unsafe act or condition that cannot be corrected at thetime of the inspection, written documentation must be provided by the contractor to verify thecorrection of the unsafe act or condition.Annual validationsFor contractors who hold maintenance agreements with the University, a yearly validation of thecontractor’s insurance certifications and the hazards inherent in the university infrastructure must beconducted. An examination of the Contractor’s ISN profile shall be done to assess the contractor’sinsurance certifications if they are connected to the University in the ISN service. If the Contractor hasan ISN exemption, the Contractor Prequalification form (Appendix B) shall be forwarded to them forcompletion and reviewed.Document RetentionAll documents pertaining to project safety shall be retained for no less than 3 years after projectcompletion and shall be held by the University Representative’s department, reviewable upon request.Incident Reporting and InvestigationThe University of Calgary requires the reporting of all incidents to the contractor representative. Thisincludes: Injury incidents-first aid, medical aid, lost time.The electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 13 of 30

Environmental incidents (e.g. Release of hazardous materials to the environment).Near misses—unplanned events which under slightly different circumstances could cause orhave caused an injury).Appendix J contains the University’s incident classification standard which includes three levels ofincidents based on severity. All three levels of incidents as described in the standard must bereported to the University immediately. The Contractor Representative is responsible for theclassification of the incident, completing the reporting in the OARS system, and ensuring theinvestigation is completed.Contractor Performance Monitoring SummaryPOST JOB ACTIVITIESPost-Job Contractor EvaluationA post-job evaluation will be conducted for all projects completed by a prime contractor when the valueof the contract exceeds 500,000. For prime contractor jobs less than 500,000 and for non-primecontractors, post-job contractor performance evaluations will be done on an exception basis if theresome safety issue that arises during the course of the work. The contractor performance evaluationmay include: Review of whether contract safety requirements were met. Review of hazard assessments. Review of incidents including corrective actions taken. Review of safety meeting minutes. Review of worksite inspection reports. Review of reported unsafe acts or unsafe conditions present while on University propertyand timeliness of corrective actions taken.The University will review acceptable and non-acceptable performance with the Contractor andUniversity stakeholders, including Facilities and other units/departments who may be responsible toselect contractors to perform work in the future. If the University’s expectations are not met withregard to a Contractor’s EHS performance, the University will provide the Contractor with anThe electronic version is the official version of this Program.Occupational Health and Safety Management SystemContractor Safety Management Program2020 Dec 2 Revision 5Page 14 of 30

opportunity to respond with corrective actions consistent with contractual provisions.Post Job Activities SummaryLIST OF APPENDIXESAppendix A—ISNetworld Exception Request FormAppendix B—Contractor Pre-Qualification FormAppendix C—ISNetworld Variance Request FormAppendix D—Project Posting FormAppendix E—Kick-Off Meeting Agenda FormAppendix F—Prime Contractor Handover DocumentAppendix G—Contractor Safety Inspection ChecklistAppendix H—Worksite Hazards Associated with University InfrastructureAppendix I—University Incident Classification StandardREFERENCESAB Occupation Health and Safety Act – Section 3 Prime Contractorhttp://www.qp.alberta.ca/1266.cfm?page O02.cfm&leg type Acts&isbncln 9780779775699&display htmlAB Occupational Health and Safety Code – Sections 7(5), 178 (2), 178(3)https://work.alberta.ca/documents/WHS-LEG ohsc 2

A Contractor Representative MUST be designated for all contractors working at the University. A key role of the Contractor Representative is to ensure that this contractor safety management program is followed. When the contractor is a prime contractor, the specific responsibilities of the Contractor Representative includes ensuring:

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