Refining Subcontractor Safety Requirements

Hazard Analysis and Risk Assessment (HARA) greatly aids our Operations Safety personnel.

ENSURING subcontractor safety requirements are adequately defined is often an arduous task. Procurement specifications are used as a complement to the design package and provide additional information to the bidders that defines special conditions associated with the work site, how scrap materials are to be handled, quality provisions and, of course, safety requirements.

In addition, these specifications describe the conditions under which the work will be performed and the required submittal documents bidders would be required to provide. Often, detailed safety requirements are necessary where the nature of the work could be hazardous. These types of tasks include welding or cutting, lockout/tagout, crane operations, confined space entry, etc. A common practice is to require prospective subcontractors to provide plans for how they would accomplish these tasks and the procedures they intend to use to ensure personnel and equipment are utilized safely.

Unless bidders are specifically asked to provide a plan for how they intend to accomplish those tasks, that information (understandably) almost certainly will not be forthcoming. These plans provide detail on how specific actions will be carried out by the bidder; they may describe precautions to be utilized; where hazard data will be maintained, and how incidents will be reported.

In an attempt to standardize procurement specifications, requirements have been routinely defined on a conservative basis, assuming such high hazard work as the "baseline." However, with the wide variety of work that may be desired, risks can vary considerably. For low-risk work, where the exposure to hazardous conditions is remote and the work is being subcontracted due to specialized skills or proprietary matters, the quantity and scope of required safety oversight will obviously be less. For example, reprogramming a software-driven controller may only involve connecting and working from a laptop. If the controller is located in a utility room and does not control critical or hazard monitoring functions, the risks are not relatively high. In these cases, providing very detailed safety specifications may be detrimental to increased safety because of the laborious nature of reading very comprehensive safety specifications--only to find there is little or no content that is applicable to their specific scope of work.

On the other hand, requiring additional safety plans from bidders is probably warranted when the work involves the type of higher-risk tasks noted previously (welding or cutting, lockout/tagout) and the procurement specification needs to include the additional detail.

Finding a Better Way
Our company faced a situation similar to the one described above. Our procurement specification template contained very detailed requirements that ensured prospective bidders had requirements for every condition they could possibly face; regrettably, it also ensured that, for many jobs (especially less hazardous ones), there was a great deal of content that was superfluous. Had this condition resulted in merely extra content that simply did not add value, the problem probably would have gone unaddressed.

But because the volume of material we were presenting prospective bidders was so great, and often little of it was applicable to their specific job, it had negative effects. Including large amounts of generic content almost ensured it remained unread; it lent itself to confusion and could even result in inflated bids, because of bidders' pricing based on contingencies that are outside the specific scope of work. It was our desire that bidders provided the appropriate documentation to demonstrate they could execute the tasks described in the subcontract in a safe manner. How we accomplished this was a concern for our company.

When we initiate a project, part of the design process is developing the Hazard Analysis and Risk Assessment (HARA). It is performed to document the initial risk assessment of the project. It analyzes the design for hazardous conditions and considers unintended effects, interfacing systems, operating environments, etc. Its development follows the design as it matures, from the Preliminary Design Review (PDR) all the way to the Critical Design Review (CDR). It is an integral part of the process and is performed to ensure risk is identified and assessed, and that unanticipated effects are not introduced. Integrating safety early in the design has been critical for our success. Even when new technology is applied with the intent of reducing worker injuries, integrating safety with other work is crucial (Linsenmayer, 1985). Although the scope and level of scrutiny may vary (depending on the complexity of the project), all of our projects include a HARA.

As part of our company's management practice, it is utilized to ensure hazards are discovered before they induce harm, that their risks are assessed and options for adequate control measures are provided. Its development follows the design; as more detail about the project design is available and the design "matures," the HARA "matures," as well.

Another factor affecting subcontractor project work was our organizational structure. Our Safety organization consists of essentially two functions: Engineering and Operations. Safety Engineering provides the technical assessment and analysis of project development (including developing the HARA), while the Operations Safety function provides oversight to the implementation--or work--phase of projects. This functional arrangement was fertile ground for omission and error in the "handoff" between the two functions.

In determining requirements for bidder submittals, we wanted a mechanism that prescribed, on a case-by-case basis, what the bidders were to provide. We wanted to base requirements for safety plans on the hazards associated with their specific job. A new approach was decided upon that involved tailoring the level of specific requirements for the bidder's safety plan, based in part on what was learned during the design process. A separate section of the HARA was developed to apply the traditional design analysis tool to assessing of the risks associated with the tasks, conditions, and materials required to implement the project.

While this is certainly not revolutionary, it continues the evolutionary trend of applying hazard recognition methodologies outside of their traditional applications in order to find an optimal "mix" to achieve program goals.

In fact, the U.S. Department of Energy continues to explore the application of different hazard analysis tools. DOE-HDBK-1163 (2003) encourages coordination in the development of hazard analyses. It notes that various analyses are integral parts of work planning that are vital to the preparation of other documentation, including Health and Safety Plans.

While falling short of a Job Safety or Task Analysis, this revised HARA reaches beyond a strict design assessment tool. It may be used to determine applicable requirements for the bidder's submittals and also as a set of requirements to review the bidder's safety plan.

While full implementation is not finalized, we anticipate this novel application of the HARA will provide a more coherent framework for developing bidder submittal requirements and will greatly aid our Operations Safety personnel.

This article appeared in the February 2005 issue of Occupational Health & Safety.

This article originally appeared in the February 2005 issue of Occupational Health & Safety.

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