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Contractor Health & Safety Policy – Alberta Version

BENEFITS


Ensuring that your own workers perform their jobs safely isn’t enough. To preserve health and safety, you must also impose rules and guidelines on the contractors and subcontractors who work at your site. That’s what this Model Policy does.

HOW TO USE THE TOOL


All companies need to adopt policies to ensure that their contractors work safely. This Model Policy, which is based on one developed by the University of Calgary, is a good starting point in devising a policy that meets your own circumstances. Note that the definitions and terminology in this policy are based on Alberta law. You’ll need to adjust them if you’re subject to OHS regulation of another jurisdiction.

ADDITIONAL RESOURCES


Community: Post a question in the discussion forum to identify other members who have dealt with this issue.

Contractor Health & Safety Policy – Alberta Version
Contractor Health & Safety Policy

Page 1 of 15

Introduction

ABC Company Ltd. (ABC) is committed to promoting the health, safety and well-being of its employees, visitors and contractors, as well as providing a safe and healthy environment in which to conduct activities, in accordance with ABC Occupational Health & Safety Policy.

ABC will meet or exceed the legislated requirements made under the Alberta Occupational

Health and Safety Act, Regulation and Code.

All contractors are required to meet or exceed the Alberta Occupational Health & Safety Act, Regulation and Code, and conduct their activities in accordance with ABC policies and

procedures.ABC has developed a comprehensive Contractor Accountability to Safety Program (CASP) for all contracted workers, including prime contractors, general contractors, sub-contractors, service contractors and consultants. The CASP clearly defines and communicates the responsibilities of all workplace parties involved in its development, administration and implementation. Contractor occupational health and safety performance is a critical factor in the awarding and renewal of ABC contracts.

The Contractor Accountability to Safety Program includes:

• Roles and Responsibility

• Contractor Occupational Health & Safety Requirements

• Contract Requirements

• Orientation

• Hazard Assessment

• Inspections

• Incident/Accident Reporting

• Performance Review

• Documentation

• Program Review

• References and Additional Resources

• Definitions

• Appendix

1.0 Roles and Responsibility

Environment, Health and safety is a resource to assist and facilitate the contractor accountability to safety process.

The three types of contractors include prime contractors, general contractors (including service contractors and consultants), and sub-contractors. The Alberta Occupational Health & Safety Act, Regulation and Code and ABC policies and procedures dictate specific requirements for all contracted workers to follow.

CONTRACTOR

ACCOUNTIBILITY TO SAFETY

PROGRAM (CASP)

1.1 Environment, Health and Safety

• Supports and coordinates the Contractor Accountability to Safety Program.

• Coordinates and assists ABC Contacts supervising contractors to resolve health and safety

issues effectively and efficiently;

• Immediately communicates all health and safety concerns to the appropriate site supervisor or

contractor. If required, EH&S has the authority to stop work if conditions or concerns are

“Immediately Dangerous to Life or Health”.

1.2 Prime Contractor

The Prime Contractor must comply with the Alberta Occupational Act, Regulation and Code, specifically Section 3 of the Act, and all applicable ABC policies and procedures.

1.2.1 ABC as Prime Contractor

ABC, as the owner of the worksite, is assigned the role as the prime contractor. As

the prime contractor, this role is assigned to an employer representative known as the ABC Contact.The ABC contact is a university employee who is the primary contact for the contractors conducting work at ABC. ABC Contacts are employer representatives of ABC. In situations where ABC acts as the prime contractor, ABC Contact has the following responsibilities:

• Performs periodic documented project work site inspections under their authority and control to

ensure that environmental, health and safety requirements are adhered to;

• Communicates inspection findings that affect the health and safety of any student, staff, worker,

contractor or visitor through written and/or verbal correspondence to the appropriate authority;

• Communicates to the contractor their health and safety responsibilities and performance

accountability to those identified responsibilities;

• Collaborates with contractors on identified or reported concerns and mediates to resolve issues

effectively and efficiently;

• Adheres to environment, health and safety rules and regulations;

• Completes the Area Work Permit/Posting and posts it at each entrance of the worksite – Note: a

copy must be sent to EH&S;

• Reports all incidents / injuries to EH&S;

• Immediately communicates all health and safety concerns to the appropriate site supervisor or

contractor. If required, ABC has the authority to stop work if conditions or concerns are “Immediately Dangerous to Life or Health”.

See Appendix 13.1 - Area Work Permit/Posting Procedure

See Appendix 13.2 - Area Work Permit/Posting Form

1.2.1 Assignment of Prime Contractor Status

ABC, as the owner of the worksite, may assign prime contractor designation and

associated responsibilities to a contractor by written contractual agreement with the contractor.

Assignment of prime contractor status does not absolve ABC of responsibilities, as the

ABC Contact remains an integral part of the contractor accountability to safety process.

The University may assign a specific worksite to a contractor and transfer, by agreement, the health & safety responsibilities to that contractor as Prime. This smaller work site must be clearly defined. Vehicle and foot traffic between the contractor’s worksite and ABC must be controlled by a physical barrier and can be treated as a separate “worksite within a worksite”.

In situations where ABC assigns Prime Contractor designation to a

contractor, the ABC Contact has the following responsibilities:

• Audits prime contractor’s Safety Management System on a regular basis - for example ensures

that hazard assessments are completed, ensures inspections are conducted, safety meetings are

held, orientations are conducted and incidents are investigated`;

• Collaborates with the prime contractor on identified or reported concerns to resolve issues

effectively and efficiently;

1.3 General Contractor

General contractors, including system contractors, service contractors, and consultants, must comply with the Alberta Occupational Act, Regulation and Code, and all applicable ABC policies and procedures.

1.4 Sub - Contractor

Any sub-contractor hired by a general contractor or contractor must comply with the Alberta Occupational Act, Regulation and Code, and applicable ABC policies and procedures.

2.0 Contractor Basic Occupational Health and Safety Requirements

• Ensure first aid services, equipment, and supplies required by the Alberta Occupational Health & Safety Code Schedule 2 are available at the work site;

• Take all necessary steps to protect all workers and third parties from injury or illness;

• All equipment provided by the contractor must be maintained in safe working order as per the manufacturer’s specifications;

• All work procedures must meet or exceed applicable legislation, industry best practices and ABC standards;

• Must provide competent supervision at the work site;

• Only qualified workers, or workers working under the direct supervision of another competent worker, are permitted to conduct work activities at ABC;

• All workers have the right to refuse unsafe work;

• Must ensure all necessary personal protective equipment is worn and maintained in good condition;

• Must investigate and resolve identified health and safety issues and concerns within their worksite as soon as reasonably possible. Copies of these reports must be forwarded to the appropriate ABC contact who must contact Environment Health and Safety (EH&S) within 24 hours of notification;

• Implement their company’s disciplinary policy for any worker who does not comply with health and safety requirements;

• Must inform the workers of the hazards and the control measures that are in place by way of a written hazard assessment.

The form must be available at the worksite for all workers;

• Must complete regularly scheduled inspections.

The written inspection must be readily available upon request;

• Must have a written emergency response plan in place.

• Must ensure all incidents/accidents are investigated and subsequent recommendations implemented.

• Ensure all staff receives adequate orientation.

3.0 Contract Requirements

3.1 Pre - Qualification – General

ABC uses a pre-qualification process as a screening method for preferred contractors to verify

that a health and safety management system in place. These general pre-qualifications are for both General Contractors and Prime Contractors.

• Good performance standing with ABC.

• Certificate of Recognition (COR), Small Employer Certificate of Recognition (SECOR) or an

active health and safety manual accompanied with a Letter of Intent to obtain a COR or

SECOR.

• Proof of an account in good standing with WCB including the company’s experience rating

assessment. This written document must be current (within 30 days of application).

3.2 Pre - Qualification – Specific

The contract bid must include a list of all specialized trades needed to complete the project or fulfill the contract requirements. This list must include in detail the education and training, both trade specific (i.e. trade ticket or journeyman certification) as well as all applicable and current safety training of the workers designated under the contract (i.e. first aid).

3.3 Verification

All applicable stakeholders, including Materials Management, Campus Infrastructure, EH&S or other departments, must review, evaluate and document all of the required documentation to verify that the contract requirements can be met by the contractor.

4.0 Orientation

Orientation is designed to inform workers of ABC policies, procedures, and identify potential

hazards. All contracted workers (General and Sub – Contractors) who perform work or intend to perform work on ABC owned or leased facilities must attend the General ABC Orientation offered by EH&S (CASP Orientation). Only those workers who have completed the orientation will receive ABC Identification badges and be authorized to work at ABC premises. The contracted workers must attend an additional orientation if roof access and/or tunnel access is

required. The ABC Contact can facilitate registration for these orientations. Prime Contractors must conduct their own orientation designed to inform workers of their company’s

policies, procedures and identify potential hazards and may have their employees attend the General ABC Orientation offered by EH&S or work with EH&S to include relevant sections of the General ABC Orientation into their orientation.

In situations where ABC acts as Prime Contractor, the ABC Contact is responsible to

ensure that a site specific orientation is conducted. This orientation should include, but is not limited to:

• Occupational Health and Safety Requirements

• Emergency Response

• Worksite Specific Hazard Assessment

• Reporting Requirements

• Notification Requirements

• Security Requirements

• Personal Protective Equipment (PPE) Requirements

• Worksite tour

See Appendix 13.3 - CASP Orientation Training Registration Process

4.1 Authorization and Identification

ABC will issue all contracted workers General and Sub –

contractors) an ABC photo identification card after they have attended the CASP

Orientation. These photo identification cards are used to identify and authorize the appropriate

contractors and workers access while on ABC property to conduct work. Keys / cards for access to aproject site will be issued as applicable and by the ABC Contact.

See Appendix 13.4 - CASP Photo Identification Request Form

5.0 Hazard Assessment

In circumstances where ABC has Prime Contractor responsibility a Hazard Assessment must be

performed by the ABC Contact and EH&S (as required) through an assessment of the work site to identify existing and potential hazards that may affect the safety of employees, staff, the operation, the public or the environment. The hazard assessment must be performed prior to any work beginning at the work site.

Where ABC assigns Prime Contractor designation to a contractor, the contractor must

conduct a hazard assessment prior to any work beginning at the work site. The ABC Contact and EH&S has the following responsibilities when Prime Contractor responsibility is assigned:

• Audits the Prime Contractor’s Hazard Assessments on a regular basis.

Hazards Assessments are to be reviewed and/or updated:

• at reasonable practicable intervals to prevent the development of unsafe and unhealthy

working conditions

• when a new work process is introduced within the worksite;

• when a work process or operation changes.

Hazard Assessments must be readily available to ensure all workers affected by the hazards are

informed of the hazards and the methods used to control or eliminate the hazards.

See Appendix 13.5 – Hazard Assessment Form

6.0 Inspections

All contractors are required to perform regular worksite inspections. The written inspection form should document any necessary actions to be taken, who is responsible for their completion and projected timelines for any identified unsafe condition and/or work practice. The inspection process should include follow-up for correction of any previously identified deficiencies. The contractor is required to ensure due diligence that the corrective actions were completed in a timely manner. These reports must be available

for review upon request.

In circumstances where ABC has Prime Contractor responsibility, inspections are required to be

conducted by the ABC Contact with the contractor and EH&S (as required). When a

recommendation is made to correct an unsafe act or condition, written documentation and follow up must be completed to verify the correction. This information should be recorded in the appropriate files under performance.

7.0 Incident / Accident Reporting

ABC requires the reporting of all incidents, which includes a sudden or unforeseen

event while conducting work authorized by ABC that could cause or has caused:

• An injury or illness;

• An unplanned release to the environment; or

• Contravention of a regulatory requirement.

ABC contractors must immediately report all incidents to their supervisor, ABC

contact or next higher authority as available. Supervisors and ABC representatives are responsible for the classification of the incident, completing the reporting and other actions as listed below. Incidents / accidents occurring when ABC is prime contractor must be internally

reported.

In situations where Prime Contractor has been assigned, the contractor must report to ABC

Contact all level 2 and 3 incidents and provide copies of the incident investigations following their own internal reporting system.

Level 1 Incidents

Level 1 incidents are characterized by confinement to ABC property, no immediate threat to workers, the public or contractors, minimal environment impacts, or on-scene

personnel can handle incident.

Level 2 Incidents

Level 2 incidents are characterized by effects extending beyond ABC property,

potential impacts to workers, the public or contractors, regulatory reportable environment

impacts, or on-scene personnel can likely handle incident but additional support may be required.

Level 3 Incidents

Level 3 incidents are characterized by uncontrolled effects extending beyond ABC property,serious injury to workers, the public or contractors, civil authorities or

regulatory agencies involved with response, or continuing environment impacts.

8.0 Performance Review

A contractor performance review will be conducted, as needed, by the appropriate stakeholders.The contractor performance review may include:

• Review of contract requirements

• Review of hazard assessments

• Review of inspections

• Review of tool box meeting minutes

• Review of building inspection reports

• Review of reported unsafe acts or unsafe conditions present while on University property and

if corrective actions were made in a timely manner

9.0 Documentation

Environment, Health and Safety will retain the current copy of the CASP and the list of contractors who have attended the CASP Orientation training.

Materials Management will maintain a list of preferred contractors who have completed the requirements as outlined under the CASP. ABC Infrastructure will retain copies of Hazard Assessments and Area Work Permits/Postings and inspection reports

10.0 Program Review

The goal of program review is to continuously improve the Contactor Accountability to Safety Program. Environment, Health and Safety will coordinate the CASP review annually or as required. The evaluation must include a review of the written program.

11.0 Definitions

ABC Contact – Is an ABC employee who is the primary contact for the contractors conducting

work at ABC. ABC Contacts are employer representatives of ABC.

Competent Worker An individual, who is adequately qualified, suitably trained and has sufficient experience to safely perform work without supervision or with a minimal degree of supervision.

Consultant - A contractor that is hired to be an advisor, resource and/or complete tasks specific to their field of expertise that are on campus to perform work.

Contractor A person or group of people that have been awarded a contract to perform work on ABC`s owned or leased property.

Letter of Intent – A written document stating the contractor is committed to acquiring a mandatory Certificate of Recognition (COR) or Small Employer Certificate of Recognition (SECOR) and a copy of the certificate be provided to ABC within one year of application.

Owner ABC Company Ltd.

Project Any work requested by a department that is coordinated by ABC Infrastructure or other

ABC Contact.

Prime Contractor The prime contractor for the worksite is ABC, unless this

designation has been given to a contractor by ABC in a written agreement.

System or Service Contractor A person or group of people who provide ongoing services to ABC and are on campus to perform work. Services may be on departmental equipment (i.e.

photocopiers).

Supplier A contractor that is in transit and is only on ABC property for the duration of the delivery of goods.

Page 8 of 15

NOTIFICATION & POSTING REQUIREMENTS:

• The ABC Contact of each construction project or maintenance work shall ensure that all safety requirements outlined on the ABC Area Work Permit/Posting Requirements are followed.

• The ABC Contact of each construction project or maintenance work is responsible to complete the “Area Work Permit/Posting”

• The ABC Contact must email, fax or send a completed copy of the “ABC Area

Work Permit/Posting” form to Environment, Health & Safety (EH&S) via e-mail:

assigned to the construction project or maintenance work at least two working days prior to the work starting.

• Environment, Health & Safety (EH&S) will provide a hardcopy of the completed ABC

Area Work Permit/Posting” to ABC Security and keep a copy of the Area Work Permit/Posting on file in the Environment, Health & Safety’s Office.

• Environment, Health & Safety or the University Contact within ABC`s prime worksite may inspect any contractor project or maintenance work. Environment, Health & Safety has the authority to stop any unsafe work and will not permit work to begin or continue unless compliance with the Alberta Occupational Health & Safety Act, Regulations and Code and ABC requirements have been demonstrated.

Contractors must fully understand their Occupational Health & Safety responsibilities to be in compliance with Alberta Occupational Health and Safety legislation and ABC

Standards.

CHECKLIST FOR ALL AUTHORIZED CONTRACTORS PERFORMING WORK:

All contractors on site have participated in the ABC Orientation by EH&S.

All contractor generated waste must be disposed of by the contractor in accordance with the ABC guidelines.

All workers have visible/readily available ABC ID.

Written hazard assessment and written standard work procedures are available on site.

Hot Works Permit and Procedures are understood and followed as needed.

Workers are aware of hazards and control measures in place.

Contractor tools and equipment are in proper working order.

First Aid kit and trained First Aider must be available onsite.

Only authorized contractor workers will be within the worksite area. Note: ABC workers who must work in the worksite to perform their regular duties are defined as “authorized”.

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