DEPARTMENTAL PROCEDURE

Transcription

1 Title: Contractor Safety Procedure Rev: 9 Page 1 of 14 Approvals: Don Buckman 9/11/2007 Sergio Macieira 9/11/2007 Title: EH&S Manager Date TitIe: EH&S Coordinator Date 1. PURPOSE 1.1. Kidde Aerospace recognizes that the safety of its Contractors and Vendors is paramount to achieving world class safety. Because of a commitment to provide a safe and healthful work place, and to comply with OSHA safety standards, the Contractor EHS Program described hereafter, is implemented as Company Policy. Kidde Aerospace & Defense will meet all Federal, state, and local requirements associated with Contractor activity by creating and maintaining a management system ensuring all contract work is performed with the safety, health, and environment a priority. 2. SCOPE 2.1. This procedure applies to contractors performing work or services at the Kidde Aerospace & Defense. All contractors including out-source services that are located on site are required to comply to the requirements set forth in SP010 United Technologies Corporation Contractor Environmental Health and Safety Program Contractor Project Coordinators, working with purchasing, need to consider, select, and conduct business with only those contractors who can demonstrate the same degree of concern for safety and the environment as Kidde Aerospace & Defense and are able to comply with environmental, occupational health, and safety laws, standards, policies and practices. 3. DEFINITIONS 3.1. Contractor: Owner and/or employee of any business providing a service to Kidde authorized by Purchase Order or Legal Agreement. Examples include, but are not limited to: construction trades, industrial cleaners, environmental remediation services, asbestos abatement, maintenance and engineering trades. Standard delivery services (FedEx, UPS, etc.) are not included Contractor Coordinator: The Kidde employee ultimately responsible for a contractor s and/or sub-contractor s presence on site Contractor Levels per SP010/HS EH&S Instruction 022: NOTE: Contractors and sub-contractors will be assessed for environmental, health and safety (EHS) past performance for entry onto the approved contractor list. Approval will be valid for three years from the date of approval unless unacceptable performance is unresolved. Level III contractors will be reviewed annually. Contractors that do not provide their information and subcontractor information shall not be allowed to bid or work at Kidde Aerospace & Defense, Wilson Low Risk (Level I): Contractor Work includes installation, maintenance, or service work in office environments limited to the use of small hand tools. In shop operations, Low Risk Contractor Work applies where vendors/contractors go into

2 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 2 of 14 manufacturing or facility services or test areas to gather information, i.e. observe operations. Low risk contractor work also includes temporary office help, copier/computer maintenance and personnel delivering non-hazardous chemicals. Low risk contractors must be informed of the site s basic EH&S awareness requirements including emergency evacuation alarms and actions, smoking rules, and rules regarding personal protective equipment, proper chemical/ waste disposal and hazardous materials in use in the areas they will enter Intermediate Risk (Level II): Contractor Work refers to minor repair and replacement activities using hand tools or powered hand tools or where the equipment in use has no power source except electricity and the electricity can be isolated by unplugging and locking out the plug. Typically this classification would apply to calibration; maintenance or repair operations done by one person on a Hamilton Sundstrand owned piece of equipment. Chemical usage would be limited to one small immediate use container, i.e. 5-gallon maximum per contractor employee. Intermediate risk contractors must be informed of the site s basic EH&S awareness requirements and site rules regarding electrical safety, lock-out/tag-out (LOTO) of energy sources, use of powered tools, etc. The contractor must consult with Facilities Engineering or other group responsible for the site LOTO program to ensure that appropriate notifications have been made and they are in compliance with the site s LOTO program High Risk (Level III): Contractor Work includes all construction work, and any other work that includes a high risk factor listed below. High risk factors in maintenance, repair and construction activities include, but are not limited to: tasks involving two or more trade groups working simultaneously on the project or task lockout/tagout of equipment not included in the lockout/tagout inventory (i.e. the first time energy sources are identified and added to the LOTO program), or that involve lockout of more than 3 energy sources tasks requiring the use of fall protection, i.e., work at an elevation greater than six feet above the ground/floor level (does not apply to a single contractor using a single ladder) tasks involving overhead work requiring scaffolding and/or multiple extension ladders in close proximity tasks requiring entry into a confined space or work in a hazardous atmosphere tasks involving work on pressurized equipment while the equipment is pressurized tasks involving work on equipment while elevated or reduced temperatures are being maintained tasks that could result in an uncontrollable chemical release or other environmental incident tasks with special waste collection requirements or application activities requiring a permit or license

3 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 3 of 14 tasks involving the handling of carcinogens, hazardous metals, asbestos or polychlorinated biphenyls (All asbestos abatement projects are considered high risk contractor work) tasks involving specialized rigging equipment and/or rigging expertise tasks involving the use of self-contained breathing apparatus, e.g. breathing air bottles, masks, regulators tasks involving demolition work and activities tasks which may include or create an unprotected floor opening, open side to a building or open hatchway tasks involving excavations tasks involving the use of more than five gallons of hazardous chemicals tasks which include any environmental remediation/clean-up project Note: Construction work refers to those activities involved in building a structure or permanent attachment, demolishing a structure or permanent attachment, and/or modification of a structure or permanent attachment. For level III high risk work, contractor site supervision shall also complete external training by a recognized expert that meets local, regional, provincial standards (e.g. OSHA 500 training for US sites; or State OSHA equivalent). Level III/High Risk Work (Construction): Contractor site supervision shall also complete external training by a recognized expert in Construction Safety that meets local, regional standards. (e.g. OSHA 510 training for US sites; or State OSHA equivalent). HS Contractor Coordinators overseeing Level III/High Risk Work (Construction) shall also complete external training by a recognized expert in Construction Safety that meets local, regional, provincial standards (e.g. OSHA 510 training for US sites; or State OSHA equivalent). Where contractor employees are not able to take HS contractor EH&S on-line training, contractor/project coordinators shall instruct each contractor and subcontractor in the content of the HS Contractor Guidebook, in recognition and avoidance of unsafe conditions, and of the regulations applicable to the work environment to control or eliminate any hazards or exposure to illness or injury Contractor Review Board (CRB): A board with representation from Facility EH&S Oversight Committee, Purchasing, Site EH&S, Division EH&S Representatives charged with reviewing contractor compliance with the Kidde Contractor EH&S Guide Contractor Safety Rating: A contractor s lost time injury rate, lost time severity rate, total recordable rate as defined by OSHA, and experience modification rate Serious EH&S Violation: Contractor work practices contrary to the Kidde Contractor EH&S Guide resulting in a serious near miss, reportable spill, serious injury, fatality, or any combination of these Serious Injury:

4 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 4 of any job-related incident which results in hospital treatment or admission of three or more employees; or any job-related incident which results in prolonged loss of consciousness; paralysis; fractures to multiple limbs, the head or back; multiple fractures of the same limb; or an injury that results in cardiac or pulmonary arrest; or an injury that results in a loss of a major body part or function; or any serious near miss that could have resulted in loss of life; or any incident that results in a fatality Subcontractor: Owner and/or employee of any business providing services and/or materials to a contractor that is under a Kidde contract or legal agreement on Kidde property Contractor Owned Bulk Tanks: Tanks used to store large quantities of bulk liquid/gas materials such as Liquid Nitrogen, Argon, Liquid Oxygen, etc., that are owned and maintained by the gas supply contractor (e.g. National Welders, Airgas, Praxair, etc.) but are operated on an HS site. 4. POLICIES 4.1. Contractors will not be permitted to perform work on site until they have been approved by the EHS department. Kidde will not approve contractors based solely on low cost service, but will consider their past EHS performance during the contractor approval process All Level II and Level III contractors must complete the appropriate level of contractor EHS training using the UTC/HS On-Line Contractor EHS Training. This training must be completed by each contractor employee prior to performing work on site. A printed copy of the contractor training completion certificate must be provided to the contractor coordinator prior to the start of work. The contractor coordinator must verify training completion of the contractor employees prior to the start of work. Records of contractor training completion will be maintained in the contractor file located in the EHS department Contractor coordinators must complete a pre-work EHS risk assessment with the supervisor of the contractors and sub contractors, and/or the contractor and sub contractor employees using form EHSDP KAD Pre-Work EHS Checklist prior to the start of work by the contractor or sub contractor. EHS will assist the contractor coordinator with the pre-work EHS risk assessment when technical input is requested by the contractor coordinator Contractor coordinators must complete and post a copy of form EHSDP Project Sign Posting at or near the Level II or Level II contractor work area or in a conspicuous location adjacent to where the Level II or Level II contractor work is being performed Contractor coordinators must complete form EHSDP Permit for Use of Internal Combustion Engines and receive required approvals for all Internal Combustion Engine (ICE) usage on site by contractors prior to the use of the ICE Contractor coordinators must complete form EHSDP Overhead Work Permit for all planned contractor overhead work and receive required approvals prior to the

5 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 5 of 14 commencement of contractor overhead work Contractor coordinators will complete an inspection once a month, more if deemed necessary by contractor coordinator, of in process contractor work and document the results of the inspection using form EHSDP KAD Contractor Area Inspection Form. To meet this requirement, it is highly recommended that each contractor coordinator perform this inspection for their first contractor of each month that is performing in process work. Contractor coordinators will maintain copies of the completed KAD Contractor Area Inspection Form in the contractor file located in the EHS department. The form can be turned in with the other required for on-site contractor work Contractor coordinators will complete a pre-lift assessment for any crane lifts with the contractor crane operator prior to any crane lift taking place on site. This pre-lift assessment must be documented using EHSDP Crane Operation Pre-Lift Checklist and be signed by the contractor coordinator and the crane operator prior to the lift. The completed Crane Operation Pre-Lift Checklist will be retained by the contractor coordinator in the contractor file located in the EHS department. 5. ASSOCIATED DOCUMENTS 2009 Kidde Contractor EHS Guidebook Disciplinary Action for Contractor EH&S Violations EHSDP KAD Project Sign Posting EHSDP KAD Contractor EHS Assessment EHSDP KAD Overhead Work Permit EHSDP KAD Permit for Use of Internal Combustion Engines EHSDP KAD Pre-Work EHS Checklist 022 HS Contractor EHS Program EHSDP KAD Contractor Area Inspection Form EHSDP List of Approved Emergency Use Contractors EHSDP KAD Contractor EHS Guidebook Review Form EHSDP Crane Operation Pre-Lift Checklist EHSDP Contractor Program Audit Form EHSDP Approval To Purge Flammable Gas Permit UTC SP-010 Contractor Safety 6. PROCEDURE 6.1. Contractor and Contractor Coordinator Training Facilities Manager At a minimum, conduct contractor coordinator training initially and whenever the Kidde Contractor EHS Guidebook is revised. Contractor Coordinators Maintain copies of all sign in sheets for contractor coordinator training for a minimum of five years. Provide copies of contractor coordinator training completion records to EHS department. Complete the internal on-line contractor safety training annually.

6 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 6 of 14 Ensure each contractor employee who will work onsite has completed the required on-line training prior to arriving on site. Ensure contractor employees complete the contractor training annually. Retain copies of completed Contractor on-line training completions in the contractor file located in the EHS department. EHS Department Develop and maintain the KAD Contractor EHS Guidebook. Inform purchasing and Contractor Project Coordinators of all changes to this work instruction and KAD Contractor EHS Guidebook to be incorporated into the appropriate training package as necessary Contractor EHS Assessment and Approval Contractor Coordinator Ensure that all contractors have been approved by EHS prior to brining the contractor on site to perform work. Work with the contractor to provide all necessary information and completed forms related to the contractor approval process to the EHS department to facilitate contractor approval. Ensure that contractors submit an approval request every three years at a minimum. EHS Department Review KAD Contractor EHS Assessments, review compliance history of contractor requesting approval, review X-mod ratio of contractors requesting approval, and determine if contractor has sufficient attention to EHS to safely perform work on-site prior to providing approval for contractor Emergency Approval of Contractors Maintain the approved contractor list by inputting the contractor approval information into the UTC database as required. Reassess contractors for approval every three years as requested by the contractor coordinator and/or contractor. Affected Departments Where possible, Affected Departments (i.e., Maintenance, Facilities, EH&S, etc.) shall conduct a pre-certification of contractors that would likely be called in an emergency. This list shall be included in the operation emergency response plan, where applicable. If the contractor in question is not pre-certified, the affected Project Coordinator must collect information concerning the contractor s EH&S programs and performance from the contractor at the time of the emergency or soon thereafter.

7 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 7 of 14 Kidde Project Coordinator(s) from Affected Departments shall provide the contractor with information needed to complete the emergency work without risk to company or contractor employees, or harm to the surrounding environment Pre-Work EHS Hazard/Risk Assessment Contractor Coordinator Follow KAD Pre-Work EHS Checklist to conduct a pre work assessment with the contractor supervisor and the contractor s EH&S designee prior to beginning work on the project. Conduct a reassessment KAD Pre-Work EHS Checklist if the scope of work or the specification of how to perform the work is changed. Maintain copies of the completed pre-work assessments as part of the project file records (alternatively, these records may be kept in the Contractor File located in the EHS department). Review the applicable sections of the Contractor EHS Guidebook with the contractor during the pre-work EHS assessment. Ensure the contractor has completed a review of the Kidde Contractor EHS Guidebook with all contractor employees who will work on the KAD site by collecting a completed KAD Contractor EHS Guidebook Review Form from the contractor prior to the start of work. Ensure that all required EHS permits and forms are completed and approved as required, prior to commencing work on the project. Maintain copies of all completed and approved EHS permits and forms as part of the project file records (alternatively, these records may be kept in the Contractor File located in the EHS department). EHS Department Provide support to the Contractor Coordinator during the Pre-Work EHS Assessment when requested Contractor Work Area Inspections Review and approve required EHS permits and forms as appropriate. Contractor Coordinator Conduct periodic inspections of contractors under your direction at least once per month using EHSDP KAD Contractor Area Inspection Form to periodically review contractor performance. Maintain inspection results (completed forms) as part of the project file records (alternatively, these records may be kept in the Contractor File located in the EHS department). Communicate the inspection results to the contractor and site EH&S Manager.

8 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 8 of 14 Follow Appendix 1 Disciplinary Action for Contractor EH&S Violations as necessary. Share the inspection results with the Contractor Review Board (CRB) as requested. EHS Department Conduct unannounced inspections of contractors at least quarterly and document these inspections using EHSDP KAD Contractor Area Inspection Form. Contractor Coordinator 6.6. Contractor Incident Investigations Contractors and Contractor Employees Contractor Coordinator Maintain inspection results in the Contractor File located in the EHS department. Forward the results of the unannounced inspections to the Contractor Coordinator. Communicate the results of the unannounced EHS inspections with the contractor. Follow Appendix 1 Disciplinary Action for Contractor EH&S Violations as necessary. Contractors are expected to immediately report any incidents or near misses to the contractor coordinator and begin an incident investigation. Assist the contractor with the incident/near miss investigation and document the incident and the investigation as required by EHSDP0104 Incident Investigation Procedure Report the contractor incident to the EHS Department immediately upon becoming aware of the incident. Present the contractor incident/near miss to the Contractor Review Board (CRB) upon the completion of the investigation. EHS Department Convene the Contractor Review Board (CRB) when notified of a contractor incident/near miss Contractor Review Board (CRB) Activities Assist the contractor coordinator in the root cause/corrective action development for the contractor incident. Contractor Review Board Meet as required to review contractor incidents and/or other contractor program performance issues related to EHS, including the performance of the contractor coordinator. Review inspection findings provided by the contractor coordinator for a contractor whenever the CRB convenes to help assess the Contractor s EH&S performance.

9 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 9 of 14 Meet with the affected parties (including the contractor employees or representative if necessary) to determine if a violation has occurred, as outlined in the KAD Contractor EHS Guidebook or any applicable environmental, health, and safety standards or policies. Follow Appendix 1 Disciplinary Action for Contractor EH&S Violations. Take action as necessary for repeat violations found during inspections following Appendix 1 Disciplinary Action for Contractor EH&S Violations. Review results of periodic EHS oversight audits of the contractor program and contractor coordinator activities as presented by EHS and determine what action, if any, should be taken in accordance with Appendix 2 Disciplinary Action for Contractor Project Coordinators Appendix 2. Establish corrective action plans to re-certify a contractor coordinator who has been de-certified due to disciplinary action. Review progress of contractor coordinators that are placed into disciplinary action to determine when and if they can be recertified to resume full project coordination duties Contractor Program Audits EHS Department Conduct periodic audits (at least annually) of the contractor program. The audit will review the use of the pre-work assessments, permit completion, inspections performed by contractor coordinators and EHS, and contractor coordinator requirements to determine the effectiveness of the contractor program Contractor Owned Bulk Storage Tanks Document contractor program audits using EHSDP Contractor Program Audit Form. Retain completed contractor program audits for three years. Present results of periodic audits of the contractor program and contractor coordinator activities to the CRB when issues affecting the quality of the contractor safety program are identified. EHS Department Review all contractor owned bulk tanks that are located on site to determine applicability to the Functional Hazard Risk Assessment (FHRA) program pursuant to EH&S Instruction 024. If a tank is found to have program applicability, an FHRA must be conducted in conjunction with appropriate contractor personnel, as required by EH&S Instruction 024.

10 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 10 of 14 Coordinate scheduling of any FHRA applicable contractor owned bulk storage tanks into the HS FHRA schedule with the HS EHS Regional Leader.

11 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 11 of REVISION HISTORY

12 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 12 of 14 Revision # Description of Change Date Author 1 Modified Contractor Safety Procedure to reference greater detail in Program document 2 Added expectations for Emergency Approval of Contractors 9/12/07 Buckman 11/15/07 Buckman 3 Added EH&S Inspection requirements 12/5/07 Buckman 4 Added Contractor Project Coordinator audit and discipline system (Appendix 2) 5 Added note under Contractor levels Definitions regarding frequency of Contractor Pre- Qualification Assessments Per EH&S Assurance Review Observation. 6 Modified actions and updated procedure links. Added EHSDP KAD Contractor EHS Guidebook Review Form 7 Added requirements for FHRA applicability review as required in HS EHS WI 022 Rev. 1; Added sections 3.9 and Added reference to EHSDP Approval to Purge Flammable Gas Permit 9 Added section 4 Policies to clarify the use of the contractor and other EHS program forms; reformatted the procedure for clarity; Added audit requirement and EHSDP Contractor Program Audit Form 10 Revised section 4.7 regarding Contractor Area Inspection requirements 5/30/08 Carlson 11/13/08 Buckman 3/2/09 Carlson 12/16/09 Carlson 3/1/2010 Carlson 11/7/2011 Carlson 7/15/2015 Henchel

13 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 13 of 14 APPENDIX 1 Disciplinary Actions for Contractor EHS Violations VIOLATION DISCIPLINARY ACTION Failure to follow Contractor EH&S Guidelines Violation of Contractor EH&S Guidelines which results in: - A Reportable Spill 2 - A Serious Injury or Fatality 3 - A Serious Near Miss 1 st Violation 1 2 nd Violation 1 3 rd Violation 1 4 th Violation 1 1 st Violation 1 2 nd Violation 1 3 rd Violation 1 Deficiency noted on inspection form; verbal warning to contractor lead person; copy of inspection form to contractor and Purchasing. Letter sent to contractor from HS Contractor Coordinator; copy to Purchasing. Letter sent to contractor from responsible Purchasing contact; contractor required to meet with HS representatives to discuss improvement plan implementation. (Purchasing should initiate the process of obtaining an alternate contractor.) Contractor banned from site until EH&S program deficiencies are corrected. Purchasing shall initiate appropriate action. Individual contractor employee(s) banned from HS site; letter to contractor issued by Purchasing outlining violation and requiring written response from contractor describing corrective action implemented. (Purchasing initiates search for alternate.) Contractor banned for 1 year by Purchasing. Reinstatement only after demonstrating significant improvement in EH&S program. Contractor permanently banned. Purchasing shall initiate. 1. Violations are recorded over a rolling twelve (12) month period. 2. Contractor will be required to pay for all costs associated with spill cleanup. 3. Serious Injury: Any job-related incident which results in hospital treatment or admission of three or more employees; or any job-related incident which results in prolonged loss of consciousness; paralysis; fractures to multiple limbs, the head or back; multiple fractures of the same limb; an injury that results in cardiac or pulmonary arrest; an injury that results in a loss of a major body part or function; or any serious near miss that could have resulted in loss of life.

14 Title: Contractor Safety Procedure Rev: 9 DRAFT Page 14 of 14 APPENDIX 2 Disciplinary Actions for Contractor Project Coordinators Contractor Project Coordinator Violation Inadequate pre-work assessment, failure to review pre-work assessment with contractor prior to the start of work, ineffective or absent contractor oversight during project. (Level 2 contractor task) Inadequate pre-work assessment, failure to review pre-work assessment with contractor prior to the start of work, ineffective or absent contractor oversight during project. (Level 3 contractor task) Disciplinary Action 1st Violation* - Project Coordinator re-instructed by EHS or CRB representative. 2nd Violation* - Project Coordinator to re-take Project Coordinator Training. - Next three pre-work assessments will be conducted with another Project Coordinator or EHS participating in assessment. 3rd Violation - Project Coordinator de-certified from performing Project Coordinator responsibilities. - Project Coordinator can only be re-instated by completion of corrective action plan determined by CRB. 1st Violation* - Project Coordinator to re-take Project Coordinator Training. - Next three pre-work assessments will be conducted with another Project Coordinator or EHS participating in assessment. 2nd Violation* - Project Coordinator de-certified from performing Project Coordinator responsibilities. - Project Coordinator can only be re-instated by completion of corrective action plan determined by CRB. * Violations are recorded over a rolling twelve (12) month period. Depending on seriousness of the violation (e.g. failure to identify controls for elevated work, electrical safety, LOTO, etc.) the CRB may skip violation occurrence levels for discipline purposes.