McIntosh Contractor Safety Oversight. Site Function: Safety Procedure No.: MC Page: 1 of 17
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1 Title: McIntosh Contractor Safety Oversight Site Function: Safety Procedure No.: MC Page: 1 of 17 McIntosh Site Preparer: B. Turner Owner: M. Khan Approver: J. Slinkard EHS Specialist EHS Team Leader Site Manager 1. Purpose To establish minimum Environmental, Health and Safety (EHS) requirements for the qualification and oversight of Contractors and Contingent Staff employees as part of the BASF McIntosh site s Responsible Care Management System. 2. Definitions 2.1 BASF Contact Sometimes referred to as a process owner, requisitioner or job representative, is a BASF employee who identifies scope of work and requests contracted services. 2.2 Background Checks A background check of all contractors and temporary workers who will be working at the BASF McIntosh Site is required. This check shall meet the requirements of BASF Corporate Procedure BC Background Checks Contractors and Temporary Workers. 2.3 Being Entirely Safety Today (BEST) Cards BASF s preferred version of pre-task planning (PTP) card. 2.4 Contractor Coordinator An individual who is responsible for monitoring activities of a contractor while on-site performing work. This person, along with Procurement and Environment, Health and Safety (EHS) personnel, will monitor the performance of the contractors from a safety perspective via the AVETTA service. 2.5 Competent Person An individual, by way of training and/or experience; is knowledgeable of applicable standards and guidelines is capable of identifying existing and predictable hazards in the surroundings or working conditions which are hazardous to employees, is designated by the employer, and has the authority to take appropriate actions. 2.6 Contingent Staff Employees Contingent staff are individual non-basf employee workers for whom BASF provides direct supervision on their day-to-day activities and direction on how an activity is to be performed. Often referred to as contract, leased or temporary employees. See MC Contractor
2 Procedure No.: MC Page: 2 of 17 A company which will be either placing or bringing Contractor(s) or Contractor Employee(s) onto a BASF site covered under this procedure. 2.8 Contractor Employee An individual engaged by or through a third party to perform services principally for the third party. 2.9 Contractor Safety Concept A written plan for major projects, e.g., turnarounds, shutdowns, plant expansion projects, etc Contractor Safety Contact The safety professional responsible for Contractor safety oversight of the working contractor company Delivery Personnel Persons providing delivery of goods and materials such as: postal service, truck trailer deliveries, office supplies, drinking water, vending machine supplies, uniform laundry, production materials and equipment, etc Job Observation program Process of conducting field reviews of Contractor Employees, by all levels of management, as well as, members of each craft or group/company located on the site, to ensure the Contractor/Agency is performing to BASF expectations to reduce/eliminate injuries, illnesses and incidents as per the Contractor Journey To Excellence (CJTE) Program Management Service Provider (MSP) An MSP is a third party company that facilitates selection, on-boarding, oversight and off-boarding processes for BASF Contingent Staff National Contractor A Contractor that has geographic presence and/or capability to supply services across the nation. The National Contractor works or can work across multiple BASF locations. Typically a Master Agreement exists to cover their services AVETTA Pacific Industrial Contractor Screening is a company contracted by BASF to provide screening of contractors who perform work on BASF sites in North America. AVETTA compiles and provides pertinent safety and work related data to BASF on contractors seeking to work on BASF sites AVETTA Exempt List The AVETTA Exempt List is located in the BASF Procurement Key and consists of contractor companies who meet the Service Personnel Definition (2.18).
3 Procedure No.: MC Page: 3 of AVETTA Manual Audit A AVETTA Manual Audit is a comprehensive review of the Contractor s safety manual that is completed by a AVETTA safety professional PQF (Pre-Qualification Form) Questionnaire used to evaluate Contractor/Agency to determine EHS qualification Pre-Task Plan (PTP) A PTP is a written plan such as a Job Safety Analysis (JSA) or a Job Hazard Analysis (JHA) that describes job tasks in step-by-step sequence, identifies associated hazards for each step, and outlines proper hazard controls that minimize/mitigate the risk of injury or illness to the individual(s) performing that task Process Owner BASF person or entity that identifies scope of work and requests Contractor/Agency services Safe Work Permits Written authorization to perform work describing the task(s), associated risks and appropriate control measures Service Personnel Providers of service whose work has traditionally posed low EHS risk to production related processes and facilities and does not involve or introduce EHS hazards to the work area, for example, performing routine interim work on non-manufacturing equipment such as bench-top laboratory equipment, vending machines and office equipment. Conversely, providers of services such as building cleaning and lawn maintenance shall be considered Contractor(s) and not Service Personnel, for the purpose of this procedure Subcontractor Any party who has a direct contract with the Contractor/Agency or who furnished material to the Contractor/Agency Temporary Staffing Agency Third party Company that is the direct employer of the Contingent Staff assigned to work at a BASF site Total Safety Task Instruction (TSTI) Pre-Task Planning (PTP) used by nested contractor B&R at the BASF McIntosh site. 3. Scope This procedure applies to the BASF McIntosh site.
4 Procedure No.: MC Page: 4 of Procedure 4.1 General Requirements Program Management 1. Contractor and Subcontractors working at BASF McIntosh covered under this procedure must meet minimum EHS qualification criteria for work that: affects or has the potential to affect the EHS of manufacturing, manufacturing-related laboratory processes or offices. introduces EHS hazards into the work area whether they are chemical or physical hazards. 2. BASF McIntosh shall use AVETTA to facilitate the EHS qualification process for a Contractor/Agency covered under this procedure. Relevant documentation of the EHS contractor approval shall be maintained in the AVETTA database. 3. Contractor companies working at BASF McIntosh covered under this procedure are required to ensure that all Subcontractors are registered in AVETTA and meet the same EHS qualification criteria. BASF Procurement will be responsible for informing the Contractor of this requirement in the contract documents. 4. EHS approval is not required for Contractor that provides only Contingent Staff Employees. If the Contractor provides both Contingent Staff Employees and Contractor Employees, then the contractor is required to obtain EHS approval. 5. Service Personnel and Delivery Personnel are not required to obtain an EHS approval under this procedure. Contractors that are retained under emergency approval provision of this procedure are also not required to obtain an EHS approval Written Program The BASF McIntosh site provides oversight to Contractors who are approved to provide services to the McIntosh site. This program includes but is not limited to the following oversights: procedure for conditional EHS qualification and approvals See Section of this procedure procedure for emergency approvals See Section of this procedure means to orient Contractor Employees and exchange process and hazard information Provided via, but not limited to, Total Safety for Construction and Industry (Third Coastal Safety (3CS)) 3 rd part training and the site Contractor Orientation Checklist Contractor Job Observation Program Provided via, but not limited to, the Contractor Journey to EHS Excellence (JTE) and the Exposure Reduction Process (ERP)
5 Procedure No.: MC Page: 5 of 17 procedure to conduct management system review See Section 4.5. of this procedure means to ensure required training qualifications for the job Provided via, but not limited to, contractor company training records participation in accident incident investigations See AIIMS system for examples participation in other EHS related activities, e.g. drills, safety celebrations Provided via, but not limited to, attendance sheets or other methods such as Contractor Monthly Safety Officers Meeting means to advise BASF McIntosh of chemicals they will bring on-site Provided via, but not limited to, Contractor Orientation Checklist means to address Contractor/Agency unacceptable performance Provided via, but not limited to BEST card reviews and Avetta PRE-TASK PLANNING (PTP) All Contractors approved to work at BASF facilities via Safe Work Permits are required to have a Pre-Task Planning (PTP) process. If preapproved by BASF personnel, the contractor may use their own PTP process. If the contractor does not have a PTP process or the PTP process is deemed insufficient by BASF personnel, then the contractor must use BASF s Being Entirely Safe Today (BEST) cards for pre-task planning. See section for more information. Approved contractor PTP processes: Brown and Root s Total Safety Task Instruction, or TSTI Background Checks Except as specifically otherwise permitted in BC , this section must be applied in the case of every contractor and temporary worker who will begin working at BASF McIntosh or who is returning to work at the BASF McIntosh site after three months or longer away from the site. This background check must address the following checks for contractors and temporary workers as identified in this section and in BC : Employment history last 2 years Social Security Number verification State criminal record (states of residence and employment for the last 7 years). Per Section 4.2.2, second bullet: criminal felony and misdemeanor convictions. Federal criminal record for the last 7 years as shown by previous resident and employment Current and prior address check as verified by Social Security Number Background check must be completed and submitted via to the head of BASF McIntosh s site security a full 48 hours prior to the contractor or temporary employee reporting to work at the site. These should be sent to Charles Moye, Security Manager (charles.moye@basf.com) and the BASF McIntosh Main Security Gate (usmc-service-mgate1@basf.com).
6 Procedure No.: MC Page: 6 of 17 These checks are required initially and are only required to be repeated if the employee leaves the BASF McIntosh site for longer than 3 months. If a contractor or temporary worker leaves the McIntosh site, the contractor/temporary worker agency shall notify Charles Moye and BASF McIntosh Main Security Gate of the employee s work termination. If the employee remains away from the BASF McIntosh site for longer than 3 months, a new background check must be initiated and sent to the above referenced address 48 hours prior to the employee returning to work at the site. NOTE: See the BASF Corporate Procedure BC Background Checks-Contractors and Temporary for additional information Documentation Documentation of the qualifications of Contractor/Agency that are approved must be maintained at the site. This documentation is the primary source of information evaluated for the EHS approval of Contractor at the site. AVETTA maintains this information as well as a controlled copy of the BASF PQF for Contractors. Go to: Avettaauditing.com for information Contracted Services Portal The Contracted Services Portal is a public access site where BASF, Contractors, MSPs Temporary Staffing Agencies and Contingent Staff can reference EHS plans, documents, standards, policies and best practices by way of the internet. The site address is basf.us/contractedservices SAFETY CONTACT TO WORKER RATIOS Establishment of a Contractor Safety Contact to worker ratio is recommended for all work performed by Contractors. This work includes construction, maintenance, and demolition activities. Inclusion of the ratio in the site s written program for Contractor EHS management is encouraged. For example: a ratio of one (1) full time Contractor Safety Contact for 25 or greater Contractor Employees. A Contractor census of less than 25 warrants a minimum of one (1) part time Contractor Safety Contact unless otherwise specified by BASF. 4.2 Contractor Selection A BASF service purchase order, service contract, or any other formal agreement to work at a BASF site cannot be generated for a Contractor to work that has not been EHS reviewed and approved. The following methods are required.
7 Procedure No.: MC Page: 7 of 17 *See the Site Service Purchase Requisition Process flowchart in Section 6 Related Documents, Attachment # Full EHS Approval BASF currently uses AVETTA to coordinate Contractor qualification. The process is as follows. 1. BASF Contact identifies scope of work and/or Contractor 2. BASF Procurement notifies the Contractor of BASF approval requirements. 3. Contractor contacts and registers with AVETTA. 4. AVETTA assigns a risk classification to the Contractor based upon the Contractor work capability or scope. Effective Jan.1, 2014, the former classifications of low, medium and high risk are changed to the following: a. Non-Safety Sensitive (pre-2014 low risk AVETTA ranking) - Contractors whose work has traditionally posed a minimal EHS risk. Examples typically include: office janitorial offsite/office engineering lawn care/lawn maintenance (excluding landscaping) IT(information technology, software development) office equipment repair uniform laundry b. Safety Sensitive (pre-2014 medium and high risk AVETTA ranking) - Contractors whose work involves higher risk activities where there is incident potential. Examples typically include: abatement/remediation confined space demolition lockout/tagout elevated work mobile crane operation electrical work hazardous waste hot work work over water rigging trench and excavation work hydroblasting and industrial cleaning
8 Procedure No.: MC Page: 8 of 17 A AVETTA Manual Audit is performed on all Contractors that are assigned the safety sensitive classification. Canadian Contractors may substitute Certificate of Recognition (COR) accreditation in lieu of the AVETTA Manual Audit. 5. AVETTA reviews Contractor PQFs and related EHS information according to the minimum BASF criteria: total recordable incident rate (TRIR) 3 - year average of 1.8 or less (US metric) recordable injury frequency (RIF) 3 year average of 1.8 or less (Canadian metric) days away from work case rate (DAFWCR) 3 - year average of 1.0 or less (US metric) lost time injury frequency (LTIF) 3 year average of 1.0 or less (Canadian metric) experience modification rate (EMR) of 1.0 or less no regulatory citations within last 3 years no fatalities within last 3 years EHS programs and procedures in place to meet regulatory and BASF s requirements. 6. An initial flag color is assigned by AVETTA as indicated below: Green Full EHS approval when all regulatory and BASF criteria is met. Red signifies deficiencies in meeting regulatory and or BASF requirements based off the type of work the company performs. 7. If EHS qualification and approval criteria are met, (green flag status) the Contractor is eligible to participate in the selection process or may continue service to BASF as long as technical and procurement approvals are in place. 8. If Subcontractors are to be used, a list of those Subcontractors must be disclosed to BASF for qualification and approval before work performance. The qualification and approval process for Subcontractors is the same, with the exception that the managing Contractor may be required to facilitate transfer of necessary documents to AVETTA for evaluation. *Refer to Section 6, Related Documents, Attachment #2 Contractor EHS Approval Flowcharts and RACI for additional guidance Conditional EHS Approval 1. When Contractors do not meet minimum EHS performance criteria (e.g., EMR, TRIR, RIF, LTIF, DAFWCR, regulatory compliance history, or EHS programs), each site may grant a conditional approval. This
9 Procedure No.: MC Page: 9 of 17 should be on a case-by-case basis with consultation from EHS, Procurement, Engineering, Maintenance, and Operations considering the following situations: Contractor s previous safety performance within BASF safety performance trends within recent years comparison with Contractor industry averages as published by the governing regulatory bodies nature of any safety program deficiencies regulatory agency compliance history nature of citation and abatement scope or risk level of work to be performed presence of Contractor EHS professional on site availability of safer alternative Contractors Conditional approval (force red flag to yellow) allows the Contractor to work at a site under certain prescribed conditions. Only BASF may assign a conditional approval for a Contractor, not AVETTA. The BASF site may grant full approval (force red flag to green) if the nature of the deficiency warrants, such as minor regulatory citations, etc. *Refer to Section 6: Related Documents, Attachment 3, Contractor Conditional Approval Decision Tree, for additional guidance. 2. Once conditional approval is decided, all information must be documented and saved in AVETTA via the Forced Flag Form *Refer to Section 6: Related Documents, Attachment 4, BASF Forced Flag Form or go to the Contracted Services portal. (See Section for portal details) Acceptable conditional work requirements include, but are not limited to: providing an escort increasing supervision increasing the number of job observations requiring additional training conducting periodic EHS meetings developing and implementing a Contractor journey roadmap developing or improving specific EHS plans, such as confined space entry, respiratory protection, fall protection, forklift operation, etc Emergency EHS Approval 1. A site manager or designee may grant emergency approvals for a Contractor in consultation with EHS Site Services, Engineering and
10 Procedure No.: MC Page: 10 of 17 Maintenance. Emergency approvals are temporary and valid for the emergency job only. Once the emergency job is completed, the Contractor is required to participate in the EHS qualification and approval process for continued work at a BASF site. Some examples of emergency approvals may include: short-term remediation of spill or release unplanned or emergency repair of process-related equipment unplanned or emergency repair of lab-related equipment correction of high-risk unsafe workplace condition 2. When emergency approvals are granted, site management, EHS Site Services, and/or Procurement may require additional EHS measures such as increased supervision and/or auditing of the work throughout the job. 3. Emergency approvals must be documented and retained for the purposes of performing the Contractor Management System Review (see 4.5.2) Service Personnel Designation 4.3 Pre-Access to Site Providers of service whose work has traditionally posed low EHS risk to production related processes or facilities and does not involve or introduce EHS hazards to the work area, can be designated as Service Personnel. For example, performing routine interim work on nonmanufacturing equipment such as bench top laboratory equipment, vending machines, and office equipment/cleaning may be considered Service Personnel tasks. *A list of suggested trades that could qualify as service personnel is included in Section 6: Related Documents, Attachment BASF Requirements 1. A BASF McIntosh Contact shall be identified for each Contractor job. 2. The BASF McIntosh Contact shall be responsible for ensuring all EHS requirements are met before the Contractor Employee(s) begins work. 3. The BASF McIntosh Contact shall ensure retention of Contractor job EHS performance documentation, such as records of inspections, job observations, and incidents. 4. The BASF McIntosh Contact shall be responsible for coordinating the reporting of Contractor accidents/incidents in accordance with site reporting requirements. 5. The BASF McIntosh Contact shall ensure Contractor Employee accidents/incidents are
11 Procedure No.: MC Page: 11 of 17 entered in AIMS Contractor Safety Concept For major projects at the McIntosh site involving special or complex hazards, e.g., shut-down or plant expansion projects, representatives with adequate knowledge of the process, materials and equipment (e.g., maintenance or construction engineer, defined EHS professionals) shall develop a concept for the implementation of the Contractor safety requirements. The Contractor Safety Concept shall include: planning activities related to process and location specific hazards coordinating and scheduling work between different Contractors and BASF employees (avoiding risks because of interaction of different activities) specific safety plans for high-risk Contractor work (e.g., demolition activities) Contractor Safety Contact (safety supervisor) to Contractor Employee ratios established based on risk and agreed to prior to work beginning. (e.g. construction project may have a 1 full time Safety Contact for every 25 Contractor Employees, or 1:25 ratio) ensuring that Contractors know the necessary BASF Contacts (or contacts to the main Contractor for turnkey projects) for possible questions or issues concerning safety specific safety supervision of the construction site on a regular basis (e.g., safety tours, safety supervisions) regular consultations held to discuss critical points and ensure all employees are informed of the applicable safety requirements, and multi-contractor coordination measures necessary to avoid accidents because of potential increase risk from on-going simultaneous work activities Before starting the work, this Contractor Safety Concept shall be discussed with the construction / maintenance managers of the Contractors and relevant BASF services. All affected Contractors must sign the Contractor Safety Concept. After that, the Contractors must inform all their Contractor Employees about the applicable safety measures. Whenever a change in the scope of the activities occurs, the concept must be updated and reviewed accordingly. *Refer to Section 6, Related Documents, Attachment #6 a nd #7, Contractor Safety Concept Templates for additional guidance. Before starting the work, this Contractor Safety Concept shall be discussed with the construction / maintenance managers of the Contractors and relevant BASF services. All affected Contractors must sign the Contractor Safety Concept. After that, the Contractors must
12 Procedure No.: MC Page: 12 of 17 inform all their Contractor Employees about the applicable safety measures. Whenever a change in the scope of the activities occurs, the concept must be updated and reviewed accordingly. *Refer t o S ection 6, Related Documents, Attachment #6 and #7, Contractor Safety Concept Templates for additional guidance EHS Orientation 1. Before work begins, all Contractors shall receive BASF site and/or unit EHS orientation. All Contractor Employee EHS orientations shall include: provisions for the right to inspect work and Stop Work as appropriate practices to control the entrance, presence and exit of Contractor Employees means for Contractors to provide the BASF site with information about hazards that the Contractor Employees may generate means to ensure that the Contractor Employee informs BASF of any chemicals brought on-site means to ensure that Contractor Employees are included in any BASF sponsored accident/incident investigations that involve them or their work overview of site s Job Observation Program emergency plans, alarms, and evacuation procedures known or potential hazards, such as, confined spaces, chemical hazards, asbestos, lead, electrical, fire, explosion, or process hazards related to the Contractor employees work or work area site specific EHS requirements, and if applicable means to ensure effective communication and understanding with non-english speaking Contractor Employees All McIntosh Site specific training will be conducted by a third party contracted training group, Third Coastal Safety (3CS) located in Mobile, AL. Information for this company will be provided to contractors by BASF McIntosh personnel. *Refer to Section 6, Related Documents, Attachment 8, Contractor Orientation Checklist Pre-Access / Pre-Job EHS Process This process is not a site orientation, but a structured and documented EHS dialog between the BASF contact (Technical Engineering Services TES) and the Contractor crew representative (supervisor, general foreman, safety representative, superintendent, etc.) responsible for executing the work. The minimum information covered in the pre-job
13 Procedure No.: MC Page: 13 of 17 process known as Activity Hazard Analysis shall be but not limited to the following: Contractor company Contractor company manager s information (name, phone number, , etc.) responsible and accountable for the work execution foreman information responsible for the on-site work (name, phone number, etc.) direct supervisor of the foreman completing the work on site (name, phone number, etc.) any plans to use Subcontractors the work history of the foremen completing the work on site (how long have they been foremen, what training do they have, etc.) the Contractor Safety Contact responsible for the work being completed on site (name, phone number, qualifications, etc.) the BASF Contact information coordinating the work being completed on site the specific procedure if one of the contractor employees is injured on site (e.g., whom to call for severe medical, 911, plant security, etc.) any local medical clinic relationship established to treat non-lifethreatening injuries incident investigation process for the site Pre-Task Planning (PTP) process requirements access to the site EHS requirements specific craft training requirements 4.4. Work Execution *See Section 6, Related Documents, Attachment #9 for an example copy of a BASF Contractor Pre-Access / Pre- Job Checklist Note: An example of an Activity Hazard Analysis (AHA) is attached as Attachment 11 of this procedure Contractor Job Observation Program 1. Each manufacturing and R&D site that nominally incurs 1000 contractor work hours per year shall have a Job Observation Program. 2. Site management shall establish and maintain a Job Observation Program that shall at minimum include: identification of multiple observers at all levels, to include production, maintenance, supervisors, managers, engineers, EHS professionals, etc. training for observers
14 Procedure No.: MC Page: 14 of 17 a feedback process to communicate findings internally and to the Contractor. a tracking system to document and analyze observation data. a frequency schedule established based on risk Note: The frequency and type of observations for a conditionally approved Contractor may be determined during the conditional approval process with the results documented in AVETTA. *Details including templates, example forms, databases and training are available at Contractor Safety Job Observation Resources webpage at to assist in implementing a Contractor Job Observation Program Pre-Task Planning (PTP) All Contractors approved to work at BASF facilities via Safe Work Permits are required to have a PTP process. As a minimum, all PTP s shall have the following elements: job/project title job location date when the work is performed all crew members signoff job description with job steps risk/hazard description for each job step risk/hazard controls / elimination / mitigation for each recognized hazard Contractors that do not have their own PTP process must be trained on and use the BASF Being Entirely Safe Today (BEST) cards. The Being Entirely Safe Today (BEST) cards are individual, personal PTP/JHAs that are to be completed each day by contractor company employees. These detailed cards are reviewed weekly by a EHS Team member and graded for completeness. Reports are issued by EHS to all BASF personnel associated with the contractor company(s) working on site at McIntosh. Contractors that have their own internal PTP process/cards may use them instead of the internal BEST cards if pre-approved by BASF. An example is the Total Safety Task Instruction (TSTI) PTP cards used by Brown and Root. Note: on rare and very special occasions more than one signature may be on a TSTI. These exceptions include but are not limited to jobs that are being performed exactly by all personnel assigned to the task. *See Section 6, Related Documents, Attachment #10_A and 10_B, for copies of example PTP forms.
15 Procedure No.: MC Page: 15 of Monitoring, Evaluation & Feedback Contractor Periodic Reviews 1. EHS performance data for all Contractor risk classifications shall be updated annually. 2. Contractors classified as safety sensitive will receive an audit of their safety program manual by AVETTA at least every three years. The review shall include Contractor injury statistics, EMR, regulatory agency citations, and EHS programs as stated in The results and findings of the annual and/or 3-year review may be used to adjust the Contractor approval status BASF Contractor EHS Management System Review/ Safety Performance Evaluation Each site shall review the effectiveness of practices at least annually to ensure that the Contractor EHS management system is properly implemented and the elements adequately support Contractor EHS performance improvement. At a minimum, the following elements of the Contractor management system shall be included in the review: the site procedure to ensure written requirements are in agreement with this procedure the participation of affected stakeholders (Procurement, Engineering, Maintenance, Operations, EHS, etc.) in the development and/or revision of site procedure for adequacy an adequate understanding of Contractor management roles and responsibilities among affected stakeholders (Procurement, Engineering, Maintenance, Operations, EHS, etc.) a system to provide opportunity for feedback and communication with Contractor employees, e.g., meetings, exchanges, forums, etc. maintenance of contractor approval documentation efficiency and adequacy of conditional approval process efficiency and adequacy of emergency approval process documented Contractor orientation performed in a timely manner before work verification mechanism in place to ensure Contractor orientation was understood Contractor Job Observations performed adequately, timely with appropriate follow-up information/data from affected stakeholders (Procurement, Engineering, Maintenance, Operations, EHS, etc.) is adequate and accessible in order to conduct periodic Contractor reviews or re- approvals safety performance review of all Contractors (by AVETTA) results of annual management system review communicated to affected stakeholders
16 Procedure No.: MC Page: 16 of 17 contractor hours accounting process *Refer to Section 6, Related Documents, Attachment #11, Contractor EHS Management System Checklist Contractor Hours Accounting BASF McIntosh site shall turn in cumulative monthly hours at the North America level each month. The corporate policy requiressites that exceed the monthly contractor hours (not including Contingent Staff hours) threshold of 2,000 hours to report those hours. All Contractor companies shall turn in hours to the sites where they completed work each month. The McIntosh site shall have a means to reasonably reconcile these hours on a periodic basis. Some of these means to reconcile can be: 1. Invoicing data 2. Sign-in and out logs with site security 3. Scan-in and out systems (electronic badging programs) 5. Responsibilities Contractor Safety Forums It is recommended by the corporate policy that McIntosh facilitate or participate in an annual Contractor safety forum. The purpose of the Contractor Safety Forum is to facilitate collaboration (two way dialogue) between BASF and our Contractor partners. communicate the BASF Safety Culture to our Contractors communicate all BASF expectations regarding Contractor safety including upcoming initiatives and share best practices among various Contractor companies Desired End Result: Drive the Zero Incident Mindset within our Contractor partners, thereby ultimately improving safety performance. *Refer to Section 6, Related Documents, Attachment #12, Contractor Safety Forums best practice document for more information Occupational Safety/Industrial Hygiene Center of Expertise (CoE) Manager The Occupational Safety/Industrial Hygiene CoE Manager has the primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure. 5.2 Site Manager The McIntosh Site Manager has the primary responsibility for the implementation of this procedure.
17 Procedure No.: MC Page: 17 of BASF McIntosh Site EHS Specialist The McIntosh EHS Specialist has the primary responsibility to: Be knowledgeable of this procedure and how it applies to the McIntosh site. Ensure each BASF McIntosh site has a written contractor EHS management process and it is up to date per the current corporate procedure revision. Initiate the MOC process to communicate all changes to the site. Be a resource for training on required content of this procedure such as the Pre-Task Planning Process and the Pre-Access / Pre-Job EHS Process. Perform Contractor reviews for potential Service Personnel designation. 5.4 Site Procurement Liaison The Site Procurement Liaison is responsible for adding companies (that are determined by the BASF Site EHS Specialist to meet the Service Personnel designation) to the AVETTA exempt list located in the Procurement Key. 5.5 BASF Contractor Safety Improvement Leader If the site designates, the Contractor Safety Improvement Leader should be responsible for ensuring concepts of the Contractor EHS performance improvement strategy are in place at the site. 5.6 BASF Contact The BASF Contact has the primary responsibility to ensure: All aspects of the job scope are identified prior to requesting work from a Contractor All EHS requirements are met prior to the Contractor performing work Retention of all Contractor job EHS performance documentation is completed That all Contractor incidents are reported in accordance with site reporting requirements All applicable Contractor incidents are entered in AIMS. 6. Related Documents (see BASF Contractor EHS Management - BC ) Attachment 1 Site Service Purchase Requisition Process Flowchart Attachment 2 Contractor EHS Approval Flowcharts and RACI (required) Attachment 3 Contractor Conditional Approval Decision Tree (required) Attachment 4 BASF Forced Flag Form Attachment 5 Contractor Safety Concept Templates (example Turnaround Concept) Attachment 6 Contractor Safety Concept Template (example Construction Project) Attachment 7 BASF Pre-Access/Pre-Job Checklist (example) Attachment 8 PTP Form (example 2) Attachment 9 Contractor EHS Management System Checklist Attachment 10 Contractor Orientation Checklist Attachment 11 Example of Activity Hazard Analysis (AHA)
Owner: Judy Brinkman Site Director
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