Procedure. Work Health and Safety Contractor Management. Document number: PRO Rev no. Description Process Owner Approved for issue

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1 Procedure Work Health and Safety Contractor Management Document number: PRO This document is the property of Seqwater. It must not be copied or reproduced in any way whatsoever without the authority of Seqwater. This document is uncontrolled when printed. An electronic database manages and stores the controlled version. Rev no. Description Process Owner Approved for issue 9 APPROVED Manager, WHS Position Name Signature Position Name Date Signature Anthony Newbold See TRIM Ref D16/ General Manager, SPS Nikki Poteri- Collie 03/11/16 See TRIM Ref D16/160837

2 Contents 1. Purpose Scope Roles and responsibilities Procedure No Arrangement Contractor (non-panel contractor) Stage one work activity identified Stage two contractor selection Stage three contractor engaged Stage four works execution Stage five works completion Arrangement (Panel) Contractor Stage one panel requirements identified and prepared for tender Stage two contractor evaluation process Stage three contractor appointed to panel Stage four works execution Stage five works completion Project Work (including construction work) Stage one contract specification Stage two contractor selection Stage three contract approval Stage four works execution Stage five contract closure Training requirements Monitoring and audit Record keeping References Legislation and other requirements Supporting procedures Supporting documents, forms and templates Definitions Appendix A: Workplace Inspection schedule Appendix B: Additional information principal contractors Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 2 of 32

3 1. Purpose Seqwater is committed to the health and safety of all people in the workplace. This procedure supports Seqwater s contractor management framework, by providing the objectives and approach to the effective Work Health and Safety (WHS) management of contractors. This procedure: outlines the WHS responsibilities of employees, managers and Seqwater in relation to contractors describes the WHS requirements for the selection, engagement, induction, consultation, monitoring and performance reporting of contractors undertaking work on behalf of Seqwater. It also provides guidance to managers and workers in relation to contractor management obligations under the Work Health and Safety Act 2011 (Qld) and the Work Health and Safety Regulation 2011 (Qld). This procedure supports the requirements of Element 10 Procurement and contractor management as detailed in Seqwater s Work Health and Safety Management System Framework (MAN-00211). This procedure adopts and is consistent with requirements outlined in the: Work Health and Safety Act 2011 (Qld) Work Health and Safety Regulation 2011 (Qld) Electrical Safety Act 2002 (Qld) Electrical Safety Regulation 2013 (Qld) AS/NZS 4801:2001 Occupational Health & Safety Systems - Specifications with guidance for use. 2. Scope This procedure applies to all Seqwater workers, business groups and work activities. Contractors engaged through a professional services contract are out of scope of this procedure. In addition, this procedure does not cover alliances or large-scale operation and maintenance contracted services, such as contracts for the operation and maintenance of Seqwater sites where the control of the site has been transferred to another entity. Examples of large-scale operation and maintenance contracts include contracts for the operation and maintenance of Advanced Water Treatment Plants, the operation and maintenance of the Gold Coast Desalination Plant and the operation and maintenance agreement for the bulk water supply system. If design forms part of your engagement with contractors reference must be made to the Engineering Review and Approval Procedure (PRO-01617) which outlines requirements for Safety in Design. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 3 of 32

4 3. Roles and responsibilities Role Responsibilities Manager Provide appropriate resources to adequately implement the WHS contractor management processes detailed in this procedure. Complete workplace monitoring activities to verify that identified WHS hazards are being effectively managed and the requirements of this procedure are being consistently complied with. Implement and communicate this procedure within their relevant business group. Undertake reviews of contractors in accordance with the requirements of this procedure. Manager, WHS Provide appropriate WHS resources to support the implementation and monitoring of this procedure. Complete workplace monitoring activities to verify the implementation and effectiveness of the WHS contractor management process. Provide appropriate resources to review and audit contractor WHS compliance with the requirements of this procedure. Establish a systematic process to manage the WHS of contractors to assist Seqwater employees or representatives engaging the contractor, or Project Manager, in the engagement, induction, consultation, monitoring and performance reporting of contractors. Procurement Team Include WHS requirements in all stages of the procurement and contract management process. Receive and forward WHS reports from contractors according to contract terms. Review and retain records of contractors WHS performance. During the procurement process undertake verification, recording and maintenance of all required licences and insurances. Project Manager Coordinate the safe delivery of projects they are responsible for with the support of the WHS Team. Maintain currency of knowledge of applicable WHS legislation, policies, procedures and other obligations relevant to the projects they are responsible for, with the support of the WHS Team. Ensure, so far as is reasonably practicable, contractors comply with relevant Seqwater policies and procedures where communicated or provided. Include WHS requirements in all stages of the procurement and contract management process. Implement strategies to confirm that contractors comply with project/contract specific WHS management plans, Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 4 of 32

5 Role Seqwater employee or representative engaging a contractor Responsibilities Safe Work Method Statements (SWMS) and Job Safety Environment Analysis (JSEA). Ensure, so far as is reasonably practicable, contractors comply with WHS contractual obligations. Arrange workplace inductions, site access and any required permits. Coordinate the safe delivery of the contracted works they are responsible for with the support of the WHS Team. Maintain currency of knowledge of applicable WHS legislation, policies, procedures and other obligations relevant to the contracts they are responsible for, with the support of the WHS Team. Ensure, so far as is reasonably practicable, contractors comply with relevant Seqwater s policies and procedures. Include WHS requirements in all stages of the procurement and contract management process. Implement strategies to confirm that contractors comply with project/contract specific WHS management plans, Job Safety Environment Analysis (JSEA) and Safe Work Method Statements (SWMS). Arrange workplace inductions, site access and any required permits. Ensure, so far as is reasonably practicable, contractors comply with WHS contractual obligations. WHS Coordinator Provide required WHS resources for WHS contractor management monitoring activities. WHS Projects and Compliance Coordinator Coordinate WHS Regional Advisor activities (including but not limited to site inspection and safety observations) in regard to this procedure. Investigate all incidents involving contractors in accordance with the Incident Investigation Procedure (PRO-00793). Implement processes for WHS contractor management to assist Seqwater employees or representatives engaging the contractor apply this procedure. Assist Seqwater employees or representatives engaging the contractor with reviewing contractor WHS systems and associated documentation. Undertake monitoring and evaluation of contractor WHS activities. Liaise with WHS Coordinator in regard to WHS project requirements. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 5 of 32

6 Role Responsibilities WHS Regional Advisor Provide WHS support to all Seqwater employees or representatives engaging contractors. Undertake regular audits, inspections and safety observations of contractors. Investigate all contractor incidents that occur as directed by the WHS Coordinator and in accordance with the Incident Investigation Procedure (PRO-00793). Contractors Comply with the WHS requirements of their contract. Comply with all lawful and reasonable safety directions provided by the Seqwater employee or representative engaging the contractor. Employees Request a contractor to stop work if there is an imminent risk to WHS, until that risk is adequately resolved. 4. Procedure Seqwater regularly obtains a range of services from contractors to undertake its business. The arrangements used to procure and manage these services differ depending on the process used to engage the contractor. The various types of arrangements are identified in the Procurement Decision Matrix Procedure (PRO ). Seqwater have a range of legislative and other WHS obligations associated with the management of contractors. To assist Seqwater managers and workers meet their WHS contractor management obligations, information is provided on the different procurement arrangements as follows: 1. No-Arrangement Contractor: an individual or company that has an ad hoc contractual relationship with Seqwater. No-Arrangement Contractors are engaged via a purchase order or contract, following an assessment by the Seqwater employee or representative engaging the contractor to confirm they meet Seqwater s WHS requirements suitable for the task or activity they have been engaged to perform. See Section 5 for guidance on managing the WHS requirements for No- Arrangement Contractors. 2. Arrangement (Panel) Contractor: an individual or company that has been appointed to Seqwater s panel of providers after meeting Seqwater s WHS commercial and performance requirements through a tender evaluation process. See section 6 for guidance on managing the WHS requirements for Panel Contractors. 3. Project Work (including Construction Work): an individual or company engaged to deliver a specific project, or part of a project. The work they undertake will be governed by a contractual arrangement. See section 7 for guidance on managing the WHS requirements for Project Work. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 6 of 32

7 5. No Arrangement Contractor (non-panel contractor) In some circumstances, Seqwater may go outside of a panel arrangement to source goods and services, as determined by the Seqwater Procurement Policy (POL ) and applied based on the guidelines published in the Procurement Decision Matrix Procedure (PRO-01336). These contractors must meet the mandatory WHS compliance for the role and these are to be included in the requirements by the Seqwater representative before entering into an agreement. The following diagram provides an overview of the five stages of the WHS contracting lifecycle for No Arrangement Contractors: 5.1 Stage one work activity identified During the planning phase of a job, the Seqwater employee or representative identifying the need for work to be undertaken must undertake a WHS risk assessment to be incorporated into the WHS requirements in the scope of works. Where the work involves design reference must be made to the Engineering Review and Approval Procedure (PRO-01617) which outlines requirements for Safety in Design. The relevant WHS risk register for the workplaces at which work is to be performed is to be made available to the potential contractor. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 7 of 32

8 5.2 Stage two contractor selection The selection of a contractor to perform work must be undertaken in accordance with the Procurement - Decision Matrix Procedure (PRO-01336). The Seqwater employee or representative engaging the contractor must make themselves aware of the WHS performance of the contractor on previous Seqwater jobs. Past performance must be taken into consideration during the contractor selection process. Past performance can be measured through review of previous Seqwater WHS contractor audits from CIS. The Seqwater employee or representative engaging the contractor must also verify the potential contractors risk management processes to confirm that at a minimum, they meet Seqwater s WHS hazard identification and risk assessment standards as documented in WHS Hazard Identification and Risk Management Procedure (PRO ). Support is available from the WHS Team to undertake this verification if required. Where a potential contractor s system is deemed to be a lower standard, then the Seqwater employee or representative engaging the contractor must provide direction in the use of WHS Hazard Identification and Risk Management Procedure (PRO-00657), then request the potential contractor to resubmit their WHS hazard identification and risk assessment. The Seqwater employee or representative engaging the contractor must also provide information to the contractor about WHS hazards and risks at, or in the vicinity of, the workplace where the work will be conducted. This information can be provided in various forms such as workplace specific inductions or pre-start scoping meetings. As part of the contractor selection process, the Seqwater employee or representative engaging the contractor is to make sure that appropriate verification of any required licences and tickets occurs at the stage applicable to the activity or task they are being engaged to perform. 5.3 Stage three contractor engaged Purchase order raised Prior to the purchase order being raised, the Seqwater employee or representative engaging the contractor must: conduct a WHS impact assessment for the task or activity to be undertaken, and advise contractor of any potential impacts that need to be considered while doing the task or activity prior to the purchase order being raised. Potential WHS impacts must be addressed in the Contractor s safety documentation including, but is not limited to, JSEA, SWMS, permits, site access requirements for the task or activity. any Seqwater training pertinent to the task, such as site inductions, site access requirements, Permit Access Safety System (PASS) training and fluoride awareness training, are to be organised by the Seqwater employee or representative engaging the contractor. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 8 of 32

9 5.3.2 Notification of upcoming work to Seqwater stakeholders Once a work order is issued, the Seqwater employee or representative engaging the contractor is to notify site stakeholders of any potential WHS issues that may arise from works being undertaken where required. This process is also managed through the site access component of PASS WHS documentation review Prior to commencing work activities the engaged contractor shall supply a job specific JSEA/SWMS for evaluation by the Seqwater employee or representative engaging the contractor. Where required this may be reviewed in consultation with the WHS Team s WHS Projects and Compliance Coordinator. The Seqwater employee or representative engaging the contractor must retain all job specific WHS documentation with the work order in CIS for future reference. 5.4 Stage four works execution During the works execution stage, the Seqwater employee or representative engaging the contractor shall make sure the activities outlined in this section, are completed to monitor the contractor s WHS performance Induction Prior to work commencing on Seqwater sites, the Seqwater employee or representative engaging the contractor shall make sure all contractors complete: WHS Contractor Induction via Seqwater s website ( workplace specific induction via Seqwater s website ( Seqwater specific training such as: - PASS training in accordance with PASS Procedure (PRO-01820) - vessel induction - fluoride awareness if applicable. Contractor induction details are recorded in Our Learning via Seqwater s website Site access and permits Site access and all required permits shall be organised by the Seqwater employee or representative engaging the contractor prior to work commencing and in accordance with the PASS Procedure (PRO-01820) Implementation of contractor s JSEA/SWMS Implementation of the contractor s JSEA/SWMS is the responsibility of the contractor. It is also the responsibility of the contractor to ensure that their JSEA/SWMS is readily available for inspection and that all workers and subcontractors onsite are signed-on and following its requirements. Contractor s WHS compliance may be subject to WHS inspections at any time. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 9 of 32

10 JSEA/SWMS are to be updated and implemented at any change to the scope of work WHS inspections and observations The Seqwater employee or representative engaging the contractor, with the support of stakeholders such as WHS Advisors, are to verify the implementation of the contractor s JSEA/SWMS by conducting random: safety observations formal and informal workplace and document WHS inspections Monitoring the implementation of the contractor s JSEA should be more frequent if conducting a high-risk activity as outlined in Appendix A - Inspection schedule. The results of observations and WHS inspections will be communicated to stakeholders prior to being recorded in Risk Wizard by the person conducting the inspection or observation WHS incident reporting All contractor WHS incidents, including near misses, are required to be notified to the Seqwater Incident Hotline (07) and the line supervisor in accordance with the requirements of the WHS Incident Notification Procedure (PRO-00388) Contractor non-conformance If during the performance of work a Seqwater employee or the Seqwater representative engaging the contractor is informed the contractor is: not conducting the work in compliance with applicable legislation or their JSEA/SWMS conducting the work in such a way as to endanger the WHS of the contractor s workers, Seqwater workers or the general public the Seqwater employee or representative engaging the contractor or stakeholder (including but not limited to WHS Regional Advisors, Site Operators) will discuss the concerns with the contractor. If this does not address the concerns they will issue a Notice of Non-Conformance (FRM-00517) and will direct the contractor to immediately cease the activity, make safe and remedy the WHS breach. If the contractor is unable to remedy the breach immediately, the Seqwater employee or representative engaging the contractor is to direct the contractor to suspend all work until such time as the contractor provides evidence that the work can be resumed in a safe manner. If the contractor fails to rectify any breaches of WHS for which work has been suspended, or if the contractor s performance has involved recurring breaches of WHS, Seqwater may terminate the work forthwith in accordance with contract terms, depending on the severity of the issue. All non-conformances and investigations raised will be communicated to stakeholders and recorded in Risk Wizard by the WHS Team. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 10 of 32

11 5.5 Stage five works completion The Seqwater employee or representative engaging the no arrangement contractor will at the completion of works: Conduct an inspection of the area where work was carried out to confirm it has been left free of hazards. If there are geographical restrictions, this inspection may be performed by another Seqwater employee or representative at the request of the Seqwater employee or representative engaging the contractor. This inspection can be performed in conjunction with ensuring the deliverables and quality of the task is as detailed in the scope. Provide information to the WHS Team if required for updating of the relevant WHS risk register, asbestos register, confined space register etc. Evaluate and record the contractor s WHS performance for future work where a non-conformance has occurred as per section Make sure that all permits are signed off and closed out. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 11 of 32

12 6. Arrangement (Panel) Contractor The following diagram provides an overview of the five stages of the WHS contracting lifecycle for panel contractors: 6.1 Stage one panel requirements identified and prepared for tender Seqwater takes a risk-based approach when planning work and engaging contractors to undertake work on our sites. All tender documentation for establishing arrangements for panel contractors must clearly set out the panel contractor WHS obligations, including provisions to the effect that any successful tenderer will, if engaged as a contractor to carry out work for Seqwater, be required to comply with all WHS related legislation including the Work Health and Safety Act 2011 (Qld) and the Work Health and Safety Regulation 2011 (Qld), and all Seqwater policies and procedures relating to WHS. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 12 of 32

13 6.1.1 Risk Assessment The Seqwater procurement team must set out within the tender documents the information provided by the Project Manager or the Seqwater employee or representative engaging the contractor about WHS hazards and risks that may be encountered throughout Seqwater workplaces. This is a high level hazard identification process only due to the organisation s diverse asset portfolio and geographical locations. The Seqwater employee or representative engaging the successful panel contractor must provide information to the contractor about known WHS hazards and risks at, or in the vicinity of, the workplace where the work will be conducted. This information can be provided in various forms such as workplace specific inductions or pre-start scoping meetings. The Seqwater employee or representative engaging the panel contractor must make sure that the contractor conducts a WHS hazard identification and risk assessment for the task or activity. In addition, they must verify the contractor s risk management process utilised to undertake the assessment is, at a minimum, to Seqwater s WHS hazard identification and risk assessment standards as documented in WHS Hazard Identification and Risk Management Procedure (PRO-00657). The panel contractor s hazard identification and risk management system is part of the evaluation process outlined in section 6.2. Where the panel contractor s system is deemed to be a lower standard, then the Seqwater employee or representative engaging the contractor must provide direction in the use of WHS Hazard Identification and Risk Management Procedure (PRO-00657), then request they resubmit their WHS hazard identification and risk assessment. WHS risk registers for workplaces at which work is to be performed are to be made available for the panel contractor WHS tender schedules The WHS tender schedule, including the minimum WHS conditions of participation, must be included in tender documentation to provide Seqwater the opportunity to assess the panel contractor s WHS Management System. Panel contractors will be required to verify responses by attaching additional documentation evidencing ability and capacity in relevant WHS matters. This is a mandatory scoring element of the tender evaluation process. 6.2 Stage two contractor evaluation process The panel contractor selection stage includes assessing tenderers against set selection criteria. All tender submissions must comply with the minimum WHS conditions of participation as stated within the tender documentation. The tender evaluation panel members must make themselves aware not only of the information supplied by tenderers but also the WHS performance of the contractor on previous projects. This is a requirement of the tender specifications. Originals of all tender documents are managed in accordance with the Procurement Procedure (PRO-01514) and saved in TRIM for future reference. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 13 of 32

14 As part of the procurement process, the Procurement Team is to confirm that the verification and recording of all required licences and insurances occurs at this stage. Once the tenderer is accepted as a successful panel member, the selection of a contractor to perform work must be undertaken in accordance with the Procurement Decision Matrix Procedure (PRO-01336). 6.3 Stage three contractor appointed to panel The contract is awarded and contract documents are executed in the contract approval stage Letter of award A contract is awarded once a letter of engagement has been issued. The contract must include the agreed WHS requirements. 6.4 Stage four works execution The works execution stage for panel contractors is the same as no-arrangement contractors in section 5.4. The Seqwater employee or representative engaging the contractor will make sure the activities outlined in section 5.4 are completed to monitor the contractor s WHS performance for the duration of the panel term. 6.5 Stage five works completion The Seqwater employee or representative engaging the panel contractor will at the completion of works, follow the requirements outlined in section Contractor evaluation After the completion of each panel contract term the Procurement Team, in consultation with stakeholders, shall review and evaluate the contractor s WHS performance. This will form part of the overall evaluation process for future tenders. The contractor s WHS evaluation is to be completed in line with the Procurement Procedure (PRO-01514) Record Keeping The Procurement Team will retain all tendered contractor records (including WHS management plans and JSEA/SWMS). All records will be retained in contract files in TRIM. Results of all contractor WHS inspections will be retained in Risk Wizard and/or CIS. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 14 of 32

15 7. Project Work (including construction work) The WHS contracting lifecycle is considered over five stages, underpinned by continuous improvement. This lifecycle begins once the General Manager and manager of the business unit have developed a business case that has been approved in accordance with the Delegations and Authorisations Manual (MAN-00076). 7.1 Stage one contract specification Seqwater takes a risk-based approach when planning work and engaging contractors to undertake work on our sites. The Project Manager, in consultation with the WHS team and Procurement Team (if required by the Project Manager) must clearly set out WHS obligations in tender documentation, including provisions to the effect that any successful tenderer will, once engaged as a contractor, be required to comply with all WHS related legislation including the Work Health and Safety Act 2011 (Qld) and the Work Health and Safety Regulation 2011 (Qld), and all Seqwater policies and procedures relating to WHS. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 15 of 32

16 7.1.1 Project Risk Assessment The Project Manager must set out within the tender documentation any information about any known WHS hazards and risks at, or in the vicinity of, the workplace where the work will be conducted. The WHS hazard identification and risk assessment coordinated by the Project Manager shall be undertaken in accordance with the WHS Hazard Identification and Risk Management Procedure (PRO-00657). Where the work involves design reference must be made to the Engineering Review and Approval Procedure (PRO ) which outlines requirements for Safety in Design. As a result of the hazard identification and risk assessment process, an overall WHS contract risk rating will be determined. This will be a residual risk rating that is determined after risks have been mitigated using appropriate controls. If there are high-risk activities, high-risk construction work or prescribed activities as listed in the Work Health and Safety Regulation 2011, the WHS contract risk will be categorised as high. More frequent inspections and audits of medium and high-risk contracts are required as outlined in Appendix A - Inspection Schedule Project Management Plan The Project Manager must include the following WHS requirements in the project management plan: WHS management WHS risk assessment Site specific hazards identified in the site WHS risk register Safety in design requirements WHS risk management for the contract WHS tender schedules The WHS tender schedule, including the minimum WHS conditions of participation as decided by the Project Manager in consultation with the WHS and Procurement teams, must be included in tender documentation. This provides Seqwater the opportunity to assess the contractor s WHS Management System. Contractors will be required to verify responses by providing additional documentation evidencing ability and capacity in relevant WHS matters. 7.2 Stage two contractor selection The selection and engagement of a contractor to perform work must be undertaken in accordance with the Procurement - Decision Matrix Procedure (PRO-01336). The contractor selection stage includes assessing tenderers against set selection criteria. All tender submissions must comply with the minimum WHS conditions of participation as stated within the tender documentation. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 16 of 32

17 The Manager, Project Manager and the tender evaluation panel members (in consultation with WHS team where required) must make themselves aware not only of the information supplied by tenderers but also the WHS performance of the contractor on previous projects. Originals of all tender documents are managed in accordance with the Procurement Procedure (PRO-01514) and saved in TRIM for future reference. As part of the procurement process, the Procurement Team is to make sure that the verification and recording of all required licences and insurances occurs at this stage. 7.3 Stage three contract approval The contract is awarded and contract documents are executed in the contract approval stage Contract The contract must include the agreed WHS requirements for the project as outlined in the tender documentation Post contract award WHS document review The Project Manager will review all WHS documentation prior to sending it to the WHS Projects and Compliance Coordinator for review. Where required by the Project Manager, the WHS Regional Advisors may also participate in the review. The contractor s project specific WHS Management Plan, SWMS and JSEA must be submitted, reviewed and endorsed prior to work commencing onsite Notification of engaged contractor to Seqwater stakeholders Once a contract is awarded, the Project Manager is to notify all stakeholders by ing the following information: contractor details (including key personnel) Seqwater affected location/s WHS risk rating of contract start date (pre-start and start up meeting date and time) expected contract duration project milestones where stakeholder involvement is required. Stakeholders should include as a minimum representatives from the following areas: WHS Team Site Operations and Maintenance Manager/Coordinator Communications Team (where public interfaces exist). Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 17 of 32

18 7.3.4 WHS project monitoring and reporting A schedule for project monitoring (site inspections, safety observations), WHS reporting requirements and meetings will be agreed upon between the Project Manager, WHS Team and other relevant parties. This may occur at the pre-start meeting, or for major projects this may be undertaken during the post contract award WHS document review Principal Contractors For each construction project (construction work for which the total costs of the construction works is $250,000 or more, as set out in section 292 of the Work Health and Safety Regulation 2011 (QLD)) Seqwater must appoint a Principal Contractor (if none is appointed Seqwater is taken to be the Principal Contractor and will be required to comply with all additional duties and obligations associated with this role). In exceptional circumstances, Seqwater may undertake the role of Principal Contractor, however this must be approved by the relevant General Manager, in consultation with the Manager, WHS. The Seqwater person taking on the responsibility of the Principal Contractor must have a full understanding of the obligation of a Principal Contractor outlined in the Work Health and Safety Regulation 2011 (Qld). Seqwater can authorise a contractor to have management or control of a workplace for construction work that is valued less than $250,000 (and is therefore not a construction project). However, in this situation the contractor would not inherit the additional duties of a principal contractor under part 6.4 of the Work Health and Safety Regulation 2011 (QLD). Refer to Appendix B: Additional information - principal contractors Pre-start meeting The Project Manager will conduct a pre-start meeting with the contractor and stakeholders (as identified by the Project Manager) prior to the works commencing. This meeting must clarify all WHS requirements (including but not limited to permits, site access, known site hazards). At this meeting a schedule for project monitoring (site inspections, safety observations), WHS reporting requirements and meetings will be agreed upon. 7.4 Stage four works execution During the works execution stage of the contract, the Project Manager shall make sure the activities outlined in this section, are completed to monitor the contractor s compliance and WHS performance Induction Prior to work commencing at a Seqwater workplace, the Seqwater Project Manager shall make sure all contractors complete: Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 18 of 32

19 WHS Contractor Induction via Seqwater s website ( workplace specific induction via Seqwater s website ( Seqwater specific training such as: - PASS training in accordance with PASS Procedure (PRO-01820) - vessel induction - fluoride awareness if applicable. Contractor induction details are recorded in Our Learning via Seqwater s website Site Access and Permits Site access and all required Permits shall be organised by the Seqwater employee or representative engaging the contractor prior to work commencing and in accordance with the PASS Procedure (PRO-01820). Permits The Project Manager is to develop an interface plan where a Principal Contractor has been appointed to clearly delineate where Seqwater s systems end and the Principal Contractor s systems and responsibilities begin Start-up meeting The Project Manager will conduct a start-up meeting with the contractor and stakeholders (as identified in the Project Management Plan) once the contractor has had formal handover of the site and prior to the works commencing. For medium to high-risk work, the start-up meeting will be attended by a WHS Regional Advisor. For low-risk work attendance by a WHS Regional Advisor is at the discretion of the Project Manager. At this meeting verification of the following must occur: all contractors, including their subcontractors have undertaken the required Seqwater inductions all relevant permits are in place all contractors have signed onto the WHS management plan and all relevant SWMS and JSEAs Implementation of WHS management plans Implementation of the contractor s WHS Management Plan and associated SWMS and JSEAs is the responsibility of the contractor. It is also the responsibility of the contractor to ensure that the WHS Management Plan and SWMS are readily available for inspection and that all workers and sub-contractors onsite are following its requirements Audits and inspections The Project Manager, with the support of WHS Regional Advisors and site stakeholders, is to verify the implementation of the contractor s WHS management plan and associated SWMS and JSEA by conducting: Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 19 of 32

20 formal and informal site and document inspections/audits meetings to review WHS performance project WHS management plan audits. Monitoring of the implementation of the contractor s WHS management plan and associated SWMS and JSEAs will be in accordance with the agreed schedule developed at the pre-start meeting. Frequency of monitoring will be determined by the WHS risk rating of the contract refer Appendix A - Inspection Schedule. Additional workplace inspections, safety observations etc. will be conducted as required where high-risk stages of the project are identified during project planning or where the contractor s WHS performance may require an increase in monitoring. This is at the discretion of the Project Manager in consultation with the WHS Regional Advisor. The contractor is required to revise, update and communicate their WHS management plan, SWMS and JSEA whenever there is a change to current work process, change in site conditions or when monitoring identifies a need to do so. Updated WHS management plans, SWMS and JSEA are to be reviewed by the Project Manager and WHS Regional Advisor. The results of audits and inspections will be communicated to stakeholders prior to being recorded in Risk Wizard by the person conducting the inspection, audit or meeting. Contractor s WHS inspections and audits will be stored in the project folder in TRIM Contractor WHS reporting to Seqwater Contractors are required to provide WHS Performance Reports as per contract conditions. The Project Manager will review the report (if required this may be in consultation with the WHS team) and discuss any concerns or issues with the contractor at project meetings. The WHS Projects and Compliance Coordinator will liaise with the Project Manager to confirm reports are being received; these results will be entered into Risk Wizard as part the ongoing contractor s WHS performance monitoring. A contractor s WHS Performance Reports will be stored in the project folder in TRIM WHS incident reporting Incident notification is to be in accordance with the WHS Incident Notification Procedure (PRO-00388). All contractors are required to notify Seqwater s Incident Hotline ( ) of any incidents or near misses and WHSQ of any notifiable incident or dangerous event as required by the Work Health and Safety Act 2011 (Qld), Work Health and Safety Regulation 2011 (Qld), Electrical Safety Act 2002 (Qld) and the Electrical Safety Regulation 2013 (Qld). Contractors will be requested by the Project Manager to provide Seqwater the following in writing as soon as practicable: Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 20 of 32

21 a report of the incident a copy of the incident investigation report, including outcomes of all incident investigations details of corrective actions implemented as a result of the investigation. All contractor WHS incidents will be investigated in consultation with the Project Manager and in accordance with WHS Incident Investigation Procedure (PRO ). Details of the incident investigation will be recorded in Risk Wizard with the documentation saved in the project folder in TRIM Contractor non-conformance If during the performance of work under the contract it is observed that the contractor is: not conducting the work in compliance with WHS legislation, WHS management plans or SWMS conducting the work in such a way as to endanger the safety of workers or the general public. The person observing the unsafe behaviour must direct the contractor to immediately cease the activity, make safe, remedy the WHS breach and notify the Project Manager. The Project Manager will issue a Notice of Non-Conformance (FRM-00517). If the WHS breach is not rectified as requested, the Project Manager will direct the contractor to suspend all work until such time as the contractor provides evidence to the Project Manager that the work will be resumed in a safe manner. Where a notice of non-conformance is issued, the contractor will be required to identify the root cause/s of the non-conformance and implement corrective and preventative actions within a specified timeframe. The timeframe for correction will be set following consultation with the contractor. The status of corrective and preventative actions shall be regularly reviewed and reported at project/site meetings until completion. Where these actions have not been carried out to the satisfaction of the Project Manager, contractual sanctions may be invoked. If the contractor fails to rectify any breaches of WHS for which work has been suspended, or if the contractor s performance has involved recurring breaches of WHS, Seqwater may terminate the work forthwith in accordance with, and subject to, the relevant contract terms, depending on the severity of the issue. All non-conformances and investigations raised will be communicated to stakeholders and recorded in Risk Wizard by the WHS Team with the documentation being saved in the project folder in TRIM. 7.5 Stage five contract closure Contract closure is a four step process with the final stage completed when the defects and liability period has ended. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 21 of 32

22 7.5.1 Practical Completion Works are commissioned and, for a construction project for which a Principal Contractor has been appointed, control and management of the workplace is formally handed back to Seqwater Site hand back The Principal Contractor relinquishes management and control of the site to Seqwater. As part of handover the Project Manager must confirm that: all required documentation and training of new installations, including safety processes have been undertaken with all relevant stakeholders a final site inspection to check that the site is free of hazards and any known hazards are controlled is conducted with the Principal Contractor, the Project Manager and a WHS Regional Advisor updates have been made to the relevant WHS risk registers, confined space register, hazard chemical register and asbestos register where required new or modified asset information is updated in CIS Contractor evaluation After the completion of each contract, the Project Manager shall review and evaluate the contractor s WHS performance. The result of the review and evaluation will form part of the overall evaluation process for future tenders. The contractor WHS evaluation is to be completed in line with the Procurement Procedure (PRO-01514) Defects Liability Period The Project Manager is to engage the WHS team where required during the defects liability period if there are any concerns that related to WHS. 8. Training requirements Training will be provided in accordance with the Training and Competency Management Procedure (PRO-01574). WHS workplace inductions will contain information about contractor management. Any training provided in relation to procurement or management of contractors will be addressed as part of the procurement management training and detailed in the Procurement Procedure (PRO-01514). This training will include information on WHS contractor management. 9. Monitoring and audit The application of this procedure shall be audited in accordance with the WHS Internal Audit Schedule and the Integrated Management System Internal Audit Procedure (PRO-00002). Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 22 of 32

23 10. Record keeping All records are to be retained, archived and disposed of in accordance with the Queensland State Archives General Retention and Disposal Schedule for Administrative Records. All WHS records (including WHS management plans and JSEA/SWMS) will be retained in project files in TRIM as required to fulfil the WHS legislative requirements. Details of all contractor WHS inspections, audits and incident investigations will be recorded in Risk Wizard. 11. References 11.1 Legislation and other requirements Description Status Location AS/NZS 4801:2001 Occupational Health & Safety Systems Specifications with guidance for use. Building & Construction Industry WHS Guide u/ data/assets/pdf_file/0009/ 82764/constructionorangebook.pdf Electrical Safety Act Electrical Safety Regulation 2013 Queensland State Archives General Retention and Disposal Schedule for Administrative Records rdkeeping/retentiondisposal/p ages/grds.aspx Work Health and Safety Act Work Health and Safety Regulation Supporting procedures Description Status Location MAN WHS Management System Framework MAN Delegations and Authorisations Manual PRO Engineering Review and Approval Procedure PRO WHS Communication, Consultation and Issue Resolution Procedure PRO Procurement Decision Matrix Procedure QPulse QPulse QPulse QPulse QPulse POL Procurement Policy QPulse Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 23 of 32

24 PRO Procurement Procedure PRO WHS Hazard Identification and Risk Management Procedure PRO WHS Incident Investigation Procedure PRO Incident Notification Procedure PRO Integrated Management System Internal Audit Procedure PRO WHS Reporting Procedure PRO Permit Access Safety System Procedure PRO Training and, Competency Management Procedure QPulse QPulse QPulse QPulse QPulse QPulse QPulse QPulse 11.3 Supporting documents, forms and templates Description Status Location Notice of Non-Conformance (FRM ) WHS Risk Register Template (TEM ) Job Safety and Environment Analysis/Safe Work Method Statement Template (TEM-00013) QPulse QPulse QPulse 12. Definitions Term Approved contractor Construction project Construction work Definitions A contractor that has met Seqwater s WHS and commercial requirements and performance through the tender evaluation process. A person conducting a business or undertaking engaged in work/service done on a Seqwater site or works done off site for installation on a Seqwater site. May be used in reference to the company or an individual. A project which involves construction work costing $250,000 or more. Any work carried out in connection with the construction, alteration, conversion, fitting-out, commissioning, renovation, repair, maintenance, refurbishment, demolition, decommissioning or dismantling of a structure. Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 24 of 32

25 Term Consultation Contractor Employee High risk construction work Definitions This includes: any installation or testing carried out in connection with an activity mentioned above the removal from the workplace of any product or waste resulting from demolition the prefabrication or testing of elements, at a place specifically established for the construction work, for use in construction work the assembly of prefabricated elements to form a structure or the disassembly of prefabricated elements forming part of a structure the installation, testing or maintenance of an essential service in relation to a structure any work connected with an excavation any work connected with any preparatory work or site preparation (including landscaping as part of site preparation) carried out in connection with an activity mentioned above an activity mentioned above that is carried out on, under or near water, including work on buoys and obstructions to navigation. Relevant information is shared with workers and they are given a reasonable opportunity to: express their views and to raise WHS issues contribute to the decision-making process Seqwater will take the views of workers into account. Workers consulted are advised of the outcome of the consultation in accordance with the WHS Consultation, Communication and Issue Resolution Procedure (PRO-00870). Any person or firm engaged under contract by Seqwater to undertake work. A contractor is not an employee. A person who is employed by Seqwater. As defined in s.291 of the Work Health and Safety Regulation 2011 (Qld) high risk construction work means construction work that involves any of the following: involves a risk of a person falling more than 2m is carried out on a telecommunication tower involves demolition of an element of a structure that is load-bearing or otherwise related to the physical integrity of the structure involves, or is likely to involve, the disturbance of asbestos involves structural alterations or repairs that require temporary support to prevent collapse is carried out in or near a confined space is carried out in or near a shaft or trench with an excavated depth greater than 1.5m or a tunnel involves the use of explosives Doc owner: Manager, WHS Doc approver: General Manager, SPS Rev no. 9 Page 25 of 32