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1 CONTRACTOR ACCOUNTIBILITY TO SAFETY PROGRAM (CASP) Section: Hazard Control Date of Issue: Issued By: Environment, Health &Safety Part: Administrative Programs Revision #: 4 Revision Date: Pages: 13 Revised By: TRW Contents 1 Introduction Roles and Responsibilities University of Calgary Environment, Health and Safety Prime Contractor University of Calgary as Prime Contractor The University Contact Assignment of Prime Contractor Status General Contractor Sub - Contractor Contractor Basic Occupational Health and Safety Requirements Contract Requirements Pre - Qualification General Pre - Qualification Specific Verification University and Site Safety Orientations Authorization and Identification Hazard Assessment Inspections Incident / Accident Reporting Performance Review Documentation Program Review References and Additional Resources Definitions Appendix AREA WORK PERMIT / POSTING PROCEDURE AREA WORK PERMIT / POSTING FORM CASP ORIENTATION / TRAINING PROCESS Page 1 of 13

2 1 Introduction The University of Calgary is committed to promoting the health, safety and well-being of its employees, students, visitors and contractors, as well as providing a safe and healthy environment in which to conduct activities, in accordance with the University of Calgary Occupational Health & Safety Policy and applicable Legislation. The University will meet or exceed the legislated requirements made under the Alberta Occupational Health and Safety Act, Regulation and Code. All contractors are required to meet or exceed the Alberta Occupational Health & Safety Act, Regulation and Code, and conduct their activities in accordance with the applicable University policies & procedures and applicable Legislation. The University has developed a comprehensive Contractor Accountability to Safety Program (CASP) for all contracted workers, including prime contractors, general contractors, sub-contractors, service providers and consultants. Contractor occupational health and safety performance is a critical factor in the awarding and renewal of University contracts. 2 Roles and Responsibilities The Alberta Occupational Health & Safety Act, Regulation and Code as well as University policies and procedures dictate specific requirements for all contracted workers. The University Environment, Health and safety department is a resource available to assist and facilitate the contractor with accountability to safety process. 2.1 University of Calgary Environment, Health and Safety Supports and coordinates the Contractor Accountability to Safety Program. Delivers the CASP orientation sessions to contractors working on the University Campus. Coordinates and assists University Contacts supervising contractors to resolve health and safety issues effectively and efficiently. Immediately communicates all health and safety concerns to the appropriate site supervisor or contractor. If required, University of Calgary EH&S has the authority to stop work if conditions or concerns are Immediately Dangerous to Life or Health. 2.2 Prime Contractor The Prime Contractor must comply with the Alberta Occupational Act, Regulation and Code, specifically Section 3 of the Act, and all applicable University policies and procedures. Page 2 of 13

3 Alberta Occupational Health & Safety Act - Prime contractor 3(1) Every work site must have a prime contractor if there are 2 or more employers involved in work at the work site at the same time. (2) The prime contractor for a work site is (a) the contractor, employer or other person who enters into an agreement with the owner of the work site to be the prime contractor, or (b) if no agreement has been made or if no agreement is in force, the owner of the work site. (3) If a work site is required to have a prime contractor under subsection (1), the prime contractor shall ensure, as far as it is reasonably practicable to do so, that this Act and the regulations are complied with in respect of the work site. (4) One of the ways in which a prime contractor of a work site may meet the obligation under subsection (3) is for the prime contractor to do everything that is reasonably practicable to establish and maintain a system or process that will ensure compliance with this Act and the regulations in respect of the work site. Reference: Alberta Occupational Health and Safety Bulletin re: Prime Contractor Section 3(1) of Alberta s Occupational Health and Safety Act requires a prime contractor whenever two or more employers are engaged in work at a work site. The two employers may not be working at the same time at the site, but their activities may have a health and safety impact on each other or are interrelated. The prime contractor is responsible for coordinating potentially incompatible internal health and safety systems of multiple employers, and for coordinating effective communication in relation to health and safety at a worksite. This is necessary as different employers may all have very effective, independent health and safety systems but which might not be compatible with other employers systems. Furthermore, a lack of effective communication and a cohesive approach to health and safety may place workers at risk. As a high level oversight or auditing function the prime contractor is expected to monitor activities to ensure that a worksite s health and safety system is functioning properly. Reference: University of Calgary as Prime Contractor The University Contact Unless otherwise specified the University of Calgary, as the owner of the worksite, assumes the role of the prime contractor. The roles and responsibilities of the prime contractor are assigned to an employer representative designated as the University Contact. The University Contact may be one of the following people: Program Manager Project Manager or Coordinator Facilities or Zone Manager Zone Operator, or A Departmental or Faculty contact. University Contacts are employer representatives of the University. In situations where the University of Calgary acts as the prime contractor, the University Contact has the following responsibilities in addition to those identified above within Alberta Occupational Health & Safety legislation: Ensures that a site specific orientation is conducted. Performs periodic documented project work site inspections under their authority and control to ensure that occupational, health and safety requirements are adhered to. Page 3 of 13

4 Communicates inspection findings affecting the health and safety of any student, staff, worker, contractor or visitor through written and/or verbal correspondence to the appropriate authority. Communicates to the contractor their health and safety responsibilities and performance accountability to those identified responsibilities. Collaborates with contractors on identified or reported concerns and mediates to resolve issues effectively and efficiently. Adheres to occupational, health and safety rules and regulations. Completes the Area Work Permit/Posting and posts it at each entrance to the worksite Note: a copy must be sent to EH&S and Campus Security as described in appendix Reports all incidents / injuries to EH&S and initiates the appropriate documentation as per the University s online accident reporting system: Immediately communicates all health and safety concerns to the appropriate site supervisor and/or contractor. If required, the University Contact has the authority to stop work if conditions or concerns are Immediately Dangerous to Life or Health. See Appendix Area Work Permit/Posting Procedure See Appendix Area Work Permit/Posting Form Assignment of Prime Contractor Status The University of Calgary, as the owner of the worksite, may assign prime contractor status and associated responsibilities to a contractor by written agreement. Assignment of prime contractor status legally transfers the requirements of coordinating effective communication in relation to occupational health & safety at the worksite to the designated Prime Contractor. The University, through the University Contact, remains an integral part of the contractor accountability to safety process. The University may assign a specific worksite within a larger worksite to a contractor and transfer, by agreement, the health & safety responsibilities of Prime Contractor to that contractor to the specific worksite within the larger worksite. This smaller work site must be clearly defined. Vehicle and foot traffic between the worksites and the University must be controlled by a physical barrier and so be treated as a separate worksite within a worksite. In situations where the University of Calgary assigns Prime Contractor status to a contractor, the University Contact has the following responsibilities: Audits prime contractor s Safety Management System on a regular basis - for example ensures hazard assessments are completed, inspections are conducted, safety meetings are documented, orientations are delivered, and, incidents/accidents are reported and investigated. Collaborates with the prime contractor on identified or reported concerns to resolve issues effectively and efficiently. 2.3 General Contractor General contractors, including system contractors, service providers, and consultants, must comply with the Alberta Occupational Act, Regulation and Code, and all applicable University policies and procedures. 2.4 Sub - Contractor Any sub-contractor hired by a general contractor or contractor must comply with the Alberta Occupational Act, Regulation and Code, and applicable University policies and procedures. Page 4 of 13

5 3 Contractor Basic Occupational Health and Safety Requirements The Alberta Occupational Health and Safety Code requires Alberta employers and workers to comply with very specific requirements for any workplace within the Province. These requirements can be found at the following links: Alberta Occupational Health & Safety Code: Explanation guide to the Alberta Occupational Health & Safety Code: A small selection of these requirements is listed below: Ensure first aid services, equipment, and supplies required by the Alberta Occupational Health & Safety Code Schedule 2 are available at the work site. Take all necessary steps to protect all workers and third parties from injury or illness. Ensures all equipment provided by the contractor is maintained in safe working order as per the manufacturer s specifications. All work procedures must meet or exceed applicable legislation and/or industry best practices; Must provide competent supervision at the work site. Must ensure only qualified workers, or workers working under the direct supervision of another competent worker, are permitted to conduct work activities at the worksite. Must ensure all necessary personal protective equipment is worn properly and maintained in serviceable condition. Must investigate and resolve identified health and safety issues and concerns within their worksite as soon as reasonably possible. Copies of these reports must be forwarded to the appropriate University Contact who must contact Environment Health and Safety (EH&S) within 24 hours of notification. Implement their company s disciplinary policy for any worker who does not comply with health and safety requirements. Must inform the workers of the hazards and the control measures utilized to eliminate, minimize, or, control those hazards by way of a written hazard assessment. The hazard assessment must be available to workers at the worksite. Must educate all workers on their right to refuse unsafe work and how to exercise that right when appropriate. Must complete regularly scheduled inspections and inspection reports must be readily available upon request. Have a written emergency response plan in place and available to workers at the worksite. Ensure all incidents/accidents are investigated and recommendations implemented. Ensure all staff and visitors receive adequate orientation. 4 Contract Requirements 4.1 Pre - Qualification General The University uses a pre-qualification process as a screening method for preferred contractors. These general pre-qualifications are for both General Contractors and Service Providers. Good performance standing with the University of Calgary. A verified occupational health & safety management system. Certificate of Recognition (COR), Small Employer Certificate of Recognition (SECOR) or an active health and safety manual accompanied with a Letter of Intent to obtain a COR or SECOR. Proof of an account in good standing with WCB including the company s experience rating assessment. This written document must be current (within 30 days of application). Page 5 of 13

6 4.2 Pre - Qualification Specific The contract bid must include a list of all specialized trades needed to complete the project or fulfill the contract requirements. This list must include in detail the education and training, both trade specific (i.e. trade ticket or journeyman certification) as well as all applicable and current safety training of the workers designated under the contract (i.e. first aid). 4.3 Verification All applicable stakeholders, including Supply Chain Management, Facilities Maintenance and Development, Environmental Health &Safety, Risk Management, and/or other departments, must review and evaluate all of the required documentation to verify that the contract requirements can be met by the contractor. 5 University and Site Safety Orientations All contracted workers (General and Sub Contractors) who perform work or intend to perform work on University owned or leased facilities must attend the General University Orientation offered by EH&S (CASP Orientation). This orientation is designed to inform workers of University policies, procedures, and identify potential hazards. Only those workers who have completed the orientation will be authorized to work at the University. When laboratories are part of the worksite, a laboratory tour should be conducted by the project manager and EHS as part of the pre-project hazard assessment due to the higher hazard potential. Contracted workers must attend an additional orientation if roof access and/or tunnel access is required. The University Contact will facilitate access to these orientations. Prime Contractors must conduct their own orientations designed to inform workers of their company s policies, procedures and identify potential hazards. Prime contractors may work with the university EH&S department to include relevant sections of the General University Orientation into their orientation. In situations where the University acts as Prime Contractor, the University Contact is responsible to ensure that a site specific orientation is conducted. This orientation should include, but is not limited to: Occupational Health and Safety Requirements Emergency Response Worksite Specific Hazard Assessment Reporting Requirements Notification Requirements Security Requirements Personal Protective Equipment (PPE) Requirements Worksite tour See Appendix CASP Orientation / Training Process 5.1 Authorization and Identification A Person of Interest (POI) relationship must be established with the University if a contracted worker requires access into sensitive or restricted spaces. The University of Calgary Human Resources department is responsible for processing the POI relationships. They can be reached at or The University ONEcard office ( will issue University of Calgary photo identification / security access cards following the development of a POI relationship. Workers must attend the ONEcard office with Government issued photo ID in order to create a university ID. Page 6 of 13

7 The University Contact or project manager will facilitate the POI process. 6 Hazard Assessment Where the University is the Prime Contractor a Hazard Assessment must be performed by the University Contact. A hazard assessment is an assessment of the work site to identify existing and potential hazards that may impact the safety of employees, staff, University operations, the public or the environment. The hazard assessment must be performed prior to any work beginning at the work site. The University EHS department is available to assist. Where the University of Calgary assigns Prime Contractor status to a contractor, the contractor must conduct a hazard assessment prior to any work beginning at the work site. A Prime Contractor would be responsible to assess and evaluate any sub-contractor s hazard assessment to ensure compatibility between all related worksite activities. The University Contact and EH&S have the following responsibilities when Prime Contractor responsibility is assigned: Audits the Prime Contractor s Hazard Assessments on a regular basis. Hazards Assessments are to be reviewed and/or updated: At reasonably practicable intervals to prevent the development of unsafe and unhealthy working conditions When a new work process is introduced within the worksite; When a work process or operation changes. When there is a work site accident/injury/incident Hazard Assessments must be readily available to all workers at the worksite to ensure all workers affected by the hazards are informed of the hazards and the methods used to control or eliminate the hazards. 7 Inspections All contractors are required to perform regular worksite inspections. The written inspection must document any necessary actions to be taken, who is responsible for completion of those actions, and, anticipated timelines to correct any identified unsafe condition and/or work practice. The inspection process must include a follow-up process to ensure previously identified unsafe conditions and/or work practices are corrected. The contractor may be required to demonstrate due diligence in that the corrective actions were completed in a timely manner. These reports must be available for review upon request. In circumstances where the University has Prime Contractor responsibility inspections are required to be conducted by the University Contact with the contractor. The University EHS department is available to assist. When a recommendation is made to correct an unsafe act or condition, written documentation and follow up must be completed to verify the correction of the unsafe act or condition. This information should be recorded as part of the appropriate project files under performance. Page 7 of 13

8 8 Incident / Accident Reporting The University of Calgary requires the reporting of all incidents, which includes; sudden or unforeseen events which could cause or have caused an injury or occupational illness; a release of hazardous materials to the environment; or a near miss. University of Calgary contractors must immediately report all incidents to their supervisor, University Contact, or next higher authority as available. Supervisors and University representatives are responsible for the classification of the incident, completing the reporting, and other actions as listed below. Incidents / accidents occurring when the University of Calgary is Prime Contractor must be internally reported utilizing the on-line accident reporting system (OARS) by the University Contact. In situations where Prime Contractor has been assigned to the contractor, the contractor must report to their University Contact all level 2 and 3 incidents and provide copies of the incident investigations and reports following their own internal reporting system. Level 1 Incidents First aide with no lost time (temporary, immediate care). Minor incident with no lost time. Spill or release not reportable to AB Environment or City of Calgary but more than 5 liters or kilograms. Near miss: Any undesired event or incident that under slightly different circumstances could have resulted in personal injury, illness, environmental release, or loss. Level 2 Incidents Medical aid with no lost time (medical care beyond first aid). Injury reportable to WCH with no lost time. Occupational disease (illness) reportable to WCB with no lost time. Spill or release reportable to AB Environment or City of Calgary that is not an adverse effect or contravention of an approval, license or Code of Practice. Chemical spill resulting in injury or exposure. Motor vehicle accident. Level 3 Incidents Injury reportable to WCB with lost time. Occupational disease (illness) reportable to WCB with lost time. Injury or accident that results in death. Injury or accident that results in a worker being admitted to hospital for more than two days. Unplanned or uncontrolled explosion or fire that causes a serious injury or that has the potential to cause a serious injury. Unplanned or controlled flood that causes a serious injury or that has the potential to cause a serious injury. The collapse or failure of any component of a building or structure necessary for the structural integrity of the building structure. The collapse or upset of a crane, derrick or hoist. Release of dangerous goods reportable under the Transportation of Dangerous Goods Act. Spill or release reportable to AB Environment or City of Calgary that is an adverse effect or contravention of an approval, license or Code of Practice. Page 8 of 13

9 9 Performance Review A contractor performance review will be conducted, as needed, by the appropriate stakeholders. The contractor performance review may include: Review of contract requirements Review of hazard assessments Review of inspections Review of tool box meeting minutes Review of building inspection reports Review of reported unsafe acts or unsafe conditions present while on University property and if corrective actions were made in a timely manner 10 Documentation The University of Calgary Environment, Health and Safety Department (EHS) will maintain the CASP program and will ensure a database is maintained confirming the attendance of contracted workers to both the CASP and Roof Access Orientation sessions. Facilities Management and Development as well as the Supply Chain Management groups will maintain a list of preferred contractors who have completed the requirements as outlined under CASP. Facilities Management and Development will retain copies of Hazard Assessments and Area Work Permits/Postings and inspection reports associated with their relevant projects. 11 Program Review The goal of program review is to continuously improve the Contactor Accountability to Safety Program. Environment, Health and Safety will coordinate the CASP review annually or as required. The evaluation must include a review of the written program. 12 References and Additional Resources 2006 Alberta Occupational Health and Safety Act, Regulation and Code Alberta OHS Explanation Guide Safety Bulletin LI018 The Prime Contractor University of Calgary Environment, Health & Safety University of Calgary Environment, Health & Safety CASP Course Page 9 of 13

10 13 Definitions Competent Worker An individual, who is adequately qualified, suitably trained and has sufficient experience to safely perform work without supervision or with a minimal degree of supervision. Consultant - A contractor that is hired to be an advisor, resource and/or complete tasks specific to their field of expertise that are on campus to perform work. Contractor A person or group of people that have been awarded a contract to perform work on the University of Calgary s owned or leased property. Letter of Intent A written document stating the contractor is committed to acquiring a mandatory Certificate of Recognition (COR) or Small Employer Certificate of Recognition (SECOR) and a copy of the certificate be provided to the University within one year of application. Owner The University of Calgary. Project Any work requested by a department that is coordinated by University Facilities Maintenance and Development, or, other University Contact. Prime Contractor The prime contractor for the worksite is the University of Calgary, unless this status has been legally transferred to a contractor by the University of Calgary through a written agreement. System or Service Provider A person or group of people who provide ongoing services to the University and are on campus to perform work. Services may be on departmental equipment (i.e. photocopiers). Supplier A contractor that is in transit and is only on campus for the duration of the delivery of goods. University Contact Is a university employee who is the primary contact for the contractors conducting work at the University of Calgary. University Contacts are employer representatives of the University and may be one of the following: Program Manager Project Manager or Coordinator Property or Zone Manager Zone Operator, or A Departmental or Faculty contact. 14 Appendix 14.1 Area Work Permit - Procedure 14.2 Area Work Permit - Form 14.3 CASP Orientation / Training Process Page 10 of 13

11 14.1 AREA WORK PERMIT / POSTING PROCEDURE Section: Contractor Accountabiltiy to Safety Program Date of Issue: Issued By: Environment, Health &Safety Part: Administrative Programs Revision #: 1 Revision Date: Pages: 1 Revised By: TRW University of Calgary Area Work Permit/Posting requirements are applicable to any temporary construction project, maintenance work, or, a smaller specific worksite where the University has transferred prime contractor responsibilities to the contractor, and, will take 6 hours or more to complete. Such operations include, but are not limited to, abatement, construction, demolition and restoration. Additional requirements such as Hazardous Material Assessments and Laboratory Safety Clearances may be required depending on project scope. NOTIFICATION & POSTING REQUIREMENTS: The University Contact for each construction project or maintenance work shall ensure all safety requirements outlined on the University of Calgary Area Work Permit/Posting Requirements are followed. The University Contact for each construction project or maintenance work is responsible to ensure a completed Area Work Permit/Posting is posted at the worksite. The University Contact must , or send a completed copy of the University of Calgary Area Work Permit/Posting form to Environment, Health & Safety (EH&S) ( and, Manager - Campus Security, Ken Kress at least two working days prior to the work starting. Environment, Health & Safety (EH&S) will keep a copy of the Area Work Permit/Posting on file. Environment, Health & Safety or the University Contact may inspect any contractor project or maintenance worksite at any time Environment, Health & Safety and the University Contact have the authority to stop any unsafe work and will not permit work to begin or continue until the unsafe act or condition has been corrected. Compliance with the Alberta Occupational Health & Safety Act, Regulations and Code must be demonstrated. Contractors must fully understand their Occupational Health & Safety responsibilities and be in compliance with Alberta Occupational Health and Safety legislation and University of Calgary policies & procedures. CHECKLIST FOR ALL AUTHORIZED CONTRACTORS PERFORMING WORK: All contractors on site have participated in the U of C Orientation by EH&S. Hot Works Permit and Procedures are understood and followed as needed All contractor generated waste must be disposed of by the contractor in accordance with U of C guidelines. Written hazard assessment and written standard work procedures are available on site Contractor tools and equipment are in proper working order Workers are aware of hazards and control measures in place Fully stocked First Aid kit and trained First Aid provider must be available onsite Only authorized contractor workers will be within the worksite area. Note: University workers who must work in the worksite to perform their regular duties are authorized. Page 11 of 13

12 14.2 AREA WORK PERMIT / POSTING FORM Section: Contractor Accountabiltiy to Safety Program Date of Issue: Issued By: Environment, Health &Safety Part: Administrative Forms Revision #: 1 Revision Date: Pages: 1 Revised By: TRW PROJECT / WORK REQUEST INFORMATION Project/WR Number: Project Location: Start Date: Completion Date: Scope of Work: PRIMARY CONTACTS Emergency Contact: Campus Security: Project Manager / Coordinator s Name: Contact Phone: EH&S Consultant: After Hours Phone: Phone: CONTRACTOR INFORMATION General Contract Company: Contact name: Cell Phone: Contract Company: Contact name: Cell Phone : Contract Company: Contact name: Cell Phone: Contract Company: Contact name: Cell Phone: Contract Company: Contact name: Cell Phone: Page 12 of 13

13 14.3 CASP ORIENTATION / TRAINING PROCESS Section: Contractor Accountability to Safety Program Date of Issue: Issued By: Environment, Health &Safety Part: Orientation & Training Revision #: 3 Revision Date: Pages: 2 Revised By: TRW The University of Calgary is committed to promoting the health, safety and well-being of its employees, students, visitors and contractors, as well as providing a safe and healthy environment in which to conduct activities, in accordance with the University of Calgary Occupational Health & Safety Policy. The University of Calgary will meet or exceed the legislated requirements made under the Alberta Occupational Health and Safety Act, Regulation and Code. All contractors are required to meet or exceed the Alberta Occupational Health & Safety Act, Regulation and Code, and conduct their activities in accordance with the applicable University policies and procedures. CASP Orientation All contracted workers who perform work or intend to perform work on University owned or leased facilities must attend the Contractor Accountability to Safety Program (CASP) Orientation offered by EH&S. Orientation is designed to inform workers about University policies and introduce unique hazards which may be found within the contractor s worksite. When laboratories are part of their worksite, a laboratory tour should be included as best practice and as part of the pre-project hazard assessment by the University Contact. General contractors are responsible to ensure all their sub-contractors hired to work at the University of Calgary attend the Contractor Accountability to Safety Program (CASP) Orientation. Prime Contractors must conduct their own orientations designed to inform workers of their company policies, procedures and identify potential hazards. Prime contractors may work with the university EH&S department to include relevant sections of the University Orientation into their orientation. All contracted workers who perform work or intend to perform work on University owned or leased facilities must attend an additional orientation if roof access and/or tunnel access is required. The Roof Access orientation follows the CASP orientation. Contact Facilities Management at for the Tunnel Access Orientation. Authorization and Identification A Person of Interest (POI) relationship must be established with the University if a contracted worker requires access into sensitive or restricted spaces. The University of Calgary Human Resources department is responsible for processing the POI relationships. They can be reached at or The University ONEcard office ( will issue University of Calgary photo identification / security access cards following the development of a POI relationship. Workers must attend the ONEcard office with Government issued photo ID in order to create a University ID. The University Contact or project manager will facilitate the POI process. Page 13 of 13

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