CONTRACTOR ENVIRONMENTAL HEALTH AND SAFETY PROGRAM

Transcription

1 Revision: 1 Page 1of 10 CONTRACTOR ENVIRONMENTAL HEALTH AND SAFETY PROGRAM WARNING This document is the property of United Technologies Corporation (UTC). You may not possess, use, copy or disclose this document or any information in it, for any purpose, including without limitation to design, manufacture, or repair parts, or obtain FAA or other government approval to do so, without UTC's express written permission. Neither receipt nor possession of this document alone, from any source, constitutes such permission. Possession, use, copying or disclosure by anyone without UTC's express written permission is not authorized and may result in criminal and/or civil liability. APPLIES TO: UTC Connecticut and Maine Manufacturing Operations 1 PURPOSE AND SCOPE: This procedure sets forth requirements for an environment, health and safety contractor management process for all contractors and guests performing services at UTC facilities. It defines a fully integrated process by which the procedure shall be implemented. Implementation of this procedure will assist UTC sites in complying with the requirements of UTC EH&S Standard Practice 010, Contractor Environment, Health and Safety Program. For the purpose of this procedure a Contractor/Subcontractor is any non-utc person or persons who have been authorized by a UTC operation to work on the premises of a UTC site. Persons who perform work as a subcontractor to an authorized UTC contractor and who meet these criteria are subject to this procedure. Other suppliers of goods or services are not subject to this procedure. Guests or visitors who are not cleared by Emergency Services are issued a visitors badge when on site, and who must be escorted at all times while on site by an authorized UTC employee (e.g. FedEx, Common Carriers, Customers, Sales Personnel, etc.) are not covered by this procedure. 2 OWNERSHIP AND APPROVAL: The Director, UTC Facilities & Services owns this procedure. The owner, or designee, must approve any revisions, with the concurrence of the UTC Site Facility Managers. 3 DEFINITIONS: 3.1 Contractor Coordinator: Any UTC employee who is responsible for giving direction to or otherwise has authority over a contractor, and has completed the required training outlined in this procedure. Employees assigned to this role should oversee contractor activities on a frequent enough basis (i.e. at least once a month) to ensure that they are able to maintain their proficiency. 3.2 Competent Person: a person capable (via training and experience) of identifying existing and predictable hazards in the surrounding or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures (See paragraph 4.5.3). Unpublished Work United Technologies Corporation 2003 COPIES PRINTED FROM THE ON LINE SYSTEM ARE CONSIDERED UNCONTROLLED

2 Page 2 of Emergency Services: Protective Services, Fire Department, or Security Department, depending on the division or facility. 3.4 Level I Contractors: Any other person performing work, or providing services that do not meet the definition of a Level II or Level III contractor service (e.g. Credit Union Employees, Office Equipment Repairs, Cafeteria Personnel, Office Staff, etc.) 3.5 Level II Contractors: Contractors whose services require them to work in the shop or other potentially hazardous work areas (e.g. process engineering consultants, equipment engineers, etc.), who service 110 volt office equipment (printers, copiers, fax machines, etc.) or delivery personnel who engage in material handling activities. Level II contractors do not perform trades type work (e.g. electrical, pipefitting, machine repair, etc). 3.6 Level III Contractors: Contractors such as general contractors, construction vendors, riggers/millwrights, painters, machine tool services vendors, and other vendors who use power tools and/or are engaged in activities that involve potentially hazardous chemicals or energy sources. 3.7 UTC EH&S Guidelines for Contractors Handbook: This handbook identifies specific environment, health and safety guidelines applicable to contractors and guests performing services for UTC. 3.8 UTC Site Contractor Program Administrator - Facilitator/Administrator of the Contractor/Guest EH&S program, responsible for ensuring effective implementation of the program, including maintaining certification of site Contractor Coordinators. The Senior Site Facilities Manager will carefully select individuals fulfilling this responsibility. The Site Contractor Program Administrator must demonstrate EH&S knowledge and performance and have experience working with contractors. 3.9 UTC Contractor Coordinator Level III Representative Requires the highest level of proficiency. Capable of managing Contractors /Guests on a day-to-day basis at all risk levels UTC Contractor Coordinator Level II Representative Capability limited to handling Level II contractor services and Guests UTC Level I Representative Acts as a company representative responsible for the Level I contractors as well as an escort for visitors who do not perform work or provide services for UTC. No formal contractor program training required Serious Violation of the UTC EH&S Guidelines for Contractors - Practices contrary to current standards which result in a serious near miss, reportable spill, serious injury, or any combination of these

3 Page 3 of 10 4 PROCEDURE 4.1 Roles and Responsibilities The Senior Site Facilities Manager is responsible for ensuring implementation of this procedure at each facility. Each Site will have a minimum of one UTC Site Contractor Program Administrator with the responsibility for administering and facilitating the Contractor/guest EH&S process and its guidelines Only the Senior Site Facilities Manager or Site EH&S Manager may grant exceptions to this policy The UTC Site Contractor Program Administrator shall oversee all Site Contractor Coordinators and assure uniform application of this process. They shall also communicate new requirements to Contractors as they go into effect Contractor Coordinators have the responsibility for day-to-day administration of contractors and oversight of visitors/guests Visitors and delivery personnel entering UTC sites must be knowledgeable of all applicable site rules and regulations All contractor supervision and guests must communicate in English with sufficient proficiency to assure their health and safety, and that of their employees. Issues to consider should include the facility emergency evacuation alarm, MSDS hazard information for chemicals, the meaning of danger and warning signs in areas where they will work, etc The contractor is responsible for compliance with this procedure as incorporated into the contract, or otherwise communicated to ensure safe operations. The contractor will have a competent, well-trained supervisor in charge at all times when its employees or those of its subcontractors are present. 4.2 Contractor Coordinator Training and Certification - This process ensures that only trained and qualified UTC employees are assigned responsibility to oversee contractor activities. Training requirements are defined in the matrix provided in Appendix B. 4.3 Contractor Pre-qualification Process - The Pre-qualification process provides a systematic method for evaluating contractor s EH&S programs and historical performance. Contractor EH&S performance at UTC facilities will be improved by using only contractors who meet or exceed UTC requirements for EH&S compliance. Original equipment manufacturer service contractors, service contractors who are responding to random occurrence emergency calls on production equipment, and product supplier representatives are exempt from the pre-qualification process but are still required to follow the requirements listed in the guidebook, complete required EH&S training, and any background checks deemed necessary by Site EHS Manager, Site Facilities Manager, and the Site Security Manager.

4 Page 4 of All contractors and subcontractors are required to submit EH&S qualification information using the UTC Contractor Assessment form. Level I contractors need only supply general company information, Level II contractors must also supply worker s compensation information, and Level III must also supply injury and EH&S program information Minimum criteria - In order to select contractors with acceptable EH&S performance, the following minimum criteria have been established. Contractors, and any subcontractors that are hired for a UTC project, must meet the minimum criteria without consideration of other factors. Conditional approvals can be made, but must be approved by the Senior Site Facilities Manager and/or EH&S manager. Contractors with conditional approval to work on site must submit documentation that they are meeting the requirements set forth in the conditional approval to the EH&S department. Contractors will re-qualify every three years at a minimum. The following is the minimum criteria: Level III contractors must have a written Environment, Health and Safety program that meets all applicable federal, state, and local EH&S regulations applicable to their work. In addition, contractor programs must meet UTC EH&S requirements, and incorporate training that provides adequate EH&S and craft skills for the work. Level III contractors must have a system in place to understand/assess the risks and hazards of the proposed work, and to identify the means to address the risks. When project-engineering changes are made or when new hazards are identified in a process, operation or project, the risk assessment must be updated to address the new hazards and their relative risk. Level III contractors must have a Lost Work Day Incidence Rate less than or equal to 4. If total of 50 employees or less, conditional approval may be granted (e.g. annual submittal of assessment form showing progressive improvement). Level II and III Workers Compensation Insurance Experience Modification Rate for three years must be < 1.0. If total of 50 employees or less <1.5 may be considered Conditional approvals of one division are not binding on other divisions or facilities. 4.4 Management Exception: Site management will clearly define the process required to obtain deviation from the Pre-qualification process and will notify the safety representative of the hourly work force. Deviations will be documented and managed. Due to the serious nature of employing contractors with non-conforming safety performance, the Site Manager retains responsibility for approval of all deviation.

5 Page 5 of Selection and Approval: This process provides a framework for selecting and approving qualified contractors to provide services at UTC facilities. Contractors selected must be capable of performing services for UTC in compliance with applicable regulatory and UTC EHS requirements. Contract documents shall require Contractors to comply with regulatory, UTC and its respective divisions EHS requirements. Only qualified contractors will be awarded contracts Any project involving Level III Contractor work on a UTC site must have a Contractor Coordinator assigned to oversee the project. The Contractor Coordinator will define the specific EH&S requirements for each job based on the work to be performed and potential hazards in the work area. The EH&S Guidelines for Contractor handbook sets forth specific UTC requirements Pre-job Activities and Compliance Review - Prior to the start of work, a contractor must demonstrate capability to perform the work within regulatory and UTC requirements. The Contractor Coordinator will verify that contractor employees have the appropriate training and certifications, and that all hazards, including specific facility hazards, have been addressed and effective control measures have been established Level III projects involving high-risk hazards (determined at pre-job hazard review by UTC Level III Contractor Coordinator and/or UTC EH&S) shall be inspected on a daily basis by a Competent Person as defined in section 3. The Facilities Manager or the Facilities Engineering Manager may at his or her discretion, require these inspections be performed by a full time EH&S Professional employed or subcontracted by the contractor. Inspections shall be documented and submitted to the Contractor Coordinator The Contractor shall provide when requested: Documentation verifying current compliance with requirements identified during the selection process. Documentation that each employee assigned to the respective job is in compliance with the requirements identified during the selection and approval process The Project Contractor Coordinator shall: Ensure comprehensive site orientations for contractor personnel are completed. Ensure English language proficiency for each supervisory employee is sufficient to ensure employee safety and the safety of others. Ensure all contractor personnel have received appropriate training relative to hazards and EH&S requirements of the job. Ensure all contractor personnel understand specific job requirements. Determine safety hazard level and specify safety requirements. Review job for high hazard operations. Perform a pre-job assessment of all Level III projects with the Contractor and post the results at the job site.

6 Page 6 of 10 Determine and complete special training requirements based on the hazard level of the work to be done. Verify tool and equipment inspection requirements are met where required and compliance documentation requirements are satisfied Contractors or construction employees who fail to meet specific requirements at the Pre-job Activities and Compliance Review will not be permitted to perform the specified work Tailboard meetings shall be held at a frequency established by the Contractor Coordinator based on the level of risk associated with the work to be performed. The meetings shall be a review of completed tasks, upcoming or in progress hazardous tasks, and the control measures used. The Contractor EHS Web site manager can post exceptional tailboard meeting notes on the UTC Contractor EHS Web site for contractors to share Examples of High Risk Hazards that should be identified in the pre job assessment process may include but are not limited: High voltage work (600 volts and above) Steel Erection Building Demolition Erected Scaffolds Elevated work using Fall Arrest Systems Critical Lifts Trenching including shored trenching Confined Space Entry 4.6 Contractor EH&S Inspection Program- Each division/facility shall develop its own inspection process. The process shall include a means for identifying contractor EH&S issues and taking corrective action as well as addressing contractor activities that employees observe and believe are hazardous to the contractor or others. 4.7 Contractor EH&S Training - Contractors will be given the following instructions at the UTC Contractor EHS Training web site to assess the level of risk their work involves, and the appropriate level of training they must take based on that assessment. Note: hazards specific only to one site may require additional training prior to work start-up If you have a supervisory roll in the services your company provides (e.g. you are self supervised or supervise others when working at a UTC facility), or you will work on site under a picture badge in hazardous areas of a UTC facility, you require a higher level of training. As such, you are also responsible for ensuring that each employee who works for you at a UTC facility is thoroughly familiar with requirements in the EHS Guidelines for Contractors handbook that are applicable to the they work they perform.

7 Page 7 of If you do not have a supervisory role (you receive supervision from another employee of your company), or your services do not expose you to hazardous areas, you need the minimal amount of training. You are however expected to become familiar with and abide by the requirements of the UTC EHS Guidelines for Contractor handbook applicable to the work you perform at UTC The definitions from section 3 will follow Use the Training Selection Matrix below to determine which training module you must take. Starting at the left column, select the level of risk applicable to the service you provide and read across to the badge column representing the type of badge you will receive. Contractor Risk Level Picture Badge One Day Badge Supervisor* One Day Badge Level I Level I Training Level II Training Level I Training Level II Level II Training Level II Training Level I Training Level III Level III Training Level III Training Level I Training * Supervisors are those who oversee the activities of contractor employees working at a UTC facility, and any contractors who perform work at a UTC facility without any direct on-site supervision from their company. 4.8 Contractors who perform services on site as a visitor with a visitor s badge must be escorted by a Contractor Coordinator with the appropriate level of training for the risk levels associated with the work, or a designated UTC employee briefed by the Contractor Coordinator on all the risks and respective control measures. 4.9 Progressive Improvement Plan When any contractor has been observed violating any UTC or regulatory EH&S requirement, they shall be confronted by a qualified Contractor Coordinator to cease the activity and the violation reported to the contractor coordinator responsible for the job for follow-up and reporting as required. Contractor serious violations and injuries, serious incidents or serious near misses that are a result of a Contractor violation shall be reported to the facility EH&S department and logged in the UTC Contractor EHS Violations database The actions outlined in the Progressive Improvement Plan (see Appendix A) shall be implemented to address each violation based on the contractor s past performance Each facility shall have a Contractor EH&S Review Board to oversee the implementation of the Progressive Improvement Plan. The board shall consist of the Senior Site Facilities Manager and or the site EH&S manager at a minimum. Contractor Coordinators shall attend any Review Board meeting that one of their contractors must attend according to the Progressive Improvement Plan.

8 Page 8 of The Contractor EH&S Review Board at each facility may outline specific points to be assigned to inspection checklist items used at the site as they deem necessary to assist in consistent application Only the Contractor EH&S Review Board has the authority to apply more than 2 violation points for a serious violation. 5 NATURE OF CHANGE FOR THIS ISSUE 5.1 5/2/2006 Section 3 Added activity frequency for proficiency to Contractor Coordinator definition. Added definition for Competent Person. Added 110 volt office equipment to Level II Contractors definition. Added Serious Violation definition added requirement for Site Contractor Program Administrator to communicate changes to contractors. 4.3 added clarification that contractors exempt from assessment process are still required to follow all EHS requirements and 4.32 added verbiage describing the type of information required on the Contractor EHS assessment form for each contractor based on their risk level. 4.5 added requirement for contract documents to require contactor compliance to all regulatory and UTC requirements modified to require daily inspections by a competent person and an option for a full time safety professional. Deleted requirement to send inspection documents to EHS department Deleted requirement to review contract documents. Added requirement to perform pre-job assessment and post at job site added Building Demolition, Elevated work with Fall Arrest Systems, Shored Trenching and all Confined spaces to examples of High Risk Hazards requiring daily inspections added requirement to report contactor violations to Contractor Coordinators for follow-up and reporting as required added authorization for Contractor EH&S Review Board to define specific violation points for specific inspection checklist items added clarification that only the Contractor EH&S Review Board may assess more than 2 points for a violation. Moved Progressive Improvement Plan to Appendix A and Training Matrix to Appendix B. Included definition of serious violation in Progressive Improvement Plan 5.2 1/14/ Initial Issue

9 Page 9 of 10 APPENDI B PROGRESSIVE IMPROVEMENT PLAN Point Assessments Minor Violation: 1 point Serious Violation: 2-6 points (Serious violation of the UTC EH&S Guidelines for Contractors or practices contrary to current standards which result in a serious near miss, reportable spill, serious injury, or any combination of these) Category Points: Violations within the same chapter of the UTC EH&S Guidelines for Contractors handbook (e.g., Lockout Tagout, Confined Space, PPE) Total Points: Total of all violations, regardless of category. Category Total Division Improvement Action Points* Points* 1 Verbal Warning to Work Crew and Contractor 2 8 Written Warning to Contractor 3 10 Contractor Meeting with site Review Board 4 15 Work Crew 1 Suspended from site for 1 week and Contractor Suspended from bidding jobs at the site/division 2 for 6 weeks 5 20 Work Crew and Contractor suspended from site for 3 months 6 25 Contractor suspended from site indefinitely * - For violations/incidents within the last 24 months. 1 - Alternate work crew may be assigned to continue work 2 - Site or division suspension determined by review board Each Division has the right to reduce the number or total points that trigger any particular improvement action. UTC-Wide Consequences* Improvement Action 1 Divisional Suspension Written Warning 1 to Contractor Management 2 Divisional Suspensions 12 Week UTC Bid Suspension 3 Divisional Suspensions 1 Year UTC Bid Suspension 4 Divisional Suspensions Permanent UTC Site and Bid Suspension * - For suspensions within the last 24 months. A suspension at any division initiates the UTC-wide Improvement Action 1 - Including warning that Contractor is at risk of UTC-wide bid suspension. The intent of this plan is to raise the level of awareness concerning poor EH&S performance to succeeding levels of management within a contractor's organization, and thereby enabling management to implement effective corrective actions to avoid future violations and business interruptions.

10 Page 10 of 10 APPENDI A UTC CONTRACTOR COORDINATOR ROLES AND RESPONSIBILITY MATRI DESCRIPTION LEVEL II LEVEL III PROG ADMIN Knowledgeable of UTC EH&S requirements Has working knowledge of the following: Respiratory Protection Hearing Protection MSDS s PPE Requirements English Proficiency Environmental Release Reporting Accident/Incident Reporting Industrial Hygiene Monitoring Environmental Issues Knowledgeable about manufacturing process within their area of responsibility including hazards/msds Attended Contractor/Guest EH&S Guidelines Course Attended OSHA 510 Based Construction Industry Standard Course Attended Contractor EH&S Inspection Program Course Process Owner/Updates Site Program Procedure Responsible for in-house Contractor Coordinator Training Certifies Level II & III Coordinators in conjunction with the line organization to approve areas within which to work Responsible for ensuring continued education of Contractor Coordinators Liaison with EH&S Department and Purchasing Responsible for accumulation of inspection data Knowledgeable on: OSHA standards Site Safety Rules/Regulations Legal Issues Understands OSHA Record Keeping Guidelines Responsible for developing/updating site specific EH&S training and certification for Certified Representatives Has team leadership skills Facilitation/presentation/training skills Responsible to identify/develop potential successors Oversee inspection process Represents site for UTC program updates Perform Contractor Inspections Enter violation/incidents in Contractor Database * * * If authorized by the Site Program Administrator