Chapter 31 – SHJA Process – Subcontractor Job Hazards

Contents

Approved by Rob Connelly
Revised 1/22

31.1 Policy 
31.2 Scope
31.3 Applicability
31.4 Exceptions
31.5 Roles and Responsibilities
31.6 Definitions
31.7 Required Work Processes 

• Work Process A. SJHA Process Overview
• Work Process B. Creating an SJHA
• Work Process C. Training and Orientation

31.8 Source Requirements
31.9 Reference Documents

Note:
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31.1 Policy

The Subcontractor Job Hazards Analysis (SJHA) Program at Berkeley Lab is a work authorization tool that helps SJHA requesters take responsibility for ensuring that all non-construction subcontractor work is performed safely and in accordance with regulations by:

• Completing the Subcontractor Job Hazards Analysis (SJHA) online process
• Reviewing the SJHA and validating hazards and controls with the subcontractor
• Providing work oversight to ensure the subcontractor is performing the work as authorized

31.2 Scope

The Subcontractor Job Hazards Analysis (SJHA) Program applies to onsite, hands-on work performed by non-construction subcontractors, vendors and affiliates.

Each division must ensure that its subcontractors, vendors, and affiliates perform on-site work in compliance with Berkeley Lab Environment, Safety & Health (ES&H) requirements.  The SJHA process includes:

A pre-job meeting must occur between the SJHA requester and the subcontractor, vendor, or affiliate at which:

• The SJHA and any other required work authorizations, permits, site specific work plans, worker submittals, etc., are reviewed and/or signed.
• The ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates is reviewed and discussed.

31.3 Applicability

This policy applies to:

• All Berkeley Lab Divisions
• All hands-on work performed at Berkeley Lab facilities by non-construction subcontractors, vendors, and affiliates
• Subcontractors, vendors, and affiliates who perform non-construction, hands-on work at facilities owned or leased by Berkeley Lab

31.4 Exceptions

This policy does not apply to activities or services that do not involve onsite, hands-on work. Examples of service providers who may be excluded may include, but are not limited to:

• Consultants
• Personal services agreements
• Contract labor
• Intra-university transactions
• Advanced Light Source (ALS) and other user-facility affiliates addressed by another work authorization mechanism
• Other university agreements
• Subcontractors, vendors, or affiliates who are already covered by a Berkeley Lab’s Work Planning and Control Program

31.5 Roles and Responsibilities

Role	Responsibility
Managers, supervisors, and employees	Adhere to the provisions of this policy by ensuring that subcontractors performing hands-on work at their request have completed the SJHA process before work begins.
Division Safety Coordinator	Provides Environment, Safety & Health (ES&H) support to his or her division as needed for implementing the safety-assurance process defined in this chapter Requests support from the EHS Division SJHA Program Manager and EHS subject matter experts, when necessary
EHS Division SJHA  Program Manager	Provides guidance, leadership, and direct consultative services to the requesting division to guide implementation of the policy and requirements Monitors the Laboratory’s performance of this program’s policy and requirements Maintains the program
Procurement Department	Communicates this program’s policy and requirements to subcontract bidders and awardees Requests that each subcontractor and vendor who will perform hands-on work at a Berkeley Lab facility complete an SJHA and review the Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet before starting work Monitors subcontractor and vendor performance, including ES&H compliance
Requestor	Responsible and accountable for ensuring the subcontractor’s safety Ensures that an SJHA is prepared for the subcontractor, vendor, or affiliate who will perform hands-on work at a Berkeley Lab facility, and that a pre-job meeting is held between the requestor and the subcontractor, vendor, or affiliate before work is performed and the SJHA is made “active” prior to work commencing Signs the SJHA and thereby authorizes the work to be performed followed by uploading the SJHA to the SJHA System to make it “active” When required, obtains safe work authorizations, permits, work plans, worker submittals, etc., for the scope of the work to be performed by the subcontractor, vendor, or affiliate Using the risk-based graded approach described in this chapter, provides and records safety oversight of the subcontractors Maintains completed Subcontractor Job Hazards Analysis and related documents (i.e., safe work authorizations, evidence of training, work plans, worker submittals, etc.) in the SJHA System
Subcontractor, Vendor, and Affiliate	Provide input on the SJHA and submit it to the requestor Review the Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet Attend the pre-job meeting and discuss the steps of the work scope and the associated hazards and controls Sign the SJHA and any required safe work authorizations, permits, work plans, etc. Agree to work in conformance with the authorized conditions Perform the scope of work as authorized in a safe manner

31.6 Definitions

The following are definitions for key terms used in this chapter.

Term	Definition
Affiliates	Non-Laboratory employees engaged in on-site Laboratory activities. Affiliates are subject to training in safety and other subjects. They are also issued a Berkeley Lab identification badge. Affiliates may receive system accounts, research access to facilities, and a per diem allowance for housing and living expenses. Examples: facility users, scientific collaborators, students.
Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates	A Berkeley Lab-produced pamphlet that includes important information regarding responsibilities, ES&H policies, security, parking, prohibited articles, etc. The SJHA requester goes over this pamphlet with the subcontractor, vendor, affiliate workers during the pre job briefing.
Hands-on work	Includes all activities except administrative office work and other similar activities. Although not limited to the following, these activities are examples of hands-on work: Activities involving the use of hand or power tools Repair or service of a device, apparatus, machine, or mechanism Material handling involving use of hand or power tools Handling or disposing of a chemical; a compressed gas; or a hazardous, radioactive, or biohazardous material Although not limited to the following, these activities are typically not defined as hands-on work, unless there is a hands-on work component involving tools or other form of safety risk factor: Office and administrative duties Computer programming Attending or making a presentation Supervision of a worker(s) who is not performing hands-on work Document archiving Financial auditing Photography Language translation Vending machine delivery and stocking Water delivery with no maintenance involved General deliveries or pickup of items with no complex material handling, crating, packaging or tools involved
High-Level Hazard Work	Any activity that requires a safe work authorization (e.g., LOTO Permit, Penetration Permit, Radiological Work Authorization, etc.) as described in ES&H Manual Chapter 6 Work Planning and Control and Chapter 21 Radiation Safety.
Low-Level Hazard Work	An activity that does not require a safe work authorization (e.g., any kind of work permit, site specific work plan, etc.)
Non-construction Work	Activities that do not create a new facility or alter, add to, rehabilitate, dismantle, or remove an existing facility, including any combination of engineering, procurement, erection, installation, assembly, demolition, or fabrication Non-construction work also excludes the alteration and repair (including dredging, excavating, and painting) of buildings, structures, or other real property, as well as any construction and excavation activities conducted as part of environmental remediation efforts (see Chapter 10 Construction Safety.
SJHA Program	An EHS Division program that provides guidance, leadership, and direct consultative services to divisions for the implementation of the policy and requirements in this chapter
SJHA Requestor	An individual in a Berkeley Lab division who is listed as the SJHA requester on the SJHA, who is responsible and accountable for the subcontractor, vendor, affiliate and for ensuring the work is performed safely
Requisition Preparer	A Berkeley Lab worker who is trained and authorized to use procurement software programs for initiating requisitions and purchase orders
Risk-Based Graded Approach	A process to ensure that work activities are efficiently managed through systems that are adequate to, and commensurate with, the risk involved in the activity. Risks include potential impact to worker or public health and safety, threats to the environment, consequences of noncompliance, and cost impacts. The risk-based approach considers the degree of  hands-on work includes low or high hazards and complexity of the work in order to determine if a written authorization, beyond the SJHA, is required and what level of worker oversight is necessary by the SJHA requester.
Subcontractor	A firm that has sole contractual responsibility for execution of defined work related to a project, and for compliance with all safety, health, and environmental codes, standards, and regulations
Subcontractor Job Hazards Analysis (SJHA)	An SJHA: Describes the scope of work to be performed Identifies work hazards and controls Is the work authorization document for subcontractors, vendors, and affiliates When required, other safe work authorizations are obtained and appended to the SJHA. Maximum duration of an SJHA is one year. Authorizations and restrictions stipulated by any required safe work authorizations supersede those in the SJHA.
Vendor	An entity that sells a product for which installation or warranty service may be provided

 

31.7 Required Work Processes

Work Process A. SJHA Process Overview

1. Lawrence Berkeley National Laboratory (Berkeley Lab or LBNL) must ensure that all subcontractors, vendors, and affiliates who perform work at its facilities do so safely and in compliance with applicable regulations. The Non-Construction Safety Assurance Program is designed to meet this requirement. General requirements are documented in PUB-3140 (Integrated Environment, Safety & Health Management Plan: Integrated Safety Management (ISM) System), and PUB-3851 (Worker Safety and Health Program). Each division must ensure that its subcontractors, vendors, and affiliates perform on-site work in compliance with Berkeley Lab Environment, Safety & Health (ES&H) requirements. The Environment, Health and Safety (EHS) Division helps Berkeley Lab divisions carry out their responsibilities through the Non-Construction Safety Assurance Program and the online Subcontractor Job Hazards Analysis (SJHA) Program, whose policies, processes, and responsibilities are described in this document. Detailed information on the use of the password-protected online SJHA System is provided in the online help associated with this system.
2. The SJHA System is linked to the Berkeley Lab Procurement process so a decision is made as to whether on-site hands-on work will be performed by the subcontractor, vendor, or affiliate. If the decision is yes, the SJHA process is initiated. A flowchart for the Non-Construction Subcontractor Safety Process is found here.
3. The full suite of Safe Work Authorizations also includes formal Authorizations for Increased Hazards discussed in ES&H Manual Chapter 6 Work Planning and Control.

NOTE: Construction safety assurance is discussed in Chapter 10 Construction Safety and is a separate process that uses Site Specific Safety Plans (SSSPs).  

Work Process B.  Creating an SJHA

1. Before hands-on work (see Definitions, Section 31.6) can be performed by subcontractors, vendors, or affiliates at Berkeley Lab facilities, the following activities must be completed:
   1. A Subcontractor Job Hazards Analysis (SJHA) form must be created and made active after signing, and the subcontractor, vendor, or affiliate must review the ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet, or equivalent (See Work Process C).
   2. A pre-job meeting must take place between the requestor and the subcontractor, vendor, or affiliate at which:
      1. The SJHA and any other required work authorizations such as LOTO permits, etc., are reviewed and signed.
      2. The ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates safety pamphlet is reviewed and discussed.
2. During the hands-on work performed by the subcontractor, vendor, or affiliate, the requestor provides safety oversight of the subcontractors using a risk-based graded approach described in this chapter.
3. Prior to performing hands-on work, the signed SJHA and any associated safety submittal documents are scanned and uploaded into the online SJHA System.
4. The following paragraphs define the minimum requirements for authorizing a subcontractor, vendor, or affiliate to perform non-construction work at Berkeley Lab facilities. Operational differences exist among divisions, and divisions may develop methods to fulfill requirements that suit their organization and work environments, and include these requirements in their division’s ISMS implementation plans.
   1. Pre-Job Planning — Creating the SJHA and Subcontractor Orientation. To develop the SJHA and prepare for the pre-job meeting, the following activities must be completed:
      1. An SJHA must be created by using the online SJHA System.
      2. The unique web link for the SJHA must be sent to Procurement as part of the requisition process and, if appropriate, sent directly to the subcontractor, vendor, or affiliate  (e.g., for warranty work not obtained through the Procurement process).
      3. Prior to the pre-job meeting, the subcontractor, vendor, or affiliate must:
         1. Review the draft online SJHA form, enter his or her input into the draft online sJHA form
         2. Review the ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates.
         3. Complete GERT Training
         4. Submit any relevant work submittals, work plans, etc.
   2. Pre-Job Meeting — To facilitate effective communication between the requestor and the subcontractor, vendor, and affiliate, a pre-job meeting is required. At the pre-job meeting, the following activities are to be completed:
      1. Review, discuss, and modify, as necessary, the SJHA and any required safe work authorizations, permits, work plans, worker submittals, etc.
      2. Confirm the work hazard level.
      3. Identify any additional hazards or controls not identified through the SJHA Process.
      4. Both parties sign the SJHA and any required safe work authorizations.
      5. The completed and signed copy of the SJHA and required safe work authorizations are available at the work location during the period of performance of the work.
      6. The signed documents must be scanned and uploaded to the SJHA System in a timely manner (e.g., preferably by the end of the next business day).
   3. Subcontractor Oversight — To confirm and document that the subcontractor, vendor, or affiliate is performing the work as authorized, the SJHA requestor must provide safety oversight and record observations by using the risk-based, graded approach described below and document these observations in the SJHA online.
      
      Work that is not performed in conformance with the SJHA must be corrected by the SJHA requester on the spot..

Hazard Level	Frequency
Low-Level Hazard Work	Oversight of low-level hazard work (see Definitions, Section 31.6) is performed at a frequency that is discretionary and comparable to the oversight of similar activities performed by Berkeley Lab employees.
High-Level Hazard Work	High-level hazard work (see Definitions, Section 31.6) must be observed and documented at a minimum frequency of once per workday, or more frequently if required by work authorizations (e.g., LOTO permits, penetration permits, site specific work plans, etc.).

Work Process C.  Training and Orientation

Non-construction subcontractors must review the ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet:

• Prior to working on site, and
• To verify understanding at the pre-job meeting.

31.8 Source Requirements

• PUB-3140, Integrated Environment, Safety & Health Management Plan: Integrated Safety Management (ISM) System
• 10 CFR 851, Worker Safety and Health Program

31.9 Reference Documents

Document number	Title	Type
07.02.003.000	ES&H Manual Chapter 6 Work Planning and Control	Program
07.07.011.000	ES&H Manual Chapter 8 Electrical Safety Program	Program
07.07.007.000	ES&H Manual Chapter 10 Construction Safety	Program

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