8- Exhibit E- Environmental_Safety_Health.pdf

Exhibit E-001 Company Document EXHIBIT E REV. 0

Construction Services Exhibit E Solicitation No. 0000313 AL 851 Applies REQ-5772, Groundwater Sampling & Geochemical Analysis Subcontract No. TBD 08/6/2024

MISSION SUPPORT and TEST SERVICES, LLC

FIRM-FIXED-PRICE SERVICE SUBCONTRACT

EXHIBIT E

1. ENVIRONMENTAL, SAFETY, & HEALTH REQUIREMENTS

TABLE OF CONTENTS

E-1 General Requirements E-2 Subcontractor and Sub-tier Subcontractors E-3 Subcontractor Commitments, Expectations, & Integrated Safety Management System5 E-4 Subcontractor’s Environmental, Safety & Health Program E-5 Subcontractor’s Site-Specific Safety & Health Plan E-6 Activity Level Work Planning E-7 Site Orientation/Pre- and Post-Job Briefings E-8 Safety Inspections E-9 Onsite Safety Representative and responsibilities E-10 Incident Reporting Requirements E-11 Occupational Medicine Requirements E-12 Employee Training/Orientations E-13 Emergency Preparedness Requirements E-14 Radiological Requirements E-15 Environmental Requirements E-16 Aviation Requirements E-17 Explosives and Munitions Storage/Use/Disposal E-18 Diving Operations E-19 Hazard Communication E-20 Respiratory Protection E-21 Employee Exposure Monitoring Program (for all chemicals of Concern) E-22 Asbestos Abatement Plan E-23 Silica E-24 Toxic Metals (Lead, Cadmium, Mercury) E-25 Chronic Beryllium Disease Prevention E-26 Infectious Diseases & Bloodborne Pathogens E-27 Lasers E-28 Hearing Conservation Program E-29 Confined Spaces E-30 Inclement Weather E-31 Heat and Cold Stress Prevention E-32 Personal Protective Equipment E-33 Hazardous Materials (HAZWOPER) E-34 Housekeeping, Fire Prevention and Protection E-35 Tools and Equipment

E-36 Demolition E-37 Welding, Cutting, Brazing, and Grinding E-38 Fall Prevention/Protection E-39 Floor And Wall Openings E-40 Scaffolding E-41 Barricades and Traffic Control Plans E-42 Excavations, Trenching, And Surface Penetrations E-43 Underground Construction (TUNNELING) E-44 Lockout/Tagout Procedures E-45 Electrical Safety Program/Procedures E-46 Portable Ladders E-47 Material Handling Equipment (Lift truck, chain falls others required?)

E-48 Cranes and Rigging E-49 Suspended Personnel Platforms E-50 Equipment Operations E-51 Pressure Systems and Compressed Gas Cylinders E-52 Vehicle Operations

Appendices:

Appendix A: Sub-Tier Subcontractor Safety and Health History forms

Appendix B: Exhibit E Training Checklist

Appendix C: Daily Activities Briefing (DAB) Form, FRM-3403

Appendix D: Subcontractor Site-Specific Safety Plan (SSSP), FRM-3252

CONSTRUCTION SERVICES SUBCONTRACT

ENVIRONMENTAL, SAFETY, & HEALTH REQUIREMENTS

Introduction

The CONTRACTOR is committed to implementing an Integrated Safety Management System (ISMS) that promotes the company’s core values and the principles set forth by the U.S. Department of Energy (DOE). The objective of ISMS is to systematically integrate Environmental, Safety, and Health (ES&H) protection into management and work practices at all levels so that workers, the public, and the environment are protected while assigned projects are accomplished. If the location or work activities do not involve the conditions or hazards identified in specific sections of this document, then the requirements in that section are not applicable.

Company Directive CD-0280.005, “Subcontracts,” provides additional information regarding the specific processes of Exhibit E.

E-1 GENERAL REQUIREMENTS

1.1 For the purpose of this Exhibit, the term Safety encompasses ES&H protection, including radiological protection, pollution prevention, and waste minimization.

1.2 The SUBCONTRACTOR shall have sole responsibility for implementing its safety program. Although the CONTRACTOR will provide oversight, neither the CONTRACTOR nor DOE National Nuclear Security Administration Nevada Field Office (NNSA/NFO) shall be responsible for the implementation of the SUBCONTRACTOR’s safety program.

1.3 When performing work at sites controlled/managed by the CONTRACTOR or NNSA, the SUBCONTRACTOR shall comply with all applicable federal, state, and local laws and regulations, including those protecting workers, air, water, soil, as well as those governing land use, waste disposal, chemical use, and pesticide use. All recognized safety and health standards identified within this Exhibit apply to the

SUBCONTRACTOR.

1.4 The SUBCONTRACTOR and SUB-TIER SUBCONTRACTORS shall comply with the following requirements while SUBCONTRACTOR employees and/or SUB-TIER SUBCONTRACTOR employees are physically located on work sites controlled/managed by CONTRACTOR or NNSA:

• Title 10 Code of Federal Regulations (CFR) Part 835, “Occupational Radiation Protection”

• 10 CFR Part 850, “Chronic Beryllium Disease Prevention Program”

• 10 CFR Part 851, “Worker Safety and Health Program”

• 29 CFR Part 1904, “Recording and Reporting Occupational Injuries and Illnesses”

• 29 CFR Part 1910, “Occupational Safety and Health Standards”

• 29 CFR Part 1926, “Safety and Health Regulations for Construction”

• 36 CFR (various), “Parks, Forests, and Public Property”

• 40 CFR (various), “Protection of Environment”

• 49 CFR (various), “Transportation”

• 50 CFR (various), “Wildlife and Fisheries”

• American Conference of Governmental Industrial Hygienists (ACGIH) “2024 TLVs and BEIs Based on the Documentation of the Threshold Limit Values for Chemical Substances and Physical Agents” (current edition)

• National Fire Protection Association (NFPA) 70, “National Electric Code (NEC) (2023)”

• NFPA 70E, “Standard for Electrical Safety in the Workplace”

• NNSA Supplemental Directive SD 413.3-7, “Project Management for Non-nuclear, Non-complex Capital Asset Acquisition”

1.5 SUBCONTRACTOR and SUB-TIER SUBCONTRACTORS must be aware of, and comply with, the requirements of these regulations. The SUBCONTRACTOR and SUB-TIER SUBCONTRACTORS must also understand the potential enforcement actions and penalties that may occur for noncompliance with these requirements. Post-award, by proceeding with the work, the SUBCONTRACTOR acknowledges it has read and understands the following requirements and that work on this Subcontract performed by the SUBCONTRACTOR and SUB-TIER SUBCONTRACTORS will comply with the above requirements. This Exhibit E shall align with NNSA Occupational Safety and Health Administration (OSHA)+ model as detailed in NNSA SD 413.3-7.

1.6 The CONTRACTOR reserves the right to perform both announced and unannounced onsite inspections and assessments of the SUBCONTRACTOR’S operations and equipment to verify compliance with the requirements of this Subcontract. The SUBCONTRACTOR shall support and accommodate oversight assessments, audits, and inspections performed by the CONTRACTOR. The CONTRACTOR may invoke Stop Work at any time for violations of applicable laws and regulations.

1.7 The CONTRACTOR shall conduct a post-award review with the SUBCONTRACTOR addressing the execution and implementation of ES&H requirements related to this Subcontract. The post-award review, site visit, and submission of required documents shall be completed before authorization of onsite work.

E-2 SUBCONTRACTOR AND SUB-TIER SUBCONTRACTORS

2.1 The SUBCONTRACTOR shall ensure that SUB-TIER SUBCONTRACTORS performing elements of the Subcontracted Scope of Work at sites controlled/managed by the CONTRACTOR or NNSA adhere to the SUBCONTRACTOR’S Site-Specific Safety Plan (SSSP). The SUBCONTRACTOR is responsible for ensuring that its SUB-TIER SUBCONTRACTORS are included in the SUBCONTRACTOR’S SSSP and that they comply with all of the requirements of this Subcontract.

2.2 If, after award, the SUBCONTRACTOR proposes to use any new SUB-TIER SUBCONTRACTORS not listed in initial contract, the SUBCONTRACTOR shall notify the CONTRACTOR at least 10 business days before the proposed start date of the new SUB-TIER SUBCONTRACTOR. The SUBCONTRACTOR will submit the SUB-TIER SUBCONTRACTOR’S, “Safety and Health History” form and other required documents for ES&H evaluation, and acceptance will be attached to Appendix A of this Exhibit.

SUB-TIER SUBCONTRACTORS shall not perform any work prior to the CONTRACTOR’S approval in writing.

E-3 SUBCONTRACTOR COMMITMENTS, EXPECTATIONS, & INTEGRATED SAFETY

MANAGEMENT SYSTEM

3.1 The SUBCONTRACTOR safety program must demonstrate the following elements:

3.1.1 Line management is responsible for the protection of employees, the public, and the environment. Line management includes SUBCONTRACTOR employees managing or supervising employees performing work.

3.1.2 Clear and unambiguous lines of authority and responsibility for ensuring ES&H functions are established and maintained at all organizational levels.

3.1.3 Personnel possess the experience, knowledge, skills, and abilities that are necessary to discharge their responsibilities.

3.1.4 Resources are effectively allocated to address ES&H programmatic and operational considerations. Protecting employees, the public, and the environment is a priority whenever activities are planned and performed.

3.1.5 Associated hazards are evaluated and an agreed upon set of ES&H standards and requirements are established, which if properly implemented, provide adequate assurance that employees, the public, and the environment are protected from adverse accidents and unplanned releases and exposures.

3.1.6 The conditions and requirements to be satisfied prior to operations starting are established and agreed upon by the CONTRACTOR and SUBCONTRACTOR. These agreed upon conditions and requirements are binding requirements upon the SUBCONTRACTOR. The extent of documentation and level of authority for agreement shall be tailored to the complexity and hazards associated with the work.

3.2 The SUBCONTRACTOR shall apply the ISMS work cycle shown at the activity level.

Depending on the size and complexity of the work activity/task, some elements of the work provide requirements for demonstrating effective safety management during the execution phase of this Contract.

3.2.1 Table 1.1 provides requirements for demonstrating effective safety management during the execution phase of this Contract.

Integrated Safety Management System (ISMS)

• Plan Work: Contract requirements are translated into work, expectations are set, activities and/or tasks are identified and prioritized, and resources are allocated.

• Analyze Hazards: Hazards associated with the work are identified, analyzed, and categorized.

• Control Hazards: Applicable standards and requirements are identified, controls to prevent or mitigate hazards are identified, SSSPs are developed, and controls are implemented.

• Perform Work: SUBCONTRACTOR’S readiness to perform contract work is confirmed and work is performed safely.

• Feedback and Improve: Feedback information on the adequacy of controls is gathered, opportunities for improving the definition of planning of work are identified and implemented, oversight is conducted, and when necessary, controls are modified to ensure a safe work environment.

Table 1.1 ISMS Work Cycle

Work Cycle Phase SUBCONTRACTOR Requirements

Compliance Strategy

Plan Work

Review of CONTRACTOR project hazards and controls.

Understand existing conditions and controls that might affect worker safety and health.

SUBCONTRACTOR will review Exhibit E and incorporate site hazards and controls into its

SSSP.

Pre-work Site Visit and Review Design Intent

Identify potential job and site hazards and hazard controls specific to the location.

SUBCONTRACTOR will review its potential work hazards and determine any potential location effects on existing CONTRACTOR area hazards.

SUBCONTRACTOR will document how the combination of hazards will be controlled in its SSSP.

Pre-work Conference Resolve emergency-preparedness responsibilities and other safety issues not identified in Request for Quote.

SUBCONTRACTOR will identify an emergency action plan and document it in the SSSP.

Analyze Hazards

Job Hazard Analysis (JHA) and Risk Assessment Approach

Evaluate job-specific activity/ and site-specific work requirements and hazards.

SUBCONTRACTOR will review work requirements and hazard controls. Activity hazard analysis shall be performed for high-hazard tasks (e.g., confined-space entry, critical lifts, hot work, excavation, penetration, energized electrical work, or respiratory protection).

SUBCONTRACTOR will ensure estimates of low probability of occurrence do not dominate early decision-making since human nature and external pressures tend to minimize the use of what would otherwise be sensible controls based on the severity of accident consequences and incorporate hazards and controls into the SSSP. SUBCONTRACTOR will use a Graded Approach.

CONTRACTOR Hazard Information

Request and incorporate hazard identification and hazard control information supplied by CONTRACTOR personnel.

SUBCONTRACTOR will ensure that hazard information from the Scope of Work is incorporated into its SSSP.

Work Cycle Phase SUBCONTRACTOR Requirements Compliance Strategy

Job Activity Analysis and Understanding the Technical Basis

Resolve job assignment and personnel fitness issues.

SUBCONTRACTOR will ensure that workers have the appropriate training and skills for assigned activities. The technical basis of an existing hazardous activity must be reconstructed sufficiently to ensure continued safe operations. The effort will be prioritized according to the severity of potential accident consequences.

Pre-work Evaluation of SUB-TIER

SUBCONTRACTOR

Work Team

Evaluate SUB-TIER SUBCONTRACTOR work group’s knowledge of SSSP safety requirements applicable to their work and how the requirements will be implemented.

SUBCONTRACTOR will ensure that SUB-TIER SUBCONTRACTOR workers have the appropriate awareness of the SSSP safety requirements and can demonstrate how they will be implemented for assigned tasks.

Control Hazards

Safety Program and Define Unacceptable Consequences

Identify company safety management policies, processes, and procedures.

Ensure there are clear responsibilities for accepting and suspending work.

SUBCONTRACTOR’S Safety Program will be complete and contain its company-specific safety information. Unacceptable consequences include the following:

• Accidents that result in a serious occupational injury

• Significant violation of environmental regulations

• Unplanned facility outages or interruptions that significantly impact critical mission work

If the SUBCONTRACTOR Safety Program does not clearly define them, then controls will be integrated into the SSSP.

SSSP – Identify and Control Hazards

Address all contract-specific safety requirements and protective measures, including combined requirements and combined controls.

The SUBCONTRACTOR will ensure the SSSP incorporates company-specific information from the company safety program as well as contract-specific requirements.

The SSSP will document how the combination of facility-specific hazards and activity-specific hazards will be controlled.

The SUB-TIER SUBCONTRACTOR’S addenda will be incorporated into the

SUBCONTRACTOR’S SSSP.

The SSSP will identify methods used by the SUBCONTRACTOR to perform oversight and self-assessment of compliance with the SSSP.

Pre-Job Meeting (as appropriate)

Participate in the pre-job meeting with the intent of understanding conditions/restrictions identified on the jobsite.

The SUBCONTRACTOR, SUB-TIER SUBCONTRACTORS, and workers are responsible for reviewing the SUBCONTRACTOR’S safety program and SSSP prior to the start of work and as needed.

Hazard Awareness and Identifying and Controlling Energy Sources

Ensure employees, SUB-TIER SUBCONTRACTORS, and suppliers are informed of foreseeable hazards and protective measures associated with work activities, as appropriate, prior to initiating work.

Ensure superintendent is qualified and has knowledge of the SSSP and contract requirements.

SUBCONTRACTOR’s supervisors are responsible for ensuring that work activities, work hazards, and work controls are clearly linked and flow down to all workers regardless of tier through documented training, safety meetings, toolbox talks, and pre-activity meetings.

For all high-risk work, the SUBCONTRACTOR shall submit JHA or Daily Activities Briefing (DAB) forms to CONTRACTOR personnel for daily review and approval as scope changes.

For projects that involve high-risk work, the SUBCONTRACTOR shall submit evidence to CONTRACTOR of the review of superintendent qualifications, ensuring they have knowledge of the SSSP and contract requirements for safe execution of activity-level work. If a superintendent is changed during a project, the SUBCONTRACTOR shall resubmit evidence of superintendent qualification for CONTRACTOR review.

Hazard Awareness and Identifying and Controlling Energy Sources (continued)

For all high-risk projects, the SUBCONTRACTOR will have a SUBCONTRACTOR Safety Representative or delegate present the following topics at the pre-job meeting:

• A detailed list of activities that constitute the scope of the project.

For any change in scope, it must be communicated that the change may not be started until approved by the Subcontract Technical Representative

(STR).

• When to pause or stop work, including pause/stop for scope changes.

• The specific sections of the SSSP that apply to the project.

• The high-risk activities to be performed during the project.

• The JHA form, JHA requirements, and expectations for JHA use.

Meetings, toolbox talks, and pre-activity meetings as required; positive verification is required.

SUB-TIER SUBCONTRACTORS and their workers will be knowledgeable about the SUBCONTRACTOR’s SSSP.

Workers will attend documented safety meetings, toolbox talks, and pre-activity meetings as required; positive verification is required.

Workers will become familiar with the hazards and work controls that result in safe working conditions.

Work Authorization Ensure that safety plans/corrective action plans are reviewed, and work is authorized prior to initiating work or corrective actions.

The SUBCONTRACTOR will obtain and follow all required permits. Permit information will be flowed down to SUB-TIER SUBCONTRACTORS and affected workers during documented toolbox talks, DAB/JHAs, and safety meetings.

Corrective actions will be completed as required.

Perform Work

Job Supervision and Positive Verification

Ensure that SUBCONTRACTOR management provides appropriate safety supervision to all workers at all times.

The SUBCONTRACTOR’S supervisors assume responsibility for the safety of the work site and workers. When unanticipated hazards or environmental risks are introduced, work will be paused until revised work planning, hazards, and environmental effects are analyzed and any additional controls are documented and approved, as appropriate.

Positive verification requires that each team member affirm to the person in charge that their part of the system is in the state intended for safe operation. This can be done during pre-activity analysis for less complex operations. If the team does not have concurrence, it should be assumed by the person in charge that it is not safe to proceed.

Safety Inspections Conduct and document daily workplace inspections, with or without CONTRACTOR personnel, to identify and correct hazardous conditions and instances of non-compliance with safety plan/requirements.

Supervisors are responsible for ensuring that daily inspections are documented and immediate action is taken for all identified non-compliance issues.

Emergency Response Ensure that all personnel at the work site can recognize abnormal or unsafe conditions and know how to respond (e.g., “what-if scenarios”).

The SUBCONTRACTOR will train workers to recognize abnormal or unsafe conditions and understand how to respond to the conditions by controlling and reporting the condition.

The SUBCONTRACTOR will ensure every worker understands they have the responsibility and authority to suspend an activity if the worker believes it presents an imminent danger.

Corrective Actions Implement interim controls for unsafe or abnormal conditions, including notification to workers and STR.

The SUBCONTRACTOR will have controls in place to immediately address unsafe or abnormal conditions.

Feedback and Improve

Self-Assessment Identify opportunities for safety process and work performance improvements.

The SUBCONTRACTOR will review daily inspection reports, lessons learned, and injury/illness reports to identify areas that require improvement.

Performance Reviews Discuss performance strengths and weaknesses with employees and Lower-Tiered Subcontractors.

Information on strengths and weaknesses will flow down to SUB-TIER SUBCONTRACTORS and workers.

Assessment of Pre-Activity Plans

Review and discuss the quality and effectiveness of in-process and completed Pre-Task Hazard Review/JHAs with employees and

SUB-TIER SUBCONTRACTORS.

The SUBCONTRACTOR will review SUB-TIER SUBCONTRACTOR pre-work assessments, DAB/JHAs, etc. to determine if SSSP requirements are communicated to SUB-TIER SUBCONTRACTOR personnel.

CONTRACTOR

Feedback

Communicate suggestions for CONTRACTOR improvements to the STR.

The SUBCONTRACTOR will provide updated information and/or suggestions to the CONTRACTOR that will add value to ongoing improvement programs.

The SUBCONTRACTOR will provide a means for workers to report unidentified or uncontrolled workplace hazards.

E-4 SUBCONTRACTOR’S ENVIRONMENTAL, SAFETY & HEALTH PROGRAM

4.1 The CONTRACTOR shall conduct a review of the SUBCONTRACTOR’S written work-specific ES&H Program addressing its execution and implementation of ES&H requirements related to contract requirements.

4.2 The SUBCONTRACTOR’S written ES&H Program will become the basis for the development of the SUBCONTRACTOR’S SSSP that must be completed and approved by the CONTRACTOR prior to the start of work.

4.3 The SUBCONTRACTOR’S ES&H Program shall be in writing and specify how ES&H requirements will flow down to employees and SUB-TIER SUBCONTRACTORS.

4.4 The SUBCONTRACTOR’S ES&H Program will include:

• A written company safety and health policy, which includes the Safety Management Program referenced in Section E-2.

• An assignment of program roles and responsibilities for all employees.

• An approved collection of procedures for hazard identification, hazard prevention, and abatement.

• A procedure for workers to report incidents and hazards without reprisal.

• An approved collection of procedures for accident investigation, reporting, and recording.

• A procedure to permit workers to stop work if they believe an activity poses an imminent risk.

• A set of programs for employee training and safety communications.

• A set of company procedures for conducting activities described in this exhibit.

4.5 SUBCONTRACTOR and SUB-TIER SUBCONTRACTOR employees shall have the right and obligation to report unsafe conditions, at-risk behaviors, interrupt or cease work without fear of reprisal, request a potential hazard to be evaluated, or request additional training. No SUBCONTRACTOR employee shall be asked to complete a work activity that the employee reasonably believes is unsafe or that will endanger the environment.

4.6 The ES&H Program shall describe the SUBCONTRACTOR’S method on how to analyze and mitigate recognized hazards relative to each definable work activity. The plan shall also describe how feedback and lessons learned will occur.

E-5 SUBCONTRACTOR’S SITE-SPECIFIC SAFETY & HEALTH PLAN

5.1 The SSSP is the over-arching document defining how work will be performed. This exhibit defines specific requirements that differ from or are in addition to other federal, state, and local regulations that must be adhered to when working on sites governed by 10 CFR Part 851 and OSHA 3886-01R 2012, “Recommended Practices for Safety & Health Programs in Construction,” which include:

MANAGEMENT

LEADERSHIP

• Top management demonstrates and communicates to workers its commitment to eliminating hazards and to continuously improving workplace safety and health as well as sets program expectations and responsibilities.

• Managers at all levels make safety and health a core organizational value, establish safety and health goals and objectives, provide adequate resources and support for the program, and set a good example.

WORKER

PARTICIPATION

• Workers and their representatives are involved in all aspects of the program—including setting goals, identifying and reporting hazards, investigating incidents, and tracking progress.

• All workers, including contractors and temporary workers, understand their roles and responsibilities under the program and what they need to do to effectively carry them out.

• Workers are encouraged and have means to communicate openly with management and to report safety and health concerns or suggest improvements, without fear of retaliation.

• Any potential barriers or obstacles to worker participation in the program (for example, language, lack of information, or disincentives) are removed or addressed.

HAZARD

IDENTIFICATION AND

ASSESSMENT

• Procedures are put in place to continually identify workplace hazards and evaluate risks.

• Safety and health hazards from routine, nonroutine, and emergency situations are identified and assessed.

HAZARD

IDENTIFICATION AND

ASSESSMENT

(continued)

• An initial assessment of existing hazards, exposures, and control measures is followed by periodic inspections and reassessments, to identify new hazards.

• Any incidents are investigated with the goal of identifying the root causes.

• Identified hazards are prioritized for control.

HAZARD PREVENTION

AND CONTROL

• Employers and workers have cooperated to identify and select methods for eliminating, preventing, or controlling workplace hazards.

• Controls are selected according to a hierarchy that uses engineering solutions first, followed by safe work practices, administrative controls, and finally personal protective equipment (PPE).

• A plan is developed that ensures controls are implemented, interim protection is provided, progress is tracked, and the effectiveness of controls is verified.

EDUCATION AND

TRAINING

• All workers are trained to understand how the program works and how to carry out the responsibilities assigned to them under the program.

• Employers, managers, and supervisors have received training on safety concepts and their responsibility for protecting workers’ rights and responding to workers’ reports and concerns.

• All workers are trained to recognize workplace hazards and to understand the control measures that have been implemented.

PROGRAM

EVALUATION AND

IMPROVEMENT

• Control measures are periodically evaluated for effectiveness.

• Processes are established to monitor program performance, verify program implementation, and identify program shortcomings and opportunities for improvement.

• Necessary actions are taken to improve the program and overall safety and health performance.

COMMUNICATION AND

COORDINATION FOR

EMPLOYERS ON

MULTIEMPLOYER

WORKSITES

• General contractors, contractors, and staffing agencies commit to providing the same level of safety and health protection to all employees.

• General contractors, contractors, subcontractors, and staffing agencies communicate the hazards present at the worksite and the hazards that work of contract workers may create on site.

• General contractors establish specifications and qualifications for contractors and staffing agencies.

• Prior to beginning work, general contractors, contractors, and staffing agencies coordinate on work planning and scheduling to identify and resolve any conflicts that could impact safety or health.

5.2 The SUBCONTRACTOR shall develop and conduct its services in accordance with the requirements of their written and approved SSSP, which will include the following applicable requirements of 10 CFR Part 851:

• Site access controls and responsibilities

• How the SUBCONTRACTOR will ensure the requirements of Section E-3, Section 1.1 of this Exhibit will be met

• Includes description of when a formal JHA is required

• General Safety Rules for the Job Site

• Roles and Responsibilities for Management and Safety personnel assigned to the job

• Emergency responses

• Scope of Work

• Activity-Level Work planning

• Equipment and materials

• Supporting documents

• Training requirements

• SSSP Change Process

• Emergency Response and Approvals

5.3 Changes required to be made to the SSSP must be approved in writing by the CONTRACTOR prior to implementation.

5.4 The SUBCONTRACTOR may use Form FRM-3252, “Subcontractor Site-Specific Safety Plan (SSSP),” to develop their SSSP or use an alternate format as long as it contains the minimum required information identified in the FRM-3252, including:

• SSSP Core Information (Company, work location, contract #, SSSP author[s], subcontractor safety representative, and subcontractor work supervisor)

• Scope of Work (including expected outcomes)

• Site Access Controls and Responsibilities

• Activity-Level Work Planning and Hazard Analysis (job activities/work steps, performer, hazards, and controls)

• Equipment and materials to be used

• Supporting documentation (e.g., relevant engineering drawings, owner’s manuals, form[s], permit[s], checklist[s])

• Specific training requirements for specific activities

• SSSP change/revision process and stop work procedure

• Revision Log

• Emergency response

• Attachments and addendums

• Approvals and concurrences (SUBCONTRACTOR job supervisor and line manager must sign, including any sub-tier subcontractor representatives, and CONTRACTOR STR, project manager or technical subject matter expert (SME), safety professional, industrial hygienist, radiological control (if applicable), environmental compliance, and any other approvals as identified by the CONTRACTOR)

5.5 If the SUBCONTRACTOR elects not to work to an SSSP and DAB, then it will follow the requirements in Section E-4 to develop and work to an Activity Level Work Control Document (ALWCD) and JHA.

E-6 ACTIVITY LEVEL WORK PLANNING

6.1 The SUBCONTRACTOR will demonstrate it has performed activity-specific planning for its subcontracted scope of work by either developing an ALWCD or incorporating activity level work planning into their SSSP. The ALWCD(s) or SSSP when used for activity level work planning must provide the following:

• Scope of work under the ALWCD

• Activities/work steps (when necessary)

• Hazards and associated controls (precautions, limitations, prerequisites, warnings, cautions, etc.)

• Special equipment and materials to be used

• Supporting documents necessary for safe work execution (engineering drawings, owner’s manuals, permits, checklists, etc.)

• Required training and/or qualifications

• ALWCD or SSSP change/revision process

• Any applicable attachments and/or addendums

6.2 The ALWCD or SSSP will be submitted to the CONTRACTOR for review and acceptance prior to the start of work. The ALWCD must be reviewed and approved by the SUBCONTRACTOR job supervisor, line manager, and by the required CONTRACTOR organizational representatives identified in FRM-2163S, “Subcontractor Work Package (WP) Approval Coversheet,” (for ALWCDs) or in FRM-3252 for SSSPs. Any changes to the ALWCD or SSSP must be reviewed and agreed upon by the SUBCONTRACTOR.

6.3 JHA

6.3.1 A JHA is a documented process by which the steps (procedures) required to accomplish a work activity are outlined, the actual or potential hazards of each step are identified, and measures for the elimination or control of those hazards are developed.

Activities are general classes of separately definable construction, maintenance, or operational work (for example, excavating foundations, erecting of structural steel, working at heights exceeding 6 feet, and mixing cement). Activities are not time- or location-specific.

6.3.2 A JHA is required for all high-risk work. If the high-risk work is not clearly defined in the initial submittal of the SSSP, then work will require a separate and discrete ALWCD containing a JHA or a modification/addendum to the SSSP.

6.3.3 High-risk work is defined as work that may result in serious personal injury, illness, or a fatality if performed improperly. The increased risk is based upon characteristics inherent in the work activity, location, materials, or proximity to other hazards. High-risk work activities include, at a minimum, the following activities:

• Critical crane lifts

• Excavation within 5 feet of known hazardous energy utilities (electrical, natural gas, other pressurized systems, etc.) or personnel entry into an excavation > 5 feet in depth

• Energized electrical work

• Work within 10 feet of aerial high voltage power lines (> 50 kilovolts [kV])

• Wall, floor, or ceiling penetrations where a site investigation cannot identify all potential hidden hazards

• Any work where a Confined Space Entry permit is required

• Roof work within 6 feet of an edge not protected by standard guardrails, parapets, or similar physical barriers, or controls approved in the SSSP

• Elevated work without the use of an approved ladder or engineered fall-protection system greater than 6 feet above a lower level or within 15 feet of an unprotected side or edge for all construction trades, excluding roofers. For roofers, the requirement is within 6 feet of an unprotected side or edge.

6.3.4 All high-risk work requires a separate and discrete ALWCD and JHA.

6.3.5 The SUBCONTRACTOR will maintain an approved copy of the ALWCD or SSSP, including any high-risk work and JHAs at the job site during performance of the work that will be available to the CONTRACTOR at all times.

6.3.6 The SSSP and ALWCD shall be communicated to each employee as part of the Site-Specific training and/or SUBCONTRACTOR DAB, signed by each employee including sub-tiers, and implemented by the SUBCONTRACTOR’s management team.

6.3.7 The SUBCONTRACTOR’S SSSP is due 30 days prior to start of fieldwork, and SUBCONTRACTORS must allow 10 business days for each comment and review period to complete the approval process by the CONTRACTOR.

6.3.8 The SUBCONTRACTOR will not mobilize to the field without written authorization from CONTRACTOR’S authorized representative as identified elsewhere in this Subcontract.

E-7 SITE ORIENTATION/PRE- AND POST-JOB BRIEFINGS

7.1 Prior to commencing work, each SUBCONTRACTOR employee or visitor, either initially or as they are introduced to the site, will receive a site orientation briefing conducted by the SUBCONTRACTOR’S supervisor and the SUBCONTRACTOR’S Safety Representative that details the requirements of the SSSP.

7.2 The SUBCONTRACTOR will provide a DAB. The DAB for SUBCONTRACTOR personnel specifically addresses the hazards and mitigating controls for work to be performed that day. FRM-3403, “Subcontractor Daily Activities Briefing,” is available for use; however, a SUBCONTRACTOR may use their own format. A Post-job briefing will be conducted at the end of the job for feedback and performance.

7.2.1 The DAB will be performed by THE SUBCONTRACTOR and SUB-TIER SUBCONTRACTORS to identify and communicate the hazards and controls associated with the planned scope of work to be performed during the day. The DAB shall clearly define the planned scope of work and the sequence of activities needed to complete the planned scope of work. The DAB shall identify and discuss the scope/activities that will be performed that day and the associated hazards and controls that will or may be encountered for the scope/activities being planned for that day.

7.2.2 Special attention should be given to potential hazards not specifically covered in the SSSP and other pre-work planning, newly emerging hazards, or hazards resulting from a change in the scope of work. A DAB shall be conducted daily and revisited if conditions or personnel change. Documents such as checklists or permits, or knowledge (such as training) that identifies and plans for the mitigation of hazards associated with an activity, can be referenced. An activity is a specific segment of a particular scope of work that is time-, condition-, worker- and/or location-dependent.

7.2.3 Critical thinking shall be utilized during this part of the analysis. A focus on what could go wrong during the day, such as weather, and changes to the process and personnel, need to be evaluated regularly. The DAB shall be developed with participation by all workers on the activity and to ensure a common understanding of the authorized scope of work and how the tasks will be accomplished. The DAB development process should establish a shared accountability for safety among the work team (e.g., “see something, say something”). SUBCONTRACTORS are required to notify the CONTRACTOR team (STR, Safety, Project Management) in advance of performing high-risk activities. In the event the SUBCONTRACTOR is performing a high-risk work evolution during the day, the STR, Safety, Project Management or alternate CONTRACTOR representatives shall review the JHA daily.

7.3 The SUBCONTRACTOR shall document and maintain records of attendance and topics covered at the site orientation and DABs. This documentation shall be maintained on the job site or in the work package for the duration of the Subcontract. The SUBCONTRACTOR DAB will be maintained at the job site and be available to the CONTRACTOR at all times.

E-8 SAFETY INSPECTIONS

8.1 The SUBCONTRACTOR shall conduct and record daily inspections of the work areas and equipment to monitor compliance with Site Specific Documents per regulatory requirements.

8.2 The SUBCONTRACTOR shall report any hazards identified or deficiency not under the control of the SUBCONTRACTOR to the CONTRACTOR.

8.3 The SUBCONTRACTOR shall take steps to ensure the safety of employees, the public, and the environment until the hazards are corrected.

E-9 ONSITE SAFETY REPRESENTATIVE AND RESPONSIBILITIES

9.1 The SUBCONTRACTOR shall have a qualified ES&H Professional accepted by the CONTRACTOR present at the worksite whenever SUBCONTRACTOR personnel are performing work.

9.2 The SUBCONTRACTOR’S Safety Representative will have:

• A degree in Occupational Safety or;

• Hold the designation of a Certified Safety Professional or;

• Hold the designation of an Associate Safety Professional with a minimum of 1-year documented safety experience.

• Occupational Health and Safety Technician or Construction Safety and Health Technician certification in addition to 3 years of experience in the field providing safety duties.

• Documented 5 years full time safety experience (100% safety work). List of projects and description of duties where person was a full-time safety professional.

• Specialized training for specialized activities (i.e., High risk, diving, high voltage).

9.3 If accepted by the CONTRACTOR, the SUBCONTRACTOR’S assigned Safety Representative may have other duties as long as they will not interfere with or prevent the employee from performing the stated activities.

9.4 The SUBCONTRACTOR’S Safety Representative will perform the following minimum activities:

• Submit a “Daily Safety Field Report” to the CONTRACTORS, detailing the days of site activities and outcome of daily inspections as noted in the SSSP to the CONTRACTOR assigned safety representative.

• Notify the CONTRACTOR’S STR to cease work and remove SUBCONTRACTOR’S personnel from the hazardous area if the safety or health of SUBCONTRACTOR’S personnel, other site personnel, or third parties is jeopardized by the SUBCONTRACTOR’S work activities.

• Conduct or participate in daily pre/post job briefings and monthly (minimum) safety meetings for the SUBCONTRACTOR’S employees.

• Provide site-specific training (as described in the SSSP) for new employees and orientations for visitors prior to on-site work.

• Obtain audit compliance with the SUBCONTRACTOR’S SSSP or ALWCD.

• Communicate the CONTRACTOR’S warning systems (including evacuation alarms, accountability rosters, assembly points, etc.).

• Confirm that proper chemical and safety postings are in place, are legible, and are removed when the project is complete.

• Confirm that operations are conducted in a manner to mitigate adverse environmental impacts (e.g., spill containment, erosion control).

• Establish and maintain the on-site hazard communication program (e.g., Safety Data Sheets, training).

• Evaluate the site for hazards not identified in the hazard assessment process(es) and initiate safety measures required to protect personnel, the public, and the environment.

• Revise the SSSP and other applicable documents accordingly.

• Confirm that wastes generated are managed in compliance with applicable State, Federal, or Local laws and Subcontract requirements.

• Maintain a first aid log for occupational injuries that occur on-site.

• Report accidents and injuries to the STR, and conduct accident/incident investigations, as required, including the completion and submission of appropriate forms to the STR.

• Update the Site map including safety information such as locations of fire extinguishers and eye wash stations and ensure that the first-aid kits are kept current as appropriate.

• Inform the CONTRACTOR’S medical services, or local emergency responder organizations if off site services are provided, and verify that phone numbers, addresses, and contacts are current and accurate.

• Interface with CONTRACTOR’S safety and health personnel and the STR to resolve safety issues and conduct periodic inspections and program review.

• Represent the SUBCONTRACTOR in incident investigations and/or critiques as requested by the CONTRACTOR.

E-10 INCIDENT REPORTING REQUIREMENTS

10.1 The SUBCONTRACTOR must immediately notify the CONTRACTOR’S STR verbally, and then in writing, of an event or condition that adversely affects, or may adversely affect the NNSA/NFO or its mission, the CONTRACTOR’S or SUBCONTRACTOR’S personnel, the public, property, or the environment. Such an event or condition includes but is not limited to:

• Employee injury/illness and any accident, incident, near-miss (potential bodily injury/illness or damage to equipment and facilities)

• Potential “Price-Anderson Act” or 10 CFR 851 noncompliance, environmental release

• Any other unplanned event that may be a violation of a regulatory requirement or that may be viewed negatively by the public, CONTRACTOR, or NNSA/NFO

10.2 In situations where any of the conditions mentioned above occur, the scene shall not be disturbed without CONTRACTOR concurrence unless it is to mitigate an imminent hazard or stop a spill in progress. SUBCONTRACTOR and CONTRACTOR personnel may jointly investigate each injury/illness, accident, incident, near miss, or environmental noncompliance.

10.3 The SUBCONTRACTOR shall provide a complete and thorough written accident/incident investigation report of any incident, outlining the causes, corrective actions, and measures taken to prevent recurrence of similar incidents to the CONTRACTOR’S STR within 2 working days of its occurrence.

10.3.1 If the SUBCONTRACTOR’s scope of work will not last beyond 2 days, the incident report shall be submitted to STR prior to leaving the worksite. The SUBCONTRACTOR accident/incident investigation reports shall be submitted on the CONTRACTOR’S ”FRM-0018, Incident Investigation Statement.” The report forms will be provided to the SUBCONTRACTOR during the pre-performance conference or pre-job briefing/orientation.

10.4 The SUBCONTRACTOR will assist the CONTRACTOR in the preparation of all reports (including occurrences and offsite notifications) related to its operations. As part of assisting in the preparation of these reports, the SUBCONTRACTOR will be responsible for, and is required to complete, the proposed corrective actions identified in the reports per the established due dates, unless otherwise agreed upon with the CONTRACTOR.

10.5 Property damage to government equipment, facilities, and motor vehicles shall be immediately reported to the CONTRACTOR’S STR.

10.6 FRM-1253, “Subcontractor Hours”: The SUBCONTRACTOR shall submit copies of the FRM-1253 to the CONTRACTOR’S STR on or before the 28th of each month. The report will pertain to actual hours spent performing work for the M&O contractor for the period from the 26th of the preceding month through the 25th of the current month as outlined on the form and will be required throughout the duration of the Subcontract, including periods of no work activity. If the duration of the work does not exceed 1 month, the “Subcontractor Safety & Personnel Report” shall be submitted upon completion of the work, prior to leaving the worksite. The SUBCONTRACTOR will include SUB-TIER SUBCONTRACTORS on the forms. The report forms will be provided to the SUBCONTRACTOR during the pre-performance conference or pre-job briefing/orientation.

10.6.1 Monthly Total Recordable Incident Rate (TRIR) and Days Away, Restricted or Transfer Case Rate (DART): The SUBCONTRACTOR shall submit their overall companies’ TRIR and DART Cases for the rolling 12-month performance. The initial information is captured on the Safety and Health History form completed prior to the contract. If the duration of the work on site does not exceed 1 month, this information will not be required. The TRIR and DART information will be submitted to the CONTRACTOR’S STR on or before the 28th of each month. The report will pertain to the company’s activities for the previous 12-month rolling year and will be required throughout the duration of the Subcontract, including periods of no work activity. TRIR and DART information can be documented in an e-mail or on the DAB (FRM-3403) in the Additional Topics section under Other.

NOTE: Once the SUBCONTRACTORS submit a copy of the FRM-1253, TRIR, and DART case information to the STR, the STR needs to send copies to the Safety Recordkeeping general e-mail box at SafetyRecordkeeping@nv.doe.gov.

10.7 Injury/Illness Medical Reports: The SUBCONTRACTOR is required to report all job-related injuries and illnesses, regardless of severity, immediately to the

CONTRACTOR’S STR.

10.7.1 The SUBCONTRACTOR’S employees must report to the CONTRACTOR’S Occupational Medicine Department after a work-related injury/illness, which requires medical attention, hospitalization, or an absence due to any injury/illness lasting 5 or more consecutive workdays (or an equivalent time period for those individuals on an alternative work schedule) for a return-to-work evaluation focusing on the employee’s physical and psychological capacity to perform their work and return to duty.

10.7.2 Copies of the attending physician’s report releasing the employee to full or limited duty and appropriate medical treatment forms (medical provider’s diagnosis, restrictions, and treatment plan) shall be submitted to the CONTRACTOR’S Occupational Medicine Department during the return-to-work evaluation.

mailto:SafetyRecordkeeping@nv.doe.gov.

mailto:SafetyRecordkeeping@nv.doe.gov.

10.7.3 The SUBCONTRACTOR is required to submit the same required information for its SUB-TIER SUBCONTRACTORS. The SUBCONTRACTOR must comply with all work restrictions made by CONTRACTOR’S Occupational Medicine Department.

10.8 The SUBCONTRACTOR shall maintain reports and documentation required by federal, state, and local regulations and those required by its SSSP. These reports and documentation shall be submitted to the CONTRACTOR upon request or at completion of the work.

E-11 OCCUPATIONAL MEDICINE REQUIREMENTS

11.1 The SUBCONTRACTOR and SUBCONTRACTOR’S SUB-TIER SUBCONTRACTORS must follow the CONTRACTOR’S medical program for their employees engaged in work activities at the CONTRACTOR-managed sites when:

• On site for more than 30 days in a 12-month period.

• They are required to be enrolled in a medical surveillance/qualification program or exposure monitoring program.

• Subcontractors need to establish Occupational medical services by using:

• Management and Operating (M&O) Contractor’s Occupational Medical Clinic or;

• Private physicians or medical groups who are capable of fulfilling the requirements and intent of Occupational Medicine requirements.

11.2 Exposure monitoring that is not enrollment in a program is monitoring performed to characterize the exposure resulting from a new activity or to validate an industrial hygienist's judgment that exposures are likely to be minimal does not constitute enrollment in an exposure monitoring program.

11.3 Exposure monitoring that is enrollment in a program is when routinely monitoring the airborne beryllium levels experienced by machinists that periodically that contain beryllium in areas where concentrations of beryllium are at or above the action level is an example of enrollment in an exposure monitoring program.

11.4 Medical surveillance requirements apply to work involving exposure to asbestos, beryllium, biological hazards, chromium (VI), formaldehyde, hazardous materials, hazardous waste, hazardous noise, lasers, lead, mercury, OSHA toxic substances, and polychlorinated biphenyls (PCBs).

11.5 Medical surveillance requirements also apply to work involving respirator wear, silica, crane operation, radiological work, and driving vehicles requiring commercial driver’s license (CDL)/commercial motor vehicle licenses.

11.6 Medical qualification requirements apply to safety sensitive activities such as tower climbing, explosive handling, confined space entry, respirator use, hazardous waste remediation, or other activities identified by the CONTRACTOR.

11.7 When medical surveillance/qualification is required for the work to be performed, the SUBCONTRACTOR shall identify the applicable exposures or tasks for personnel conducting these work activities and ensure that the required monitoring has been verified with the CONTRACTOR’S Occupational Medical Department using the information in the note below.

NOTE: The Occupational Medical Department can be contacted via e-mail at occmedscheduling@nv.doe.gov and on phone NLV: (702) 295-1473 or NNSS: (702) 295- 6224 for scheduling.

11.8 The SUBCONTRACTOR must notify the CONTRACTOR of any SUB-TIER or SUBCONTRACTOR employee’s absence of 5 consecutive workdays due to injury or illness.

11.9 Prior to returning to work on site, the SUBCONTRACTOR shall have the employee receive clearance from Nevada National Security Site (NNSS) Occupation Medicine.

E-12 EMPLOYEE TRAINING/ORIENTATIONS

12.1 The SUBCONTRACTOR shall verify that employees are properly trained and qualified…