16-Harris Health Phase 2 - OCIP - Safety Performance Program (SPP).pdf

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Harris Health Safety Performance Policy (SPP)

Loading Dock Expansion at Ben Taub Hospital

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Table of Contents

1. Safety Policy Statement

2. Definitions

3. Purpose

4. Pre-Construction Phase

4.1. Supplemental Exhibits

4.2. Design for Construction Safety

4.3. OSHA Partnership

4.4. NPFA 241 Requirements

4.5. Project Hazard Analysis/Risk Assessment

4.6. Roles and Responsibilities

4.6.1. Enforcement and Hazard Abatement

4.6.2. Alliant Broker Administration

4.6.3. Alliant Loss Control Resource

4.6.4. Alliant Loss Control Site Representative

4.6.5. Owner and Contractor Project Managers

4.6.6. Contractor Site Supervisor

4.6.7. Subcontractors

4.6.8. Contractor Employees

4.6.9. Authority (All Site Personnel)

4.6.10. Contractor Safety Representative (CSR)

4.6.11. Competent Persons

4.6.12. Visitors and Vendors

4.6.13. General Employee Conduct

5. Project Planning & Start-Up

5.1. Public Protection

5.2. Site Conditions

5.3. Jobsite Ground Conditions

5.4. Vertical Transport

5.5. Medical Equipment

5.6. Project Utilities

5.7. Administrative Requirements

5.8. Safety Meetings and Communications

5.9. Employee Orientations

5.10. Contractor Inspections

5.11. Accountability Plan

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5.12. Culture and Recognition Plan

5.13. Material Delivery & Storage

5.14. Return to Work (RTW) and Clinic Protocols

5.15. Emergency Notifications

5.16. Maintenance of Project Emergency Contacts

5.17. Project Reporting

5.18. Post-Incident Report/Root Cause Analysis

6. Construction Phase

6.1. General Construction Phase Safety Requirements

6.1.1. Safety Observations

6.1.2. Training and Retraining

6.2. Emergency Action Plan

6.2.1. Emergency Response

6.2.2. Emergency Notification (Fire or Medical)

6.2.3. Storm and Weather Emergencies

6.3. Authorized Entry, Parking, Identification Procedures, Vehicles, Delivery

6.4. Aerial Lifts and Elevating Work Platform

6.5. Elevating Work Platforms (Scissor Lifts)

6.6. Airborne Contaminants & Dust

6.7. Barricades

6.8. Concrete Construction

6.9. Confined Space Entry

6.10. Cranes

6.11. Rigging, Slings and Hooks

6.12. Critical Lifts (Cranes, Etc.)

6.13. Demolition

6.14. Electrical

6.15. Lockout/Tagout

6.16. Structural Steel Erection

6.17. Excavations

6.18. Fall Protection

6.19. Falling Objects and Tethering

6.20. Fire Protection/Prevention

6.21. First Aid

6.22. Flaggers

6.23. Forklifts

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6.24. Hazard Communication

6.25. Heat Illness Prevention

6.26. Heavy Equipment

6.27. Housekeeping

6.28. Ladders

6.29. Laser Equipment

6.30. Lighting

6.31. Machine Guarding

6.32. Personal Protective Equipment

6.33. Ramps and Runways

6.34. Scaffolds

6.35. Toilets/ Washing Facilities/ Sanitation

6.36. Tools and Equipment

6.37. Welding, Cutting and Other Hot Work

7. Appendix: Health Care Safety Program – Additional Measures

8. Appendix: Sample Fine Program

9. Appendix: Jobsite Gym Program

10. Appendix: Employee Orientation Outline

11. Appendix: Safety Orientation Acknowledgement Form

12. Refusal of Medical Treatment

13. Designated Competent Person Acknowledgement Form

14. Appendix: Release of Floor or Stair Template

15. Appendix: Confined Space Assessment

16. Appendix: Confined Space Alternate Entry Certificate

17. Appendix: Confined Space Entry Permit

18. Appendix: Crane Use Plan

19. Appendix: Silica Competent Person Inspection Form

20. Appendix: Guardrail Removal Form

21. Appendix: Dig Permit Form

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1. Safety Policy Statement

Sponsor is dedicated to the safety, health, and protection of its staff, the public, and all contractors and subcontractors. All individuals regardless of role or tier, are expected to uphold the values, goals and responsibilities outlined in this Safety Performance Policy (SPP).

This policy is not meant to restate existing safety laws, regulations, or standards, nor does it relieve contractors of their contractual or legal obligations. This policy is intended to be used as a supplement to clarify such regulatory requirements and present a comprehensive approach to compliance, raising the level of safety to reduce risk and achieve the safest possible workplace in which all adhere to such requirements, processes, procedures, and work practices while working on this project.

This policy may not cover every potential safety concern that could arise during construction. The Sponsor reserves the right to revise this document to improve compliance and reduce risk. All contractors must adhere to updated provisions.

• The Safety Performance Program is a binding contractual obligation for all projects defined by the Sponsor.

• Construction Managers, General Contractors, and Subcontractors of every tier, and their respective employees are required to adhere to all applicable laws, statutes, ordinances, rules, regulations, and/or orders of any public authority (federal, state, local) as they relate to the safety of persons, environment, public, or property. and the requirements of the supplemental exhibits applying to a contractor’s specific scope of work.

• If any conflicts arise where language is contradictory within this policy, or when used in conjunction with another policy, or between these requirements and federal, local, state, or Sponsor-specific rules, the stricter requirement shall apply. Throughout the duration of the project, the Construction Manager, General Contractor, and Subcontractor of every tier shall be responsible for developing and administering their own safety programs.

o Neither these requirements, nor the safety or environmental services provided by individuals associated with this project, are intended to serve as substitute for the control and responsibility of the Construction Manager, General Contractor, and Subcontractors of every tier to provide a safe work environment for their employees and the public.

• For CIP projects, the guidelines of the CIP Project Insurance manual will also apply.

o Refer to the project specific Alliant Controlled Insurance Manual located in the exhibit of the contract documents for further information.

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2. Definitions

Activity Hazard Analysis A systematic process that identifies and evaluates potential hazards in a specific activity or task.

Certified Person An individual who has successfully completed both written and practical exams specific to the job being performed.

CIP Administrator Responsible for the management and coordination of Controlled Insurance Program risks of the project including claims, safety, and loss control.

Code of Federal Regulations (CFR) The Code of Federal Regulations, as promulgated by the Occupational Safety and Health Administration (Title 29CFR), the Environmental Protection Agency (Title 40CFR), or the Department of Transportation (Title 49CFR).

Competent Person One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, the public, and the environment, and who has authorization to take prompt corrective measures to eliminate them.

Construction Project or Project Any project involving construction, demolition, on buildings, utilities, landscaping and the like major renovation, or alteration on buildings, utilities, landscaping, and the like. The term ‘construction’ is interchangeable with demolition, major renovation, and alteration, except where otherwise noted.

Controlled Insurance Program Where Sponsor procures insurance on behalf of all (or most) parties performing work on a construction project or specific site.

Construction Manager The organization contractually responsible for ensuring acceptable performance of construction-related work and for the payments and debts pertaining to this work.

Contract The binding agreement, written or otherwise, between Sponsor and the Construction Manager/General Contractor. Included in this term are all associated documents and drawings referenced or included in the contract. The term ‘contract’ may also apply to agreement entered between a prime-tier contractor and lower-tier contractors/suppliers/vendors.

Contractor The entity to which this document applies. ‘Contractor’ includes entities of every tier.

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Cost Per Work Hour Cost Per Work Hour will be reviewed by the Sponsor to determine safety performance program execution.

Cost incurred (under deductible limit) / Work hour = Cost Per Work Hour

Critical Lift Any hoisting operation where the load weight exceeds 75% of the lifting device’s net capacity, where hoisting over an occupied structure, where two lifting devices are used in tandem to hoist a load, where non-standard rigging practices are employed, or is in the presence of special hazards.

Construction Manager Safety Representative (CMSR) Construction Managers designated full time on-site safety professional(s). This person will monitor the safety efforts of all contractor managers, site supervisors, and CSR’s.

Contractor Safety Representative (CSR) The designated responsible qualified and competent person employed by contractor at this site who is responsible for the protection of persons and property and the administration of the contractor’s project safety and loss prevention program. Can appoint and or work with SSR assigned to them as a contractor.

DART Rate Days Away from work, Restriction of duty, or Transfer. This term is used and defined by OSHA and the Bureau of Labor Statistics for the tracking and reporting of these types of injuries and is used in this Standard consistent with that definition. The DART rate is calculated by multiplying the number of OSHA recordable injuries and illnesses resulting in days away, restricted, or transferred by 200,000 and then dividing that number by the total number of hours worked by all employees.

Emergency Coordinator General Contractor’s designated employee responsible for notification and coordination of all incidents related to the job site.

Emergency Action Plan A written document outlining the specific procedures and actions that workers and site personnel should take in the event of an emergency on a construction site, including details on how to report incidents, evacuate safely, provide first aid, and contact emergency services, aiming to minimize injuries and property damage in crisis situations.

Employee Persons employed by the construction manager, general contractor, subcontractor, vendor, supplier, or Sponsor employee. This term means any person on the Project, except where specifically denoted.

Employer Any entity employing workers at or in support of the construction project.

General Contractor The organization contractually responsible for ensuring acceptable performance of construction–related work and for the payments and debts pertaining to this work. This entity maintains the overall responsibility and authority for management of the safety program at the construction project. This term will be interchangeable with ‘Construction Manager,’ where contractual language requires, but shall in no way relieve the General Contractor of the obligation(s) related to safety responsibility.

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Inducted Employee/ Eligible Party An employee of an enrolled contractor who has completed all required Safety Orientation procedures and meetings, who is able to competently represent their employer and the safety requirements of this performance document.

Infection Control Risk Assessment (ICRA) A systematic process that determines level of risk within a healthcare setting to patients and defines controls to reduce risk.

Insured(s) Sponsor and eligible enrolled Parties and other such parties that.

Sponsor and insurer deem eligible under contract to add as additional insureds.

Insurer(s) The OCIP insurer(s) issuing a policy for coverages under the OCIP.

Jobsite The property owned by, leased by, or under the control of the Owner on which construction activities with respect to the project are being conducted and/or areas and ways contiguous thereto. Jobsite includes any work area set up by the Owner for use by an authorized project contractor exclusively for storage of material or equipment, or for on-site fabrication of material to be used in the construction and all staging and project support areas. Jobsite does not include any permanent locations of any insured party other than the Owner. This term is interchangeable with ‘Project’ and ‘Site.’

Job Hazard Analysis (JHA) Identifies and analyzes hazards associated with the performance of various individual tasks to maximize worker safety.

Leading Edge The edge of a floor, roof, or formwork for a floor or other walking/working surface which changes location as additional floor/roof/decking/formwork is placed or constructed.

Occupational Safety and Health Administration (OSHA) OSHA, working under the authority of the U.S. Department of Labor is responsible for the enforcement of the Occupational Safety and Health Act of 1970, and charged with the promulgation of standards under this Act.

Owner Safety Monitoring System A system in which a Competent Person is responsible for recognizing and warning employees of fall hazards.

Project Refer to Construction Project

Qualified Person One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated his/her ability to solve or resolve problems relating to the subject matter, the work, or the project.

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Root Cause Analysis The process of identifying the source of a problem and looking for a solution so that the problem is treated at the root level.

Severity Rate The Severity Rate is calculated by dividing the total number of lost workdays by the number of recordable incidents

Sponsor In this document shall be known as Harris Health.

Contracted entity and any affiliated subsidiary or associated companies as now exist or may hereafter be constituted or acquired. In addition, any corporations, partnerships, joint ventures, individuals, or companies over which any of the above exercises financial or management control, as now exist or may hereafter be constituted or acquired.

Sponsor EHS Office The Environmental, Health, and Safety representative, responsible for a defined set of services on behalf of the Sponsor. EHS Representative is also responsible for a core set of services to the Sponsor, including policy establishment and qualification of contractor safety programs.

Sponsor Project Manager The Project Manager(s) responsible for the oversight and coordination of the construction Project. This person may be a Sponsor employee, or an employee of a 3rd party service corporation contracted to perform the duties of the Sponsors Project Manager.

Sponsor Construction Mitigation Manager Works to minimize or eliminate negative impacts to the surrounding abutters, the city, and the internal community of the sponsor, from construction projects, while allowing for an efficient approach to construction work.

Sponsor Health and Safety Plan The environmental health and safety plan, issued by the sponsor if applicable is owned by each individual contractor, which outlines the requirements, policies, procedures, responsibilities, goals, and accountability structure specific to contractors.

Subcontractor Any person or organization of a lower-tier, having a direct contract with an upper-tier contractor. The term subcontractor also applies to vendors and suppliers performing work at the project.

Subcontractor Safety Representative (SSR) Reporting to and/or assigned by the contractor, who is responsible for the protection of persons and property and the administration of the subcontractor’s project safety and loss prevention program. SSR can be assigned through subcontractor employee count, contractor requirements, compliance correction, training, and or high hazard activities.

Superintendent The person typically employed by the General Contractor, responsible for the general coordination of work and labor forces. This person may be a General Superintendent overseeing other Superintendents, or an Area Superintendent responsible for a defined operation or contractor.

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Supplemental Exhibits Documents that supplement the requirements of this Standard. Exhibits contain requirements that are specific to operations or tasks (i.e., scaffolding, trenching, etc.).

Total Recordable Cases (TRC) This term is used and defined by OSHA and the Bureau of Labor Statistics for tracking and reporting of injuries and illnesses that meet the defined criteria of a ‘recordable incident’ and is used in this Standard consistent with that definition. Commonly referred to as ‘OSHA Recordable’ rate.

Visitor/Vendor Any person who is not an employee of the Sponsor, construction manager, general contractor, or subcontractor(s), working on the project. This term includes salespersons, vendors, suppliers, architects, engineers, students, but who does not perform construction work on the site.

Work Includes all matters and activities conducted on the construction project required for the progress or completion of the project.

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3. Purpose

The Sponsor’s Project Manager and/or Primary Contractor, as designated by the Sponsor, shall have overall responsibility for all aspects of safety for the Project.

The effectiveness of the Safety and Loss Prevention program hinges on everyone’s active engagement, coordination and cooperation, regardless of position, to supply the resources, planning, equipment, and training needed to implement essential safety measures. This Safety Performance Policy provides a practical framework for cultivating a safety-conscious culture, managing risk proactively, minimizing personal injuries and property damage, boosting efficiency, and cutting the direct and indirect costs tied to incidents or claims. By interrupting the chain of events that lead to accidents, we can control them and ultimately prevent them.

Regulations: Comply with Federal, state, and local, and Authority laws, ordinances, regulations, industry standards.

Planning: Plan all work to minimize the potential for personal injury, property damage, and loss of productivity (i.e., Activity Hazard Analysis, Job Hazard Analysis, and High Hazard Job Pre Planning, Design for Construction Safety).

Culture: Establish and oversee a sitewide safety and risk avoidance and accountability culture that is best in class and will positively impact each site employee.

Education: Establish and conduct an educational program to stimulate and maintain the interest and cooperation of all employees. Education will be conducted through active coaching, orientation sessions, safety meetings, bulletin boards, and training programs.

Detection: Maintain a system of prompt detection and correction of unsafe practices and conditions by all employees.

Investigation: All incidents, accidents, near misses, and claims will be investigated to determine their root cause and implement reasonable corrective actions in a timely manner.

Verification: Verification of effective safety process through audits and statistical data.

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4. Pre-Construction Phase

4.1. Supplemental Exhibits

• Construction Manager/General Contractor, and Subcontractors of all tiers are responsible to review and adhere to the requirements of all applicable supplemental exhibits that apply to the specific scope of the project.

4.2. Design for Construction Safety

• Design for Construction Safety means considering worker safety throughout the design process, factoring in how design decisions affect construction risk and incorporating safety into the constructability review process. The Sponsor, is in consensus with the first tenant of the Code of Ethics of the American Society of Civil Engineers and the National Society of Professional Engineers, which state that an engineer “shall hold paramount the safety, health and welfare of the public,” explicitly requires designers to address the safety and health risks to all parties affected by their designs and design out those risks where feasible.

• It is understood that the application of Design for Construction Safety techniques (elimination, engineering, and substitution) is inherently more cost effective and a best practice for reducing injuries versus using traditional reactive methods.

4.3. OSHA Partnership

• The Sponsor recommends that the General Contractor or Construction Manager collaborate closely with local OSHA offices to establish a project partnership. If a partnership with OSHA is signed, all partnership documents will be made available to all subcontractors, the owner, or owners’ designee by the General Contractor or Construction Manager. 100% participation by all contractors is mandatory.

4.4. NPFA 241 Requirements

• Sponsor’s expectation is in municipalities where NFPA 241 is locally enforced, the

General Contractor or Construction Manager must comply with the Local Fire Department regulation. In areas without local enforcement, the following requirements shall still apply.

o A fire Safety Plan shall be established, and a Fire Prevention Superintendent designated (Preferably an existing Superintendent) The following requirements apply to partially occupied buildings.

Temporary separations walls between the work area and the rest of the building shall have 1-hour separation walls and 45-minute opening protective rating.

Egress from the occupied area shall not be compromised.

Temporary impairments or restrictions in occupied areas shall be approved by the Sponsor or its designated representative.

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Fire-protection devices and alarm/detection systems that are temporarily impaired shall be restored immediately after work is complete at the end of every shift.

An impairment coordinator shall be designated (preferably a Project Manager).

o Fire walls and exit stairwells, when required for the completed building, should be given construction priority for installation and fire doors should be installed as soon as protocol.

o The sprinkler system shall be in place and operational as soon as practicable, sprinkler valves shall be checked at the end of each shift.

o All temporary panels, wood, tarps, plastic sheeting, and similar materials shall be flame-retardant.

o The General Contractor or Construction Manager shall provide a designated command post stocked with building plans, emergency contacts, keys and other required equipment or information.

o Access to hydrants, standpipes, and fire-department connections shall be pre-approved, maintained, and unobstructed at all times.

o Readily accessible pull-box fire alarms shall be provided. If a telephone is used instead, clear operating instructions shall be posted and maintained.

o Means of egress shall be maintained in an acceptable condition at all times, including proper signage, clear pathways, safe surfaces and adequate lighting.

o Flammable Gasses and Combustible liquids shall not exceed 60 gallons inside and within 50 feet of the building structure.

o Trash chutes shall be constructed of non-combustible material or protected by sprinklers.

o Internal combustion devices shall exhaust outside, with at least nine inches between exhaust and combustible materials.

o Fire extinguishers shall be present in all temporary buildings. Ceiling mounted fire extinguishers shall be installed in all temporary office areas or shacks/shanties on the project.

o Remove waste, dust, and debris daily to prevent accumulation.

4.5. Project Hazard Analysis/Risk Assessment

• The General Contractor or Construction Manager is required to develop a Project

Hazard Analysis (PHA) The PHA should identify major anticipated hazards, outline mitigation strategies, and assign responsibility for each control method. The PHA shall be made available to Sponsor upon request.

• Prior to commencement of work, a Project Hazard Analysis/Risk Assessment meeting will be conducted with the Sponsor and Alliant representatives when appropriate.

• A process must be developed and implemented by the General Contractor or Construction Manager to identify and communicate job-related hazards and control measures to all subcontractors, regardless of tier. This process shall be documented and shall include an expectation for the frequency with which hazards will be reviewed, identified, and communicated to the workforce during the course of construction.

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• On projects with no General Contractor or Construction Manager, regardless of contract structure each Contractor shall develop and implement a similar process.

4.6. Roles and Responsibilities

• The Sponsor and its representatives are responsible for promoting a safety-focused environment that helps all trade partners meet the requirements of this Safety Performance Policy.

• The Project Manager, General Contractor or Construction Manager, and the Subcontractors (including all tier subcontractors) and its/their employees have the explicit responsibility to provide a safe workplace and always follows safe work practices.

• Construction activities by the Project Manager, General Contractor or Construction Manager, and the Subcontractors must be coordinated and consistently communicated with the Sponsor prior to initiation of work.

• The General Contractor or Construction Manager shall review all work tasks with subcontractors and site employees to reduce risk and incorporate industry best practices and shall provide these reviews to the Sponsor upon request.

• Any construction activity occurring outside the perimeter of the Project but within the scope of the overall Project or within the Project perimeter that may affect operations, the general public, or pedestrian/vehicle traffic, must be communicated to the Sponsor.

4.6.1. Enforcement and Hazard Abatement

• The Sponsor and its designated representatives reserve the right to enforce all security and safety regulations. They assume no responsibility for employee safety or for damage, fire, or theft involving employees’ or contractors’ tools, vehicles, or materials.

• The employer that creates a hazard is responsible for correcting it. On multi-employer worksites, trade partners may be cited if their employees are exposed to hazards created by another contractor on the shared job site. The Sponsor and its representatives follow OSHA’s multi-employer policy, which applies four tiers of responsibility to hold trade partners accountable for correcting hazardous conditions on site:

o Employer creating the hazard.

o Employer whose employees are exposed to the hazard.

o Employer responsible for correcting the hazard.

• Controlling employer whose position is to hold others responsible for preventing, identifying, and correcting the hazards.

4.6.2. Alliant Broker Administration

• Sponsor’s Broker/Administrator contact is available to assist Sponsor and its representatives, contractors, and subcontractors of every tier with all aspects of CIP administration.

o Provide the Sponsor, CIP Administrator, or CIP insurer(s) with any information or documentation required for policy issuance, in the form and substance specified by the Sponsor or its designee.

Page | 15 o Submit on-site payroll reports online to WrapX portal each month, as described in the OCIP manual, for the prior month (including months with no payroll).

o Permit the CIP insurer(s) to audit the enrolled parties’ books and records and provide documentation as may be required to assure accuracy of those payroll reports. The enrolled parties (Subcontractors and their Sub-subcontractors) agree that their failure to submit documents as required may result in withholding progress payments until said payroll reports are received by Sponsor or its designee.

o Promptly comply with the requirements, obligations and recommendations issued by the Sponsor, CIP Administrator, or CIP insurer(s) to ensure proper administration of the CIP and continuity of coverage. The Sponsor may withhold payments until the enrolled partiers meet these obligations.

o The enrolled parties will provide Sponsor, its CIP Administrator or CIP insurer(s) with all information necessary for the issuance of said policies and will maintain and make available to the insurance companies payroll records and such other records relating to the Work as may be necessary for the proper computation of the insurance premiums.

o The enrolled parties will cooperate with Sponsor regarding administration and operation of the CIP. The enrolled parties’ responsibilities will include but are not limited to: operations and insurance information; inclusion of CIP provisions in all subcontracts; notification to Sponsor’s representative of all subcontracts awarded; maintenance and provision of monthly payroll records and other records as necessary for premium computation;

compliance with applicable loss control (safety), return to work program, and claims reporting procedures; maintenance of an OSHA Log to be provided as required by Sponsor.

4.6.3. Alliant Loss Control Resource

• The Sponsor’s Alliant Loss Control Resource is an offsite contact that is available to assist the Sponsor and its designated representatives with generating and maintaining a high level of commitment for safe operations among all personnel assigned to the project site. The Sponsor’s Alliant Loss Control Resource can assist with efforts that could include, but are not limited to, the following:

o Assist with the review and follow-up of safety performance statistics from the project. Alliant Loss Control Resource will communicate findings from the above information to the designated Sponsor and its designated representatives.

o Keep apprised of new regulations, developments, safety bulletins, and best practices. Communicate to The Sponsor and its designated representatives to keep the safety policies and procedures current and effective.

o Assist with conducting safety surveys of contractors’ and subcontractors’ activities to observe safety performance and make appropriate recommendations.

o Assist with the review and communicate methods and procedures to foster the highest level of accident prevention performance possible.

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Provide such information to the to The Sponsor and its designated representatives.

o Assist with the development and involvement with the project Culture program and/or the Safety Incentive Program.

o Assist with conducting accident investigations if required, and/or review requested accident investigation reports, to provide comments to The Sponsor and its designated representatives.

o Assist in the review and evaluation of contractors’ safety meeting minutes and provide comments to The Sponsor and its designated representatives.

o The ability to provide OSHA 10- and 30-hour OSHA Construction Outreach Training and other pertinent safety related awareness courses, to Owner Representatives, Contractor Personal and Sub-Contractor employees, training will be conducted exclusively at the discretion of the Owner and the Alliant Loss Control resource.

o Assist and consult in areas of special training, etc., to the contractors and subcontractor’s regarding complications and challenges that may arise on the project.

o Assist The Sponsor and its designated representatives with the development and oversight of this Safety Performance Policy document.

All changes to this document shall be communicated with the Alliant

Loss Control Resource to ensure proper maintenance of this document during the insured term.

4.6.4. Alliant Loss Control Site Representative

• The Sponsor’s Alliant Loss Control Site Representative is a delegated contact that is available to assist the Sponsor and its designated representatives with generating, maintaining, and overseeing a high level of commitment for safe operations among all personnel assigned to the project site. The Sponsors Alliant Loss Control Site Representative can assist with or manage efforts that could include, but are not limited to, the following:

• Assist with or oversee any of the above listed efforts or requests of the Alliant Loss Control Resource from the Sponsor.

• Serve as a technical advisor and resource to all project entities impacting Loss Control, Risk, and Safety for daily activities on the project. Communicate necessary information to the Sponsor and its designated representatives, Contractor Personal and Sub-Contractor employees.

• Assist the Sponsor and its designated representatives with the development and oversight of this Safety Performance Policy. The Alliant Loss Control Site Representative daily activities should include the following.

o Communicate known or possible hazards to the appropriate site personnel for abatement.

o Stop any IDLH hazard if observed.

o Generate safety observations using proprietary software.

o Provide periodic reports on key performance indicators.

o Support incident and accident investigations conducted by contractor partners.

Page | 17 o Support and ensure program compliance with Return to Work, Clinic Procedures, and communication with claims.

o Review high hazard work plans in an advisory capacity, providing feedback where appropriate.

o Support safety communication in a multi–Sponsor, General Contractor, or Construction Manager environment.

o Participate in site safety meetings.

o Coordinate carrier site visits.

o Track status of recommendations and areas for improvement.

4.6.5. Owner and Contractor Project Managers

• The Sponsor’s Project Management team occupy a position of trust and are obligated to prioritize the Sponsor's best interests in all project-related decisions and actions.

• The Sponsor, its designated representatives or the Contractor’s Project Manager holds overall authority and responsibility for all site operations, including Safety and Loss Control, as determined by the sponsor.

• Contractor shall supply the Sponsor’s representatives and site superintendents with work plans, staffing and budgetary resources sufficient to meet the project’s safety and loss-control needs.

• Ensure that the Activity Hazard Analysis addresses every aspect of the contractor’s scope of work and that the Project Hazard Analysis remains current through regular reviews with the contractor site supervisors.

• If the Contractor’s Project Manager does not appoint a full-time Corporate Safety Representative (CSR), all CSR duties shall be assumed by the Contractor’s site Supervisor, the Contractor’s Project Manager.

• The General Contractor or Construction Manager must hold the credentials and experience required to achieve the safety performance specified in this policy.

o When a trade partner struggles or fails to meet its safety responsibilities, the Sponsor may require that contractor or subcontractor to assign a full-time on- site CSR or additional safety professionals, at no cost to the sponsor, until performance meets project standards.

• Contractors shall ensure that each contractor assigns a qualified, full-time competent person on-site who is knowledgeable about the tasks being performed each day, for as long as the contractor’s own employees and/or subcontracted employees are working on the project.

4.6.6. Contractor Site Supervisor

• The contractor site supervisor has the overall responsibility and authority to direct work activities and operations at the project site according to the provided work plans in accordance with the Contractual scope of work as directed by the Sponsor and its designated representatives. The contractor site supervisor shall oversee the following.

o Observing and providing guidance regarding safe work behavior and site safety training.

o Verify that all employees, including sub-tier contractors, are fit for duty.

Page | 18 o Discussing deviations from the work plan with the Contractor Safety Representative (CSR), Project Manager, and the Sponsor and its designated representatives.

o Discussing safety issues with the Contractor Safety Representative (CSR), Project Manager, and the Sponsor and its designated representatives, assisting the CSR with the development and implementation of corrective actions for site safety deficiencies.

o Oversee implementation of the Safety Performance Policy, confirm compliance, and correct identified hazards.

o Provide oversight and verify adherence to this Safety Performance Policy and all applicable SH&E procedures through regular site inspections.

o Ensure that all Job Hazards Analysis are completed, reviewed, and signed daily with all crews and employees for which the Contractor Site Supervisor is responsible for.

o The contractor site supervisor is expected to ensure all operations comply with this Safety Performance Policy and to stop any activity that poses a hazard to personnel, property, the public, or the environment.

Hold individuals accountable for infractions against this Safety

Performance Policy pending understanding of contributing factors (management, personal, environment, etc.), and consideration by the Contractor Safety Representative (CSR), Project Manager, and the Sponsor and its designated representatives.

4.6.7. Subcontractors

• Subcontractors at every tier are responsible for complying with all safety in this Safety Performance Policy, the contractor requirements, and the site’s safety and security procedures, including but not limited to:

o Providing a list to the Contractor of all competent or qualified personal required for their scope of work.

o Providing the names of all CPR/First Aid employees on site.

o Providing the Contractor with a list of all Hazardous Materials or items used on site with all updates SDS sheets.

o Providing a list of supervisory personal including off duty contact information.

o Property preplanning work.

o Adequately identifying and inspecting tools and equipment.

o Securing all tools and equipment at the end of the shift to prevent vandalism, theft, or unauthorized use.

o Assuring all subcontractor employees comply with project rules and regulations.

o Assuring proper identification is acceptable and displayed while on site.

o Assuring immediate notification to the General Contractor or

Construction Manager of known hazardous conditions, unsafe work activities, property damage, bodily harm, or near misses, or any potential concern.

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4.6.8. Contractor Employees

• Trade partner employees are responsible for the following safety-related duties on this construction project:

o Understand and abide by the policies and procedures specified in this

Safety Performance Policy and other applicable safety policies, and clarifying those areas where understanding is incomplete.

o Providing feedback to management about omissions, Needed changes, or other safety-related issues.

o Report to work fit for duty.

o Immediately notifying the General Contractor or Construction Manager of unsafe conditions or acts. Follow the chain of command until the concern is resolved and submit written reports if required.

o Review, contribute to, and sign the Job Hazard Assessment for every task performed during the day.

Each employee on the Project is accountable for their own safety and that of their coworkers Safety requirements will be communicated through orientation, training, bulletins, project signage, and Safe Work Plan materials. Employees must stay alert to their surroundings at all times, follow all applicable safety rules and regulations, participate in the Safe Work Plan process, and promptly report hazards and incidents.

4.6.9. Authority (All Site Personnel)

• Every employee on site has the following safety and health authority:

o The right to refuse to work or stop work when a task presents an immediately dangerous to life or health (IDLH) condition, or when required safety precautions are inadequate or not understood, including work performed by subcontractors.

o The right to refuse to work on any site or operation where the safety procedures specified in this Safety Performance Plan or other safety policies are not being followed.

o The right to contact the Contractor Safety Representative (CSR), Project Manager, or the owner’s designated representative at any time to discuss concerns without fear of reprisal.

o The right and duty to stop unsafe work and help correct the condition.

Employees who knowingly observe hazardous conditions or activities and fail to act to mitigate or report them will face disciplinary review.

4.6.10. Contractor Safety Representative (CSR)

• The Contractor Safety Representative (CSR) has the overall responsibility and authority to provide onsite safety oversight to the Sponsor and its designated representatives, and the General Contractor or Construction Manager. The CSR will work directly with the Sponsor and its designated representatives, the General Contractor or Construction Manager, and the subcontractors to develop and implement site work plans, training, and other regulator safety-compliance requirements and to verify that all employees and subcontractor employees are fit for duty.

Page | 20 o These safety-professional requirements ensure that qualified personnel can serve as technical resources to GC/CM supervision and can perform regular, frequent site inspections.

o Superintendent, general foreman, and foreman must establish and maintain safe work areas and ensure safe work practices among their crews.

• Every contractor shall employ at the site a responsible, qualified, and competent Contractor Safety Representative (CSR), who shall be responsible for the protection of persons and property and the administration of the Sponsors Safety Performance Policy.

o The CSR may be a full time or part time position as specified by this Safety

Performance Policy.

If the Scope of work requires a full-time, that individual’s only duties are protecting persons and property and administering the Sponsor’s Safety Performance Policy and the contractor’s safety program.

The Sponsor may require a full-time CSR with specific credentials when project complexity or risk assessment warrants it.

Construction Value Greater than $25M

• The Sponsor requires CSR on all projects with a construction value of $25 million or more. The CSR must meet these qualifications:

o Current OSHA 500 Construction Industry Trainer card (29 CFR 1926) o At least five years of safety-related experience or a safety-related degree.

o Other relevant credentials, additional experience, or a proven safety-performance record, as accepted by the Sponsor.

o Contractors shall submit the qualifications of all candidates proposed for full-time CSR positions to the Sponsor or its designated representatives for review and approval.

• All full-time CSRs will serve a 90-day prohibitionary period, regardless of their qualifications or prior approval.

• A contractor must assign one full-time CSR when its onsite workforce on the project, including sub-tier contractors, reaches 50 employees.

• Provide one additional full-time CSR for every additional 50 employees added to the project.

• If the Scope of Work does not require a full-time CSR, the role may be filled on a part-time basis and combined with other duties.

Construction Value Under $25M

• Every project with a construction value under $25 million must have an assigned CSR who reports to the Sponsor’s designated representatives.

• Minimum qualifications for a part time CSR are.

o Completion of an OSHA 30-hour Construction (29 CFR 1926) course within the past 12 months.

o Contractors shall submit the qualifications of all candidates proposed for part-time CSR positions to the Sponsor or its designated representatives for review and approval.

• Board Certified Safety Professional o If a contractor struggles or fails to meet its safety responsibilities, the

Sponsor and its designated representatives may require the contractor or

Page | 21 subcontractor to provide a full-time on-site CSR or additional on-site safety professionals until performance complies with project standards.

• Sponsor and its designated representatives retain the right to supplement without expense if there is known risk or delay.

o Contractors with an EMR (Experience Modification Rate) above a 1.01 will be required to have a Safety Mitigation Plan and bi-monthly 3rd party safety inspections completed and copied to the Sponsor and its designated representatives.

o Contractors with an EMR over 1.20 will be required to have a Safety Mitigation Plan and a full-time dedicated CSR on-site at all times. EMR will be reviewed during the Contractor Safety Assessment process, and the requirement will be fulfilled for the entire scope of work by the contractor on the project. CSR’s will be required to perform the following duties on the Project:

o Jobsite Inspections: The primary function of the CSR is to maintain a high level of presence in the field. Most of the CSR’s time must be spent in the field making jobsite observations and ensuring that all unsafe acts and conditions are abated. The CSR shall conduct and document safety inspections weekly for those contractor’s employees and those of the contractor’s lower tier subcontractors. The weekly inspection reports are to be provided to the General Contractor or Construction Manager, Sponsor, and its designated representatives.

o Accident/ Incident Investigations: The CSR is responsible for immediate verbal notification to the General Contractor or Construction Manager, Sponsor, and its designated representatives. The CSR is responsible for investigation of all accidents, incidents and near miss incidents.

Preliminary investigation findings for all incidents and accidents shall be provided to the General Contractor or Construction Manager, Sponsor, and its designated representatives within 4 hours of the occurrence.

Additionally, the CSR is required to assist the General Contractor or Construction Manager, Sponsor, and its designated representatives with facilitation of accident/incident review meeting.

o Recordkeeping: Each contractor is responsible for maintaining the OSHA Recordkeeping requirements and posting their company’s job-specific OSHA 300/300A form annually. Monthly reporting procedures for Hours, Incidents, and OSHA Rates will be established with the General Contractor or Construction Manager, Sponsor, and its designated representatives.

o Weekly Safety Documentation: All weekly documentation is required to be turned into the General Contractor or Construction Manager, Sponsor, and its designated representatives weekly. This will include but not be limited to, toolbox talks, inspections, JHA’s, etc. The General Contractor or Construction Manager, Sponsor and its designated representatives reserves the right to develop the program and details on how and what documentation is turned in weekly.

o Cooperation: Safety responsibilities include cooperation with the General Contractor or Construction Manager, Sponsor and its designated representatives, and others related to the project. Implementation of corrective actions for unsafe acts and conditions must be completed with documentation forwarded to the General Contractor or Construction

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Manager, Sponsor and its designated representatives immediately following implementation. CSR shall furnish General Contractor or Construction Manager, Sponsor, and its designated representatives with any and all documentation requested. This includes but is not limited to policies, programs, reports, etc.

o Equipment Inspections: All machinery, tools, equipment, and safety devices must be regularly inspected for deficiencies with documented inspection log. Any deficiencies noted will result in the item being tagged “out of service,” correction of the deficiency, or disposal of the item by the CSR. Equipment shall include but not be limited to; forklifts, personnel lifts, skid steers, and or rented equipment.

o First Aid/Medical Treatment/Blood-borne Pathogens: The CSR shall ensure that persons requiring first aid/medical treatment are brought to the immediate attention of the health care provider designated for the Project and follow established clinic protocols. This must occur in every case regardless of the severity. The CSR is to ensure that only properly trained personnel address Blood-borne Pathogens concerns.

o Permits: The CSR is responsible for initiating all required project specific work permits and submitting the permit to the General Contractor or Construction Manager, Sponsor, and its designated representatives for review.

o Safety Representative Meetings & Site Walks: The CSR is required to attend all weekly project meetings, safety representative meetings, or meetings requested by the General Contractor or Construction Manager, Sponsor, and its designated representatives. At the direction of the General Contractor or Construction Manager, Sponsor and its designated representatives, project safety walks shall be established on a periodic basis (daily, weekly, monthly, etc.) The full time, CSR shall attend and contribute to the walk. Contractors without a full time CSR, will make all feasible efforts to provide a representative (onsite competent person) at the walk.

o Safety Training: The CSR is required to verify and provide to the General Contractor or Construction Manager, Sponsor, and its designated representatives upon request training documentation for all state, local and federal safety requirements. Examples of this training include but are not limited to Hazard Communication, Fall Protection, Heavy Equipment Operator, Forklift, PPE, scaffolds, excavation, Confined Space, Scaffold Erection, and Competent Person etc. The CSR is required to conduct training with all employees under their supervision on the project on a regular basis to ensure their work force is adequately and properly trained in a timely manner.

o Disciplinary Action: The CSR is required to initiate disciplinary procedures when safety policies and procedures are violated, or at the request of the General Contractor or Construction Manager, Sponsor, and its designated representatives. Documentation of disciplinary actions shall be provided to the General Contractor or Construction Manager, Sponsor, and its designated representatives within 24 hours.

Page | 23 o Corrective Actions: Any unsafe acts or conditions that are observed or reported must be immediately abated. Written documentation of corrective actions is to be forwarded to the CMSR within 24 hours.

• Subcontractor Safety Representative (SSR) o Responsible for the protection of persons,…