Subcontractor Safety

Introduction

ICM promotes and maintains a safe and healthy work environment. Safety & Health is an integral part of our daily operations and valued as a performance standard for our employees, contractors, and vendors.

This document highlights many of the safety practices, which are your responsibility while working on ICM projects. You are responsible for maintaining our safe environment and ensuring the safety of your operations and your employees. Subcontractor employees who disregard these procedures, or endanger ICM employees or operations will be removed from the project.

The safety of your employees remains your responsibility. You (the subcontractor) must also ensure your activities do not endanger ICM employees or operations. Subcontractors are required to comply with the U.S. Occupational Safety and Health Act (OSHA)/MSHA and with all applicable state and local safety laws and regulations. You are also required to comply with accepted industry practices and ICM requirements applicable to the work performed.

The rules and practices described in this section are not intended to replace OSHA requirements or to be a complete summary of those requirements. You are responsible for complying with all such laws and accepted industry practices even if they are not discussed in this document. This section is intended to call attention to some standards and practices that you must comply with while working on ICM projects.

General Rules of Conduct

The following general rules of conduct apply to all contactors and their employees while engaged in work for ICM.

Alcoholic beverages, illegal substances or persons under the influence of such products are not permitted on ICM projects.

Firearms, explosives and ammunition are strictly prohibited on ICM property or project sites.

Employees must wear appropriate attire at all times, while onsite.

All posted instructional signs such as WARNING, CAUTION, RESTRICTED AREA, etc. must be followed.

Best management practices should be utilized to ensure safe and environmentally sound performance of all tasks.
Appropriate signage must be used to adequately redirect traffic in the event of road or property access closures.

Building exits and emergency equipment must be kept accessible at all times.

Outdoor painting, grinding or similar activities should be done away from building air handling equipment or air intake vents.

Your employees must have received appropriate safety training, provided by you, for their job tasks and for all chemicals and equipment to be used. Certification that training has been provided may be required by the Safety Office.

Property, equipment, and materials left at job sites is done so at your risk.

You must cooperate during any inspection of your work area by any authorized entity.

Smoking is permitted only in designated areas. You must use appropriate receptacles for all cigarettes and matches.

All incidents (whether or not there is an injury or damage) must be reported to your management and the ICM office.

Emergency Procedures

Immediate and orderly evacuation of all personnel in a commercial or industrial facility is critical during an emergency.

Each subcontractor shall understand the emergency action plan of the facility at which they are working. The plant addresses emergency evacuation procedures for such events as fire, hazardous chemical release, or other catastrophes.

Upon initial entry to the facility, the subcontractor project representative working on site will receive a tour of the facility to address egress routes, fire extinguisher locations, and evacuation assembly areas; the subcontractor project representative shall disseminate the same information to all persons working on his/her behalf.

In the event a subcontractor employee notices a chemical release, fire, injured employee, bomb threat or any other such situation, that employee is to notify site management immediately.

In the event a subcontractor is on the premises during an evacuation, the subcontractor employee is to evacuate with the employees of the area they are working in. If working alone, they are required to evacuate in a safe and immediate manner and find the nearest group and report with that group.

Overhead Work

Whenever work is performed above ground level and requires use of a ladder or raised platform, or when working above a suspended ceiling, the area must be barricaded to prevent injury to others. Tools used on high lifts or other raised surfaces must be attached with a safety line or ensure other measures are in place to prevent the tools from falling.

When barricades will prevent use of a regular route (aisle, corridor, etc.), signs identifying alternative routes should be posted.

Ladder Safety

Only non-conductive ladders shall be used for electrical jobs.

Match the correct ladder size for each job.

Ladders shall not be used as work platforms or stages.

Ladders utilized in access ways where they may be displaced must be guarded, blocked, and/or barricaded from passersby.

Fall Protection

Employees must be protected at all times against falls from elevated work platforms.

Each contract employee on a walking/working surface with an unprotected side or edge, which is 6 feet or more above a lower level, shall be protected from falling. The contractor is responsible for having established standards for the use of fall protection equipment. The subcontractor must provide the essential equipment required for each particular job and provide necessary training in its safe use to their employees, prior to utilization of said equipment. Fall protection equipment must meet OSHA and MSHA standards.

Floor openings must be covered or otherwise guarded to prevent injury to persons on a low level from falling debris or tools.

Scaffolding shall be erected in accordance with OSHA standards to ensure the safest and sturdiest work platforms are constructed.

Housekeeping

Aisles and corridors shall remain clear at all times.

Exits and emergency equipment (fire extinguishers, first-aid kits, etc.) shall be accessible.

Debris, dust, etc., shall be cleaned periodically. The subcontractor should remove all scrap daily from the site.

Materials and supplies should be stored in a safe manner to prevent injury or damage.

Spills shall be cleaned up immediately.

Cords and hoses shall not cross aisles or corridors. When necessary, these may be hung at ceiling level or be appropriately enclosed to prevent tripping.

Dust producing operations such as drywall installation, grinding, etc. shall be adequately contained to minimize the impact on nearby work areas.

Soiled rags or garments must be stored in non-combustible containers recognized by a national testing organization (Underwriter’s Laboratory & Factory Mutual) and be removed each day from the site by the subcontractor.

Burning, Welding, or Cutting (Hot Work)

“Hot work” such as burning, welding or cutting presents a special hazard. A permit process must be implemented to ensure adequate controls are in place to prevent fire or other damage due to these processes.

A permit or contractor provided form is required before using any portable heating unit or performing ANY burning, welding, or cutting. You must obtain the appropriate permits prior to any “hot work.” Local, state and/or federal regulations may also apply to these processes.

Whenever possible, “hot work” should be done outdoors away from buildings and any landscaping. All combustible materials must be removed or adequately shielded prior to any “hot work.”

Subcontractors are also responsible for ensuring that personnel performing “hot work” have been appropriately trained.

A person qualified must perform a fire watch for at least 30 minutes after the completion of any “hot work.”

“Hot work” must terminate at least 30 minutes prior to the end of each shift.

Subcontractor must provide appropriate fire extinguishers for use during fire watch.

ICM fire extinguishers and other equipment should not be used.

Fire Safety

Good housekeeping practices are essential to fire safety and are expected to be followed as all times.

Each subcontractor is expected to familiarize themselves with the location of the fire extinguisher nearest their work.

Only contractor’s that are qualified to fight fires shall do so.

If a qualified contractor employee discovers a fire, he/she is to use the nearest fire extinguisher, if they are not able to extinguish the fire, they shall notify 911 emergency immediately. Upon extinguishing a fire, the subcontractor shall notify ICM or the Project Manager of the situation immediately.

Fire System Impairment

Such operations may necessitate the temporary shutdown of some fire protection systems such as sprinklers, fire/smoke detectors, etc. These impairments should be avoided whenever possible.

Prior to any fire protection impairments, you must notify the ICM Project Manager. Facilities may have fire protection impairment plans, which may include notification to the local fire department and alarm companies.

Hot work (cutting, welding, etc.) is not permitted during a fire protection impairment.

You may be required to staff and equip a fire watch during an impairment in order to continue work.

Fire protection impairments should be for the shortest duration possible and restored to full service at the earliest opportunity.

Fire protection systems must be restored at the end of each day.

Personal Protective Equipment (PPE)

You must provide you own PPE as necessary for the work area. Typically, safety glasses and/or safety shoes may be required. The Project Manager and/or posted signage will inform you if PPE is required in your work area.

Your operations may introduce hazards to our work areas, which would require ICM employees and visitors to wear PPE. You must post appropriate signage to identify these hazardous areas and the PPE necessary to prevent injury.

Compressed Air

Compressed air may be used for various tasks. Whenever possible, cleaning should be done using a vacuum rather than compressed air.

Compressed air used for cleaning must be regulated to 30 psig or less.

Hand held nozzles must have pressure activated triggers and all air hoses must have quick disconnects.

Compressed air must not expose employees to flying debris. Compressed air must not be used for dusting off your clothing.

Air hoses or lines should not cross aisles, corridors or other traffic areas.

Compressed air shall not be used for air supplied respirators or breathing air.

Tools and Equipment

Subcontractors are responsible for ensuring all tools and equipment used on ICM premises and job sites are in safe operating condition.

Tools should be inspected at least daily to identify and repair/replace any damage.

Tools should not be left in aisles, corridors or on ladders or other raised surfaces.

Tools used on raised platforms should be secured with a safety line or other method to prevent them from falling.

Pneumatic or air actuated tools should be disconnected when not in use.

Use of tools or equipment, which produces dust or other particulate, must have adequate controls in place to minimize/prevent particular fallout.

Non-sparking or explosion-proof tools/equipment must be used in flammable liquid storage areas or where concentrations of flammable vapors or combustible dusts may exist.

Evacuations & Trenches

Before starting any excavation work, the Contractor must determine the existence and location of all underground utilities, pipes and other service equipment and connections. Contractors are responsible for any damage or disruption of service caused during an excavation or trench work.

Excavations and trenches around existing structures must be done so without undermining the foundation or other structure/supports.

Appropriate shoring or other protection shall be used as required by local, state and/or federal regulations for trenches. Your designated competent person is responsible for evaluating and approving all excavation slopes, shoring, etc.

Excavations and trenches must be adequately barricaded to prevent unauthorized access. Barricades must enclose all access points and provide adequate clearance around the perimeter of the site.

Warnings for the movement of equipment and adequate barriers for the swing distance/rotation of equipment must be properly posted.

Illumination and warning markers must be present to ensure excavations can be adequately identified, especially during darkness.

Confined Spaces

Prior to entering confined spaces and performing any work, you must coordinate your confined space entry program with ICM’s confined space program.

Contractors shall provide all of the equipment necessary and required for the safe operation of a confined space entry procedure.

A confined space permit shall be obtained prior to entry in to a confined space.

Confined space entries shall not be made without the consent and prior knowledge of the ICM Point of Contact and Safety Department.

Questions regarding access and entry to any confined space should be discussed with the ICM Point of Contact or ICM Safety Department.

Hazardous Energy Control (Lockout/Tagout)

Control of hazardous energy (lockout/tagout) is required prior to performing any service or maintenance activity on all equipment at ICM.

Subcontractor employees are required to follow (at a minimum), the applicable OSHA Standard for lockout/tagout safety.

ICM requires all powered equipment to be locked out whenever any part of an employee’s body enters any point of operation, by-passing any safety device, guard, or barrier, or when working on live electrical parts unless the individual is a certified electrician.

Lockout/Tagout procedures shall be followed whenever working with potentially dangerous chemical systems, high-pressure systems, electric systems, temperature extremes, or any other procedure or equipment with a stored energy source.

Lockout/Tagout also includes servicing, adjusting, maintenance, or unjamming equipment with any of the above systems.

Electrical Safety

You are responsible for meeting all applicable state and local statutes, codes, etc. regarding electrical safety.

All temporary electrical connections must be grounded and properly insulated, or GFI protected.

Cables and power supply cords shall be placed in a manner to prevent trips, falls and other hazards. Only 3-wire extension cords may be used.

Contractors are responsible for all temporary wiring and must provide adequate ground-fault circuit interrupters as required.

All electrical equipment and temporary wiring must be inspected periodically and repaired/replaced as necessary.

Wiring should be protected from dust, oils and moisture.

Explosion proof equipment and fixtures must be used in areas where flammable liquids are stored, flammable vapors may be present or combustible dusts are likely to be present.

Material Handling

Manual material handling and other physical activities must be performed only by those employees physically able to do so. Prior to performing a task requiring physical stress, each employee must ensure it can be done safely, get others to assist, or use mechanical equipment to perform the job safely.

Safe and proper operation of any powered industrial vehicle is important for the safety of all employees.

Subcontractor employees are to be alert at all times for powered industrial vehicle traffic. It is the responsibility of both pedestrians and vehicle operators to be alert and avoid accidents.

Subcontractors are responsible for providing their own powered industrial vehicles and equipment, unless authorized by the ICM Project Manager. All operators must be trained.

Internal Combustion Engines

Gasoline, LP gas or other internal combustion engines may not be operated without adequate ventilation. These engines when located outside, should be positioned away from air handling equipment or air intake vents.

Tarapaulins

Tarapaulins used for hot slag, dust, painting, etc. should be in good condition and free from accumulation.

The tarapaulins must be flame resistant.

Tarapaulins should be used to cover openings when transporting large containers to prevent debris or other materials from blowing out.

Combustible Trash & Refuse

Combustible trash and refuse materials must be removed from the work area periodically, but at least once each day.

Contractors are responsible for providing dumpsters or other approved containers for collection of combustible trash and materials.

ICM’s garbage/refuse containers shall not be used without authorization of the Project Manager.

Containers used for combustible materials must be stored at least 25 feet from any existing building.

Containers should be located to provide safe access for collection vehicles and minimize damage to landscaping.

The Subcontractor will be responsible for any damage to the premises resulting from work performed by you or your company.

Whenever possible, you should segregate and arrange for recycling of combustible construction materials.

Motor Vehicles

Motor vehicles operated on customer’s premises must obey all posted traffic and information signs.

Park vehicles in designated areas.

Be sure your vehicles do not block an emergency exit or access to emergency equipment such as fire hydrants, sprinkler controls, etc.

Parking in a fire lane is prohibited. Your vehicle may be towed and you will be responsible for all fees and charges if your vehicle presents a hazard.
Vehicles used onsite should be in good condition. The use of horns or other equipment producing noise (compressors, etc.) should be limited near office buildings.

Any Subcontractor vehicles found to be leaking fluids or otherwise present potential hazards to customer’s premises will be required to be removed immediately.

Incident Investigations

Point of Contact and Safety Department investigates all workplace incidents, whether or not there is an injury or damage to property.

Subcontractors are responsible for reporting incidents to your management as required by your safety program.

You must immediately report all incidents occurring on customer’s property or project premises to the ICM Safety and Project Manager. You must complete an incident investigation to identify the cause(s) and any action needed to prevent recurrence within 24 hours of the incident. Joint incident investigations with your safety representative may be required when deemed necessary by ICM. The findings of our investigation will be available to your management by written request of the Safety & Health Office.

Reporting Hazards, Unsafe Acts, or Conditions

Hazards you identify which are within the control of ICM should be reported to ICM and Project Manager immediately. These hazards will be investigated and corrective action taken, when appropriate.

Hazard Communication

ICM Hazard Communication Program facilitates the exchange of information on hazards, emergency procedures and safety precautions when working with hazardous chemicals or substances. As a contractor of ICM, you have certain responsibilities to ensure adequate communication of hazards you introduce into the workplace.

Hazardous chemicals/substances include gases, liquids, solids and chemical mixtures.

Subcontractors are required to notify the ICM Safety Office and the Project Manager of any chemicals or substances you will be bringing onsite for use prior to your work.

Material safety data sheets (MSDS) for each chemical/substance must be maintained onsite and available to the ICM Safety Office.

All containers used to store chemicals/substances must be appropriately labeled in an easy to understand method such as the NFPA labeling system or other common methods.

Subcontractors are required to immediately remove unlabeled or unauthorized chemicals.

Subcontractors must provide adequate personal protective equipment for your employees when they work with or in areas containing hazardous chemicals.

The ICM Project Manager will provide you information on chemicals/substances that may be present in your work area and the container labeling system used. Material safety data sheets are available in the work area where the chemical/substance is used. MSDS or other information should be requested through your Project Manager.

Subcontractors are responsible for informing their employees of the chemicals in their work area, the hazards (if any) and appropriate precautions.

Storage of flammable and combustible substances should be limited to one days supply in safety cans, which have been recognized by a national testing organization such as an Underwriter’s Laboratory (UL) or Factory Mutual (FM).

Appropriate precautions such as grounding/bonding and flame arrestors are also required when transferring flammable liquids.

SMOKING IS NOT PERMITTED WHEN HANDLING HAZARDOUS CHEMICALS OR SUBSTANCES.

Chemical Spills

All chemical spills must be reported even if you do not require any assistance to address the spill. You should identify the location of the spill and the substance, if known, and if medical assistance is necessary.

You should prevent others from entering an area of a chemical spill until the local emergency services arrive.

Do not attempt to clean the spill unless you have been properly trained and have the necessary personal protective equipment and other materials.

Chemical/Substance Disposal

You are responsible for the safe and legal disposal of all chemicals and substances brought and/or used onsite.

No chemical or substance waste is to be placed in ICM refuse containers or released into the air, water or soil.

Whenever possible, chemical recovery or recycling should be utilized.

Chemical waste storage must be discussed with the ICM Project Manager prior to generating any waste.

Environmental Protection

ICM is committed to preservation of the environment for future generations. The following is an overview regarding safe environmental performance:

Subcontractors are responsible for maintaining a clean and safe environment while working on ICM. Inc. projects.
Subcontractors must comply with all local, state, and federal laws and regulations regarding environmental protection.

Whenever possible, construction debris and materials should be recycled rather than disposed of in landfills or by other means.

Subcontractors must ensure nothing enters site storm drains.

The use of unattended pumping or transfer operation is not permitted.
Contractors are responsible for the clean up and restoration of all spills or other environmental contamination caused or aggravated by your work or employees.

Other practices and precautions may be required depending on your project.

SUBCONTRACTOR SAFETY GUIDELINES ACKNOWLEDGEMENT

Subcontractor_____________________________________________________________________

Address__________________________________Phone_____________Fax #______________

License No._______________________________________________Expiration____________

I acknowledge receipt of the ICM Subcontractor Safety Guidelines. I have read the attached Subcontractor Safety Guidelines as they apply to contractors working for ICM. I and all my agents, employees, and subcontractors will abide by all the Guidelines while under contract with ICM. I will inform the contract employees of the content and requirements. I understand and agree that the Guidelines will be used as a reference and as a minimum standard of conduct. All contract employees shall do their utmost to ensure that any hazards identified will be eliminated immediately before proceeding.

Contract employees will also follow all applicable OSHA regulations and other industry guidelines which the work may be affected by. I understand that if any of the subcontract employees are found to be in non-compliance with this contractor safety program, or OSHA regulations, corrective action can be taken by ICM depending on the severity and/or frequency of the infraction, including immediate removal from the worksite and termination of the work contract.

Company______________________________________________________________________

Designated Representative (print name)______________________________________________

Signature_____________________________________________Date_____________________