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ESH Manual Page: 7000: Occupational and Subcontractor Safety

The Sanford Underground Laboratory at Homestake (hereafter called Sanford Laboratory) is committed to providing and maintaining the safest possible work conditions for all workers by promoting the integration of safety management into all contractor processes.
Project managers, safety representatives, and foremen are responsible for implementing and maintaining an effective safety program. It is the responsibility of these individuals to ensure workers under their supervision maintain safe work areas and perform their tasks in a safe manner. It is also the responsibility of each worker to follow every precaution and Sanford Laboratory safety rules and policies to protect themselves and their fellow workers.

Sanford Laboratory will monitor subcontractor safety programs and performance to ensure compliance with Laboratory requirements. When performing work at Sanford Laboratory, each contractor:

  • is responsible for the safety of their employees, subcontractors, and/or visitors as required by the rules and regulations of this chapter; 29 CFR 1926 Safety Standards for the Contractor Industry; and all local, state, and federally recognized standards and codes.
  • is required to understand and follow the contents of this chapter.
  • is responsible for training and educating their employees, subcontractors, and/or visitors, as to the contents of this chapter and requirements for conduct of work at Sanford Laboratory. (Documentation of all training is the responsibility of the contractor.)

Where conflict between cited standards or safe practices occurs, the EHS Department will determine which standard shall apply.


This policy applies to all contractor activities performed by non-Laboratory employees under the supervision of contractors.

2.1. Contract Employees

The safety rights and obligations of contract employees are the same as those of Laboratory employees. Those supervisors assigned to direct the work of contract employees must verify that contract employees are afforded conditions equivalent to those provided to Laboratory employees, including training and personal protective equipment (PPE).

2.2. Contractor Safety Qualification

Contractor selection shall include an evaluation of the contractor's prior safety performance, the contractor’s current written safety programs, and qualifications of key EHS personnel to assure Sanford Laboratory that the contractor is capable of meeting its safety performance goals. All contractors being considered to perform contractor activities at Sanford Laboratory controlled sites and property shall undergo such an evaluation.

The Sanford Laboratory project management and procurement team shall evaluate the information submitted by the contractors. Contractors shall demonstrate an equivalent process in the selection of lower-tier subcontractors and submit evaluation criteria and results to Sanford Laboratory.

2.3. Contractor On-site Health and Safety Representative Qualifications

The contractor shall provide a qualified on-site Health and Safety Representative, accepted by the Sanford Laboratory Project Manager, with the authority to enforce all of the safety requirements of this program, including implementation of the subcontractor’s Injury and Illness Prevention Program and Project EHS Plan.
Sanford Laboratory project management and the EHS Department will make a risk- based decision as to the qualification level of the contractor EHS representative. Requirements may range from a full-time on-site safety professional (Certified Safety Professional) to a craft supervisor with competency as measured by experience training.
During periods of active work, the contractor must have a designated representative on the worksite that is knowledgeable of the project’s hazards and who has full authority to act on behalf of the contractor. The contractor’s designated representative must make frequent and regular inspections of their worksites to identify and correct any instances of noncompliance with the project health and safety requirements.

2.4. Qualification Evaluation

Based on the level of EHS qualification determined necessary by Sanford Laboratory, the contractor shall submit the following documentation, for review and acceptance by the Sanford Laboratory Project Manager, in support of the proposed candidate:

  • Professional certifications (CSP, CIH, ASP, etc.).
  • Curriculum vitae detailing work experience and EHS responsibilities on projects of similar scope for the previous five years, at a minimum.
  • Evidence of safety training with a minimum of the 10-hour OSHA training (the requirement will be modified as necessary and may require the 30-hour OSHA Contractor supervision training or successful completion of the OSHA 500 program).
  • Proof of Competent Person or Qualified Person status attained by the proposed on-site EHS representative.

A contractor shall replace his or her EHS Representative at the discretion of the Sanford Laboratory Project Manager within 24 hours upon written notification if the EHS Representative is unsuccessful in enforcing project safety requirements.


ANSI: means American National Standards Institute

Authorized person: means a person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite.

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

Confined Space: is a space that (1) is large enough and so configured that an employee can enter bodily, (2) has limited or restricted means for entry or exit (e.g., tanks, vessels, vaults, shafts, pits), and (3) is not designed for continuous occupancy.

Contractor Manager: is the Sanford Laboratory employee responsible for the supervision and field management of day-to-day needs of a contractor project. It may be a project superintendent, a craft supervisor, or a lead person.

Contractor Safety Engineer: is the Sanford Laboratory Environment, Health and Safety Department's representative responsible for overseeing the safety and health management of contractor activities. This person monitors and documents compliance with the applicable safety and health codes, standards, and regulations.

Contractor work: For purposes of this section, "contractor work" means work for contractor, alteration, and/or repair, including painting and decorating.

Contractor: is a person, partnership, corporation, subsidiary of a corporation, firm, association or other organization that contracts to perform construction at the Sanford Laboratory property.

Controlled Access Zone (CAZ): means an area in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled.

Imminent Danger: is any condition or practice that could reasonably be expected to cause death or serious physical harm (permanent or prolonged impairment of the body or temporary disablement requiring hospitalization) to employees or the public unless immediate actions are taken.

Project Inspector: is the Sanford Laboratory representative responsible for monitoring contractor quality and verifying compliance with the terms and conditions of the design documents.

Project Manager: is the Sanford Laboratory employee representative with overall responsibility for a project. This person ensures contractor compliance with contract documents, including performance, schedule, budget, and safety.

Shall: means mandatory

Should: means recommended

Subcontractor: is a firm that has sole contractual responsibility for execution of the contractor work related to a project, and for compliance with all safety, health, and environmental codes, standards, and regulations.

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 ability to solve or resolve problems relating to the subject matter, the work, or the project.


4.1. Contractor Health and Safety Representative Responsibilities

The contractor EHS Representative shall:

  • Assist in the development of the contractor’s safety plan and job site management system
  • Support training of contractor personnel
  • Evaluate the contractor safety process continuously
  • Respond to questions regarding the contractor safety process
  • Attend pre-job meetings to discuss their site-specific safety plan
  • Conduct and document job site safety audits.
  • Assist in the identification of jobs requiring an activity-based hazard analysis.

4.2. Competent Person

Each contractor shall provide to Sanford Laboratory a written list of those persons on- site who are capable of identifying existing and predictable hazards in the surrounding
or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.
Contractors shall ensure that each competent person listed has been trained in the following areas as applicable:

  • Asbestos
  • Cranes
  • Confined Space
  • Demolition
  • Excavations
  • Fall Protection
  • Ladder
  • Scaffold
  • Steel Erection
  • Underground Contractor

4.3. Qualified Person

Each contractor shall provide to Sanford Laboratory a written list of those persons on- site who by possession of a recognized degree, certification, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated their ability to solve or resolve problems relating to the subject matter, the work, or the project. Subcontractors shall ensure that each qualified person listed has been trained in the following areas as applicable:

  • Asbestos
  • Hazardous Waste Operation
  • Crane
  • Chemical Hazards
  • Concrete & Masonry Const.
  • Electrical, Overhead Lines
  • Steel Erection, Open Joists, Site Layout, and Plan
  • Hoist & Rigging
  • Scaffold
  • Underground Const.
  • Gases, Vapors, Dust, Mist,
  • Ventilation
  • Material Hoisting, Personnel Hoist, Elevators
  • Excavation

Each contractor shall provide Sanford Laboratory with a written IIPP. The IIPP or the IIPP with a Site Specific Safety Plan shall contain at a minimum:

  • The name of the On-site Health and Safety Representative who is responsible for the implementation of the plan, their qualifications, and what roles this person will play during the project.
  • The company policy and senior company officer statement on environment, safety and health.
  • The company safety management and safety oversight plan.
  • A list of those project activities for which subsequent activity-based hazard analysis are to be performed.
  • The company policy on substance abuse and testing policies if applicable.
  • Code of Safe Practices.
  • How and when each contactor will conduct their toolbox safety talks.
  • Provisions for conducting and documenting job site safety inspections by supervision.
  • Training methods used to meet OSHA training requirements.
  • Incident reporting, first aid, and emergency procedures. Details for the management of work related injuries.
  • List of competent persons overseeing those tasks in which OSHA requires such person(s), such as excavation, confined space, fall protection, etc.

Lower tier subcontractors may utilize and abide by the Prime contractor’s written (IIPP) or Site-specific safety program. Prime contractors that engage lower tier subcontractors shall submit written documentation for each lower tier subcontractor that demonstrates the methods of compliance with the site specific EHS plan requirements.


Contractors shall submit a Job Hazards Analysis (JHA) for their work. The JHA shall be approved by the Sanford Laboratory Project Manager before work commences.
Each employee scheduled to work in the activities identified below shall receive safety training in those activities prior to working on them. The contractor shall maintain proof of employee training at the work site and make it available to the Sanford Laboratory Project Manager upon request (Toolbox safety meetings are an acceptable forum to meet this requirement).
Contractors shall be responsible for submitting a JHA and work procedures to the Sanford Laboratory Project Manager for review prior to the start of work.
The contractor must maintain 2 copies of the Sanford Laboratory approved JHA. The first copy to be maintained with the project files; the second copy shall be posted on the jobsite/project in a conspicuous location.

6.1. JHA Requirements

A JHA shall be written based on the following conditions:

  • Jobs with the highest injury or illness rates
  • Jobs with the potential to cause severe or disabling injuries or illness, even if there is no history of previous accidents
  • Jobs in which one simple human error could lead to a severe accident or injury
  • Jobs that are new to your operation or have undergone changes in processes and procedures
  • Jobs complex enough to require written instructions.

If not otherwise specified in a particular project specification, the JHA shall be performed in accordance with the OSHA 3071 JHA processes. In general the JHA will include:

  • Description of work phase or activity
  • Identification of potential hazards associated with the activity
  • Address further hazards revealed by supplemental site information (e.g., site characterization data, as-built drawings) provided by the contractor’s contract manager.
  • A list of the contractor’s planned controls to mitigate the identified hazards
  • Identification of specialized training required
  • Identification of special permits required

• Name of the contractor’s competent persons responsible for inspecting the activity and ensuring that all proposed safety measures are followed.

6.2. Additional Requirements for Reporting Hazardous Conditions
Workers must be instructed to report to the contractor’s designated representative hazards not previously identified or evaluated. If immediate corrective action is not possible or the hazard falls outside of project scope, the subcontractor must immediately notify affective workers, post appropriate warning signs, implement needed interim controls measures, and notify the Sanford Laboratory Project Manager of the action taken. The contractor or the designated representative must stop work in the affected area until appropriate protective measures are established.

6.3. Review of Work Planning Packages

The EHS Department Contractor Safety Engineer (CSE) is responsible for coordination, tracking, and final approval for the ESH review of Sanford Laboratory contractor activities. The Project Managers (PMs) receive all required safety documents from the subcontractors and have them available in the Work Planning Packages for review by the CSE. Work Planning Packages may require review by several EHS Subject Matter Experts.


Contractors shall submit for review to the Sanford Laboratory Project Manager any worker, environment or property protective system required by EHS regulation to be designed by a registered professional engineer. Sanford Laboratory’s review of such system is solely to verify that the subcontractor has had the required protective systems prepared and stamped by a registered professional engineer.

Sanford Laboratory’s review of any documents showing the design or contractor of protective systems for worker and property protection shall not relieve the contractor of its obligations to comply with applicable laws and standards for the design and contraction of such protective work.


The contractor shall submit to the Sanford Laboratory Project Manager, for review, any proposed procurement, stocking, installing, or other use of materials containing asbestos, cadmium, chromates, or lead. Additionally, the contractor shall submit the product Material Safety Data Sheet (MSDS) for architectural and surface coatings, solvents, adhesives, sealants, oils, compressed gases, pesticides, herbicides, welding materials, or other chemicals used in the contractor process, for review and acceptance by the Sanford Laboratory EHS Department prior to the start of work.


Contractors shall provide a workforce that is trained to the requirements set forth in general and in the specific substance-and subject-specific standards of 29 CFR 1926 and as applicable 29 CFR 1910. Contractors shall be able to demonstrate satisfaction of training requirements.


All contractors and their lower tier subcontractors shall require and administer pre-job training/orientation on Sanford Laboratory and contractor safety program requirements to all employees prior to engaging in work activities. The contractor shall maintain on the work site a detailed outline of the orientation and a signed and dated roster of all employees who have completed the project EHS indoctrination. The orientation program shall address the following elements at a minimum:

  • Employee rights and responsibilities
  • Responsibility for Stop Work Order (imminent danger)
  • Contractor/subcontractor responsibilities
  • Alcohol and drug abuse policy
  • Contractor’s disciplinary procedures
  • First aid and medical facilities
  • Site and project specific hazards
  • Hazard recognition and procedures for reporting or correcting unsafe conditions or practices
  • Procedures for reporting accidents and incidents
  • Firefighting and other emergency procedures to include local warning and evacuation systems
  • Hazard Communication Program
  • Access to employee exposure monitoring data and medical records
  • Protection of the environment, including air, water, and storm drains from contractor pollutants
  • Location of and access to reviewed project Illness and Injury Prevention
  • Program, Hazard Analysis and Hazard Abatement Plan
  • Location and contents of required posting

10.1. Toolbox Talks

All contractors are required to conduct and document daily pre-shift toolbox talks. These talks shall be conducted at the site and address safety information relevant to the work to be performed. Attendance by all site personnel is mandatory. An attendance roster of signatures shall be collected and filed with a copy of the toolbox talk.

10.2. Safety Instruction for Employees

The contractor shall permit only qualified persons to operate equipment and machinery.
Where employees are subject to known job site hazards, such as flammable liquids and gases, poisons, caustics, harmful plants and animals, toxic materials, confined spaces, etc., they shall be instructed in the recognition of the hazard, in the procedures for protecting themselves from injury, and in the first aid procedure in the event of injury.


An emergency is any situation that poses an immediate threat to life or property. This would include but not be limited to collapse of a building or a portion thereof, fire, explosion, equipment failure such as collapse of a crane, release or exposure to toxic liquids, vapors, or fumes, presence of gas or other explosive atmospheres, flood, earthquake, etc. Violent or suspicious behavior may also be cause for initiating emergency procedures.

11.1. Procedures

Each contractor must ensure that they maintain one person currently qualified in American Red Cross or equivalent CPR and First Aid on site at all times. In the event of a life threatening of other serious incident (fire, injury, etc.) requiring the assistance of outside personnel, contact Sanford Laboratory emergency services immediately at:

  • Call 9-1-1 for assistance

Upon calling, the person shall state their name, their contractor's name, the location of the emergency, and the type of emergency. The caller must stay on the call until released by the emergency dispatcher. The Sanford Laboratory Project Manager shall be contacted as soon as practicable.

The Sanford Laboratory Project Manager will provide direction to the contractor on evacuation procedures as the job progresses. For emergencies involving evacuation, all contractor personnel shall follow the developed, posted evacuation routes to their designated assembly point, remain there until they are accounted for, and an "all clear" or alternate directive is given. In the event of an evacuation, the contractor shall immediately notify Sanford Laboratory of any missing personnel.
Following the occurrence of an emergency, the contractor shall ensure that all proper incident reports are completed and distributed in the required timeframe.
A list of "key" on-site and home office personnel (with 24 hour phone numbers) shall be developed by each contractor and submitted to the Sanford Laboratory Project Manager prior to commencement of work.
The Sanford Laboratory Project Manager or designated Sanford Laboratory management team member in off-hours will take charge in the event of a major catastrophe. One or all steps are to be followed:

  • Stop work
  • Take whatever actions are needed to make people on the project safe.
  • Call 9-1-1 for assistance
  • If necessary, call for site evacuation with roll call and clear site access roads
  • Issue instructions to all supervisors and employees
  • Set up security control at the emergency area
  • Refer all media requests to the Sanford Lab Media Affairs Office.

In the event a job site accident occurs, the contractor shall immediately implement controls and restrictions on the accident site to ensure the site remains undisturbed until released in- writing by the Sanford Laboratory Project Manager to resume work.

12.1. Procedures
Near Miss / Injury-free Event
It is the responsibility of the contractor, to complete all Near Miss investigation, and to report these occurrences with recommendations / implementation of corrective actions. The report will be submitted to the Sanford Laboratory Project Manager within 24 hours.
First Aid Event
It is the responsibility of the contractor to collect and log the contractors' incident reports and recommend corrective action. The incident logs and work hour statistics will be sent to the Sanford Laboratory Contractor Safety Engineer by the 1st of each month.
Medical Treatment Event
If the injury is considered an emergency, immediately call 9-1-1 from laboratory phones and 9-1-1 from any cell phone. It is the responsibility of the contractor to immediately notify the Sanford Laboratory Project Manager.
Serious Injury Event
It is the responsibility of the Prime subcontractor to immediately notify the Sanford Laboratory Project Manager, of any serious event requiring medical treatment. Refer ALL media inquiries to Sanford Laboratory Media Relations, Media Affairs Office, at office 605-722-8650.


A stop work order must be given when imminent danger is identified or where significant damage to equipment or property or environmental degradation could occur if the operation continued. When a stop work order is issued, only those areas of a contractor project immediately involved in the identified hazardous situation are to be included in the order.
Any employee that observes an imminent-danger situation is responsible for stopping the work and reporting it to the contractor representative at the work site;
Immediately after stopping work, the person issuing the order must report to the Sanford Laboratory Project Manager, Contractor Safety Engineer, of his/her action. Sanford Laboratory personnel will be dispatched to the site to verify that the operation has stopped and that the stop order was exercised in a justifiable and responsible manner.
Work may only resume when the Project Manager has agreed that the imminent danger has been eliminated. Notification to restart work will be passed to the subcontractor by the Project Manager.
13.1. Stop Work Memorandum Safety Deficiency Notice
Following a Stop Work action by Sanford Lab, a Safety Deficiency Notice will be issued to the contractor by the Sanford Laboratory Contractor Safety Engineer; it will reference the appropriate OSHA regulation and the subcontractor provision that caused the work stoppage.


To ensure compliance to this program Sanford Laboratory’s disciplinary hereby implements this procedure of non-compliance to all contractors working on Sanford Laboratory controlled property. This is established to promote safety and eliminate offenders and repeat offenders, and may lead up to contract termination with a subcontractor. This program may be used or may be superseded with more severe discipline based on the degree of the infraction(s). The Sanford Laboratory has sole authority to deny site to individuals or organizations that fail to follow safe work practices.

  • First offence, give a verbal warning keep written record of the offence/notify his/her supervisor
  • Second offence, give a written warning with his/her supervision is brought into the office for a "discussion" with the contractor superintendent and the Sanford Laboratory Project Manager along with the Sanford Laboratory Contractor Safety Engineer. A copy of the written warning is sent to the offending workers company's office, with a statement to the effect that if this happens again the worker will be removed from the project and could lead to a termination of the contract.
  • Third offence the worker is removed from the project.
  • If repeat occurrences with other crewmembers are found the supervisor of said offenders shall be subject to removal from the project.

All visitors are required to report to the project field office upon entering the project site. Access to the site shall be denied to any individual who does not have justifiable business on the job site.
Requests for tours of the project site shall be carefully screened and limited in frequency and numbers of people. Tours of the site shall be approved by the Sanford Laboratory Project Manager and Sanford Laboratory Contractor Manager and shall be conducted during non-working hours.
Sanford Laboratory shall establish the time and travel route for any tour. Areas which may present hazards to the tour groups shall be prohibited. The tour's travel route shall be cleared of any tripping hazards, cleaned, and properly protected to avoid potential personal injury. A designated member of the Sanford Laboratory management team shall guide the approved tours. All members of a tour group shall sign a release prior to touring the site.
Any project site visitors who are permitted access to the site but are not on official on- site business shall sign the release before being authorized to proceed beyond the project office.
All visitors must wear long pants, shirts with sleeves over the shoulder, hard hats, safety glasses, and hard-soled work shoes or boots when on site.


16.1. Codes and Standards

Contractors shall comply with the requirements, in case of conflict or overlap of the above references, the most stringent provision shall apply.

  • Occupational Safety and Health Act (OSHA)
  • 29 CFR 1926, Occupational Safety and Health Standards for Contractor
  • 29 CFR 1910, Occupational Safety and Health Standards for General Industry
  • National Electrical Safety Code, ANSI C2
  • National Fire Protection Association (NFPA) 70E 2005, Standards for Electrical

Safety in the Workplace

  • NFPA 51B, Fire Prevention During Welding, Cutting, and Other Hot Work
  • NFPA 241, Safeguarding Contractor, Alteration, and Demolition Operations
  • ANSI Z88.2 – 1992 Respiratory Protection
  • ANSI (Z 308.1) First aid kit on this job site