Development, Validation, Implementation and Enhancement of a Voluntary Protection Programs Center of

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Development, Validation, Implementation and
Enhancement of a Voluntary Protection Programs
Center of Excellence (VPP CX) Capability for
Department of Defense (DoD)

• The VPP Model of Interacting with Contractors

Department of Defense Voluntary Protection
Programs Center of Excellence Operated by
DoD Lead AgentOffice of the Assistant
Secretary of the Army (Installations and
Environment)
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Objectives

• After this training you will be able to
• Define a Department of Defense (DoD) contractor
• Describe the Voluntary Protection Programs (VPP)
  requirements relating to contractors
• Describe contractor selection considerations for
  safety
• Identify government and contractor
  responsibilities for contractor work performed at
  a VPP participant site
• Describe basic safety and security procedures
  that should be covered during contractor
  orientation
• Describe contractor requirements for control of
  environmental/health hazards
• Describe the use of contractor work permits

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Contractors

• A contractor is a non-federal employer performing
  under a DoD contract.

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VPP Contractor Classifications

• A resident contractor is one whose employees
  are regularly intermingled with site employees
  and are directly supervised by site personnel.
  They are sometimes called personal services or
  nested contractors.

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VPP Contractor Classifications

• An applicable contractor is one whose employees
  worked at least 1,000 hours for a VPP site in any
  calendar quarter within the last 12 months and
  are not directly supervised by site personnel.

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VPP Requirements - All Contractors

• All contractor employees must
• Comply with Occupational Safety Health
  Administration (OSHA) requirements
• Comply with applicable site safety rules
• Receive awareness information from the site
• Key hazards, recognition methods, and controls
• Key Site safety rules
• Emergency Procedures
• Site participation in VPP and VPP fundamentals
• Receive training from their employer
• Employee rights under the Occupational Safety and
  Health (OSH) Act
• Relevant hazard controls and Personal Protective
  Equipment (PPE)

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VPP Requirements Resident Contractors

• In addition to meeting the requirements for ALL
  contractors, a site using resident contractors
  must
• Include nested contractor employees mishaps in
  the site injury/illness rates
• VPP sites routinely include nested contractor
  employees in the sites Safety and Health (SH)
  employee involvement activities, such as
• Training and awareness programs
• Emergency drills
• Safety and health teams and committees
• Problem solving initiatives

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VPP Requirements Applicable Contractors

• In addition to meeting the requirements for ALL
  contractors, a site using applicable
  contractors must
• Maintain TCIR and DART rate data for all
  applicable contractors based on hours worked at
  the site
• Consider SH in the contractor selection process
• Monitor contractor SH performance and encourage
  improvement when appropriate
• Provide for identification and correction of
  uncontrolled hazards in contractor work areas
• Provide for removal of contractor employees for
  SH violations

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Safety Consideration for Selecting Contractors

• Work with the Contracting Officer Representative
  (COR) to select contractors based on their
• Comprehensive safety and health management system
• Low mishap rates as compared to competitors
• Understanding of hazards and proposed hazard
  controls
• Relevant SH qualifications
• Careful selection and oversight of contractors
  ensures quality SH protection at installations

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Leadership ResponsibilitiesContractor Orientation

• Risk levels related to workplace hazards may be
  greatly reduced by following basic safety and
  health policies in such areas as
• SH Postings
• Drugs and Alcohol
• Code of Conduct
• Housekeeping
• Smoking Policy
• Weapons
• Use of Cell Phones

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Leadership Responsibilities

• The Contracting Officer or their designated
  representative will inform contractors of
  site-specific rules and regulations. Some
  examples may include
• Parking Restrictions
• Work Hours
• ID Requirements
• Radio Restrictions

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Leadership Responsibilities

• Oversight of contractors
• Confirm conformance to contract provisions and
  work control procedures
• Monitor the effectiveness of the contractors
  safety management system
• Monitor contractor injury/illness rates versus
  industry peers (quarterly review recommended)
• Provide encouragement to improve when needed
• Get results by working cooperatively through the
  COR to encourage good performance --- NOT by
  telling them how to do the job

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Contractor Responsibilities

• Contractors on a VPP site are responsible for
• Protecting their employees from work area hazards
• Protecting the site employees and the public from
  the hazards of contractor operations and work
  areas
• Knowing and complying with all applicable OSH
  requirements
• Keeping emergency phone numbers at the worksite
  and familiarizing employees with emergency
  procedures
• Reporting mishaps/incidents to COR or a
  designated supervisor

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Occupational and Environmental Health Hazards

• Government and contractors must work together to
  control environmental/health hazards to both
  government and contractor employees. Its a
  partnership.

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Chemicals

• Under the VPP, both the installation and the
  contractor must be informed of any hazardous
  substance or chemical which will be used or
  stored in their work area.

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Hazardous Materials

• Contractors with hazardous materials or goods
  must
• Comply with all federal regulations, including
  the use, storage and disposal
• Submit all forms in cooperation with the
  installation
• Maintain all material safety data sheets (MSDS)
  in the work area
• Control their use of hazardous or irritating
  materials
• Follow any additional installation rules where
  applicable

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Work Permits

• Hazardous work must be carried out under a permit
  to work system. A work permit
• Identifies the work to be done
• Identifies hazards involved
• Identifies all necessary precautions
• Installation personnel must communicate all known
  hazards to contract personnel
• Contractors may use their own permits if they
  comply with Federal and installation regulations

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Permit Work

• Personal service contractors who perform
  hazardous tasks will be trained and comply with
  installation permit programs.
• Contractors performing permit-required work will
  coordinate those procedures with the contracting
  office as detailed in their contracts.

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Federal Regulations

• Contractors must ensure that federal and host
  installations regulations on such items as PPE,
  heavy equipment, electrical items, etc. are
  followed.

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Contractor Follow-On Work

• A contractors safety performance will be one
  factor used to determine if future contracts are
  granted.

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Action Plan Completion

• This training can be used as part of your sites
  documentation of action taken to address the
  following VPP actions
• Management Leadership and Employee Involvement
• Contract Worker Coverage
• Employee Involvement / SHMS Awareness
• Hazard Prevention Control
• Emergency Preparedness and Response
• Process Safety Management
• Safety Health Training
• Training Needs Assessment
• All Employees / Managers /Supervisors/SH Staff
  /Contractors

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Summary

• In this session, you learned about
• What a DoD contractor is (definition)
• VPP requirements relating to contractors
• Contractor selection considerations for safety
• Government and contractor responsibilities for
  contractor work performed at a VPP participant
  site
• Communication of basic safety and security
  procedures to contractors
• Contractor requirements for control of
  environmental/ health hazards
• Using contractor work permits to control hazards

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Questions?