SJHA Process – Subcontractor Job Hazards Analysis

Title:	SJHA Process – Subcontractor Job Hazards Analysis
Publication date:	2/2/2022
Effective date:	10/25/2010

BRIEF

Policy Summary

The Subcontractor Job Hazards Analysis (SJHA) Program at Lawrence Berkeley National Laboratory (Berkeley Lab) is a work authorization tool that helps SJHA requesters take responsibility for ensuring that all nonconstruction subcontractor work is performed safely and in accordance with regulations by:

Completing the SJHA form.
Reviewing the SJHA and validating hazards and controls with the subcontractor.
Providing work oversight to ensure the subcontractor is performing the work as authorized.

Who Should Read This Policy

This policy applies to Berkeley Lab subcontractors, vendors, and affiliates who perform nonconstruction, hands-on work.

To Read the Full Policy, Go To:

The POLICY tab on this wiki page

To Read the ES&H Program Details, Go To:

ES&H Manual Chapter 31

Contact Information

SJHA Program Manager
Operations Support Team
Environment, Health, and Safety (EHS) Division

Title:	SJHA Process – Subcontractor Job Hazards Analysis
Publication date:	2/2/2022
Effective date:	10/25/2010

POLICY

A. Purpose

The Subcontractor Job Hazards Analysis (SJHA) program at Lawrence Berkeley National Laboratory (Berkeley Lab) is a work authorization tool that helps SJHA requesters take responsibility for ensuring that all nonconstruction subcontractor work is performed safely and in accordance with regulations by:

Completing the SJHA form.
Reviewing the SJHA and validating hazards and controls with the subcontractor.
Providing work oversight to ensure the subcontractor is performing the work as authorized.

SJHAs are implemented through the password-protected online SJHA System.

B. Persons Affected

This policy applies to Berkeley Lab subcontractors, vendors, and affiliates who perform nonconstruction hands-on work at facilities owned or leased by Berkeley Lab.

C. Exceptions

This policy does not apply to activities or services that do not involve on-site, hands-on work. Examples of service providers that may be excluded may include, but are not limited to:

Consultants.
Personal services agreements.
Contract labor.
Intra-university transactions.
Advanced Light Source and other user-facility affiliates addressed by another work authorization mechanism.
Other university agreements.
Subcontractors, vendors, or affiliates who are already covered by Berkeley Lab's Work Planning and Control program.

D. Policy Statement

Berkeley Lab ensures that all subcontractors, vendors, and affiliates performing hands-on work at facilities owned or leased by Berkeley Lab do so in a safe manner that complies with applicable regulations (Work Process A).
Before hands-on work (see Section F, "Definitions/Acronyms," of this policy) can be performed by subcontractors, vendors, or affiliates at Laboratory facilities, the following activities must be completed:
1. A Subcontractor Job Hazards Analysis (SJHA) form must be created and made active after signing (Work Process B).
2. A pre-job meeting must take place between the requester and the subcontractor, vendor, or affiliate.
Nonconstruction subcontractors must review the ES&H Orientation for Nonconstruction Subcontractors, Vendors & Affiliates at the pre-job meeting or otherwise prior to working on-site (Work Process C).
The SJHA work authorization process may also be used for simple facility repairs conducted by subcontractors. These simple activities are generally accomplished by a single craft on a single day. Activities that are more complex or involve construction activities must use the construction, Site Specific Safety Plan (SSSP) process.

E. Roles and Responsibilities

Role	Responsibility
Managers, supervisors, and employees	Adhere to the provisions of this policy by ensuring that subcontractors performing hands-on work at their request have completed the SJHA process before work begins.
Division Safety Coordinator	Provides his/her division with Environment, Safety & Health (ES&H) support for implementing the requirements of the SJHA Program. Requests support from the EHS Division SJHA Program Manager and EHS subject matter experts, when necessary.
EHS Division SJHA Program Manager	Provides the requesting division with guidance, leadership, and direct consultative services in SJHA policy and program implementation. Monitors the Laboratory's performance in SJHA policy and program implementation. Maintains the SJHA Program.
Procurement Department	Communicates the SJHA policy and program requirements to subcontract bidders and awardees. Requests that each subcontractor and vendor complete an SJHA and review the Berkeley Lab ES&H Orientation for Nonconstruction Subcontractors, Vendors & Affiliates pamphlet before performing hands-on work at a Laboratory facility. Monitors subcontractor and vendor performance, including ES&H compliance.
SJHA Requester	Responsible and accountable for ensuring the subcontractor's safety. Ensures that an SJHA is prepared for the subcontractor, vendor, or affiliate who will perform hands-on work at a Laboratory facility; a pre-job meeting is held between the requester and the subcontractor, vendor, or affiliate before work is performed; and the SJHA is made "active" prior to work commencing. Signs the SJHA and thereby authorizes the work to be performed followed by uploading the SJHA to the SJHA System to make it "active." Obtains safe work authorizations, permits, work plans, submittals, etc., for the scope of work to be performed by the subcontractor, vendor, or affiliate. Provides and records safety oversight of the subcontractors using the risk-based graded approach described in the ES&H Manual SJHA Process – Subcontractor Job Hazards Analysis program.
Subcontractor, vendor, and affiliate	Provide input on the SJHA and submit it to the SJHA requester. Review the Berkeley Lab ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates pamphlet. Attend the pre-job meeting and discuss the steps of the work scope and associated hazards and controls. Sign the SJHA and any required safe work authorizations, permits, work plans, etc. Agree to work in conformance with the authorized conditions. Perform the scope of work as authorized in a safe manner.

F. Definitions/Acronyms

Term	Definition
Affiliates	Non-Laboratory employees engaged in on-site Laboratory activities. Affiliates are subject to training in safety and other subjects. They are also issued a Berkeley Lab identification badge. Affiliates may receive system accounts, research access to facilities, and a per diem allowance for housing and living expenses. Examples: facility users, scientific collaborators, students
Hands-on work	Includes all activities except administrative office work and other similar activities. Although not limited to the following, these activities are examples of hands-on work: Activities involving the use of hand or power tools. Repair or service of a device, apparatus, machine, or mechanism. Material handling involving use of hand or power tools. Handling or disposing of a chemical; a compressed gas; or a hazardous, radioactive, or biohazardous material. Although not limited to the following, these activities are typically not defined as hands-on work, unless there is a hands-on work component involving tools or other form of safety risk factor: Office and administrative duties. Computer programming. Attending or making a presentation. Supervision of a worker(s) who is not performing hands-on work. Document archiving. Financial auditing. Photography. Language translation. Vending machine delivery and stocking. Water delivery with no maintenance involved. General deliveries or pickup of items with no complex material handling or tools involved.
High-level hazard work	Any activity that requires a safe work authorization document (e.g., LOTO Permit, Penetration Permit, Radiological Work Authorization, etc.) as described in the ES&H Manual Work Planning and Control and Radiation Safety programs
Low-level hazard work	An activity that does not require an additional safe work authorization document (e.g., any kind of work permit, site specific work plan, etc.)
Nonconstruction work	Activities that do not create a new facility, or alter, add to, rehabilitate, dismantle, or remove an existing facility, including any combination of engineering, procurement, erection, installation, assembly, demolition, or fabrication. Nonconstruction work also excludes the alteration and repair (including dredging, excavating, and painting) of buildings, structures, or other real property, as well as any construction and excavation activities conducted as part of environmental remediation efforts (see the ES&H Manual Construction Health & Safety program).
SJHA Program	An EHS Division program that provides guidance, leadership, and direct consultative services to divisions for the implementation of the policy and requirements in this chapter
SJHA Requester	An individual in a Berkeley Lab division who is listed as the SJHA requester on the SJHA, who is responsible and accountable for the subcontractor, vendor, or affiliate and for ensuring the work is performed safely
Requisition preparer	A Berkeley Lab worker who is trained and authorized to use procurement software programs for initiating requisitions and purchase orders
Risk-Based Graded Approach	A process to ensure that work activities are efficiently managed through systems that are adequate to, and commensurate with, the risk involved in the activity Risks include potential impact to worker or public health and safety, threats to the environment, consequences of noncompliance, and cost impacts The risk-based approach considers whether or not work is hands-on, includes low or high hazards and complexity of the work in order to determine if a written authorization (beyond the SJHA) is required and what level of worker oversight is necessary by the SJHA requester
Subcontractor	A firm that has sole contractual responsibility for execution of defined work related to a project, and for compliance with all safety, health, and environmental codes, standards, and regulations
Subcontractor Job Hazards Analysis (SJHA)	An SJHA: Describes the scope of work to be performed. Identifies work hazards and controls. Is the work authorization document for subcontractors, vendors, and affiliates. When required, other safe work authorizations are obtained and appended to the SJHA. Maximum duration of an SJHA is one year, but it may be renewed indefinitely. Authorizations and restrictions stipulated by any required safe work authorizations supersede those in the SJHA.
Vendor	An entity that sells a product for which installation or warranty service may be provided

G. Recordkeeping Requirements

Completed SJHAs and related documents (i.e., safe work authorizations, evidence of training, worker-related submittals, site specific work plans, etc.) must be maintained in the SJHA system by the requester.

H. Implementing Documents

Document number	Title	Type
07.02.004.001	SJHA – Subcontractor Job Hazards Analysis	Program
07.02.004.002	Work Process A, SJHA Process Overview	Work Process
07.02.004.003	Work Process B, Creating an SJHA	Work Process
07.02.004.004	Work Process C, Training and Orientation	Work Process
	ES&H Orientation for Non-Construction Subcontractors, Vendors & Affiliates	Orientation pamphlet
07.02.003.001	ES&H Manual Chapter 6, Work Planning and Control	Program
07.07.011.001	Electrical Safety	Program
07.07.007.001	Construction Health & Safety	Program

I. Contact Information