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:
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:
- A Subcontractor Job Hazards Analysis (SJHA) form must be created and made active after signing (Work Process B).
- 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 |
|
Division Safety Coordinator |
|
EHS Division SJHA Program Manager |
|
Procurement Department |
|
SJHA Requester |
|
Subcontractor, vendor, and affiliate |
|
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 typically not defined as hands-on work, unless there is a hands-on work component involving tools or other form of safety risk factor:
|
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 |
|
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:
|
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
SJHA Program Manager
Operations Support Team
Environment, Health, and Safety (EHS) Division
J. Revision History
Date |
Revision |
By Whom |
Revision Description |
Section(s) Affected |
Change Type |
1/2/2012 |
0 |
M. Ruggieri |
Re-write for wiki (brief) |
All |
Minor |
6/18/2013 |
1 |
M. Ruggieri |
Re-write for wiki (policy) |
All |
Minor |
2/2/2022 |
1.1 |
R. Connelly |
Periodic review |
All |
Minor |
DOCUMENT INFORMATION
Title: |
SJHA Process – Subcontractor Job Hazards Analysis) |
Document number |
07.02.004.000 |
Revision number |
1.1 |
Publication date: |
2/2/2022 |
Effective date: |
10/25/2010 |
Next review date: |
2/2/2027 |
Policy Area: |
Safe Work Authorization |
RPM Section (home) |
ESH |
RPM Section (cross-reference) |
none |
Functional Division |
EHS |
Prior reference information (optional) |
ES&H Manual Chapter 31 |
Source Requirements Documents
- 10 CFR 851, Worker Health and Safety Program
- PUB-3581, Work Health and Safety Program, Section 1.6, Flow Down of 851 Requirements to Subcontractor
Related Berkeley Lab Policies
- ES&H Manual Chapter 6, Work Planning and Control
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 |