The Integrated Water Services, Inc. (the Company) Subcontractor Safety Responsibilities (SSR or SSR's) are prerequisites and mandated for any work performed on any Integrated Water Services (“IWS”) or any other IWS affiliate site. 

Subcontractors shall comply with all applicable laws including but not limited to legally binding codes, standards, and regulations regarding health, safety, and environmental matters, whether at the federal, state, and/or local level.

In order to prevent confusion that can create an unsafe condition, subcontractors, their workers, and their affected parties are required to follow their employers established safety procedures and policies. For this reason, the IWS safety policies and procedures have been constructed to meet the minimum lawful requirements.

Because the IWS policies and procedures have been developed to represent the minimum lawful requirements, it is expected that all subcontractors will at a minimum meet the requirements set forth in the IWS published procedures. This expectation will make it easy for all IWS employees, subcontractor employees and their affected parties to easily meet the expectations as set forth in this SSR.

In such cases where a subcontractor or affected party does not have established written safety procedures, they are allowed to adopt the published IWS procedures for their use while performing services for IWS or their affiliates.

The IWS Safety Procedures can be accessed by going to the following website: www.iws.support (ISW Support Center). 

The subcontractor shall maintain all documentation (original or duplicates) of work execution verifying compliance with all provisions of their safety responsibilities. All such documentation shall be made available upon request by IWS or their affiliates. 

A defined strategy must be developed by the subcontractor to ensure program adherence and consistency by their employees and their third party affiliates.

A formal incident review will be required in response to all serious or potentially
serious incidents. Subcontractors will participate and be represented by site and corporate management during any scheduled incident review sessions. The injured party and any applicable witnesses to the incident may also be required to attend. 

All subcontractor delivery drivers, vendors, trucking or concrete drivers will adhere to all site PPE requirements.

IWS maintains an Emergency Action Plan (EAP) for each project that includes a list of local emergency services, emergency contact information, along with addresses and google maps driving directions to the nearest medical care facilities. IWS also provides Google Maps driving directions to all Company worksites. EAP's and driving directions can be accessed by going to www.iws.support and clicking on the Emergencies and Directions tab respectively.

Subcontractors shall submit to IWS and appropriately post emergency contact information, including work/mobile telephone numbers and email addresses for all applicable operations and safety management personnel.

Subcontractor shall maintain the appropriate “competent or qualified persons” (via OSHA standard) who are authorized and able to recognize and anticipate hazards. The qualifications of all competent and qualified individuals shall be made available to IWS upon request. Such persons shall have authority to take prompt corrective action to abate hazards. Such persons will also have the authority to alter, modify or stop work plans in the process of hazard review or abatement.

It is encouraged that all workers actively engage in the Stop Work/Good Catch program. This program must be highlighted during pre-job safety meetings and each employee will be granted the authority to pause or stop work to ask questions or to verify that conditions are safe. Workers who follow a stop work action by submitting a Good Catch form on the IWS Support Center will be qualified to receive an award for their participation.

Subcontractor shall plan and execute all work operations to comply with its written policies and established written contract Terms and Conditions.

Subcontractor shall utilize personal fall restraint systems and attach to manufacturers approved anchorage points. All Subcontractor employees will be tied off while operating or working in scissor lifts and from aerial work platforms. Subcontractors will ensure that any scissor lifts delivered on site are equipped with manufacturer approved anchor points. Standing on mid-rails and handrails of aerial/scissor lifts is strictly prohibited and considered an imminent danger violation. Blocks or steps are not permitted in lifts to gain access to a higher elevation or stepping.

 

Subcontractor will utilize a 100% 6-foot fall protection policy and program. Each person on a walking or working surface with an unprotected side or edge which is 6 feet or more above the next lower level shall be protected from falls using the Hierarchy of Controls (elimination, substitution, engineering, administrative, and personal protective equipment). As such, personal fall arrest systems (PFAS) should be considered as the last option.

 

The following exceptions to the 100% 6 foot fall requirement may exist, depending on site specific requirements:

• Proper use of a step ladder (up to 12 feet) on a stable and level foundation and away from wall/window openings, mezzanines or other fall hazards.
  Proper use of an approved and inspected extension ladder (up to 24 feet) for
  movement between levels (not as a working platform).
• Other extraordinary circumstances only if: (i) Subcontractor’s competent person determines that neither engineering controls nor a PFAS would be feasible; (ii) Contractor provides prior approval in writing; and (iii) the method of proceeding complies with all applicable laws.

Where work could result in a fall of equipment, materials or tool, measures will be taken to prevent the fall, reduce the distance, and/or ensure no one can struck by accidental release.

Measures may include:

• Exclusion Zones with signage established below or around work areas to prevent struck by hazards.
• Tethers used to tie-off tools or equipment to prevent fall of material hazards.

Subcontractor shall ensure that any lifting attachment used on mobile equipment has a positive locking mechanism that prevents accidental displacement or release.

Job made ladders shall be built in accordance with OSHA standards.

Subcontractor’s employees and all third-party subcontractors shall participate in daily pre-job safety meetings and any job-wide safety stand-downs.

Subcontractors shall utilize a job task hazard assessment process that identifies the tasks associated with the day’s work, hazards associated with the tasks, and controls that will be implemented to control the identified hazards. This planning process shall take place before the work is started. Task or condition changes will warrant a new assessment. Any activity assigned to employees by a supervisor will be considered appropriate for the job task assessment process. Subcontractor will document the job task hazard assessments and keep records on file for the duration of the project. All impacted workers shall participate in the job task hazard assessment.

Subcontractor shall adhere to and comply with their written post-incident and reasonable suspicion drug testing practices, programs, and policies.

Subcontractor is invited to utilize and participate in the weekly IWS toolbox talks. The IWS toolbox talks library can be found at www.iws.support in the Training tab.

Subcontractor shall implement immediate corrective action to eliminate unsafe practices and conditions as they are observed or reported. In cases where immediate or “On the Spot” actions are not taken, IWS reserves the option to abate the condition at the expense of the subcontractor.

Subcontractor shall notify IWS within four (4) hours of any incident involving injury or damage to any person or property. In addition, each Subcontractor shall investigate and document all such incidents. Findings shall be documented in an incident report and submitted to IWS at the earliest reasonable convenience.

Subcontractor shall provide adequate safety measures and controls to address potential occupational exposures such as gases, fumes, silica, dusts, chemicals, noise, and confined spaces.

Per OSHA 1926.1153, each subcontractor covered by the silica standard shall establish and implement a written silica exposure control program that identifies tasks that involve potential exposure and methods the company will use to protect employees. Procedures and protocols may include restricting access to work areas where high exposures may occur, designation of a competent person to implement the plan, restricting housekeeping practices that expose employees to silica where feasible alternatives are available, and use of appropriate tools and work practices to minimize the potential for exposure. The plan must be reviewed prior to the start of work.

Subcontractor shall provide Personal Protective Equipment (PPE) to all employees as needed and required per written policy/procedure or regulatory requirements.

IWS reserves the right to remove any party or employee from the site for committing unsafe conditions or behaviors.  

Subcontractor shall case managers injured workers in compliance with regulatory requirements.

Subcontractor will inspect all hand tools and extension cords prior to their use. Tools and extension cords found to be defective will be taken out of service immediately by subcontractor. Other equipment, such as scaffolding and ladders, shall be inspected for defects by Subcontractor’s competent person prior to use. Any equipment found to be defective or unserviceable will be immediately taken out of service and removed from site.

All equipment and tools shall be used per the manufacturer’s recommendations and equipped with manufacturer-provided handles.

Only trained and competent persons are allowed to operate mobile equipment, i.e.; excavators, forklifts, backhoe’s, skid steers.

A documented inspection shall be completed for all mobile equipment prior to use.

Subcontractor shall ensure that no power tools have a positive locking trigger. Each power tool shall be equipped with a constant pressure trigger.

Subcontractor shall ensure that all power tools and cords are protected by an operable Ground Fault Circuit Interrupter (GFCI) plugged in at the power source or GFCI circuit breaker or GFCI “pigtail”. Above 110 V, all cord sets and plug sets shall be protected via GFCI or Assured Equipment Grounding Conductor Program (AEGCP).

Subcontractor shall ensure that all work on live electrical components is performed only if and when all other alternatives have been deemed infeasible. Such work by Subcontractor requires written approval and consent from the IWS Superintendent or HSE manager. Such electricians must be trained and licensed.

All electrical tasks will be carried out in compliance with NFPA 70E, OSHA and Contractors Stored Energy program. Additionally, Subcontractor will only handle or engage de-energized wiring or circuits after appropriate Lock and Tag and a secondary confirmation of source isolation via a working voltage detector or like instrument. Any and all work on live/energized sources requires advance notice and approval by the IWS site management team.

Subcontractor shall ensure that all permanent and temporary electrical panels are locked and labeled with controlled access. All de-energized electrical and power systems will be locked out in accordance with appropriate lock and tagging guidelines.

Subcontractor shall maintain all required and appropriate OSHA documentation related to injuries and illnesses on site. Such documents will be made available to IWS upon request.

Each Subcontractor shall maintain all appropriate documentation under the Hazard Communications standard and the Globally Harmonized System (GHS). The Subcontractor shall submit all Safety Data Sheets (SDS) used in the performance of work to IWS to the following link: https://iws.support/safety-data-sheets. The Subcontractor shall maintain a copy of a hazardous communications program and a library of SDSs for materials provided/used in the performance of its scope of work. Subcontractor will ensure that all employees are trained to address any potential chemical exposures/interfaces.

Subcontractor shall conduct a formal and documented regular safety inspection and take corrective actions for recognized hazards. A copy of all inspections completed by the subcontractor will be provided to IWS upon request.

When working with mobile cranes or tower cranes, subcontractor shall appoint a certified signal person and qualified rigger prior to the lift. Documentation on qualifications/certifications will be maintained. All applicable crane and rigging policies, procedures, and practices will be adhered to by Subcontractor.

Subcontractors that fail to meet minimum lawful safety performance standards may be required to designate a full-time, on site, dedicated safety professional. Such determination may be based upon: on site injury/illness rates, safety violations/concerns issued by IWS or a regulatory authority, or lack of participation in required safety forums, activities and meetings.

Subcontractor shall develop and submit a Pressure Testing Safety Plan to the IWS Superintendent and prior to performing any pneumatic, hydrostatic or other pressure testing of pipes or vessels. Subcontractor shall not use pneumatic testing as a testing medium unless required by the design and approved well in advance by the IWS project superintendent.

Subcontractor shall ensure that all scaffolds are built and tagged in accordance with the OSHA guidelines.

Subcontractor shall follow their documented respiratory protection program where applicable. This program shall cover the requirements for Appendix D, Voluntary Respirator Use. The Subcontractor shall retain all signed copies of Appendix D that were performed on the project. The signed Appendix D shall be made available to IWS upon request.

Subcontractor will ensure that all open flame and spark producing activities are performed in accordance with written hot work procedures. Hot work procedures include the completion and approval of a Hot Work Permit before activities begin and, in some cases, may require a dedicated fire watch while work is taking place and for a minimum of 30 minutes past the completion of the work. A subcontractor supplied fire extinguisher must be present at the work area where the hot work is being performed and employees must be trained in the use of such extinguisher.

Subcontractor shall supply fire extinguishers for all related work activities including, but not limited to, the use of combustible engines and fuel storage, if any. All fire extinguishers will meet a minimum size requirement of 10 lb. and be at least ABC type.  

The following work rules are important to the safety of all personnel on IWS sites and shall be adhered to at all times:

• Possession of or working under the influence of alcohol or drugs is prohibited and subject to immediate dismissal.
• Hazard Communication and Lockout/Tag out Programs shall be observed.
• Unsafe conditions or acts, along with any accidents or near misses shall be reported to your immediate supervisor and a member of the Contractor’s management team.
• Appropriate work attire shall be worn at all times. Hard hats, in construction areas, safety glasses, High-Visibility vests and durable boots covering the feet and ankle are minimum requirements. Appropriate work gloves are required for all employees at all times while on site.
• Work wear shall not be offensive or inappropriate.
• “Horseplay”, harassment, fighting, work place violence, and other inappropriate behaviors are strictly prohibited.
• Maintaining good housekeeping is mandatory at all times. Subcontractor is responsible for daily clean up.
• Photos, pictures or video is not allowed on site.
• Fire protection equipment is not to be tampered with or removed from its assigned location.
• Vehicles are to be operated and driven in a safe manner at all times.
• Barricaded areas will not be entered without proper authorization.
• Modification or alteration of any piece of personal protective equipment is strictly prohibited.
• “No Smoking” rules shall be adhered to. Smoking/tobacco shall be allowed in designated areas only.
• All gasoline engines shall be shut off before refueling.
• The use of plastic gas cans for storing combustible/flammable liquids on the site is prohibited. Use only approved metal containers.
• Tampering with firefighting or life safety equipment is prohibited and grounds for immediate termination/removal.