Contractors working on University premises

1.  Introduction

This policy aims to control the health and safety of contractors working on University premises, by:

(a)  identifying the potential for harm arising from the proposed work

(b)  identifying who may be affected

(c)  instigating appropriate controls.

For the purposes of this policy, a contractor is anyone carrying out work on the University premises who is not an employee. However, the general principles of this policy will also usefully apply to University staff working in differing departments, such as members of the University Estates Services and University Security Services. The following provides examples of the type of work that is covered:

(a)  non-University employees working on building plant or equipment

(b)  service or maintenance engineers working on departmental equipment

(c)  contract cleaners

(d)  contract catering staff

(e)  University Estates Services personnel working on building plant or equipment

(f)  University Security Staff entering buildings to conduct routine checks.

Note, the policy does not cover the following:

(a)  non-University employees undertaking academic work

(b)  activities that are covered by the Construction, Design and Management Regulations, 2007 (CDM) – see University Safety Policy, S3/15 for details. In general, S3/15 covers all construction work or modifications to a building, where it is necessary to involve the University Estates Servcies.

2.  Responsibilities

The head of department must ensure that appropriate arrangements are in place to identify when contractors are to work in their buildings and that the proposed work complies with the University’s health and safety policies.

The person, who has arranged for a contractor to work in a department, must act as a Departmental Coordinator. The Departmental Coordinator must ensure that an appropriate risk assessment has been made, prior to the work commencing. They must ensure that the contractor is made aware of the outcome of this risk assessment and that they are expected to comply with the relevant requirements of the University’s health and safety policies. They must ensure appropriate arrangements are made to provide an induction (covering at least the relevant fire and first aid arrangements) to all contractors and sub-contractors and organise a Site Contact for the period of work.

Contractors – all work carried out on University premises must be carried out in accordance with University health and safety policies.

NOTE:   Where departments have concerns regarding the health and safety arrangements of contractors or personnel controlled by the University Estates Services, they must inform the relevant Estate Services contact of any concerns, rather than directing the contractor themselves. Departments must be represented at pre-contract meetings for work organised by the University Estates Services.

3.  Contractor selection

When selecting a contractor,there must be some consideration as to their previous health and safety performance. The degree to which this is necessary will depend on the size and nature of the work involved, but the following points should be considered:

(a)  Any employer with five or more employees must have a written health and safety policy. Departments should ask to see a copy of the potential contractor's health and safety policy before engaging them for the first time.

(b)  Depending on the scale of a contract, departments may wish to ask potential contractors about their accident record and for information about any enforcement action (prosecutions, prohibition or improvement notices) over, say, the last five years. Departments may also wish to consult the University Safety Office for information on a contractor's accident history at the University.

(c)  Contractors should be asked what health and safety training they provide and how information about health and safety is passed on to staff and sub-contractors. The contractors should be asked for any training records and any relevant current certificates of competence.

(d)  Contractors should be asked what safety checks they make on their equipment and materials, e.g. electrical testing of portable electrical items. All plant, tools, tackle and equipment used on University premises is expected to comply with relevant health and safety standards and to be maintained in a safe condition.

(e)  Where sub-contractors are involved, good arrangements between all parties must exist. The main contractor must inform all sub-contractors of the University's and their own site rules, working methods and procedures. The main contractor should be asked how they ensure that they engage competent sub-contractors and asked to give an undertaking that all sub-contractors engaged would be competent.

(f)  A safety method statement should be obtained from the contractor wherever possible. The documentation should be available well in advance of any work commencing.

(g)  Site supervision is essential and it is important to ascertain from the contractor how they plan to supervise the job and who will be responsible for that supervision. The nominated Site Contact is expected to liaise with the contractor’s supervisors.

(h)  Departments are responsible for checking that contractors (other than those engaged by the University Estates Services) have appropriate insurance policies. As a minimum, contractors must have public liability insurance with a limit of indemnity of £1,000,000.  In some circumstances the project and risks may warrant a request for a higher limit of indemnity or other policies.  Either way, copies of the policy certificate or written assurances must be obtained during the selection process.

4.  Risk assessment

All contractor work must be assessed before the work begins. In areas where a contractor is not exposed to, or will not introduce any significant hazard (e.g. a photocopier service engineer), then a simple discussion is sufficient. In other areas, there may be a need for some formal level of assessment. This is certainly the case, if:

(a)  Contractor introduces a significant hazard into the building. For instance, contractors carrying out ‘Hot Work’, such as welding or brazing, could pose a significant risk of fire, along with the introduction of hazardous gases such as oxygen or acetylene. Alternatively, contractors may introduce hazardous substances in significant amounts, such as paints, cleaning agents or flooring compounds.

(b)  Contractor may be exposed to existing hazards in the department. For instance, contractors may need to access areas where hazardous substances are directly handled. This is particularly relevant where high-risk chemicals or biological agents are handled, but would also apply where liquefied gases exist or where asbestos is known or suspected to be present. In addition, the work may impact on building services, such as ventilation or drainage systems, which may themselves carry or be contaminated with hazardous substances. Contractors may also need entry into controlled areas where hazardous equipment is present, such as X-rays, lasers, and magnetic resonance imaging systems.  

(c)  Work proposed is likely to effect existing controls. For instance, fire alarm detectors may need to be isolated where smoke, heat, dust, or fumes are generated. There may be a need to temporarily redirect emergency exit routes, either inside or outside the department. The work may involve isolating service supplies, such as water, ventilation, heating or drainage. This could have an effect on the general welfare facilities for a building, along with specific safety controls such as local exhaust ventilation systems and cooling systems on safety critical equipment. When service engineers work on specific types of equipment, there may be a need to remove existing guarding or interlock systems from around embedded hazards, e.g. moving parts, electrical conductors, lasers, X-ray generators.

In general, there is no specific format for a risk assessment but the process outlined in University Safety Policy S5/08 should be followed. In addition the following documents may supplement the risk assessment:

(a)  Contractors method statement/risk assessment. It is always advisable to ask for a copy of the contractor’s own method statement/risk assessment before the work commences. This will help identify the likely impact on the building and ensure appropriate information is supplied and arrangements are made ahead of the work commencing.

(b)  Decontamination certificates. Where an item of plant/equipment has been contaminated with a particular hazardous substance, then the equipment should, where possible, be decontaminated before it is worked upon. If the equipment cannot be completely decontaminated, then the residual risks must be outlined to the contractor

(c)  Equipment isolation. In some circumstances, it will be necessary to isolate either plant or equipment, to restrict entry or to over-ride safety controls or alarms. In these instances, to ensure that all affected personnel are aware and to manage isolation and use, then physical restrictions may be needed, or warning signs and notices must be displayed. If signs/notices are displayed, then it is equally important that they are removed afterwards, so it is clear that the situation has been returned to normal

(d)   Permit(s) to work. A permit to work is a formal system of control, which must be issued for any significantly high-risk activity. For instance, hot work, roof work, work on live electricity, working in confined spaces, work in high-risk areas such as animal houses.  Individuals issuing permit(s) to work must be appointed by the department and suitably trained.  An example proforma is given within Appendix 1.

Finally, in some circumstances, there will be a need to hold a pre-contract meeting to fully discuss the above points with all interested parties.  Pre-contract meetings must be held if:

(a)   The work and subsequent hazards are particularly complex

(b)   The work is likely to affect (and/or will require input from) more than one department

(c)   The work has no set timescale and will continue over an extended period.

Where a pre-contract meeting is held, the Departmental Coordinator must keep a record of the meeting. 

5.   Information/training

All contractors must be given the following basic information:

(a)   sign in/out procedures and/or other security arrangements for the building

(b)   welfare arrangements (e.g. toilets, drinking/rest areas, ‘no smoking’ policy)

(c)   contacts, specifically details of the Departmental Coordinator and Site Contact

(d)   emergency procedures (e.g. fire evacuation, first aid, spillages, emergency cut-offs for gas, electricity and water, accident reporting).

In addition, there may be a need for more specific training. For instance, if individuals are to enter hazardous areas, they will need information relating to the associated risks, what controls are to be followed, and what work is actually permitted. This is particularly important for individuals who may be given general access to departments (e.g. cleaners, University Estates Services or Security Services staff). 

If there are contractor staff changes during the period of work, arrangements must exist to ensure all new personnel are trained before they begin work. This may be by the use of documented local rules or by incorporation into departmental safety inductions. If the person carrying out the induction is not a member of the department, then the Departmental Coordinator must make sure that this person has a clear understanding of the likely risks and controls, and is kept up to date with any changes.

Individuals involved in supervising contractors, may also require additional training. As mentioned there may be a need for training in issuing permit(s) to work. There may also be a need for individuals involved in isolating smoke detectors or in lockout procedures where safety-critical guarding is removed.

Finally, information must be distributed to all effected departmental individuals as soon as possible. For instance, if ventilation systems or welfare facilities are affected, individuals must be told well in advance of what work can continue, or of any alternative arrangements. 

6.   Use of departmental equipment/personal protective equipment

The use of departmental equipment by contractors must wherever possible be avoided, particularly if the equipment is critical to that individual’s own health and safety (e.g. ladders, HEPA vacuum cleaners). Where such equipment is required, it should be identified as part of the risk assessment process and the contractor should supply it.

The need for personal protective equipment (e.g. eye, face, respiratory, hand protection) must also be considered as part of the risk assessment and again where required, be supplied by the contractor. The contractor must be notified of any specific local rules, such as the need to wear laboratory coats in containment facilities or the University’s policy on latex gloves.

Where it is not possible or indeed practicable for contractors to supply the equipment, it should be jointly agreed and recorded beforehand. The exact requirements, particularly in terms of personal protective equipment (e.g. size, standard, fitting, storage arrangements) must be documented and the equipment must be deemed to be in good working order and suitable for the proposed work. Work must not be permitted to take place, if contractors do not have access to the appropriate equipment.

7.   Health surveillance

Access to certain areas may require health surveillance (e.g. cleaners accessing areas where laboratory animal allergens are present). This should be identified as part of the risk assessment process and reported to the contractor before the work begins. It is the responsibility of the contractors to arrange their own health surveillance, but advice may be taken from the University Occupational Health Service. 

8.   Monitoring and reviewing the job

Departments are not expected to watch contractors all the time they are on site, but they must check to see that the contractor is carrying out the work as agreed. The degree of contact needs to be proportionate to the hazards and risks associated with the job.

Before work commences, the Departmental Coordinator must be satisfied that all risks have been identified and that the appropriate controls are in place and are to be followed.

During the work and at appropriate intervals, the Departmental Coordinator should ensure that the work is visually checked to ensure the agreed controls are being followed and are working effectively. If there is any doubt, the work should be stopped or readjusted to ensure the continuing health and safety of all concerned.

At the end of a period of work, it must be agreed that the work has been completed to each other’s satisfaction. If the work has not been fully completed and residual risks still remain, then the area and equipment must be made safe before it is left unsupervised. This may require the temporary reinstatement of guarding and other controls, or the isolation of equipment and areas by barriers or lockout systems. Importantly, any permit(s) to work issued must not be dated for a period longer than one day. 

If the contractor is likely to generate waste, then arrangements for disposing of this waste must have been agreed before the work starts and the final inspection must ensure that this waste has been correctly removed.  All waste must be disposed of in line with current legislation and particularly University Policy Statement S5/11, including the need to obtain a copy of the waste transfer note before waste is removed from University premises.

After the work has been completed, departmental and centrally held records must be reviewed and where applicable, updated. For instance:

(a)   equipment log books and service records

(b)   test certificates (e.g. fire precautions, microbiological safety cabinets and other local exhaust ventilation systems, pressure vessels or lifting equipment)

(c)   building health and safety file

(d)   asbestos register

(e)   fire zone plans.

9.   Accidents and reporting

All accidents and incidents involving a contractor must be reported via their own arrangements. However, the department should investigate the cause of any incident and identify if there is a need to modify existing departmental procedures. In that regard, details of the accident should be gained from the contractor before they leave site and reported to the University Safety Office on an accident report form.

 

10.   Summary of departmental action

(a)   Arrangements must be made for controlling contractors working in departments.

(b)   Contractors must be deemed competent to carry out the work before being appointed.

(c)   Departmental Coordinators must ensure an appropriate risk assessment is done at the earliest opportunity and that the required actions are communicated to all concerned.

(d)   A site contact must be appointed to liase with the contractor and ensure the required actions are implemented, along with an appropriate safety induction.

(e)   Afterwards, the work must be inspected and all relevant records updated.

THIS STATEMENT FORMS PART OF THE UNIVERSITY’S SAFETY POLICY AND UNIVERSITY POLICY NOTE S7/98 IS SUPERSEDED.  PLEASE AMEND THE INDEX.

June 2008