Your company has a strong safety program and your employees are trained. Your supervisors understand OSHA requirements and you have someone responsible for safety in the field. So you’re ready for a federal construction project, right?
Maybe.
There’s another question worth asking: Are you prepared to meet the safety requirements of the contract itself?
For contractors moving into federal work, that distinction can be easy to overlook. OSHA compliance may be familiar territory, but depending on the project, the contract can introduce another layer of safety requirements. Discovering those requirements after the project starts can create problems that extend well beyond safety.
What Does the Contract Actually Require?
When reviewing a federal project, how closely does your team examine the safety requirements before submitting a bid?
More importantly, who is responsible for identifying requirements that differ from the way you normally operate?
Federal construction contracts may incorporate safety requirements that are more prescriptive than what contractors encounter on a typical commercial project – including requirements for qualified safety personnel, government-accepted Accident Prevention Plans, Activity Hazard Analyses, specialized safety submittals, and additional documentation. (These come from the U.S. Army Corps of Engineers’ EM 385-1-1, Safety and Occupational Health Requirements)
That means the question changes from: “Are we OSHA compliant?” to” “Are we compliant with what this specific contract requires?”
Those aren’t necessarily the same thing.
Does Your Safety Person Meet the Requirements?
If you’re reading this and thinking “Well my safety person should be able to handle that,” you may want to confirm that the person that handles your safety program (be it a dedicated safety professional, a project manager, or a foreman) meets the qualifications required by the contract.
Certain federal projects may require a qualified Site Safety and Health Officer (SSHO) or other designated safety personnel. Depending on the applicable requirements, these positions can carry expectations for experience, training, responsibilities, authority and documentation. Simply assigning someone the safety role doesn’t necessarily make that person qualified for the position specified in the contract.
Also consider what happens if that gap isn’t discovered until you’re preparing to mobilize.
- How quickly could you find someone who meets the requirements?
- What would that do to your schedule?
- What happens if you’ve already priced the project without accounting for that additional resource?
Suddenly, a safety requirement has become a project problem.
Documentation: Who Handles It?
Personnel are only one piece of the puzzle. Federal projects can also come with significant safety documentation requirements.
Depending on the project, your team may need to prepare and maintain items such as:
- Accident Prevention Plans
- Activity Hazard Analyses
- Competent and Qualified Person documentation
- Safety inspection records
- Employee orientations
- Safety meeting records
- Training documentation
- Corrective-action records
- Other safety-related submittals
If your superintendent is your safety person and is already responsible for production, subcontractors, schedules, coordination, day-to-day field issues…do they have time to organize this additional documentation?
And if the documentation doesn’t meet the project’s requirements, how much time will your team spend correcting it?
When Would You Rather Find the Gap?
Imagine two scenarios.
In the first, your team reviews the safety requirements while bidding or preparing for the project. You identify the required personnel, documentation and training, determine what you can handle internally, and account for any outside resources you may need.
In the second, those same requirements are discovered as mobilization approaches, or after work has already begun.
Which situation gives your team more options?
Identifying requirements early can give you time to evaluate personnel, prepare documentation, address training needs, and build the associated costs into the project.
Finding them later can mean scrambling for qualified personnel, revising submittals and pulling project leaders away from other responsibilities.
That’s why federal safety compliance shouldn’t begin when the crew arrives onsite.
It should begin when you’re reviewing the contract.
Know Before You Bid
Before pursuing or mobilizing on a federal project, consider asking:
- What safety standards does this contract incorporate?
- Do our proposed safety personnel meet the required qualifications?
- What needs to be submitted or approved before work starts?
- Do we have the internal resources to manage these requirements throughout the project?
- If we have a gap, when would we want to know about it and how will we address it?
At Exceed Safety, we work with contractors to ask the questions you don’t know to ask and then find the answers.
Depending on the project, that can mean reviewing safety specifications, evaluating personnel qualifications, developing missing documentation, or providing qualified safety professionals.
The objective isn’t to add another layer of safety administration where one isn’t needed.
It’s to help determine what your contract requires, where your current resources may or may not meet those requirements, and what makes the most sense for your project.
Before asking, “Do we need a safety person?” there may be a more useful question:
“What have we agreed to provide – and are we prepared to provide it?”
