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Full text of "DTIC AD1037095: Best Practices for Optimizing DoD Contractor Safety and Occupational Health Program Performance"

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PDC Briefing 


Defense Safety Oversight Council 


Defense Safety Oversight Council (DSOC) Initiative 

Best Practices for Optimizing DoD Contractor Safety and 
Occupational Health Program Performance 


Douglas Craddock, CTC Initiative Lead 


March 16, 2012 


Background/Objective 


Defense Safety Oversight Council 


Background: 

• Thousands of US workers die or are disabled each year in workplace 
mishaps. 

• DoD contractors involved in demolition/construction contracts must comply 
with the Army Corps of Engineers, EM 385-1-1 in accordance with the FAR 
Accident Prevention Clause 52.236-13. 

• Similar safety and health requirements are not mandatory for most other non¬ 
construction related DoD contracts. 

• OSHA continues to cite DoD and their contractors for serious and willful 
violations of safety regulations. 

• All Contractors are required to comply with Federal or State OSHA Standards. 

Objective: 

• Develop a safety and health “best practices guide” to be used by Contracting 
Officer Representatives (COR), safety professionals, and acquisition 
personnel. 

- Guide could be added to the Contracting Office Technical Representative (COTR) 
training curriculum. 


Working Group 


Defense Safety Oversight Council 


Name 

Organization 

E-MAILADDRESS 

Joy Erdman 

DSOC Initiative Government Lead 

joy.erdman@navy.mil 

Tony Militello 

Service Stakeholder (NAVFAC Safety) 

Anthony.j.militello@navy.mil 

John Masterson 

Service Stakeholder (NAVFAC Legal) 

John.masterson@fe.navy.mil 

Richard Wright 

Service Stakeholder (USACE Safety) 

Richard. I.wright@hq02.usace. army, 
mil 

Vance Lineberger 

Service Stakeholder (USAF) 

Vance.Lineberger@pentagon.af.mil 

Jerry Waibel 

Service Stakeholder (USA) 

Jerry.waibel@us.army.mil 

Jim Boom 

Agency Partner (USDOLVPP) 

Boom.Lloyd@dol.gov 

Carl Rockstroh 

Other Technical POC (CTC VPP) 

rockstrc@ctc.com 

Paul Leach 

Other Technical POC (FLTCYBERCOM) 

paul.leachl @navy.mil 

Karen Nelson 

DSOC Program Manager (CTC) 

nelsonk@ctc.com 

Doug Craddock 

Initiative Lead (CTC) 

craddocd@ctc.com 


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Deliverables 


Defense Safety Oversight Council 


Deliverable 

Delivery Schedule 

Monthly Reports 

5th of each month 

Kick off Meeting 

25 Dec 2011 

Implementation Plan 

25 Jan 2012 

Draft guidebook; iterative reviews and 
updates based on feedback from 
stakeholders 

Initial table of contents and 
outline to be provided at 
the Mar 2012 DoD Safety 
PDC 

Final contractor Safety and Health 
Guidebook 

30 Aug 2012 

Final report and Briefing* 

Draft 15 Sept 2012; Final 

15 days after receipt of 
comments 


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Implementation Activities 


Defense Safety Oversight Council 


• Review Current Instructions, Directives, and Defense 
Acquisition Guide (DAG) 

• Review Available Contractor Mishap Data 

• Review Existing Guidelines for Contractor Safety 

• Determine Plan of Action, Requirements and 
Guidebook Transition 

• Guide to be available electronically 

• Develop Draft Guidebook for Review and Approval 

• Finalize, Distribute and Collect Feedback on 
Guidebook 

• Final Report, Recommendations, and Briefing 


Review Current Instructions , Directives, & DAG 


(examples) 


• FAR Clause 52.223-3, Hazardous Material Identification and Material 
Safety Data 

FAR Clause 52.236, Permits and Responsibilities 

FAR Clause 52.236-13, Accident Prevention 

AFFARS Clause 5352.223-9001, Health & Safety on Government 

Installations 

DoDD 5000.1, The Defense Acquisition System 

DoDI 6055.1, DoD Safety and Occupational Health Program 

Defense Acquisition Guide (DAG) 

Air Force Instruction 91-202, The US Air Force Mishap Prevention 
Program 

Army Regulation AR 385-10, The Army Safety Program 

OPNAVINST 5100.23G, Navy Safety and Occupational Health Program 

Manual 

USACE EM 385-1-1, Safety and Health Requirements Manual 
UFGS 01 35 26, Governmental Safety Requirements 
UFGS 01 45 00.10 20, Quality Control for Minor Construction 



Defense Safety Oversight Council 


Review Mishap Data for Contractor Injuries, Lost-Time and 
Fatalities 

• DoD-wide (e.g., Force Risk Reduction (FR2) tool 

• VPP CX (Voluntary Protection Program Center of Excellence) 

• Contractor mishap data maintained by Commands (NAVFAC, USACE, 
others) 

• Contractor Mishap data available from Service Safety Centers 

• US Dept of Labor (OSHA/BLS) 


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Defense Safety Oversight Council 


Review Existing Guidelines for Contractor Safety 

• OSHA Instruction CSP 03-01-003, “Voluntary Protection Program 
(VPP) Policies and Procedures Manual”, April 18, 2008 

• Air Force “Contracting VPP Support Guide”, May 2009 

• Air Force AETC Pamphlet 91-202, 19 Nov 1999, “Contract Safety”, 
Certified Current June 16, 2008 

• Defense Contract Management Agency, “Contract Safety 
Requirements”, November 2009 

• DoD VPP CX Presentation, “Interaction with Contractors” 

• DoD “Guidebook for the Acquisition of Services”, July 20, 2011 
•DoD Safety PDC, “Contractor Oversight Course”, Briefings FY08-12 


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Defense Safety Oversight Council 


BEST PRACTICES FOR OPTIMIZING DOD 
CONTRACTOR SAFETY AND OCCUPATIONAL 
HEALTH PROGRAM PERFORMANCE 

(Version 1.0) 



A GUIDE FOR CONTRACTING, LEGAL AND SAFETY AND 
OCCUPATIONAL HEALTH PROFESSIONALS 

DRAFT 

_2012 

Department of Defense 


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Preface (excerpts) 


Since this is a guide, the information presented within is not 
mandatory to follow, but Acquisition Personnel, Safety Professionals 
as well as other Management Officials are encouraged to apply the 
fundamental concepts presented here to all contracting efforts. 

This guide is intended to provide guidance and best practices for 
integrating safety into the contracting process and should be used in 
conjunction with related directives, instructions, policy memoranda, or 
regulations issued to implement mandatory requirements. 

Many of the concepts and best practices herein reflect requirements 
and lessons learned from implementation of the OSHA Voluntary 
Protection Program (VPP) at DoD installations and commands. 


Table of Contents (Draft) 

1.0 Introduction-Contractor Safety Management Process Overview 

1.1 Introduction 

1.2 References 

1.3 Definitions and Terms 

1.4 Types of Contracts 

1.5 Contracting Safety Process 

1.6 Contracts for Services 

2.0 Responsibilities 

2.1 Contractor 

2.2 Contracting Officer and/or Contracting Officer’s Representative (COR) 

2.3 Installation or Activity safety and health personnel 

2.4 Installation or Activity leadership 

2.5 Multi-employer worksites 

2.6 Contractor Employees 
3.0 Contractor Selection 

3.1 Key Elements and Desired Outcomes 

3.2 Process 

3.3 Safety Criteria for Contract Solicitations and Requirements Documents 

3.4 Evaluation of Safety Criteria 



Defense Safety Oversight Council 


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Table of Contents (Draft) 



Defense Safety Oversight Council 


3.5 OSHA Voluntary Protection Program (VPP) 

3.6 Contracts not involving RFPs or IFPs 

3.7 Determining if Contractors are Responsible (FAR Subpart 9.1) 

4.0 Contract Preparation 

4.1 Key Elements and Desire Outcomes 

4.2 DoD, Air Force, Army, Navy, and Local Instructions 

4.3 Construction/Demolition 

4.4 High Hazard Work 

4.5 Hazardous Materials 

4.6 Facility Services 

4.7 Air Force Service and Commercial Contracts 

4.8 Army Service Contracts 

4.9 Weight Handling Equipment (Navy only) 

4.10 Contracts covered by the Construction Safety Act 

4.11 Additional Safety Considerations in Contract Solicitations and Requirements 

5.0 Post Award Safety Orientation and Conferences 

5.1 Key Elements and Desired Outcomes 

5.2 Contractor Orientation 


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Table of Contents (Draft) 


Defense Safety Oversight Council 


5.3 Pre Work Meeting 

5.4 Safety and Health Plan 

5.5 VPP Site Requirements 

6.0 Contract Safety Administration 

6.1 Key Elements and Desired Outcomes 

6.2 Activity Hazard Analysis 

6.3 Routine Contract Safety Surveillance 

6.4 Mishap Investigation and Reporting 

6.5 Inspections by Federal or State OSHA Officials 

6.6 Other Records and Reports 

6.7 Hazard Identification and Correction 

6.8 Contractor Noncompliance 

7.0 Post Contract Evaluation of Safety Performance 

7.1 Key Elements and Objectives 

7.2 Contractor Performance Assessment Reporting System (CPARS) 

7.3 Certificate of Service 


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Appendix 


Table of Contents (Draft) 


Defense Safety Oversight Council 


A Applicable References 
B Acronyms 
C Definitions 

D Types of Contracts (FAR Part 16) 

E-1 VPP Requirements for Service Contracts (sample) 

E-2 Navy Contract Announcement Addressing Installation VPP 
Requirements (sample) 

E-3 Quality Assurance Surveillance Plan (sample) 

E-4 Information to be included in Contract Specifications 

F Basis of Evaluation and the Solicitation Submission 
Requirements (sample) 

G Frequently Asked Questions 


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Does Emphasis on Contractor Safety moke a 

Difference? 


Defense Safety Oversight Council 


DART Case Rate 

BLS General Industry BLS Construction 

NAVFAC Contractors USACE Contractors 



2006 2007 2008 2009 2010 2011 


Total Case Incident Rate 

BLS General Industry BLS Construction 

NAVFAC Contractors USACE Contractors 




2006 2007 2008 2009 2010 2011 


USACE data is LWDR for FY2006-2011 


USACE did not record TCIR-converted to DART & 
TCIR for FY2012 












Invitation to Attendees 


Defense Safety Oversight Council 


• All of you are invited to participate in the review and 
validation process to ensure the guidebook will meet the 
needs of the target audience 

• Your feedback will be critical to ensuring a value-added end 
product 

• If you would like to participate please give me your POC 
information at the end of this session or contact me via 
email 


• craddocd@ctc.com 


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Defense Safety Oversight Council 

Questions?? 


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