PLAN

Sub-contractor Management Plan

Rev 01.00 , Oct 2024

4
Document History
Revision code Description of changes Purpose of issue Date

Rev 01.00 First Issue Issued for Info 23.09.24

Document Approval
Prepared by Reviewed by Approved by

Name Khan Bacha Khan Bacha Fady Daher

Job Title Corporate Manager – Corporate Manager – Health Operation Manager –

Health and Safety and Safety Projects Enterprise

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Contents
1 INTRODUCTION.........................................................................................................5
2 DEFINITIONS.............................................................................................................5
3 PREQUALIFICATION AND BIDDING PROCESS.....................................................6
4 INSURANCE CONSIDERATIONS.............................................................................7
4.1 Certificate of Insurance...............................................................................................7
4.2 Additional Insureds.....................................................................................................7
4.3 Insurance Coverages Subcontractors Should Possess..............................................7
5 BEGINNING WORK...................................................................................................9
5.1 General Subcontractor Management........................................................................10
5.2 Safety Information Exchange....................................................................................10
5.3 Pre-work Meetings....................................................................................................11
6 WORK SITE’S WRITTEN SAFETY PLAN...............................................................11
6.1 Introduction...............................................................................................................11
6.2 Management Commitment........................................................................................11
6.3 Responsibilities for Different Parties.........................................................................11
6.4 Safety Rules and Regulations...................................................................................12
6.5 Disciplinary Policy.....................................................................................................12
6.6 Accident and Injury Reporting and Investigation Procedures...................................12
6.7 Safety Training Requirements..................................................................................12
6.8 Emergency Response Plan......................................................................................12
6.9 Workplace Violence Prevention................................................................................13
7 SAFETY TRAINING AND RECORDKEEPING POLICIES......................................13
7.1 Safety Training..........................................................................................................13
7.2 Recordkeeping..........................................................................................................13
8 MANAGEMENT OF SUB-CONTRACTOR PROCEDURE......................................14
8.1 Establishment of Project OSH Requirements...........................................................14
8.1.1 Scope of Works.........................................................................................................15
8.1.2 Known OSH Hazards and Risks...............................................................................15
8.1.3 Minimum OSH requirements.....................................................................................15
8.2 Evaluation / Selection...............................................................................................16
8.2.1 OSH Policy................................................................................................................17
8.2.2 Roles and Responsibilities........................................................................................17
8.2.3 Legal Compliance.....................................................................................................17
8.2.4 OSH Risk Management............................................................................................17
8.2.5 OSH Performance and Monitoring............................................................................18

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8.2.6 Communication and Consultation activities..............................................................18
8.2.7 Emergency Management..........................................................................................18
8.2.8 Incident Investigation and Reporting........................................................................19
8.2.9 Training, Awareness and Competency.....................................................................19
8.2.10 OSH Inspection and Monitoring................................................................................19
8.2.11 OSH Reporting..........................................................................................................19
8.2.12 Non-Compliance and Enforcement...........................................................................19
8.2.13 Preferred Sub-contractor / Supplier Register............................................................19
8.3 Contractual Agreement.............................................................................................20
8.4 Mobilization / Pre-Start..............................................................................................21
8.4.1 Sub-contractor Main Focal Point..............................................................................21
8.4.2 Communication and Consultation.............................................................................21
8.4.3 Provision of OSH Information...................................................................................22
8.4.4 Sub-contractor Staff Competency.............................................................................23
8.5 Monitoring Sub-contractor Performance...................................................................23
8.5.1 Key performance Indicators......................................................................................23
8.5.2 Sub-contractor Meetings...........................................................................................24
8.6 Commissioning.........................................................................................................24
8.7 Contract Close Out...................................................................................................25

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1 INTRODUCTION
This Plan provides information to assist NBC & its sub-contractor complies with the
requirements of NBC – Management of Sub-contractor.

The use of sub-contractor can range from occasional work such as window cleaning right
through to high-risk specialized work on construction sites. Each will have their own risks
and will need to be managed by the NBC that is engaging them.

A common error made when engaging a sub-contractor is the presumption that it is the sole
responsibility of the sub-contractor to manage OSH issues related to the works. Although
the sub-contractor does have a duty to manage OSH, the NBC who engages the sub-
contractor also has a duty to ensure that the sub-contractor is competent to undertake the
tasks and that they follow the standards that have been agreed.

A Subcontractor Management Plan (SMP) outlines the relationship between NBC and his
sub-contractors while they are performing work for a certain project, and it outlines the
methods by which the NBC will ensure the production of quality deliverables from each of its
subcontractors and ensure the development of long-term business relationships between
the companies.

This SMP provides guidance for subcontract management activities, including the following:

 Prequalification and bidding process

 Insurance considerations

 Beginning work

 Work site’s written safety plan

 Safety training and recordkeeping policies

 Safety inspections

 Work-in-progress and post-project reviews

2 Definitions
a. A sub-contractor has been defined within the NBC as:

 A person, NBC, their employees or a nominated representative engaged to carry

out work for the NBC in a contract for service arrangement.

b. A supplier has been defined within the NBC as:

 A person, organization, their employees or a nominated representative engaged to

supply goods. A supplier may be distinguished from a sub-contractor or
subcontractor, who commonly adds specialized input to deliverables. A Supplier is
also commonly called a vendor.

c. Although the risks involved with engaging suppliers are in many cases lower than those
associated with the engagement of sub-contractor, organizations do still have a duty to
ensure that their supplier is competent and meets their OSH requirements. Further,

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 organizations should ensure that the goods supplied are sufficient for the needs of the
NBC requirement and do not pose unnecessary risk.

3 Prequalification and Bidding Process

Prequalifying subcontractors is an important way to ensure the hiring of a subcontractor that
has the necessary experience and the ability to complete the job safely, on time and within
the budget. While not mandatory, prequalifying a subcontractor helps minimize risk and
increases the chance of the job being done right. Consider the following when going through
the prequalification process.

 Gather the subcontractor’s qualifications, whether through a questionnaire, formal

written request, qualification statement or other method. Examine the following
information:

 Does the subcontractor have experience completing similar work?

 Does the subcontractor have the necessary resources (manpower,

finances, available equipment, insurance and surety bonding capacity,
licensing, etc.) to complete the job?

 Does the subcontractor have a history of litigation or other legal

problems?

 Does the subcontractor have any past OSHA or EPA violations?

 Does the subcontractor’s safety record prove that the job can be done in
a safe manner?

 Does the subcontractor have any references from previous contracts?

Were past customers satisfied with the subcontractor’s work?

 What is the subcontractor’s Experience Modification Rate (EMR)?

 Prequalification should let a potential bidder know exactly what to expect from
project start to finish. Giving a bidder every piece of relevant information, along with
being available to answer any questions he or she might have, will make the
process fair and objective.

 Not all subcontractors will qualify for the bid. To weed out bids that fall short of your
standards, consider implementing minimum requirements for the subcontractor,
such as making sure the subcontractor:

 Has not been nor is currently debarred by any federal, state or local
government authority in the past 2 years

 Has not defaulted on any project in the past 2 years

 Has not had any professional license revoked in the past 2 years

 Has not committed a serious or willful OSHA, ISO or state safety violation in
the past 2 years

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  After a list is compiled of qualified bidders, bids can be submitted. Generally,
qualified bidders with the lowest bid will be selected for the contract, although this is
not always the case.

 Prior to awarding the contract to a qualified bidder, the NBC or owner should
document:

 The proposed project schedule that includes key milestones and a

description of the technical approach to the project;

 The project management team that includes, at a minimum, the construction

management, field supervision and technical personnel. With the project
management team list, resumes of the people listed may be included;

 A quality control plan that includes a copy and/or description of the quality
control program to be used on the project and any implementing documents
applicable to its program; and

 A cost control plan that includes a description of the cost control program
being used for the project.

4 Insurance Considerations
4.1 Certificate of Insurance
Prior to the beginning of the project, the subcontractor should provide two certificates of
insurance to the NBC showing that the subcontractor has coverage for him- or herself and
his or her employees, agents and subcontractors. The subcontractor’s insurance must
provide adequate coverage for any workers’ compensation obligations, employer’s liability
and automobile liability. If any of these policies are terminated, the subcontractor should
provide certificates of insurance showing replacement coverage. All coverage must be
placed with insurance companies duly admitted in the state or in the desired licensing
jurisdiction in which the work is being done, and all coverage must be reasonably
acceptable to the NBC.

The certificate of insurance should provide that the insurer give the contractor a written
notice of cancellation and termination of the contractor’s coverage at least 30 days prior.

4.2 Additional Insureds

The subcontractor’s policy must name the contractor as an additional insured. Coverage
must be afforded to the contractor as an additional insured whether or not a claim is in
litigation. Additional insured coverage must apply as primary insurance with respect to any
other insurance afforded to the owner and contractor.

4.3 Insurance Coverages Subcontractors Should Possess

Workers’ compensation
 The subcontractor should secure a workers’ compensation insurance policy. The
workers’ compensation policy must cover all of the subcontractor’s work and
performance and provide coverage for all employees, executive officers, sole
proprietors, and partners and members of a limited liability company, in the amounts
required by all applicable laws.

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  In addition, the subcontractor should secure an employers’ liability insurance policy
(part II of the standard workers’ compensation policy). This type of coverage covers
the damages that become due in case of bodily injury, occupational sickness or
disease or death of subcontractor employees that are not covered by the workers’
compensation policy.

 If a subcontractor does not have his or her own work comp insurance, you may see
your work comp premium rise during an audit. This is why it is so important that the
subcontractors you hire provide proof of insurance before any work is done.

Commercial general liability (CGL)

Subcontractors should secure a CGL insurance policy to cover the damages that become
due in case of bodily injury, property damage and personal or advertising injury arising out
of or related to:

 All of the subcontractor’s operations and premises;

 All of the subcontractor’s products and completed operations;

 All liability or responsibility assumed by the subcontractor;

 All liability assumed in a business contract;

 The contractor as an additional insured; and

 Defense expenses paid in addition to the policy limits.

There should be no endorsement or modification of the CGL for risks arising from pollution,
explosion, collapse, underground property damage or work performed by the subcontractor.

Auto liability
 The subcontractor should secure an automobile liability insurance policy to cover
the damages that become due in case of bodily injury, death of a person or property
damage arising out of ownership, maintenance or use of any motor vehicle or trailer
owned, hired, leased, used on behalf of or borrowed by the subcontractor. The
policy must also include coverage for any equipment subject to motor vehicle laws,
contractor and owner (if different than the contractor) and any subcontractor liability
or responsibility.

Umbrella or excess liability coverage

 The subcontractor should secure an umbrella liability insurance policy to cover the
damages that become due in case of bodily injury, property damage and personal
and advertising injury, with at least the same terms and conditions as the policies
mentioned above.

Completed Operations Liability and Obligations

 Even quality workmanship is not immune to potential claims of property damage or
bodily injury. All operations carry the risk that injury or damage may occur as a
result of the work, leading to costly lawsuits. Considering the complicated mix of
NBC and subcontractors that contribute to each project, who is liable for this risk?

 In insurance terms, “your work” as used in an insurance policy is a broadly defined

term that includes operations performed by the policyholder or on the policyholder’s

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 behalf, including material, parts or equipment in connection with the operations.
Operations or work performed on behalf of the policyholder means work done by a
subcontractor is considered the contractor’s work. Therefore, faulty electrical work
performed by an electrician that causes a fire or other damage could be considered
the contractor’s liability, but would be covered under a standard policy.

 Because a contractor or other involved party could be held liable for defects in a
subcontractor’s work, years after it has been completed, and filing the claim under
the contractor’s CGL policy could cause the premium to rise, many construction
contracts require subcontractors to provide insurance coverage for claims resulting
from their completed work for a finite period of time, typically the one- to five-year
range. Typical contracts also require that the subcontractor name the owner, the
architect, the general contractor and other third parties as “additional insured”
parties, entitled to coverage under the insured subcontractor’s CGL policy. Naming
additional insured parties requires a separate endorsement to that policy.

 This means that subcontractors can be held liable for claims of property damage or
bodily injury resulting from a defect in a contractor’s work. It is also critical to
maintain this coverage into the future; failure to do so could lead to a breach-of-
contract lawsuit brought by the contractor or other party.

 It is important for subcontractors to understand this commitment when signing the

contract—the insurance commitment doesn’t end with the project. Further, in the
event of a large claim, subcontractors could be faced with a substantial increase in
premiums on the policy.

 What can subcontractors do to reduce the risk of a claim being filed against them for
a defect in their completed work? To avoid litigation, it is crucial to know local
regulations and adequately document proper performance. Subcontractors must
know their company’s documentation practices relative to each subcontract, and
carefully keep records of all processes.

5 Beginning Work
After a subcontractor has been selected, each subcontractor should have a legally binding,
written contract that defines the following items:

 The legal names of the parties involved in the contract

 The scope of the contracted work (contained in an attached statement of work

(SOW)), which should include the following items:

 Each subcontractor’s clearly defined responsibilities and authorities

 Each subcontractor’s deliverables identified, and required content clearly

specified

 Each subcontractor clearly identified and described services that it is

responsible for providing

 Schedule and budget constraints

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  Each subcontractor’s clearly defined requirements for quality, including the
requirement to allow independent quality inspections of materials and
processes

 Appropriate terms and conditions

 Adequate facilities provided to meet the needs of the subcontractors

 NBC’s support in processing invoices and payments

 The appropriate terms and conditions that will be imposed on both the NBC and the
subcontractor

 An acceptance process

5.1 General Subcontractor Management

Managing various subcontractors and their teams can be a difficult task, but successful
projects all tend to have the same characteristics:

 They all have clear and unambiguous subcontracts established that include an
SOW.

 The efforts of all subcontractors are integrated into a cohesive project plan with all
subcontractors understanding where their efforts fit into the overall picture.

 The formal and informal interfaces between the NBC and the subcontractors, as
well as among the subcontractors, are documented.

 Before starting specific work, the subcontractors are granted authorization to

proceed. This authorization is given, in writing, via a Work Authorization form.

 A formal team building process is established and implemented.

These practices all contribute to reducing the risk of misunderstandings or isolationism.

The work of all subcontractors should be coordinated by the NBC to ensure that the efforts
of all parties are integrated into a cohesive unit throughout the entire project process. A
master schedule should be developed to establish schedule constraints and identify
contractual and significant internal milestones.

Subcontractors should have a single point of contact with the NBC for contractual matters.
On a day-to-day basis, all subcontractor personnel will be free to interact with any NBC
personnel as needed.

5.2 Safety Information Exchange

To make the project go as smoothly as possible, there needs to be open lines of
communication between the subcontractor and NBC regarding proper safety procedures.
The subcontractor must:

 Designate a safety representative to handle all safety and health issues during the
job

 Provide proof of necessary safety training

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  Perform a safety hazard assessment to address any problem areas before work
begins

 Report all injuries, spills, property damage incidents and near misses

 Obtain phone numbers and directions for the nearest hospital, ambulance service
and fire department, should an accident occur

 Know, follow and train his or her employees about the safety policy of the
contracting company

 Obtain the Safety Data Sheets (SDS) of any chemicals used during the job

 Provide employees with proper identification

 Comply with all owner safety rules

5.3 Pre-work Meetings

Before work begins each day, subcontractors should hold a pre-work meeting (Activity
Briefing) to discuss the type of work to be performed. Safety should be the main focus of
these meetings—the subcontractor and his or her team should review specific safety
considerations for the particular type of work to be accomplished. Workers should be
encouraged to voice any safety concerns before an accident occurs. Subcontractors should
secure all necessary permits (hot work, lockout/tagout, confined spaces, etc.) before work
begins.

6 Work Site’s Written Safety Plan

All subcontractors and their employees should abide by the site-specific rules and
regulations that are set forth by the contracting company. The safety policy must be followed
by all contractors, subcontractors and their employees. Failure to comply could result in
disciplinary action, up to and including contract termination. The safety policy will generally
contain the following:

6.1 Introduction
 Lists the overall goal of the safety program and conveys the importance of following
it while on the job

 Encourages employees to work safely and report injuries or unsafe conditions

6.2 Management Commitment

 Lists the company’s policies and philosophies and makes employees aware of
management’s commitment to safety

 May include a mission statement, outlining the company’s goals for the safety
program

6.3 Responsibilities for Different Parties

 Explains what everyone’s responsibilities are in executing the safety program,
including management, supervisors and employees

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  Management’s responsibilities may include ensuring that the safety program is
enforced and correcting any problems brought to its attention by supervisors or
employees on the work site.

 Supervisors may be responsible for taking action to correct safety problems,

providing personal protective equipment (PPE) to all employees, disciplining
workers and investigating any accidents or injuries.

 Employees may be responsible for reporting accidents and injuries, reporting unsafe
conditions, attending any safety training and obeying all safety and health
regulations.

6.4 Safety Rules and Regulations

 Outlines specific rules and regulations that must be followed at all times on the job

 For example, OSHA regulations for lockout/tagout procedures (29 CFR 1910.147)
may be spelled out for workers.

 May include the work site’s Hazard Communication Program

6.5 Disciplinary Policy

 Explains what may happen if workers break rules or regulations. Disciplinary action
may range from a verbal warning to dismissal from the job.

6.6 Accident and Injury Reporting and Investigation Procedures

 Explains when and how to report an accident or injury while at the work site

 Outlines an accident investigator’s process for determining why an accident

happened and what can be done to prevent similar accidents from happening in the
future

6.7 Safety Training Requirements

 Describes training requirements for all employees working on the job

 Training topics may include the following:

 Aerial lift safety

 Crane, hoist and rigging safety

 Excavation and trenching safety

 Fall protection

 Fire extinguisher operation

 Hearing protection

 Heat illness prevention

 Housekeeping

 Ladder safety

 Lockout/tagout procedures

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  Powered industrial truck safety

 Respiratory protection

6.8 Emergency Response Plan

 Outlines the procedure for responding to an emergency due to a fire, chemical spill,
natural disaster, injury, etc.

6.9 Workplace Violence Prevention

 Lists the risks and warning signs of workplace violence and offers ways to reduce
the likelihood of violence on the job

 Subcontractors should also submit their site-specific safety plans before work
begins. These plans should include job-specific safety requirements, roles and
responsibilities of the subcontractor’s team, potential project risks and
countermeasures to those risks.

7 Safety Training and Recordkeeping Policies

7.1 Safety Training
Subcontractors are expected to train their employees about site-specific hazards before the
project begins. They should also provide documentation of the training to a contracting
company representative.

The subcontractor’s employees should also be aware of proper first-aid procedures and
know what to do in the event of a medical emergency. Stress to the subcontractor that it is
his or her responsibility to notify his or her employees of any safety information provided by
the contracting company to the subcontractor.

As the contracting company, your employees should be trained on any specific hazards
introduced by the subcontractor’s work.

7.2 Recordkeeping
A strong recordkeeping policy will ensure the job is done in compliance with various federal
and state regulations and will be useful should you ever be audited.

Your hired subcontractors should:

 Keep records of all safety training with the subcontractor’s workers

 Keep copies on file of all forms you provide to the subcontractor throughout the
contract

 Have a list of telephone numbers for the nearest hospital, ambulance service and
fire department

 Have copies of all necessary SDSs and other required information regarding
chemicals used for the job

 Keep an OSHA recordable injury and illness log (Form 300 and 300A, if applicable)
for the project, along with copies of accident reports for all accidents that occur on
the job

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 As the contracting company, you should keep thorough records, as well, including:
 A copy of the contract on file and be familiar with its contents, along with the safety
and health aspects of the job

 Training records for your company’s workers regarding hazards that may be caused
by the subcontracting company

 Copies of all forms related to the contract that are required to be filled out by the
company before or during contract work

 OSHA recordable injury and illness logs for the job, along with copies of accident
reports filed throughout the project

 Daily pre-work inspection checklist findings

 Records of any documentation given to you by the subcontractor

 Documentation of all communications made to the subcontractor regarding safety

issues

The following is a sample list of project records:

 Contract documents, including plans, specifications, etc.

 Daily work site inspection forms

 Meeting minutes

 Noncompliance and compliance notices

 Contract status

 Change work orders

 Permit forms

Please note that each contract may require different forms.

8 Management of Sub-contractor Procedure

8.1 Establishment of Project OSH Requirements
 It is vital that prior to any tender being issued, the NBC must first fully understand all
the OSH requirements for the project and how these will impact upon the sub-
contractor that has been selected to undertake the works.

 These impacts could be in a variety of forms, such as restricting the working hours
due to the surrounding neighborhood, the times that goods can be delivered to the
project or specific OSH requirements that the sub-contractor must adhere to whilst
on site.

 All this information should be gathered and included within the tender
documentation to ensure that all sub-contractor is aware of the OSH requirements
for the project and have allowed enough cost, time and resources to meet those
requirements.

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  The main purpose of providing this information is to ensure that all parties who are
tendering for the project are fully aware of all the significant risks, any restrictions
that are to be placed on them whilst working on the project and also the minimum
OSH requirements / systems they must have in place. This will ensure that there are
no surprises to either party once the project commences and should be the
foundation of a successful project.

 As a minimum the following should be included within the tender documentation:

 Detailed scope of works;

 Known OSH Hazards and Risks; and

 Minimum OSH requirements.

8.1.1 Scope of Works

 The tender documents should include not only a detailed scope of works, but also
any information related to sequencing and phasing within the scope.

 The scope of works should include enough detail to allow a competent sub-
contractor to fully understand the requirements of the project.

8.1.2 Known OSH Hazards and Risks

 The NBC may provide a list of all known significant risks and hazards associated
with the project. This list should be limited to those risks and hazards that are
considered significant or medium to high risk.

 Further if the NBC requires that the hazard is managed in a particular manner or
has defined parameters that are different from those defined in legislation or best
practice, these should also be stipulated within the tender document.

 An example of this could be noise. The NBC may have identified noise as a general
hazard on the project, however due to their own risk management systems, the
NBC has a lower noise action level than that is set within the current legal
standards. This information must be provided to the sub-contractor at this stage
otherwise it would be reasonable for the sub-contractor to provide costs and
information to only manage the noise to the levels as defined in current standards.

 Other issues the NBC may wish to highlight when discussing project hazards and
risks could be the way they are managed. The NBC may wish to have set criteria for
different hazards or may require the use of permit to work systems for set hazards
and risks. This should be highlighted to the tendering sub-contractor to allow them
to include this in their considerations.

8.1.3 Minimum OSH requirements

 The NBC should highlight the minimum OSH requirements that each sub-contractor
must have in place when undertaking the works that are being tendered for. The
requirements will differ dependent on the risk and complexity of each project,
however as a minimum these should include:

 Adequate OSH Resources;

 Legal Compliance;

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  Risk Management Programs;

 OSH performance monitoring and incident reporting;

 OSH Training, Awareness and Competency;

 OSH reporting

 Incident Investigation

 Emergency Management

 OSH Inspection and Auditing requirements; and

 Non-Compliance and Enforcement procedures.

 If it is a high-risk project, the NBC may require a high level of OSH management
and supervision. As part of the tender documents, this should be specified, including
the competency levels that are required for each role. This again ensures that all
parties are clear on the requirements prior to the project commencing.

 Further to the NBC highlighting the minimum requirements that the successful sub-
contractor have in place, they should also provide information on the systems they
will have to comply with whilst on the project.

 NBC should ensure that the sub-contractor is fully aware of any requirements that
will be in place that may be a burden (in terms of time, resource or cost) to the
successful sub-contractor.

 Examples of this could be that the NBC require all staff who are working on the
project to undergo a specific induction program, the content of which is developed
by the NBC. This would be an additional induction to the project specific OSH
induction that the sub-contractor would normally provide and would be a burden
upon the sub-contractor in terms of time and cost.

 Other examples could include the requirement that the NBC undertake site
inspections or regular audits or require the project OSH manager to attend a weekly
OSH meeting. The sub-contractor should be aware of these facts prior to tendering
for the project.

8.2 Evaluation / Selection

 Following the release of tender information and responses from interested sub-
contractors, the NBC should develop a systematic approach to evaluating these
responses to ensure OSH requirements have been fully considered and comply with
the OSH requirements issued within the tender documentation.

 The review for OSH should be integrated into an overall sub-contractor review
process to ensure that the successful sub-contractor has not only solid OSH
systems and performance, but has adequate resources, financial ability and
experience to undertake the project.

 The process that is utilized for the review should take into account the complexity
and risk of the project that is going to be undertaken, for example for a high risk
contract the NBC should consider meeting with prospective sub-contractor to review
their systems and examine how they have undertaken previous similar works. They

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 may also wish to visit previous works to judge completion. For a low risk, straight
forward project, a desk top review of responses may be considered adequate.

 NBCs should also give preference to those sub-contractors that already have an
approved OSHMS, as they will already have a documented approved OSHMS that
has been independently reviewed and is implemented (or in the process of) into the
NBC. Further, sub-contractor who do already have an approved OSHMS should be
able to demonstrate solid risk management processes and will be regularly audited
and inspected by NBC.

 The scope of the evaluation of OSH performance and systems should be defined by
the risks and complexity of the project. If the risk is deemed low then as a minimum
the sub-contractor should be implementing the requirements of NEOM-NPR-GFR- If
the risk is seen as medium to high, then ideally the sub-contractor selected should
hold an approved OSHMS, however if this is not the case then the following should
be in place as a minimum:

8.2.1 OSH Policy

A good Safety and Health policy will have been reviewed within two years and signed by the
responsible person within the sub-contractor. The policy should include three definite
sections:

 Statement of intent - will be a top line statement that outlines the company
objectives for safety and health;

 Organization - outlines the company organization for Safety and Health, including
roles and responsibilities within that project; and

 Arrangements – will detail how the company intends to achieve the objectives
delineated in the statement of intent.

8.2.2 Roles and Responsibilities

 A vital element of a successful project is the clear definition of roles and
responsibilities on behalf of the sub-contractor. The sub-contractor should provide a
clear outline of all key roles and responsibilities throughout the life of the project.

 The sub-contractor should also define a clear organization structure for the project
as part of his submission. For more complex projects, the sub-contractor should
have been requested to submit CVs of the staff he is planning to utilise on the
projects. These should be reviewed to ensure they meet the competency
requirements that have been set as part of the pre-tender information

8.2.3 Legal Compliance

 The successful sub-contractor should be able to demonstrate how they identify and
comply with all applicable NEOM and legal requirements. The procedure should
clearly identify what legislation is relevant to the NBC, how it impacts their
operations and how they comply with the requirement.

 Further NBCs with robust management systems will be able to demonstrate how
these requirements are communicated within their firm and responsibilities for the
upkeep and review of the legal registers etc.

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  When reviewing the legal compliance of a sub-contractor, it is important that the
NBC understands any specific legal requirements for the project and ensures that
the sub-contractor has incorporated this into his register.

8.2.4 OSH Risk Management

 The sub-contractor should define within his submission how he will manage the risk
management program for the project. It is important that this is site specific rather
than the overall corporate procedure.

 Also, as part of the submission the sub-contractor should outline who will have
overall responsibility for the risk management program, including the review and
approval of all risk assessments / method statements for the project.

 Further it is important to ensure that this program covers the review and approval of
any subcontractor’s risk assessments as these are often overlooked.

 The procedure should also include information on any known hazard’s that have
been defined in the pre-tender information and how the sub-contractor will manage
the said hazard / risk.

 Dependent on the current status of the projects or information known, the sub-
contractor may be in a position to submit some specific project risk assessments.

8.2.5 OSH Performance and Monitoring

 The sub-contractor should define what the performance targets are and how they
will ensure they achieve them during the life of the contract. The performance
targets that are set out should also include any that the client originally set as part of
the pretender information.

 Further to discussing what the performance targets are, the sub-contractor should
also show how these will be managed and achieved. This, ideally, should come in
the form of an action plan that identifies the required actions, timescales and owners
for each individual target.

 The NBC should also review the past performance of the sub-contractor, as this will
give information on how they have performed on previous contracts. Again,
dependent on the risks involved, it may be prudent to contact previous clients to
review past performance and gain references.

8.2.6 Communication and Consultation activities

 It is important that robust procedures are in place to manage consultation and
communication to ensure that all parties are aware of the latest information and
have had an opportunity to input to the decision-making process.

 The sub-contractor should define how this will be managed during the contract,
including the communication with all external and internal parties such as sub-sub-
contractor, regulatory authorities or the client.

 The sub-contractor should also define how he will communicate with his employees
on OSH matter including how they will be consulted on these matters.

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8.2.7 Emergency Management
 The sub-contractor should define what the emergency management procedure will
be for the project / contract along with the detailed arrangements for managing
these situations.

 The NBC should ensure that the sub-contractor has identified all foreseeable
emergency situations and that the arrangements are reasonable for managing the
situation.

 Also, the contract should provide information on who will form the emergency
management team or crisis management team.

8.2.8 Incident Investigation and Reporting

 Each sub-contractor should define what the procedures are for incident investigation
and reporting on the project.

 The procedure should clearly show how incidents will be managed from the point of
initial notification right through until close out and corrective actions.

 The procedure should also show how incidents will be reported, both internally and
externally.

8.2.9 Training, Awareness and Competency

 As part of the submission the sub-contractor should define how they will identify and
manage training requirements during the contract. This should include the
monitoring of training requirements and refresher training.

 Further, the sub-contractor should also include information on how they will train
employees on any specific hazards or risks that have been identified as part of the
pre-tender information.

8.2.10 OSH Inspection and Monitoring

 Regardless of complexity of risk, all projects will require an element of inspection
and auditing to ensure compliance to agreed standards. The sub-contractor should
define what these arrangements are and how they will be managed on the project.

 Further it is important to ensure that these arrangements incorporate all other

parties that are involved on the project, such as sub-sub-contractor.

 The sub-contractor should also discuss how they will ensure compliance to any
client audit and inspection requirements that have been set as part of the pre-tender
information.

8.2.11 OSH Reporting

 Each project will have different reporting requirements, and these should be defined
in the pre-tender information that was developed. The sub-contractor should show
how OSH information will be gathered, defined and then reported.

 This procedure should also include internal and external reporting

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8.2.12 Non-Compliance and Enforcement
The sub-contractor should define what the arrangements are for the management and
enforcement of any non-compliance within the project. It is important that this procedure
also includes any other parties on the project.

8.2.13 Preferred Sub-contractor / Supplier Register

 As part of the management of sub-contractor’s plan that each NBC is required to
develop and implement, it is good practice to hold a list of preferred sub-contractor /
suppliers that have already been evaluated. The procedure should stipulate that
only sub-contractors who have met the criteria set for evaluation can be used within
the NBC.

 When developing a preferred suppliers list, NBC should consider how many sub-
contractors you wish to hold on the preferred list for each type of activity you use
sub-contractor for. If your NBC uses sub-contractor on a regular basis, then it may
be best to have up to three different sub-contractors / suppliers for each different
activity. For those NBCs that only seldom use sub-contractors, then the preferred
list may be smaller.

 Regardless of the complexity of the preferred list, this register should be used as a
tool to manage sub-contractor and track performance. Sub-contractor and suppliers
should be revaluated on an annual basis, including an examination of past
performance during the year

8.3 Contractual Agreement

 Contracts and services agreements are essential business tools for professional
trading and business relationships. Without clearly defined and agreed contracts,
misunderstandings can develop, expectations of client and provider (customer and
supplier) fail to match, and all sorts of problems can occur.

 While the tradition and spirit of shaking hands on a verbal deal between two friends
in business is helpful in underpinning a good trading relationship, it is sensible for
significant supply arrangements to be documented and agreed, usually by
signatures.

 Aside from the process of clearly agreeing and understanding the expectations
between supplier and client, contracts or agreements also help if one or both of the
original dealmakers one day move on, which can then give other people the
problem of how to make sense of what might or might not have been agreed
between the two parties.

 NBC can reduce the formality and detail according to their own situation and the
risks involved with the works being undertaken, however NBC needs to be aware of
the risks if potentially contentious matters are vague and open to dispute.

 Robust contracts and agreements provide an essential reference point upon which
to discuss and negotiate effective outcomes whenever situations change, in terms
of the client's requirements and the provider's capability.

 NBCs should ensure that all OSH requirements are clearly stipulated within the
service contract. The complexity or level of detail required will be defined by the risk

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 of the project or works that are being undertaken, however as a minimum it shall
include the following items:

 That sub-contractor has an approved OSHMS, or, if sub-contractor do not

have an approved OSHMS, then NBC shall induct and train the sub-
contractor on the clients standards and ensure the sub-contractor has
systems in place to manage the risks from their undertakings.;

 The requirement for adequate OSH resources;

 OSH roles, responsibilities and accountabilities of all relevant stakeholders

are clearly defined and communicated;

 A chronological division of work to be performed under the contract (or

subcontract) up until the completion of a project;

 A description in sufficient detail to enable sub-contractor to understand the

complexity, potential hazards and level of risk of the work to be performed;

 The requirements of sub-contractor in respect of OSH;

 SOPs and / or penalties for managing ongoing non-conformance to OSH

requirements; and

 Relevant project OSH documentation (e.g. site induction requirements, site

safety plan, OSH procedures, permit systems and OSH policy).

8.4 Mobilization / Pre-Start

Prior to mobilising any contract, there are several issues that the NBC must ensure are in
place. These include:

 Nomination of a main focal point within the NBC for the sub-contractor;

 Providing all sub-contractor staff with the relevant OSH information; and

 Checking that the staff that have been allocated by the sub-contractor are
competent.

8.4.1 Sub-contractor Main Focal Point

 The NBC should nominate someone from within their own to be the main focal point
/ responsible person for the sub-contractor whilst undertaking the works. This has
many advantages including:

 One point of contact for the sub-contractor;

 Ensures information is not ‘lost’ by going through different parties; and

 Helps to build stronger relationships with the sub-contractor

 The person that is nominated by the NBC should have a working knowledge of the
work that is being undertaken to allow them to make informed decisions when
required.

 The focal point should have full responsibility to ensure that the contract and works
are managed in line with the NBC and legal requirements.

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  Depending on the complexity or risk of the contract, the focal point may require
additional support to assist in the management of the works.

8.4.2 Communication and Consultation

 Prior to mobilising any contract, NBCs should consider allocating appropriate levels
of planning, coordination and communication to the management of sub-contractor
to ensure that all risks are identified, and activities are properly planned.

 Coordination activities may include:

 Forward planning of work activities and tasks between sub-contractor to

minimise risks;

 Joint risk assessment of work activities and tasks;

 Sub-contractor’s participation in consultative activities (e.g. OSH

committee);

 Employee welfare related and transportation activities;

 Emergency response and management arrangements;

 Communication of OSH information (including hazard alerts, site safety

alerts and incident reports, toolbox meetings, etc.); and (vii) OSH record
keeping requirements.

8.4.3 Provision of OSH Information

 NBC has a legal obligation to ensure that all staff who are working within their
premises or on their behalf are aware of all OSH hazards and risks that are present.
This obligation also includes staff who are employed by a sub-contractor to work on
behalf of the NBC. This is often delivered through a sub-contractor’s induction
procedure.

 When developing a sub-contractor’s induction, the NBC should consider not only
what OSH information is required but should also ensure that other vital information
such as site rules, what facilities are available etc. are included as part of the
induction.

 The NBC should also ensure that it includes information on the risks that are
present within their facility and what procedures are in place to manage the risks.

 When developing a sub-contractor’s induction program, the NBC should consider

the following issues:

 OSH legal requirements;

 Contact information – focal point / responsible person;

 Site rules;

 Working hours – including any restrictions (noise etc.);

 Reporting procedures;

 Restricted areas;

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  Facilities available;

 Emergency procedures;

 High risk activities – Permit to Work procedures;

 OSH risks and procedures;

 Storage areas – if relevant; and

 Ongoing communication and consultation.

 The issues that are covered within the induction will be determined by the risks and
complexity of the works and the environment they will be undertaken within. For
example, if the contract is considered a low risk and is undertaken within a very
controlled environment, the amount of information that is required by the sub-
contractor is probably minimal.

 Dependent on the size, complexity duration of the contract, the NBC may choose to
allow the sub-contractor to deliver the induction, however the NBC still has a duty to
ensure that all staff have undertaken the induction and that the information passed
is factually correct and understood by the attendees. This can be done through a
series of audits or ongoing inspections.

8.4.4 Sub-contractor Staff Competency

The NBC may have stipulated within the pretender information that all persons working on
the contract must have certain competencies. This should be checked prior to work
commencing. It is also good practice to undertake ongoing checks as part of the inspection
and auditing of the sub-contractor’s performance.

8.5 Monitoring Sub-contractor Performance

 Following the evaluation of competence, it is often assumed that there is no need to
undertake any further action and the sub-contractor is responsible for the works and
any problems that may arise. Although sub-contractors do hold the main
responsibility, under current legislation, the NBC is required to ensure that the
standards that have been agreed through the pre-tender information are being
adhered to.

 Dependent on the risk and complexity of the works, the NBC should develop an
audit and inspection program to cover the works that are being undertaken. The
frequency of the audit and inspection program should be defined by the risks and
complexity of the works.

 If the works are identified as high risk, then as a minimum, daily checks should be
undertaken out on the work activities. If the works are not defined as high risk, then
checks must still be carried out, but on a less frequent basis.

 Further if the work is being undertaken under a permit to work system, additional
control measures and requirements will be needed.

 The NBC should inform the sub-contractor of what the audit and inspection plans
are for the contract as part of the pretender information so he is fully aware and also
to allow them to include any additional requirements within his own systems, costs

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 or resources. Further the NBC may also decide that they will undertake random
unplanned inspections on the works,

 It is important that the work is inspected to ensure that the safe systems of work and
risk assessments that the supplier provided are being followed and correctly
implemented. The sub-contractor’s staff should be questioned on site to ensure they
are aware of the content of the risk assessments and the actions they should take to
mitigate any risks.

 Other stakeholders, such as the finance or security, should also be asked for
feedback on the sub-contractor’ performance during the works. This should also be
gathered and used as part of the evaluation of performance.

8.5.1 Key performance Indicators

 As part of the contract that has been agreed between both parties, several Key
Performance Indicators (KPI’s) should have been defined. As a minimum these will
include the KPI’s that are defined within NEOM-NPR-SOP 06.0 – OSH Performance
Monitoring and Reporting.

 The NBC should ensure that the sub-contractor’s performance against these KPI’s
is regularly measured and that feedback is given to ensure they are aware of their
current performance.

8.5.2 Sub-contractor Meetings

Depending on the length and complexity of the contract, the NBC may also wish to hold
regular meetings with the sub-contractor to discuss performance and any ongoing issues.
These meeting can be a valuable tool to ensure that contracts run smoothly, and all parties
are aware of any issues.

For longer fixed contracts, such as cleaning services etc., it is good practice to meet with the
sub-contractor at least four times a year. The frequency of these meetings should be
defined by the risks and complexity of the works being undertaken.

The following issues should be considered when meeting with sub-contractor:

 Key performance Indicators;

 Results of audits and inspections;

 Incidents;

 Ongoing issues / remedial actions;

 Feedback from other suppliers; and

 Future planned activities (both from the NBC and sub-contractor).

8.6 Commissioning
Depending on the work that have been undertaken, the NBC shall ensure that all activities
related to the commissioning of plant and equipment are undertaken by trained and
competent persons and that prior to any activities being undertaken, the sub-contractor has
full documented operating procedures for the commissioning activity.

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 The commissioning procedures shall document a logical progression of steps necessary to
verify that installed plant is fully functional and fit for purpose.

These procedures shall include the following steps (not an exhaustive list):

 Permit to work procedures;

 Isolation (Lock-out / Tag-out) procedures;

 Restrictive access;

 Operator training and competency;

 System configuration check;

 Calibration of vessels and instrumentation;

 Start-up protocol;

 Shut-down protocol;

 Chemical (live) trials; and

 Handover.

8.7 Contract Close Out

Upon completion of the works or end of the contractual period, the NBC shall ensure that all
OSH requirements have been complied with and all necessary records have been handed
over by the sub-contractor. This list of records will be dependent on the scope of works that
was undertaken and could vary from a complex operating manual for a piece of machinery
through to simple time keeping records for staff.

The NBC should also ensure that the area of the works has been returned to the original
state or to an agreed condition.

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