TAB 2 – SUBCONTRACTOR SAFETY REQUIREMENTS

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Since our inception, safety has been part of Unger’s fundamental culture. We started as a family business. With respect to safety, Unger treats employees and Subcontractors as part of its extended family. Safety at Unger isn’t about money, insurance savings, or mandatory requirements set forth by governmental agencies. To us, safety is about people and making sure at the end of the day they go home in good health to their family and friends. Unger is a team oriented, learning centered organization that promotes safety excellence through awareness, empowerment and participation at all levels.

Safety excellence at Unger is defined by our planning and executing work with a passion for preventing injuries. Additionally, safety excellence includes: looking out for each other’s safety, stopping and correcting unsafe acts or unsafe conditions on the spot, coaching and developing less safety savvy individuals.

Our safety excellence goal is not limited to our corporate boundaries. Unger willingly partners with Subcontractors, trade organizations and local universities to improve safety in the construction industry. Employees and Subcontractors understand that the expectation is to eliminate injuries, not to hide them. Hiding injuries provides the illusion of safety excellence. We want Unger and our Subcontractors to achieve safety excellence. In order to achieve safety excellence, you need total commitment from the top down, the bottom up and both ways from the middle of our organization. In fact, Unger believes the truest measure of safety excellence is when peer to peer observations correct unsafe work behaviors and unsafe conditions without the need for management intervention.
The intention of our safety program is fact finding, not fault finding. Freely identifying our short-comings, celebrating our successes and putting proper measures in place help make measureable progress in Unger's safety excellence journey. We have not fully achieved safety excellence, and in fact we might never be able to achieve it, but it is our goal and we are continuously making improvements. The safety of our people and our reputation are worth it.

 

1. General Expectations

Subcontractors must develop and maintain safety, health and environmental programs and procedures that meet or exceed Federal, State, and Local laws, regulations and standards. Subcontractor will also comply with any Owner and/or Unger site specific requirements.

Subcontractors will make Unger immediately aware of any unique safety, health, or environmental concerns related to its Work and make timely efforts to notify other affected contractors working on site and protect the public from hazards.
 

Subcontractors will be responsible for costs related to fines and citations issued by regulating agencies and others caused by or related to Subcontractor's Work.
 

2. Pre-Mobilization Meeting

Prior to onsite mobilization, all subcontractors are required to develop and submit Unger's Pre-Mobilization Checklist. Pre-Mobilization Checklist available in the Project Manual, TAB 2A.

The checklist must be completed and submitted to Superintendent during the pre-mobilization meeting. The Subcontractor's foreman or team lead that will be performing the Work must attend the pre-mobilization meeting. Subcontractors will incorporate their respective work and the work of their respective tier-subcontractors' portion of the work. Each tier-subcontractor is expected to fill out a checklist. Crews will be allowed to start Work until the checklist has been reviewed and approved by Unger.

**Failure to submit the required checklist and accompanying data may result in the withholding of progress payments due to the Subcontractor and/or may delay the start of Work by Subcontractor.**

3. Staffing Requirements and Expectations

Subcontractor will provide an adequate number of first aid trained people to respond to emergency events. Unger will be notified of any changes in First Aid/CPR staffing during performance of the Work on the Project. Subcontractors will provide Unger with a site-specific emergency plan identifying CPR/First Aid staff, First Aid equipment, and the nearest medical clinic or hospital on the pre-mobilization form.
 

4. Orientation

Subcontractor's employees must attend a site specific safety orientation. Unger conducts a site specific orientation for all subcontractors, vendors and support personnel prior to granting access to the jobsite. This orientation communicates the Owner’s expectations as well as Unger’s expectations. The safety orientation is conducted by supervisory personnel in a face-to-face format to ensure that each worker fully understands site safety expectations. The orientation typically lasts about 45 minutes.

5. Safety Meetings

Subcontractor’s superintendent and/or foreman must be present at all Unger scheduled safety/coordination meetings and it is Subcontractor's superintendent's or foreman's responsibility to relay the information to other members of Subcontractor's crew. Each subcontractor must also conduct its own safety meetings as required by law. In addition, Subcontractor's personnel will attend Unger's weekly toolbox training meetings and coordination meetings if directed by the Unger's Superintendent. Subcontractors are to provide Unger’s Superintendent with a copy of Subcontractor's safety meeting reports

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Performance expectations are managed via 10–15 minute daily “all hands” safety coordination huddles comprised of all subcontractors on the jobsite. Unger believes the huddles build better team harmony, improve communications and productivity across trades, which leads to better safety performance overall.

6. Alcohol and Drug Free Project

The use of drugs and alcohol are strictly prohibited at the Project site. Unger reserves the right to require drug testing of Subcontractor’s employees before commencement of the Work onsite and after accidents unless otherwise prohibited by law or by collective bargaining agreement.
 

7. Insurance and Accident Report

All subcontractors are required to immediately notify Unger's Superintendent any accident or injury to Subcontractor's employees, tier-subcontractors, or suppliers, and will furnish Unger with a written report of the accident as well as copies of all accident reports not later than 24 hours following an accident. Written reports and/or accident reports must include information about any injury to Subcontractor's employees and/or accidents involving other people or property damage caused by Subcontractor's actions. Subcontractor employees, including site supervision, the designated safety person, the subcontractor’s safety manager, and the employee’s involved in the incident, will be required to meet with the Unger’s Superintendent immediately following an incident to discuss the root cause and the corrective measures to be taken to ensure that the incident does not reoccur. Subcontractors should have post-incident drug testing procedures.
 

In the event of media involvement, Subcontractors will cooperate with Unger and follow Unger's and Owner's direction in their crisis management efforts.
 

8. Safety Data Sheets (SDS)

Subcontractor will submit all SDS required by law before delivery of any hazardous materials or substances to the site. The SDS must contain all information required by Title 29 Code of Federal Regulations, Part 1910, as amended. All hazardous compounds must be clearly labeled as to content, with appropriate warnings noted, and name and address of the manufacturer listed. Subcontractor's employees using these compounds must be trained in protective handling and potential hazards before any hazardous compounds or materials included in the Work or that arrive on site. Subcontractor will inform Unger in writing of any precautionary measures to be taken to protect employees.

9. Signage and Barriers

Subcontractor will erect and maintain reasonable safeguards for safety and protection, including installing barricades and barriers, posting danger signs and other warnings against hazards, and promulgating safety regulations.

10. Project Safety Inspections and Audits

Subcontractors will conduct daily safety inspections of the Work areas and will cooperate with any regulatory agency consultation or compliance inspections including any inspections or audits performed by an insurance agency or consultant. Written safety audits or inspections must be done at least weekly and documented by Subcontractor. Documentation of safety audits must be available upon request to Unger. Subcontractor's will report any hazards found at the Project to Unger's Superintendent whether related to Subcontractor's Work or other work, and must immediately correct any Subcontractor unsafe conditions.

Subcontractors will be notified of any violations of safety regulations and safe practices while working on site. Failure to correct conditions within 24 hours places the offending Subcontractor in violation of its Subcontract. This may result in progress payments being withheld until the conditions noted are corrected and could result in termination of Subcontract. If the hazard is serious, Unger will stop Subcontractor's Work activities until the hazard is corrected at the Subcontractor’s expense. Any employee who refuses to comply with or has been repeatedly observed violating safety regulations will be removed from the Project site.

11. Enforcement / Disciplinary Procedures

Workers who do not comply with safe practices or who are in violation with the Project safety procedures are subject to the following disciplinary steps:

a. Verbal warning
b. Written warning
c. Suspension from the site for a period of not less than 3 business days
d. Worker asked to leave site permanently

If any employee demonstrates a willful or repeated violation of the safe policies and practices or the employee’s action willfully disregarded his or her safety or the safety of any workers, the offending worker will be asked to leave the site without a verbal or written warning. It is the Subcontractor’s responsibility to replace any worker removed from the Project site with another comparable worker and without delay in Project Schedule.

12. JHA and Pre-Task Planning

All subcontractors are required to furnish to Unger a Job Hazard Analysis (JHA), safe work plan or pre-task plan prior to commencement of work on site. Subcontractor's JHA must cover general and specific Work activities, and all related hazards, and actions to be taken to eliminate the hazards. Subcontractor must submit the JHA to Unger for approval before commencement of the Work on-site. Subcontractor will go over the JHA with its on-site workers as part of Subcontractor's training. During performance of the Work, Subcontractors may be required to submit additional JHAs to Unger for Work activities or related hazards not covered by the original JHA . Subcontractor will perform and document pre-task planning to identify any hazards related to its Work. The JHA must be available at the Project site for inspection by Unger at any time.

13. Proof of Training

A number of tasks have formal training requirements or certifications required by regulatory agencies. For example powered industrial equipment (forklifts, boomlifts, scissorlifts) heat illness prevention, powder actuated tools, scaffold and fall protection to name a few. Before Subcontractor can start Work at the Project site, proof of training must be submitted to the Unger's superintendent for all employees that will be working on the jobsite. Failure to provide proof of training is not justification for a delay in the Project Schedule.

14. Dress Code

All Subcontractors’ employees must be dressed in appropriate clothing when entering the jobsite including long pants, work boots, and shirts with sleeves.

15. Music Players

The use of portable audio, video players “open air” and personal music systems such as; iPods, MP3, CD players, cell phones, headsets, earphones and related equipment that may interfere with verbal instructions, audible alarms, emergency warnings, or construction sounds, are strictly prohibited.

16. Personal Protective Equipment

Safety glasses, hard hats and work boots are required 100% of the time while working within the designated construction area. High visibility top colors (vest, shirt, jacket) are required when powered industrial equipment such as scissors lifts, forklifts, boom lifts, backhoes, concrete trucks, concrete pumps, delivery trucks, cranes, or earth moving equipment. In other words, most construction sites will require a high visibility top color. Other safety equipment such as gloves or safety goggles may be required depending on the activity. Subcontractors are responsible for providing necessary PPE for their employees and all tier-subcontractor employees.

17. Silica Dust

The following is a list of requirements for subcontractors that work with materials that contain silica.

a. Silica Dust Hazard Communication – Health hazards associated with respirable silica, Subcontractor’s to provide specific tasks that could result in exposure, specific measures implemented to protect subcontractor employees, purpose and description of medical surveillance.

1) Proof that all Subcontractor employees that work with – or – around materials that contain silica have been given silica dust specific hazard communication/training.

b. Silica Dust Site Specific Silica Dust Exposure Control Plan for all tasks that expose Subcontractor's workers to respirable silica dust.

1) Subcontractors written policy – safe work practices
2) Subcontractors Training – policies/procedures, safe work plans
3) Competent person – capable of identifying silica hazards, has the authority to correct hazards, frequent/regular inspections
4) Medical surveillance – for employees that wear a respiratory 30 or more times per year
5) Housekeeping
6) Record Keeping

c. Silica Dust safe Work Plan

1) 1926.1153 Table 1
2) Air monitoring data (below the action level, above the action level but below the permissible exposure level, above the permissible exposure level)
3) Engineering controls (local exhaust ventilation, wet methods, containment/isolation to protect those working nearby)

d. Administrative controls (barriers to prevent unauthorized workers from entering the area, worker rotation, scheduling/time limits)

1) Personal protective equipment (respirators)

e. Respiratory Protection

1) Annual Medical Evaluation
2) Annual fit testing
3) Respiratory training (usage, limitations, maintenance, storage)
 

18. Stop Work Cards

Unger expects excellence in its safety programs, the quality of materials/workmanship and its business practices. Every employee and Subcontractor must adhere to the highest quality standards as well as Unger’s safety policies. Unger’s senior management team empowers each and every Subcontractor and employee to stop unsafe acts, to correct conditions that appear to be unsafe, and to stop poor quality or substandard workmanship.

Employees and Subcontractors can promptly stop any activity that violates Unger's quality expectations, safety policies or business practices by presenting a stop work card. When a stop work card is presented, work must stop immediately. Work cannot restart until a better, safer way of performing the work can be developed or it is determined that the current practice is appropriate.

If something does not:

a. Look right
b. Sound right
c. Seem right
d. Feel right
e. Smell right

Present the stop work card. Discuss the situation. A copy of the card can be obtained by asking Unger's superintendent. A physical copy of the card is not needed in order to stop the work and discuss the situation.

 19. COVID 19 Procedures and Reporting Requirements

a. COVID 19 regulations (OSHA) and Best Practices (CDC, Local Government, Public Health) change frequently and are not uniform for all of our project locations.  Each Unger Construction project has a Site Specific COVID Safety Plan that includes roles responsibilities for everyone working on that project. Each project will be updated as necessary.

b. The Unger Construction Project Superintendent is designated as the default project site specific COVID-19 Safety Compliance Officer, unless otherwise directed by Unger in the site specific plan.

c. Everyone is required to wear a face mask covering their nose and mouth.

d. Unger Construction will prescreen individuals entering the site daily to ensure the safety of all.  Jobsite screening by Unger Construction and subcontractors shall be conducted and recorded prior to workers beginning work within the designated project site. The following questions are typical, some sites may vary:

1) Are you experiencing symptoms of COVID 19 (cough, fever, chills, shortness of breath, difficulty breathing, chills, muscle pain, headache, sore throat, recent loss of taste or smell, loss of appetite, diarrhea)?

2) Are you taking any over the counter or prescription medications to reduce or control fever?

3) Have you been in close contact with anyone who has been diagnosed with COVID 19?

4) Have you been in close contact with anyone who is experiencing symptoms of COVID 19?

5) If a worker answers ‘yes’ to any of the above questions, access to the site will be denied. The worker will be told to leave the jobsite immediately, contact their supervisor and self-quarantine. The supervisor of the ill worker shall follow the site specific protocol for reporting an ill worker.

e. Workers must notify their supervisors immediately if they begin feeling ill during the day or if someone in their household is sick. If there is a suspected or confirmed case of COVID-19 involving a worker(s) that was on the jobsite:

1) If a worker is symptomatic with a fever and other symptoms prior to confirmation of COVID-19, this could be considered an exposure to other workers and they must be sent home.

2) Should any workers develop a fever and other symptoms they should be referred for medical care.

3) When Unger Construction is made aware of a worker that tests positive for COVID-19 by a medical provider, Unger Construction will notify the Project Owner’s Representative.

4) If exposure has occurred the company for which the ill worker is employed shall clean and disinfect commonly touched surfaced in the work area. In some instances Unger Construction may quarantine the impacted work are for 72-hours.

f. Social distancing, specifically separation of 6 feet, will be implemented where practical. This practice is difficult to achieve and will require coordination and patience between workers.

1) Workers should maintain social distancing (arm’s length between workers) to the best of their ability. Speak with your supervisor if you are not able to safely perform your job function while maintaining social distancing.

2) If a worker is not able to comply with 6’ of separation they must notify Unger Construction so the project team can engage in scheduling and re-sequencing the project to allow these distances between all trades.

3) Distancing guidelines will be discussed each day as part of daily huddles and pre-task plan sessions.

4) Foremen & leads should be especially observant to social distancing and make adjustments as needed.

5) Lunch/breaks shall be conducted in a manner and location that will enable proper social distancing.

6) With respect to elevators workers shall maintain 6 foot spacing which will dramatically affect the capacity of the elevator. This means that materials and tools will be transported by the elevator, workers will take the stairs.

7) Meetings shall be conducted in a manner and location that will enable proper social distancing. Generally speaking all gatherings and meetings (i.e. breaks, stretch & flex, plan reviews, safety meetings, PTP, etc.) must be limited to groups of 10 or less and with a distance of 6’ minimum.

g. Break and eating areas will be cleaned and disinfected after use, including shared surfaces or scheduled in a manner that allows these guidelines to be followed:

1) Minimum 6’ distancing applies to lines for food trucks.

2) Food served or on display must be wrapped to protect from contamination.

3) Food trucks will not allow the use of shared condiments and will comply with all applicable health codes.

4) Unger Construction has the discretion to discontinue the use of food trucks, if necessary.

5) The use of communal water jugs and ice will be discontinued.

h. All subcontractors should consider modifying means and methods to mitigate germ transmission via tools (chop saws, skill saws, etc.) Examples of mitigation include:

1) Single person assigned to a chop say or workstations that they clean and disinfect prior to use.

2) Assign individual tool and work areas per the Site Specific COVID-19 Safety Plan.

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20. Site Cleaning and Disinfecting Requirements

a. Unger Construction will be implementing cleaning/disinfecting protocols. Cleaning is the removal of dirt, impurities, and some germs. Cleaning does not kill germs it decreases their number reducing the risk of spreading infection. Disinfection is killing germs on the surface. Disinfection does not necessarily clean dirty surfaces.

b. Due to the limited availability of disinfection products common household cleaning products (all-purpose cleaners similar to Pine sol, 409, Windex, Simple Green etc.) will be utilized when they are available. As a default position cleaning/disinfection shall be performed with detergent/soap and water.

c. Follow the manufacturer’s instructions for all cleaning and disinfection products. Labels will contain instructions for safe precautions you should take when applying the product (such as wearing gloves and making sure you have good ventilation) and effective use of the product (concentration, application method and contact time).

d. Cleaning/disinfecting products are not designed for all surfaces or materials. Follow the manufactures recommendations. For example, soft (porous) surfaces such as upholstery, carpeted floor and rugs, should be cleaned/disinfected with methods that are appropriate these surfaces.

e. Products and personal protective equipment used for cleaning/disinfecting shall be provided by the company that is responsible for their scope of work.

1) Paper products used for cleaning/disinfecting shall be bagged, sealed and discarded into jobsite trash cans after use.

2) Cloth products used for cleaning/disinfecting shall be bagged, sealed and stored after use. Bags should not be reopened until they reach the laundry facility.

3) Single use gloves shall be discarded as paper products listed above. Multiple use gloves shall be cleaned after use and stored per the manufacturer’s instructions.

f. Unger Construction will clean and disinfect their following items regularly (at least twice per shift, for example ~10 AM and ~ 2 PM).

1) Common areas such as conference rooms (tables, chairs, doors, light switches), copy/fax machines, microwaves, coffee machines, lunch/break areas, handrails, doors, elevators and restroom doors.

2) Toolboxes, tools, transportation carts, battery charging stations, and communication radios used by workers of Unger Construction.

3) Heavy Equipment (Forklifts, Scissor Lifts, Boom Lifts, etc.) Prior to and after use, wipe down controls, seats, handrails or other frequently touched surfaces.

4) Areas, tools and materials where a sick Unger Construction worker previously worked.

g. Subcontractors and their subcontractors/suppliers are to clean and disinfect the following items used by their workers regularly (at least twice per shift, for example ~10 AM and ~ 2 PM).

1) Toolboxes, tools, transportation carts, battery charging stations, and communication radios.

2) Workstations (desks, chairs, tables), plan tables, lunch/break areas.

3) Heavy Equipment (Forklifts, Scissor Lifts, Boom Lifts, etc.) Prior to and after use, wipe down controls, seats, handrails or other frequently touched surfaces.

4) Areas, tools and materials where a sick worker previously worked.

5) Workers that perform cleaning/disinfection functions shall wash their hands directly after completing this task.

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