If there is an accident involving a subcontractor on a Hogan project, the site Superintendent or site Foreman is responsible to complete the “Subcontractor Accident Investigation” form (found in Procore in “Forms”).
In addition, contact Jared Morgan at 801-910-7011 immediately. He will decide if it is necessary to report the incident to OSHA. In Utah, employers are required to notify UOSH within 8 hours of occurrence of any fatality; disabling, significant, or serious injuries; or illnesses to workers. For Idaho and Wyoming, employers are required to notify OSHA within 8 hours for any fatalities, and 24 hours for inpatient hospitalizations, amputations, or losses of an eye.
Tools, equipment, materials, or other evidence that might pertain to the cause of such accidents shall not be removed or destroyed until authorized by osha. You are also required to investigate all incidents of worker injuries and occupational illnesses.
Jared Morgan, Hogan’s VP over safety will be responsible to contact OSHA.
If a subcontractor is injured on a Hogan project, Hogan’s VP of Safety will be responsible to contact OSHA if it meets this definition:
“Employers are required to notify the respective OSHA state office within eight hours of occurrence of any fatality, or within 24 hours of any inpatient hospitalizations, amputations, or losses of an eye.”
All personnel using aerial lifts must be trained and tied off as required by OSHA.
The following applies to all subcontractors on the jobsite. If subcontractor employees don’t comply, they may be sent home.
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For work inside the building of a Hogan project, when there isn’t any overhead work, ceiling grids are in, and the finishes are going in, the hard hat requirement may be lifted. Even though the hard hat requirement may be lifted at this stage of the project, subcontractors are still required to wear high-viz shirts or vests, safety glasses, work gloves, long pants, and a quality pair of boots. Our subcontractors will coordinate with the project Superintendent when the hard hat requirement may be lifted.
A competent person is defined as a person who has the ability and has been adequately trained to recognize hazards and has the authority to correct them or to stop work until they are corrected. Each subcontractor will have the responsibility to select, train, and authorize competent persons appropriate for their scope of work as required by OSHA. This includes but is not limited to trenching and excavations, scaffolding, steel erection, fall protection, roof fall protection, etc.
A loud horn is stored in each Hogan job office near the posted emergency information. In the event of an emergency where evacuation is necessary, the Superintendent or designated worker will sound the horn in sets of three until the project is completely evacuated. When the horn is sounded the subcontractor’s supervisor or foreman in charge will be responsible to account for all his or her company’s employees, and to report their status to the Hogan Superintendent.
All subcontractors are responsible to inform their employees of the emergency horn, and to train their employees on evacuation and other emergency plans.
All subcontractors are responsible to have an OSHA-compliant HazCom program for themselves and any subcontractors under them. HazCom should be discussed at the preconstruction meeting(s), and each week during the safety and coordination meeting with the site superintendent (see “Safety Meetings” below).
Continual housekeeping on the site is a process that must be maintained by everyone. Each subcontractor is responsible for the removal of debris and excess materials that result from their work. Those who do not clean up their debris may be charged the cost of having it cleaned up for them.
One of the most dangerous hazards on a construction site is also unsurprisingly one of the most common violations. It occurs when workers stand on the top or second-to-the-top rungs of an A-frame ladder. DO NOT make this dangerous mistake! OSHA requires, all employees who use ladders to be properly trained with documentation available upon request. This training is available on Hogan University.
Due to the high risk of falls, Hogan requires site-specific safety plans from all:
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Your safety plan is required when you turn in the "Subcontractor's Safety Form".
In order to maintain a safety culture where all operations are conducted as safely and efficiently as possible, we have each subcontractor sign a Subcontractor Safety Contract wherein Hogan assigns the responsibility, authority, and accountability for all safety-related issues to the management and supervisory personnel of each subcontractor within their individual area of operation. The Subcontract Agreement places responsibility upon subcontractors to insure their sub-subcontractors and their individual employees perform their work in a safe manner and according to Hogan and OSHA policies.
As provided in the Agreement, payment may be withheld from the subcontractor, subcontractor employees may be expelled from the site, or other discipline may be assessed for safety noncompliance.
Payment will not be released until all pages of the Subcontractor Safety Contract are filled out, sent to Hogan, and approved. Due to the high liability, past incidents, and past OSHA citations involving these Masons, Steel Erectors, and Roofing subcontractors, the Subcontractor Safety Contract requires site-specific safety plans from them.
Our Project Assistants store the Safety Subcontracts in Procore where the jobsite Superintendent and jobsite Foreman can access them if needed. To find them, do the following in Procore.
While they are on the project working the job, all subcontractors are required to attend a weekly safety meeting with the Hogan superintendent and the other subcontractors on the project. The first agenda item should be safety. Use this meeting to coordinate, plan for, and communicate safety issues on the project. In addition to the weekly meeting with Hogan, each subcontractor is responsible to hold weekly safety meetings with their own crews to pass on information from Hogan as well as address trade-specific safety.
The template used for the weekly subcontractor safety meeting is found in Procore under “Forms” and in the Forms section of this book.
Each subcontractor is required to have a formal safety program in place and available for review upon request. At a minimum, this safety program should meet and enforce all OSHA standards.
Each subcontractor should know when safety training is required for the activities of their employees and subcontractors under them. Each subcontractor is responsible to provide the training and to keep appropriate documentation available for review.
Subcontractors must take appropriate measures to control the dust from mason block cutting, concrete grinding, or wherever a silica dust hazard exists, so their employees and others are not exposed.
In the event a sub-contractor is found not following safety rules, the Superintendent may issue the “Sub-contractor OSHA Violation Warning”. If the problem continues, proper authorities should be notified so proper corrective action is taken. Superintendents should record dates and names and details of all verbal and written warnings.
The “OSHA Violation Subcontractor” form is in the “Forms” section of this Handbook as well as in Procore in “Forms”.
Drug or alcohol abuse is not tolerated. Subcontractors will be responsible for the investigation, testing, and if necessary, the discipline of their employees who are suspected of drug or alcohol abuse, possession of, or under its influence while on project grounds. If a subcontractor supervisor cannot be found, Hogan superintendents have the authority to dismiss workers from the site.
Subcontractors will not be allowed to start work on site until proof of worker’s compensation and general liability insurance has been submitted and approved by Hogan.
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