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SMG 07-007 Independent Third-Party Contractor Site Safety Program (CSSP)
SMG 07-007 Independent Third-Party Contractor Site Safety Program (CSSP)
Table of Contents
1. Purpose .................................................................................................................. 2
2. Scope ................................................................................................................... ..2
3. Definitions............................................................................................................. ..2
4. Introduction........................................................................................................... ..3
5. Responsibilities..................................................................................................... ..3
6. Requirements ....................................................................................................... ..5
Supplements
Supplement 1: Safety Review Methodology .................................................................... 8
Supplement 2: Contractor Site Safety Program (CSSP) ................................................ 15
Supplement 3: Independent Third Party CSSP Review Flowchart ................................. 17
CONDITIONS OF USE
This information is not to be modified from its current form and may not be offered for
resale or other commercial purposes without the express written permission of Saudi
Aramco.
Retention of this material shall constitute acceptance on the part of any third-party to the
Conditions of Use stated herein.
2. SCOPE
For long form capital construction contracts where Saudi Aramco (SA) Project
Management is the proponent or as otherwise requested in writing by the Saudi Aramco
Proponent Organization (SAPO), the contractor shall have safety audits performed by an
independent third party.
This guide provides direction on selecting a third party auditor and the methodology to be
followed when performing a safety review of the CSSP.
This guide does not replace the SAPO’s contractor performance monitoring process to
properly monitor and evaluate the safety performance of their contractors at the job site
(see LPD Safety Management Guide 07-002-2010).
3. DEFINITIONS
3.2 Contractor Site Safety Program (CSSP): A job-specific contractor site safety
program that shall state specifically how the contractor will meet SA’s safety
requirements for the work to be performed. The CSSP shall include all items
provided in the SA Contractor Safety Administrative Requirements (CSAR),
Section 5.3, as applicable to the contract and work to be performed. (See
Supplement 2).
3.5 Third Party Safety Review: Systematic, independent and documented process to
obtain records, statements of fact or other information and evaluating it objectively
to determine the extent to which the policies, procedures or requirements of the
contractor’s safety program are fulfilled. Third-party audits are conducted by
external, independent auditing organizations with no interest in the contractor
company, are free from bias and conflict of interest.
4. INTRODUCTION
As required by the CSAR, contractors shall properly plan and establish job-specific, safe
work procedures for all contracted work. For long form capital project construction
contracts where SA Project Management is the proponent or as otherwise requested in
writing by SA, the contractor shall develop, implement and adhere to a job-specific
contractor site safety program (CSSP) that conforms to the requirement of the contract,
the CSAR and Work Site Safety Manual (WSSM) of the SA Construction Safety Manual
(CSM), and all other applicable SA safety requirements.
A safety and health requirement of the company’s Schedule ‘D’ attachment to long form
capital contracts is for the contractor to have safety reviews performed by an independent
third party six (6) months after starting work, and at least every nine (9) months
thereafter. The safety reviews are performed to verify proper implementation of the CSSP
and make recommendations to improve the contractor’s safety programs and execution.
The independent third party used in these reviews shall be approved in advance in writing
by the company representative, who shall be given copies of all audit reports.
Safety reviews shall follow the methodology established in this guide, see Section 6 and
Supplement 1.
5. RESPONSIBILITIES
5.3.4 Provide all documentation and records requested by the auditor to verify
execution of the contractor’s programs.
5.3.5 Immediately take all necessary actions to comply with the requirements of
the CSSP and improve safety programs or their implementation upon
receiving notification from the third party auditor or SA Company
Representative.
5.3.6 Establish an action plan with estimated time to completion dates (i.e.,
ETCs) to address recommendations provided by the safety review. The
action plan shall be submitted to the SA Company Representative.
5.3.7 Provide the findings from previous third party safety reviews and status of
findings and recommendations resulting from the previous safety review
report to third party audit companies selected for subsequent safety
reviews.
6. REQUIREMENTS
6.1 General Requirements
6.1.1 Third party auditors selected by contractors shall meet the principles and
requirements for competence, consistency and impartiality for reviewing
management systems per ISO/IEC 17021:2011. Third party auditors
selected by contractors shall be certified by an accredited certification
Supplement 1
Part I:
The independent third party auditor should include the items provided in this Supplement when
conducting safety reviews of a contractor’s site safety program (CSSP) per the scope of this
Safety Management Guide (SMG). The independent third party safety review, referred to as the
“Safety Review,” should be based on documented objectives, scope and criteria. Any changes to
the objectives, scope or criteria should be agreed to by the contractor and independent third party
auditor.
2. Safety Review Objectives. The objectives are defined by this management guide. The
objectives should define what is to be achieved and include the following:
2.1 Evaluate of the capability of the CSSP to meet Saudi Aramco Construction Safety
Manual (CSM) and Schedule ‘D’ contractual requirements.
2.2 Independently assess the contractor’s compliance with and implementation of the
CSSP in accordance with the Contractor Safety Administrative Requirements
(CSAR) per CSM, Volume 1.
2.3 Evaluate the effectiveness of the CSSP in meeting its specified objectives.
2.4 Identify the parts of the CSSP and related contractor safety programs that are
working well and those requiring improvement.
2.5 Assess contractor management and employee commitment to and participation in
the contractor’s safety programs.
2.6 Develop recommendations for CSSP improvements, including identifying areas
that can guide the contractor to meet expectations of the CSAR and CSM.
2.7 Provide a mechanism for supporting continuous improvement of the contractor’s
CSSP.
3. Sources of Information. Section 6.3.2 of this guide identifies the inputs to the safety
review that should be considered. Sources of information should include:
3.1 Documents such as the contractor’s CSSP, plans, procedures, safety programs and
processes, contracts and work orders.
3.2 Interviews with contractor employees and management staff.
3.2 Observations of activities and the work environment/conditions, including project
sites, laydown yards and fabrication yards/shops.
3.3 Records, such as inspection findings, minutes of meetings, internal safety review
reports, records of monitoring programs, etc.
3.5 Data summaries, analyses and performance indicators.
3.6 Reports from other sources, such as employee feedback/surveys, suggestion
programs, relevant information from external assessments and ratings.
3.7 Computerized databases and web sites, if necessary.
4. Documentation Review. The selection of documents for review should be based on their
relative importance to the overall safety performance of the contractor. Each of the
selected documents should be reviewed with the objective of determining adequacy and
completeness in terms of their compliance with the contractor’s CSSP, the Saudi Aramco
CSAR, CSM and relevant company standards and procedures (e.g., Engineering
Procedures [SAEPs], General Instructions [GIs], and Saudi Aramco Sanitary Code
[SASC]).
6. Observations of Activities. Selected job sites and project support facilities (e.g.,
laydown yards, fabrication yards) should be visited to ascertain the degree of compliance
with the contractor’s CSSP and applicable SA safety and health requirements. Areas of
major importance considered in these inspections include life safety, fire prevention, fire
protection, accident prevention, risk management, and emergency preparedness.
Supplement 1
Part II:
The safety review criteria should be used as a reference against which conformity of the
contractor’s CSSP is determined. The contractor’s CSSP (see Supplement 2) shall state
specifically how the contractor will meet Saudi Aramco’s safety requirements for the work to be
performed as specified in Saudi Aramco Construction Safety Manual, Volume 1, Contractor
Safety Administrative Requirements (CSAR).
Saudi Aramco (SA) safety and health requirements applicable to the contract scope of work may
include, engineering procedures (SAEPs), General Instructions (GIs), SA Construction Safety
Manual (CSM), SA Safety Handbook, and Schedule ‘D’ requirements. The safety review criteria
should include, but not be limited to the applicable topics in Table S1-1.
Hazardous materials inventories, storage and hazards communication. CSM Vol. 2, Ch. I-10
Excavations.
• Excavation plans.
CSM Vol. 2, Ch. II-1
• Pre-excavation checklist and routine inspections.
• Thrust boring operations.
Scaffolding.
• Scaffold plans and approvals.
CSM Vol. 2, Ch. II-2
• Authorized manufacturers and materials.
• Inspections.
Overhead powerline and utility excavation planning and authorization. CSM Vol. 2, Ch. III-3
Pressure testing.
CSM Vol. 2, Ch. III-4
• Approved pressure test packages and procedures.
Non-destructive testing (NDT).
• SAG issued Radiation Practice License(s).
• SA approval of radiographic techniques.
CSM Vol. 2, Ch. III-6
• Radiographic film interpretation certification.
• Temporary radioactive source storage pit permits, source utilization
and tracking log.
Cranes, lifting equipment and rigging.
• Crane/lifting equipment inspections.
CSM Vol. 2, Ch. III-7 &
• Certification of riggers.
Ch. III-8
• Inspection of slings and rigging hardware.
• Critical lift plans.
Supplement 2
Contractor shall properly plan and establish job-specific safe work procedures for all contracted
work. For long form capital construction contracts where SA Project Management is the
proponent or as requested in writing by the SAPO, the contractor shall develop, implement and
adhere to a job-specific Contractor Site Safety Program (CSSP).
The CSSP shall state specifically how the contractor will meet SA’s safety requirements for the
work to be performed.
1. Contents of CSSP
3.1 Title page, specifying budget item (BI), job order (JO) or contract number.
3.2 Job title and brief scope of work.
3.3 Site location map(s) with legend (symbols).
3.4 Contractor company’s current safety policy (signed by their upper management).
3.5 Job-specific organization chart that clearly defines safety reporting relationships.
3.6 Names and qualifications (e.g., CV/resume) of safety manager/supervisor(s) and
safety officers, as required.
3.7 Job-specific assignment of safety responsibilities by job classification.
3.8 Job-specific training needs analysis (e.g., training matrix) showing the safety
training and job-skills/competency training required for all job classifications, as
applicable to the project’s scope of work.
3.9 Written safety training program that includes:
a) A description of the basic safety training courses (e.g., first aid, fire safety,
hazard recognition, confined space entry, H2S safety, and driving safety)
provided to contractor company’s employees.
b) How these safety training courses are delivered (e.g., in-house and/or third
party).
c) Which of these courses are required for each type of job (e.g., documented in a
safety training matrix or safety training plan).
3.10 Written job skills/competency training program that includes:
a) A description of the specific job skills/craft training courses required for each
type of job (e.g., HVAC technician, plumber, pipefitter, or welder) that is
specific for their work in SA.
b) How these job skills/craft training courses are delivered (e.g., in-house and/or
third party).
c) Refresher training frequency.
3.11 List of jobs to be performed that require SA-approved certification (e.g., scaffold
supervisor/inspector, crane/heavy equipment operator, rigger, or welder).
3.12 Complete list of known subcontractors.
3.13 Project-specific plan/program the contractor will use for managing their
subcontractors, including their safety performance.
3.14 Procedures to behavioral observations, site safety inspections, safety meetings,
incident/injury/near miss reporting and investigation, safety training, safety
recommendations tracking, etc.
3.15 Description of the contractor’s site safety incentive and/or disciplinary action
programs.
3.16 Hazard identification plan (HIP) per CSAR, Section 6.0.
3.17 Waste management plan per CSAR, Section 10.0.
3.18 Hazardous substances plan, which describes the contractor’s procedures for
identifying and handling hazardous chemicals, materials, etc. Hazardous
chemicals/materials shall be stored and handled accordance with the manufacturer’s
material safety data sheets (MSDSs).
3.19 Job-specific and/or location specific safety procedures that are applicable to the
contract’s scope of work. These procedures may include but are not limited to: work
permits, confined space entry, personal protective equipment, respiratory protection,
fall protection, isolation and lockout, waste management, site
demobilization/restoration, emergency response, etc.
3. Subcontractors
3.1 The contractor shall verify that the safety procedures and safe work practices
identified in each subcontractor’s site safety program are adequate and satisfy SA’s
minimum expectations and requirements.
3.2 In the event that any subcontractor’s safety procedure or safe work practice does not
meet the minimum expectation, contractor shall work closely with subcontractor to
develop/upgrade the appropriate safety procedure or safe work practice.
Supplement 3
Independent Third Party CSSP Review Flowchart
Contractor
Action items
establishes action Action plan submitted
addressed by
plan to address to SAPO
contractor
findings
Evaluate previous
SAPO verifies key
audit findings and
findings closed
recommendations Subsequent third party
safety reviews
conducted every 9
months
Records of safety
Action items from review results
subsequent safety retained by SAPO
reviews addressed
by contractor