Dear Sudhir,
You’re not addressed lot of points on your Sub-contractors EHS Manual. Please see the below points you must to include this on your plan.
Its only few points mentioned below you can add GENERAL(PPE, Minimum dress requirements etc.,), EMPLOYEE ORIENTATION AND TRAINING, REPORTS AND SUBMITTALS, FIRST AID AND EMERGENCY MEDICAL CARE (Its should be clearly addressed by CONTRACTOR) etc.,,
SUBCONTRACTOR and its lower tier subcontractors are responsible for the development, implementation, administration, and enforcement of their individual safety and health programs, regardless of any safety or first aid personnel the CONTRACTOR may have assigned as oversight to the project site or facility.
SUBCONTRACTOR shall be required to designate a qualified Safety Representative that has the authority and support of his/her management to conduct and coordinate SUBCONTRACTOR and its lower tier subcontractors' safety and health program and/or policies. The duties and responsibilities of the Safety Representative shall be specified in the site specific Safety and Health Plan. The Safety Representative shall be granted “stop work” authority, along with the responsibility and organizational freedom necessary to implement and enforce SUBCONTRACTOR safety and health program.
TRANSPORTATION AND ENVIRONMENTAL COMPLIANCE
If activities of the SUBCONTRACTOR involve transportation or shipping of Hazardous Materials (as defined by the Department of Transportation) or if the work requires Environmental Controls or potential for spills and/or releases, a designated person will be available to provide necessary compliance support. In the event of a transportation incident or environmental release, the designated person will provide necessary coordination of response activities for SUBCONTRACTOR. This person will also provide necessary notification of insurance carriers and HAZMAT response for any SUBCONTRACTOR incidents.
SAFETY MEETINGS
The SUBCONTRACTOR safety representative will attend a weekly meeting with the CONTRACTOR safety representative. The purpose of this meeting will be to discuss safety related matters such as safety concerns, corrective actions, accident prevention, and new procedures and policies.
SUBCONTRACTOR will conduct regularly scheduled safety meetings with its employees and/or supervision as necessary to ensure safety is adequately addressed in its work planning and execution. SUBCONTRACTOR will provide written notice of the time, place, and subject of these meetings and provide CONTRACTOR the opportunity to observe. CONTRACTOR reserves the right to require changes necessary to comply with safety rules and regulations.
INSPECTIONS
A.SUBCONTRACTOR is responsible for conducting daily and documented weekly jobsite inspections for unsafe conditions and work practices.
B.SUBCONTRACTOR shall prohibit the use of unsafe machinery, tools, materials, or equipment and shall conduct pre job and as required inspections on it in accordance with manufacturer’s recommendations and appropriate regulations. All heavy equipment shall have a documented safety inspection prior to being used on the project. All equipment, tools, and appliances shall be used according to manufacturer specifications. Modifications or alternative uses must be approved by the manufacturer prior to planned use.
C.SUBCONTRACTOR will immediately notify CONTRACTOR of any and all OSHA inspections and shall afford CONTRACTOR the opportunity to observe the inspection. SUBCONTRACTOR will provide CONTRACTOR a copy of all citations received and all SUBCONTRACTOR responses issued as a result of such inspections within two working days of receipt or issuance.
D.CONTRACTOR will perform periodic safety inspections of SUBCONTRACTOR work. SUBCONTRACTOR safety representative will accompany CONTRACTOR safety supervisor during these inspections and take prompt action to correct all identified deficiencies. SUBCONTRACTOR management will participate in a scheduled safety walk through with CONTRACTOR management. Such inspections and identification of deficiencies by CONTRACTOR does not relieve SUBCONTRACTOR from its responsibility to comply with all applicable safety regulations and rules.
Hope Information helps.
Thanks & Keep on touch. . .