Contractor Management Manual 2012 - BP€¦ · Web viewContractor Management Policy P olicy No.:...

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USPL Contractor Management Policy Document Number: USPL-HSSE-F-14-MAN-001 Document Location: Document and Records Management Document Custodian: Contractor Management Coordinator Renewal Date: 03/28/2024 Revisio n No. Reason for revision Sections / Documents revised Author Date 1.0 S&O, Exemplar, LT Entire document re- written, additions highlighted Cross- functional CI team 12/1/201 2 2.0 Self-Assurance, OMS conformance & User comments Numerous areas throughout the entire document; all highlighted Contractor Management Coordinator 8/31/201 5 3.0 Grading criteria modifications, Establishment of contractor management operations network and contractor onboarding tool; Remove process safety management (PSM) references Numerous areas throughout the entire document Contractor Management Coordinator 03/28/20 19

Transcript of Contractor Management Manual 2012 - BP€¦ · Web viewContractor Management Policy P olicy No.:...

Page 1: Contractor Management Manual 2012 - BP€¦ · Web viewContractor Management Policy P olicy No.: USPL-HSSE-F-14-MAN-001 Revision Date: April 16, 2018 Effective Date: Ju ly 1, 2018

USPL Contractor Management Policy

Document Number: USPL-HSSE-F-14-MAN-001

Document Location: Document and Records ManagementDocument Custodian: Contractor Management Coordinator

Renewal Date: 03/28/2024

Revision No.

Reason for revision Sections / Documents revised

Author Date

1.0 S&O, Exemplar, LT Entire document re-written, additions highlighted

Cross-functional CI

team

12/1/2012

2.0 Self-Assurance, OMS conformance & User comments

Numerous areas throughout the entire document; all highlighted

Contractor Management Coordinator

8/31/2015

3.0 Grading criteria modifications, Establishment of contractor management operations network and contractor onboarding tool; Remove process safety management (PSM) references

Numerous areas throughout the entire document

Contractor Management Coordinator

03/28/2019

Document Approvers Role Signature Title Date

Raymond Wood Approver eMOC #1711 HSSE Manager

John Diendorf Approver eMOC #1711 Site Procurement Manager

Juan Ortega Authorizer eMOC #1711 USPL Head of Operations and HSSE

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USPL

USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Contractor Management PolicyUS Pipeline & Logistics (USPL) shall work with qualified contractors who have demonstrated a high level of commitment and performance with regards to HSSE. Contractors are expected to perform their work consistent with the agreed to terms and conditions of their contract and, if applicable, their Master Service Agreement. Contractors shall be in conformance with all applicable federal, state, and local health, safety, and environmental laws and regulations and with USPL policies and procedures. Contractors shall employ competent people and establish and follow safe work plans, practices, and permit systems.

This document is intended to provide guidance to help implement OMS Group Essential 2.5 – Working with Contractors.

1.0 Purpose and ScopeThe purpose of this policy is to set forth a formal approach in the selection and retention of contractors associated with the following activities that are managed and coordinated by BP USPL; construction, maintenance, demolition, remediation, operations, manual labor and other similar work activities.

This policy only applies to those working under an Authorization to Work.

This policy does not apply to contractors with little or no field exposure, to uniquely qualified contractors such as Asset Operator Designees, or to contractors who will be accompanied at all times by a USPL employee.

Information regarding Operator Qualifications for personnel performing covered tasks on DOT-regulated facilities can be found on the OQ Home Page and includes, but is not limited to, the following: OQ Plan, OQ Overview for All Affected Personnel, OQ Compliance Flow Chart, and ISNetworld training.

https://uspl.app.bpglobal.com/HR/Learning/OperatorQualification/tabid/835/Default.aspx

Use the chart below for examples of workers to whom this policy applies. If you are unsure if this policy applies to a contractor, contact the Contractor Management Coordinator, a Safety Coordinator or any a member of the HSSE team.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Applicable Not Applicable Construction workers Office-based consultants (i.e. Kelly Services,

administrative office support)

Maintenance workers Individuals performing a site survey, including land/engineering surveys, or pre-bid job site walk arounds

HVAC workers, if working at heights or in confined space

SCADA programmers; satellite system programmers

Vacuum Truck operators Offsite valve, pump, motor rebuilders

Abrasive Blasting workers Third party carriers

Drillers Material suppliers and their technical advisors for installations

Crane Operators FedEx, water or other delivery services

Asset painters (tanks, pipes, valves)

Janitorial services

Any work requiring an Authorization to Work form

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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**NNNOTE: This is not an all-inclusive list.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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2.0 Minimum Requirements

Requirements Supporting Documentation

1. Only Contractors meeting the Contractor Selection Requirements (CSR) as defined in this policy shall be used.

Section 5.1

2. Contractors who do not meet the CSR shall be identified as Do Not Use in the electronic Purchase to Pay tool and shall not be awarded new work without the evaluation and approval from the Contractor Management Operations Network (CMON).

Section 6.1

3. Any contractor who does not meet the CSR during the course of performing awarded work shall be reviewed by the CMON to determine if the contractor’s status should be changed, the contractor should stop work on the USPL job site, and/or any other necessary action should be taken.

Section 6.1

4. Contractor employees who perform DOT Covered Tasks shall meet the Operator Qualification requirements. The contractor shall also assign their personnel to the virtual Job Site set up by USPL in ISNetworld (ISN).

Section 3.2, 3.8 & 6.6

5. Contractor employees performing DOT Covered Tasks shall be in an anti-drug and alcohol testing pool and the contractor company anti-drug & alcohol plan shall meet Department of Transportation (DOT) requirements. This verification is performed by the National Compliance Management Service (NCMS) and reported through ISN.

Section 3.2, 5.1 & 8.3

6. Contractors shall be informed of the electronic site where BP’s HSSE policies and procedures are available, such as ISNetworld’s BP Pipeline bulletin board and USPL’s Contractor Management website).

Section 3.2, 3.8 & 5.1

7. Contractors shall be required to complete and submit a Site-specific Safety, Health and Environmental plan (SSHEP) prior to work, when applicable.

Section 3.2 & 6.5

8. Contractors shall identify sub-contractors they propose to use along with their selection criteria data in their bid or proposal, as appropriate, and in the SSHEP.

Section 3.2 & 6.6

9. Subcontractors shall meet the statistical Contractor Selection Requirements for subcontractors; otherwise approval from the CMON shall be required.Primary contractors shall manage subcontractor employees on the job site.

Section 6.6

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USPL Contractor Management Policy

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Revision Date: April 16, 2018

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3.0 Roles and Responsibilities3.1. Contractor Management Coordinator (CMC)

a) Drive continuous improvement in the performance of USPL contractors by managing, implementing, and improving the contractor management process.

b) Evaluate new contractor information in ISN against the contractor selection requirements (CSR) upon receipt of a new Contractor Approval Request form (CARF).

c) Evaluate currently utilized contractors information in ISN against the CSR on an as needed basis as well as quarterly audits.

d) Identify contractors who fail to meet or maintain the statistical selection requirements as Do Not Use in the electronic Purchase-to-Pay tool.

e) Convene and lead the Contractor Management / Operations Network (CMON). Accountable for ensuring the team has representatives from the following disciplines (at a minimum): procurement, health and safety, operations, projects, construction, and engineering.

f) Document CMON meetings via minutes and the Contractor Variance Review Form, as appropriate. (see Attachment 1)

g) Manage and serve as the point of contact for USPL’s ISN account.

h) Ensure the external contractor management website is current and maintained.

i) Maintain current USPL HSSE policies and procedures both in ISN and the contractor management external website. Communicate revisions to contractors.

j) Develop and maintain training documentation for USPL employees regarding contractor management.

k) Lead the process for revising this policy in accordance with the Management of Change (MOC) procedure and consult with representatives from applicable disciplines to ensure consistency and accuracy. Minor changes to this policy may be made without submitting them for comments.

l) Responsible for Operating Management System Level 5 Conformance for OMS Element 2.5 Working with Contractors, including self-assurance activities outlined in Section 9.0.

m) Responsible for the Performance Improvement Cycle (PIC) for OMS Element 2.5 Working with Contractors.

3.2. Contractor Management/Operations Network (CMON)a) Evaluate and determine actions to be taken regarding contractors who have not met the

CSR with an approved rating in ISN, or who have had an OSHA Recordable or vehicle accident on a USPL job site, or as deemed necessary by the CMON.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

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Revision Number: 3.0

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NOTE: If the actions include requiring a safety representative on site at all times, discontinuing work with the contractor immediately, or allowing the contractor to complete current work but not use in the future, a recommendation shall be made to the USPL governance board for final decision and approval.

b) Seek 100% agreement for decisions.

If full agreement is not reached, a decision will be made by a majority vote of the members (including the Convener).

If 50/50 vote is garnered, the final decision shall be made by the HSSE Manager.

c) The HSSE Manager shall be involved in any decision regarding a contractor with an OSHA recordable incident on a USPL (or any BP) jobsite or with a fatality within their company.

d) Meet on a monthly basis or as deemed necessary by the CMC.

e) Should suggest and review any improvements to the contractor management process.

f) Should not be required to evaluate contractors with insurance issues or who fail to answer the acknowledgement questions in ISN. Those issues should be handled by procurement and the Contractor Management Coordinator, respectively.

3.3. Person Responsible for the Contracted Work (PRCW) a) Identified as the person accountable for the purchase order. Typically, this would be the

Project Manager or Team Leader.

b) Accountable to :

Ensure consultants and contractors receive training on site safety, emergency response, and other orientation as applicable.

Verify contractors involved in marine activities or using marine equipment are approved by the marine authority or their designee.

Verify contractors involved in diving activities are approved by the diving technical authority or their designee

Verify specialized contractors receive the necessary USPL training.

Contact the CMC when exceptions to the CSR are requested.

c) Responsible to :

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Provide the contractor with information for accessing Site Technical Practice / Engineering Technical Practice (STP/ETP), standard procedures and applicable HSE policies.

Prior to procurement of services:

- Verify the contractor, and subcontractors if applicable, meet the CSR or are approved for a variance by the CMON.

- Verify the contractor, and subcontractors if applicable, have Operator Qualified (OQ) employees where necessary.

- Verify the contractor is active and approved for use in the electronic Purchase-to-Pay tool. If not, then initiate the Contractor Approval Request Form process.

NOTE: Approval for the CARF can be a member of the EPIC LT or a District Operations Manager.

Review SSHEPs developed by the contractor.

Verify the contractor is informed of work that involves DOT Covered Tasks requiring Operator Qualified individuals to perform such tasks.

Follow the USPL Sourcing Expectations posted on the Purchase-to-Pay site and involve PSCM as appropriate.

Submit persons to act in the role of specialized contractor to the District Operations Manager for approval. (Example: AOD).

Verify that a documented post-job survey, including contractor performance, is completed and provided to PSCM when required.

3.4. Head of Engineering, Projects, Inspection, and Construction Manager (EPIC)a) Shall provide a member(s) of organization for the CMON.

b) Approve reinstatement of terminated contractors per Section 6.4 for EPIC-related work.

c) Appoint the Inspection Manager as the approving authority for new Contractor Approval Request Forms (CARF).

3.5. Head of Operations and HSSEa) Shall provide a member of organization for the CMON.

b) Approve reinstatement of terminated contractors per Section 6.4 for operations and maintenance-related work.

3.6. HSSE Manager a) Shall have final decision regarding a contractor with an OSHA Recordable incident on a

USPL, or BP, jobsite or a fatality within the contractor company. Last printed 5/19/2023 1:31:12 PM

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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b) Shall be a member of the CMON.

c) Shall provide member(s) of organization for the CMON.

d) Should review Safety Improvement Plans for contractors on a variance.

3.7. District Operations Manager (DOMs) and Control Center Manager(s)a) Shall serve as the operations approving authority for new Contractor Approval Request

forms (CARF).

b) Shall serve as the approving authority for fungible contractors and specialized contractors proposed for use at facilities for which they are responsible.

c) Should maintain a list of fungible contractors verify they meet the CSR.

A list of fungible contractors should be kept in an Excel spreadsheet with the following information: Contractor Name, Service provided by the Contractor, Date(s) Service Provided on Site.

3.8. Procurement and Supply Chain Management Manager (PSCM)

a) Either participate in or provide a team member of the CMON.

b) Shall verify the safety status in ISNetworld of a contractor prior to issuing agreements, contracts, or purchase orders.

c) Shall monitor contractor compliance with Master Services Agreement (MSA) insurance provisions within ISN.

d) Shall determine the most appropriate contracting option between USPL and the contractor, issue new or revised agreements, contracts, and purchase orders according to Delegation of Authority.

e) Shall create and maintain contracts under BP policy.

f) Shall qualify contractors based on the PSCM Supplier Qualification process for material suppliers, if applicable.

g) Monitor strategic suppliers’ performance and take appropriate action if contractor performance requires changes to the contractor’s status.

4.0 Contractor Types4.1. Primary Contractor

a) If primary contractor is doing work which requires an ATW on a USPL job site, they shall register with ISNetworld (ISN) and comply with USPL requirements.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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NOTE: The exception shall be fungible contractors that are locally managed. Those contractors can register and submit their data with ISN but it is not required. However, any primary contractor that is also a fungible contractor not registered in ISN shall need to provide annual evidence of safety performance.

b) Shall answer the following acknowledgement questions in ISN:

They have disseminated USPL HSSE policies and BP’s code of conduct to its employees and any subcontractor it utilizes and documents such distribution.

Their equipment used by themselves and/or its subcontractors (owned, leased or otherwise obtained) is fit for service.

Their employees are competent and that their work shall be carried out in compliance with USPL requirements.

c) Register with NCMS and submit their anti-drug and alcohol plan if performing any Covered Tasks requiring Operator Qualifications or performing work of any kind on a DOT jurisdictional terminal or facility.

d) Provide appropriate qualified employees when performing specific Covered Tasks under U.S. DOT Operator Qualification regulations on BP facilities regulated by the U.S. DOT Parts 192 and 195.

e) Comply with USPL HSSE policies and contract requirements.

f) Follow the requirements in the development and submittal of the SSHEP.

g) Responsible for the subcontractor’s performance, including: Submittal of subcontractor statistical data with their bid/proposal. Providing on-site representation when subcontractor is performing work unless:

- otherwise granted an exception by the CMON- subcontractor is also a primary contractor for USPL and in ISNetworld

h) Shall develop and submit an HSSE Improvement Plan when identified by USPL as a condition of a Variance.

i) Shall provide purchase order notification in electronic Purchase-to-Pay tool.

4.2. Sub-contractorsa) Approved subcontractors safety statistics:

3-year OSHA TRIR <2.0 3-year OSHA DART < 1.0 EMR <1.05 Fatalities = 0 for the prior 3 years

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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NOTE: Some work types will have TRIR levels higher than 2.5. Contractors providing those services (for example traffic control) may be evaluated vs delta from the industry average at the discretion of the CMON.

b) Documentation shall be required for the above statistics. If the subcontractor is a member of ISN, the statistical summary provided in ISN will be sufficient evidence.

c) The CMON shall decide whether a subcontractor who does not meet the statistical selection requirements can be used.

d) In the event a subcontractor has an OSHA recordable or other safety incident on a USPL work site, the following shall be done:

Evaluation completed by CMON with recommendation of actions

Notation regarding incident made in ISN account of primary contractor and subcontractor, if in ISN

e) Any subcontractor who is also a primary subcontractor for USPL shall be required to register with ISN and held to the same CSR as the primary contractor.

f) If the subcontractor is paid by the primary contractor,

Subcontractor shall not be required to register with ISN unless they will be completing DOT covered tasks requiring Operator Qualified personnel.

g) USPL has a contractual right to approve or reject any subcontractors.

h) Contractors with less than 10 employees shall be held to the same criteria as a subcontractor but they shall not be required to have an ISNetworld account. Documentation shall be provided to verify the requirements are met.

4.3. Fungible Contractorsa) Fungible contractors provide general maintenance and services at USPL facilities that

are managed locally (e.g. janitorial services, lawn maintenance and are not required to be registered in ISN.

b) Use the following to assist in the determination of contractor type.

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Fungible Maintenance Operations related Non-OQ tasks No CoW permits Non-process equipment tasks

Non-Fungible Construction Projects related OQ tasks CoW Permits required Process equipment tasks

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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c) The Asset Operator shall provide the appropriate fit-for-purpose site orientation and determine the level of oversight needed based on the level of risk for the work that will be performed. The company name, individual name and date shall be recorded on-site and require an annual renewal of the site orientation.

NOTE: Fungible contractors are not vetted by the CMC and are typically not in ISN.

d) If there is uncertainty in the level of oversight needed, the local safety coordinator and DOM should be consulted and a decision made with the Team Leader and Asset Operator.

5.0 Selection Criteria5.1. Contractor Selection Requirements (CSR)

a) Statistics:

3-year rolling average OSHA Total Recordable Incident Rate (TRIR)

NOTE: If the contractor has less than three years of data, the CMON shall review the contractor for approval.

Current year Experience Modification Rate (EMR)

Fatalities within last three years

Days Away/Restricted or Transfer Rate (DART)

b) Safety Programs

Have safety programs meeting OSHA requirements in accordance with the work types identified in ISNetworld.

Have a driving policy when the contractor will drive on BP business or on BP sites.

NOTE: Mobilization and demobilization work is excluded from the driving safety program requirement.

c) Safety Culture Questionnaire

Answers to selected questions from ISN’s Master Services Questionnaire (MSQ) regarding safety, operations, and audits.

Questions should be chosen by the CMC and HSSE members of the CMON.

d) Showstoppers

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

Page 13

If any of the following requirements are not met, the contractor shall receive a D-grade:

Anti-drug and Alcohol Program:

- If performing DOT covered tasks, National Compliance Management Service (NCMS) shall verify both the contractor anti-drug and alcohol program and quarterly MIS reports as meeting DOT requirements.

- For non-DOT service work, the contractor anti-drug and alcohol program shall provide testing post incident and for cause.

Annual Acknowledgements Questions:

- Disseminated USPL HSSE Policies and BP’s Code of Conduct to its employees, personnel and any subcontractor it utilizes and documents such distribution.

- Equipment used by themselves and/or subcontractors (owned, leased or otherwise obtained) is fit for service.

- Employees are competent and that their work shall be carried out in compliance with USPL requirements.

NOTE: CSR data for the division of the company being used shall be evaluated whenever that specific data is available.

e) Requirements Scoring

The table below illustrates the scoring mechanism for each of the contractor selection requirements.

NOTE: These values are also available in ISNetworld.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Contractor Selection Requirements and Scoring

Category Total Point Allowance

Measure Score

Experience Modification Rate (EMR) 10

<1.05 10

>1.05 0

Fatality 160 16

1+ 0

Days Away/Restricted or Transfer (DART) 8

<0.6 8

>0.61 -1.0 6

>1.0 0

Total Recordable Injury Rate (TRIR) 16

<0.24 16

>0.24 – 1.5 12

1.51-2.0 8

>2.0 0

Safety Programs 25

100 25

90-99.99 20

80-89.99 10

70-79.99 5

0-69.99 0

Safety Culture 25 95-100 25

85-94.99 18

75-84.99 10

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USPL Contractor Management Policy

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Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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0-74.99 0

f) Grade Scoring

The table below indicates the scoring criteria for the final grade in ISNetworld.

NOTE: These values are also available in ISNetworld.

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Ariba Score Grade Details Range

Approved A Approved for use with exceptional safety performance

97 - 100

Approved B Approved for use 85 – 96.99

Do Not Use C Variance required before beginning new work on USPL site.

If currently working on USPL job site, can continue but shall be evaluated for a variance as soon as reasonable.

75 – 84.99

Do Not Use D No new work, or continue current work, on USPL site without variance.

<75

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USPL Contractor Management Policy

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Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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5.2. HSSE Vettinga) The Contractor Management Coordinator shall utilize ISN for review of a contractor

safety performance and the necessary safety programs based on the services they will provide on USPL work locations.

b) USPL requires contractors to update their HSSE statistical data in ISN at least annually and updates are desired at the end of every quarter.

5.3. Sourcinga) Sourcing process shall be governed by the PSCM Common Sourcing Process.

b) Minimum requirements for contractor utilization:

Contractor shall be compliant with CSR.

Contractor shall be qualified in accordance with the PSCM Supplier Qualification Process, if applicable.

Contractor shall be issued a Purchase Order prior to work-except under Emergency Response conditions.

c) Have an environmental program with no environmental violations involving fines for the past two years that are relative to the type of work they are being contracted to perform for USPL.

d) Any single, or sole, sourcing of a contractor shall be documented by the PRCW and approved by the appropriate USPL Manager, Procurement Specialist and the PSCM Director.

e) PSCM Sourcing is performed under the ‘Ways of Working’ lead by site and the respected category teams.

6.0 Contractor Status Types6.1. Approved

a) Contractors identified as an ‘A’ or ‘B’ grade in ISNetworld are considered Approved in the electronic Purchase-to-Pay tool.

6.2. Do Not Use a) Contractors identified as a ‘C’ or ‘D’ grade in ISN are considered Do Not Use in the

electronic Purchase-to-Pay tool.

b) Any contractor who obtains a DNU status during the course of performing work shall be reviewed by CMON for determination of variance status. If a variance is not granted, CMON will make a decision regarding work stoppage.

c) Any new work shall not be awarded to a contractor on DNU without review by CMON.

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6.3. Variance a) A contractor identified as Do Not Use may be granted a variance and used on a USPL

job site for up to one-year from the variance date.

b) Variances shall be reviewed on an annual basis by the CMON for a total of 3 years. CMON will determine if the variance can continue or if another course of action should be taken.

c) Requirements for a variance may include:

Safety Improvement Plan

Safety Professional onsite during work

Job-specific Management Plans (for one-time contractors)

No additional requirement

d) If at the end of a 1-year working probation period, the contractor’s performance deficiency area has not improved, the CMON shall conduct a review to determine whether the contractor is making acceptable progress and should remain on a variance or whether to terminate the contract.

e) If termination is the recommendation, see Section 6.4 Termination & Reinstatement.

f) The Contractor Variance Review Form shall be used to document the variance. (See Attachment 1).

g) A completed Contractor Variance Review Form shall be uploaded to the contractor’s account in ISNetworld by the CMC.

6.4. Termination & Reinstatementa) Termination/Suspension

Decision to terminate and/or suspend contractor from working on USPL job site shall be at the discretion of the USPL Leadership team and/or Procurement manager.

Contractor disconnection in ISN shall be made at time of termination.

b) Reinstatement

Reinstatement of a contractor after termination requires authorization from Leadership team and/or Procurement manager.

The following criteria shall be met before contractor reinstatement:

- A minimum of 12 months has passed since the contract was terminated.

- Meets the CSR.

- Meets any other site-specific prequalification criteria.

- Issues involved in their termination have been appropriately addressed.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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- The contract is modified or re-negotiated, if applicable.

- Demonstrates its employees can meet OQ requirements, if applicable.

7.0 Contractor Onboarding Tool: “Working Safely at USPL”7.1. Roles

a) Asset Operator / Asset Operator Designee (AO/AOD) is responsible to:

Deliver on-site onboarding discussion, using the tool, to contractor employees on the USPL jobsite during the Authorization to Work (ATW) process.

Request materials (tool with and/or tool without notes and stickers) from the contractor management coordinator (CMC).

Identify anyone new to the job site and ask questions regarding safety programs covered in the onboarding tool to validate knowledge and understanding.

7.2. Process

a) CMC shall provide materials. (See Attachment 2 for the tools.)

b) AO/AOD shall use tool during the ATW discussion with the workforce.

c) AO/AOD should distribute “Will you stop the job” sticker to the individual receiving the onboarding.

NOTE: The intent is for the sticker to provide a visual representation that the person received the onboarding message. Not having a sticker on the hardhat, should serve as an indicator to the AO/AOD to ask the person if they have had the conversation and are aware of the tool. If the person doesn’t answer in a way that satisfies the AO/AOD, the onboarding tool shall be discussed immediately.

8.0 Self-Assurance8.1. Desktop data validation audits shall be done on a quarterly basis by the CMC.

8.2. Contractor audits regarding safety policies, training and implementation shall be handled via ISN, specifically the RAVS+ program. The CMC shall monitor the audit findings and address any deficiencies.

8.3. A minimum of four (4) field-based audits shall be done on an annual basis to validate contractor understanding of USPL expectations.

8.4. Follow USPL self-verification methods in order to meet OMS 2.5 Contractor Management Level 5 conformance.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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9.0 References BP Pipelines Contractor Management website http://www.bppipelines.com/

USPL-COW-001-001 Control of Work Policy

USPL-MOC-001-001 Management of Change Policy

ATW Policy

BP Code of Conduct (see PL Legal, Code of Conduct online).

GRP 2.5–0001, BP Group Recommended Practice, Working with Contractors

GRP STD 02 Group Standard, Control of Work

GDP 4/5-0001, BP Group Defined Practice, Control of Work

49 CFR Part 199, Drug and Alcohol Testing

49 CFR Part 195, Subpart G Operator Qualification

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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DefinitionsContractor A company who contracts to perform work in the field involving maintenance,

construction or operations activities. Unless otherwise specified, the term “Contractor” applies to both primary and sub-contractors.

Contractor’s employees

Employees of the contractor and its subcontractors and vendors who perform field work involving maintenance, operations or construction activities.

Contractor Management / Operations Network (CMON)

Cross-discipline group to provide a standardized evaluation methodology for USPL Contractors falling below safety expectations and the contractor selection requirements.

At a minimum, the network shall consist of one representative from each of the following disciplines: procurement, operations, projects, construction, health and safety. The network shall be convened by the Contractor Management Coordinator.

Contractor Selection Requirements (CSR)

A contactor company’s statistical OSHA data, anti-drug and alcohol program as well as safety programs based on services provided are reviewed on a regular basis to determine their grade in ISNetworld as well as their HSSE status in the electronic Purchase to Pay tool.

See Section 5.1 for more details and information.

Specialized contractors are not subject to CSR (Job Inspectors, Construction Managers, and Asset Operator Designees).

Covered Task An activity that (a) is performed on a pipeline or terminal facility subject to DOT jurisdiction and (b) is an Operations or Maintenance task and (c) is required by Part 192 or Part 195 and (d) affects the operation of integrity of the pipeline.

DOT Operator Qualification

An individual who has been evaluated and is able to perform activities identified as Covered Tasks and responds to abnormal operating conditions that may be encountered while performing these activities.

Field work Operations, maintenance, or construction activities performed on BP USPL assets and facilities and at a non BP USPL controlled premise where the work is under the direct control, supervision and contract with USPL as may be the case in third party terminals, refineries, tank farms or green fields.

Fungible

Fungible contractors provide general maintenance and services at USPL facilities that are managed locally (e.g. janitorial services, lawn maintenance and are not required to be registered in ISN.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Contractors

ISNetworld ISN is a web-based contractor database that helps owners and suppliers satisfy governmental and owner-specific recordkeeping and management requirements. ISN is the USPL “office of record” for confirmation of operator-qualified contract personnel.

http://www.isnetworld.com/

Marine Activit The procurement, chartering or contracting, selection, inspection, approval, vessel operation, commercial operation, scheduling, design, construction, commissioning, and / or disposal of marine vessels (but excluding the ‘mission systems’, e.g., diving systems on diving vessels); and the floating structure or marine systems of a floating production and / or storage unit; and the operation of, and equipment associated with, the ship to shore interface of marine terminals including single buoy or single point moorings.

MSA contractor An approved contractor working under a Master Service Agreement.

National Compliance Management System (NCMS)

NCMS reviews alcohol and drug testing programs from contractors performing U.S. DOT Covered Tasks and advises whether the plan and its implementation are in compliance with the DOT PHMSA pipeline safety regulations 49 CFR Part 199 and Part 40.

http://www.nationalcompliance.com/

One-time contractor

Non-MSA contractors which may be used “one-time”, for “one-off”, unique, or specialty services, or commonly used “lower risk” work that does not warrant an MSA. These contractors are governed by Terms & Conditions in the Purchase Order.

Person Responsible for Contracted Work

USPL employees such as, but not limited to, Project Manager, Project Engineer, Team Leader, or Technician who hire contractors to perform field work.

Primary contractor

Company retained to execute a scope of work and direct billed by USPL.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Procurement & Supply Chain Management (PSCM)

The strategic management of the supply base, to include supplier selection, commodity strategies, supplier qualification, and performance management. Additionally, the complete financial process of obtaining goods and services, from preparation and processing of a requisition through to receipt and approval of the invoice for payment.

Program Deficiencies Contractor who meets the statistical and anti-drug and alcohol program selection

requirements but are missing or have deficiencies in the safety programs required for the services they have identified they perform.

Purchase to Pay System

The process, activities, systems, and information flow associated with the purchasing of goods and services from suppliers. The BP Business Service Center owns the requisition and purchase order processes and is responsible for these activities, and manages all payment processes.

Ariba P2P Pro is the current database of contractors used to implement the Purchase to Pay process.

Specialized Contractor

Specific individual(s) from a contracting company who perform work at a site(s). Examples are Job Inspectors, Construction Managers or Asset Operator Designees for control of work support.

Sub-contractor A non-BP entity retained to perform an operations or engineering scope of work under the direction of the primary contractor.

Variance Allows contractors who do not meet CSR to be considered for contract work. Decided by the Contractor Management Operations Network.

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Appendix 1Forms and Templates Contractor HSSE Improvement Plan Template (located on DRM in the folder with the Contractor

Management Policy)

USPL New Contractor Approval Request Form (CARF) and Instructions (located on DRM in the folder with the Contractor Management Policy)

Site Safety, Health and Environmental Plan Procedure, Guide and Template (located on DRM in the folder with the Contractor Management Policy)

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Attachment 1Contractor Variance Review Form

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USPL Contractor Management Policy

Policy No.: USPL-HSSE-F-14-MAN-001

Revision Date: April 16, 2018

Effective Date: July 1, 2018

Revision Number: 3.0

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Attachment 2Contractor Onboarding Tool

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