At BP Pipelines (North America) our goals are simply stated - no accidents, no harm to people, and no damage to the environment. Our construction, maintenance and support contractors are an integral part of fulfilling our service commitment to our shippers. We strive to make sure all our contractors conduct their business for us in an efficient, productive manner that meets the goals outlined above. This page provides links to resources and information to further these goals, and will be expanded and revised on an ongoing basis in an effort to make more useful information available to our contractors. This applies to contractors performing work in the field including field maintenance, operations and construction, when performed on BP USPL assets and facilities. In addition any field maintenance, operations and construction occurring at a non BP USPL controlled premise but the work is under the direct control and supervision and contract with USPL as may be the case in third party terminals, refineries, tank farms or green fields. Excluded from the full scope of this policy are contractors with little or no field exposure such as:
- consultants who perform their services in an office,
- contractors who do not go to the field to manage work activities,
- contractors providing minor facility services (e.g., repairing a clogged sink, painting an office),
- administrative office support personnel, and
- carriers who are managed by the Transport Operations teams.
Contractors working for BP Pipelines (North America) shall:
- Register with ISN and submit required company data, safety information, programs, and policies at the end of every quarter.
- 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.
- 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.
- Comply with USPL HSSE policies and contract requirements. These policies are found on the BP USPL Bulletin Board within ISNetworld.
- For each contracted project (as directed by BP) we require contractors to submit a SSHEP that has been reviewed and agreed to by BP Pipelines’ Project Manager or authorized Job Representative.
- Manage sub-contractors in accordance with USPL requirements. Verify that proposed sub-contractors meet CSR and provide documentation as evidence.
- Develop and submit an HSSE Improvement Plan when identified by the PUL or PE&TS Manager as a condition of Working Probation.
- Provide purchase order notification in electronic Purchase to Pay tool.
- The primary contractor shall notify the Person Responsible for the Contracted Work anytime during the project that a subcontractor is to be retained for work. The subcontractor will not be allowed to work until authorization is provided by the Person Responsible for the Contracted Work.
Sub-contractors shall be subjected to the statistical Contractor Selection Requirements; average 3 year OSHA TRIR, current year EMR and fatalities. USPL has a contractual right to approve all subcontractors. Primary contractors shall hold their sub-contractors to USPL statistical Contractor Selection Requirements and provide documentation as evidence of their performance. Before work is awarded to the primary contractor, the subcontractor statistical selection requirements documentation shall be submitted to the PRCW for review, verification, or PUL/ PE&TS Manager approval if required. The PRCW and the appropriate Performance Unit HSSE are responsible for ensuring the contractor uses safe, qualified subcontractors. The PUL or PE&TS Manager shall be the decision authority as to whether a subcontractor who does not meet the statistical selection requirements can be used. The subcontractor performance documentation shall be included in the SSHEP. The primary contractor shall notify the PRCW anytime during the project that a subcontractor is to be retained for work. The subcontractor shall not be allowed to work until authorization is provided by the PRCW. The contractor shall require the following from sub-contractors: - Documentation as evidence of their statistical selection requirements, OSHA logs for the last 3 years, and a letter from the workers’ compensation carrier including the current year insurance modification rate. If the subcontractor is a member of ISN, the statistical summary report will be sufficient as evidence. - Subcontractors shall submit their own SSHEP to be reviewed and approved by the primary contractor or provide their statistical information to the primary contractor to be included in their SSHEP submittal. Any sub-contractor who is paid directly by BP shall be required to register with ISN. However, if the subcontractor is paid by the primary contractor, they do not need to register with ISN unless they will be providing Operator Qualified personnel to completed DOT Covered Tasks.