Should proposed variances be included in the submitted worker safety and health program?
Response: Variances in the appropriate format and containing the required information may be submitted at anytime. Question: Does each subcontractor require a written program? Does the Field Element review and approve the written program? There are many subcontractors who come on site with just a few workers for short durations of time. Response: A contractor is defined as any entity, including affiliated entities such as a parent corporation, under contract with DOE, or a subcontractor at any tier, that has responsibilities for performing work at a DOE site in furtherance of a DOE mission. The scope of the rule includes the conduct of contractor activities at DOE sites. As such, all subcontractors are required to have a written program, however, the scope of the subcontractors worker safety and health program should be tailored to the hazard and complexity of their work. There are numerous approaches to meeting the requirement that subcontractors are covered by a written WSHP. Some ex
