The Site Safety and Health Officer (SSHO) has several key responsibilities related to the safety and occupational health (SOH) program at a project site. These duties include developing, implementing, and managing the contractor’s SOH program. The SSHO is also responsible for conducting inspections, and developing Activity Hazard Analyses (AHAs).
A crucial aspect of their role is to ensure that all project personnel comply with safety requirements, including subcontractors and visitors.
SSHO Specific Duties
- Reporting to the corporate safety official, senior Project Manager (PM), or corporate official.
- Maintaining applicable safety reference material at the site, such as this manual, Safety Data Sheets (SDSs), and the Accident Prevention Plan (APP).
- Conducting daily SOH inspections and maintaining a SOH deficiency tracking system.
- Reporting and investigating all accidents and near misses and completing the required accident report form (ENG Form 3394).
- Attending all pre-construction conferences, tail-gate meetings, and pre-work meetings, including preparatory and periodic in-progress meetings.
- Conducting ongoing evaluations of the APP to ensure it remains current and site-specific, and submitting changes for approval by the prime contractor.
- Providing and keeping records of site safety orientation and indoctrination training for all project personnel.
- Reviewing and signing the Site Safety and Health Officer Designation Letter (ENG Form 6282).
- Ensuring visitors are escorted, properly protected with Personal Protective Equipment (PPE), and receive a safety brief.
- Developing AHAs for all activities and coordinating their review and understanding with all affected employees and applicable agencies.
- Developing and signing the site-specific APP and coordinating its review and understanding.
- In coordination with the prime contractor, being ultimately responsible for SOH program management, communication, and implementation at the worksite.
- Ensuring that all materials, documentation, and drawings comply with applicable contract SOH requirements.
- Ensuring the APP is developed by a Competent Person (CP) and reviewed for compliance.
- Maintaining and updating the APP and AHAs.
- Ensuring work does not begin before government review and acceptance of required safety submittals.
- Erecting and maintaining a SOH bulletin board.
- Immediately notifying the Contracting Officer (KO) or Contracting Officer Representative (COR) of any Occupational Safety and Health Administration (OSHA) or other regulatory agency inspection.
- Reporting all recordable accidents to the KO or COR and fully cooperating with accident investigations.
- Conducting and documenting safety meetings.
- Ensuring all employees receive required SOH training before starting work.
- Ensuring all contractor employees comply with contract, manual, and regulations.
- Ensuring no person works in unsafe conditions.
- For environmental cleanup and investigation projects, the SSHO has additional responsibilities such as being present during active operations, inspecting site activities for SOH deficiencies, coordinating changes to the Site Safety and Health Plan (SSHP), conducting exposure monitoring, conducting project-specific training, participating in SSHP preparation, ensuring site-specific emergency procedures are developed and rehearsed, and bringing unforeseen hazards to the attention of the Safety and Health Manager (SHM) and the KO or COR.
Training Requirements for SSHO’s
The training requirements for an SSHO vary depending on the level. The EM385 engineers manual outlines requirements for Level 1, Level 2, and Level 3 SSHOs.
Level 1 SSHO:
- Must receive OSHA 30-hour general industry or construction safety training. This training can be web-based if permitted by OSHA.
- Alternatively, SOH training covering the subjects of the OSHA 30-hour course and this manual may be accepted by the KO in coordination with the local SOHO. The local SOHO will evaluate the proposed equivalent training.
- Must have maintained competency by taking 24 hours of documented formal classroom or online SOH-related training within the past five years.
- Must maintain competency by taking 24 hours every three-year period for the duration of the contract. This 24-hour requirement is separate from the initial OSHA 30-hour training.
- Hours spent instructing SOH-related training can be considered for the 24-hour competency training, but each course can only be counted once.
- For environmental cleanup and investigation projects, the SSHO must meet the initial, refresher, and supervisor training requirements according to paragraph 36-3.a.
Level 2 SSHO:
- Must receive OSHA 30-hour construction or general industry safety training. Web-based training is acceptable if permitted by OSHA.
- Equivalent SOH training covering the OSHA 30-hour subjects and this manual may be accepted by the KO in coordination with the local SOHO, who will evaluate its applicability.
- Must have maintained competency by taking 24 hours of documented formal classroom or online SOH-related training within the past five years.
- Must maintain competency by taking 24 hours every three-year period during the contract. This is separate from the initial OSHA 30-hour training.
- Similar to Level 1, instructing SOH training can count towards the 24-hour competency requirement, with each course counted only once.
- For environmental cleanup and investigation projects, the SSHO must meet the initial, refresher, and supervisor training requirements according to paragraph 36-3.a.
Level 3 SSHO:
- Must be a designated Qualified Person (QP) or Competent Person (CP) according to manual paragraph 2-2.
Must have experience which enables identification of hazards and implementation of controls for the work being performed.
General Training Requirements for SSHOs in Environmental Cleanup:
- Must meet the initial training requirements for general site workers or other site workers as per 29 CFR 1910.120(e)/ 29 CFR 1926.65(e), which includes a minimum number of off-site instruction hours and supervised field experience. This relates to OSHA HAZWOPER (Handling Hazardous Substances)
- Must receive supervisor training, which may include additional specialised training on the employer’s SOH program, PPE program, spill containment, record keeping, and health hazard monitoring.
- Must attend an annual 8-hour refresher training meeting the requirements of 29 CFR 1910.120(e)(8) or 29 CFR 1926.65(e)(8). This relates to OSHA HAZWOPER (Handling Hazardous Substances)
- Must receive site-specific training covering the SSHP and its application to their activities, as well as other relevant SOH standards and site-specific hazards.
The KO, in coordination with the local SOHO, may adjust the training requirements for all levels of SSHOs.
Other Requirements of an SSHO
In addition to their duties and training, SSHOs must meet certain experience and other criteria:
Experience Requirements:
- Level 1 SSHO: Must have at least five years of cumulative safety experience within the last ten years, managing or implementing a SOH program on projects similar in industry type, size, and complexity to the contract work. This requirement may be reduced to three years if the SSHO holds a safety-related degree or a relevant third-party, nationally accredited certification requiring a minimum of three years of experience.
- Level 2 SSHO: Must have at least three years of cumulative safety experience within the last 10 years, managing or implementing a SOH program on projects similar in industry type, size, and complexity. This requirement may be reduced to two years if the SSHO has a safety-related degree or a relevant third-party, nationally accredited certification requiring a minimum of two years of experience.
- Level 3 SSHO: Must have experience that enables the identification of hazards and the implementation of controls for the work being performed.
For SSHOs on hazardous waste investigation and cleanup projects, the experience required by chapter 2 must include at least one year of experience with implementing SOH requirements on such projects. The SSHO must also have the training and experience to conduct exposure monitoring, sampling, and selecting/adjusting controls.
Other Requirements:
- SSHOs must be present at the site of work and located to have full mobility and reasonable access to all major work operations during their shift.
- They must be designated by the contractor Corporate Safety Official on a mandatory ENG Form 6282 (Site Safety and Health Officer Designation Letter).
- For environmental cleanup and investigation projects, the SSHO must be able to conduct exposure monitoring and sampling and adjust protective equipment with the concurrence of the SHM.
It’s important to note that the KO, in coordination with the local SOHO, has the authority to adjust both the training and experience requirements for SSHOs.
