Naylor Love’s Minimum HSE Requirements set out the standards that we expect all subcontractors and suppliers on our sites to comply with. Documentation or instructions prepared for specific projects may set higher standards, which take precedence over this document.
1.1 Naylor Love’s Minimum HSE Requirements
Compliance with Naylor Love’s HSE (health, safety and environmental) systems and procedures is mandatory for all personnel, including contractors, working on any Naylor Love site. Your Company must ensure that work instructions and HSE-related plans comply as a minimum with these Minimum HSE Requirements. It is important to be aware that other documentation or instructions prepared for specific projects may set higher standards, which take precedence over this document.
1.2 HSE Commitment, Policy and Expectations
One of Naylor Love’s values is Consideration to its contractors and employees, which extends to property and the environment. Naylor Love expects the same dedication from Your Company. Naylor Love relies upon Your Company to adopt, implement and enforce rules and practices necessary for the safe and environmentally responsible performance of Your Company’s work. This document sets out the minimum health, safety and environmental requirements that must be met by Your Company. Additional requirements include:
a. Your Company acknowledges Naylor Love’s strong commitment to Health, Safety and Environmental matters
b. Your Company is required to either hold a current health and safety prequalification that is acceptable to Naylor Love or to have obtained an exemption from Naylor Love
c. Your Company shall meet with Naylor Love as soon as practicable after the contract award to review your Site Specific Safety Plan (SSSP)
d. Your Company is responsible for verifying and determining what safety and health hazards and environmental concerns it may be subjected to in the performance of the work
e. Your Company shall provide a copy of its health, safety and environmental policies and procedures to Naylor Love upon request
2. Legal Requirements and Regulations for HSE
Your Company shall comply with all applicable health, environment and safety laws and regulations applicable to the work being carried out, and any additional guidelines, operating standards and policies provided to Your Company by Naylor Love.
3. Breach of HSE Requirements
3.1 HSE Breaches and Unsafe Acts
In the event of an unsafe condition or behaviour being identified, Naylor Love management will stop the work activity immediately and raise a hazard or near miss report. Work will not re-commence until all corrective actions have been implemented. In the event of a serious breach, a Yellow or Red Card may be issued, and the individual concerned may be subject to a just cause drug/alcohol test.
Infringements could include:
- Refusal to comply with Health and Safety directives
- Refusal to wear required personal protective equipment
- Being on site while under the influence of drugs or alcohol
- Working contrary to an agreed Task Analysis or SSSP
- Failure to complete planning or reporting paperwork
An infringement results in a Yellow Card infringement notice, which will require the infringing person or persons to leave site for the rest of the day or shift. In the event of a serious incident or breach, a Red Card will be issued immediately. If the recipient of a Yellow Card continues to infringe, a Red Card will be issued.
Yellow Card: The morning or shift following the incident resulting in the issue of the Yellow Card, the recipient of the Yellow Card and their manager are required to meet with Naylor Love Site Management to discuss events leading up to the issue of the Yellow Card. Corrective action must be taken.
Red Card: The recipient is dismissed from site and may only return when the Naylor Love General Manager – Health & Safety or the Regional Director is satisfied that they no longer pose a danger to themselves or others on a Naylor Love site.
3.2 Behaviour on Site
Naylor Love aims to maintain a work environment which is safe, performance focused, respectful, based on trust and honesty and is enjoyable for all. Naylor Love has a Code of Conduct that sets out our expectations of how our staff should behave at work, and we also expect contractors working on our sites to maintain high standards of behaviour. Unacceptable on a Naylor Love site includes but is not limited to:
- Theft from site or your workmates
- Harassment or intimidation (including of a sexual nature)
- Refusal or continued failure to observe health and safety rules, and misuse of safety equipment
- Assault against another person at work, including horseplay
- Consuming alcohol on site
- Wilful damage to property
We expect everyone on site to:
- Participate in the Naylor Love HSE programme in a positive and co-operative way
- Act constructively in an emergency
- Support their workmates in their efforts to work safely, including speaking up if someone is doing something silly or dangerous
- Take the initiative in eliminating hazards and by maintaining good housekeeping standards
- Look after themselves through good manual handling techniques
- Stay away from work if under the influence of any drugs or alcohol and be aware of the impacts of prescription medication and fatigue
- Respect their workmates
Conduct that does not meet our standards of behaviour will be handled with the Red Card/Yellow Card programme at Naylor Love Site Management’s discretion.
4. Your Company’s HSE Subcontractor Management
Your Company has the responsibility to verify that all their subcontractors are properly managed to perform the work as contracted. Your Company shall have in place appropriate formal systems, procedures and safe practices for the control of subcontractors working under their control and supervision.
5. HSE Organisation and Responsibility
5.1 Personnel Competency and Responsibility for HSE
Prior to the commencement of the work, Your Company shall provide documentation to the satisfaction of Naylor Love. This documentation shall identify that Your Company’s personnel and that any subcontractors are competent and have the appropriate qualifications, job skills and training as required by the Contract Documents and approved regulations.
Your Company represents and warrants that its Line Management are responsible and have been advised in writing that they are responsible, for ensuring that the work is performed in accordance with all applicable health, environment and safety regulatory requirements, best working practices, and any additional guidelines and/or operating standards provided to Your Company by Naylor Love.
Your Company shall at Naylor Love’s request, provide Naylor Love with organisation charts, specifying any dedicated HSE resources and the areas of HSE responsibility of Line Management.
6. Risk Management
6.1 Hazard and Risk Assessment
Prior to the commencement of the work, Your Company shall demonstrate to the satisfaction of Naylor Love that Your Company has performed a detailed HSE hazard and risk assessment of the contracted work to be undertaken. Specific requirements include:
a. Your Company shall maintain and keep updated a detailed Risk Register that is relevant to the contracted work scope. The risk register shall identify risks, preventative controls & mitigation controls.
6.2 Task Analysis
Effective application of the Task Analysis (TA) process at all Naylor Love operational locations is a requirement. Your Company shall conduct high-quality TAs for all tasks that are non-routine or where there is a risk to personnel, damage to property or the environment.
There is a clear requirement and expectation that Your Company’s supervisors or leading hands will actively involve relevant work crews in the development and review of TAs. This practice will help to build a clearer understanding of task specific hazards and controls.
7. Site Specific Safety Plans
All subcontractors must submit a Site Specific Safety Plan (SSSP) for the project.
A Site Safe SSSP template can be downloaded for free from www.sitesafe.org.nz or can be ordered from Site Safe. Additionally, Site Safe run training courses in completing these plans, also known as the Advanced Passport or Silver Card.
Where Naylor Love site representatives are required to provide continuous assistance in completing these plans and related documents, a contra charge may be issued to the subcontractor.
Where there is a requirement for statutory certification of a safety system or of a key person in the team, then copies of these certificates must be attached to the plan.
Your SSSP must be complete with the following information:
- Significant Hazard identification and Hazard Control Plan, including risk assessments where common controls are not in place
- Task Analysis of any activities requested by Naylor Love
- Hazardous Substances Register including Safety Data Sheets
- Training and Competency Register for all workers
- Emergency Procedures and Contingency Plan (or confirmation that Your Company intends to comply with the site plan)
Toolbox Talks/Site Inspections must be completed and submitted weekly. Templates are available within the SSSP.
Should your trade work involve site erection or assembly of components, the following documentation is to be supplied at least 10 days before on-site work is programmed to commence:
- A method statement showing clearly the sequence of work and the method of maintaining structural integrity at each stage.
- An Engineer’s certificate relating to the adequacy of any temporary bracing, propping systems and fixings used to maintain structural integrity. The certificate should state the temporary loadings which have been provided for alongside the permanent loadings derived for the completed structure under the relevant New Zealand design standards.
Should your work involve Particular Hazardous Works (notifiable work), you are responsible for reporting these to WorkSafe New Zealand within the timeframes they specify and supplying a copy of the notification to Naylor Love Site Management.
7.1 Competency Register
When you commence on a project for Naylor Love, completion of the competency register included in the Site Specific Safety Plan is compulsory. This register will list each individual’s name and their role, qualifications, the qualification number where appropriate, the expiry date and/or the years of experience in any given aspect of your trade. This information will assist Naylor Love to ensure that tasks are only undertaken by people with the appropriate qualification or sufficient experience.
7.2 Critical Risk Activities & Permits
Naylor Love has classified certain tasks as Critical Risk and as such have a mandatory checklist or permit requirement. These are:
- Asbestos Removal
- Hot Works
- Crane Lifts
- Confined space entry
- Dig (Ground penetration)
- Temporary Works
- Working in a harness (other than when using a MEWP)
The Permit or Critical Checklist will be completed by Naylor Love Site Management to confirm that the TA has been reviewed and contains the essential elements for the task to proceed safely.
The supervisor of the works must hold a minimum of a Site Safe Supervisor Gold Card or a ConstructSafe Tier 3 Card and is required to be on site at all times while workers under their supervision complete Critical Risk work. All personnel involved in the work are required to participate in a daily pre-start meeting, and this meeting must be documented. Records of pre-start meetings need to be made available to Naylor Love Site Management on request.
Any change in the work activity agreed with Naylor Love will require adjustment to the TA and Essential Checklist/Permit.
8. HSE Communication & Consultation
8.1 Site Safety Meetings
Meetings are held on a regular basis to review health and safety processes and results on site Each meeting will last from half an hour to one hour. Subcontractors who are active on site are expected to be involved by providing representation.
8.2 Safety Tool Box Meetings
Your Company is required to plan and conduct weekly toolbox meetings with their employees and subcontractors to:
a. Ensure that their workforce is informed of and aligned with Naylor Love’s HSE goals and requirements
b. Ensure personnel are informed of hazards and required safe work practices and regulations associated with their work
c. Communicate about past incidents and lessons learned and to share relevant HSE information
d. Provide an opportunity for personnel to raise HSE issues and concerns, and to provide a feedback forum
Your Company shall also provide Naylor Love with minutes of these meetings for their records.
8.3 Pre-Start Meetings
Where required, Your Company is required hold pre-start meetings and take minutes.
8.4 Site Inspections
Site inspections are to be completed by Your Company and submitted to Naylor Love.
9. Hazard and Incident Notification, Investigation and Reporting
Incident reporting must be actively promoted and encouraged at all Naylor Love controlled work locations and a “No Blame” policy will be in place. All hazards and incidents (including hazard incidents) must be reported in accordance with relevant Naylor Love procedures. Specific requirements include:
a. Your Company shall use its best efforts at all times to control or overcome the cause or minimise the effect of any hazardous condition.
b. Your Company shall comply with all applicable statutory requirements for hazard and incident reporting, as well as Naylor Love’s Accident, Near Miss and Hazard Reporting procedures.
c. It is Your Company’s responsibility to provide rehabilitation for your injured workers. Naylor Love requires Your Company to offer your workers alternative duties where reasonable after an incident to avoid a Lost Time Injury.
d. Any hazard or incident involving Naylor Love’s, the Your Company’s or any third party’s personnel, property, plant or equipment on a Naylor Love site shall be reported immediately to Naylor Love, irrespective of whether injury to personnel, damage to property or equipment or environmental damage has resulted.
e. All unplanned or unauthorised spills or releases are to be reported regardless of volume.
10. HSE Audits and Inspections
Naylor Love shall have the right to conduct audits/inspections of the Your Company’s operations, equipment and emergency procedures at any time without giving prior notice. Your Company shall fully cooperate with Naylor Love during such audits/inspections. This requirement shall not relieve Your Company of its own obligations to conduct audits and reviews of its own HSE performance or expose Naylor Love to any liabilities which may arise from the Your Company’s failure to satisfy its HSE obligations.
Your Company shall have an appropriate formalised process and program for undertaking its own formal and informal routine inspections, audits and reviews. Specific requirements include:
a. Planned inspections / audits of all facilities and work sites according to published schedule.
b. Records of such inspections, audits and reviews shall be maintained. Corrective actions shall be identified, implemented and tracked to completion.
11. HSE Systems and Procedures
11.1 Your Company’s HSE Manual
If requested, Your Company shall provide a copy of its HSE manual, policies and procedures to Naylor Love for review and possible incorporation into the contract. All of Your Company’s personnel shall, where required, comply with all relevant procedures set out in Naylor Love’s Safety Management Plan for the site.
11.2 Permit to Work
Your Company shall at all times comply with the site Permit to Work system. Any conflicts with the site Permit to Work system shall be addressed and resolved prior to commencing the work.
12. Safe Work Requirements
12.1 Plant & Equipment
All machinery and plant used on site shall be maintained in a safe working order at all times. This means that plant and machinery must comply with all known current legislative requirements and regulations. Any equipment that is deemed not fit for purpose will be removed from site immediately.
Specialised equipment is to be checked and certified as safe for use prior to commencing work. This includes but is not limited to:
- All electrical equipment, including leads, must be tested and date tagged by a competent person. Tagging is required to be three-monthly.
- All lifting equipment (by a qualified person)
- All scaffolding above five metres (by a qualified and registered scaffolder), as per current WorkSafe New Zealand Good Practice Guidelines
- Mobile plant and equipment
- Passenger/material hoist
- Mechanical Elevated Work Platforms (MEWP) including scissor lifts, cherry picker, and any telescopic boom devices. Refer to WorkSafe’s Best Practice Guidelines for Mobile Elevated Work Platforms.
Subcontractors are required to provide evidence of certification for items on the above list.
In the event of plant/equipment/machinery breakdown or the discovery of a fault, all equipment will be removed from service and repaired by a competent person or replaced.
Subcontractors are responsible for their own plant, equipment, and material security at all times.
12.2 Working at Height
Scaffolds will only be erected by competent persons.
Working in Harnesses
- Wearing harness: minimum Unit Standard 23229 Use a safety harness for personal fall prevention when working at height (except in MEWP)
- Setting up and supervising (must be on site at all times): Unit Standard 15757 Use, install and disestablish temporary proprietary height safety systems when working at height
- Only workers who can demonstrate competence are allowed to operate MEWPs
- Daily pre-checks will be undertaken and logged by the operator
- MEWPs will have current certification (six-monthly)
Ladders should be used primarily as a means of access or egress from a work area or, in the case of A-frame ladders, for short term work only. Access equipment that provides more effective fall protection should always be used unless not reasonably practicable. This means the use of stair towers, mobile platform, podium towers or platform ladders. When planning to use ladders, workers are to ensure that:
- Three points of contact can be maintained
- The ladder is in good condition
- No two or three step ladders
- The rating is industrial or trade
- A-frame ladders are of fixed stay type. This means that the stay automatically locks when the ladder is prepared for use. The ladder also cannot be folded out.
- Climbing ladders are tied and footed and project at least a metre above the step-off point and are used at a 1:4 angle
- Fall prevention measures will be put in place if there is a risk of fall when working close to the structure’s edge
- Keep to walkways and within guard rail systems and bump rails where they are installed
- Utilise fall arrest equipment only as a last option
12.3 Electrical Safety
All electrical work will be carried out by registered electricians in accordance with relevant standards, regulations and codes of practice.
All electrical wiring is to be treated as live until confirmed as otherwise. Work on live circuits and equipment is not to take place unless allowed under contractual arrangements.
All electrical equipment and leads must comply with NZS3012 and must be tested and tagged every three months. All electrical equipment and leads must be checked daily prior to use. If defective, it must be immediately withdrawn from service and repaired or scrapped.
- Electrical extension cords connected to power tools require the use of a Residual Current Device (RCD)
- If the RCD trips, it is a sign of a fault and a check on the system is to be carried out by a competent person before using it again
- An RCD is a valuable safety device and is never to be bypassed. A RCD is not a “cure-all” for poor work practices.
- Workers should know how to test any portable RCD they are about to use and tests should be carried out before using the equipment. If they are not working properly, withdraw from use immediately.
12.4 Crane Operations
- Operators must have the unit Standard as a minimum for the type of crane they are operating
- Dogmen: US 3789
When using all grinders, the following must be in place:
- Full face shield (high impact rated) mandatory, with glasses underneath recommended
- Deadman device
- Adjustable guard
- Side handle
A reviewed Task Analysis must be in place when using a 9-inch angle grinder.
12.6 Powder-Actuated Tools
Only piston operated powder-actuated tools (PATs) are permitted on Naylor Love sites.
12.7 Hazardous Substances
Any company introducing a hazardous substance to a site must provide an inventory which includes:
- The substance’s name & UN number (where available)
- The maximum amount likely to be on the work site
- Where it will be stored
- Any specific storage, segregation or handling requirements (PPE requirements etc.)
A Safety Data Sheet shall be provided to Naylor Love by the subcontractor prior to being on site with the potentially hazardous material / product. These will be held in Naylor Love’s SDS file on site.
12.8 HSE Related Rules and Restrictions
All of Your Company’s employees and contractors are required to go through a site-specific induction by a Naylor Love staff member.
No one is permitted to work on site until they have been inducted. Failure to comply with this requirement will result in a breach and may result in a yellow/red card being issued.
Personal Protective Equipment
Personal Protective Equipment (PPE) provides an important last line of defence to control or minimise the potential for injury or illness associated with a task. The appropriate PPE for the task is identified by a risk assessment and is defined within the applicable Task Analysis or by the minimum site standard, as displayed on the site hazard board.
PPE shall be worn at all times with due regard to the type of work being undertaken and any adjacent activities. Minimum PPE standards on the project will be:
- Current issue hard hats
- Approved safety footwear
- High visibility upper torso clothing
- Safety eye wear to be worn at all times
- Suitable gloves are to be available at all times for use
Specific to the environment and/or task, PPE providing a higher standard of protection and additional PPE may be required, such as: dust mask, respirator, hearing protection, harnesses, face shields and sun protection.
Where a subcontractor employee arrives on site without the required and mandatory PPE, this will be provided by Naylor Love upon request at a cost specified by the Quantity Surveyor.
Site Safe Passports/ConstructSafe Cards
All site personnel must have a current Site Safe or Construct Safe qualification to work on this site.
We will only accept proof of course bookings when existing cards have expired, or where there is a current recognised overseas equivalent such as an Australian white card. This is to ensure we do not employ workers who are new to construction, as is often the case with young trainees and labourers.
The use of radios on site, which includes the use of personal devices such as MP3/smart phone/iPod and radio headset/ear muffs, is not permitted.
At the Site Manager’s discretion, a single radio may be permitted in site lunch rooms at a volume that does not cause a nuisance.
The use of mobile phones on site is allowed, providing this does not distract the user, who should not be performing other tasks at the same time. Texting or emailing while driving is strictly prohibited.
12.9 Unsafe Operations and the Right to Stop Unsafe Work
If Your Company believes that the operations cannot be safely undertaken or that continuance of operations may result in any hazardous conditions, it shall immediately notify Naylor Love. Your Company shall use its best efforts at all times to control or overcome the cause or minimise the effect of any hazardous condition.
Your Company and Your Company’s personnel shall understand that they have the right to stop work when they consider it unsafe to continue. All employees and contractors have the right to refuse to do unsafe work. This right must be communicated and understood by all personnel working on the project.
In the event of either scenario (i.e. stopping a job or refusing to do a task based on a safety concern), the most senior Naylor Love HSE representative at that location must be notified immediately.
13.1 Drugs and Alcohol
Naylor Love has a drug and alcohol programme that includes post incident, reasonable cause and random testing. In an effort to make our sites safer for everyone who works on them, testing has been extended to cover all personnel on the site at any time.
Your Company must therefore have employment and/or contractual arrangements in place to ensure all employees and/or contractors are aware of their obligation to take a post incident, reasonable cause or random drug and alcohol test if requested.
If Your Company’s staff are asked to take a test, they will be asked for signed consent.
Either failure to consent to a test or a positive test result will result in them being removed from all Naylor Love sites.
We do however encourage return to work and will offer this once the requirements of our Drug & Alcohol procedures are fulfilled.
13.2 Dust Control
All operations that create dust must have adequate controls in place to protect the working environment and to protect workers.
- Vacuums and attachments for cutting fibre cement
- Wet cut or vacuum extraction for concrete cutting and grinding
- Effective dust control on all other tools
Your Company shall ensure that its personnel and subcontractor’s personnel shall maintain high standards of hygiene in connection with the performance of the work and, where required, to carry out training to raise awareness of hygiene standards.
Smoking is not allowed in any building or in any operational areas of a site. Many sites are now completely smoke free and others will have a designated smoking area which may not be close to the workplace. The logistics of this need to be considered when you are allocating project staff.
14.1 Spill Contingency Plan
Subcontractors, Suppliers, and Vendors must have a plan in place in the event of a spill and all personnel must be fully aware of this plan.
A Naylor Love representative must approve spill contingency plans before hazardous material is brought onto the site. This must include all applicable Safety Data Sheets (SDS).
In the event of a spill occurring, the Subcontractors, Suppliers, or Vendors are required to:
- Follow the spill response plan immediately to contain the spill and prevent release to any waterways
- Report the incident to the Naylor Love supervisor immediately and follow the incident reporting procedure applicable
- Clean up the spilled material and arrange for its disposal at their cost