The University of Wolverhampton is committed to the protecting the health, safety and welfare of all in its community, including students, staff, contractors, partners and visitors. This Policy focuses on the critical need to protect the integrity of our Estate, its infrastructure, fabric and services.

In order to achieve this we have to ensure that any work procured and/or managed by the University that impacts on its infrastructure, crucially the penetration of any passive fire materials or fire compartments is prohibited without the express approval of the Estates and Facilities Directorate. The supporting Procedure sets out the agreed approach as to how we manage Contractors safely.

1.1 The purpose of this policy is to:

This policy and supporting procedures/documents set out the agreed approach to ensuring the integrity of the University’s infrastructure, physical assets and services by the Estates and Facilities Directorate. This will be achieved by adhering to the following:

• Perform appropriate checks of each of its contractors prior to the letting of any contract (or establishment of any framework agreement) to ensure, so far as is reasonably practicable, that it only engages suitably competent contractors to carry out works on its behalf.
• Provide contractors with the necessary information, induction training, supervision and instruction to undertake their work in accordance with this and all other relevant health and safety policies and any specific legislative requirements that might apply.
• Provide contractors with suitable and sufficient asbestos information, at tender stage, to enable them to plan and deliver their works without risk of exposure to or the uncontrolled release of, asbestos fibres.
• Only allow contractors to commence work once they have provided and where necessary implemented, suitable and sufficient risk assessments to manage any significant risks associated with their works. In the case of notifiable projects, construction works will only be allowed to commence when the Principal Contractor has provided a suitable and sufficient Construction Phase plan and has put in place adequate welfare arrangements.
• Notify the Health and Safety Executive (HSE) of all relevant University construction projects as soon as is reasonably practicable. The University may instruct the Principal Contractor or another agent to notify the HSE on their behalf.
• Ensure that construction works and projects are planned so that there is adequate time to deliver these safely.
• Oversee and monitor all contractor works under the direct control of the University. Oversight will be carried out by a suitably competent person (or persons) appointed by the University.
• Develop and implement suitable and sufficient risk-based procedures to gain effective control, coordination, cooperation and communication of all contractor works.
• Establish and implement “Permit to Work” arrangements for the management of specified high risk works. This will include providing sufficient resources such that Permits to Work are only issued by suitably competent and appropriately authorised persons.
• Require that all contractor works which involve, to any extent, works on building fabric or services or infrastructure are approved, in writing, by the Director of Estates and Facilities (or their appointed agent). No such works will be allowed to commence until this approval has been provided. This will include the installation of any services not controlled by Estates and Facilities, such as data cabling, where this requires works on building fabric or services.
• Monitor contractor performance at appropriate intervals and taking appropriate corrective action where health and safety issues are identified.
• Implement arrangements to ensure that contractors provide any necessary information, documentation or certificates in order to ensure that the University can meet its general and specific health and safety responsibilities.
• Review overall contractor performance at the end of each contract and implementing, where practicable, any significant findings.
• Provide managers with guidance to assist them. 

This policy and procedure will apply to all members of staff working for the University in particular:

• All members of staff who procure and/or manage Contractors whose work involves penetration or alteration/addition to the building infrastructure, fabric or services.

2.1 Definitions

Contractor means any individual, company or organisation, other than an employee, engaged by the University to carry out any work for gain or reward. People carrying out work for an organisation on a voluntary basis are considered to be employees for the purposes of health and safety law, Sub-contractors are individuals, companies or organisations employed to undertake works, for gain or reward, by the contractor.

All Contractors: are both contractors and sub-contractors.

Competent Person: individuals who have the relevant skills, knowledge (qualifications) and experience to carry out specified tasks. For complex or large projects, the competency requirement may be met by a team rather than by an individual. However, clear accountabilities should be established within the team to ensure that duties are assigned to the appropriately competent team member.

Construction Work: is legally defined within the Construction Design & Management (CDM) Regulations as “the carrying out of any building, civil engineering or engineering construction work” and includes:

• The construction, alteration, conversion, fitting out, commissioning, renovation, repair, upkeep, redecoration or other maintenance (including cleaning which involves the use of water or an abrasive at high pressure, or the use of corrosive or toxic substances), de-commissioning, demolition or dismantling of a structure
• The preparation for an intended structure, including site clearance, exploration, investigation (but not site survey) and excavation (but not pre-construction archaeological investigations), and the clearance or preparation of the site or structure for use or occupation at its conclusion
• The assembly on site of prefabricated elements to form a structure or the disassembly on site of the prefabricated elements which, immediately before such disassembly, formed a structure
• The removal of a structure, or of any product or waste resulting from demolition or dismantling of a structure, or from disassembly of prefabricated elements which immediately before such disassembly formed such a structure
• The installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services which are normally fixed within or to a structure 

Notifiable projects: CDM requires that certain projects be notified to the Health and Safety Executive. These include projects that will last more than 30 days where there will be 20 or more workers on site at any time during the project and any projects involving more than 500 person working days.

Principal Contractor: a specific duty holder required, under CDM, to be appointed on all notifiable projects. They plan, manage and monitor the construction phase so that it can be performed safely. The University will never act as the Principal Contractor on such projects. Whilst the University has some duties with regards to how notifiable projects are planned and delivered, these do not extend to approving method statements and risk assessments or directly supervising works unless these are carried out outside of areas specifically handed over to the Principal Contractor. In these instances, the University must check and approve Risk Assessments and Method Statements before any works are carried out. The University will also be responsible for monitoring how the work is undertaken to satisfy themselves that appropriate safety procedures are being followed.

3.1 The Vice-Chancellor (VC) has the overall day to day responsibility for health and safety matters at the University. The VC delegates responsibility for undertaking aspects of these duties through line management and identified roles. This policy is specifically aimed at ensuring the integrity of the Universities infrastructure, physical assets and services.

3.2 Director of Estates and Facilities has delegated responsibility for approving and overseeing all works on University building fabric and services. The Director of Estates and Facilities delegates the day to day management of these duties through the Estates and Facilities line management chain.

The Director of Estates and Facilities will ensure that:

• All applications to carry out work on University owned or managed building fabric or services or infrastructure are considered in a timely manner by a suitably competent person
• All duty holder appointments required by the CDM Regulations are made for relevant approved projects (including any approved projects that will be locally managed (i.e. outside of the Estates and Facilities function) and that the appointed duty holders are competent to fulfil their appointed role
• All projects subject to Estates and Facilities’ approval are managed by a suitably competent person
• Adequate resources, including reasonable access to competent project managers, are available to enable the University to manage construction works in accordance with legislative and policy requirements
• Faculties, Schools and Directorates are provided with adequate information about routine works that Estates and Facilities’ contractors will be carrying out in their areas. This will include giving sufficient advanced notice of when, where and how such works will be carried out and ensuring adequate communications with local management about matters which could affect the health, safety or welfare of members of the campus community whilst the works are delivered. In the event of an emergency situation, where there is a significant risk of imminent injury or of significant damage to property, the requirement to provide notice to local management may need to be waived in order to ensure that the University does not breach its duty to manage such significant risks
• Where there is sufficient reason to believe that any duties associated with notifiable projects cannot be met then the project work should be halted and the VC advised

3.3 Deans, Heads of Directorate & Directors are responsible for ensuring that: People who may be commissioning and/or managing contractors for works controlled by the School, Faculty or Directorate are competent to do so.

Where the required competency to manage specific contractors or projects is not available within the School, Faculty or Directorate then a suitably competent person is engaged to manage these works on their behalf. 

Sufficient competent people have been appointed, where relevant, to implement and manage School, Faculty or Directorate permit to work systems.

Suitable and sufficient information about local hazards (other than those related to building fabric and services) are communicated to contractors working in their areas.

Their staff cooperate with other duty holders under this policy to ensure that the Management of Contractors policy is implemented effectively.

All proposed works to building fabric or services or infrastructure are communicated, at the earliest opportunity, to the Director of Estates and Facilities (or the appointed deputy) for approval and in any case before any such works are commenced.

Procurement or design for works on University owned or managed building fabric or services or infrastructure is not started unless and until approval for these works has been provided in writing to them by the Director of Estates and Facilities (or appointed deputy). If Estates and Facilities are subsequently appointed to manage the project on behalf of the School, Faculty Directorate or Department then all subsequent contractor management responsibilities under this policy will transfer to Estates and Facilities. If the Director of Estates and Facilities agrees that the works can be managed locally then all duties, except those explicitly placed on the Director of Estates and Facilities, will fall to the School, Faculty, Directorate or Department engaging and managing the contractor(s).

Process

Before any work or Contractor is procured the Faculty/Directorate/Department must, after going through the University approval process, seek permission from Estates and Facilities via a submission through HRAMs. This enables the process to be documented, given a Works Order Number, be monitored and reported upon.

Dependent upon the size of the project, it will be categorised as Minor Works or a Capital Project and further, more detailed documents/investigations will be instigated.

Links to these can be found in the Appendices.

A Process Map is included below in 4.1. 

Minor Works Process Map  

4.2 Commissioning and/or Managing Contractors for the University

University employees (or consultants or other persons appointed by the University to undertake this role) commissioning or managing contractors for, or on behalf of, the University will be responsible for ensuring that the contractors under their control:

• Provide the University with any required information before they are permitted to commence work. Where the work will be carried out in University controlled areas and poses significant risks to any person or to University property or to the Campus environment then this will include the provision of written Risk Assessments and Method Statements to clearly describe how the work will be carried out. Such works will not be allowed to commence until these have been agreed by Estates and Facilities
• Contractors will have the necessary competence to undertake the work they are employed to carry out and to deliver that work to the required quality/safety standards. Are provided with suitable and sufficient information, including information on any hazards or significant risks that may be present in the areas that they will be working, and instruction to safely carry out the works expected of them
• Receive a suitable and sufficient induction appropriate to the work that they will be doing and that a record of this induction is kept. Where works involve works on building fabric and services then Estates and Facilities will provide this induction. For all other works, for example servicing of Directorate-owned equipment, this responsibility will fall to whoever commissions the contractor to undertake this work
• Are monitored at appropriate intervals depending on the risks associated with their works
• Are aware of and, as far as is reasonably practicable, comply with the University’s Management of Contractors policy and any associated procedures

Where a project involves the contractor working in areas that are controlled by others, then the University representative responsible for managing the contractor will be responsible for ensuring that:

• Local management are given timely notice about what contractor works will be carried out, and where and when these will be undertaken
• Works are coordinated and organised with local management so as to ensure that the risks to contractors and to other members of the campus community are reduced to a tolerable level

4.3 Construction Works / Works on Building Fabric or Services or Infrastructure in University Controlled Areas

If the proposed works will involve construction works or other works on building fabric, services or infrastructure, including passive fire materials, the commissioner will, in addition to the responsibilities in 4.2, be responsible for ensuring that:

• The works are communicated as soon as is practicable to the Director of Estates and Facilities (or their appointed deputy) but in any case prior to any works being carried out
• Works on building fabric or services or infrastructure are not started unless and until these have been approved in writing by, or on behalf of, the Director of Estates and Facilities, or their appointed officer

1. Appointed contractors:

- Are allocated sufficient time in order to deliver their works safely

- Are provided with suitable and sufficient asbestos information to reduce the risk of exposure to, or uncontrolled release of, asbestos fibres

- That the relevant Permits to Work are in place and displayed

- That job specific Method Statements and Risk Assessments are approved

- Are easily identifiable by other members of the campus community 

• Works are communicated and coordinated to ensure that significant risks associated with those works are reduced to a tolerable level

4.4 Maintaining Building Integrity Policy

A detailed policy outlining the considerations and controls to be taken prior to any work that breaches the building fabric across the University Estate is included in the Appendices. This policy does not only impact on what are regarded as significant changes to the environment, it also includes small changes, those that are potentially perceived as insignificant actions, examples:

• Coat hooks discreetly screwed into walls/doors
• Wall hangings 

4.5 Notifiable Projects

Where the construction works are “notifiable” projects under the CDM Regulations then the project will be managed in its entirety by the Estates and Facilities Directorate.

4.6 Permit to Work

When work is deemed high risk it will be subject to a Permit to Work issued by Estates and Facilities. Such activities are, but not limited to, the list below. The Permit to Work Issue Procedure and Permit are included in the Appendices.

• Hot Work e.g. welding, hot roofing works
• Work involving Passive Fire Materials 
• Confined Spaces e.g. work in a boiler, roof space
• Natural Gas – breaking into gas lines in boiler room
• Working at Height e.g. roof access maintenance without edge protection
• Bio Hazard maintenance activities
• Excavations creating a confined space
• Local exhaust ventilation
• Pressure systems

4.7 Safe Working Practices for Contractors

Estates and Facilities have produced guidelines or a “Rule Book” for issue to Contractors when on site. A copy of which is included in the Appendices.

4.8 Induction

All Contractors will be subject to Site Induction. A copy of the PowerPoint presentation is included in the Appendices.

Amendment This Policy was approved by the University’s Executive Board on 21 February 2022. The University may change this Policy at any time, and where appropriate. Where a policy is not due for review, but is found to require updating, it will remain published, unless the reasons for review render it obsolete. 

Appendix 1: Maintaining Building Integrity Policy

Appendix 2: Project Initiation Document 

Appendix 3: Permit to Work Procedure

Appendix 4: Safe Working Practices for Contractors

Appendix 5: Induction

Estates Health, Safety Compliance and Risk Manager – Samantha Bevington
University of Wolverhampton, Wulfruna Street, Wolverhampton WV1 1LY

S.Bevington@wlv.ac.uk 

Fire Manager – Sean Tomkins University of Wolverhampton, Wulfruna Street, Wolverhampton WV1 1LY S.Tomkins@wlv.ac.uk