When considering the biggest drivers of organizational safety and compliance, it’s not often that contractors enter the discussion. As a result, organizations may be overlooking an area of significant risk and opportunity.
Pat Cunningham, Director of Safety & Auditing Services at BROWZ, addresses the following questions:
-Why are businesses relying on contractors more than ever before?
-What does OSHA expect when it comes to contractors?
-What types of data should you be collecting about your contractors?
-What are elements of a good screening program?
-Who else from your organization needs to be involved?
-What are the different ways you can approach prequalification?
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Mitigate Hidden Business Risk: Improving Safety by Pre-screening and Qualifying Contractors
1. MITIGATE HIDDEN BUSINESS RISK
IMPROVING SAFETY BY PRE-SCREENING AND
QUALIFYING CONTRACTORS
PAT CUNNINGHAM
Director, Safety & Audit Services
WEBINAR SEP 18, 2013
2. The Safety Guy
‖ Who is Pat Cunningham?
Masters, Occupational Health & Safety Management
Delegate to National Safety Council
Career safety professional
Not “the sales guy”
Loves sharing best practices
Wants to give you useful information that benefits your
business and improves workplace safety for everyone.
WATCH FOR THESE - Signals a “Gold Nugget” of particularly useful information.
Pat Cunningham, MS
Director, Safety & Auditing Services
3. What we will cover
‖ Let’s answer these questions:
Why are businesses relying on contractors more than ever before?
What does OSHA expect when it comes to contractors?
What types of data should you be collecting about your contractors?
What are elements of a good screening program?
Who else from your organization needs to be involved?
What are the different ways you can approach prequalification?
4. Why so many contractors?
‖ Key drivers that
increase usage of
contractors…
IF YOUR BUSINESS USES CONTRACTORS…
You should be considering them in all your risk
management programs and processes.
Lean-hiring practices
Reduced benefits cost
Possible tax incentives
Access to expertise that’s
not available in-house
Flexible employment &
staffing models
5. Mitigate hidden business risk
Prevent fatalities, reduce the number
of injuries & other unwanted
outcomes
Measure all contractors against
company-defined “acceptable risk”
standards
Avoid time lost due to incident
investigation
Avoid cost overrides
Decrease the amount of possible
citations, violations, and penalties
Decrease legal exposure
Why prequalify?
6. Improve safety and quality efforts
Fewer people going home injured
Influx of qualified workers
Improve project execution and
operations
Support quality management and
Continuous Process Improvement
(CPI)
Maximize production time
Demonstrate corporate social
responsibility
Protect corporate brand
Why prequalify?
7. ‖ Contractors that are prequalified
consistently outperform their peers
on key safety performance indicators.
Better Safety Outcomes!
8. What does OSHA expect?
Date: 7/9/13
From: Pat Cunningham., Director of Safety & Auditing Services,
BROWZ, LLC
To: Dorothy Dougherty, Directorate of Standards & Guidance
US Department of Labor – OSHA
Greetings,
I am looking for a ‘guideline’ document from OSHA which outlines its pre-qualification
expectations/desires of business owners when hiring contractors.
I did a search of the OSHA web site, and cannot find a single source document that
provides business owners recommendations, or criteria for screening contractors.
There is related verbiage regarding owner/contractor pre-qualification embedded in the
following
General Industry Standards: 119, .120, .146, .252, .272 & .1200
There may be other standard references I have missed, but I believe this illustrates how
embedded the content is for anyone who desires guidance from OSHA on this topic.
9. ‖ OSHA Standards
1. Process Safety
2. Hazardous communications
3. Permit-required Confined Spaces
4. Control of Hazardous Energy,
LOTO
5. Welding, Cutting, Brazing
(fire prevention)
6. Special Industries – Grain
handling
7. Hazard communication
OSHA Standards & Implications
10. OSHA Standard #1
‖ Process Safety, 1910.119(h):
“When selecting a contractor, shall obtain and
evaluate information regarding the contact employer’s
safety performance and programs.”
Periodic evaluation of contractor performance
Inform contractor: fire, explosion, toxic release
potentials, EAP
Maintain contract employee injury/illness log
Contractors assure that each employee is trained to
perform their work safely
11. OSHA Standard #2
‖ Hazardous Materials, 1910.120 (b)(1)(iv):
Contractors and sub-contractors: retained for work in
hazardous waste operations, shall inform them of
potential fire, explosion, H&S and emergency
response. The written program shall be made available
to contractors and subs.
12. OSHA Standard #3
‖ Permit-Required Confined Spaces, 1910.146 (c)(8):
• When a “Host employer” arranges to have employees of another
employer “contractor” perform CSE work:
- Inform the contractor that the workplace contains
permit-required spaces
- Apprise the contractor of the elements of the hazards and
the experience within the space
- Ensure necessary precautions
- Coordinate entry operations when both are in space
- At the conclusion of entry work – contractor debriefing
(hazards confronted or created)
13. OSHA Standard #4
‖ Control of Hazardous Energy, LOTO,
1910.147 (f) (2) (i):
• Outside personnel (contractors):
• Whenever outside service personnel are to be engaged
in activities covered by the standard, the on-site
employer and outside employer shall inform each other
of their respective LOTO procedures
• The on-site employer shall ensure that his/her
employees understand and comply with the restrictions
and prohibitions of the outside employer’s LOTO
program
14. OSHA Standard #5
‖ Welding, Cutting, Brazing [fire prevention &
protection], 1910.252 (a) (2) (xiii) (D):
• Advise all contractors about flammable materials or
hazardous conditions of which they may not be aware
15. OSHA Standard #6
‖ Special Industries - Grain Handling,
1910.272 (i):
• The employer shall inform contractors performing work at the
grain handling facility of known fire and explosion hazards
related to the contractor’s work and work area. The employer
shall also inform contractors of the applicable safety rules of
the facility
• The employer shall explain the applicable provisions of the
emergency action plan to contractors
16. OSHA Standard #7
‖ Hazard Communication, 1910.1200 (e) (2):
• Multi-employer workplaces: Employers who produce,
use or store hazardous chemicals at a workplace in
such a way that the employees of other employers
may be exposed (contractors) shall ensure that the
hazard communication program includes:
- Method used to provide the other employers on-site access
to Safety Data Sheets
- Precautionary measures needed to protect workers during
normal conditions and emergencies
- Labeling system used in the workplace
17. Business Implication #1
‖ Multi-Employer Citation Policy, CPL 2-0.124:
• On multi-employer worksites (all industry sectors), more
than one employer may be citable for a hazardous
condition that violates an OSHA standard (types of
employers):
- Creating – created the unsafe condition
- Exposing – their employee’s were exposed
- Correcting – responsible for installation/maintenance
- Controlling – worksite supervisory authority
18. Business Implication #2
‖ Voluntary Protection Program, CSP 03-01-003
H&S pre-qualification screening
Provided “equally effective protection” and abide by
rules of host
Orientation, EAP, and knowledge of VPP site
Hazard ID and correction
Provision for removing contractor or its employees for
violating work rules
Contractor participation and worker interviews
conducted by OSHA
Annual site review
Combined workforce injury/Illness rates VPP, a great
benchmark
19. What are the elements of a good screening program?
Protocols &
Metrics
Gather
VerifyAssess
Track/Share
20. What types of data should you collect?
‖ What’s Important?
Benchmark with industry peers and others
Conduct an internal assessment to determine what’s needed:
Existing company policies and procedures for contractor pre-qualification
Organization’s willingness for change
Metrics/KPI’s
Organization Objectives
Company/community image
Current risk exposure/liabilities
Annual assessment & report
Metrics
21. Injury/illness logs (annual updates)
Experience Modification Rate
OSHA Establishment search
Policies/procedures – related to site work
NAICS/BLS industry comparisons
Employee training programs and records
Observation program
Labor/management safety committee
(employee involvement)
Supervisor training
Sub-contractor pre-qualification
HS&E Data Collection
22. Professional memberships – Safety Council,
VPPPA, etc.
Spill control/counter measure plans,
equipment and training
Human performance tools: self checking,
stop work authority, co-worker coaching,
verbal communication and shift turn-over
Injury/incident and near-miss reporting
Hazard awareness/injury prevention tools:
JSA, Tailgate, etc.
Dedicated site safety professional and/or
competent person with duties for site
inspections
Requirement for crew safety meetings and
safety stand-downs (if necessary)
HS&E Data Collection
23. Endorsements
Coverage limits
Workers Compensation
Bankruptcy
Liens
Judgments
Ongoing monitoring of policy
changes and expiration dates
Insurance & Risk
24. Corporate citizenship
Special licenses or certification
requirements
Security and clearances
Drug and alcohol screening
Weapons ban
Sexual harassment
Equal Opportunity Employment
Proprietary non-disclosure
policies
Organizational Specific Data
25. Who needs to be involved?
Stakeholder: Area of concern / involvement:
Supply Chain / Procurement Will you be circumventing my current processes?
Project Manager Can I hire contractors I want? Is this going to slow things
down?
Safety Department What if contractors aren’t safe? How will I know when
they are on-site?
Legal What if processes are not documented correctly? Are we
increasing our liability exposure?
Current Contractors What are the expectations? Are there equal safety
expectations for similar contractors? Why do I have to
submit so much information?
Government / OSHA Was the event preventable? Were contractors involved?
Were the contractors pre-screened?
Consider perspectives of other stakeholders
27. Prequalification Option #2
‖ Perform the function in-house (prerequisites):
Established policy, procedure, tools & training
Sufficient number of staff, agreement on departmental
duties - responsibilities & authority
Robust repository for storing & updating documentation
Agreed upon protocols & metrics
Ability to apply special provisions
Auditing function (internal & contractors)
28. Prequalification #3
‖ Partner with a prequalification service provider (prerequisites):
Established policy, procedure, tools & training
Do your homework – know what you want to accomplish:
- Relief of administrative burden
- Repository - information verification & updating
- Configurable system to meet your protocols
- Customer support – single point of contact for clients & contractors
- Straight forward pricing
- Ability to benchmark ‘best practices’ & desire for continuous process improvement
29. Ready to get started?
‖ Where is your organization today?
Contractor Safety Risk Assessment
- Prequalification Program Elements
- Score indicator (gap analysis)
- Will be emailed to you
Take risk assessment
30. Closing “Nuggets”
‖ Summary:
Contractor companies are utilized by most companies, the added risk exposure should be
assessed and there are benefits to managing the risk
While there is no single source document from OSHA regarding their expectations for
contractor pre-qualification, there are requirements embedded into various standards
There is a wealth of information that can be collected from contractors – client specific
Many stakeholders – whose perspectives all need to be incorporated into the decision
making process
Two options for managing contractor pre-qualification: in-house, or use of a service provider
31. Closing comments
Become to others, “The ____ Guy or Gal“
Respect for all workers & create win-win
situations
Leave a positive legacy
32. Contact Info
‖ Pat Cunningham, MS
Director, Safety & Auditing Services
pat.cunningham@browz.com
www.browz.com