Contractor Safety A Growing Issue
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James
Roughton
Introduction
- Why do contractors
need to be prequalified?
- New regulations.
- Best management
practices.
- Improved relationships.
Performance-Oriented
Standards
- Designed for
flexibility to protect employees.
- Offers general
guidelines.
- HAZWOPER
- Health &
Safety (H&S) plans must be developed for hazardous waste sites.
Contractor control is required.
- Lockout/Tagout
- When contractors
are utilized, the on-site employer and the outside contractor must
inform each other of their respective lockout or tagout procedures
- Permit-Required
Confined Space
- Contract employees
who perform work in confined spaces.
Maintenance/Repair.
Rescue Service.
- Process Safety
Management
- To ensure
that the actions of contractors do not lead to catastrophic releases,
fire, or explosions.
PreQualification
Safety Evaluation
- Must complete
prequalification safety evaluation.
- Prequalification
based on a numerical experience system:
- Incidence
rates, BLS - SIC codes.
- EMR - Workers
compensation.
- OSHA recordable
cases.
Evaluation of Contractor
Safety
- Effectiveness
of a contractor's safety performance:
- Measurable
results
Recordable
cases (Lost time, Restricted cases, OSHA citations).
EMR.
- Is senior
management committed to safety?
- Is safety
an integral part of project management?
- Are safety
and training improvement programs in place?
Contractor-Management
Responsibilities
- 29 CFR 1926.16(a),
OSHA states, "In no case shall the prime contractor be relieved
of overall responsibility for compliance with the requirements of this
part for all work to be performed under the contract."
- 29 CFR 1926.16(c)
OSHA further states, "With respect to subcontracted work, the prime
contractor and any subcontractor or subcontractors shall be deemed to
have joint responsibility."
- 29 CFR 1926.16(d),
"Where joint responsibility exists both the prime contractor and
his subcontractor or subcontractors, regardless of tier, shall be considered
subject to the enforcement provisions of the Act."
Key Factor - Contractor
Relationship
- Identifying who
supervises contract employees.
- OSHA may treat
contract employees as direct-hire employees if management of
the host employer provides the majority of supervision and the contractor
supervisor only serves as a figure head.
Training
- Contractors have
the responsibility to ensure that all employees are properly trained.
- Safety orientation
should include a review of:
- Physical and
chemicals hazards on site (fire, explosion, and toxic release type
hazards).
- General safety
rules and regulations.
- Emergency
reporting and response procedures.
- Work permit
procedures.
- Other day-to-day
issues.
- Training will
raise the level of safety awareness.
Work Plan
- Essential in reducing
injuries and illnesses and in maintaining a safe work environment.
- Designed to protect
employees, company's facilities, and local community.
- Conduct pre-entry
briefing prior to site entry and at other times, as necessary, to ensure
that employees are aware of site hazards.
- JHA techniques
can be used to develop project-specific specification and procedures
by:
- Reviewing
scope of work.
- Identifying
and evaluating controls for reducing hazards.
- Reviewing
hazards of each task.
- Biological
hazards.
- Fall
hazards.
- Overhead/Underground
Utilities.
- Heavy
equipment.
- Other
hazards.
- Periodic safety
inspections
- Correct known
deficiencies.
- Must be kept
at the work area - Readily available for all personnel.
- Must be documented,
reviewed, and updated as necessary.
Contractor Project
Management
- Must have on-site
project manager (Site-Supervisor).
- Essential
for providing a smooth and efficient operation.
- Must share overall
responsibility and liability.
- Must be a professional:
- Able to interpret
and manage safety programs, solve problems efficiently and expediently.
- Must develop
skills for recognizing and managing legal, financial, and customer relations.
Continual Improvement
- Guidelines must
be created for contractors.
- Company policies
and standards, contractor safety rules and procedures.
- Initial training.
- Must learn from
mistakes or near misses.
- Safety must be
measured and monitored.
Summary
- A good safety
program is a catalysts for reducing accidents.
- Minimal or "paper"
safety programs - Not Acceptable.
- Commitment to
excellence in safety and quality practices.
- Safety first.
- Without safety
- Poor quality.
- Poor quality
- increased production cost - poor employee morale.
This paper appears in the eLCOSH website with the permission of the author
and/or copyright holder and may not be reproduced without their consent.
eLCOSH is an information clearinghouse. eLCOSH and its sponsors are not
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