Contractor Safety Program
Hello!
Safety Newbie here (technically Safety coordinator). I was asked to develop a program for Contractors, to ensure they are following rules. Any advice on where to start? Also , according to 1904.31, contractors are responsible for their own recording, but since we are a company that is under the NAICS code (banking)that doesn't have to report, are we still able to do random audit's without being responsible for recording? Thank you in advance for all your assistance.
Comments (6)
Regarding the contractor safety program, the purpose of that should just be to inform your contractors of your site-specific EHS programs that they must follow. It's not intended to provide them training on the various topics, such as train them on fall protection, but instead, just tell them what your fall protection policies are so they know what to abide by. Typically, you either do a "contractor orientation" or create a packet that outlines that key points of your various EHS policies/procedures, then simply tell them to refer to your safety/EHS manual for more information if required.
If you don't have one already, I'd implement some type of contractor management program that evaluates your contractors' safety records, insurance, written programs, EMR, etc. to ensure they don't pose a risk your company.
As far as the audits, you can do anything you want to them (for the most part) without having to record any of their injuries/illnesses. The only time you'd have to record one of your contractor's injuries/illnesses is if you provide daily supervision over their employees (rather than them being supervised by their own management).
Hi, I teach an OSHA injury and Illness recordkeeping class if you want to dive into those recordkeeping standards more:
https://trianglesafetyllc.com/safetyresources/p/oshainjuryandillnessrecordkeeping-ndfbk
Also, I agree with Drew, though!
I too teach OSHA Recordkeeping like Safety Bran:
https://safetyfitz.com/
or fitz@safetyfitz.com
Contractor Management is one component of MOC (Management of Change). It is a huge job especially if you have over a few contractors. I would copy your Quality Departments Vendor Approval Process! Almost the same as EHS! By the way not the only thing you can copy from Quality! There scarp and rework investigation process works for Accident Investigation too!!! ISO 9000 and 18000 have the same framework, so make the QM (Quality Manager) your best friend!
As an example, how are you going to ensure the contractors have the training they are supposed to have? I can tell you you cannot do it alone! You will need lots of support and all mangers have to be involved!!! You will have more safety training to do. How is your Engineering Manager going to evaluate a new machine if he does not know the guarding it needs? HUGE project. With my new customers we do not hit MOC until the basics are covered well! In my opinion MOC is a high level LEAN safety tool. Do not mean to discourage you but even with software a big job by itself. If you have over 20 contractors a full time job on its own!!!
Back to recordkeeping before you relax on contractors. Their injuries may not go down on you 300 Log but consider:
#1 If a contractor gets hurt on your site, their employer may still have to call OSHA just like you do! Guess who OSHA wants to come see if the accident happened in your plant? Will not be the contractor's office!
#2 You do not have to pay the contractor's Worker Comp bills! Good news right? But if somehow you the conditions at your facility in any way contributed to the injury guess what? ALL insurance companies love to subrogate any claims! What are the first questions asked by your car insurance when you call to report an accident? The contractor's insurance company will then come after you to reclaim their money!
I also work in the financial industry and rely on contractors to perform many activities at our sites across the U.S. Feel free to connect. My email is jaragaki@unum.com.
We have a packet that outlines expectations that contractors must follow. Contractors are responsible for managing their workers - including any sub-contractors they bring on site.
The packet discusses things like horseplay, security requirements, HAZCOM, drug/alcohol/tobacco/e-cigarette prohibitions, JSA/JHA for certain work, hot work permits for certain work, and several other items.
Our packet does manage their training, or tasks to complete their job, but focuses on items that have the potential to affect our employees and property. Here are some examples:
- Closing an egress path for construction will affect our employees. The work will require a review by our company to ensure a plan is in place for our employees.
- Contractors that core/saw into our property has the potential to cut mechanical/electrical/plumbing lines creating business interruptions; therefore, coring and cutting will require a JSA that needs to be reviewed (not approved) by my company.
- If a contractor is tasked with cleaning parts of a building, we will require the SDS so we can create a safety plan for our employees.
- Contractors are required to follow specific security requirements so that our employees remain safe in our buildings.
- We do have drug/alcohol/tobacco/e-cigarette prohibitions. These prohibitions keep our employees and property safe.
- If a contractor is performing hot work (e.g. welding), then a JSA must be submitted AND a hot work permit must be completed. Fires have the potential to injure our employees and/or property.