Recently the Protecting America’s Workers Act was introduced
in the US Congress to implement significant changes to the 1970 Occupational
Safety and Health Act that developed the US Occupational Safety and Health
Administration (OSHA). Among the most significant changes are changes to what
is known as the General Duty Clause, which currently requires that employers
provide a safe workplace to their employees. The proposed changes would require
employers to not only protect their employees but all other employees in the
workplace. This means that OSHA would evaluate not only your internal safety
programs, but also how your safety programs protect visitors and contractors. This
new requirement would be consistent with many of the recognized safety
management system standards, such as ANSI Z10-2012 and OHSAS 18001:2007, which
require contractor safety programs.
Making employers at least partly responsible for the safety
of visitors and contractors at their site is one of those “easier said than
done” things. After all, we don’t have nearly the control over contractors that
we have with our own employees. So how can we control their safety programs?
Well, using a 4 Step Model to contractor safety management
(seen below), you can comply with any forth-coming regulations and help take
your overall safety management system to the next level.
Step 1 – Pre-Job Planning. As Steven Covey said, begin with
the end in mind. If you want your project to end safely, create solid safety
specifications for any contractor that walks into the door, rather than leaving
it to chance. Every job should begin with a thorough risk assessment where the
applicable hazards and risks are identified, analyzed, and prioritized. Then
specifications to get risks reduced to acceptable levels can be implemented.
By doing this you can influence the design of project to
ensure that safety is considered at all phases. You can also implement controls
into the design that assist in implementing other safety controls, such as
ensuring adequate anchor points exist in those areas where employees may need
to use fall protection. More mature organizations can even identify the highest
risk jobs and create specifications for ensuring that the crews working those
jobs are selected for having low-risk safety behaviors.
In the early phases there may not be enough information to
identify all hazards and risks, which is why the risk assessment process should
continue throughout the project. But the earlier we can start identifying and
reducing risks the easier they are to deal with.
Step 2 – Prequalification. This is arguably the most
important part of contractor management. If you may be held responsible for
contractor safety performance, wouldn’t it make sense to look at the safety
performance of the contractor BEFORE they get in the door? This can be
accomplished through looking for a combination of lagging indicators (e.g.
incidents rates, EMRs, etc.) and leading indicators (looking at the management
systems that are in place, the contractor’s internal training programs, whether
or not the contractor uses safety as a criteria for selection and development
of employees, etc.). What you look at should be based on the risks of the job,
with the higher risk jobs requiring more indicators to show positive safety
performance. But if you’re not screening contractors based on safety
performance you shouldn’t be surprised when you have to deal with a contractor
that doesn’t have a mature safety management system.
Step 3 – Orientation. Once you’ve identified the job
specifications and you’ve found your contractor with a mature management
system, then next step is to ensure that the contractor is aware of the
requirements to do the job safely. There should be separate sessions for both
contractor employees and contractor supervisors, since supervisors are vital to
the success of the project.
One of the biggest mistakes many organizations make in the
orientation process though (outside of not having an orientation) is to turn
the orientation into a negative experience. Make the orientation only as long
as it needs to be and do not talk down to the contractors. Instead, remember
that you brought these contractors onsite at least partially because they have
a good safety program. Acknowledging that and getting their input as part of
the process can go a long way to building trust and cooperation, which is vital
to building a strong safety culture.
Step 4 – Feedback. The first three steps built the
foundation for a safe project, now we need to follow through with feedback
about the process. Remember, although they are professionals, the contractors
are visitors to your site and may not be aware of your specific policies,
procedures, hazards, etc. So providing timely feedback, particularly in the
early stages of the contractor’s safety performance is crucial.
Feedback should come in two ways – to supervisors and to
employees. To supervisors a regular meeting to look at leading and lagging
indicators for the project and make appropriate adjustments. After the job,
provide feedback to the contractors and to your overall prequalification system
for consideration of future jobs. For employees, providing positive
reinforcement for those contractor employees who are following your job
specifications (Step 1) goes a long way to getting the results you want and
creating a culture of trust rather than of punishment and fear.
Certainly, each of these steps require careful consideration
on how they can best be implemented in your organization. One of the best ways
to learn about innovative solutions is through networking with other
professionals about what works and what doesn’t. Share your comments and
questions about contractor management in the comments section below to continue
the discussion!
Safety requires information to be shared among all the employees about workplace rules. Most of people don't care what about safety, they just want to earn cash by spending time operating machines. That is when accidents happen.
ReplyDeleteRegards,
Arnold Brame
Health And Safety Consultant Norfolk
Good point Arnold. A key point though is that everyone cares about safety. Very few people want to die or be injured. The problem comes though in two areas: First, people don't always associate the task they are doing with risk. There are lots of reasons for this, but they separate the actions of "safety" from the actions of "operating machines." When they don't see those things as tied together they easily disregard "safety" to get their jobs done. But, importantly, this is not because they don't care about their own safety. Rather, they don't believe that what they are doing will get them hurt or killed.
ReplyDeleteSecond, and this is very important for us in the safety world, people don't care as much about our version of safety. Safety professionals often have a version of safety that is separated from how people actually work. We look at regulations, rules, management systems, etc. When the average worker sees this they scratch their heads and move on because they don't see how it helps them get their jobs done.
But that doesn't mean they don't care about safety, it just means we haven't done a good job of relating why the things we're talking about are worth listening to and how they help their employees do their jobs. As Todd Conklin says, "people are as safe as they need to be, without being overly safe, in order to get their job done." So if we can translate our rules and regulations and management systems and everything else in a way that is meaningful to the average employee, we'll go a long way in creating safety in the organization.